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PHMSA wy-2018-gas-program-evaluation
2018 WY NG Program Evaluation - wy-2018-gas-program-evaluation (Wyoming; Natural Gas State Program Evaluation)
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WY 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 Public Service Commission, State of Wyoming 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: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 1#
WY NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Wyoming Rating: Agency Status: Date of Visit: 09/16/2019 - 09/19/2019 Agency Representative: David Piroutek, Engineering Supervisor PHMSA Representative: David Lykken, PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Kara B. Fornstrom, Chairman Agency: Wyoming Public Service Commission Address: 2515 Warren Avenue, Suite 300 City/State/Zip: Cheyenne, WY 82002 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2018 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 44 44 D Compliance Activities 15 14 E Incident Investigations 5 5 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 107 106 State Rating................................................................................................................................................... 99.1 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 2#
WY NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No issues. Inspection Unit totals by operator type on Attachment 3 are consistent with the Inspection Unit totals on Attachment 1. Detailed notes provided under Attachment 1 explaining changes to operator information. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Minimum number of inspection days required was 221. Actual was 224. The number of inspection days entered for each operator/unit type and inspection type essentially match the records kept by the program. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed PDM data including operator annual reports. No issues noted. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No re-portable incidents in CY2018 although one erroneously as part of an operator's emergency drill. Information is consistent with the incident report information contained in PDM. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The information entered for compliance activities matches the records kept by the program. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No issues noted. Records stored on agency servers and other spreadsheets as maintained. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes. Information verified through T&Q Blackboard training site. Training for personnel found to be complete and accurate. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 122 - 82 FR 7972 dated 3/24/2017 Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Changes The Commission is taking steps to adopt and effective by the end of this calendar year. DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 3#
WY NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WYPSC has a number of goals noted such as completing new inspector core training, completing next round of TIMP and DIMP inspections, and participating in more joint team inspections with other states. 10 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part "A". Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 4#
WY 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 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: Inspection Planning beginning on page 5, Pre-Inspection, Inspection and Post Inspection pages 5-7 and 10. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Pre-Inspection, Inspection and Post Inspection pages 5-7 and 11. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Pre-Inspection, Inspection and Post Inspection pages 5-7 and 11-12. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Pre-Inspection, Inspection and Post Inspection pages 5-7 and 12. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On-site operator training addressed on page 12. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Pre-Inspection, Inspection and Post Inspection pages 5-7 and 12. 1 1 DUNS: 110414138 2018 Gas State Program Evaluation 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement Wyoming Public Service Commission, State of Wyoming, Page: 5#
WY NG Program Evaluation, 2018, page 6c. 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: Items a thru e covered on pages 3-5, and 11 of written procedures. TIMP and DIMP inspections are conducted within two years of the notification of changes to an operator's Integrity Management Program and at intervals not to exceed 5 years after the initial inspection. Units apportioned appropriately. 8 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part B. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 6#
WY 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): 224.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.46 = 321.93 Ratio: A / B 224.00 / 321.93 = 0.70 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. Total inspection days/ratio met. No issues. A.Total Inspection Person Days = 224 B.Total Inspection Person Days Charged to the program(224*1.46=321.93) Ratio = A/B = 224/321.93 = 0.70 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. Yes. b. Yes. C. McCollom needs new combined CRM/SCADA course to complete IMP requisites. c. PM has Root Cause training. d. Program staff attended the Wyoming Underground Corrosion Committee Training. e. Yes 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No issues noted. PM is well acquainted with PHMSA program and regulations. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Chairman Fornstrom's response letter was received on February 25, 2019. PHMSA's outbound letter was dated February 8, 2019, thus the State responded within the 60-day time requirement. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes. Last participation was the 2017 joint South Dakota/Wyoming seminar in Rapid City, SD 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 7#
WY NG Program Evaluation, 2018, page 8Evaluator Notes: frames. Yes. Tracker maintained to ensure that all operator types, units, and inspection types are completed within established time- 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Program has migrated to IA for conducting most types of inspections except for D&A and LPG. Only three inspections CY2018 inspections closed in IA. 20 remain open. Program has been keeping IA inspections open until resolution. Encouraged PM to close inspections as soon as possible. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: N/A. The PDM indicates there is no CI remaining in the state. 1 NA 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: N/A. The PDM indicates there is no CI remaining in the state. 1 NA 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The program has migrated to the IA. Covered under Procedures/Emergency Group. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. The program has migrated to the IA to conduct most inspection types. Question covered under IA Records/O&M group. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Tracked and reviewed annually with data pulled from the PDM to check for accuracy. Program tracks data on spreadsheet. Program has identified the top three threats as 1. Equipment Failure 2. Pipe/Joint Weld Failures 3. Excavation Damage. Data from analysis followed up with operators during inspections. 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 Evaluator Notes: DUNS: 110414138 2018 Gas State Program Evaluation 1 1 Wyoming Public Service Commission, State of Wyoming, Page: 8#
WY NG Program Evaluation, 2018, page 9Yes. Included in the standard inspection checklist in IA. Reviewed Tronox Records and Field inspection. 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. Reported 2 D&A inspections conducted in CY2018. Reminded the PM to use PHMSA Form 3.1.11 (excluding protocols O & P) to conduct a comprehensive inspection not to exceed five years between inspections. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 10.37 days devoted to OQ program reviews and field validations. 7 Field Records/Protocol 9 inspections and 6 plan reviews conducted. 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. 13.88 days devoted to IM inspection activity. Reviewed DEN Records inspection and TMP plan review inspection. Per written procedures, Integrity Management Program inspections conducted within two years of the notification of changes to an operator's Integrity Management Program and at intervals not to exceed 5 years after the initial inspection. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Reviewed MDU, PNG Plan review, and TOW plan review. Per the programs written procedures, Distribution Integrity Management inspections will conducted within two years of the notification of changes to an operator's Integrity Management Program and at intervals not to exceed 5 years after the initial inspection. 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. 7 PAPE inspections conducted in CY2018. 2 2 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes. PHMSA Advisory Bulletins forwarded to operator via email distribution list (reviewed). Commission web site provides DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 9#
WY NG Program Evaluation, 2018, page 10web links to PHMSA State Programs Overview page, Wyoming One-Call. Only enforcement cases brought to commission open meetings made available via public records request. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 NA Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. There were no reported SRC's in CY2018. Provided suggested language for written procedures for receiving and processing of SRC's. 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. Program reviews data supplied in operator annual reports. Reviews operator's leak investigation during standard inspections. 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. No issues. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 1 NA 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: N/A. There are presently no open waivers/special permits. Those currently posted on the PHMSA web site are... No longer active (3), Rejected (2). PM to contact Standards and Rulemaking group to get updated. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, was attended by the PM. Meeting held in Santa Fe, NM. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Damages per 1000 tickets continues trending down since CY2010 which was at 6.6. Ratio in CY2018 is 3.0 damages per which is slightly higher than the national average of 2.9. Inspector qualification core training remains high as well as 5 year retention percentage. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed. Tool was updated in CY2018. No significant changes to inspections day calculation and have not identified any additional staffing needs. DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 10#
WY NG Program Evaluation, 2018, page 1127 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: N/A. No flow reversal, product changes, and/or conversion to service in CY2018. 28 General Comments: Info Only = No Points Evaluator Notes: No Point deductions under Part C. Question C-27 N/A. Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 44 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 11#
WY 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: a, b, and c. Page 8 of 13 (Post Inspection Activities/Facilities Inspection Report). 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Yes. 2018 Inspection reports sent to appropriate company officer. Probable Violations well documented. Program tracks and reviews progress and resolution of PV's on spreadsheet. 30 and 90 day requirement to communicate findings generally met via exit interview which is performed at the end of each inspection and written notice via compliance letter to company officer. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Reviewed inspection documentation and associated correspondence. Compliance actions correlate with numbers submitted under Attachment 5 of the Progress Report. 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Correspondence to operators outline procedures for challenging where a penalty or corrective action has been recommended. 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 No issues - The PM understands the process for issuing civil penalties. Penalties are considered for repeat violations. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 110414138 2018 Gas State Program Evaluation 1 0 Wyoming Public Service Commission, State of Wyoming, Page: 12#
WY NG Program Evaluation, 2018, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No. As identified in previous evaluations the WYPSC has not demonstrated the use of civil penalties. It was noted in the Chairman's letter for CY's 2014, 2015, 2016, and 2017 evaluations. 7 General Comments: Info Only = No Points Evaluator Notes: Question D-6. One-point deduction for not using enforcement fining authority. Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 13#
WY 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. Section 3 (Specific Instructions for the Inspection of Gas Utilities and Intrastate Gas Pipeline Operators), Part g (Incident/Accident investigations). 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: Each operator is to notify the gas pipeline safety section by telephone. If an incident occurs outside the commission's working hours, the operator contacts an employee of the gas pipeline safety section. The commission provides a list of pipeline staff and their telephone numbers to each operator. No reportable incidents in CY2018. 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: There were no incidents reported in CY2018. 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There were no incidents reported in CY2018. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: N/A. There were no incidents reported in CY2018. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 NA appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. There were no incidents reported in CY2018. The program has demonstrated in the past of maintaining good communications with both AID and WR. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 110414138 2018 Gas State Program Evaluation 1 1 Wyoming Public Service Commission, State of Wyoming, Page: 14#
WY NG Program Evaluation, 2018, page 15Yes = 1 No = 0 Evaluator Notes: Yes, at the NAPSR Western Region meeting and also during the state Pipeline Safety Seminars. 8 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part E. N/A's on questions 3,4,5,and 6. Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 15#
WY NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Question covered in IA under O&M Procedures. 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. Covered under relevant IA module Records/O&M. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 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: As noted in previous evaluations, The program utilizes the PHMSA One Call Grant award to purchase advertising to promote the use of the Wyoming One Call system. The program attends the annual state One Call meeting. 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: The WYPSC does a good job collecting data and trends via spreadsheet. The information obtained is from operators' Annual Reports. 5 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 16#
WY 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: Walden Gas Utility Name of State Inspector(s) Observed: Perry McCollom Location of Inspection: Walden, CO (Records), GT & GD facilities along State Route 230. Date of Inspection: 9/18/2019 Name of PHMSA Representative: David Lykken Evaluator Notes: Observed a portion of a standard inspection on both the records and field of the Walden Gas Utility Gas Transmission Line and Distribution facilities located in Wyoming. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. The company was notified and was represented during the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the IA application was used for this inspection. Questions selection: Baseline Records, Baseline Field, and OQ Field (Form 15) Directives utilized. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Observed partial inspection. Complete results still to be recorded. Recommend noting specific operator records reviewed in notes section. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, testing and safety equipment calibrations/dates were verified. 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes. Consisted of records review, right-of-way (ROW) inspection, Regulator stations, pipe-to-soil potential readings, valve inspection, meter location (protection from potential snow damage). DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 17#
WY NG Program Evaluation, 2018, page 187 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Inspector demonstrated good knowledge of regulations and program specifics. 2 2 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: 1 1 Issues communicated to operator during initial briefing after records review. Potential NOPV's and AOC's to be determined. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Potential PV identified related to the pressure testing of new PE services. Areas of Concern identified related to availability of records, OQ PE joining re-qualifications. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 18#
WY NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: No issues. The inspector conducted a though inspection. Encouraged inspector to provide additional detail in IA inspection notes in IA to better support SAT results such as noting specific operator records reviewed. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 19#
WY 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: N/A. Does not have a interstate agent agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. Does not have a interstate agent agreement. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Part H is N/A. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 20#
WY 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: N/A. State does not have a 60106 agreement. 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: N/A. State does not have a 60106 agreement. 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: N/A. State does not have a 60106 agreement. 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: N/A. State does not have a 60106 agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A. State does not have a 60106 agreement. 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: N/A. State does not have a 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Part I is N/A. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110414138 2018 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 21#
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