2023 Program Evaluation

1200 New Jersey Avenue SE
Washington DC 20590
U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
2023 Gas State Program Evaluation
for
IDAHO PUBLIC UTILITIES COMMISSION
Document Legend
PART:
O -- Representative, Dates and Title Information
A -- Progress Report and Program Documentation Review
B -- Program Inspection Procedures
C -- State Qualifications
D -- Program Performance
_ E -- Field Inspections
F -- Damage prevention and Annual report analysis
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2023 Gas State Program Evaluation -- CY 2023
Gas
State Agency: Idaho Rating:
Agency Status: 60105(a): Yes 60106(a): No Interstate Agent:No
Date of Visit: 04/02/2023 -04/04/2023
Agency Representative: Jeff Brooks
PHMSA Representative: Joe Subsits
Commission Chairman to whom follow up letter is to be sent:
Name/Title: Eric Anderson,President
Agency: Idaho Public Utilities Commission
Address: 11331 W Chinden Blvd. Bldg 8, Suite 201A
City/State/Zip: Boise, ID 83714
INSTRUCTIONS:
Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety
program evaluations. The evaluation should generally reflect state program performance during CY 2023
(not the status of performance at the time of the evaluation).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 than the maximum points, include a brief explanation in the
appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all
responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program
performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline
safety programs conduct and execute their pipeline safety responsibilities (their 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 0 0
B Program Inspection Procedures 15 15
C State Qualifications 10 10
D Program Performance 50 50
E Field Inspections 15 15
F Damage prevention and Annual report analysis 10 10
_ TOTALS 100 100
StateRating................................................................................................................................................... 100.0
C
C
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PART A - Progress Report and Program Documentation
Points(MAX) Score
Review
1 Were the following Progress Report Items accurate?(*items not scored on progress Info Only Info Only
report)
Info Only=No Points
a. Stats On Operators Data-Progress Report Attachment 1
b. State Inspection Activity Data-Progress Report Attachment 2
C. List of Operators Data-Progress Report Attachment 3*
d. Incidents/Accidents Data-Progress Report Attachment 4*
e. Stats of Compliance Actions Data-Progress Report Attachment 5*
f. List of Records Kept Data-Progress Report Attachment 6 *
g. Staff and TQ Training Data-Progress Report Attachment 7
h. Compliance with Federal Regulations Data-Progress Report Attachment 8
i. Performance and Damage Prevention Question Data-Progress Report
Attachment 10*
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
h.Unsatisfactory,4 progress report points were deducted for not meeting Civil Penalty requirements.
i. Satisfactory
Total points scored for this section: 0
Total possible points for this section: 0
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PART B - Program Inspection Procedures Points(MAX) Score
1 Do written procedures address pre-inspection,inspection and post inspection activities 5 5
for each of the following inspection types: Chapter 5.1
Yes=5 No=0 Needs Improvement=1-4
a. Standard Inspections,which include Drug/Alcohol,CRM and Public
Awareness Effectiveness Inspections
b. TIMP and DIMP Inspections(reviewing largest operator(s)plans annually)
C. OQ Inspections
d. Damage Prevention Inspections
e. On-Site Operator Training
f. Construction Inspections(annual efforts)
g. LNG Inspections
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
2 Do written procedures address inspection priorities of each operator,and if necessary 4 4
each unit,based on the following elements and time frames established in its procedures?
Chapter 5.1
Yes=4 No=0 Needs Improvement=1-3
a. Length of time since last inspection
b. Operating history of operator/unit and/or location(includes leakage,incident
and compliance activities)
C. Type of activity being undertaken by operators(i.e. construction)
d. Locations of operator's inspection units being inspected-(HCA's,Geographic
area,Population Centers,etc.)
e. Process to identify high-risk inspection units that includes all threats-
(Excavation Damage,Corrosion,Natural Forces,Outside Forces,Material and Welds,
Equipment,Operators and any Other Factors)
f. Are inspection units broken down appropriately?
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
3 (Compliance Procedures)Does the state have written procedures to identify steps to be 3 3
taken from the discovery to resolution of a probable violation?Chapter 5.1
Yes=3 No=0 Needs Improvement=1-2
a. Procedures to notify an operator(company officer)when a noncompliance is
identified
b. Procedures to routinely review progress of compliance actions to prevent
delays or breakdowns
C. Procedures regarding closing outstanding probable violations
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
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4 (Incident/Accident Investigations)Does the state have written procedures to address state 3 3
actions in the event of an incident/accident?
Yes=3 No=0 Needs Improvement=1-2
a. Mechanism to receive,record,and respond to operator reports of incidents,
including after-hours reports
b. If onsite investigation was not made,do procedures require on-call staff to
obtain sufficient information to determine the facts to support the decision not to go
on-site.
Evaluator Notes:
a. Satisfactory
b. Satisfactory
5 General Comments: Info Only Info Only
Info Only=No Points
Evaluator Notes:
No Issues
Total points scored for this section: 15
Total possible points for this section: 15
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PART C - State Qualifications Points(MAX) Score
I Has each inspector and program manager fulfilled training requirements?(See Guidelines 5 5
Appendix C for requirements)Chapter 4.3
Yes=5 No=0 Needs Improvement=1-4
a. Completion of Required OQ Training before conducting inspection as lead
b. Completion of Required DIMP/IMP Training before conducting inspection as
lead
C. Completion of Required LNG Training before conducting inspection as lead
d. Root Cause Training by at least one inspector/program manager
e. Note any outside training completed
f. Verify inspector has obtained minimum qualifications to lead any applicable
standard inspection as the lead inspector(Reference State Guidelines Section 4.3.1)
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Staff attended the SIEO Corrosion conference in Sun Valley. Matt and Jeff also attended NACE CP training.
£ Satisfactory
2 Did state records and discussions with state pipeline safety program manager indicate 5 5
adequate knowledge of PHMSA program and regulations?
Yes=5 No=0 Needs Improvement=1-4
Evaluator Notes:
Satisfactory
3 General Comments: Info Only Info Only
Info Only=No Points
Evaluator Notes:
No issues
Total points scored for this section: 10
Total possible points for this section: 10
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PART D - Program Performance Points(MAX) Score
1 Did state inspect all types of operators and inspection units in accordance with time 5 5
intervals established in written procedures?Chapter 5.1
Yes=5 No=0 Needs Improvement=1-4
a. Standard(General Code Compliance)
b. Public Awareness Effectiveness Reviews
C. Drug and Alcohol
d. Control Room Management
e. Part 193 LNG Inspections
f. Construction(did state achieve 20%of total inspection person-days?)
g. OQ(see Question 3 for additional requirements)
h. IMP/DIMP(see Question 4 for additional requirements)
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
h. Satisfactory
2 Did inspection form(s)cover all applicable code requirements addressed on Federal 10 10
Inspection form(s)?Did State complete all applicable portions of inspection forms?
Chapter 5.1.Do inspection records indicate that adequate reviews of procedures,records
and field activities,including notes and the appropriate level of inspection person-days
for each inspection,were performed?
Yes=10 No=0 Needs Improvement=1-9
a. Standard(General Code Compliance)
b. Public Awareness Effectiveness Reviews
C. Drug and Alcohol
d. Control Room Management
e. Part 193 LNG Inspections
_ f. Construction
g. OQ(see Question 3 for additional requirements)
h. IMP/DIMP(see Question 4 for additional requirements)
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
h. Satisfactory
3 Is state verifying monitoring(Protocol 9/Form15)of operators OQ programs?This 2 2
should include verification of any plan updates and that persons performing covered tasks
(including contractors)are properly qualified and requalified at intervals established in
the operator's plan.49 CFR 192 Part N
_ Yes=2 No=0 Needs Improvement=1
Evaluator Notes:
Satisfactory
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4 Is state verifying operator's integrity management Programs(IMP and DIMP)?This 2 2
should include a review of plans,along with monitoring progress.In addition,the review
should take in to account program review and updates of operator's plan(s).49 CFR 192
Subparts O and P
Yes=2 No=0 Needs Improvement=1
a. Are the implementation plans of the state's large/largest operators(s)being
reviewed annually to ensure they are completing full cycle of the IMP process?
b. Are states verifying with operators any plastic pipe and components that have
shown a record of defects/leaks and mitigating those through DIMP plan?
C. Are the states verifying operators are including low pressure distribution
systems in their threat analysis?
Evaluator Notes:
a. Idaho has several inspection days attributed IMP activities. I will suggest that a standardized process to review the full
cycle of the IMP process be developed and performed.
b. Satisfactory
c.N/A,no low pressure systems in the state.
5 Did the state review the following(these items are NTSB recommendations to PHMSA 2 2
that have been deemed acceptable response based on PHMSA reviewing these items
during the evaluation process): Chapter 5.1
Yes=2 No=0 Needs Improvement=1
a. Operator procedures for determining if exposed cast iron pipe was examined
for evidence of graphitization and if necessary remedial action was taken;
b. 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);
C. 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;
d. 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;
e. 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;
_ f. Operator procedures for considering low pressure distribution systems in threat
analysis?
g. Operator compliance with state and federal regulations for regulators located
inside buildings?
Evaluator Notes:
a. Satisfactory
p b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
6 Did the State verify Operators took appropriate action regarding advisory bulletins issued 1 1
since the last evaluation?(Advisory Bulletins Current Year)
Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
N/A,No advisory bulletins issues in 2023
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7 (Compliance Activities)Did the state follow compliance procedures(from discovery to 10 10
resolution)and adequately document all probable violations,including what resolution or
further course of action is needed to gain compliance?Chapter 5.1
Yes=10 No=0 Needs Improvement=1-9
a. Were compliance actions sent to company officer or manager/board member if
municipal/government system?
b. Were probable violations documented properly?
C. Resolve probable violations
d. Routinely review progress of probable violations
e. Did state issue compliance actions for all probable violations discovered?
f. Can state demonstrate fining authority for pipeline safety violations?
g. Does Program Manager review,approve and monitor all compliance actions?
(note:Program Manager or Senior Official should sign any NOPV or related
enforcement action)
h. Did state compliance actions give reasonable due process to all parties?
Including"show cause"hearing,if necessary.
i. Within 30 days,conduct a post-inspection briefing with the owner or operator
outlining any concerns
j. Within 90 days,to the extent practicable,provide the owner or operator with
written preliminary findings of the inspection. (Incident investigations do not need to
meet 30/90-day requirement)
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d. Satisfactory
e. Satisfactory
f. Satisfactory
g. Satisfactory
h. Satisfactory
i. Satisfactory
j. Satisfactory
8 (Incident Investigations)Were all federally reportable incidents investigated,thoroughly 10 10
documented,with conclusions and recommendations?
Yes=10 No=0 Needs Improvement=1-9
a. Does state have adequate mechanism to receive and respond to operator reports
of incidents,including after-hours reports?
_ b. Did state keep adequate records of Incident/Accident notifications received?
C. If onsite investigation was not made,did the state obtain sufficient information
from the operator and/or by means to determine the facts to support the decision not
to go on site?
d. Were onsite observations documented?
e. Were contributing factors documented?
f. Were recommendations to prevent recurrences,where appropriate,
documented?
g. Did state initiate compliance action for any violations found during any
incident/accident investigation?
h. Did state assist Region Office or Accident Investigation Division(AID)by
taking appropriate follow-up actions related to the operator incident reports to ensure
accuracy and final report has been received by PHMSA?
i. Does state share any lessons learned from incidents/accidents?
Evaluator Notes:
There were no incidents in 2023. No NRC reports were submitted.
a. Satisfactory
b.N/A,No incidents In 2023
c.N/A,No incidents in 2023
d.N/A,No incidents in 2023
e.N/A,No incidents in 2023
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f.N/A,No incidents in 2023
g.N/A,No incidents in 2023
h. Satisfactory
i. Satisfactory
9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 1 1
or address any noted deficiencies?(If necessary)Chapter 8.1
Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
Satisfactory
10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only
Years?Chapter 8.5
Info Only=No Points
Evaluator Notes:
Satisfactory
11 Has state confirmed transmission operators have submitted information into NPMS Info Only Info Only
database along with changes made after original submission?
Info Only=No Points
Evaluator Notes:
Satisfactory
12 Does the state have a mechanism for communicating with stakeholders-other than state 1 1
pipeline safety seminar?(This should include making enforcement cases available to
public).
Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
Satisfactory
13 Did state execute appropriate follow-up actions to Safety Related Condition(SRC) 1 1
Reports?Chapter 6.7
Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
N/A,No safety related condition occurred in 2023.
14 Was the State responsive to: 1 1
Yes=1 No=0 Needs Improvement=.5
a. Surveys or information requests from NAPSR or PHMSA;and
b. PHMSA Work Management system tasks?
Evaluator Notes:
p a. Satisfactory
b.There were no WMS entries in 2023.
15 If the State has issued any waivers/special permits for any operator,has the state verified 1 1
p conditions of those waivers/special permits are being met?This should include having the
operator amend procedures where appropriate.
Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
There are no Idaho waivers on record..
16 Were pipeline program files well-organized and accessible? Info Only Info Only
Info Only=No Points
Evaluator Notes:
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Satisfactory
17 Discussion with State on accuracy of inspection day information submitted into State 3 3
Inspection Day Calculation Tool(SILT).Has the state updated SICT data?
Yes=3 No=0 Needs Improvement=1-2
Evaluator Notes:
Satisfactory
18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only
site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805
Info Only=No Points
Evaluator Notes:
Satisfactory
19 Did the state encourage and promote operator implementation of Pipeline Safety Info Only Info Only
Management Systems(PSMS),or API RP 1173?This holistic approach to improving
pipeline safety includes the identification,prevention and remediation of safety hazards.
Info Only=No Points
a. https://pipelinesms.org/
b. Reference AGA recommendation to members May 20,2019
Evaluator Notes:
Satisfactory
20 General Comments: Info Only Info Only
Info Only=No Points
Evaluator Notes:
No issues with part D
Total points scored for this section: 50
Total possible points for this section: 50
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PART E - Field Inspections Points(MAX) Score
1 Operator,Inspector,Location,Date and PHMSA Representative(enter specifics into the Info Only Info Only
comments box below)
Info Only=No Points
a. What type of inspection(s)did the state inspector conduct during the field
portion of the state evaluation?(i.e. Standard,Construction,IMP,etc)
b. When was the unit inspected last?
C. Was pipeline operator or representative present during inspection?
d. Effort should be made to observe newest state inspector with least experience
Evaluator Notes:
a.Construction inspection
b.N/A,construction inspection
c.DAS construction of Idaho(MDU contractor on-site)
d.Matt Galli has 2.5 years of experience.
2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2
used as a guide for the inspection?(New regulations shall be incorporated)
Yes=2 No=0 Needs Improvement=1
Evaluator Notes:
Satisfactory
3 Did the inspector adequately review the following during the inspection 10 10
Yes=10 No=0 Needs Improvement=1-9
a. Procedures(were the inspector's questions of the operator adequate to
determine compliance?)
b. Records(did the inspector adequately review trends and ask in-depth
questions?)
C. Field Activities/Facilities(did inspector ensure that procedures were being
followed,including ensuring that properly calibrated equipment was used and OQ's
were acceptable?)
d. Other(please comment)
e. Was the inspection of adequate length to properly perform the inspection?
Evaluator Notes:
a. Satisfactory
b. Satisfactory
c. Satisfactory
d.N/A
e. Satisfactory
4 From your observation did the inspector have adequate knowledge of the pipeline safety 2 2
program and regulations?(Evaluator will document reasons if unacceptable)
Yes=2 No=0 Needs Improvement=1
Evaluator Notes:
Satisfactory
5 Did the inspector conduct an exit interview,including identifying probable violations?(If 1 1
inspection is not totally completed the interview should be based on areas covered during
time of field evaluation)
_ Yes=1 No=0 Needs Improvement=.5
Evaluator Notes:
Satisfactory
6 Was inspection performed in a safe,positive,and constructive manner? Info Only Info Only
Info Only=No Points
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a. No unsafe acts should be performed during inspection by the state inspector
b. What did the inspector observe in the field?(Narrative description of field
observations and how inspector performed)
C. Best Practices to Share with Other States-(Field-could be from operator
visited or state inspector practices)
d. Other
Evaluator Notes:
a. Satisfactory
b.Matt checked operator qualifications,calibration records,pipe specifications,bedding,pressure testing,procedures,locate
information,project sheet.
c.Procedures and qualifications were in cell phone app.
d.N/A
7 General Comments: Info Only Info Only
Info Only=No Points
Evaluator Notes:
No issues in part E.
Total points scored for this section: 15
Total possible points for this section: 15
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PART F - Damage prevention and Annual report analysis Points(MAX) Score
1 Has the state reviewed Operator Annual reports,along with Incident/Accident reports,for 2 2
accuracy and analyzed data for trends and operator issues.
Yes=2 No=0 Needs Improvement=1
Evaluator Notes:
Satisfactory
2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2
determining root causes and minimizing the possibility of a recurrence?(192.617)
Has the state verified that the operators have appropriately identified excavators who
have repeatedly violated one-call laws and damaged their facilities.Have the operators
taken steps to mitigate that risks?(192.1007)
Yes=2 No=0 Needs Improvement=1
Evaluator Notes:
Satisfactory
3 Has the state reviewed the operator's annual report pertaining to Part D-Excavation 4 4
Damage?
Yes=4 No=0 Needs Improvement=1-3
a. Is the information complete and accurate with root cause numbers?
b. Has the state evaluated the causes for the damages listed under"One-Call
Notification Practices Not Sufficient"(Part D.La.)?
C. Has the state evaluated the causes for the damages listed under"Locating
Practices Not Sufficient"(Part D.Lb)?For each operator,does the state review the
following?
d. Is the operator or its locating contractor(s)qualified and following written
procedures for locating and marking facilities?
e. Is the operator appropriately requalifying locators to address performance
deficiencies?
f. What is the number of damages resulting from mismarks?
g. What is the number of damages resulting from not locating within time
requirements(no-shows)?
h. Is the operator appropriately addressing discovered mapping errors resulting in
excavation damages?
i. Are mapping corrections timely and according to written procedures?
j. Has the state evaluated the causes for the damages listed under"Excavation
Practices Not Sufficient"(Part D.I.e.)?
Evaluator Notes:
a j. Satisfactory
_ 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?
Yes=2 No=0 Needs Improvement=1
a. What stakeholder group is causing the highest number of damages to the
pipelines?Operator,contractor,locating company or public.
b. Has the state verified the operator is appropriately focusing damage prevention
education and training to stakeholders causing the most damages?
p C. Has the state evaluated which of the following best describes the reason for the
excavation damages;i.e.,operator or contractor not following written procedures,
failure to maintain marks,failure to support exposed facilities,failure to use hand
tools were required,failure to test-hole(pot hole),improper backfilling practices,
failure to maintain clearance or insufficient excavation practices.
d. Has the state verified the operator is appropriately focusing damage prevention
education and training to address the causes of excavation damages?
Evaluator Notes:
a.Excavators
b. Satisfactory
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c. Satisfactory
d.Satisfactory
5 General Comments: Info Only Info Only
Info Only=No Points
Evaluator Notes:
No issues with Part F.
Total points scored for this section: 10
Total possible points for this section: 10
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