HomeMy WebLinkAbout2017 Program Evaluation.pdfDUNS: 102589939
2017 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
2017 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 PerformanceD--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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2017 Gas State Program Evaluation
Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2
2017 Gas State Program Evaluation -- CY 2017
Gas
State Agency: Idaho Rating:
Agency Status:60105(a):Yes 60106(a):No Interstate Agent:No
Date of Visit:08/20/2018 - 08/24/2018Agency Representative:Mr. Joe Leckie, Pipeline Safety Program ManagerPHMSA Representative:David Appelbaum, 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 83720City/State/Zip:Boise, ID 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 2017 (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 46 46DCompliance Activities 15 14EIncident Investigations 10 10FDamage Prevention 8 8GField Inspections 12 12HInterstate Agent State (If Applicable)0 0I60106 Agreement State (If Applicable)0 0TOTALS114113
State Rating ...................................................................................................................................................99.1
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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 2017. IPUC is investigating 11 facilities to determine if they are jurisdictional master meter systems. Investigation should be completed by 12/31/2018.
2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Reviewed inspection-person day activity results to individual time sheets. Inspection days appear to be reflected
appropriately.
3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator 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 = .5Evaluator Notes:
Idaho had two incident reports listed. Attachment 4 was correct.
5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Review shows attachment 5 is accurate.
6 Were pipeline program files well-organized and accessible? - Progress Report
Attachment 6
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
Files appear to be well organized. Program Manager and other staff were capable of readily accessing requested documents.
7 Was employee listing and completed training accurate and complete? - Progress Report
Attachment 7
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:Reviewed information on each inspector and compared completion courses to TQ records. All employees participating in the pipeline safety program were listed properly.
8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report
Attachment 8
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator 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 = .5Evaluator Notes:Yes, a sufficient list of detailed information on accomplishments and future activities was provided. IPUC was encouraged to
develop goals on dig-in reduction. The State's current hit/1000 one-call ticket ratio is 8.3, significantly higher than the
National average.
10 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC generally complied with the requirements of Part A of this evaluation.
Total points scored for this section:10Total 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:Yes. Idaho Public Utility Commission's Program Operations Procedures (POP), Sections 3 and 7, and Attachment E contains pre-inspection, inspection and post inspection procedures.
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 = .5
Evaluator Notes:Yes. Idaho Public Utility Commission's Program Operations Procedures (POP), Sections 3.10 and 7, and Attachment E contains pre-inspection, inspection and post inspection procedures for IMP and DIMP.
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:Yes. Idaho Public Utility Commission's Program Operations Procedures (POP), Sections 3.9 and 7, and Attachment E contains pre-inspection, inspection and post inspection procedures for OQ.
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 = .5Evaluator Notes:Yes. Idaho Public Utility Commission's Program Operations Procedures (POP), Sections 3.12 and 7, and Attachment E contains pre-inspection, inspection and post inspection procedures for Damage Prevention.
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:Yes. Idaho Public Utility Commission's Program Operations Procedures (POP), Sections 3.11 and 7, and Attachment E contains pre-inspection, inspection and post inspection procedures for Construction.
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
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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
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 was
recently implemented into the inspection priority process. Attachment B in the POP is used to score the risk based analysis.
8 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC generally complied with the requirements of Part B of this 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 5
Yes = 5 No = 0
A. Total Inspection Person Days (Attachment 2):416.50
B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7):220 X 2.83 = 623.52
Ratio: A / B
416.50 / 623.52 = 0.67
If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0Points = 5Evaluator Notes:
The IPUC's ratio of 0.67 far exceeded the minimum ration of .38.
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:
All lead inspectors in 2017 have met the TQ requirements.
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:
Program Manager displayed a proficient understanding of the pipeline safety program.
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:Yes, Chairman Kjellander's response letter to Zach Barrett was received on September 22, 2017. PHMSA's outbound letter was dated July 26, 2017, thus the State responded within the 60-day time requirement.
5 Did State conduct or participate in pipeline safety training session or seminar in Past 3
Years? Chapter 8.5
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:The IPUC uses the federal inspection forms for its inspections. Upon a review of randomly selected 2017 inspection files all
applicable portions of the forms were completed appropriately.
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 NA
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 NA
Yes = 1 No = 0Evaluator 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:
Yes, the IPUC inspects the responses required for failures.
13 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, has question on inspection form, and reviews the report in PDM of Annual Report miles vs. NPMS miles.
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14 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:Yes, IPUC did not complete any D&A inspections in CY2017, but are compliant with their three and five year cycle
requirements. IPUC has not found any positive test results to date.
15 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:The IPUC spent 30.5 inspection person-days conducting OQ inspections. Several OQ plans were reviewed and field
inspections conducted.
16 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? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
No IMP inspections were conducted in 2017, but the IPUC is compliant with their 5 year schedule.
17 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
2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
No IMP inspections were conducted in 2017, but the IPUC is compliant with their 5 year schedule.
18 Is state verifying operators Public Awareness programs are up to date and being
followed. State should also verify operators have evaluated Public Awareness programs
for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be
conducted every four years by operators. 49 CFR 192.616
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes: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.
19 Does the state have a mechanism for communicating with stakeholders - other than state
pipeline safety seminar? (This should include making enforcement cases available to
public).
1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:The IPUC has been working to have better transparency with enforcement cases and inspection reports being posted on website. Information on enforcement is currently limited to docket searches. IPUC indicated they would look to include their progress report on the website as a next-step in transparency. No point deduction but IPUC does acknowledge they need to enhance the mechanisms for communicating with stakeholders.
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20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
There were no open SRCRs for Idaho in 2017.
21 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 = .5Evaluator Notes:
Each operator is asked question which is included in the IPUC Form 2 (Supplemental Checklist).
22 Did the state participate in/respond to surveys or information requests from NAPSR or
PHMSA?
1 1
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
Yes
23 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 = 1
Evaluator Notes:
There have been no waivers or permits for IPUC in 2017.
24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? 1 1
No = 0 Needs Improvement = .5 Yes = 1Evaluator Notes:
IPUC attended the National NAPSR meeting in Columbus, OH in 2017.
25 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:All of the metrics are trending in the direction of improvement. It was clear from the discussion with the Program Manager
and Supervisors that the drivers of the trends are understood.
26 Discussion with State on accuracy of inspection day information submitted into State
Inspection Day Calculation Tool (SICT) Has the State updated SICT data?
1 1
No = 0 Yes = 1Evaluator Notes:The IPUC's inspection person days increased substantially with the new calculation tool. PHMSA discussed the importance
to continually review the inspections days for all inspections and to compare with the initial estimates entered into the
calculation tool.
27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals,
Product Changes and Conversions to Service? See ADP-2014-04
1 NA
Needs Improvement = .5 No = 0 Yes = 1Evaluator Notes:
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28 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC generally complied with the requirements of Part C of this evaluation.
Total points scored for this section:46Total possible points for this section:46
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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 3
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
Improvemente. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs
Improvementf. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection.Yes No Needs
Improvement
Evaluator Notes:IPUC has, as a matter of practice, communicates findings of non-compliance and/or probable violations via email. Inspection
procedures (POP 5.7.) currently has no provision for compliance actions to be communicated by email. IPUC could not
guarantee that company officers receive email notices in all cases.
IPUC either needs to amend POP 5.7. to allow for email correspondence or utilize compliance letters. One point deduction.
3 Did the state issue compliance actions for all probable violations discovered? 2 2
Yes = 2 No = 0 Needs Improvement = 1Evaluator Notes:
Yes, see D.2. for additional information.
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:
No instances were discovered where the operator was not given due process to argue the allegations of non-compliance.
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 = 1Evaluator 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
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Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Through CY2017 the IPUC had not exercised its fining authority on an operator. In early 2018, Avista Utilities was issued a $10,000 penalty which was late suspended in exchange for other conditions met.
7 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC has generally complied with the requirements of Part D of this evaluation.
Total points scored for this section:14Total 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 2017 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 2017 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:
6 Did the 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? (validate report data from operators
concerning incidents/accidents and investigate discrepancies) Chapter 6
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
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
8 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC generally complied with the requirements of Part E of this evaluation.
Total points scored for this section:10Total possible points for this section:10
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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 verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system?
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 = 1Evaluator Notes:
Yes
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, and evaluates this data for trends on the number of pipeline damages per 1,000 locate requests.
5 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
The IPUC has generally complied with the requirements of Part F of this evaluation.
Total points scored for this section:8Total 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 Company
Name of State Inspector(s) Observed:Bruce Perkins
Location of Inspection:
Nampa, ID
Date of Inspection:August 23, 2018
Name of PHMSA Representative:David AppelbaumEvaluator Notes:
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:
Yes
4 Did the inspector thoroughly document results of the inspection? 2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Yes
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 = 0Evaluator Notes:
Yes, inspector verified calibrations on equipment used.
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, inspectors observed regulator testing, cathotic protection and atmospheric corrosion at a number of regulator stations.
7 Did the inspector have adequate knowledge of the pipeline safety program and
regulations? (Evaluator will document reasons if unacceptable)
2 2
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Yes = 2 No = 0 Needs Improvement = 1
Evaluator 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 = 0Evaluator Notes:
Yes
9 During the exit interview, did the inspector identify probable violations found during the
inspections? (if applicable)
1 1
Yes = 1 No = 0Evaluator Notes:
No probable violations but 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
C. Tapping
D. Valve Maintenance
E. Vault Maintenance
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F. Welding
G. OQ - Operator Qualification
H. Compliance Follow-up
I. Atmospheric Corrosion
J. Other
Evaluator Notes:
Total points scored for this section:12Total 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:
2 Are results documented demonstrating inspection units were reviewed in accordance with
"PHMSA directed inspection plan"?
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
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:
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:
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 = .5Evaluator Notes:
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:
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:
8 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
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:
2 Are results documented demonstrating inspection units were reviewed in accordance with
state inspection plan?
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
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:
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:
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 = .5Evaluator Notes:
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:
7 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
Total points scored for this section:0Total possible points for this section:0