2016 Program Evaluation.pdf

DUNS: 102589939
2016 Gas State Program Evaluation
Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 1
1200 New Jersey Avenue SE Washington DC 20590
U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
2016 Gas State Program Evaluation

for

IDAHO PUBLIC UTILITIES COMMISSION
Document Legend
PART:
O --Representative Date and Title Information
A --Progress Report and Program Documentation Review
B --Program Inspection Procedures
C --Program Performance
D --Compliance Activities
E --Incident Investigations
F --Damage Prevention
G --Field Inspections
H --Interstate Agent State (If Applicable)
I --60106 Agreement State (If Applicable)
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Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2
2016 Gas State Program Evaluation -- CY 2016
Gas
State Agency: Idaho Rating:
Agency Status:60105(a):Yes 60106(a):No Interstate Agent:No
Date of Visit:06/05/2017 - 06/08/2017
Agency Representative:June 13, 2017
Mr. Joe Leckie
Pipeline Safety Program Manager
PHMSA Representative:June 13, 2017
Clint Stephens
State EvaluatorCommission Chairman to whom follow up letter is to be sent:Name/Title:Mr. Paul Kjellander, PresidentAgency:Idaho Public Utilities CommissionAddress:472 West Washington Street, P.O. Box 83720
City/State/Zip:Boise, Idaho 83720-0074
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 2016 (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.
Field Inspection (PART G):
The field inspection form used will allow different areas of emphasis to be considered for each question.
Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA
representative should include a written summary which thoroughly documents the inspection.
Scoring Summary
PARTS Possible Points Points Scored
A Progress Report and Program Documentation Review 10 10BProgram Inspection Procedures 13 13CProgram Performance 49 43DCompliance Activities 15 15EIncident Investigations 11 11FDamage Prevention 8 8GField Inspections 12 12HInterstate Agent State (If Applicable)0 0I60106 Agreement State (If Applicable)0 0TOTALS118112
State Rating ...................................................................................................................................................94.9
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PART A - Progress Report and Program Documentation
Review Points(MAX)Score
1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress
Report Attachment 1
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Data is accurate and all units were inspected in calendar year 2016 .
2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Review of inspection days was analyzed to differentiate construction days with standard inspections. Review of inspection
days was found to be accurate
3 Accuracy verification of Operators and Operators Inspection Units in State - Progress
Report Attachment 3
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
Operators and operator inspection units are accurate in Attachment 3 of Progress Report.
4 Were all federally reportable incident reports listed and information correct? - Progress
Report Attachment 4
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
All incident reports were listed and information was correct.
5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
There were two compliance actions that were found to be accurate from Attachment 5 of Progress Report.
6 Were pipeline program files well-organized and accessible? - Progress Report
Attachment 6
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:All pipeline program files were well-organized and accessible. These files were kept in paperback form in cabinet drawer 3
in inspector's office and by Program Manager.
7 Was employee listing and completed training accurate and complete? - Progress Report
Attachment 7
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Employee listings and completed training was accurate and complete. New employee Bruce Perkins started employment in
October 2016
8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report
Attachment 8
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Idaho's rules and amendments for adoption has been reported accurately.
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9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:The Program Manager stated that he had reviewed the DPAP in 2016, but Attachment 10 states 'No'. Carrie Winslow was
contacted on June 13, 2017 to change response. Idaho is in the process of identifying new master meters (universities) for
jurisdiction. Idaho is still working with State Legislature to increase civil penalty to meet DOT guidelines. The State has put
an emphasis on inspecting Intermountain Gas due to the number of farm taps which are not being inspected by operator.
10 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:There were no issues identified in Part A of the IPUC Program evaluation.

Total points scored for this section:10
Total possible points for this section:10
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PART 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.
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Process for Standard Inspections is included in Sections 3.8, 7.2, and Attachment E of Program Operation Procedures (POP).
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.
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
Process for IMP/DIMP Inspections is included in Sections 3.10, 7.2, and Attachment E of POP.
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.
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Process for OQ Inspections is included in Sections 3.9, 7.2, and Attachment E of POP.
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.
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Process for Damage Prevention Inspections is included in Sections 3.12, 7.2, and Attachment E of POP.
5 Any operator training conducted should be outlined and appropriately documented as
needed.
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
Process for On-Site Operator Training is included in Sections 3.13, 7.2, and Attachment E of POP.
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.
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Process for Construction Inspections is included in Sections 3.11, 7.2, and Attachment E of POP.
7 Does inspection plan address inspection priorities of each operator, and if necessary each
unit, based on the following elements?
6 6
Yes = 6 No = 0 Needs Improvement = 1-5
a. Length of time since last inspection (Within five year interval)Yes No Needs Improvementb. Operating history of operator/unit and/or location (includes leakage, incident and
compliance activities)Yes No Needs Improvement
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c. Type of activity being undertaken by operators (i.e. construction)Yes No Needs
Improvementd. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc)Yes No Needs
Improvemente. 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)
Yes No Needs
Improvement
f. Are inspection units broken down appropriately?Yes No Needs
ImprovementEvaluator Notes:Process for Inspection priorities is included in Sections 8.0 of POP. Idaho has a risk based inspection procedure that has not
been implemented into the inspection priority process. Idaho will start to incorporate a risk based approach when
establishing inspection priorities. Attachment B in the POP is used to score the risk based analysis.
8 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
There were no issues identified in Part B of the IPUC Program evaluation.
Total points scored for this section:13Total possible points for this section:13
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PART 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 5 0
Yes = 5 No = 0
A. Total Inspection Person Days (Attachment 2):262.00
B. Total Inspection Person Days Charged to the Program (220 X Inspection Person
Years) (Attachment 7):220 X 3.39 = 746.17
Ratio: A / B
262.00 / 746.17 = 0.35
If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0
Points = 0Evaluator Notes:Ratio of Total Inspection person days does not meet requirement >=.38. Ratio = A/B = 262/ (220 x 3.39) = 262/745.8 = .35.
Idaho will appeal results based on inspectors being at T&Q Training over half of the year in 2016.
2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See Guidelines Appendix C for requirements) Chapter 4.4 5 5
Yes = 5 No = 0 Needs Improvement = 1-4
a. Completion of Required OQ Training before conducting inspection as lead?Yes No Needs Improvementb. 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 Improvemente. Verify inspector has obtained minimum qualifications to lead any applicable
standard inspection as the lead inspector.Yes No Needs Improvement
Evaluator Notes:
Inspectors and Program Manager had fulfilled the T&Q Training requirements before conducting inspection as lead in 2016.
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
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
Yes, Pipeline Safety Program Manager indicated adequate knowledge of PHMSA program and regulations.
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
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Chair letter sent October 19, 2016, response received December 7, 2016. There were no issues.
5 Did State conduct or participate in pipeline safety training session or seminar in Past 3
Years? Chapter 8.5
1 1
Yes = 1 No = 0
Evaluator Notes:
Yes, there was a consolidated TQ Seminar with the States of WA, OR, and ID in May 2015.
6 Did state inspect all types of operators and inspection units in accordance with time
intervals established in written procedures? Chapter 5.1
5 5
Yes = 5 No = 0 Needs Improvement = 1-4Evaluator Notes:
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The State inspected all operators and inspection units at intervals less than outlined in POP. Each operator has been
inspected on an annual basis.
7 Did inspection form(s) cover all applicable code requirements addressed on Federal
Inspection form(s)? Did State complete all applicable portions of inspection forms?
Chapter 5.1
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:For standard inspections in 2016, Idaho was using the IA inspection form, dated 1/20/16. Recommended that Idaho follow-
up on inspections completed by Lyle Barthlome in 2016. Lyle left the IPUC on January 2017. Reviewed one of Lyle's
inspection reports and found items that were incomplete and not documented in the report.
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
1 1
Yes = 1 No = 0Evaluator Notes:
There was no cast iron pipe in the State of Idaho.
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
1 1
Yes = 1 No = 0
Evaluator Notes:
There was no cast iron pipe in the State of Idaho.
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
1 1
Yes = 1 No = 0
Evaluator Notes:Reviewed form "IPUC Pipeline Safety Audit Inspection Checklist" (Form 2) which includes question for operator emergency
response procedures for leaks caused by excavation damage near buildings.
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
1 1
Yes = 1 No = 0
Evaluator Notes:Idaho collects data from annual reports on a "Leak Cause Spreadsheet" which list cause of leaks, excavation tickets, and
excavation damage per 1000 tickets. Reviewed form "IPUC Pipeline Safety Audit Inspection Checklist" (Form 2) which
included check operator records of previous accidents and failures including third party damage and leak response.
12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for
accuracy and analyzed data for trends and operator issues?
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:IPUC has reviewed operator annual reports, along with incident/accident reports and discovered that Avista Utilities had
issues with not repairing all its leaks. IPUC with operator to discuss the issues to have all leaks classified and repaired.
13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a
timely manner? This includes replies to Operator notifications into IMDB database.
Chapter 5.1
2 1
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Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:There were 11 OQ field inspections and 1 program inspection uploaded to the OQ database in 2016. There have been no IM
inspections uploaded to the IMDB since 12/08/2011.
14 Has state confirmed intrastate transmission operators have submitted information into
NPMS database along with changes made after original submission?
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Yes, IPUC includes question in its PHMSA form 2 inspection checklist.
15 Is the state verifying operators are conducting drug and alcohol tests as required by
regulations? This should include verifying positive tests are responded to in accordance
with program. 49 CFR 199
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:A Drug and Alcohol inspection was performed on each operator in 2016 and those results were attached to the inspection
reports that was reviewed during the evaluation.
16 Is state verifying operators OQ programs are up to date? This should include verification
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
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:Northwest Gas OQ scheduled for October 2017; Intermountain Gas Co. OQ inspection performed in 2014 scheduled for
November 2107, Avista OQ inspection performed in 2014 scheduled for 2017; and Questa OQ inspection performed in 2012
scheduled for 2017. Idaho performed 12 OQ protocol 9 inspections in 2016.
17 Is state verifying operator's gas transmission integrity management programs (IMP) are
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?). 49 CFR 192 Subpart 0
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Intermountain Gas Co. IM inspection performed in 2015 scheduled for 2017; and Questar IM inspection performed in 2015
scheduled for 2017.
18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:IPUC performed DIMP inspections on all operators in 2016. Questar previous DIMP performed in 2013; Avista previous
DIMP performed in 2012; Intermountain Gas previous DIMP performed in 2013.
19 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 have
been completed by December 2013. PAPEI Effectiveness Inspections should be
conducted every four years by operators. 49 CFR 192.616
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
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Intermountain Gas Co. PAP inspection performed in 2013 and 2016; Avista PAP inspection performed in 2014 and 2017;
Questar PAP performed in 2014 and 2017; Northwest Gas Co. performed in 2017. Each operator is utilizing 3rd party
consultants to verify effectiveness of PAP program.
20 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).
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:The Idaho State program will be working with the Pipeline Safety Trust to improve its website to include enforcement cases
for the public view. The IPUC expects to have by 2018 transparency with enforcement cases and inspection reports being
posted on website.
21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC)
Reports? Chapter 6.3
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
There were no open SRCRs for Idaho in 2016.
22 Did the State ask Operators to identify any plastic pipe and components that has shown a
record of defects/leaks and what those operators are doing to mitigate the safety
concerns?
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Each operator is asked question which is included in the IPUC Form 2 (Supplemental Checklist).
23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA?1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC responded to surveys pertaining to jurisdictional gas storage facilities and States' use of IA.
24 If the State has issued any waivers/special permits for any operator, has the state verified
conditions of those waivers/special permits are being met? This should include having the
operator amend procedures where appropriate.
1 1
No = 0 Needs Improvement = .5 Yes = 1Evaluator Notes:
There have been no active waivers or permits for IPUC in 2016.
25 Did the state attend the National NAPSR Board of Directors Meeting in CY being
evaluated?
1 1
No = 0 Needs Improvement = .5 Yes = 1
Evaluator Notes:
IPUC attended the National NAPSR meeting in Indianapolis in 2016.
26 Discussion on State Program Performance Metrics found on Stakeholder Communication
site - http://primis.phmsa.dot.gov/comm/states.htm
2 2
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 ImprovementEvaluator Notes:Idaho met with Avista to discuss leaks not being classified for repair. Leaks were being grouped together and not being
scheduled for repair. Idaho is preparing a letter of concern to be mailed to the operator.

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Gas Pipeline inspector qualification has decreased each year 2013-2015. The percentage of inspector staff that has the core
training has decreased each year. As of 2016 the IPUC was fully staffed and two inspectors have completed their core
courses.
27 Discussion with State on accuracy of inspection day information submitted into State
Inspection Day Calculation Tool. (No points)
Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:Idaho is concerned with not being able to meet the inspection days submitted in the inspection day calculation tool. Idaho
has suggested to State Programs that the calculation tool should be opened up for modification of their numbers submitted as
inspection days for the State of Idaho. Will not be able to meet those days in calculation tool without possibly an increase in
budget funding and the inspectors increasing their inspection days in the field. Idaho needs to make modification of numbers
in calculation tool to meet the 416 days compared with 262 inspection days in the 2016 Progress Report. Even with the 262
inspection days in 2016, IPUC did not meet the ratio of total inspection person days to total person days.
28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals,
Product Changes and Conversions to Service? See ADP-2014-04 (No Points)
Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:Idaho contacted each operator in 2016 to notify them of the ADB and had them sign off on receiving the information and to
inform the IPUC if they had any pipeline flow reversals, product changes, or conversions to service. Idaho could not find
operators' submittal letters of return, so this should be reviewed for the CY2017 evaluation.
29 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:There were two issues identified in Part C of the evaluation. The IPUC did not meet the ratio of total inspection person days to total person days at >=.38. The IPUC ratio was calculated to .35. Lastly, the IPUC had not uploaded IM inspections into the IMDB since 12/08/2011.
Total points scored for this section:43Total possible points for this section:49
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PART D - Compliance Activities Points(MAX)Score
1 Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 4 4
Yes = 4 No = 0 Needs Improvement = 1-3a. Procedures to notify an operator (company officer) when a noncompliance is
identified Yes No Needs
Improvementb. 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
ImprovementEvaluator Notes:
Procedures are contained in Sections 5.5-5.7 of POP.
2 Did the state follow compliance procedures (from discovery to resolution) and adequately
document all probable violations, including what resolution or further course of action is
needed to gain compliance? Chapter 5.1
4 4
Yes = 4 No = 0 Needs Improvement = 1-3a. 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. Were applicable civil penalties outlined in correspondence with operator(s)Yes No Needs
ImprovementEvaluator Notes:Procedure included in POP 5.7. Idaho had two compliance actions in 2016 and the reports were mailed to the VP, Operations
(Intermountain Gas, Co ? Hart Gilchrist) and Director, Natural Gas (Avista Corp, - Mike Faulkenberry). Probable violations
were documented for both Intermountain Gas and Avista Corp. There were a total of five probable violations cited and they
have not been resolved as of the date of this Program Evaluation. Idaho has scheduled meetings with both operators in June
2017 to resolve issues.
3 Did the state issue compliance actions for all probable violations discovered? 2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Yes, all probable violations that warranted did have compliance actions issued to the operators (Intermountain Gas Co. and Avista, Corp.).
4 Did compliance actions give reasonable due process to all parties? Including "show
cause" hearing if necessary.
2 2
Yes = 2 No = 0
Evaluator Notes:Yes, the IPUC has not gotten to the stage of a show cause hearing with compliance actions that were issued in 2016. IPUC
scheduled to meet with parties to discuss issues in June 2017.
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)
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Procedures included in 5.7 of POP. Yes, the Program Manager has shown familiarity of the state process for imposing civil
penalties.
6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety
violations?
1 1
Yes = 1 No = 0 Needs Improvement = .5
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Evaluator Notes:The State of Idaho has not issued a fine in 10 years. The Idaho Program started writing more compliance actions in 2012,
with 12 compliance actions issued to the date. Those compliance actions were resolved with no civil penalties being
assessed. There are two compliance actions open in 2017 from inspections performed in 2016 with the possibility of civil
penalties being assessed due to the nature of the probable violations.
7 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
There were no issues in Part D of the IPUC Program evaluation.
Total points scored for this section:15Total possible points for this section:15
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PART E - Incident Investigations Points(MAX)Score
1 Does the state have written procedures to address state actions in the event of an incident/accident?2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Procedures is included in Section 6.0. of POP.
2 Does state have adequate mechanism to receive and respond to operator reports of
incidents, including after-hours reports? And did state keep adequate records of Incident/
Accident notifications received? Chapter 6
2 2
Yes = 2 No = 0 Needs Improvement = 1
a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D)Yes No Needs
Improvementb. Acknowledgement of Federal/State Cooperation in case of incident/accident
(Appendix E)Yes No Needs
Improvement
Evaluator Notes:Procedures is included in Sections 6.2 and 6.5 of POP. The Program Manager is contacted by operator to report incidents
after-hours.
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
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:Procedures is included in Sections 3.15, 6.1, and 6.6 of POP. Idaho had two incidents in 2016 and performed a follow-up
visit to investigate status of equipment failures.
4 Were all incidents investigated, thoroughly documented, and with conclusions and
recommendations?
3 3
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
ImprovementEvaluator Notes:Procedures is included in Sections 6.6-6.7 of POP. Idaho had two incidents in 2016 and performed a follow-up visit to
investigate status of equipment failures.
5 Did the state initiate compliance action for violations found during any incident/accident
investigation?
1 1
Yes = 1 No = 0
Evaluator Notes:
There were two incidents that occurred in 2016, and there were no violations found during the follow-up visits.
6 Did the state assist region office by taking 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
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
Procedure is included in Section 6.5 of POP. There were no PHMSA reportable accidents in 2016 for the State of Idaho.
7 Does state share lessons learned from incidents/accidents? (sharing information, such as:
at NAPSR Region meetings, state seminars, etc)
1 1
Yes = 1 No = 0
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Evaluator Notes:Yes, a video was presented from Mr. Kevin Henderson, State of Oregon, which outlined investigation process and writing a
comprehensive accident report.
8 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
There were no issues in Part E of the IPUC Program evaluation.
Total points scored for this section:11Total possible points for this section:11
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PART 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
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Procedure is included in Section 3.4 of POP. Idaho has question contained in its IPUC Form 2 (Supplemental Checklist)
2 Did the state inspector check to assure the pipeline operator is following its written
procedures pertaining to notification of excavation, marking, positive response and the
availability and use of the one call system?
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
Procedure is included in Section 3.12 of POP. Idaho has question contained in its IPUC Form 2 (Supplemental Checklist)
3 Did the state encourage and promote practices for reducing damages to all underground
facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best
Practices encouraging adoption of the 9 Elements, etc.)
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:IPUC is involved with a coalition to strengthen damage prevention laws with the establishment of the Damage Prevention Board; and IPUC encourages operators report to "DIRT".
4 Has the agency or another organization within the state collected data and evaluated
trends on the number of pipeline damages per 1,000 locate requests? (This can include
DIRT and other data shared and reviewed by the pipeline safety program)
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Idaho collects the data, but will be implementing a process to evaluate this data for trends on the number of pipeline damages
per 1,000 locate requests.
5 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
There were no issues in Part F of the IPUC Program evaluation.
Total points scored for this section:8
Total possible points for this section:8
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PART G - Field Inspections Points(MAX)Score
1 Operator, Inspector, Location, Date and PHMSA Representative Info OnlyInfo Only
Info Only = No Points
Name of Operator Inspected:
Intermountain Gas Co.
Name of State Inspector(s) Observed:Robert Jamison and Darrin Ulmer
Location of Inspection:
4050 Can Ada Road, Nampa, ID 83687
Date of Inspection:June 6, 2017
Name of PHMSA Representative:Clint Stephens
Evaluator Notes:
The IPUC performed a standard LNG inspection.
2 Was the operator or operator's representative notified and/or given the opportunity to be
present during inspection?
1 1
Yes = 1 No = 0
Evaluator Notes:
Yes. The operator was notified and was present during the inspection.
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)
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:Idaho used the "PHMSA Form 4 (IA Equivalent) Standard Inspection Report of an LNG Facility", dated May 2015, during
the inspection.
4 Did the inspector thoroughly document results of the inspection? 2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Yes. The inspector thoroughly documented the results of the inspection. Those results were recorded on the IA equivalent
LNG inspection form.
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.)
1 1
Yes = 1 No = 0
Evaluator Notes:
Schematic diagram for the plant layout.
6 Did the inspector adequately review the following during the field portion of the state
evaluation? (check all that apply on list)
2 2
Yes = 2 No = 0 Needs Improvement = 1
a. Procedures
b. Records
c. Field Activities
d. Other (please comment)
Evaluator Notes:Yes, the inspectors reviewed records and procedures pertaining to operation, start-up/shutdown, reporting, emergency
response, and control systems. During the field activities the inspector observed areas for atmospheric corrosion, ESDs,
emergency exits, and fire equipment.
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7 Did the inspector have adequate knowledge of the pipeline safety program and
regulations? (Evaluator will document reasons if unacceptable)
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
Yes. The inspector had adequate knowledge of the pipeline safety program and regulations during the inspection.
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)
1 1
Yes = 1 No = 0
Evaluator Notes:Two recommendations made by the inspector were not having procedures for taking LNG tank out-of service and no
documentation pertaining to NPMS submittals annually.
9 During the exit interview, did the inspector identify probable violations found during the
inspections? (if applicable)
1 1
Yes = 1 No = 0
Evaluator Notes:There were probable violations found during the inspections; however, the inspector did identify areas of concern (recommendations) during the exit interview.
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 OnlyInfo Only
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
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C. Tapping
D. Valve Maintenance
E. Vault Maintenance
F. Welding
G. OQ - Operator Qualification
H. Compliance Follow-up
I. Atmospheric Corrosion
J. Other
Evaluator Notes:During the field activities the inspector observed areas for atmospheric corrosion, ESDs, emergency exits, and fire
equipment. The inspector performed its duties adequately during the field activities.
Total points scored for this section:12
Total possible points for this section:12
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PART H - Interstate Agent State (If Applicable)Points(MAX)Score
1 Did the state use the current federal inspection form(s)? 1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
IPUC is not an interstate agent.
2 Are results documented demonstrating inspection units were reviewed in accordance with
"PHMSA directed inspection plan"?
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC is not an interstate agent.
3 Did the state submit documentation of the inspections within 60 days as stated in its latest
Interstate Agent Agreement form?
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC is not an interstate agent.
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.)
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
IPUC is not an interstate agent.
5 Did the state immediately report to PHMSA conditions which may pose an imminent
safety hazard to the public or to the environment?
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC is not an interstate agent.
6 Did the state give written notice to PHMSA within 60 days of all probable violations found?1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC is not an interstate agent.
7 Did the state initially submit documentation to support compliance action by PHMSA on
probable violations?
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
IPUC is not an interstate agent.
8 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
IPUC is not an interstate agent.
Total points scored for this section:0
Total possible points for this section:0
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PART I - 60106 Agreement State (If Applicable)Points(MAX)Score
1 Did the state use the current federal inspection form(s)? 1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
IPUC has no 60106 Agreement.
2 Are results documented demonstrating inspection units were reviewed in accordance with
state inspection plan?
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC has no 60106 Agreement.
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.)
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC has no 60106 Agreement.
4 Did the state immediately report to PHMSA conditions which may pose an imminent
safety hazard to the public or to the environment?
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
IPUC has no 60106 Agreement.
5 Did the state give written notice to PHMSA within 60 days of all probable violations
found?
1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC has no 60106 Agreement.
6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations?1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
IPUC has no 60106 Agreement.
7 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
IPUC has no 60106 Agreement.
Total points scored for this section:0
Total possible points for this section:0