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PHMSA al2009hlprogramevaluation
2009 AL HL Program Evaluation - al2009hlprogramevaluation (Alabama; Hazardous Liquid State Program Evaluation)
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AL HL Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Hazardous Liquid State Program Evaluation for Alabama Public Service Commission Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Accident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 1#
AL HL Program Evaluation, 2009, page 22009 Hazardous Liquid State Program Evaluation -- CY 2009 Hazardous Liquid State Agency: Alabama Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 07/19/2010 - 07/22/2010 Agency Representative: Wallace R. Jones, Sr., Gas Pipeline Safety Administrator, Alabama Public Service Commission PHMSA Representative: Don Martin, State Programs Coordinator, Office of State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Lucy Baxley, President Agency: Alabama Public Service Commission Address: 100 N. Union Street, RSA Union Suite 836 City/State/Zip: Montgomery, Alabama 36104 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 25 25 C Interstate Agent States 0 0 D Accident Investigations 2.5 2.5 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 9 8.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 95.5 95 State Rating................................................................................................................................................... 99.5 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 2#
AL HL Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over Hazardous Liquid and CO2 facilities (1) b. Total state inspection activity (2) c. Hazardous Liquid facilities subject to state safety jurisdiction (3) d. Hazardous Liquid pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the Hazardous Liquid pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: The APSC submitted complete information on its 2010 Certification. 8 8 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance 1 1 with 60105(a) Certification/60106(a) Agreement requirements (accident criteria as referenced in 195.50? - Mechanism should include receiving "after hours" reports) (Chapter 6) Previous Question A.2 Yes = 1 No = 0 SLR Notes: Yes. APSC pipeline safety regulations requires operators to provide telephonic notice to the APSC when an incident occurs. An electronic log of incidents reported to the APSC is maintained by the administrative assistant. The APSC has a mechanism to receive and respond to after hour incident reports. 3 Has the state held a pipeline safety T & Q seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar 2 2 or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.5 Yes = 2 No = 0 SLR Notes: The APSC holds a seminar each year for natural gas and hazardous liquid pipeline operators. The last seminar was conducted in December, 2009. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.6 Yes = 1 No = 0 1 1 SLR Notes: The APSC maintains hard copy files and electronic files. The inspection reports for 2009 were easy to access for a random selection of reports to review. The inspection reports kept in electronic files were easily accessed. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.7 Yes = 2 No = 0 Needs Improvment = 1 2 2 SLR Notes: Yes. Wallace Jones, Administrator of the APSC, has greatly improved his knowledge of the requirements in managing a pipeline safety program as outlined in the "Guidelines For States Participating in the Pipeline Safety Program". Wallace has been active supporting NAPSR initiatives. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.9 Yes = 1 No = 0 SLR Notes: The APSC Chairman was not requested to provide a response. 1 1 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (Chapter 8.1) Previous Question A.10 Yes = 1 No = 0 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation 1 1 Alabama Alabama Public Service Commission, Page: 3#
AL HL Program Evaluation, 2009, page 4SLR Notes: The APSC was not requested to initiate any actions related to issues identified in the Chairman's letter. The APSC did create a process to rank risks on a relative basis to schedule its inspections. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year T&Q training requirement? If No, has the state been granted a waiver regarding T&Q courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all T&Q courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.11 Yes = 3 No = 0 3 3 SLR Notes: Only certain inspectors have responsibilities to inspect hazardous liquid pipeline operators. Tommy Lancaster and Judy Ramsey are the designated lead hazardous liquid pipeline inspectors at this time. Tommy and Judy had completed the training requirements until the Hazwoper class was added as a requirement. Both have completed the Hazwoper class since 12/31/2008. Daniel Trapp will have hazardous liquid pipeline lead inspection responsibilities in the future once he has completed all of the training. He is on track to complete the training. 9 Brief Description of Non-T&Q training Activities Info Only = No Points For State Personnel: All staff members attended ANGA fall and spring conferences. For Operators: The APSC has a staff member dedicated to training. This person taught topics such as fire training, plastic pipe fusion, static electricity and cathodic protection for operators during 2009. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: The APSC participated with the Alabama One Call Center for training with all stakeholders including the public. SLR Notes: See notes above. Info Only Info Only 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: not lead OQ inspections. Yes. All inspectors that have lead OQ inspections completed the OQ CBT training course in 2003. Inspectors that have not completed the OQ training, have 11 Did the lead inspectors complete all required T&Q Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.14 Yes = 1 No = 0 1 1 SLR Notes: Judy Ramsey is designated as the lead inspector for hazardous liquid pipeline integrity management inspections. Judy has completed IMP training requirements since 12/31/2008. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.14 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 5 5 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): Ratio: A / B If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 SLR Notes: The APSC had 45 inspection person days during 2009 with 0.08 person years assigned to the program. The resulting ratio calculated to be 2.56 which exceeds the minimum ratio of 0.38. DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 4#
AL HL Program Evaluation, 2009, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: There were no changes to the APSC's approved level of inspection staff. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The APSC has generally complied with the requirements contained in Part A. Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 5#
AL HL Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators) (Chapter 5.1) 6.5 6.5 Previous Question B.1 + Chapter 5 Changes Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: The APSC procedures state that each operator and unit will be inspected annually. OQ Protocol 9 and Damage Prevention are covered during each standard inspection. Follow up inspections are conducted after other inspections that result in non-compliance actions. Operators are required to notify the APSC on new construction projects. Construction inspections are scheduled based on notifications by operators. All reportable accidents are investigated by the APSC as they occur. On site operator training is conducted on an as need basis. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: The APSC procedures cover the items above. The APSC's inspection frequency states that each operator and unit will be inspected annually. The APSC has developed a risk ranking process that it intends to implement in the future to verify the scheduling of inspections. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: The APSC procedures require that each operator and unit be inspected each calendar year. The APSC reported on its 2010 Certification - Attachment 1 that all operators and units were inspected during 2009. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 1 1 SLR Notes: For standard inspections, the APSC utilizes an inspection form developed by the APSC. The APSC form was developed by revising the federal form to remove questions related to reviewing an operator's Operation and Maintenance Procedures. The APSC conducts a full standard inspection including a review of the Operation and Maintenance Procedures once each three years. When conducting the full standard inspection including O&M Procedures review, the federal form is used. The federal form is used for OQ and Liquid IMP inspections. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.6 Yes = 1 No = 0 SLR Notes: Upon a review of randomly selected inspection files, applicable portions of the forms were completed. 1 1 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 6#
AL HL Program Evaluation, 2009, page 76 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Yes. The APSC continued follow up on a safety related condition report filed in 2008. The APSC concluded the report during 2009. .5 0.5 7 Did the state review operator procedures for determining areas of active corrosion on liquid lines in sufficient .5 0.5 detail? (NOTE: PHMSA representative to describe state criteria for determining areas of active corrosion) Previous Question B.8 Yes = .5 No = 0 SLR Notes: The APSC reviews operators' O&M Procedures on a three year rotation. The APSC reviews operator's corrosion and cathodic protection procedures during this review. The operator's procedure for determining active corrosion is covered. The APSC's position is that active corrosion is present if corrosion with metal loss is found. 8 Did the state adequately review for compliance operator procedures for abandoning pipeline facilities and analyzing pipeline accidents to determine their causes? (NOTE: PHMSA representative to describe state criteria for determining compliance with abandoning pipeline facilities and analyzing pipeline accidents to determine their causes) Previous Question B.9 Yes = .5 No = 0 SLR Notes: Yes. The APSC's standard inspection form has a question covering this pipeline safety concern. .5 0.5 9 Is the state aware of environmentally sensitive areas traversed by or adjacent to hazardous liquid pipelines? (reference Part 195, review of NPMS) Previous Question B.16 Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC conducted a review during the first round of liquid IMP inspections. The APSC has access to the National Mapping System to review environmentally sensitive areas in the vicinity of the hazardous liquid pipelines. 10 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 195.402(c)(5)? Previous Question B.11 Yes = 1 No = 0 SLR Notes: Yes. The APSC covers the requirements of 195.402 on its inspection checklist form during each standard inspection. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.13 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Upon a review of randomly selected inspection files, each probable violation noted in non-compliance letters to operators had documentation of the actions the operators failed to take to comply with the regulations. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question C(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: operator. Yes. The APSC's procedures require that the inspector conduct a followup inspection to confirm whether or not corrective action has been taken by the 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question C (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The APSC's procedures state that a written notification will be sent to the operator notifying the operator of any non-compliance. 1 1 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 7#
AL HL Program Evaluation, 2009, page 814 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question C(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. The APSC's procedures require that the inspector conduct a followup inspection to confirm whether or not corrective action has been taken by the operator. Inspection reports are not closed until corrective action has taken place. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question C(1).4 Yes = 1 No = 0 SLR Notes: Upon a review of randomly selected inspection files, all inspections that discovered probable violations had letters of non-compliance in the files. 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question C(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Upon a review of randomly selected inspection files, the files contained responses from operators within the deadlines given by the APSC and the had conducted followup inspections with operators to confirm if corrective action had taken place. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question C(1).6 No = 0 Yes = 1 SLR Notes: The APSC did not have a need to request a "show cause" hearing before the commission. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 C(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: action. Upon a review of randomly selected inspection files, it appears the APSC is following through with the resolution of probable violations. Upon a review of randomly inspection files, inspectors initial each response item as acceptable and complete a form which documents acceptance of the operator's remedial 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question C(1).8 Yes = .5 No = 0 .5 0.5 SLR Notes: Upon a review of randomly selected inspection reports, compliance letters were sent to a company officer of private firms and the appropriate individual in a municipal or government system. 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question C(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. The APSC's procedures and rules provide operators with an opportunity to argue their position as to whether a probable violation occurred. The operator is provided with an opportunity to present its position in a "show cause" hearing before a presiding officer or the commission. Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question C(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question C(2).2 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation 1 NA Alabama Alabama Public Service Commission, Page: 8#
AL HL Program Evaluation, 2009, page 9Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 23 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.) Previous Question C(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question C(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question C(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only NA SLR Notes: Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 9#
AL HL Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use an inspection form that was approved by the Regional Director? Previous Question C(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The APSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question C(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The APSC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question C(3).3 Yes = 1 No = 0 SLR Notes: The APSC is not an interstate agent. 1 NA 4 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.) Previous Question C(3).4 Yes = 1 No = 0 1 NA SLR Notes: The APSC 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? Previous Question C(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: The APSC is not an interstate agent. 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question C(3).6 Yes = 1 No = 0 SLR Notes: The APSC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question C(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The APSC is not an interstate agent. 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: The APSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 10#
AL HL Program Evaluation, 2009, page 11PART D - Accident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an accident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question D.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: The APSC's staff exhibited knowledge of their responsibilities in the Federal/State cooperation of handling hazardous liquid pipeline incidents. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question D.2 Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The APSC program manager and staff exhibited knowledge of the understandings between the NTSB and PHMSA outlined in the Memorandum of Understanding contained in the Guidelines. 3 Did the state keep adequate records of accident notifications received? Previous Question D.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: There were no reportable hazardous liquid pipeline accidents in 2009. The APSC maintains a log of incident reports as they are telephonically reported to the National Response Center. The APSC investigates all incidents that meet the federal reporting requirements. Reports and documentation of each incident investigated is maintained in the APSC's files. 4 If an onsite investigation of an accident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question D.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: There were no reportable hazardous liquid pipeline accidents in 2009. 1 NA 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? 2 NA Previous Question D.5, , comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations Yes No Needs Improvement b. Contributing factors c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Yes No Needs Improvement SLR Notes: There were no reportable hazardous liquid pipeline accidents in 2009. 6 Did the state initiate enforcement action for violations found during any accident investigation(s)? Previous Question D.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: There were no reportable hazardous liquid pipeline accidents in 2009. 1 NA 7 Did the state assist region office by taking appropriate follow-up actions related to the operator accident (and forward to PHMSA within 10 Days per 195.58) reports to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question D.7/D.8 and A.4 Yes = .5 No = 0 SLR Notes: There were no reportable hazardous liquid pipeline accidents in 2009. .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Info Only Info Only Alabama Alabama Public Service Commission, Page: 11#
AL HL Program Evaluation, 2009, page 12The APSC has generally complied with Part D requirements. Total points scored for this section: 2.5 Total possible points for this section: 2.5 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 12#
AL HL Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives 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? Previous Question B.12 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: review. Yes. The APSC conducts reviews of operators' OM procedures on a three year rotational basis. Directional drilling/boring procedures are a part of the 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? New 2008 Yes = 2 No = 0 2 2 SLR Notes: inspection checklist form. The APSC reviews operators' damage prevention program annually when it conducts a standard inspection. This is covered under 192.614 of the APSC's 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.8 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Wallace Jones participates in the Alabama Damage Prevention Council where he has encouraged stakeholder representatives to use CGA Best Practices. The APSC has also included a discussion of certain best practices in its annual pipeline safety seminar. 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? New 2008 Yes = 1 No = 0 1 1 SLR Notes: The APSC has developed this information since last year by obtaining damage information from operators and number of tickets per operator from Alabama One Call Center. The APSC uses this information in relative risk ranking model. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of 2 2 failure are addressed to minimize the possibility of recurrence as required by 195.402 (c)(5)? Yes = 2 No = 0 SLR Notes: Yes. The APSC reviews operators' compliance with damage prevention requirements under 195 and operators' records pertaining to 195.402 as part of its standard inspection. Excavation damage related failures and repairs are part of this information. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: The APSC has generally complied with the requirements of Part E. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 13#
AL HL Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: BP North America Name of State Inspector(s) Observed: Tommy Lancaster Location of Inspection: Birmingham, AL Terminal Date of Inspection: 04/20/2010 Name of PHMSA Representative: Don Martin SLR Notes: BP operates 2.2 miles of 12" pipeline that carries gasoline and diesel products that are batched through the pipeline from Colonial Pipeline's system to the terminal. The entire pipeline has been determined to be in an HCA. Mr. Lancaster conducted a standard inspection of BP operations. The last inspection was conducted February 18, 2009. BP was represented by Ty Sisung, DOT Compliance Advisor, and Jerome W. Griffin, Corrosion Specialist. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: BP was notified of the inspection in January, 2010. Normally two to three month notice is given by the APSC. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question E.2 Yes = 2 No = 0 2 2 SLR Notes: The APSC inspector used the "Field Evaluation Report For Liquids", revised July, 2008, form for the standard inspection. Mr. Lancaster stepped through the inspection form to progress in the inspection. The form appeared to contain all of the same requirements covered by the federal inspection form. 4 Did the inspector thoroughly document results of the inspection? Previous Question E.3 Yes = 2 No = 0 2 2 SLR Notes: Yes. The APSC inspector completed the inspection form as he reviewed the requirements covered in the inspection. The inspector checked the Yes or No check blocks on each requirement. No probable violations were found during the inspection. Documentation of probable violations was not required. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, valve keys, half-cells, etc.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: instruments. Yes. The inspector reviewed the operator's test equipment for taking cathodic protection readings. He verified that the voltmeter and half cell were proper 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: The APSC inspector conducted a standard inspection for hazardous liquid pipelines. He also reviewed the Operator Qualification task for Cathodic Protection test readings and Drug and Alcohol testing records. 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 2 2 a. Procedures b. Records c. Field Activities/Facilities DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 14#
AL HL Program Evaluation, 2009, page 15d. Other (Please Comment) SLR Notes: The APSC inspector reviewed the operator's Operation and Maintenance procedures for their adequacy and to verify the operator's compliance while reviewing office records. Records since the last standard inspection were reviewed to verify compliance with regulations and the operator's procedures. Cathodic protection facilities and test readings were observed in the field. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question E.8 Yes = 2 No = 0 2 2 SLR Notes: regulations. Yes. Mr. Lancaster has twenty two years experience in conducting pipeline safety inspections. He exhibited excellent knowledge of pipeline safety 9 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) Previous Question E.10 Yes = 1 No = 0 SLR Notes: Yes. The APSC inspector provided the operator's representative with a briefing of the results from the inspection. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question E.11 Yes = 1 No = 0 SLR Notes: The APSC inspector informed the operator's representative that no probable violations were found during inspection. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: corrosion. The APSC inspector observed cathodic protection readings taken in the field. He also checked right of way conditions, signs, markers and atmoshpheric 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points SLR Notes: There were no best practices discovered during the inspection. Info Only Info Only 13 Field Observation Areas Observed (check all that apply) 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 Info Only Info Only DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 15#
AL HL Program Evaluation, 2009, page 16q. 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 F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: The APSC inspector covered the items checked above either in the office portion or the field portion of the inspection. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Mr. Lancaster conducted a thorough and effective inspection of the operator's operation and maintenance activities and records. He conducted his inspection in a professional manner and treated the operator's representatives with respect. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 16#
AL HL Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: Yes. The APSC developed a relative risk ranking model during 2009 that will be used for inspection planning in 2010. 1.5 1.5 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: Based upon the definition of inspection units in the guidelines, it appears that the APSC's inspection units are appropriate. .5 0.5 3 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC inspects operators and units annually. The APSC created a spreadsheet system to collect data on risks to pipeline safety in Alabama. The APSC will be inputing the data it collects in the future to evaluate high risk areas. Use of Data to Help Drive Program Priority and Inspections 4 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: The APSC has developed the data gathering process to begin the analysis. The APSC cannot complete an effective analysis until more data is gathered over time. The APSC is a participant in the Alabama Damage Prevention Council which has an interest in damage prevention effectiveness. 5 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: March of each year. Yes. The APSC revised its rules in 2009 to require operators to submit a copy of annual reports directly to the APSC. The APSC analyzes the reports in 6 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: repairs reported by operators. The APSC reviews mileage counts for the various pipe materials in systems to evaluate the trend of replacements. The APSC also reviews the number of 7 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The APSC reviews all Written Incident Reports filed by operators. The APSC insures that the operator's report is consistent with findings in the APSC's investigation report. There were no hazardous liquid accidents during 2009. 8 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures,trends,etc.) .5 0 Yes = .5 No = 0 SLR Notes: The APSC has developed the measures that it wants to analyze for program effectiveness; however, the APSC has just begun collecting the needed data. The APSC will not be able to perform an evaluation until it has a sufficient amount of data. DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 17#
AL HL Program Evaluation, 2009, page 189 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Yes = .5 No = 0 .5 0.5 SLR Notes: Upon a review of the Operator Qualification Database, it appears that the APSC has uploaded the results of its Operator Qualification inspections, including inspections of plans and Protocol 9 (Field Inspection). These inspections were conducted prior to 2009. 10 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Yes = .5 No = 0 .5 NA SLR Notes: There were no notifications during 2009. 11 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 .5 0.5 Yes = .5 No = 0 SLR Notes: area during 2009. Yes. The APSC has uploaded all of the IMP Federal Protocol forms for completed IMP inspections. The APSC focused on improving its performance in this 12 Did the State use the Federal Protocols to conduct IMP Inspections? (If the State used an alternative inspection form(s) please provide information regarding alternative form(s)) Previous Question C(2).6 Yes = .5 No = 0 SLR Notes: Yes. Upon a review of the inspection files, the Liquid IMP forms were completed for the inspections. .5 0.5 13 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC now includes as part of its IMP inspections a discussion with operators on their submission of updates to the National Pipeline Mapping System. Accident/Incident Investigation Learning and Sharing Lessons Learned 14 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: Region. When accidents occur, the APSC discusses details of incidents which have occurred in Alabama each year at the annual meeting of NAPSR's Southern 15 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 NA Yes = .5 No = 0 SLR Notes: The APSC gathers data as part of the incident investigation. There have been no requests made to the APSC asking for data concerning incidents. 16 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only SLR Notes: Wallace Jones recently completed the root cause analysis training and is considering how to implement the techniques into its incident investigation process. 17 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only SLR Notes: There have not been any accidents to occur since the root cause training was completed by the Wallace Jones. The APSC is considering how to implement the techniques into its investigation process. DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 18#
AL HL Program Evaluation, 2009, page 1918 Has state participated on root cause analysis training? (can also be on wait list) No = 0 Yes = .5 .5 0.5 SLR Notes: At least one individual from the APSC has completed root cause analysis training Transparency - Communication with Stakeholders 19 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Commission's website. The APSC participates in and makes presentations at the ANGA Roundtable and Spring Meetings. The APSC posts pipeline safety information on the 20 Does state share enforcement data with public? (Website, newsletters, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC shares a summary of the annual results of pipeline safety inspections on its portion of the Commission's web site. 21 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Question G.9 - The APSC has developed the measures that it wants to analyze for program effectiveness; however, the APSC has just begun collecting the needed data. The APSC will not be able to perform an evaluation until it has a sufficient amount of data. 0.5 points could not be given for this question. Total points scored for this section: 8.5 Total possible points for this section: 9 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 19#
AL HL Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Previous Question A.15 Yes = .5 No = 0 .5 0.5 SLR Notes: Developed a risk ranking spreadsheet for inspection scheduling. The APSC obtained a substantial amount of training at Training and Qualification during 2009. The APSC conducted a well attended and effective pipeline safety seminar during 2009. The APSC began its participation in the newly formed Alabama Damage Prevention Council. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) A.16 Yes = .5 No = 0 .5 0.5 SLR Notes: Introduction of new bill to change Alabama One Call Law to prevent underground facility owners from seeking damages if they did not accurately mark their facilities or mark them within an allowed time. 3 Any Risk Reduction Accomplishments/Projects? (i.e. Replacement projects,bare steel,third-party damage reductions, HCA's/USA mapping, internal corrosion, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC recognizes that third party excavation is the largest threat to the integrity of pipelines in Alabama. The APSC is actively participating a stakeholder group dedicated to improving the damage prevention law in Alabama. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: Yes. Responded to all requests - furlough days, fire first events, non-federal fees, state budget cuts 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: The APSC discusses its practices at NAPSR meetings. Risk ranking spreadsheet was shared with several states. 6 Part H: General Comments/Regional Observations Info Only = No Points SLR Notes: The APSC has generally complied with the requirements of Part H. Info Only Info Only Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 20#
AL HL Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 SLR Notes: 1 1 Yes. The APSC conducted Drug and Alcohol written plan reviews for all operators in 2006. The APSC reviews program changes during each standard inspection. The APSC conducted three drug and alcohol inspections during 2009. 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: results of this inspection. The APSC reviews this requirement each year when it conducts a standard inspection of an operator. The APSC uses a one page form to document the 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? .5 0.5 Yes = .5 No = 0 SLR Notes: The APSC reviews operator's number of positive results and return to duty testing on the one page form included with the standard inspection form. Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 1 1 SLR Notes: The APSC reviewed all operators' OQ written programs prior to 2008. Upon a review of the OQ database, it appears that most of the program reviews were completed prior to 2007. The OQ database also shows that the APSC uploaded the results of over 100 inspections on Protocol 9 of the OQ inspection protocols. The APSC continued reviewing the field portion (Protocol 9) during 2009. 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 0.5 Yes = .5 No = 0 SLR Notes: The APSC reviewed all operators' OQ written programs prior to 2008 while using PHMSA's Protocols. The APSC continually reviews the requirements covered by Protocol 9 during its standard inspections. 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: Yes. While conducting standard inspections, the APSC reviews operators' personnel qualification and requalification records. .5 0.5 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 SLR Notes: Yes. This concern is being addressed as Protocol 9 is covered in its standard inspections of operators. .5 0.5 Hazardous Liquid Pipeline Integrity Management (49 CFR Part 195.452) 8 Has the state verified that all operators with hazardous liquid pipelines have adopted an integrity management program (IMP)? Yes = 1 No = 0 1 1 SLR Notes: Yes. The APSC has conducted the integrity management programs of all hazardous liquid pipeline operators. The APSC placed a high priority on completing these reviews in 2009. 9 Has the state verified that in determining whether a plan is required, the operator properly applied the definition of a high consequence area? Yes = .5 No = 0 DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation .5 0.5 Alabama Alabama Public Service Commission, Page: 21#
AL HL Program Evaluation, 2009, page 22SLR Notes: The APSC uses PHMSA's Protocols when conducting Liquid IMP inspections. The Protocols cover this requirements. 10 Has the state reviewed operator IMPs for compliance with 195.452? Yes = .5 No = 0 .5 0.5 SLR Notes: pipeline operators. Yes. The APSC uses the federal protocol forms which cover all requirements of 195.452. The APSC has completed IMP inspections for all hazardous liquid 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, which includes the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: Yes. The APSC completes the federal protocol forms during its inspections. The Protocols cover these requirements. .5 0.5 12 Is the state verifying operators are periodically examining their hazardous liquid piplines for the appearance of new HCAs? Yes = .5 No = 0 SLR Notes: Yes. The APSC completes the federal protocol forms during its inspections. .5 0.5 Public Awareness (49 CFR Section 195.440) 13 Has the state verified that each operator has developed a continuing public awareness program (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators)? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Prior to 2008, the APSC completed a review of all operators Public Awareness Plans for compliance with 192.616 and the incorporated API RP 1162 standard. The APSC conducted its review in conjunction with the Public Awareness Plan Clearinghouse. Operators with plans that were found to be deficient were notified of changes needed in their plans. 14 Has the state reviewed the content of these programs for compliance with 195.440 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Prior to 2008, the APSC completed a review of all operators Public Awareness Plans for compliance with 192.616 and the incorporated API RP 1162 standard. The APSC conducted its review in conjunction with the Public Awareness Plan Clearinghouse. Operators with plans that were found to be deficient were notified of changes needed in their plans. 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? .5 0.5 Yes = .5 No = 0 SLR Notes: Public Awareness Plans. Yes. The APSC has incorporated the new requirements into its standard inspection checklist form. Operators's actions are verified for compliance with 16 Is the state verifying that operators have evaluated their public awareness programs for effectiveness as described in RP1162? Info Only = No Points SLR Notes: The APSC is planning to start this review in 2010 since operators were not required to complete their evaluations until June, 2010. Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: The APSC has generally complied with the requirements of Part I. Info Only Info Only DUNS: 961833431 2009 Hazardous Liquid State Program Evaluation Total points scored for this section: 9 Total possible points for this section: 9 Alabama Alabama Public Service Commission, Page: 22#
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