Inspectionhistorical
PHMSA casfm2015hlprogramevaluation
2015 CASFM HL Program Evaluation - casfm2015hlprogramevaluation (California; Hazardous Liquid State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA casfm2015hlprogramevaluation
CASFM HL Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 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 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 1#
CASFM HL Program Evaluation, 2015, page 22015 Hazardous Liquid State Program Evaluation -- CY 2015 Hazardous Liquid State Agency: California Rating: Agency Status: Date of Visit: 09/20/2016 - 09/22/2016 Agency Representative: Doug Allen, Daniel Hastert, Bob Gorham, Josh Cleaver PHMSA Representative: Rex Evans Commission Chairman to whom follow up letter is to be sent: Name/Title: Michael Richwine, Acting State Fire Marshal Agency: California State Fire Marshal Address: PO Box 944246 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 2015 (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 8.5 B Program Inspection Procedures 13 13 C Program Performance 44 30.5 D Compliance Activities 15 13 E Accident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (if applicable) 0 0 I 60106 Agreement State (if applicable) 0 0 TOTALS 112 95 State Rating................................................................................................................................................... 84.8 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 2#
CASFM HL Program Evaluation, 2015, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues with information reported. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Summary review by operator - no issues. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues with information on Attachment 3 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All incidents listed appear to meet requirements of reportable incidents and all appear to be accounted for. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Found needs improvement, largely due to timing of getting compliance actions issued. Ribost Terminal compliance actions found in May 2015 were not listed - compliance letters have not been sent out at time of evaluation. They will list them on CY2016 compliance report and note in comments. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 1 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Files were accessible, but improvement needed in organization so operator inspection records can be easily obtained and verification of past inspections are confirmed. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues, recommend thorough review of TQ course curriculum. 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 3#
CASFM HL Program Evaluation, 2015, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8.5 Total possible points for this section: 10 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 4#
CASFM HL Program Evaluation, 2015, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Standard Inspection procedures included in Chapter 3 of Program Procedures along with intervals. Pre,Inspection and Post are included 2 IMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IMP Inspection Activities included in Chapter 3 or procedures. Operators are required to notify and provide summaries of activities. Recommend memorializing this in procedures. 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Included in Chapter 3 of Procedures. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage Prevention included in procedures Chapter 3. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Operator Training generally included in Chapter 3. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: procedures. Construction inspections included in procedures. Construction projects tracked internally, recommend memorializing this in 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 5#
CASFM HL Program Evaluation, 2015, page 6a. Length of time since last inspection (Within five year interval) 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 Evaluator Notes: Information is generally noted in procedures. Units appear to be broken down properly. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 6#
CASFM HL Program Evaluation, 2015, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 0 A. Total Inspection Person Days (Attachment 2): 295.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.00 = 880.00 Ratio: A / B 295.50 / 880.00 = 0.34 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: The program did not achieve person day requirement again in CY2015, Five point deduction again. Discussion held regarding imperative need for each inspector to get field time. 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines 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? 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 e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Reviewed Attachment 7 of progress report information. A couple still waiting ECDA course on IMP, but not lead. Sent engineers to API training on welding and pipe manufacturing. No issues. 3 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Doug Allen recent program manager. Discussion on improvement to process needed. 2 1 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 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Noted deficiencies from the previous evaluation largely stem from the hiring of staff to complete many of the inspections. Deficiencies were addressed - the two quarterly responses requested were received. They had signed letter in file from September 30 as response letter, but our letter said October 7. Gave credit for letter being sent in 60 days. The later letter mentioned quarterly responses omitted in first letter. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: May 17-18, 2016 - Long Beach. 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 5 3 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 7#
CASFM HL Program Evaluation, 2015, page 8Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Crestwood West Coast, Paramount and Tidelands all had inspection in CY2009 and not again until CY2016. Crimson Pipeline, Unit 25A not inspected since CY2009. Found several of the 11 units of Plains All American who had extensive gaps since previous inspections. Discussions with program regarding Plains units found previous plans on "Integrated Inspections" with Plains - made it unclear whether all units necessarily needed inspecting per the II Plan. Program has concentrated on Plains inspections over past year to get caught up with all units and plan to get fully caught up. Based on discussions only deducting two of five possible points, but discussed need to get all units inspected/not just operators. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Forms reviewed appear to have all items covered and completed. 2 2 8 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)? Yes = 1 No = 0 Evaluator Notes: Program maintains database system to review operator records. Has CalOES where records are kept. 1 1 9 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: Operator completes annual questionnaire on systems. More specific than annual reports due to state specific information being listed. Also reviewed during standard inspection. 10 Did state input all applicable OQ, LIMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: It appears the inspections that have been completed are uploaded. 2 2 11 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verify on standard inspections also have state GIS system which requires operators to submit. 1 1 12 Is the state verifying operators are conducting drug and alcohol tests as required by 2 1 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Found several operators with no current drug and alcohol inspections, but some caught up in CY2015/CY2016. Improvement needed 13 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 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation 2 1 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 8#
CASFM HL Program Evaluation, 2015, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Per discussion it appears improvement is needed in getting all programs reviewed. Field OQ inspections are done during standards, but not all programs are up to date. 14 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 1 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Also, through discussion it appears full program reviews are in need of improvement. Monitoring is done a various times, but improvement needed in full programs. 15 Is state verifying operators Public Awareness programs are up to date and being 2 0 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 195.440 PAPEI Effectiveness Inspections should be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Have not completed effectiveness inspections of all operators. Carry over item from previous year. Recommend matching intervals with PAPEI effectiveness of four years. 16 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: Website is in place, pipeline safety division has own section with appropriate information. 1 1 17 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: Information on SRC's shows appropriate actions are taken and monthly updates relayed to Western Region 1 1 18 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 19 If the State has issued any waivers/special permits for any operator, has the state verified 1 .5 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Reviewed this issue. Concentrated on Unocal (Conoco Philliips now) waiver from 1991 where operator had agree to due annual UT thickness verification on tanks in lieu of painting. Last inspection completed on 2011 did not verify conditions of waiver had been met. Improvement needed on this issue. 20 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation 1 1 California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 9#
CASFM HL Program Evaluation, 2015, page 10Yes, Bob Gorham attended NAPSR National in Phoenix 21 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Excavation damage not necessarily relevant to HL lines, but discussion on trends. 22 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 30.5 Total possible points for this section: 44 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 10#
CASFM HL Program Evaluation, 2015, page 11PART 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 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: Enforcement procedures in chapter 3 of procedures. Procedures mention company office such as General Manager and Vice President, but General Manager would not typically be a company officer. Asked to make technical correction in procedures. General follow-up procedures are noted. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 2 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 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 b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: Review of CASFM compliance actions. Compliance action sent to Plains on November 10, 2015 was sent to Western Division Manager and not company officer. Valero compliance action November 16, 2015 was sent to General manager. Need letters sent to corporate officer which was not done. Improvement needed in getting compliance actions issued, found compliance actions found on Ribost Terminal LLC found in May 2015 have yet to be sent out and resolved. Should also make sure no delays with getting issues resolved. Civil penalties were outlined. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Reviewed inspection reports and all compliance actions appear to have been taken care of. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: No issues with due process. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Evaluator Notes: Yes - no issues and considerations all appear adequate. Penalties collected in CY2015 from Chevron - 2 penalties $65k, $100k from CY2014. Phillips 66 $78k from CY2014. Exxon - $174k from CY2014. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 11#
CASFM HL Program Evaluation, 2015, page 12Evaluator Notes: Yes, CASFM has used fining authority. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 15 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 12#
CASFM HL Program Evaluation, 2015, page 13PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This is outlined in Chapter 4 of program procedures. 2 2 2 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 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: Operator notifies CA Office of Emergency Services about any accident. OEA provides CASFM via cell phone email. No issues. 3 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: will still document response in CAL OES database. No issues 1 1 4 Were all accidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? 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: I review of the incidents for CY2015, it appears all were appropriately investigated, factors considered and recommendations as appropriate. Recommend one incident follow-up that occurred on Crimson Pipeline December 2015 on the companies line locate activity to provide proof company actually located hit line. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: 1 1 It did not appear any of the incidents required compliance action at time of review, but appropriate actions taken. 6 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) 1 1 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 13#
CASFM HL Program Evaluation, 2015, page 14Yes = 1 No = 0 Evaluator Notes: Yes 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 14#
CASFM HL Program Evaluation, 2015, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Information is verified in inspection Form 3 under Damage prevention program procedures reviewed during standard inspections 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Also generally included in the Damage Prevention Program Procedures section of Standard Checklist. 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.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Tom Williams part of CGA group and attends meetings. CASFM in stages of setting up Damage Prevention program within CalFIRE 4 Has the agency or another organization within the state collected data and evaluated 2 2 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues at this time. Recommend as state damage prevention program is stood up that some drilling down on damages to HL pipelines is done to benefit program. Much of state data is commingled with gas numbers. 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 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 15#
CASFM HL Program Evaluation, 2015, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: DCOR - Jerry Palo Name of State Inspector(s) Observed: Tommy Flores, Ben Ho Location of Inspection: Huntington Beach location Date of Inspection: September 21, 2016 Name of PHMSA Representative: Rex Evans Evaluator Notes: Evaluation of right of way and vault inspection conducted. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Operator was present, no issues 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) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: No issues - inspection appeared to be well documented. Have asked for final inspection report when complete. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Information appears to have been well documented. Report will be forwarded when entirely finished, attended only one portion of full inspection and follow-up inspection was to occur at later date due to facility access. 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) Yes = 1 No = 0 Evaluator Notes: Yes, maps available - corrosion contractor had necessary measurement equipment. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: The portion of the inspection reviewed related to field activities on their applicable line segments. 2 2 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 16#
CASFM HL Program Evaluation, 2015, page 177 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 Evaluator Notes: Inspector Flores had excellent grasp of program and regulations. 2 2 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) Yes = 1 No = 0 Evaluator Notes: No issues - areas were reviewed with operator during inspection. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Probable violations had not been determined at time of review. 1 NA 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) 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 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation Info Only Info Only California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 17#
CASFM HL Program Evaluation, 2015, page 18E. Vault Maintenance F. Welding 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 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 18#
CASFM HL Program Evaluation, 2015, page 19PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 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.) 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? 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? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Section not applicable Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 19#
CASFM HL Program Evaluation, 2015, page 20PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? 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? 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.) 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? 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? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Section not applicable Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 949093272 2015 Hazardous Liquid State Program Evaluation California CDF/OFFICE OF STATE FIRE MARSHAL, Page: 20#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.