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PHMSA flpsc-2021-gas-program-evaluation
2021 FLPSC NG Program Evaluation - flpsc-2021-gas-program-evaluation (Florida; Natural Gas State Program Evaluation)
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FLPSC NG Program Evaluation, 2021, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2021 Gas State Program Evaluation for FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 1#
FLPSC NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: Florida Rating: Agency Status: Date of Visit: 03/21/2022 - 04/06/2022 Agency Representative: Mr. Robert Graves Gas Safety Program Manager PHMSA Representative: Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Andrew Giles Faye, Chairman Agency: Florida Public Service Commission Address: 2540 Shumard Oak Blvd. City/State/Zip: Tallahassee, Florida 32399-0850 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2021 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 2#
FLPSC NG Program Evaluation, 2021, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: 1.a. Data in Attachment 1 of Progress Report seems accurate. 1.b. Data in Attachment 2 of Progress Report seems accurate. 1c. Data in Attachment 3 of Progress Report seems accurate. 1.d. Information in Attachment 4 of Progress Report is accurate. 1.e. Information in Attachment 5 of Progress Report seems accurate. 1.f. Information in Attachment 6 of Progress Report is accurate. 1.g. Information in Attachment 7 of Progress Report seem accurate. 1.h. Information in Attachment 8 of Progress Report is accurate. 1.i. Information in Attachment 10 of Progress Report seem accurate. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 3#
FLPSC NG Program Evaluation, 2021, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Yes. The procedures are included in the Division of Engineering SOP 1111, pages 27 - 30. 5 5 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Yes. The procedures are included in the Division of Engineering SOP 1111, page 27. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Yes. The procedures are included in the Division of Engineering SOP 1123, page 56. 3 3 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 Evaluator Notes: There is a procedure for when an onsite investigation was not made, to obtain sufficient information in SOP 1122 page 50. *Note: Recommend add wording to SOP 1122 ? Accident and Incident Inspection section wording on the Mechanism to DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 4#
FLPSC NG Program Evaluation, 2021, page 5receive, record, and respond to operator reports of incidents, including after‐hours reports. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 5#
FLPSC NG Program Evaluation, 2021, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: - Rudy Isaac only inspector qualified to lead Gas IM inspections. - Not qualified to lead DIMP: Norman Witman and Rafael Bohorquez. - Not qualified to lead failure investigation: Norman Witman (missing Root Cause Course). There were no issues. 5 5 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. The pipeline safety program manager had adequate knowledge of PHMSA program and regulations. 5 5 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part C of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 6#
FLPSC NG Program Evaluation, 2021, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: - Standard ? Distribution- WILLISTON GAS DEPT, CITY OF (4/6/21 & 9/30/20), CENTRAL FLORIDA GAS CORP (9/8/21 & 9/9/20), MADISON, CITY OF (5/20/21 & 10/16/20), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/12/21 & 11/12/20), CENTURY, TOWN OF (11/17/21 & 10/20/20), QUINCY MUNICIPAL GAS SYSTEM, CITY OF (11/17/21 & 10/30/20), JAY, TOWN OF (4/14/21 & 7/6/20), FLORALA UTILITY BOARD, CITY OF (5/17/21 & 2/26/20); Transmission - SEBRING GAS SYSTEM, INC ( 5/21/21 & 10/12/20), HARDEE POWER PARTNERS LTD (9/13/21 & 12/15/20), CONTINENTAL BUILDING PRODUCTS (4/26/21 & 3/4/20); M/M - Area Housing Commission Pensacola (12/22/21 & 11/20/20), Ft Walton Beach Housing Authority (12/16/21 & 10/13/20), Gainesville Housing Authority (9/7/21 & 7/15/20), Universal Orlando (11/16/21 & 9/3/20). - P/A ? is included in Standard inspections. - D/A - Distribution- WILLISTON GAS DEPT, CITY OF (8/23/19), CENTRAL FLORIDA GAS CORP (8/13/19), MADISON, CITY OF (7/10/19), ), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/17/19), CENTURY, TOWN OF (5/24/19), QUINCY MUNICIPAL GAS SYSTEM, CITY OF (11/8/19), ), JAY, TOWN OF (5/21/19), FLORALA UTILITY BOARD, CITY OF (2/20/19), Transmission - SEBRING GAS SYSTEM (8/5/19), HARDEE POWER PARTNERS LTD (11/6/19), CONTINENTAL BUILDING PRODUCTS (3/4/19). - CRM ? No control rooms. - Construction ? No construction inspections. - OQ ? is included in Standard inspections. - DIMP ? is included in the Standard inspection. - IMP - Transmission - SEBRING GAS SYSTEM, INC (8/5/20 & 9/11/15), HARDEE POWER PARTNERS LTD (6/28/18 & 8/7/13), 2 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. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 10 Evaluator Notes: Reviewed the following inspections: Standard, /P/A, OQ, ? Distribution- WILLISTON GAS DEPT, CITY OF (4/6/21), CENTRAL FLORIDA GAS CORP (9/8/21), MADISON, CITY OF (5/20/21), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/12/21), CENTURY, TOWN OF (11/17/21), QUINCY MUNICIPAL GAS SYSTEM, CITY OF (11/17/21), JAY, TOWN OF (4/14/21), FLORALA UTILITY BOARD, CITY OF (5/17/21); Transmission - DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 7#
FLPSC NG Program Evaluation, 2021, page 8SEBRING GAS SYSTEM, INC ( 5/21/21), HARDEE POWER PARTNERS LTD (9/13/21), CONTINENTAL BUILDING PRODUCTS (4/26/21); M/M - Area Housing Commission Pensacola (12/22/21), Ft Walton Beach Housing Authority (12/16/21), Gainesville Housing Authority (9/7/21), Universal Orlando (11/16/21). Yes. The inspection forms covered all applicable code requirements addressed on Federal Inspection forms. The state completed all applicable portions of inspection forms. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Reviewed the following inspections: Distribution- WILLISTON GAS DEPT, CITY OF (4/6/21), CENTRAL FLORIDA GAS CORP (9/8/21), MADISON, CITY OF (5/20/21), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/12/21), CENTURY, TOWN OF (11/17/21), QUINCY MUNICIPAL GAS SYSTEM, CITY OF (11/17/21), JAY, TOWN OF (4/14/21), FLORALA UTILITY BOARD, CITY OF (5/17/21); Transmission - SEBRING GAS SYSTEM, INC ( 5/21/21), HARDEE POWER PARTNERS LTD (9/13/21), CONTINENTAL BUILDING PRODUCTS (4/26/21), M/ M - Area Housing Commission Pensacola (12/22/21), Ft Walton Beach Housing Authority (12/16/21), Gainesville Housing Authority (9/7/21), Universal Orlando (11/16/21). Yes. The state is monitoring operators OQ programs. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 Evaluator Notes: Reviewed the following inspections: Distribution - WILLISTON GAS DEPT, CITY OF (4/6/21), CENTRAL FLORIDA GAS CORP (9/8/21), MADISON, CITY OF (5/20/21), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/12/21), CENTURY, TOWN OF (11/17/21), QUINCY MUNICIPAL GAS SYSTEM, CITY OF (11/17/21), JAY, TOWN OF (4/14/21), FLORALA UTILITY BOARD, CITY OF (5/17/21); Transmission - CONTINENTAL BUILDING PRODUCTS (12/3/21), M/M - Ft Walton Beach Housing Authority (12/16/21), Universal Orlando (11/16/21). ? The FLPSC inspects every operator on annual basis to discuss annual implementation of their DIMP/IMP plans. ? Recommend the FLPSC use the most current IA equivalent inspection forms to document state is verifying with the operators any plastic pipe and components that have shown a record of defects/leaks. ? The FLPSC has the low-pressure distribution question added to the GS-05 Pressure Regulation form. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); 2 2 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 8#
FLPSC NG Program Evaluation, 2021, page 9c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: 5a. The question is included on the GS-3 O&M form page 11. 5b. The question is included on the GS-3 O&M form page 12. 5c. The question is included in the GS-3 O&M form page 4 -5. 5d. The question is included in the GS-3 O&M form page 5. 5e. The question is included in the GS-3 O&M form page 3. 5f. The question is included in the PHMSA Form 24 and DIMP Implementation Form page 4 of 31. 5g. The question is included in the GS-5 Pressure Regulation from page 7. Note: The FLPSC emailed each operator a link to the NTSB recommendations on January 10, 2022. Note: No change since CY 2021, except for the email link to operators. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The FLPSC emailed each operator a link to the advisory bulletins on January 10, 2022. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) 10 10 Evaluator Notes: Reviewed the inspections: MADISON, CITY OF (5/20/21), CITY OF JACKSONVILLE BEACH D/B/A BEACHES ENERGY SERVICES (10/12/21), CENTURY, TOWN OF (11/17/21), CONTINENTAL BUILDING PRODUCTS (4/26/21), Area Housing Commission Pensacola (12/22/21). ? Compliance actions were sent company officers or manager/board members. DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 9#
FLPSC NG Program Evaluation, 2021, page 10? Probable violations were documented and resolved properly. ? The FLPSC routinely reviews progress of probable violations. ? The state issued compliance actions for all probable violations discovered. ? The FLPSC fined Peoples Gas $1,000,000 in 2016. ? The Program Manager reviews, approves, and monitors all compliance actions. ? State conducted a post-inspection briefing with operator within 30 days. ? State provided operator with written preliminary findings with in 90 days. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: There were no federally reportable incidents in CY 2021. There was an incident that occurred in 2021, but Peoples Gas reported the incident in 2022. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Letter sent June 3, 2021; response received June 30, 2021. No issue. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: The FLPSC had pipeline safety seminar 8/3/21 (Discussed Section 114) & 11/9/21 (Discussed PSM). Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: The question is included in the FLPSC GS-13 Summary form. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The FLPSC communicates to its stakeholders through its State webpage where there is a "Public Records Requests" page. DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 10#
FLPSC NG Program Evaluation, 2021, page 11The public can use this page as a FOIA request. he FLPSC website communicates information to effected stakeholders and the public pertaining to 811, pipeline safety program (annual reports, gas maps, etc.), and call before you dig info. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no open SRC reports. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 1 Evaluator Notes: The State was responsive to surveys or information requests form NAPSR or PHMSA. FLPSC has to follow-up on a SRC in WMS for Peninsula Pipeline Company that has no note update. This was created on 7/26/21. There was a note submitted in WMS on 2/8/22. No issue. 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There are no waivers/special permits for the pipeline safety office. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. The pipeline files are stored electronically in FLPSC pipeline safety database. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: There were no issues with accuracy of inspection day information submitted into State inspection Day Calculation Tool (SICT). The State updated its SICT data from CY 2020 to CY 2021. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: The State Program Performance Metrics were not current for CY 2021 except Leak Management. There were no negative trends found within this category. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: The FLPSC had a PSM seminar with at an estimated 100 participants on 11/9/21. Peoples Gas (largest operator in state) provided the information to the participants. FLPSC provided the recording and slide presentation of the seminar to FL Gas Association to disseminate to all the operators. DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 11#
FLPSC NG Program Evaluation, 2021, page 1220 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part D of the program evaluation. DUNS: 074152559 2021 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 12#
FLPSC NG Program Evaluation, 2021, page 13PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Operator: Lake Apopka Natural Gas Inspectors: Rudy Isaac (L) and Tony Velazquez Location: Winter Garden FL Type of Inspection: Standard Field Date: March 22 - 24 PHMSA Rep.: Clint Stephens ? Last inspected 7/20/21 ? The pipeline operator was present during the inspection. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The inspector used the GS-04 (Corrosion Survey), GS-05 (Pressure Regulation), GS-06 (Odorization), and GS-14 (Valve Survey) during the inspection. The forms were used as a guide. 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: The inspector asked the operator adequate questions to determine compliance. The inspector ensured procedures were being followed, equipment was calibrated, and operator personnel was OQ qualified. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: From my observation, the inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 13#
FLPSC NG Program Evaluation, 2021, page 14Evaluator Notes: An exit interview was not conducted at the time of this inspection; however, the operator was made aware of any safety issues or probable violations the moment they were identified. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only Info Only Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: The inspection was performed in a safe, positive, and constructive manner. The inspector observed the operator operate valves, check cathodic protection (pipe-to-soil and rectifier readings), tested over pressure protection equipment, and checked odorant. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 14#
FLPSC NG Program Evaluation, 2021, page 15PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The state has reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Reviewed spreadsheets and charts with information taken from the 2020 annual reports. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Peoples Gas (Largest gas operator) holds meetings with State Fire Marshall and the excavators to discuss training opportunities. The State Fire Marshall sent out a TEAMS invite to the necessary stakeholders pertaining to "Developing local education and Information Underground Pipeline Damage" (3/9/22). 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: The state is reviewing the operator's annual report pertaining to Part D ? Excavation Damage. The information has been verified for accuracy with root cause numbers. The state has evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient", " Excavation Practices Not Sufficient", and "Locating Practices Not Sufficient". 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. 2 2 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 15#
FLPSC NG Program Evaluation, 2021, page 16d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The state has collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests. 811 Sunshine has collected data on the stakeholder group that is causing the highest number of damages to pipelines. The excavator is causing the highest number of damages. The State Fire Marshall sent out a TEAMS invite to the necessary stakeholders pertaining to "Developing local education and Information Underground Pipeline Damage" (3/9/22). 811 sunshine evaluated the reasons/root causes for exaction damages and that information has been submitted to DIRT. Peoples Gas has established an outreach program to engage, at a leadership level, approximately twenty of the riskiest excavators as measured by the number of 2021 significant pipeline damages. This outreach program is designed as one part of the strategy to mitigate damages through engagement targeted at the highest risk excavators. "High Risk Excavator" is defined as an excavator who damages PGS facilities based on the quantity of high-risk damages in 2021. High risk damages include damages that are caused by a backhoe/excavator directional drill, pneumatic drill. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 16#
FLPSC NG Program Evaluation, 2021, page 17PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: FLPSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 074152559 2021 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 17#
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