RegulusPipeline researchPHMSA wa-2018-hazardous-liquid-program-evaluation
WA HL 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 Hazardous Liquid State Program Evaluation for Washington Utilities and Transportation Commission 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 -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 1#
WA HL Program Evaluation, 2018, page 22018 Hazardous Liquid State Program Evaluation -- CY 2018 Hazardous Liquid State Agency: Washington Rating: Agency Status: Date of Visit: 08/26/2019 - 09/19/2019 Agency Representative: Sean Mayo, Director Pipeline Safety Program Joe Subsits, Chief Engineer Debbie Becker, Operations Manager Rell Koizumi, Transportation Specialist PHMSA Representative: Glynn Blanton, PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: David W. Danner, Chairman Agency: Washington Utilities and Transportation Commission Address: PO Box 47250 City/State/Zip: Olympia, WA 98504-7250 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 38 38 D Compliance Activities 15 15 E Accident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (if applicable) 7 7 I 60106 Agreement State (if applicable) 0 0 TOTALS 114 114 State Rating................................................................................................................................................... 100.0 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 2#
WA HL 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: A review of SharePoint confirmed jurisdictional authority for each operator type is consist with the authority stated on Attachment 8. WUTC is an interstate agent for four interstate refined petroleum product operators and one crude oil operator. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A review of Attachment 2 compared to last year's indicated a larger number of standard comprehensive inspection. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Number of operators remained the same except for one system. Targa Sound Terminal LL is now Seaport Sound Terminal, LC. Operator ID 30909. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of Pipeline Data Mart for CY2018 found no federally reportable incidents. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The number of probable violations to be corrected at the end of the year was verified using the previous year's progress report. The number of compliance actions taken was higher than in previous year, eleven versus 1 last year. All violations were cleared in CY2018 and no carryover into CY19. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, files were accessible. No issues with program files. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, reviewed TQ Blackboard to confirm the qualification categories were correct. Seven of the eight individuals listed are active liquid inspectors. One individual is scheduled to attend the HL Safety Evaluation course. 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No issues on regulation adoption and amendments. Current civil penalty amount will increase to federal level on May, 2019. DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 3#
WA HL Program Evaluation, 2018, 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: Excellent description of past and future plans. No areas of concern in the review of the document. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: No loss of points in this section of the review. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 4#
WA HL 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, information is located in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual - Section 15 Standard Intrastate Inspection and Section 16 Standard Interstate Inspections & Correspondence. All of the three elements are listed. They continue to use IA form for inspections. 2 IMP 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, IMP procedures are located in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual and Hazardous Liquid Integrity Management Inspections Section 23 and General Inspection Guidelines Section 14. 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, OQ procedures are located in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, General Section 14 & Operator Qualification Inspection Section 17. All three elements of the inspection are listed. 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, Damage Prevention has been added as a separate procedure into Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual - Section 31 Damage Prevention Enforcement & Civil Penalty Investigation Procedures. The three elements are provided in the document. 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, training information is listed in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, Section 27 Operator Training & Technical Assistance. 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. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, construction inspection is listed in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, Section 21 Design and Construction Inspection. The three elements are provided. DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 5#
WA HL Program Evaluation, 2018, page 67 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 area, 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: a thru e. These items are provided in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, Section 13 Inspection Scheduling Policy. f. Inspection units are reviewed by Chief Engineer with inspectors routinely to see if it meets the scope of the inspection program. 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 6#
WA HL 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 5 5 A. Total Inspection Person Days (Attachment 2): 98.11 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.17 = 256.30 Ratio: A / B 98.11 / 256.30 = 0.38 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 98.11 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=256.3 Formula:- Ratio = A/B = 98.11/256.3 = 0.38 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 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 IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram 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: a All inspectors except one have completed the requirements as the lead for OQ inspections. b. Four inspectors have completed the requirement for Liquid IM c. Four inspectors have completed the root cause course. d. NFA 59 A course March 13-15, 2018. e. All inspectors except for one have completed the minimum qualification to lead a standard inspection. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Sean Mayo has two years of experience in pipeline safety regulation and enforcement and attended five of the seven required TQ courses. 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 2 2 Evaluator Notes: Yes, Chairman Danner's response letter to Zach Barrett was received on March 4, 2019 and within the sixty day 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: DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 7#
WA HL Program Evaluation, 2018, page 8The last seminar was 2017. The next seminar will be scheduled at the WUTC office on July 14, 2020. 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: WUTC inspects all units and operators not to exceed five years in accordance to their pipeline safety procedures. A review of records and data base confirm for CY2018 they inspected 9 intrastate operators and 9 inspection units and 5 interstate operators and 10 inspection units. 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, they use IA and PHMSA forms for inspections. 2 2 8 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 195.402(c)(5)? Yes = 1 No = 0 Evaluator Notes: NA. No accidents occurred in CY2018. 1 NA 9 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 and failure reports are required by WUTC state rules to be submitted to the agency. Inspectors review the reports and post trends on the operator's action. This item is covered in sections 15 & 16 of WUTC procedures. 10 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this is addressed in Form D, Records and Field Inspection State Checklist Question 1. 1 1 11 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, this is provided in WUTC Pipeline Procedures -15 Standard Intrastate Inspection and Correspondence and Pipeline Procedures -18 Drug and Alcohol Inspection policy. Also listed in Inspection report Form 13. 12 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 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is listed in WUTC Pipeline Procedure - 15 Standard Inspection and Correspondence and Pipeline Procedures - 17 Operator Qualification Inspections. DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 8#
WA HL Program Evaluation, 2018, page 913 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are up to date? This should include a previous review of LIMP 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-10)). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this information is located in the Pipeline Procedures section 15 & 23. 2 2 14 Is state verifying operators Public Awareness programs are up to date and being 2 2 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 195.440 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, WUTC has developed a new procedure in their Policy & Procedures Manual - Section 30 Public Awareness Program Inspection that address these issues. 15 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: WUTC staff have quarterly meetings with the Citizens Committee on Pipeline Safety. The committee provides suggested topics and items about potential pipeline safety matters to help improve the WUTC pipeline safety program. WUTC website provides information to the public. 16 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 condition reports submitted in CY2018. 1 NA 17 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 they responded to all surveys from NAPSR and NARUC. 1 1 18 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. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: NA 1 NA 19 Did the state attend the NAPSR National Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: Yes. Sean Mayo attended the NAPSR Board of Director's meeting in Santa Fe, NM on October 15-19, 2018. 20 Discussion on State Program Performance Metrics found on Stakeholder Communication site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 Yes = 2 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation 2 2 Washington Washington Utilities and Transportation Commission, Page: 9#
WA HL Program Evaluation, 2018, page 10a. 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 metric and found the information on the website only applies to CY2017. Sean Mayo provided additional information to show their awareness of the metrics for HL. No areas of concern. 21 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: 1 NA Discussed the SICT number with program manager and the 85 state inspection days is reasonable and meets their needs. 22 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: NA 23 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 38 Total possible points for this section: 38 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 10#
WA HL Program Evaluation, 2018, page 11PART 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, written procedures pertaining to notification of company officer, compliance action and closing probable violations are located in WUTC Pipeline Procedures - 25 Compliance Enforcement Tracking Policy, 26 Follow-up Inspection Policy, 34 Compliance and Enforcement Manual and Penalty Recommendation Matrix page 17, and Compliance Tracker. 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 director 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.Yes, a review of compliance action letter sent to Tidewater Terminal Company 10-9-17 confirm the letter was sent to the company officers. b.Yes, violations were found and noted in the letters. c. Probable violations were resolved within the established time schedule. d. All violations were reviewed on a bi-weekly schedule. e. Yes this is conducted in the exit interview. f. Yes, WUTC provides the findings of the inspections to the operator within 45 days of the inspection 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of files found violations and compliance actions were issued in CY2018. 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: 2 2 Yes, WUTC rules and RCW Title 81.88.040 provides the operator and all parties due process including a show cause. 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 Evaluator Notes: Yes, program manager is familiar with this process and has issued civil penalties to natural gas operators. 2 2 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 11#
WA HL Program Evaluation, 2018, page 126 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: Yes, this has been demonstrated in last year's civil penalty against the gas operators Cascade and PSE in CY2017. 7 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 12#
WA HL Program Evaluation, 2018, page 13PART E - Accident 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, this is addressed in the Pipeline Procedures -10 One Call & Telephone Notification, 19 Federal State Cooperation in Case of Accident, 20 Response to Pipeline Incidents and 24 Investigation Policy. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, 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, this is addressed in the Pipeline Procedures -10 One Call & Telephone Notification & 19 Federal State Cooperation in Case of Accident 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: 1 1 Yes, this is addressed in the Pipeline Procedures -10 One Call & Telephone Notification & 24 Investigation Policy that was recently updated in CY2019. The notification and supporting decision to not go on site is in the check list document. 4 Were all accidents 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 where appropriate Yes No Needs Improvement Evaluator Notes: Yes, the McCord incidents that occurred in CY2017 demonstrated the investigation by WUTC was thoroughly documented. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: Yes, a civil penalty was assessed in the amount $10,000 in accordance to WUTC dig law. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator accident 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, this item is addressed in the Pipeline Procedure section 24. Additionally the program manager and chief engineer are in contact with PHMSA AID. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 13#
WA HL Program Evaluation, 2018, page 14Yes = 1 No = 0 Evaluator Notes: Yes, this is accomplished via the State of State Report at the Western Region NAPSR Meeting. 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 14#
WA HL Program Evaluation, 2018, page 15PART 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is addressed in Form G2 - Standard Liquid Inspection Question 11. 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, this is addressed in Form G2 - Standard Liquid Inspection Question 10. 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, this is addressed in RCW 19.122 and Gov. Inslee's Proclamation for Dig Safe in February, 2018. 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, this is accomplished in the DIRT report and data analysis provided in the Damages by County per 1,000 Locate Request report. Operator Excavation annual reports is also used in evaluating damages. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 15#
WA HL Program Evaluation, 2018, page 16PART 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: Seaport Sound Terminal Name of State Inspector(s) Observed: Lex Vinsel, Pipeline Safety Engineer Location of Inspection: Tacoma, WA Date of Inspection: August 27, 2019 Name of PHMSA Representative: Glynn Blanton, PHMSA State Evaluator Evaluator Notes: This was a supervisory control, data acquisition and leak detection inspection conducted on Seaport Sound Terminal property located at 2628 Marine View Drive in Tacoma, WA. Mr. Anthony Dorrough, Pipeline Safety Engineer participated in the inspection but was not the lead. Seaport Sound Terminal representatives were Pamela Cannon, DOT Compliance Coordinator, Ted Lilyeblade, Terminal Manager & Luis DeLeon, DOT Compliance Coordinator. 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, the operator representative Ted Lilyeblade, Terminal Manager was contacted on June 20, 2019 by Lex Vinsel, WUTC Pipeline Safety Engineer. 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, observed Lex Vinsel, Pipeline Safety Engineer using the IA inspection form. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, observed Lex Vinsel entering answers to questions into his laptop computer IA form. Accurate information was entered based on responses from operator representatives and review of documents. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,valve keys, half cells, etc) Yes = 1 No = 0 Evaluator Notes: Yes. The operator's representative had a copy of their written procedures available as a reference to answer questions in demonstrating compliance to CRM requirements. No issues. 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: 088967570 2018 Hazardous Liquid State Program Evaluation 2 2 Washington Washington Utilities and Transportation Commission, Page: 16#
WA HL Program Evaluation, 2018, page 17The field inspection was a review of written procedures pertaining to CRM and leak detection. No outside field inspection or observations were conducted. 7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Lex Vinsel, the lead inspector has a good working knowledge of the hazardous liquid safety program and regulations. He has completed all TQ courses relative to HL. 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, at the end of the day, an exit interview was conducted and noted on the inspector's inspection report. 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 issues of probable violations were noted or found. 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 Info Only Info Only DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 17#
WA HL Program Evaluation, 2018, page 18A. 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 supervisory control, data acquisition and leak detection inspection was a review of the operator's written procedures. The lead inspector performed a professional and knowledgeable inspection and asked a lot of questions to the operator's representatives to insure compliance with all safety regulations. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 18#
WA HL Program Evaluation, 2018, page 19PART 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 1 Yes, WUTC uses the PHMSA - IA program. Information on the program is listed in Pipeline Procedures section 16. 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: Yes, this is documented in the work plan submitted to PHMSA Western Region. 1 1 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 1 Yes, this is accomplished within 45 days from the inspection. This is listed in the Pipeline Safety Procedure 16 document. 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: 1 1 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: No probable violations were identified but WUTC is familiar with referring the item to PHMSA Western Region. 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 1 1 Evaluator Notes: No probable violations were identified and WUTC is familiar with referring the item to PHMSA Western Region. This item is listed in Pipeline Safety Procedures 16. 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 This is followed in their 45 day requirement in the pipeline procedures 16. 1 1 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: None were discovered in 2018. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 19#
WA HL Program Evaluation, 2018, page 20PART 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: NA 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: NA 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: NA 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: NA 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: NA 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: NA 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 088967570 2018 Hazardous Liquid State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 20#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.