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PHMSA wa-2018-gas-program-evaluation
2018 WA NG Program Evaluation - wa-2018-gas-program-evaluation (Washington; Natural Gas State Program Evaluation)
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WA 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 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 -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 1#
WA NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas 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 46 46 D Compliance Activities 15 15 E Incident Investigations 10 10 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 121 121 State Rating................................................................................................................................................... 100.0 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 2#
WA 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 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Jurisdictional authority was review in SharePoint. WUTC is an interstate agency with PHMSA. In the note section, Puget Sound Energy was listed under Distribution LPG. 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 found an increase in the number of total inspection days. The largest increase was in Design & Construction with 348.49 compared to 280.24 in last year's filing. It was suggested the number of drug & alcohol inspections results should include a count of the Drug and Alcohol inspections completed during the calendar year. (e.g. 60 of 80 operators' D & A inspections completed). 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: List of Operator types and inspection units reviewed found they are consistent with the data entries in Attachment 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: Yes, verification of the reportable incident was found to be consistent with the incident report information contained in PHMSA's database, (Pipeline Data Mart). 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of attachment 5 found the number of carried over violations from previous years was incorrectly stated. The correct number is 47 not 67 that was listed on last year's progress report. WUTC found the error and listed this item in the note section of the report. It was unclear if WUTC had notified PHMSA requesting this error be corrected to maintain an accurate database. On September 18th, WUTC notified Carrie Winslow to have this item corrected in the previous WUTC 2017 Progress Report. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of program files and database found information on inspection person days and forms were organized and accessible. 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, a review of TQ Blackboard database found 7 of the 8 inspectors are state qualified gas inspectors. One inspector has completed two of the required seven courses after being employed on July, 2018. DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 3#
WA NG Program Evaluation, 2018, page 48 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: A review of attachment 8 found all federal regulations have been adopted within the 24 month period. Additionally, WUTC has adopted maximum civil penalty amount of $200,000/$2 M. It is anticipated the penalty amount of $213,268/$2,132,268 will be adopted by reference on May, 2019. 9 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: Excellent description of planned and past performance was provided in attachment 10. WUTC continues to review the DPAP document annually. No issues. 10 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: 10 Total possible points for this section: 10 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 4#
WA NG Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, information is located in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, Standard Intrastate Inspections & Correspondence Section 15. The three elements pertaining to conducting an inspection are listed. 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, IMP and DIMP inspections procedures are located in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual and Gas Integrity Management Inspections Section 22 and DIMP Inspection Policy 36. A review of procedures confirm the three element of conducting an inspection were listed. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, OQ inspection procedures are found in Washington Utilities & Transportation Commission Pipeline Safety Policy & Procedures Manual, General Section 17. The three elements were listed in the procedure. 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 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, 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 5#
WA NG 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 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: 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. This item is also on the annual review form. 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 6#
WA 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 5 5 A. Total Inspection Person Days (Attachment 2): 700.54 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.24 = 1371.70 Ratio: A / B 700.54 / 1371.70 = 0.51 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)= 700.54 B. Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=1371.7 Formula:- Ratio = A/B = 700.54/1371.7 = 0.51 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 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: a. All inspectors except for one have completed the requirements to conduct an OQ inspection as the lead. b. Four of the eight inspectors have completed required DIMP/IMP training to be the lead. c. Four inspectors have completed the root cause course. d. All inspector staff attended the NFPA 59A on March 13-15, 2018 and HAZWOPER training course on January 17, 2018. e. Seven of the eight inspectors have completed the minimum qualification requirements 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 Gas State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 7#
WA NG Program Evaluation, 2018, page 8Each state agency must conduct or participate in a pipeline safety seminar within the last three calendar years to educate operators within the state on current regulations. Yes, WUTC held a pipeline safety seminar on June 6, 2018 in Lacey Washington with 46 operators in attendance. 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: A review of data base found all inspections performed were completed within 45 days of the established date of the inspection. All exit interviews were completed on the last day of the inspection or when additional information was provided to the inspector by the operator. 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: WUTC currently is using the IA form along with other questions. 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: NA. No cast iron pipe in the State of Washington. 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: NA. No cast iron pipe in the State of Washington. 1 NA 10 Did the state review operator emergency response procedures for leaks caused by 1 1 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, these items are listed in Form C, Records and Field Inspection state checklist question 31 and Form V, Procedure and Plan Review Questions 375 & 376. 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, this item is addressed in Form C- Records and Field Inspection State Checklist Question 32 and Form D, Records and Field Inspection State Checklist question 41. 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 Evaluator Notes: DUNS: 088967570 2018 Gas State Program Evaluation 2 2 Washington Washington Utilities and Transportation Commission, Page: 8#
WA NG Program Evaluation, 2018, page 9Yes, this is addressed in Forms C & D Records and Field Inspection State Checklist page 2. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, this is addressed in Form D Records and Field Inspection State Checklist Question 1. Reviewed data base and confirmed this item is being reviewed with the operator. 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, this is addressed in Pipeline Procedures -15 Standard Intrastate Inspection and Correspondence and Pipeline Procedures -18 Drug and Alcohol Inspection policy. Also listed in Form 13. 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, this is addressed in Pipeline Procedure - 15 Standard Inspection and Correspondence and Pipeline Procedures - 17 Operator Qualification 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, this is addressed in Pipeline Procedure - 15 Standard Inspection and Correspondence and Pipeline Procedure - 22 Gas Integrity Management Inspection. 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: Yes, this is addressed in Pipeline Procedure - 15 Standard Inspection and 36 DIMP Inspection Policy. 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, this is addressed in Pipeline Procedure - 30 Public Awareness Program Inspections. 2 2 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 9#
WA NG Program Evaluation, 2018, page 1019 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 meets quarterly with the Citizens Committee on Pipeline Safety (CCPS) members. The committee provides suggested topics and items about potential pipeline safety matters to help improve the WUTC pipeline safety program. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No safety related condition report in CY2018. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, WUTC has a replacement plan and materials defect report that operators are required by state rules to submit to their agency. WUTC will review all planned pipeline replacement projects to determine if it is justifiable and cost recovery is reasonable and necessary. 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, WUTC has responded to all NAPSR and PHMSA survey questions. 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: Yes, they have one waiver that was issued in CY2016 on PSE LNG facility located in Tacoma, WA. In CY2018 no waivers were issued. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 1 1 Evaluator Notes: Yes, Sean Mayo and Joe Subsits attended the NAPSR 2018 Board of Directors meeting in Santa Fe, NM in October 14, 2018. 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: Program Manager has a good understanding of the trends and noted the inspection for HL was not posted for CY2017. A review of the metrics on leakage found the number of leaks continue to go downward. PM will continue to monitor and take AA if trends change. 26 DUNS: 088967570 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 Washington Washington Utilities and Transportation Commission, Page: 10#
WA NG Program Evaluation, 2018, page 11No = 0 Yes = 1 Evaluator Notes: Discussed with Sean Mayo about the SIDCT results. The number of person days for the gas program is 416. They feel comfortable with their number and do not anticipate increasing the number of person days next year. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: No pipeline flow reversals occurred in CY18. This item is on the annual review checklist form. 28 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: 46 Total possible points for this section: 46 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 11#
WA 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, 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 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.Yes, a review of compliance action letters sent to AirGas 8-27-18, Puget Sound Energy on 05-03-18, Snug Harbor Resort on 08-30-18, Slovay Chemical, Inc. 08-30-18 confirm all letters were 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. information is posted on their website. 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 180 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 hearing. 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: DUNS: 088967570 2018 Gas State Program Evaluation 2 2 Washington Washington Utilities and Transportation Commission, Page: 12#
WA NG Program Evaluation, 2018, page 13Yes, program manager is familiar with this process and has issued civil penalties. The last civil penalty issued was in CY2017 against Cascade Gas Company in the amount of $2.5 M and PSE in the amount of $2.75 M. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this was clearly demonstrated in last year's civil penalty against Cascade and PSE. 1 1 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 13#
WA 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, 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 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, 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 incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, the one incident involving PSE that occurred in CY2018 was investigated and thoroughly documented with information and findings of fact. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: NA/ No compliance action was issued against PSE. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, program manager and chief engineer have provided information on incident reports to the PHMSA Region Office and AID. Additional information on this action is described in their written procedures - 24 Investigation Policy. DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 14#
WA NG Program Evaluation, 2018, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, this information is presented at the State of the State Report given by Sean Mayo at the 2018 Western Region 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: 10 Total possible points for this section: 10 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 15#
WA NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is addressed in Form C - Records and Field Inspection State Checklist Question 33, Form V Procedure and Plan Review Question 310, Form D Records and Field Inspection State Checklist Question 40. 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, this is addressed in Form C - Records and Field Inspection State Checklist Question 34, Form V Procedure and Plan Review Question 310, Form D Records and Field Inspection State Checklist Question 50 and on-site crew inspection. 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 Requests report. 5 General Comments: Info Only = No Points Evaluator Notes: No lose 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 16#
WA NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Casade Natural Gas Company Name of State Inspector(s) Observed: David Cullom, Gas Pipeline Engineer & Darren Tinnerstet, Damage Prevention Investigator Location of Inspection: Pasco, WA Date of Inspection: August 28-29, 2019 Name of PHMSA Representative: Glynn Blanton, PHMSA State Evaluator Evaluator Notes: This was a Drug and Alcohol inspection performed at the operator's office location. The following operator representatives were present Justin Waldron, Drug Program Manager, Sam Hamilton, Manager Compliance, Colby Lundstrom, Compliance Audit Specialist, & Craig Pulley, Manager of Human Resources. An in-depth review of the records and company's procedures used in conducting the program was reviewed. David Cullom was the lead inspector and Darren Tinnerstet assisted in the inspection. 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, David Cullom contacted Mike Schoepp, Director of Operations Services MDU Utility Group on October 20, 2018 via email. 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 inspector used WUTC, Substance Abuse Program form no. 3.1.11 revision 2. 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 the inspector recording detailed notes and answers to questions from the operator representatives. Information entered into the form was detailed and thorough from the responses provided. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, operator representatives provided and had available all records pertaining to drug & alcohol testing of their employees. 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) 2 2 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 17#
WA NG Program Evaluation, 2018, page 18Evaluator Notes: Yes, observed inspector checking and verifying records and documentation on drug and alcohol testing. 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, David Cullom has completed all courses at TQ and is qualified as a Gas Inspector. He demonstrated excellent knowledge pertaining to Drug & Alcohol testing requirements. 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: Yes, at the end of each day, David Cullom performed an exit interview with the operator representatives. He noted the items reviewed in the inspection form each day to the operator representatives. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: No areas 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 18#
WA 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: A very thorough inspection was performed. David Cullom conducted a professional inspection demonstrating his knowledge in pipeline safety regulations. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 088967570 2018 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 19#
WA 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: 1 1 Yes, WUTC uses the PHMSA - IA program. Information on the program is listed in WUTC 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 1 1 Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this is accomplished within 45 days from the inspection. This is listed in the Pipeline Safety Procedure section 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 probable violations 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 any items of concern to PHMSA Western Region. This item is listed in WUTC Pipeline Safety Procedures Section 16. 6 Did the state give written notice to PHMSA within 60 days of all probable violations 1 1 found? Evaluator Notes: days. Yes = 1 No = 0 Needs Improvement = .5 Yes, WUTC has a requirement in their Pipeline Procedure section 16 that all written notice will be sent to PHMSA within 45 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: No compliance action was required. 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 DUNS: 088967570 2018 Gas State Program Evaluation Total points scored for this section: 7 Total possible points for this section: 7 Washington Washington Utilities and Transportation Commission, Page: 20#
WA 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: 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 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 21#
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