HomeMy WebLinkAbout2015 Program Evaluation.pdfDUNS: 102589939
2015 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
2015 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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2015 Gas State Program Evaluation
Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2
2015 Gas State Program Evaluation -- CY 2015
Gas
State Agency: Idaho Rating:
Agency Status:60105(a):Yes 60106(a):No Interstate Agent:No
Date of Visit:08/15/2016 - 08/19/2016
Agency Representative:Joe Leckie
PHMSA Representative:Clint Stephens
Commission Chairman to whom follow up letter is to be sent:
Name/Title:Mr. Paul Kjellander, President
Agency:Idaho Public Utilities Commission
Address:472 West Washington Street
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 2015 (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 9.5BProgram Inspection Procedures 13 13CProgram Performance 46 45DCompliance Activities 6 6EIncident Investigations 9 9FDamage Prevention 8 8GField Inspections 12 12HInterstate Agent State (If Applicable)0 0I60106 Agreement State (If Applicable)0 0TOTALS104102.5
State Rating ...................................................................................................................................................98.6
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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 each unit was inspected in 2015.
2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
Data is accurate for inspection days in 2015.
3 Accuracy verification of Operators and Operators Inspection Units in State - Progress
Report Attachment 3
1 0.5
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Data is inaccurate for number of operator inspection units based on the numbers not being in correlation with Attachment 1
and 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:
Yes, one reportable incident was reported in 2015, and was listed in Progress Report and Pipeline Data Mart.
5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
There were no compliance actions in 2015.
6 Were pipeline program files well-organized and accessible? - Progress Report
Attachment 6
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
Inspection reports are kept in a filing cabinet in order of operators.
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:
Yes, three inspectors started their T&Q training in 2015.
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.
9 List of Planned Performance - Did state describe accomplishments on Progress Report in
detail - Progress Report Attachment 10
1 1
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Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:Idaho described past and present accomplishments in damage prevention (establishment of Board); and the increase in
construction inspections.
10 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:There were two issues identified in Part A, the inaccuracy of operator inspection units, and the non-implementation of civil
penalties which do not meet DOT requirements.
Total points scored for this section:9.5
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 Inspection is included in 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 Attachment E of Program Operation Procedures (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 Attachment E of Program Operation Procedures (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 Attachment E of Program Operation Procedures (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 Attachment E of Program Operation Procedures (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 Attachment E of Program Operation Procedures (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 is included in Section 8.0, Attachment B of the Program Operations Procedures (POP).
8 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
There were no issues identified in Part B.
Total points scored for this section:13
Total 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):250.50
B. Total Inspection Person Days Charged to the Program (220 X Inspection Person
Years) (Attachment 7):220 X 3.09 = 679.62
Ratio: A / B
250.50 / 679.62 = 0.37
If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0
Points = 0Evaluator Notes:Idaho's ratio of calculated inspection person-days was 250.5/679.8=.368 which did not meet the requirement >=.38 for the
2015 calendar year. Idaho had no full time inspectors in 2015 with 12 months of pipeline safety experience. Per discussion
with the States Program Director there will be no deduction in points for the 2015 calendar year due to the ratio of inspection
days not meeting requirement by .01. However, State must meet the ratio of inspection days during the next evaluation
period or expect a deduction in points.
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:
Idaho has three inspectors that started employment in 2015 and were completing their T&Q core courses.
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 1
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Chairman's letter was sent on 10/29/15, and the response was received by PHMSA on January 13, 2016. This exceeded the
60 day required response time frame by 16 days.
5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 2 2
Yes = 2 No = 0
Evaluator Notes:
Yes, there was a consolidated TQ Seminar with the States of WA, OR and ID in May 2015.
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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 = 1-4
Evaluator Notes:
Idaho inspected 100% of its operators and units in 2015.
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:State completed all applicable portions of inspection form; however State needs to establish an inspection form for
construction inspections.
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:
No cast iron pipe in 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 = 0
Evaluator Notes:
No cast iron pipe in 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:The process for reviewing the operator emergency response procedures for leaks caused by excavation damage is included in
section 3.2 of Program Operation Procedures. Also, information included in the IPUC Inspection Forms 1 and 2.
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 analyzed risk for each operator based on information taken from annual reports and included this information in a Leak
Cause Spreadsheet that is updated on an annual basis.
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:Performance metrics identifies repairs and outstanding leaks that do not correlate from 2014 to 2015. Outstanding leaks have
decreased from 2014 to 2015, but repairs have remained the same from 2014 to 2015. Idaho stated that this data will be
discussed with their LDCs in 2016.
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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 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
There were six OQ field inspections uploaded into database in 2015, and no IM inspections were performed in 2015.
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 = .5Evaluator Notes:
Yes, included in PHMSA Form 2 - Standard inspection form.
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 = 1
Evaluator Notes:Yes, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection Activity Sheet.
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 = 1
Evaluator Notes:Yes, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection
Activity Sheet.
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). 49 CFR 192 Subpart 0
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:Yes, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection
Activity Sheet.
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). 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 = 1Evaluator Notes:
There was one follow-up inspection performed in 2015.
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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. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be conducted every four years per RP1162
2 2
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
There were no Public Awareness programs audited in 2015, but one scheduled for 2016.
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:IPUC website has mechanism for communicating with stakeholders, but no enforcement cases are on website. State is in
process of discussing with legal on what should be posted on website.
21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC)
Reports? Chapter 6.3
1 NA
Yes = 1 No = 0 Needs Improvement = .5Evaluator Notes:
There were no SRCRs in 2015.
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:
Idaho has one LDC (Avista Utilities) with plastic aldalay tap fittings that are under a 20 year replacement program.
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:
Yes, the state participated and responded to surveys or information request from NAPSR and PHMSA.
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 NA
No = 0 Needs Improvement = .5 Yes = 1Evaluator Notes:
No active waivers//special permits.
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:
Yes, in Phoenix, AZ.
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:
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Performance metrics identifies repairs and outstanding leaks that do not correlate from 2014 to 2015. Outstanding leaks have
decreased from 2014 to 2015, but repairs have remained the same from 2014 to 2015. Idaho stated that this data will be
discussed with their LDCs in 2016.
27 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
There was one issue identified in Part C, the Chairman's letter response was not received within 60 days.
Total points scored for this section:45
Total 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
Evaluator Notes:
State has process included in sections 5.5 - 5.7 of the Program Operations Procedures.
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 NA
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:
There were no compliance actions sited in 2015.
3 Did the state issue compliance actions for all probable violations discovered? 2 NA
Yes = 2 No = 0 Needs Improvement = 1
Evaluator Notes:
There were no compliance actions sited in 2015.
4 Did compliance actions give reasonable due process to all parties? Including "show
cause" hearing if necessary.
2 NA
Yes = 2 No = 0Evaluator Notes:
There were no compliance actions cited in 2015.
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:
The program manager is familiar with state process for imposing civil penalties; however there were none imposed in 2015.
6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? 1 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
There were no violations identified by State in 2015.
7 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
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There were no issues identified in Part D.
Total points scored for this section:6Total possible points for this section:6
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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:Process to address state actions in the event of an incident/accident are included in section 6.0 of the Program Operations
Procedures.
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:Process to receive and respond to operator reports to incidents, including after-hours reports is included in section 6.2 and 6.5
of the Program Operations Procedures.
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 NA
Yes = 1 No = 0 Needs Improvement = .5
Evaluator Notes:
There was no onsite investigation made during the 2015 calendar year.
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:There was one incident in 2015; a failure of regulator due to temperature (frozen). However, this incident was not
investigated but a report was submitted by operator.
5 Did the state initiate compliance action for violations found during any incident/accident
investigation?
1 NA
Yes = 1 No = 0
Evaluator Notes:
There were no compliance actions or violations in 2105.
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:
The State is available to assist region office when needed.
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:Idaho did a presentation at NAPSR Western Region meeting in 2015. Presentation provided insight on current affairs of
State program.
8 General Comments: Info OnlyInfo Only
Info Only = No PointsEvaluator Notes:
There were no issues identified in Part E.
Total points scored for this section:9Total possible points for this section:9
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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:Process for the review of directional drilling/boring is included in section 3.4 of the Program Operations Procedure, and the
information also included in Form 2 - Standard inspection form used by the IPUC.
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 = 1
Evaluator Notes:Process is included in section 3.12 of the Program Operations Procedures, and the information included in Form 2 - Standard
inspection form used by IPUC. There are two one-call centers in Idaho (PASSWORD and Digline).
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:A new law was passed by the legislature creating a damage prevention council that will enforce the damage prevention laws.
The Council will hold its first meeting in September 2016. Joe Leckie will be representing the IPUC on the council.
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:The IPUC collects data for each operator on the number of pipeline damages per 1,000 miles of pipeline based in information
in the operator's annual reports. Also, operators on a voluntary basis are entering data into DIRT.
5 General Comments: Info OnlyInfo Only
Info Only = No Points
Evaluator Notes:
There were no issues identified in Part F.
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:Darrin Ulmer and Bob Jamison
Location of Inspection:
5555 South Cole Road, Boise ID
Date of Inspection:August 17 & 18, 2016
Name of PHMSA Representative:Clint Stephens
Evaluator Notes:
The State inspectors performed a Standard inspection by reviewing records and field observations.
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 given the opportunity to be 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, the inspector used the appropriate form as a guide 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.
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, the operator used pressure gauges to test regulators, and voltmeters with half cells to check pipe-to-soil potentials.
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 inspector observed testing of regulators; cp monitoring; marker signs; above ground leaks (soap test); exposed
piping (bridge crossing; regulator test records; pipeline maps; and cp monitoring records.
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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 = 1
Evaluator Notes:
Yes, the inspector had adequate knowledge of the pipeline safety program and regulations.
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:The inspection was not complete during the audit; however the operator was made aware of issues found at the time of
discovery.
9 During the exit interview, did the inspector identify probable violations found during the
inspections? (if applicable)
1 1
Yes = 1 No = 0Evaluator Notes:The inspection was not complete during the audit; however the operator was made aware of issues found at the time of
discovery.
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
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D. Valve Maintenance
E. Vault Maintenance
F. Welding
G. OQ - Operator Qualification
H. Compliance Follow-up
I. Atmospheric Corrosion
J. Other
Evaluator Notes:The items checked above were observed during field observations with no non-compliance issues found during the audit. A
relief valve failed to seat during test, but was repaired during audit with no further issues.
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:
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:
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 = .5
Evaluator 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:
Idaho 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:
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:
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 = .5
Evaluator 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 Points
Evaluator Notes:
Idaho does not have a 60106 Agreement.
Total points scored for this section:0
Total possible points for this section:0