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PHMSA casfm2010hlprogramevaluation
2010 CASFM HL Program Evaluation - casfm2010hlprogramevaluation (California; Hazardous Liquid State Program Evaluation)
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CASFM HL Program Evaluation, 2010, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Hazardous Liquid State Program Evaluation for CDF/OFFICE OF STATE FIRE MARSHAL 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: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 1#
CASFM HL Program Evaluation, 2010, page 22010 Hazardous Liquid State Program Evaluation -- CY 2010 Hazardous Liquid State Agency: California Rating: Agency Status: Date of Visit: 09/19/2011 - 09/21/2011 Agency Representative: Bob Gorham PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Tonya Hoover, Acting State Fire Marshal Agency: California State Fire Marshal Address: PO Box 944246 City/State/Zip: Sacramento, California 94244-2460 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2010 (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 24 24 C Interstate Agent States 7 7 D Accident Investigations 6 6 E Damage Prevention Initiatives 9 9 F Field Inspection 9 9 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 103 103 State Rating................................................................................................................................................... 100.0 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 2#
CASFM HL Program Evaluation, 2010, 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: 2011 Certification was completed and filled out properly. 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: Communications with Califirnia Emergency Management Agency with letter dated April 12, 2011 with current employee phone numbers. State law requires for operators to contact the EMA for leaks on their system. 3 Has the state held a pipeline safety T & Q seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar 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: CA SFM conducted a TQ seminar in May 2008 and again in May 2011. 2 2 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: Working toward a paperless record keeping system. CA SFM has its own server located in Sacramento, CA and it is backed up nightly. 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 SLR Notes: Yes. Bob Gorham has been program manager for many years and was the Chair of the NAPSR Liaison Committee in 2010. 2 2 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: Yes - letter to CA SFM was dated 8/19/2011 and response letter was dated 10/4/2011. 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 SLR Notes: DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation 1 1 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 3#
CASFM HL Program Evaluation, 2010, page 41 - In 2009, CASFM did not get the minimum 85 inspection days per person year. In 2010, the CASFM did meet the required 85 inspection days per person year. 2 - In 2009, the CASFM did not send interstate agent inspection documentation to the Western Region within 60 days. In 2010, although the documentation was not sent within the 60 days, communication with the Western Region about the inspection was conducted within 60 days to ask for an extention. 3 - In 2009, statistics/data was not kept on pipeline damages for each one thousand locate request. Not kept in 2010, more of a gas distribution data keeping. 4 - In 2009, OQ inspections were not entered into the PHMSA database. In 2010, OQ inspections were entered into the OQ database. 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: TQ's SABA reports all inspectors employed by the CASFM for more than 3 years have completed all training for conducting HL standard inspections. In 2007, TQ required all HL IMP inspectors to take the PL 3306 course. None of the CASFM inspectors have taken this course. 9 Brief Description of Non-T&Q training Activities Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: 10 SLR Notes: Yes. 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 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 SLR Notes: All, but PL 3306 (ECDA). ECDA is not allowed by state law in CA. 1 1 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): 549.01 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.00 = 1320.00 Ratio: A / B 549.01 / 1320.00 = 0.42 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 5 5 SLR Notes: Yes. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 4#
CASFM HL Program Evaluation, 2010, page 5Info Only = No Points SLR Notes: No. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 5#
CASFM HL Program Evaluation, 2010, 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) 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) SLR Notes: 6.5 6.5 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 Yes, these are listed in the procedures manual taht was updated in 2010. Received an electronic copy for file. 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: Yes, in Section 3.14 of the procedures manual. 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: Yes. 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 SLR Notes: Yes, CA SFM used the federal hazardousliquid inspection form. 1 1 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.6 1 1 Yes = 1 No = 0 SLR Notes: Yes, checked Kinder Morgan 1400B-SFPP, LP Watson to Norwalk and Kinder Morgan 1400B-SFPP, LP Concord to Sacramento line reports. 6 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, checked Pipeline Data Mart prior to inspection and all SLRs were closed. DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation .5 0.5 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 6#
CASFM HL Program Evaluation, 2010, page 77 Did the state review operator procedures for determining areas of active corrosion on liquid lines in sufficient detail? (NOTE: PHMSA representative to describe state criteria for determining areas of active corrosion) Previous Question B.8 Yes = .5 No = 0 SLR Notes: Yes, this is covered in using the federal inspection form. Operatorspick this up on smart pig runs and CASFM review test results. .5 0.5 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, operators notify the CASFM for lines taken out of service or abandon. .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 SLR Notes: Yes. .5 0.5 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, there were 4 in 2010 and of these 3 were significant. 1 1 27 SLR Notes: Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Info Only = No Points Info Only Info Only 28 Part B: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous Question B.13 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, reviewed a VENOCO and Chevron inspection report thru compliance actions. 1 1 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: Yes, it is in the procedures manual Chapter 3.12 - Enforcement Proceedings. When a noncompliance is identified a written notice of the results of an inspection shall be sent to a company officer such as a vice president or general manager. This notice will follow the procedures outlined in Title 19 of the California Public Safety Code of Regulations, Chapter 14, Article 6. DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 7#
CASFM HL Program Evaluation, 2010, page 813 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 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, it is in the procedures manual Chapter 3.12 - Enforcement Proceedings. When a noncompliance is identified a written notice of the results of an inspection shall be sent to a company officer such as a vice president or general manager. This notice will follow the procedures outlined in Title 19 of the California Public Safety Code of Regulations, Chapter 14, Article 6. 14 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, it is in the procedures manual Chapter 3.12 - Enforcement Proceedings. When a noncompliance is identified a written notice of the results of an inspection shall be sent to a company officer such as a vice president or general manager. This notice will follow the procedures outlined in Title 19 of the California Public Safety Code of Regulations, Chapter 14, Article 6. 15 Has the State issued compliance actions for all probable violations discovered? (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(1).4 Yes = 1 No = 0 SLR Notes: Yes, on all report reviewed. 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 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: Yes, has documentation in notebook for all NCs back to 2006. 1 1 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: NA for 2010. 1 NA 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question C(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, CASFM keeps good records on probably violations. 1 1 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: Yes, it is in their procedures manual in Chapter 3.12 Enforcement Proceedings When a noncompliance is identified a written notice of the results of an inspection shall be sent to a company officer such as a vice president or general manager. This notice will follow the procedures outlined in Title 19 of the California Public Safety Code of Regulations, Chapter 14, Article 6. 20 SLR Notes: DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation 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 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 8#
CASFM HL Program Evaluation, 2010, page 9Yes, CASFM followed state law. 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: NA 1 NA 22 SLR Notes: NA Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question C(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 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: NA 24 SLR Notes: NA 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 25 SLR Notes: NA 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 26 SLR Notes: NA 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 Total points scored for this section: 24 Total possible points for this section: 24 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 9#
CASFM HL Program Evaluation, 2010, 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: Yes, CA SFM uses federal hazardous liquid inspection form. 1 1 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: Yes, CA SFM provided evaluator a PHMSA directed inspection plan for 2010. 1 1 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 1 1 SLR Notes: Communication with Western Region about inspections were conducted within the 6o day time frame. Actual report sent after 60 days. 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 1 SLR Notes: Certification. 2 probable violations were found during the inspections and both were submitted to the PHMSA Western Region and documented on the 2011 HL 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 1 SLR Notes: Yes. 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: Yes. 1 1 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: Yes. 1 1 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 10#
CASFM HL Program Evaluation, 2010, 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 SLR Notes: Yes. 1 1 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 SLR Notes: Yes, this is reference in the procedures manual in Chapter 8 - Enforcement Procedures - Section 8.04. .5 0.5 3 Did the state keep adequate records of accident notifications received? Previous Question D.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. 1 1 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: NA 1 NA 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? 2 2 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: Yes, very good records kept. 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: Yes, Chevron was fined $10,000 for a noncompliance found during an accident investigation. 1 1 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 .5 .5 SLR Notes: Yes. 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 11#
CASFM HL Program Evaluation, 2010, page 12Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 12#
CASFM HL Program Evaluation, 2010, 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: Yes. Shell IVEC line beneath I-5 - Line# 409. Also during construction inspections which are mostly relocation of pipelines. 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: Yes. During standard inspections and during USA North/South meetings. 12 damage prevention activity days conducted in 2010. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.8 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, Bob Gorham and staff are actively involved in CGA meeting and conference calls. 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: We have confirmed with CPUC that they are collecting this information, This issue was addressed in our response to Zach Barrett after last year's evaluation. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 195.402 (c)(5)? Yes = 2 No = 0 2 2 SLR Notes: Yes. Last major incident was in 2010 - City of Long Beach vs. BP. Accident file line # 143 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 13#
CASFM HL Program Evaluation, 2010, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Kinder Morgan Name of State Inspector(s) Observed: Doug Allen Location of Inspection: Fairfield, CA Date of Inspection: September 19, 2011 Name of PHMSA Representative: Jim Anderson Info Only Info Only SLR Notes: 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: Yes, several employees including Steve Marositz, Manager, Pipeline Safety - Pacific Region. 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 SLR Notes: Yes, used federal form. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question E.3 Yes = 2 No = 0 SLR Notes: Yes. 2 2 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 SLR Notes: NA 1 NA 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 SLR Notes: Office visit for records. Info Only Info Only 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 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) 2 2 SLR Notes: DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 14#
CASFM HL Program Evaluation, 2010, page 15Yes. 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 SLR Notes: Yes. 2 2 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: NA at this time during the inspection. 1 NA 10 SLR Notes: NA During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question E.11 Yes = 1 No = 0 1 NA 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Info Only = No Points SLR Notes: No field inspection was observed. Info Only Info Only 12 SLR Notes: Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points 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 q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation Info Only Info Only California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 15#
CASFM HL Program Evaluation, 2010, page 16u. 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: 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 16#
CASFM HL Program Evaluation, 2010, 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 1.5 1.5 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, it is in the procedures manual - Section 3.14 - Criteria for Establishing Inspection Priority. For Standard inspections: 1. The length of time since the last inspection. 2. The history of the inspection unit (leak history, prior noncompliance, accident/incident history, etc.) 3. Internal and external events affecting the inspection unit (construction, recent changes in operator personnel or operating procedures, etc.) 4. On large operators, rotation of locations inspected. 5. All interstate inspections agreed to in the Interstate Inspection Plan For other types of Inspections: 1. OQ inspections will be performed on a continuing basis to follow-up and verify compliance. This includes a review of their OQ Plan (New operators) and review and an ongoing review of their field compliance. Emphasis is on performing a field verification of all operators utilizing Protocol 9 inspection Form. Thereafter, random OQ inspections will be performed. All OQ inspections conducted will be uploaded into the PHMSA OQ database in a timely manner. 2. Construction inspections will be conducted on a routine basis. Construction projects are tracked and assigned to inspectors. New pipeline construction will receive a higher inspection priority. Additionally, replacement projects by small operators will be closely monitored. 3. Field review of Integrity Management Plans and programs will be reviewed based on availability of staff and workload. All pipeline integrity test results received in the office will be reviewed by inspection staff for adequacy and timeliness. All IMP inspections will be uploaded to the PHMSA database in a timely manner. 4. Accidents will be investigated as they occur. 5. Damage prevention activities ? Inspectors will respond to requests from operators to assist in educating contractors and other entities from encroaching on their pipeline rights-of-way or failure to use the one-call center. Participation in one-call and CGA contractor awareness meetings as schedule permits. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: Yes, Units are evaluated by inspectors in field to determine if changes are needed. .5 0.5 3 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: The PSD maintains a database to track inspection history of each pipeline and pipeline operator. The database is populated primarily through inspection activity and operator data submissions including testing records and accident investigations. This database contains an overall profile of each operator's inspection units. These profiles can be reviewed and prioritized by risk. The PSD utilizes a risk-based inspection approach in establishing inspection priorities. 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) Yes = .5 No = 0 SLR Notes: Yes, reviews leak reports. .5 0.5 5 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: Yes ? reviews from OPS site and those that are received from operator. (limited value) .5 0.5 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 17#
CASFM HL Program Evaluation, 2010, page 186 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: Yes, when received. .5 0.5 7 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: Yes, Form 7000-1 reports reviewed. .5 0.5 8 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures,trends,etc.) Yes = .5 No = 0 SLR Notes: Yes, looks at trends from operators. Refocus inspection efforts if necessary. .5 0.5 9 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 SLR Notes: Yes, reviewed PHMSA's webpage prior to evaluation. .5 0.5 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 SLR Notes: Yes, Hydrotest and ILI results and reviewed PHMSA's webpage prior to evaluation. .5 0.5 11 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: Yes, PHMSA Form 19 - Hazardous Liquid IMP Field Verification Inspection. .5 0.5 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, CA SFM uses federal inspection forms. .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 SLR Notes: Yes, SFM has its own liquid pipeline mapping system. They notified NPMS of inadequacy of there data verification process. .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 14 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) Yes = .5 No = 0 SLR Notes: Yes, at Western Region NAPSR meetings and TQ seminars. .5 0.5 15 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 18#
CASFM HL Program Evaluation, 2010, page 19Yes = .5 No = 0 SLR Notes: Yes, CA SFM reviews 7000-1 reports and keeps in communication with the Western Region and notes changes as needed. 16 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points SLR Notes: Not yet ? PS Engineers know operators need to do it. Info Only Info Only 17 SLR Notes: Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only No ? up to operator to conduct. SFM reviews and is involved. 18 Has state participated on root cause analysis training? (can also be on wait list) No = 0 Yes = .5 SLR Notes: Chuck McDonald has succesfully takent he course. Five inspectors are on the TQ waitlist for attendance. .5 0.5 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: Yes ? on CA SFM website. 20 Does state share enforcement data with public? (Website, newsletters, etc.) Yes = .5 No = 0 SLR Notes: Yes ? on CA SFM website. .5 0.5 21 Part G: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 19#
CASFM HL Program Evaluation, 2010, 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: Hired one engineer in 2010. Bob Gorham is on the NAPSR Board and has been the Liaison Committee Chair for 4 years. Leak rates remain low. Refer to SFM annual report for other accomplishments. 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: San Bruno Gas explosion has created numerous statewide initiatives and proposed legislative changes. While mostly directed at the CPUC and natural gas operators, the CASFM has been active in seeking a statewide website where emergency response plans, mapping information and contact numbers can be assessed 24 hours a day through a secure website. The California CGA is actively working on developing an enforcement model for one call dig law violations. Working on a letter/advisory to operators concerning a recent uptick in internal corrosion leaks. 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: Major leaks are down. Focusing on in plant piping and facility leaks. 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 to NAPSR/PHMSA and OIG surveys. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes, at NAPSR meetings. 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 20#
CASFM HL Program Evaluation, 2010, 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: Yes, during standard inspections. 1 1 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 SLR Notes: Yes, sent Stan Kastanas a Drug Inspection Report on Febuary 18, 2011. .5 0.5 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: Yes, no positive tests were found in 2010. .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 195 Subpart G) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: Yes, during OQ inspections. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 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, during maintenance, replacement projects and at standard inspections. 5 OQ inspections conducted in 2010. .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. .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 SLR Notes: Yes. 1 1 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 SLR Notes: DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation .5 0.5 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 21#
CASFM HL Program Evaluation, 2010, page 22Yes, state's mapping program identifies HCA's and is used to verify line jurisdiction and testing requirements. Under state law all portion of pipeline are tested. 10 Has the state reviewed operator IMPs for compliance with 195.452? Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 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 .5 0.5 SLR Notes: Yes, state law requires all intrastate pipeline test results to be submitted to CA SFM for review. CA SFM goes to all SRC and immediate dig-ins. 12 Is the state verifying operators are periodically examining their hazardous liquid piplines for the appearance of .5 0.5 new HCAs? Yes = .5 No = 0 SLR Notes: tested. Yes, state's mapping program identifies HCA's and is used to verify line jurisdiction and testing requirements. Under state law all portion of pipeline are 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: program. 3 inspectors west to PHMSA Public Awareness seminars to become more knowledgeable in assisting operators on a more effective public awareness 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 SLR Notes: Yes. .5 0.5 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 SLR Notes: Yes, during inspections and as needed. .5 0.5 16 SLR Notes: Is the state verifying that operators have evaluated their public awareness programs for effectiveness as described in RP1162? Info Only = No Points Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 949093272 2010 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 22#
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