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PHMSA flpsc-2022-gas-program-evaluation
2022 FLPSC NG Program Evaluation - flpsc-2022-gas-program-evaluation (Florida; Natural Gas State Program Evaluation)
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FLPSC NG Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 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 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 1#
FLPSC NG Program Evaluation, 2022, page 22022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Florida Rating: Agency Status: Date of Visit: 03/20/2023 - 03/24/2023 Agency Representative: Mr. Robert Graves, Gas Safety Program Manager PHMSA Representative: Michael Thompson, State Liaison WR 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 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 2022 (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 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 2#
FLPSC NG Program Evaluation, 2022, 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: Review of progress report information appears to be accurate. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 3#
FLPSC NG Program Evaluation, 2022, 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: A. Standard Inspections are in SOP 1111, Pages 27-30 B. TIMP & DIMP in SOP 1129 Pages 76-77 C. OQ inspections = SOP 1126 and 1127, Pages 69-70 D. Damage prevention is part of Standard inspection SOPP 1111 E. On-site Operator training = SOP 1106, page 20 F. Construction Inspections = SOP 1121 Page 49 G. LNG Inspection = No LNG facilities in Florida 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, pages 55-56 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 3 3 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 4#
FLPSC NG Program Evaluation, 2022, page 5b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Incident investigation SOP 1107, Pages 22-23 also in SOP 1122 Pages 50-54 5 General Comments: Info Only = No Points Evaluator Notes: No issues with this part of evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 5#
FLPSC NG Program Evaluation, 2022, 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: Inspectors that lead inspections in 2022 had the required TQ training before being assigned to lead. 5 5 2 Did state records and discussions with state pipeline safety program manager indicate 5 5 adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, Robert Graves the PM showed ad adequate knowledge of the pipeline safety program, and regulations during the evaluation. 3 General Comments: Info Only = No Points Evaluator Notes: No issues identified in this part of the evaluation Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 6#
FLPSC NG Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 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) 5 5 Evaluator Notes: Reviewed all types of inspections conducted for each operator on the random sample list, and checked to insure that the inspections where completed during the required time interval. 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: Yes, the forms used covered all applicable code requirements addressed in the PHMSA forms for each type of inspection. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the state is monitoring the operator's OQ programs 2 2 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: DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 7#
FLPSC NG Program Evaluation, 2022, page 8The FLPSC conducts their DIMP inspections annually for all operators and has quarterly meetings with their states largest operator where DIMP is one of the topics discussed. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator 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); c. 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. 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 state has emailed all operators a copy of the ADBs in January of 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. 10 10 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 8#
FLPSC NG Program Evaluation, 2022, page 9i. 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) Evaluator Notes: After a review of all compliance actions for 2022 it was found that; A. Compliance actions were sent company officers or manager/board members. B. Probable violations were documented and resolved properly. C. All Probable Violations reviewed were resolved. D. The Program Manager routinely reviews progress of probable violations. E. The state issued compliance actions for all probable violations discovered. F. The only civil penalty recorded was to Peoples Gas in 2016 for $1,000,000.00 G. The Program Manager reviews, approves, and monitors all compliance actions. H. The state has a reasonable due process. I. State conducted a post-inspection briefing with operator within 30 days. J. 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? Evaluator Notes: There was one reportable incident in 2022. It was investigated and documented thoroughly with no probable violations issued. 10 10 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, letter was sent on 5/20/2022 and the response was received from the chair on 6/8/2022. The points lost were tied to the progress report review. 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 State held a pipeline safety seminar on 8/3/21 & 11/9/21 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: DUNS: 074152559 2022 Gas State Program Evaluation Info Only Info Only Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 9#
FLPSC NG Program Evaluation, 2022, page 10Yes, the question is included on their form. 12 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The program has a web site that they use to communicate with stakeholders. 1 1 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 was 1 in 2022 and it is still open at this time. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, the state is responsive to PHMSA and NAPSR surveys. The state is also responsive to items in WMS. 1 1 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 active waivers at this time. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, the programs files were well organized. 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 Evaluator Notes: Discussed the accuracy of the SICT numbers for the state and what the intend use of the numbers is. Yes, the state has been updating their SICT numbers. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Info Only Info Only Covered the most recent state program performance metrics in detail with the program manager. 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/ Info Only Info Only DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 10#
FLPSC NG Program Evaluation, 2022, page 11b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: This was covered at their safety seminar in 2021. 20 General Comments: Info Only = No Points Evaluator Notes: No issues identi8fied at this time. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 11#
FLPSC NG Program Evaluation, 2022, page 12PART 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: A. Field verification of valve maintenance records and operation. Located in Tallahassee. B. Last year. C. Yes, Stephen Mayfield - Assistant General Manager - Gas Operations - City of Tallahassee. Robert Simpson from the Tallahassee region was observed. 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 Evaluator Notes: Yes, the inspector used a state field verification form to track the operators actions. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: A. The inspector reviewed the operators procedures prior to the field visit and asked questions to insure the operators understanding. B. N/A C. The inspector asked for and reviewed the operators OQ qualifications. D. None E. This portion of the inspection was of adequate length. 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: Yes, the inspector observed 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 Evaluator Notes: Yes, a summary of the days activities was discussed with the operator. This is an ongoing inspection. 1 1 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 12#
FLPSC NG Program Evaluation, 2022, page 136 Was inspection performed in a safe, positive, and constructive manner ? 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 Info Only Info Only Evaluator Notes: A. No unsafe acts were observed in the field. B. The inspector observed and verified the location and operability of some of the operators emergency valves. C. No best practices to share at this time. D. None 7 General Comments: Info Only = No Points Evaluator Notes: None at this time Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 13#
FLPSC NG Program Evaluation, 2022, page 14PART 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: Every year, annual report data is entered in to an Excel spreadsheet for ease of sorting. This information has been used to evaluate operator trends such as EFV installations, miles of main, and services. The data was also recently used to evaluate leak data for prioritizing Section 114 inspections. Incident data, both PHMSA reportable and State reportable, is maintained in a spreadsheet that provides a summary of the incident as well as a link to communications and staff 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: Commission staff meets with Florida's largest operator (People's Gas) on a quarterly basis. People's Gas has maintained an outreach program which engages with the leadership of the 20 riskiest excavators (as measured by damages). People's Gas provided staff with an update during a March 2023 in-person meeting. One of Florida's largest municipal operators has made efforts to have two of its employees complete training to become code enforcement officers and has worked to update its Municipal Codes and Gas Service Manuals to stipulate a citation process. 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: Commission staff uses the aforementioned Annual Report Spreadsheet to review excavation damage information. Additionally, damages related to mismarks are collected during inspections and are compared/reviewed to annual reports when available. Commission staff review excavation damage information for anomalies to assist in directing any operator questions. DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 14#
FLPSC NG Program Evaluation, 2022, page 154 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. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: Commission staff and Sunshine 811 both collect damage information and compare it to locate requests. Information collected by Sunshine 811 is submitted to the Common Ground Alliance using the Damage Information Report Tool. Commission staff has taken part in meetings with various stakeholders to evaluate how to best focus enforcement/education efforts. 5 General Comments: Info Only = No Points Evaluator Notes: No issues identified at this time Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 15#
FLPSC NG Program Evaluation, 2022, page 16PART 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: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: FL PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 074152559 2022 Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 16#
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