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PHMSA ut-2017-gas-program-evaluation
2017 UT NG Program Evaluation - ut-2017-gas-program-evaluation (Utah; Natural Gas State Program Evaluation)
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UT NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for Utah Division of Public Utilities 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: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 1#
UT NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Utah Rating: Agency Status: Date of Visit: 07/09/2018 - 07/13/2018 Agency Representative: Al Zadeh, Pipeline Safety Manager Connie Hendricks, Administrative Assistant Jimmy Betham, Pipeline Safety Engineer PHMSA Representative: David Appelbaum Leonard Steiner Commission Chairman to whom follow up letter is to be sent: Name/Title: Chris Parker, Director, Division of Public Utilities Agency: Utah Department of Commerce Address: 160 East 300 South, 4th Floor City/State/Zip: Salt Lake City, Utah 84114-6751 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 2017 (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. Field Inspection (PART G): 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 G, the PHMSA representative should include a written summary which thoroughly documents the inspection. 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 45 45 D Compliance Activities 15 14 E Incident Investigations 11 11 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 114 113 State Rating................................................................................................................................................... 99.1 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 2#
UT NG Program Evaluation, 2017, 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: Information was entered correctly. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information was entered correctly. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information was entered correctly. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State reported four incidents, all but one were later determined not to be "incidents." Recommended that State not enter non- incidents/accidents in attachment 4. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State only had 18 compliance actions in CY2017, but attachment 5 reflects 67. State was accidently including the total number of probable violations for compliance actions. State needs to ensure accuracy of entries, but since program evaluations missed this in previous years, no point deduction in this year's evaluation. Further guidance was provided to the State. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, information was available on spreadsheets, office files and data bases. 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 Reviewed information on each inspector and compared completion courses to TQ records. Accurate as reported. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported. 1 1 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 3#
UT NG Program Evaluation, 2017, page 49 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: Adequate 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 4#
UT NG Program Evaluation, 2017, 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. Utah Pipeline Safety (UTPS) Policy and Procedures Manual, Sections IV through VII contains pre-inspection, inspection and post inspection procedures. This information is listed on pages 8-31. Last year's inspection recommended that the procedures for notification to the operator (Section VI, A.) should be expanded to include the date and the name of the inspector conducting the inspection. At the time of review, UTPS appears to not have made any modification to the procedures that address this recommendation. Program Manager did not fully understand last year's recommendation but has committed to incorporate recommendation in the 2018 procedure updates. There is no deficiency in performance of tasks, only in the language contained within the procedure. Program Manager acknowledged that a one point deduction would occur in next year's evaluation if modifications are not made. 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. UTPS Policy and Procedures Manual, Sections IV through VII contains pre-inspection, inspection and post inspection procedures. This information is listed on pages 8-31. Three and five year inspection cycles are illustrated in Appendix C. 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: 1 1 Yes. UTPS Policy and Procedures Manual, Sections IV through VII contains pre-inspection, inspection and post inspection procedures. This information is listed on pages 8-31. Three and five year inspection cycles are illustrated in Appendix C. 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: UTPS Policy and Procedures Manual does not specifically address Damage Prevention (DP). Procedures only address DP as it relates to construction activities (Sections V(B)2.d, V(I) and V(J). The references to DP that are provided do not give guidance on performing these inspections (methods or frequency) and do not indicate which forms would/should be used. UTPS happens to cover damage prevention questions as "additional questions" in the IA program. Recommend UTPS amend their procedures to define processes for conducting these inspections. 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. UTPS Policy and Procedures Manual, Sections V(S) contains guidance on operator training. This information is listed on page 26. Recommend UTPS amend procedures to more accurately document what forms to use, frequencies, etc. DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 5#
UT NG Program Evaluation, 2017, page 66 Construction 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. UTPS Policy and Procedures Manual, Section V(J) contains guidance on construction inspection procedures. This information is listed on pages 18-20. Three and five year inspection cycles are illustrated in Appendix C. 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 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: Verify letter b. 8 General Comments: Info Only = No Points Evaluator Notes: content. Info Only Info Only UTPS should consider conducting a complete review of their procedures and remove any superfluous and unnecessary Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 6#
UT NG Program Evaluation, 2017, 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): 232.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.08 = 458.33 Ratio: A / B 232.00 / 458.33 = 0.51 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ration = 0.51 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: Inspectors have completed requisite training to conduct inspections. 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: Program Manager has completed all required courses at TQ and qualified to conduct gas safety inspections. He is in the 23rd year as the agency's program manager. 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: Yes, Chairman Parker's response letter to Zach Barrett was received on October 13, 2017 and within the sixty-day time requirement. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, last conducted in CY2016. Next one targeted for CY2019. 1 1 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 Evaluator Notes: DUNS: 143528862 2017 Gas State Program Evaluation 5 5 Utah Utah Division of Public Utilities, Page: 7#
UT NG Program Evaluation, 2017, page 8As a matter of practice, UTPS historically has inspected all types of operators on an annual basis except for master meter operators. During 2017, due to employee turnover, which created the inability to inspect all types of operators, UTPS opted to use its risk ranking of operator type (Appendix B) to eliminate the least-risk-ranked operator type (Gathering). This allowed UTPS the ability to perform inspections on higher risk operators. UTPS followed their procedure described in Section IV (B) found on Page 8. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Utah uses PHMSA inspection forms and has recently started using IA. 2 2 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: No known cast iron in Utah. 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: No known cast iron in Utah. 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 Evaluator Notes: Yes, this is covered on their inspection forms in IA. 1 1 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: Yes, Utah inspects the responses required for failures. 1 1 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: UTPS requires all operators to submit their annual report to their agency. After submission is completed a review of the reports are performed by the Program Manager. If inconsistencies are found the operator is notified. The annual reports are also checked for accuracy during all gas safety inspections. DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 8#
UT NG Program Evaluation, 2017, 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 1 1 Evaluator Notes: Yes, has question on inspection form, and reviews the report in PDM of Annual Report miles vs. NPMS miles. The City of Blanding had 34.1 miles of intrastate transmission listed in NPMS. They have since converted these assets to high pressure distribution. UTPS needs to have Blanding remove assets from NPMS. 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, UTPS did not complete any D&A inspections in CY2017, but are compliant with their three and five year cycle requirements. UTPS has not found any positive test results to date. 15 Is state verifying operators OQ programs are up to date? This should include verification 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, completed several OQ inspections in 2017 and is compliant with this question. 2 2 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 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: UTPS did conduct IMP (Protocol A) on all operators in 2017. 2 2 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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: UTPS conducted a DIMP inspection on the City of Hildale in 2017. State is compliant with this question. 2 2 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, they have conducted public awareness effectiveness inspections. 2 2 19 DUNS: 143528862 2017 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). Yes = 1 No = 0 Needs Improvement = .5 1 1 Utah Utah Division of Public Utilities, Page: 9#
UT NG Program Evaluation, 2017, page 10Evaluator Notes: Yes, Utah has a website with a section for pipeline safety awareness. 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 SRC reports in 2017. Last SRC was in 2014. 1 1 21 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Utah has a question on their inspection form in IA. 1 1 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: UTPS responded to a number of surveys in 2017. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: 1 NA 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Attended in CY2017 in Coeur d'Alene, ID 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 with program managers the website and the important Accelerated Actions to monitor for improving the Utah pipeline safety program. Encouraged to review Utah's performance with similar states. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Looks appropriate - discussed the importance to continually review the inspections days for all inspections and to compare with the initial estimates entered into the calculation tool. 27 DUNS: 143528862 2017 Gas State Program Evaluation 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 Utah Utah Division of Public Utilities, Page: 10#
UT NG Program Evaluation, 2017, page 11Evaluator Notes: 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 45 Total possible points for this section: 45 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 11#
UT NG Program Evaluation, 2017, 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 3 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: Procedures have letter being directed to operator representatives, not company offices. Several compliance actions reviewed were addressed to company personnel below the officer level - one point deduction. Procedures for routinely reviewing compliance actions should provide better detail (i.e., discussed in monthly staff meetings, etc.) - no point deduction. 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? 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: a. UTSP followed their procedures which allowed them to send compliance actions to company officials other than officers. UTSP is correcting their procedures accordingly. Four random compliance letters were reviewed and three of the four were routed to company representatives below the officer level. Since a point was reduced in D.1. there is no point deduction for this question. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all discovered probable violations were issued a compliance action. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes 2 2 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, the Program Manager has 23 years experience and is well versed with this process. 2 2 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 12#
UT NG Program Evaluation, 2017, 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: The last time a civil penalty was imposed was in CY2009. Program manager was encouraged to use their fining authority to improve their safety program. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 13#
UT NG Program Evaluation, 2017, 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/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, UTSP has adequate procedures for responding to and investigating an incident. 2 2 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, there are procedures to receive notification of an incident (Section VIII (F) page 35. The program manager was familiar of the MOU and agreement. 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 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: Documentation of reviewed incidents appeared sufficient. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: 1 1 State had 74 incidents in 2017, one of which was DOT reportable. A compliance action was initiated for the DOT reportable. 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Utah maintains good communication with the region and now the Accident Investigation Division. 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) 1 1 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 14#
UT NG Program Evaluation, 2017, page 15Yes = 1 No = 0 Evaluator Notes: Lessons learned are shared at NAPSR regional meetings. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 15#
UT NG Program Evaluation, 2017, 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: Utah has a question on their inspection form (IA) for protection from directional boring. 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: 2 2 Yes, UTSP has questions in IA about receiving notice of excavation, marking and follow up on locate requests. 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: UTSP takes steps to enhance damage prevention and the CGA best practices. 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, They collect the data from annual reports and analyze it for trends and improvement of operator's damage prevention programs. 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: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 16#
UT NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Dominion Energy Name of State Inspector(s) Observed: Jimmy Betham Location of Inspection: 1140 West 200 South, Slat Lake City, UT Date of Inspection: 7/12/2018 Name of PHMSA Representative: David Appelbaum and Leonard Steiner Evaluator Notes: Info Only Info Only 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: UTSP notified Dominion in May 2018 of this 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, They used IA with direct input into the computer. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, sufficient field notes were taken during the 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: Yes, all equipment used was verified operational, and where appropriate, calibrated. 1 1 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: Inspector thoroughly inspected all aspects of evaluation. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) 2 2 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 17#
UT NG Program Evaluation, 2017, page 18Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, inspector appeared well versed in the regulations. 8 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) Yes = 1 No = 0 Evaluator Notes: Yes 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: No probable violations were discovered, but recommendations and appropriate feedback was given. 1 1 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 D. Valve Maintenance E. Vault Maintenance Info Only Info Only DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 18#
UT NG Program Evaluation, 2017, page 19F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 19#
UT NG Program Evaluation, 2017, 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: 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: 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: 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: 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: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 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: 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: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 20#
UT NG Program Evaluation, 2017, 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: 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: 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: 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 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 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: 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: 143528862 2017 Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 21#
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