RegulusPipeline researchPHMSA casfm-2020-hazardous-liquid-program-evaluation
CASFM HL Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Hazardous Liquid State Program Evaluation for CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL 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: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 1#
CASFM HL Program Evaluation, 2020, page 22020 Hazardous Liquid State Program Evaluation -- CY 2020 Hazardous Liquid State Agency: California Rating: Agency Status: Date of Visit: 09/13/2021 - 09/17/2021 Agency Representative: Jim Hosler PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Michael J. Richwine, State Fire Marshal Agency: CAL FIRE - Office of the State Fire Marshal Address: 2251 Harvard Street, Suite 400 City/State/Zip: Sacramento,, California 95815 60105(a): Yes 60106(a): No Interstate Agent: No 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 2020 (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 48 E Field Inspections 15 15 F Damage prevention and Annual report analysis 6 6 G Interstate Agent/Agreement States 0 0 TOTALS 96 94 State Rating................................................................................................................................................... 97.9 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 2#
CASFM HL Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points 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 Evaluator Notes: Attachment 10* A review of the results of the Progress Report scoring summary spreadsheet found no issues. A review of the programs documentation of inspection days found no issues. different commodities. Total number of operators on attachment 1 does not match attachment 3 because some operators have inspection units of Did a review of staff training in Blackboard - All OK. All regulations and amendment shave been adopted. Civil penalties are set at $200,000.00 and $2,000,000.00 Total possible points for this section: 0 Total points scored for this section: 0 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 3 California#
CASFM HL Program Evaluation, 2020, 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) Evaluator Notes: Yes, written procedures were reviewed Section 8 - Conducting Inspections - 8.9 Section 8 - Conducting Inspections - 8.23 & 8.24 Section 8 - Conducting Inspections - 8.12 & 8.13 Section 8 - Conducting Inspections - 8.22 Section 8 - Conducting Inspections - 8.21 They have this section which is training for New Operators. However, it notes it would work for any reason. Section 8 - Conducting Inspections - 8.11 5 5 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: A) Section 7.3 Time Intervals for Inspections. B) Section 7.3 Risk-based approach. Inspection History Section 7.4.1 Link to Activity Reports C-D_E) Section 7 f. Inspection units are broken down appropriately. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 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, written procedures were reviewed Section 11 - Enforcement Program - 11.3 Section 11 - Enforcement Program - 11.10 Section 11 - Enforcement Program - 11.10 3 3 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 4#
CASFM HL Program Evaluation, 2020, page 54 (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. Evaluator Notes: Yes, written procedures were reviewed Section 10 - Accident Investigation - 10.1 Section 10 - Accident Investigation - 10.1, 1-5 3 3 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 5#
CASFM HL Program Evaluation, 2020, 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 4.4 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: The CaSFM uses a system of monitoring and qualifying inspectors by supervisors and final approval is by program manager before they are allowed to conduct inspections as a lead. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: The program manager has been in the position for several years and showed adequate knowledge of the the pipeline safety program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 6#
CASFM HL Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 3 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 inspections completed for the operators on the 2020 Random Operators list, and found that some types of inspections are not meeting the time intervals established in the CaSFM written procedures. The CaSFM has created a tracker to help ensure that all operator types, units, and inspection types are completed within established time-frames. This also includes tracking the units thru all purchases and separate operators.The program is aggressively working to get all types of inspections back on schedule and should be able to do so in the next couple years. 2-Points deducted for Needed improvement - 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: Yes, the program is using IA to conduct inspections. A review of inspections showed that inspectors were keeping good notes and documenting evidence of probable violations. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 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 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the state looks at this during each annual Standard inspection conducted as required by the State. 2 2 4 Is state verifying operator's integrity management Programs (IMP)? This should include a 2 2 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 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? Evaluator Notes: Yes, this is verified during their annual Standard inspection conducted on each operator as required by the State. DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 7#
CASFM HL Program Evaluation, 2020, 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: Yes, incident investigations for 2020 were reviewed and no issues were found. Incidents investigations are well documented. 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: Yes, this is verified during their annual Standard inspection conducted on each operator as required by the State. 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: After review of inspections conducted for operators on the 2020 Random Operators list the state is following up on all PVs found during inspections, using their enforcement process correctly and verifying compliance. 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? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? 10 10 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 8#
CASFM HL Program Evaluation, 2020, page 9g. 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: their procedures. Reviewed all incidents listed on the progress report showed the CaSFM had investigated all reportable incidents following There were many incidents on the list that were for spills that caused from $1100.00 to $33,000.00 in costs t the operator. In some cases the spills were less than one barrel. The state finds out about them when the operator files a 30 day report. 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 Evaluator Notes: Yes, the letter was received on 9/15/2020 and the state responded on 10/29/2020. 1 1 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: April 17-18, 2019 with TQ help 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, this is verified during the states annual Standard inspection with each operator. Info Only Info Only 12 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the State Fire Marshall information is available on their public web site. 1 1 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, there was one in 2020. The state covers these in staff meetings. 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? Evaluator Notes: Yes, reviewed examples from the Program Manager's files. 1 1 15 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. 1 1 California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 9#
CASFM HL Program Evaluation, 2020, page 10Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PHMSA website showed 11 active waivers for the CaSFM, however the state has reviewed the list and has only 3 active waivers at this time. The state is in contact with PHMSA at this time and is working to clean up the records. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, the programs files and records are well organized and accessible. 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: The program is tracking and evaluating the number of inspection days in SICT on an ongoing basis. They have been very close to the number of actual days over the past couple years. 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: The CaSFM has increased the number of inspection days per 1000 miles of pipeline significantly from 60 in 2016 to 260 in 2020. The Ca SFM training and retention of inspectors has improved ever year with their 5 year retention percentage hitting 60% in 2020. The CazSFM enforcement program evaluation has stayed steady at 100 percent over the past two years. The CaSFM incident investigation program evaluation has been at 100% for many years. 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: Yes OK 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D1. Reviewed inspections completed for the operators on the 2020 Random Operators list, and found that some types of inspections are not meeting the time intervals established in the CaSFM written procedures. The CaSFM has created a tracker to help ensure that all operator types, units, and inspection types are completed within established time-frames. This also includes tracking the units thru all purchases and separate operators.The program is aggressively working to get all types of inspections back on schedule and should be able to do so in the next couple years. 2-Points deducted for Needed improvement - Total points scored for this section: 48 Total possible points for this section: 50 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 10#
CASFM HL Program Evaluation, 2020, page 11PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the 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 Info Only Info Only Evaluator Notes: Corrosion Inspection of Zenith Energy's crude oil line from their facility in Long Beach to their flush tank in El Segundo. It was looked at last year. The operator had representatives present at the inspection. Observed Bita Emami. She is a new inspector so she was working under the lead of Thomas Williams. 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 Evaluator Notes: Yes, the inspector used a question set from iA 2 2 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: The inspector did a good job of asking questions. There were no records reviewed in this part of the inspection. (Field) The inspector did verify the calibration of equipment used during the inspection. The days inspection was just part of the overall ongoing inspection of this operators facilities. 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: asked good in depth questions of the operator. She is new, but showed she has a good understanding of the regulations. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 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: Yes, at the end of the day the inspector covered all concerns and issues discovered not only during this portion of the inspection, but everything discovered to date. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points Info Only Info Only DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 11#
CASFM HL Program Evaluation, 2020, page 12a. 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 Evaluator Notes: No unsafe acts were performed during the inspection. The inspection covered the corrosion control program for this pipeline including the crossings that were cased. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 12#
CASFM HL Program Evaluation, 2020, 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: The CaSFM had 0 - incidents in 2019 and 2020 on HL pipelines by excavation damage. They have worked with the CPUC to look at their damage stats over the past few years to see the trending taking place. 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: As noted in F1, The CaSFM had 0 - incidents in 2019 and 2020 by excavation damage. The California OSFM monitors and coordinates with the California Underground Facilities Safe Excavation Board to verify and coordinate the activities to ensure the safe protection of pipelines from excavation damage. The CPUC, OSFM and the SEB meet and coordinate monthly on excavation damage throughout the state. The programs routinely evaluate, review the regulatory needs and suggested recommendations for improvements throughout the state. 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: As noted in F1, The CaSFM had 0 - incidents in 2019 and 2020 by excavation damage. The California OSFM monitors and coordinates with the California Underground Facilities Safe Excavation Board to verify and coordinate the activities to ensure the safe protection of pipelines from excavation damage. The CPUC, OSFM and the SEB meet and coordinate monthly on excavation damage throughout the state. The programs routinely evaluate, review the regulatory needs and suggested recommendations for improvements throughout the state. 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? 2 2 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 13#
CASFM HL Program Evaluation, 2020, page 14c. 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. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The CaSFM had 0 - incidents in 2019 and 2020 on HL pipelines by excavation damage. TThe California OSFM monitors and coordinates with the California Underground Facilities Safe Excavation Board to verify and coordinate the activities to ensure the safe protection of pipelines from excavation damage. The CPUC, OSFM and the SEB meet and coordinate monthly on excavation damage throughout the state. The programs routinely evaluate, review the regulatory needs and suggested recommendations for improvements throughout the state. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 14#
CASFM HL Program Evaluation, 2020, page 15PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: The California State Fire Marshal's Office is NOT an interstate agent Info Only Info Only 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: The California State Fire Marshal's Office is NOT an interstate agent 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: The California State Fire Marshal's Office is NOT an interstate agent Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: The California State Fire Marshal's Office is NOT an interstate agent Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: The California State Fire Marshal's Office is NOT an interstate agent Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The California State Fire Marshal's Office is NOT an interstate agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 949093272 2020 Hazardous Liquid State Program Evaluation California CAL FIRE - OFFICE OF THE STATE FIRE MARSHAL, Page: 15#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.