# 2011 CASFM HL Program Evaluation - casfm2011hlprogramevaluation (California; Hazardous Liquid State Program Evaluation)

- **operation:** document
- **citation:** PHMSA casfm2011hlprogramevaluation
- **title:** 2011 CASFM HL Program Evaluation - casfm2011hlprogramevaluation (California; Hazardous Liquid State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-01-01
- **effective on:** Not available
- **summary:** 2011 PHMSA hazardous liquid program evaluation for California.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 Hazardous Liquid State Program Evaluation for CDF/OFFICE OF STATE FIRE MARSHAL Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 1

2011 Hazardous Liquid State Program Evaluation -- CY 2011 Hazardous Liquid State Agency: California Rating: Agency Status: Date of Visit: 09/11/2012 - 09/13/2012 Agency Representative: Bob Gorham PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Tonya Hoover, State Fire Marshal Agency: California State Fire Marshal Address: PO Box 944546 City/State/Zip: Sacramento, CA 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 2011 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9.5 B Program Inspection Procedures 15 15 C Program Performance 41 41 D Compliance Activities 14 14 E Accident Investigations 8 8 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (if applicable) 3 3 I 60106 Agreement State (if applicable) 0 0 TOTALS 110 109.5 State Rating................................................................................................................................................... 99.5 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 1 completed accuractely. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Atachment 2 completed accurately. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 3 completed accurately. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 4 OK. CA SFM listed 5 accidents on Progress Report and 5 listed in Pipeline Data Mart. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: Needs improvement. 2011 Certification listed 78 carry over noncompliances and the 2011 Progress Report stated 83 carryover noncomplicances from previous year. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Reports kept in cabinets in CA SFM office in Lakewood, CA. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All employees and training classes were listed correctly on Attachmant 7. 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 1 1 (A1h) Evaluator Notes: $200,000/2,000,000. Yes = 1 No = 0 Needs Improvement = .5 CA SFM rules atomatically adopt US DOT standards. Jan 1, 2012, civil penalty raised to same as federsl civil penalty - DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 3

9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Planned Performance - Each year the primary focus is on performing standard inspections based on risk ranking. The goal is to get the frequency of these inspections down to a minimum of once every three years and to perform some type of inspection on each operator annually. Recruiting and hiring qualified personnel is dificult due to the economy and hiring procedures. Plan on opting out of the interste agent agreement. Past Performance - Identified the need for improved communication between emergency responders and the pipeline operators. Participated in planning meetings in CY 2011 to coordinate and facilitate a series of emergency training classes. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 2 2 2 IMP Inspections (B1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 1 1 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 1 1 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. In Chapter 3 - Section 3.01. DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic area, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 5

Evaluator Notes: Yes. Chapter 3 - Section 3.14 - Criteria for Establishing Inspection Priority 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. 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 6. Interval between standard inspections should not exceed 5 years. 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. 6. Public Awareness Program Effectiveness Evaluation (PAPEE) ? inspectors will review based on availability of staff and workload. Training of inspectors in conducting these inspections will be required before inspectors conduct these inspections. 7. Breakout Tank Inspections ? inspections will be conducted based on availability of staff and workload. 8. Control Room Inspections ? inspections will be conducted based on availability of staff and workload. Inspectors will be required to attend Control Room Management training before conducting these inspections. 9 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 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 527.25 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 527.25 / 1320.00 = 0.40 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. Ratio was .4 which is greater than the needed .38 ratio. 5 5 2 Has each inspector and program fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement Evaluator Notes: Completion of Required OQ Training before conducting inspection as lead? YES ?all personnel who conducted this type of inspection were trained Completion of Required IMP Training before conducting inspection as lead? Staff on waiting list for ECDA ? no IMP program reviews were conducted. Root Cause Training by at least one inspector/program manager. YES ? Chuck MacDonald ? several others in 2012 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Bob Gorham has been the CA SFM program manager many years and has several on numberous NAPSR/PHMSA committees. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Letter sent to CA SFM dated December 7, 2011 and received response latter dated January 9, 2012. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: Yes. Held seminar in torrence, CA in May of 2011. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) 5 5 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 7

Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. Reviewed inspection dates on inspection reports. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. CA SFM uses the fereral hazardous liquid inspection form. 2 2 8 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) (B7) Yes = 1 No = 0 Evaluator Notes: CA SFM reviews Smart Pig run information, annomily repairs and inspection of coatings by operator. 1 1 9 Did the state adequately review for compliance operator procedures for abandoning 1 1 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) (B8) Yes = 1 No = 0 Evaluator Notes: Has information bulletins on abandoment plans, maintains abandoned pipelines on maps and make report annually on abandon pipelines. 10 Is the state aware of environmentally sensitive areas traversed by or adjacent to hazardous liquid pipelines? (reference Part 195, review of NPMS) (B9) Yes = 1 No = 0 Evaluator Notes: Yes. Noted on the CA SFM pipeline mapping system they maintain. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 195.402(c)(5)? (B10,E5) Yes = 1 No = 0 Evaluator Notes: 1 1 The CSFM receives notifications of all reportable accidents. Significant failures are reviewed for assignment. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G5-8,G15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CA SFM only received one annual report for CY2011. They review 30-day accident reports for accuracy and trends. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G9-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Reviewed OQ/IMP databas and information was entered. DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 8

14 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? (G13) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: CA SFM has its own hazardous liquid pipeline mapping system and receives submissions from its regulated operators. To the best of their knowledge each operator is required to make a yearly submission not only to CA SFM but also to NPMS, however, they are not required to notify SFM that they have met that requirement. 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: None conducted in CY 2011. Not identified as a priority in the risk-based inspection plan. 2 NA 16 Is state verifying operators OQ programs are up to date? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 195 Part G (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CA SFM received some plan updates from operators. 2 2 17 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 195.452 Appendix C (C8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Most LIMP Plans were reviewed at the time that the regulations went into effect. No LIMP program reviews will be scheduled until trained staff is available and the need is identified. Because of California's more stringent and robust testing requirements which places an emphasis on tracking and reviewing each IMP required test or inspection we feel we have a good handle on each operators LIMP. 18 Is state verifying operators Public Awareness programs are up to date and being 2 2 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 195.440 (I13-16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Only as a part to the standard inspection checklist. Not identified as a priority to warrant individual reviews based on staff availability. 19 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). (G19-20) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes through webpage and annual questionnaire survey to pipeline operators. 1 1 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Reviewed communication with the PHMSA Western Region. 1 1 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 9

21 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 22 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 41 Total possible points for this section: 41 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 10

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator 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. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director if municipal/government system? Yes No Needs Improvement Evaluator Notes: Yes. Reviewed Conoco Phillips, Kinder Morgan, Valero, and Vopak letters and correspondence. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Reviewed 40 in log book. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes. State law, Title 40 Section 2000, Article 6. Enforcement Proceedings. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Evaluator Notes: Yes. CA SFM issued 2 civil penalties totally $85,000 and collected on 3 civil penalties totaling $23,400. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: Yes. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation Total points scored for this section: 14 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 11

Total possible points for this section: 14 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 12

PART E - Accident Investigations Points(MAX) Score 1 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 (A2,D1-3) Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator 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. 2 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Reviewed book with accident reports. 1 1 3 Were all accidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Evaluator Notes: Yes. Reviewed 5 - Crimson Pipeline, Exxon Mobile Pacific Pipeline, Kinder Morgan and 2 from Conoco Phillips. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: None found during investigation. 1 NA 5 Did the state assist region office by taking appropriate follow-up actions related to the operator accident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: At Western Region meeting and state seminar. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation Info Only Info Only California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 13

Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 14

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. This is reviewed as neeeded during construction inspections. 2 2 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. During standard inspections. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CA SFM is active in the California section of the Common Ground Alliance. April 2012 - SFM newsletter promoting 811. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. CPUC collects this information. 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 15

PART G - Field Inspections 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: Tom Williams Location of Inspection: Los Angeles - I 5 and Shumaker Date of Inspection: September 13, 2012 Name of PHMSA Representative: Jim Anderson Evaluator Notes: Conducted through inspection of lowering pipeline for highway expansion. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Yes. many company representatives on site. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Used federal inspection form. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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) (F5) Yes = 1 No = 0 Evaluator Notes: yes. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation 2 2 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 16

Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Tom is a former operator employee and has completed TQ training courses. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: 1 NA 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding Info Only Info Only DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 17

G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 18

PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: yes. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 19

PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 949093272 2011 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 20
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