{"operation":"document","citation":"PHMSA wa2010ngprogramevaluation","title":"2010 WA NG Program Evaluation - wa2010ngprogramevaluation (Washington; Natural Gas State Program Evaluation)","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-01-01","effective_on":null,"summary":"2010 PHMSA natural gas program evaluation for Washington.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wa-ng-program-evaluation-wa2010ngprogramevaluation.json","markdown":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wa-ng-program-evaluation-wa2010ngprogramevaluation.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wa-ng-program-evaluation-wa2010ngprogramevaluation","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/211/wa2010ngprogramevaluation.pdf","body":"1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Natural Gas State Program Evaluation for Washington Utilities and Transportation Commission Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 1\n\n2010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: Washington Rating: Agency Status: Date of Visit: 06/27/2011 - 07/01/2011 Agency Representative: David Lykken, Pipeline Safety Director Steven King, Director Safety & Consumer Protection Joe Subsits, Chief Engineer Jim Fernald, Operations Manager PHMSA Representative: Glynn Blanton, DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Jeffrey D. Goltz, Chairman Agency: Washington Utilities and Transportation Commission Address: 1300 S. Evergreen Park Drive SW, 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 2010 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 24 21 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 7 7 D Incident Investigations 7 7 E Damage Prevention Initiatives 9 9 F Field Inspection 9 9 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 102.5 99.5 State Rating................................................................................................................................................... 97.1 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 2\n\nPART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as \"needs improvement\". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Information reviewed in 2011 Natural Gas Certification attachments 1, 2 & 3 are correct with inspection units and activities. All incident reports, attachment 4, were submitted with good details of the incidents and information on cause code was entered correctly. List of records maintained by the agency on their inspection program was reviewed and found to be complete. Training requirements for pipeline safety staff in attachment 7 was found to be correct and meets the requirements of the federal guidelines. A review of Joe Subsits and Kuang Chu category classifications in the certification document with David Lykken confirmed each individual is a registered Engineer and has a minimum of three years experience in pipeline safety and successfully completed the T&Q courses. This meets the requirements as described in the guidelines manual located on page 14 in Section 4-1, Categories and Qualifications for State Agency Inspectors. Discussed moving Jim Fernald, Operations Manager, into the Clerical and Administrative Support section on the 2012 Certification filing due to his duties and responsibilities are similar to those position and do avoid having to meet the training requirements listed in the guidelines for states participating in the pipeline safety program. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving \"after hours\" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 SLR Notes: Yes, incident reporting is required under WUTC's rule 480-93-200, sectiion 1. The telephone number is 888-321-9146. 1 1 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes. Last seminar was held in June 17-18, 2009. The next scheduled seminar will be held with Idaho PSC in the fall, the week of November 5th 2012. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: Yes. The files were well organized and accessible by file folders located in the office. In 2012, WUTC will be going to a electronic database that will be accessible by all pipeline safety personnel. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, David Lykken has a good working knowledge of the pipeline safety program. He started his career with the WUTC in 2000 and has over 11 years of experience in pipeline safety serving as Chief Engineer for 6 years. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark \"Yes\") (Chapter 8.1) Previous Question A.8 DUNS: 088967570 2010 Natural Gas State Program Evaluation 1 NA Washington Washington Utilities and Transportation Commission, Page: 3\n\nYes = 1 No = 0 SLR Notes: No response was necessary due to no items of concern were found or noted. 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark \"Yes\") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: No response was required. 1 NA Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 0 SLR Notes: No, Stephanie Zuchlke has not completed all the required training. PL3257, Enforcement course, was not completed in calendar year 2010. Loss of three points due to not completing the course in the required three year period. David Cullom, Pipeline Safety Engineer, was transferred into the division at middle year and has experience in pipeline safety dealing with the GIS system. He attended the PL1250 course in December, 2010. 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: State personnel: On October 26-27, 2010 House Fire Explosion Investigation Training was conducted in-house with all engineers attended the course. The course was presented by Sammy Russo. Additionally, on November 16, 2010, all engineers attend the Incident Investigation/Root Cause Analysis Training conducted by Baker Engineering & Risk Consultants, Inc. at their location. For Operators: Two damage prevention training seminars were conducted in Vancouver and Spokane, WA. Representatives from the operators and contractor communities were in attendance. Approximately, sixty-six individuals attended the training meetings. Operator Qualification \"Train the Evaluator\" course was conducted by APGA Security & Integrity Foundation organization on November 19, 2010 in Olympia, WA. Several industry representatives and one WUTC member participated in the class. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: WUTC continues to participate in the Citizens Committee on Pipeline Safety meetings providing education on pipeline safety regulations and initiatives from PHMSA. Info Only Info Only SLR Notes: 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: Yes, all lead engineers have completed the required T&Q courses and computer based training before conducting OQ inspections. David Cullom, Pipeline Safety Engineer, is scheduled to attend the OQ training and complete the WBT course in 2012. 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 SLR Notes: Yes, Joe Subsits, Scott Rukke, Chu Kuang are the lead engineers and have completed all required courses. 1 1 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 DUNS: 088967570 2010 Natural Gas State Program Evaluation 5 5 Washington Washington Utilities and Transportation Commission, Page: 4\n\nA. Total Inspection Person Days (Attachment 2): 636.23 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.32 = 1390.40 Ratio: A / B 636.23 / 1390.40 = 0.46 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: this category. A= 636.23 total inspection person days: B (220 x 6.36 = 1390.4) A/B= 0.46. This amount meets the larger amount and an award of five points is charged in 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Question B.13 Info Only = No Points Info Only Info Only SLR Notes: Yes, David Cullom, Pipeline Safety Engineer, was transfered into the division at the end of 2010. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Question 8: No, Stephanie Zuchlke has not completed all the required training. PL3257, Enforcement course, was not completed in calendar year 2010. Loss of three points due to not completing the course in the required three year period. Total points scored for this section: 21 Total possible points for this section: 24 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 5\n\nPART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: WUTC added Section 26, Compliance Follow-up Inspection and Section 31, Damage Prevention to their WUTC Pipeline Safety Section Policy & Procedures Manual on June, 2010 to address the items listed in the Program Manager letter that needs improvement. Listed below are additional information of the location of the items listed in section a thru h above. a: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 14, 15 & 16 address this item. b: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 22 c: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 17 d: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 31 e: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 27 f: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 21 g: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 20 h: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 26 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual and data base program includes these items. Each inspection visit is determined by a risk ranking method developed by Joe Subsits and reviewed by each staff member. WUTC inspects all operators on their risk ranking model or within three years from the last inspection performed. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: Yes, They are also reviewing potential master meter operators that will be included in their pipeline safety program in the future. In 2010, they surveyed more than thirty potential operators and ten have been included in their potential list in the future. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: Yes. I reviewed their inspection forms and found all items in the federal inspection document match their WUTC forms. DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 6\n\n5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: by all staff members. Yes, WUTC has included their commission rules with the federal regulations on their inspection forms. All forms were found to be complete and being used 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: No safety reports were submitted or filed in 2010. .5 NA 7 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Yes, WUTC has this item in their standard inspection form but all cast iron pipelines have been removed in the State of Washington. .5 .5 8 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) Previous Question B.8 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, the WUTC has this item in their standard inspection form but all cast iron pipeline has been removed from the State of Washington. 9 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, WUTC has a state rule WAC 480-93-186 Leak Evaluation that address this requirement and it is included in their inspection form. 10 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: Yes, this is covered in their standard inspection form. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: with their written procedures. Yes, a review of probable violation against Cardinal Pacific FG Company on March 29, 2010 was reviewed. The documentation was followed in accordance 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the \"Guidelines for State Participating in the Pipeline Safety Program\"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this information is completed and described in WUTC Pipeline Safety Policy and Procedure Manual Section 34. 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the \"Guidelines for States Participating in the Pipeline Safety Program\"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 088967570 2010 Natural Gas State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 7\n\nSLR Notes: Yes, this information is completed and described in WUTC Pipeline Safety Policy and Procedure Manual Section 34, pages 49 thru 65. 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the \"Guidelines for States Participating in the Pipeline Safety Program\"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this is accomplished by the WUTC \"Project Tracking System\". 1 1 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: Yes, WUTC issues compliance action in the form of either accepting the operator's response to their compliance letter or may offer a proposed settlement before going to a formal complaint. 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the \"Guidelines for States Participating in the Pipeline Safety Program\"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, WUTC Pipeline Safety Policy and Procedures identifies this item in Section 26. This revision was conducted and effective on June 22, 2010. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a \"Show Cause Hearing\" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: Yes, WUTC has the authority through the Commission's rules and regulations. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, a review of the file on Cardinal FG Company pertaining to probable violations cited on March 29-31, 2010 and settlement offered by the company indicate the agency is adequately documenting all violations. 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 SLR Notes: system. Yes, a review of letters and other correspondence to the operators indicate all information is being sent to the company officer or manager of the distribution 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Enforcement Manual. Yes, this information is described in WUTC's Pipeline Safety Policy & Procedures, Section 34. Safety & Consumer Protection Division Compliance & Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 8\n\n22 SLR Notes: Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 SLR Notes: Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 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) Info Only = No Points SLR Notes: Yes, program manager is familiar with state process and the issue of repeated violations. Info Only Info Only 28 Part B: General Comments/Regional Observations Info Only = No Points SLR Notes: No issues or areas of concern. Info Only Info Only Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 9\n\nPART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: requirement is being met. Yes, they are using the federal inspection forms. A review of the inspection performed on Williams Gas Pipeline on January 4. 2010 indicated this 2 Are results documented demonstrating inspection units were reviewed in accordance with \"PHMSA directed inspection plan\"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, information is well documented and demonstrated the inspection units were reviewed in accordance with PHMSA directed inspection plan. 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: Yes, WUTC submits within thirty days to PHMSA all required documentation on the inspections performed. 1 1 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 1 SLR Notes: Yes, a review of the documentation pertaining to TransCanada Transmission Northwest inspection performed on August 23-27, 2010 was forwarded to PHMSA Western Region on November 10, 2010 regarding three probable violations. 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: No imminent safety concerns were reported in 2010. 1 1 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: Yes, information reviewed in their files indicates WUTC is providing the information to PHMSA within thirty days. 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, a review of the TransCanada Transmission Northwest inspection documentation supports all federal reporting forms and information is being provided. 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: No issues or areas of concern in this section. Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 10\n\nPART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in \"Guidelines for States Participating in the Pipeline Safety Program\") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: incidents. Yes, reviews of the five incidents reported in 2010 indicate they are following their written procedures pertaining to working with PHMSA on accidents and 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in \"Guidelines for States Participating in the Pipeline Safety Program\") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: Yes, they are familiar with the Memorandum of Understanding between NTSB and PHMSA. .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, all incident reports are recorded and maintained by WUTC. In 2010, WUTC had 106 state reportable incidents which must be reported by the operators in compliance with WAC Rule 480-93-200. \"Reporting Requirements\". 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, onsite investigations were conducted on the Northwest Pipeline Corp on September 3, 2010, Northwest Natural on October 30, 2010 and Cascade Natural Gas Corporation on November 11, 2010. 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Information reviewed in the files and folders indicate the investigations were thorough and conclusive with the findings of facts. 2 2 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: No enforcement action was required by WUTC on the incident investigations conducted in 2010. 1 1 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: WUTC has been responding to the PHMSA Western Region office within ten days of an accident or information pertaining to the DOT Form 7100. 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: No issues or areas of concern. DUNS: 088967570 2010 Natural Gas State Program Evaluation Info Only Info Only Washington Washington Utilities and Transportation Commission, Page: 11\n\nTotal points scored for this section: 7 Total possible points for this section: 7 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 12\n\nPART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. A review of WUTC Form \"V\" Intra Gas ? Procedure and Plan Review, section 297 shows this item is included and meets this requirement. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes, this requirement is located on WUTC inspection form C. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Yes. at their excavator trainer meetings on October 5, 2010 in Vancouver, WA and October 13, 2010 they shared information about the Common Ground Alliance Best Practices documents to the excavators in attendance. WUTC continues to support these practices at the Northwest Common Ground regional meetings. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes, WUTC has a State Damage Prevention Statistics Mandatory Reporting form requirement for those operators under their jurisdiction to report damages. They have implemented the Virtual DIRT program , a volunteer participation for only pipeline operators to report the number of pipeline damages per 1,000 locate request in 2009. In January 1, 2013, the new damage prevention law will require all underground operators and excavators to report all damages via the Virtual Dirt Program to WUTC. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes, this item is reviewed by staff members on their inspection visits and available on the federal standard inspection form. This review is found on WUTC's Form C Intrastate Gas Distribution, Section 36-40. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: No issues of concern were noted in this section. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 088967570 2010 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 13\n\nPART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Georgia Pacific Consumer Products Name of State Inspector(s) Observed: Stephanie Zuehlke, Pipeline Safety Engineer Location of Inspection: Camas, WA Date of Inspection: July 11-12, 2011 Name of PHMSA Representative: Glynn Blanton, PHMSA State Programs SLR Notes: Stephanie Zuehike, Pipeline Safety Engineer, was observed two days peforming a standard inspection of Georgia Pacific Consumer Products in Camas, WA. The last inspection performed on this operator was in 2008 by Patti Johnson, WUTC Engineer. On July11 & 12, 2011 the following individuals were present during the inspection and represented the operator: Steve Ringquist, Reliablity Leader, Ron Kramer, HR Manager, Patrick Terry, Sr. Staff Engineer and Roy Rogers, Cathodic Protection, Inc. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes, Steve Ringquest, Georgia Pacific Consumer Products Supervisor and Roy Rogers, a consultant for Georgia Pacific Customer Products, were contacted prior to the inspection visit and provided a copy of WUTC Standard Report for Intrastate Gas Transmission Pipelines Form D that would be used during the inspection. 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 2 2 SLR Notes: Yes, Stepanie Zuehlke used WUTC Standard Inspection Report for Intrastate Gas Transmission Pipelines Form D. She completed each section of the form as information and response was provided by the operator. 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: Yes, Stephanian Zuehlke documented each response and information provided to her on the standard inspection form. She asked for copies of operator's records when an area of concern was found or noted during the inspection. 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.) New 2008 Yes = 1 No = 0 SLR Notes: This was a standard inspection office records review inspection. No outside field inspection was performed on July 11 & 12, 2011. 1 NA 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: WUTC inspector conducted a Standard Inspection Report for Intrastate Gas Transmission Pipelines using Form D - Records Review and Field Inspection. 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures DUNS: 088967570 2010 Natural Gas State Program Evaluation 2 NA Washington Washington Utilities and Transportation Commission, Page: 14\n\nb. Records c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: No field inspection was performed on July 11 7 12, 2011. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 2 2 SLR Notes: Yes, Stephanie Zuehlke demonstrated excellent knowledge of the pipeline safety regulations and WUTC rules and regulations to the operator. She provided additional information on the justification of the rules and regulations when the operator requested clarification on the meaning of the rule(s). 9 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) Previous Question F.10 Yes = 1 No = 0 1 1 SLR Notes: Yes, each day at the end of the inspection review she provided a re-cap of the items found to be in non-compliance or area of concern to the Georgia Pacific company representatives. These items were noted on the inspection form each of the two days during my observation. 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: Yes, Stephanie Zuehlke reviewed with the operator representatives the areas of concern or probable violations prior to leaving each day. She answered all questions pertaining to probable violations or areas of concerns with the citing of the regulations or WUTC rules. When asked about notification of these violations, she provided an estimated time when an official notification via certified letter would be sent to the operator from David Lyyken. 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Info Only = No Points SLR Notes: This was a standard records review and no field inspection was observed during July 12 & 13, 2011. 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