RegulusPipeline researchPHMSA az-2022-hazardous-liquid-program-evaluation
AZ HL Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 Hazardous Liquid State Program Evaluation for ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 1#
AZ HL Program Evaluation, 2022, page 22022 Hazardous Liquid State Program Evaluation -- CY 2022 Hazardous Liquid State Agency: Arizona Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: Yes Date of Visit: 03/28/2023 - 03/30/2023 Agency Representative: Eric Villa, Program Manager, AZCC PHMSA Representative: David Lykken, Transportation Specialist, PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Mark OConnor, Chairman Agency: Arizona Corporation Commission Address: 1200 W. Washington Street City/State/Zip: Phoenix, AZ 85007 INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2022 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 6 6 G Interstate Agent/Agreement States 0 0 TOTALS 96 96 State Rating................................................................................................................................................... 100.0 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 2#
AZ HL Program Evaluation, 2022, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a & c) Operator/Inspection Unit totals on Attachment 1 are consistent with the Operator/Inspection Unit totals on Attachment 3. b) No issues. SICT estimated day total was 22. Actual days 77.5 d) No HL reportable incidents. Verified in the PDM. e) No issues. g) Information verified through T&Q Blackboard training site. Training for personnel found to be complete and accurate. h) Working to adopt 84 FR 20940 10/5/2020 amendment. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 3#
AZ HL Program Evaluation, 2022, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. IMP Inspections c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) 5 5 Evaluator Notes: Yes. No notable revisions from prior edition. AZOPS Policy and Procedures Rev. 12-2022. Intrastate Annual Audit Procedure pg. 16-20, Specialized Audits pg. 21, Construction pg. 22, Intrastate Operator Audit Files pg. 26. Interstate Audit Procedures pgs. 29 - 39. On-Site Operator training addressed in separate document. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Major Operator Annual Reports pg. 12; Audit Frequencies pg. 12-13; Work Plan pg. 28. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Yes. Same as prior years. a) Operator Correspondence, pg. 8 & 14-15.); b, c, d Intrastate Annual Audit Procedure (Post Audit) pgs. 18-20, Enforcement pg. 23, Order to Show Cause pgs. 24-25. Underground Facilities Law Enforcement pgs. 50-56. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 Evaluator Notes: Yes. The program system in place to receive telephonic notices of incidents 24/7. All notifications of incidents are recorded DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 4#
AZ HL Program Evaluation, 2022, page 5on the AZOPS telephonic report form. Incident/Accident Investigations pg.'s 40 - 49. On-site investigation determination pg.'s 45-46. 5 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part B. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 5#
AZ HL Program Evaluation, 2022, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required IMP Training before conducting inspection as lead c. Root Cause Training by at least one inspector/program manager d. Note any outside training completed e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: a-c, f. Yes, staff who conducted OQ and Liquid IMP, inspections as Lead have completed the necessary training. d. Yes. Ten inspectors including Program Manager and the Assistant PS Engineer Supervisor have completed Root Cause Training. e. new inspectors are required to complete in-house training for Failure Investigation, Welding Inspection, and Underground Facilities Law. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes. Eric has been with the ACC pipeline safety program since 2002. He has been Program Manager for four years. Eric has successfully completed all T&Q required courses covering all inspection types. 3 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part C. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 6#
AZ HL Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Construction (did state achieve 20% of total inspection person-days?) f. OQ (see Question 3 for additional requirements) g. IMP (see Question 4 for additional requirements) Evaluator Notes: Reviewed all CY inspections. No issues noted. Total DT&C days (11) of SICT estimated total days (22) =50%. Actual total days were 77.5. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Construction f. OQ (see Question 3 for additional requirements) g. IMP (see Question 4 for additional requirements) Evaluator Notes: The program utilizes their own state HL inspection forms for conducting intrastate inspections. Forms described on page 18 of the program's written procedures. Reviewed all CY2022 HL inspections. Ia utilized for all interstate inspections. No issues noted. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR Part 195 Subpart G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Zero days devoted specifically to OQ activities in CY2022. A review of 2022 standard inspections show OQ verifications typically conducted primarily during the field portion of inspection and during DT&C inspections utilizing the OQ Protocol 9 (PHMSA Form 15). Updates to the operator's OQ plans are reviewed during the operator's annual standard inspection. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR Part 195 Subpart F & G Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? 2 2 Evaluator Notes: Seven days devoted to IM activities in CY2022. IM plan updates and plan implementation typically conducted during annual standard inspections as observed during the program field observation portion of this year's HL evaluation. DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 7#
AZ HL Program Evaluation, 2022, page 85 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 195.402; and b. 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; Evaluator Notes: a & b: Part of HL Inspection Report procedures checklist under Damage Prevention Program, and Emergency Procedures sections. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed during standard inspections. Supplemental form provides operator with latest Advisory Bulletin information. One AB issued in CY2022 related to potential damage to pipelines/facilities caused by earth movement or other geological hazards. 7 (Compliance Activities) 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 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) 10 10 Evaluator Notes: Yes. Operator is notified immediately, and issues discussed with management at the time a PV identified. An email is sent by the AZCC inspector to the operator outlining the preliminary findings soon after the exit interview is conducted. No written preliminary findings exceeded the 90-day requirement. The program has demonstrated its fining authority having last collected civil penalties in CY2019. Docket #G-20889A-19-0102 ($50,000 Fine). Another complaint filed in CY2022. Not final yet. Docket to be issued. Staff recommending 75K civil penalty. Both not HL related. 8 (Accident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation 10 10 Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 8#
AZ HL Program Evaluation, 2022, page 9d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: a: Telephone Notice of Gas Incidents mechanism in place to receive calls. b: Yes. Telephonic Incident Report form utilized to document initial notifications. c: N/A. No HL Incidents in 2022. d/e: N/A. f/h: The program has demonstrated maintaining good communications with both AID and WR office. I: State of the State presentation at NAPSR Regional meetings and annual state operator seminar. Also letter to operators on occasions when issue comes up that should be communicated. 9 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 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: State Programs letter issued 10/18/22. PR scoring was 47 of 50 points available for not adopting rule amendments within the required timeframes stipulated. Full points awarded for both NG and HL program evaluations. Chairwoman's response received on 11/3/2022. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes, Last seminar was conducted on 12/14/2021 via MS Teams. No seminars held in CY2022. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes. Question is included in the AZOPS standard inspection forms. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Same as prior years. No changes or additions. The AZCC maintains a public website and works with the Arizona Utility Group. The AZCC is a member of the AZ National Utility Contractors Association, One call ticket resolution committee, Arizona Emergency Response Committee Advisory Board, the Arizona and National Common Ground Alliance. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no SRCR's summitted in CY2022. Verified in the WMS. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 1 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 9#
AZ HL Program Evaluation, 2022, page 10Evaluator Notes: CY2022. Per RC, the program responded to 9 of 16 NAPSR surveys in CY2022. There were no IM notifications summitted in 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No new issued in CY2022. No open waivers related to HL pipelines. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. Files were made readily available and complete. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: total days were 77.5. Discussed past SICT estimates. For CY2022, DT&C actual days were 11 (50%) of SICT estimated total days (22). Actual 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed 2022 results. Pipeline damages per 1000 locate tickets at approximately 0.75 continuing downward trend since 2013. Now at approximately .75 in CY2021. National average of 2.55. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: PSMS question is included in the program's annual inspection checklists. Some operators have adopted aspects of RP 1173. 20 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part D. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 10#
AZ HL Program Evaluation, 2022, page 11PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the Info Only Info Only comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: a. Standard Inspection (Records & Field) of the Swissport PHX Fueling Facility and pipeline. Also, OQ Plan review, OQ Field, D&A short forms, IMP plan review, and Breakout Tank inspections. b. Last inspected in CY2022. The unit is inspected annually. c. Yes, the company was represented. d. Lead inspector John Caughlin has been with the pipeline program since 2014. This was his first hazardous liquid inspection. Juan Guzman assisted during days 3-5 of the inspection. 2 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) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Up to date IA Equivalent inspection forms for HL Standard (Records & Field), OQ Plan & Protocol 9, PAPEI, and Breakout Tank (Records & Field) were utilized. 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: Inspectors had copies of operator procedures for all tasks performed. A detailed review of records was conducted. Mr. Caughlin and Mr. Guzman did not hesitate to ask questions follow-up questions when necessary. Facility site visits determined based in part by review of records and random selection. Checks included instrument calibration, Field OQ's, general condition of pipeline ROW, pipeline markers, valve operation, vaults, PSP reads, rectifiers, casing vents, Field notes were properly documented utilizing the AZCC Notes - Field inspection form. Swissport remote fueling site also included general condition of breakout tanks, cp system, signage, security, and breakout tank overflow protection. The field facility inspection was of adequate length to determine compliance. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Both Mr. Caughlin and Mr. Guzman demonstrated good knowledge of safety programs and regulations. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation 1 1 Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 11#
AZ HL Program Evaluation, 2022, page 12The exit will be conducted at the end of the overall inspection with a written preliminary notice provided to the operator at that time. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: Yes. No unsafe acts were observed. Both inspectors demonstrated adequate knowledge of safety programs and regulations. 7 General Comments: Info Only = No Points Evaluator Notes: No issues noted. No point deductions under Part E. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 12#
AZ HL Program Evaluation, 2022, page 13PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. No changes from prior evaluation years. The ACC uses mandatory quarterly reports for leaks and accidents/damages from operators to track this information. It gives a good real time account of the information. They also review the annual reports to track new installation of and HL pipe. AR review process detailed on pg. 12 of AZOPS written procedures. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No issues noted. The program has a robust excavation damage enforcement program. The state's damages per 1000 locate requests is among the lowest in the country for CY2022 averaging .80% with the national average being 2.55%. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation Info Only Info Only Damage? Info Only = No Points a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Yes. Same as prior years. The programs process for reviewing operator annual reports meet all requirement listed. AZOPS written procedures pg. 12. Reviewed two examples where the AR review identified issues. Both questioning the % of unaccounted gas reported by the operator. No issues with HL reporting identified. 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. 2 2 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 13#
AZ HL Program Evaluation, 2022, page 14d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: Yes. No changes. operators. The information provided includes the number of tickets, number of damages and the cause of damages. This information is compiled by an assigned inspector and reviewed by the Program Manager. Discussed with program Excavation Damage Worksheet results concerning above average percentage of One-Call Notification Practices not sufficient being reported by two of the three largest operators in state and one operator's above average percentage of Excavation Practices not sufficient. 5 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part F. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 14#
AZ HL Program Evaluation, 2022, page 15PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant Info Only Info Only program for documenting inspections? Info Only = No Points Evaluator Notes: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA Info Only Info Only immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 4 If inspections were conducted independent of a PHMSA team inspection did the state Info Only Info Only coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 5 Did the state take direction from and cooperate with PHMSA for all incident Info Only Info Only investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 6 General Comments: Info Only = No Points Evaluator Notes: letter to the Chair. Info Only Info Only Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 141953807 2022 Hazardous Liquid State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 15#
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