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Pipeline Safety
2021 Gas Base Grant Progress Report
for
IDAHO PUBLIC UTILITIES COMMISSION
Please follow the directions listed below :
1. Review the entire document for completeness.
2. Review and have an authorized signatory sign and date page 2.
3. Scan the signed document to your computer and email it to Carrie.Winslow@dot.gov.
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Electronic Submission Date:3/2/2022 3:47:00 PM
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OF TRANSA
2 09�
ae 'S Pipeline and Hazardous Materials Safety Administration
Z 1200 New Jersey Avenue,SE
Washington DC 20590
`STATES OF P
OFFICE OF PIPELINE SAFETY
2021 Gas Base Grant Progress Report
Office: IDAHO PUBLIC UTILITIES COMMISSION
Authorized Signature
Printed Name
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Date
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PROGRESS REPORT ATTACHMENTS (GAS)
PHMSA Form No.PHMSA F 999-92
Attachment 1: State Jurisdiction and Agent Status over Facilities.
Attachment 2: State Field Inspection Activity
Attachment 3: Facilities Subject to State Safety Jurisdiction
Attachment 4: Pipeline Incidents
Attachment 5:State Compliance Actions
Attachment 6: State Record Maintenance and Reporting
Attachment 7: State Employees Directly Involved in the Pipeline Safety Program
Attachment 8: State Compliance with Federal Regulations
{there is no attachment 9}
Attachment 10: Performance and Damage Prevention Questions
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Attachment 1 - Stats on Operators
STATE JURISDICTION AND AGENT STATUS OVER GAS FACILITIES AS
OF DECEMBER 31, 2021
State Agency Jurisdiction/ No. of Operators No. of
Operator Type gent Status Operators Inspected Inspection Units Inspected
Units
No' Yes # % # %
Distribution
Private X/60105 3 3 100.0% 10 10 100.0%
Municipal A 0 0 N/A 0 0 N/A
Master Meter X/60105 0 0 N/A 0 0 N/A
LPG X/60105 0 0 N/A 0 0 N/A
Other A 0 0 N/A 0 0 N/A
Transmission
Intrastate X/60105 3 3 100.0% 3 3 100.0%
Interstate F 0 0 N/A 0 0 N/A
LNG
Intrastate X/60105 1 1 100.0% 1 1 100.0%
Interstate A 0 0 N/A 0 0 N/A
Other
Gathering Lines X/60105 1 1 100.0% 1 1 100.0%
Offshore Facilities A 0 0 N/A 0 0 N/A
Total 8 8 100.0% 15 1 15 1100.0%
'Codes: A-None in state and does not have jurisdiction;
B - State does not have jurisdictional authority(Provide current status or action being taken to obtain authority
in notes section below)
F -No, State is currently not an interstate agent.
X/60105P=Yes,I have Section 60105 (Certification)over some of the operator type(meaning: I have 60105
authority over some,but not all of this operator type and do not have a 60106 agreement with PHMSA to inspect
them). These operators are identified in the notes below.
X/IA-Yes, I have Interstate Agent jurisdiction over this type of operator
Distribution"Other" -ie Co-ops,Public Utility Districts, etc.
States should explain any special circumstances
General Instructions -All above facilities should only include facilities as defined by federal pipeline regulations
and should not include extended jurisdiction by state regulation.
Attachment 1 Notes:
Idaho has 5 operators: 1. Avista(distribution only), 2. Dominion(transmission and distribution), 3.Intermountain Gas
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Company(transmission, distribution and LNG), and 4.Northwest Gas Processing(gathering only). 5.New for 2021
Douglas Pipeline added as an operator(transmission only).
-
-
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Attachment 2 - State Inspection Activity
TOTAL STATE FIELD INSPECTION ACTIVITY AS
OF DECEMBER 31, 2021
Design On-Site Damage
Standard Investigating Integrity Operator Incidents or Compliance
Operator Type Testing and Operator Prevention Total
Comprehensive Construction Training Management Qualification Accidents Activities Follow-up
Distribution
Private 131.500 111.000 0.000 9.500 23.000 1.000 2.500 0.000 278.500
Municipal 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
Master Meter 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
LPG 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
Other 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
Transmission
Intrastate 9.500 0.000 0.000 15.000 2.000 0.000 0.000 0.000 26.500
Interstate 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
LNG
Intrastate 5.500 0.000 0.000 0.000 0.000 2.000 0.000 0.000 7.500
Interstate 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
Other
Gathering Lines 12.500 0.000 0.000 0.000 0.500 0.000 0.000 0.000 13.000
Offshore Facilities 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000
Total j 159.000 1 111.000 0.000 24.500 25.500 3.000 2.500 0.000 325.500
C
Drug and Alcohol
Total Count of Drug and Alcohol Inspections 2
Attachment 2 Notes
=Per PHMSA guidance the'training' in our Idaho inspection days tracking was corrected and moved to OQ.
Total count of drug and alcohol were entered for full program I.A. inspections as per PHMSA guidance.
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Attachment 3 - List of Operators
GAS FACILITIES SUBJECT TO STATE SAFETY JURISDICTION AS OF DECEMBER 31, 2021
Distribution TransmissionLNG(Operator type& Other(Operator type
Operator (Operator type&Inspection Units) (Operator type& Inspection Units) &Inspection Units)
Inspection Units)
Business Name Offshore
Operator ID Gathering Facilities
Address Private Municipal
Master Lines Juris- State
LPG Other Intrastate Interstate Intrastate Interstate
Meter dictional Waters
Avista Corporation 5 0 0 0 0 0 0 0 0 0 0
31232
1411 E.Mission, Spokane,WA 99220
Dominion Energy 1 0 0 0 0 1 0 0 0 0 0
12876
1040 W.200 S., Salt Lake City,UT 84145
Douglas Pipeline Co 0 0 0 0 0 1 0 0 0 0 0
31442
_ 3829 Willow Ave Suite 203, Pittsburg,PA 15234
Intermountain Gas Company 5 0 0 0 0 1 0 1 0 0 0
8160
555 South Cole, Boise,ID 83707
Northwest Gas Processing,LLC 0 0 0 0 0 0 0 0 0 1 0
39370
15021 Katy Freeway,Suite 400 Houston,TX 77094
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Distribution Transmission LNG(Operator type& Other(Operator type
(Operator type&Inspection Units) (Operator type& Inspection Units) &Inspection Units)
Inspection Units)
Offshore
Gathering Facilities
Master Lines(Juris- (State
Private Municipal LPG Other Intrastate Interstate Intrastate Interstate
Meter dictional) Waters
Inspection Unit totals by type 11 0 0 0 1 0 3 0 1 0 1 0
Total Operators 5
Attachment 3 Notes:
Avista now has(5)different inspection units which has changed from 4. (2)of them have been and still are often
grouped for logistical reasons and proximity.
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Attachment 4 - Incidents/Accidents
SIGNIFICANT' GAS INCIDENTS/ACCIDENTS JANUARY 1,THROUGH DECEMBER 31,2021
Date of Location- System Injuries FatalitiesProperty Operator State
Incident City/County/etc. Type # # Damage' Cause Cause
$ Code' Code'
02/17/2021 NO LOCATION LNG 0 0 $3,978,532.00 Al Al
Name of Operator: INTERMOUNTAIN GAS CO
Operator ID: 8160 Report No: 20210003
Summary2
On Thursday,February 4, 2021 a Plant Operator was working on the roof of the LNG tank and audibly
and visually
discovered a non-hazardous leak. The non-hazardous leak is under a steel backing plate that is welded
to the roof of the
LNG tank. The backing plate is part of the support system for the walking platform. Because the
backing plate is not fully
welded,water accumulated between the backing plate and the LNG tank roof,ultimately leading to a
non-hazardous
corrosion leak. An estimated 300 CFH is venting to the atmosphere.
Intermountain Gas Company(IGC)hired an engineering consultant on February 11,2021 to evaluate
repair options. On
February 17,2021 at 11:10 a.m. MST,using data provided by the engineering consultant,IGC
determined the LNG tank
will be taken out of service to make repairs,which is expected to exceed$50,000, at which time IGC
notified the NRC.As of February 17, 2021,the LNG tank had 3,093,114 gallons of LNG. To allow for
the offload and vaporization of the
LNG,the LNG tank will be taken out of service in June 2021.
The estimated volume of commodity released unintentionally(Part A, Question 9)is 201.6 MCF as of
March 4,2021.
p This quantity will be revised for the Final report.
Estimated cost of Operator's property damage&repairs(Part C, Question Lb.)is $500,000. This cost
will be revised for
the Final report.
03/01/2021 GOSHEN GD 0 0 $26,495.00 F 1 F 1
_ Name of Operator: INTERMOUNTAIN GAS CO
Operator ID: 8160 Report No: 20210031
Summary'
Intermountain Gas Company(IGC)was notified of an outside gas odor in Goshen,ID (an
unincorporated community in Bingham
p County) at 18:07 on February 27,2021.After arriving on site at 18:51, a Company first responder
_ found a 3"relief valve at a
district regulator in the full open position at which time additional personnel was dispatched to the
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scene. The regulators at the
location of the relief valve were inspected and found to be operating correctly. Company personnel
then began inspecting the
regulators at a regulator station located 3.7 miles west of the blowing relief valve that supplies gas to
the same 200 psig MAOP
pipeline. The primary regulator at the second regulator station was shut in at 21:45 at which time the
system pressure dropped to
170 psig; however,the relief valve was still in the open position. The relief valve was isolated at 12:28
on February 28,2021. It
was determined hydrocarbons had accumulated and froze causing the relief valve to stick in the open
position.
The morning of March 1, 2021 Company personnel inspected and repaired the primary regulator at the
second regulator station. A
yellow/white powder was found on the seat, diaphragm and pilot components which was the cause of
the regulator failure that
resulted in the relief valve opening. The powder was cleaned off all surfaces and the soft components
were replaced.
At 11:52 on March 1, 2021 the engineering department calculated the gas loss for this release at which
time it was discovered the
3 million cubic feet reporting threshold was exceeded.
10/28/2021 RATHDRUM GD 0 0 $778,199.00 C3 C1
Name of Operator: AVISTA CORP
Operator ID: 31232 Report No: 20210098
Summary'
At approximately 10:00 a.m. PDT on October 28,2021,PG Contractors, a third-party contractor,was
installing
telecommunications infrastructure using a horizontal directional drill when they severed a 2"
polyethylene(PE)main at the
intersection of Christine Street and Beechwood Street in front of 6997 W Christine St.,Rathdrum,
Idaho. The PE pipe operated at
a pressure of approximately 55 psig with an MAOP of 60 psig,was at a depth of 36 inches, and locate
marks were present and
accurate.Avista was notified at 10:13 a.m. PDT and was on site at 10:20 a.m. PDT. The Northern
Lakes Fire District responded
and evacuated 3 nearby residences at 6971, 6997 and 7025 W Christine Street. The location of the
damage required squeezing
the 2" main in three locations as it was close to a tee. The squeezes were complete at 11:43 a.m. PDT
to control the flow of gas.
The fire department left once the scene was secure.Underground barhole readings were taken in front
of the three evacuated
houses and showed 0 percent LEL. Inside gas readings were taken at 6997 W Christine Street at
approximately 12:10 p.m. PDT
and showed readings between 10%and 70%LEL. The Gas Serviceman exited the house and left the
doors open to air out the
house.
At approximately 12:30 p.m.PDT the homeowners at 7025 W Christine Street came home and
requested to enter their house.A
Gas Serviceman checked each room of the house with a combustible gas indicator and found readings
of 0%LEL, so the Gas
_ Serviceman cleared the house for the homeowners to reenter.
Shortly thereafter,the homeowners at 6997 W Christine Street requested to get back into their house.
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The Gas Serviceman
checked each room with a combustible gas indicator,which now read 0%LEL and he allowed the
homeowners back in their
house. At this time,the gas and electricity were still shut off to the house and the electric meter had to
be re-installed. After
turning the electricity back on the homeowner reported popping noises coming from the furnace. The
Gas Serviceman checked
near the furnace and found 0%LEL and decided to turn the furnace off at the thermostat.While
entering the house from the
Form PHMSA F 7100.1 (rev 4-2019)Page 12 of
12
Reproduction of this form is permitted
garage,the Gas Serviceman saw a red glow above his head which was an ignition of gas at
approximately 12:46 p.m. PDT. The
Gas Serviceman exited through the open garage door and the male homeowner exited through the rear
garage access door.
Individuals on scene then helped to get the female homeowner out of the upstairs of the house through
a window. Shortly
thereafter the building was consumed by flames. Operator personnel on scene called 911 immediately
after the gas ignited and
the Northern Lakes Fire District was on scene at approximately 12:57 p.m.PDT. The female
homeowner was assessed by EMTs
on site and the male homeowner went to the hospital to be treated for second degree burns on his
forearm but was not admitted.
Preliminary investigation suggests that there was a pocket of gas inside the house in a location that
could not be detected by the
Gas Serviceman's instrument. It was that pocket of gas that ignited causing the fire. The building was
deemed a total loss with a
value exceeding$122,000 resulting in this incident being reportable. Avista denies liability for
damages and injuries associated
with this incident.
'High Level Cause Codes: A-Corrosion failure; B-Natural Force Damage; C-Excavation Damage; D-Other
Outside Force Damage; E-Pipe,Weld or Joint Failure; F-Equipment Failure; G-Incorrect Operation; H-Other
Incident Cause; IP-Investigation Pending;
2Please include a summary or report of the state agency's investigation of each of the above incidents.
='Interstate agents should use the 191.3 Incident definition for listing incidents investigated on interstate facilities.
Attachment 4 Notes
p The LNG incident is considered to be located in Nampa,ID.
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Attachment 5 - Stats on Compliance Actions
STATE COMPLIANCE ACTIONS -- CALENDAR YEAR (CY) 2021
Probable Violation Categories Intrastate Interstate
Number carried over from all previous CY's 0 0
Number Found During CY 12 0
Number submitted for DOT action [60106 Agreement agent 0 0
only]
Number corrected during CY(including carry over from 12 0
previous year(s))
Number to be corrected at end of CY(including carry over) 0 0
Number of Compliance Actions Taken '
(see definition) 12
Civil Penalties
Number assessed during CY 0
Dollars assessed during CY $0.00
Number collected during CY 0
Dollars collected during CY $0.00
'Do not double count for a related series of actions.
Attachment 5 Notes
(12) separate compliance notices and letters during the CY.
p IPUC also recieved a whistleblower complaint regarding OQ compliance. IPUC conducted an investigation of
these claims. The case is continuing into the next year. Civil penalties are expected pending commission
approval.
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Attachment 6 - List of Records Kept
GAS STATE RECORD MAINTENANCE AND REPORTING DURING CY 2021
Records Maintained by the State Agency
Pipeline Safety Program Annual Certification/Progress Report
Operator Annual Reports
Common Ground Alliance
Compliance Actions
Damage Prevention Program
Inspection Field Days
Annual Inspection Schedule
Operator Incident/Accident
PHMSA Correspondence
PUC Pipeline Safety Program Plan(POP)
PHMSA Program Evaluation
OPS Grants-Base Grant Application
Safety Related Condition Reports
Pipeline Training
T& Q Seminars
NAPSR Surveys
Inspection Reports: 2017,2018, 2019, 2020, 2021
Reports Required from Operators
Incident Reports as per IPUC rule
Operators Annual Reports
Attachment 6 Notes
NAPSR Surveys are conducted online. A receipt is not always given from the Survey Monkey website for
Idaho retention.
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Attachment 7 - Staffing and TQ Training
STATE EMPLOYEES DIRECTLY INVOLVED IN THE GAS PIPELINE
SAFETY PROGRAM DURING CY 2021
Name/Title % ft Qual.
Time Months Cat.
Supervisor
Jeff Brooks
Program Manager 50.0001 0.5 1 NA
Ulmer,Darrin
Program Manager 40.0001 8 1 NA
Inspector/Investigator
Jeff Brooks
Inspector 98.0001 12 1 111
Perkins,Bruce
Inspector ,100.0001 12 1 II
Ulmer,Darrin
Inspector 160.0001 8 II
Summary
Employee Type No. of Staff Person-Years
� Supervisor 2 0.290
Damage Prevention/Technical 0 0.000
Inspectors/Investigators 3 2.380
Clerical/Administrative 0 0.000
Total 5 2.670
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Attachment 7 Notes
Kyle Russo was not with the program in 2021 -he left prior to 2021. Darrin Ulmer left the program in September. Jeff Brooks was the new
program manager as of the middle of December 2021.
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Attachment 8 - Compliance with Federal Regulations
STATE COMPLIANCE WITH FEDERAL REQUIREMENTS AS OF DECEMBER 31, 2021
No. Effective Impact Adoption AdoptionStatus
Date Date
Maximum Penalties Substantially same as DOT ( 225,134/ 2,251,334). State
1 must adopt minimum penalties of at least($100,000/$1,000,000).Indicate actual 04/1970 Adopted Other
amount in notes.
Note' $2,000 per each violation per day the violation persists. $200,000 maximum for any related series of violations.
2 Part 192 Amendments
1-115 Pre 2011 [All applicable amendments prior to and including 2010] 12/31/2010Adopted
Note'
116-76 FR 5494 4/4/2011 Mechanical Fitting Failure Reporting Requirements 04/2012 Adopted
Note'
117-76 FR 35130 8/15/2011 Control Room Management/Human Factors 04/2013 Adopted
Note'
Administrative Procedures Updates, and Technical Corrections(Not
118 -78 FR 58897 10/25/2013 applicable to States) 04/2016 Adopted
Note'
119 - 80 FR 168 3/6/2015 Periodic Updates of Regulatory References to Technical Standards and 04/2016 Adopted
Miscellaneous Edits
_ Note'
Miscellaneous Changes to Pipeline Safety Regulations (Part 192.305
C 120- 80 FR 12779 10/1/2015 DELAYED) 04/2016 Adopted
Note'
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121 - 81 FR 70989 4/14/2017 Expanding the Use of Excess Flow Valves in Gas Distribution 07/2018 Adopted
Systems to Applications Other Than Single-Family Residences
Note'
123 - 82 FR 7972 3/24/2017 Operator Qualification, Cost Recovery,Accident and Incident 07/2018 Adopted
Notification, and Other Pipeline Safety Changes
Note'
124- 83 FR 58694 1/22/2019 Use of Plastic Piping Systems in the Transportation of Natural and 07/2021 Adopted
Other Gas
Note' Adopted through CFR and Commission Safety Regulations Order 35095 (Rule 201). Code of Federal Regulations have been updated to the
most current annual editions.
Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP
125 - 84 FR 52180 7/l/2020 Reconfirmation,Expansion of Assessment Requirements, and Other 07/2021 Adopted
Related Amendments
Adopted through CFR and Commission Safety Regulations Order 35095 (Rule 201). Code of Federal Regulations have been updated to the
Note most current annual editions.
126- 86 FR 2210 3/12/2021 Pipeline Safety: Gas Pipeline Regulatory Reform(Delayed to 3/21) 07/2021 Adopted
(Delayed Compliance date 10/12/2021)
Note' Adopted through CFR and Commission Safety Regulations Order 35095 (Rule 201). Code of Federal Regulations have been updated to the
most current annual editions.
3 Part 193 Amendments(applicable only where state has jurisdiction over LNG)
1-23 Pre 2011 [All applicable amendments prior to and including 2010] 12/2010 Adopted
Note'
24-78 FR 58897 10/25/2013 Administrative Procedures, Updates, and Technical Corrections 04/2016 Adopted
Note'
p Periodic Updates of Regulatory References to Technical Standards and
25 - 80 FR 168 3/6/2015 Miscellaneous Edits 04/2016 Adopted
Note'
4 Part 199 -Drug Testing 03/2001 Adopted
Note'
p 5 Part 199 Amendments
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1-24 Pre 2011 [All applicable amendments prior to and including 2010] 12/2010 Adopted
Note'
25 -78 FR 58897 10/25/2013 Administrative Procedures, Updates, and Technical Corrections 04/2016 Adopted
Note'
26- 80 FR 168 3/6/2015 Periodic Updates of Regulatory References to Technical Standards and 04/2016 Adopted
Miscellaneous Edits
Note'
27- 82 FR 7972 3/24/2017 Operator Qualification, Cost Recovery,Accident and Incident 07/2018 Adopted
Notification,and Other Pipeline Safety Changes
Note'
Conforming Amendments and Technical Corrections to Department
28 - 84 FR 16770 4/23/2019 Rules Implementing the Transportation Industry Drug Testing 07/2021 Adopted
Program
Note' Commission Safety Regulations Order 35095 is expected to be amended within the year 2022 to incorporate by reference the pipeline safety
Code of Federal Regulations to the most current eCFR editions.
6 State Adoption of Part 198 State One-Call Damage Prevention Program
a. Mandatory coverage of areas having pipeline facilities 04/1990 Adopted
Note'
b. Qualification for operation of one-call system 04/1990 Adopted
Note'
C. Mandatory excavator notification of one-call center 09/1990 Adopted
Note'
C d. State determination whether calls to center are toll free 04/1991 Adopted
Note'
p e. Mandatory intrastate pipeline operator participation 04/1990 Adopted
Note'
f. Mandatory operator response to notification 04/1990 Adopted
Note'
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g. Mandatory notification of excavators/public 07/2002 Adopted
Note'
h. Civil penalties/injunctive relief substantially same as DOT 07/2018 Adopted but Different Dollar Amounts
Note' Current law provides for$1,000 penalty for second occurance; $5,000 for any subsequent occurrences.
'If Adoption Status is No,Please provide an explanation
State Attendance at 2021 NAPSR Regional Meeting: Attended full time(Lead rep or alternative pipeline staff)
Frequency of General Legislative Session: Annually
Attachment 8 Notes
Commission Safety Regulations Order 35095 (July, 2021)is expected to be amended within the year 2022 to incorporate by reference the Title 49 pipeline safety Code
of Federal Regulations to the most current eCFR editions.
Commission Safety Regulations Order 35095 is expected to be amended within the year 2022 to incorporate by reference the pipeline safety Code of Federal
Regulations to the most current eCFR editions.
All enforcement authority for damage prevention is held within Idaho Division of Building Safety's Damage Prevention Board. The Commission does hold a seat on
the 11 person board but does not have any directive authority over it.
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Attachment 10 - Performance and Damage Prevention Questions
CALENDAR YEAR (CY) 2021
Planned Performance: What are your Planned Annual and Long-term goals for your Pipeline Safety Program?
The IPUC Pipeline Safety Program is committed to improving our safety program. The Commission's annual goals are to ensure
Idaho jurisdictional pipeline operators are providing the safe transportation and delivery of natural gas to its customers and doing this
without affecting the safety of the public. This is accomplished by a comprehensive program of inspections and audits of the
companies'records and field equipment and following-up on each incident and non-compliance found. The Commission has added a
new operator into their inspection plan. The Commission's inspection staff will continue conducting construction inspections,follow-
up inspections of the high-pressure service sets(HPSS/farm taps)and will continue to attend the construction of the renewable natural
gas pipelines. The Commission's goal is to get a new inspector hired to begin the TQ learning path and be able to lead basic
inspections with the long term goal of maintaining a full inspection staff.
Past Performance: What did the Pipeline Safety Program accomplish during the subject year(to this document)to contribute
toward the program's annual and long-term goals?
Five Intrastate operators within the Commission's jurisdiction were inspected for the safe transportation and delivery of natural gas
within the state according to the Commission's approved program of operating procedures. Any deficiencies found were documented
and discussed with the operators for corrective action(s).Follow-up inspections were performed as required. IPUC inspectors
completed 13 T&Q courses in 2021.The PUC's program manager vacated the position but was replaced with one of the existing PUC
inspectors.The PUC is attempting to hire a third inspector to fill the vacancy.
1. Has the state or agency reviewed the Damage Prevention Assistance Program(DPAP)document in the last twelve months?
No
2. Has the state or agency developed or is in the process of developing a plan to address the nine elements contained in the PIPES
Act of 2006 for an effective State Damage Prevention Program?
Yes
If yes to question 2,where does the state or agency stand on implementation of the nine elements contained in the PIPES Act of
2006? Please provide a description of how the state or agency has or will meet each element. If not,please provide a brief passage
explaining the reasons why the state or agency has not.
The Commission has continued to participate in the statewide coalition for damage prevention but does not have statutory authority to
develop a State Damage Prevention Program that would have any enforcement ability. All enforcement authority for damage
prevention is held within Idaho Division of Building Safety's Damage Prevention Board. The Commission does hold a seat on the
board but would not have any directive authority over it. The board's objective plan has addressed the nine elements for an effective
State Damage Prevention Program. The Commission supports the program through an alliance with(two)one-call centers,Operator's
public awareness programs,and utility coordinating councils. The goal of the coalition is to improve the underground damage
p prevention law,eliminate as many exemptions as possible,educate the public and establish an effective enforcement mechanism in
accordance with the 9 elements contained in the PIPES Act. During annual audit(s)of each operator,the Commission continues to
review operator's damage prevention program against rules and standards to ensure the programs processes are in place and effective.
Noted deficiency(s)are documented on the IPUC Form 1 and the appropriate section of the PHMSA checklist. Significant process
deficiencies result in immediate corrective actions and if needed a compliance action. Procedures for probable violation process
established in the Commission's program operating procedures will be followed.
Attachment 10 Notes
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