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PHMSA flpsc2009ngprogramevaluation
2009 FLPSC NG Program Evaluation - flpsc2009ngprogramevaluation (Florida; Natural Gas State Program Evaluation)
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FLPSC NG Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 1#
FLPSC NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Florida Rating: Agency Status: Date of Visit: 10/19/2010 - 10/22/2010 Agency Representative: Ed Mills Bob Trotter PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: , 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 Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2009 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 25 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 0 0 D Incident Investigations 6 6 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 98.5 98.5 State Rating................................................................................................................................................... 100.0 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 2#
FLPSC NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Upon a review of the attachments to the FLPSC's 2010 Certification Application, no errors were found in the information. The State Program Office review of the 2010 Certification raised a question about the listing of four operators under the Other category. The FLPSC answered that these four operators are utility district distribution operators and do not fall under the categories of Private or Municipal therefore they were listed as Other. Documentation of the information entered into the attachments was verified in the FLPSC's records. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: Yes. The FLPSC maintains a log of telephonic reports. The log contains both federal required reports and incident reports required by state regulations. 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes. The FLPSC conducts a pipeline safety TQ seminar once each three year. The FLPSC conducted its previous seminar in 2007. The FLPSC has submitted a request to PHMSA TQ for a seminar to be conducted in 2010. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: for the evaluation. Yes. The FLPSC relies on hard copy files for most of pipeline safety records. Inspection report records for 2009 were well organized and easily accessible 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Ed Mills has been in the pipeline safety program for the FLPSC for over thirty years. Mr. Mills exhibited excellent knowledge of pipeline safety regulations and the requirements for a state pipeline safety program outlined in the Guidelines For A State Pipeline Safety Program. The FLPSC staff members also have many years of experience in the pipeline safety program. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: The Southern Region Office received a response from the FLPSC Chairman on 1/20/2010. DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 3#
FLPSC NG Program Evaluation, 2009, page 47 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 NA previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: The window of opportunity to seek legislative changes had passed at the time the FLPSC received the evaluation letter. The FLPSC will consider requesting legislative changes at the appropriate time in the future. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: PHMSA TandQ records indicate that the FLPSC inspection staff has attended the required courses within the 3 year timeframe. 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: No significant non-T&Q traiining was identified during 2009. 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: inspections were conducted. Yes. Upon a review of the OQ database and training records, the inspectors assigned to lead OQ inspections completed the required training prior to the time 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: Yes. Upon a review of the IMP database and training records, the inspectors assigned to lead IMP inspections completed the required training prior to the time inspections were conducted. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 996.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 5.00 = 1100.00 Ratio: A / B 996.00 / 1100.00 = 0.91 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: Yes. The FLPSC's 2010 Certification - Attachment 2 shows that 996 inspection person days were logged during 2009. Attachment 7 shows that 5 person years were charged to the program. The resulting ratio equals 0.91 which above the minimum ration of 0.38. DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 4#
FLPSC NG Program Evaluation, 2009, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: No changes occurred during 2009. No definite changes are planned for the near future. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The FLPSC generally complied with the requirements in Part A of this evaluation. Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 5#
FLPSC NG Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: The FLPSC procedures require each operator's systems to be inspected annually not to exceed fifteen months. The FLPSC determines if special or focus areas should be inspected based upon past inspection history. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: The FLPSC written procedures consider all of the factors shown above. The primary considerations in scheduling inspections are the length of time since the last inspection and past inspection results. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: Yes. Upon a review of the FLPSC 2009 inspection records, the FLPSC complied with the required inspections intervals in its inspection procedures. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: The FLPSC uses inspection forms that were developed by the FLPSC. Upon a review of the forms used by the FPSC, it appears that the forms cover all of the federal pipeline safety requirements and state requirements that are more stringent. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: inspection. Yes. Upon a review of randomly selected inspection reports, the supporting inspection forms were completed on the applicable portions covered during the 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: DUNS: 074152559 2009 Natural Gas State Program Evaluation .5 NA Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 6#
FLPSC NG Program Evaluation, 2009, page 7There were no safety related condition reports filed by an intrastate operator in Florida during 2009. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 .5 .5 SLR Notes: The FPSC has reviewed operators' procedures related to graphitization of cast iron pipe since the NTSB recommendation was issued several years ago. The FLPSC provides operators with PHMSA Advisory Bulletins as they are published. 8 Did the state review 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) (NTSB) Previous Question B.8 Yes = .5 No = 0 .5 .5 SLR Notes: The FLPSC has mandated cast iron main replacement programs for its operators. The FLPSC mandate resulted from reviews of operators' leak history and pipeline facility failures. The FLPSC reviews operators' leak repair records and verifies that operators are noting whether cast iron leaks are resulting from circumferential cracking. 9 Did the state review 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? (NTSB) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: The FLPSC has reviewed all operators' operation and maintenance procedures to ensure that all leaks are repaired in a manner that does not pose a safety hazard to the public. The FLPSC reviews operators leak repair records as a part of its standard inspections. 10 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: The FLPSC is involved in monitoring operators' response times to leak reports or other emergency notifications to operators. The FLPSC reviews operators' compliance with the requirements of 192.617 when it conducts standard inspections. Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Upon a reveiw of randomly selected inspection reports completed in 2008, probable violations in reports reviewed were documented with the code paragraph violated along with descriptions of the operator's actions or lack of actions that resulted in a probable violation. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The FLPSC procedures direct inspectos to notify operators as soon as possible after the discovery of a probable violation. The FLPSC is required to provide operators with written correspondence notifying the operator of a probable violation or safety concern. 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D 1 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The FLPSC requires that operators be provided with written notification of any non-compliance that are found by the FLPSC. The FLPSC inspector also provides a briefing to the operator upon the conclusion of the inspection. 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 074152559 2009 Natural Gas State Program Evaluation 1 1 Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 7#
FLPSC NG Program Evaluation, 2009, page 8SLR Notes: Yes. The FLPSC tracks the progress of operators' corrective action. The FLPSC follows up with operators through telephonic contact or by conducting follow up inspections. The completion of corrective action is documented on the FLPSC's GS-12 form. The operator is notified in writing when the corrective action is accepted and the report is closed. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: during 2009. Upon a review of the FLPSC's inspection report log, the FLPSC documented the actions and dates of written correspondence for probable violations found 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Upon a review of the FLPSC's inspection report log, the FLPSC documented the responses to its written notifications. Based upon the information in the log, Operators responded to the FLPSC's notifications within the timeframe specified in the written notification from the FLPSC. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 SLR Notes: The FLPSC has administrative procedures that allow for a formal show cause hearing before the Commission. No show cause hearings were required in 2009 to require corrective action. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The resolution of probable violations are documented in the inspection report file and on the "Gas Safety Violation Log". 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 SLR Notes: operators. Upon a review of randomly selected inspection files, non compliance letters were addressed to company officers for letters sent to private company 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. The FLPSC's enforcement procedures provide operators with the ability to provide evidence of compliance to be considered by the FLPSC. Operators have the opportunity to request hearings with the FLPSC Commissioners to present their arguments. Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 8#
FLPSC NG Program Evaluation, 2009, page 923 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The FLPSC has generally complied with the requirements of Part B of this evaluation. Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 9#
FLPSC NG Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The FLPSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The FLPSC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: The FLPSC is not an interstate agent. 1 NA 4 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: The FLPSC is not an interstate agent. 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? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The FLPSC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: The FLPSC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The FLPSC is not an interstate agent. 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: The 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 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 10#
FLPSC NG Program Evaluation, 2009, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: The FLPSC is knowledgable of the cooperation procedures with PHMSA. The FLPSC has excercised the required ccoperation during past incidents. One reportable incident occurred in 2009. The incident was caused by third party damage when a soil mixer preparing a roadway sub surface struck a pipeline. The FLPSC followed the requirements described in the Appendices of the Guidelines. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 .5 .5 SLR Notes: Yes. Ed Mills has considerable experience and tenure in the pipeline safety program. Ed is well aware of the authorities and understandings outlined in the MOU between the NTSB and PHMSA. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. The FLPSC program manager maintains an electronic log of all incidents (including those that do not meet federal thresholds for reporting) reported to the FLPSC. Incident investigation files are kept by the FLPSC. The one reportable incident was well documented and an investigation report was published with all supporting documentation. 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: All reportable incidents that occurred in 2009 were investigated at the incident scene. 1 1 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes. The FLPSC's investigation of the one reportable incident in 2009 was thorough and complete. 2 2 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: There were no probable violations issued during the incident investigation that occurred in 2009. 1 NA 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: The Southern Region Office reported in an email dated 11/12/2010 that the FLPSC had complied with requirement satisfactory during 2009. 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 074152559 2009 Natural Gas State Program Evaluation Info Only Info Only Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 11#
FLPSC NG Program Evaluation, 2009, page 12The FLPSC generally complied with the requirements in Part D of this evaluation. Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 12#
FLPSC NG Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: The FLPSC has addressed this issue with operators in the past while reviewing operation and maintenance procedures required in 192.605. The FLPSC also reviews directional drilling/boring procedures when conducting construction inspections that involve trenchless excavation. The FLPSC provides it operators with PHMSA Advisory Bulletins as they are published. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes. The FLPSC reviews the operators procedures and records pertaining to requirements for locating pipeline facilties resulting from excavation notifications. This requirement is reviewed when the FLPSC covers 192.614 requirements during standard inspections. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: The FLPSC works closely with the one call system in Florida. The FLPSC has discussed with operators the need to adopt practices in the CGA document that are applicable to facility owners. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 1 SLR Notes: The FLPSC collects data from its operators and trends the data over time. The FLPSC includes this trend chart in its Annual Pipeline Safety Report provided to the Commissioners each year. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: The FLPSC covers 192.617 requirements during its standard inspections of operators. The FLPSC reviews operator's leak repair records while conducting standard inspections. The FLPSC attempts to identify any excavation damage trends that justify the revision of operators procedures. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: The FLPSC has generally complied with the requirements in Part E of this evaluation. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 13#
FLPSC NG Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Energy Services of Pensacola (ESP) Name of State Inspector(s) Observed: Bob Trotter Location of Inspection: Pensacola, Florida Date of Inspection: 10/19 -20/2010 Name of PHMSA Representative: Don Martin SLR Notes: ESP is the operating entity for the City of Pensacola, Florida, a municipal natural gas system. The FLPSC was in the process of conducting a standard inspection of ESP. On the days of October 19th and 20th, the FLPSC inspector observed odorant concentration testing and critical valve inspections. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: The operator's reresentative stated he was given two weeks notice prior to the inspection. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: Yes. The inspector used the proper inspection form for odorization tests and valve inspections. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: Yes. The inspector recorded readings taken on the odorant concentration readings and noted the operating condition of the valves. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes. The inspector reviewed the odorator that was being used and the calibration records for the instrument. The inspector also reviewed the operator's procedures for taking odorant concentration tests. The inspector also checked the operator's valve wrenches used to turn the valves. 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: The FLPSC inspector, Bob Trotter, observed the operator taking test readings on odorant concentration levels and the inspection of critical valves on ESP's system. This activity was just a portion of the standard inspection that would involve approximately three full weeks. The records portion of the inspection was completed prior to the beginning of the state program evaluation. 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 2 2 a. Procedures b. Records c. Field Activities/Facilities DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 14#
FLPSC NG Program Evaluation, 2009, page 15d. Other (Please Comment) SLR Notes: facilities. The records portion was completed prior to the state program evaluation. The inspector was in the process of observing test readings on the operator's 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 2 2 SLR Notes: TQ training. Yes. Mr. Trotter has many years of experience inspecting natural gas distribution and transmission operators. Mr. Trotter has completed all of the required 9 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Previous Question F.10 Yes = 1 No = 0 1 1 SLR Notes: The inspection was not completed at the time that the evaluation observation ended. The inspector did provide a briefing for the inspection activity during the time of the evaluation observation. 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: The inspector informed the operator that no probable violations were found during the time that PHMSA observed the inspection. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Info Only = No Points SLR Notes: The inspector observed operator personnel taking odorant concentration level testing and the inspection of critical valves. Info Only Info Only 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points SLR Notes: There were no best practices identified during the evalaution observation. Info Only Info Only 13 Field Observation Areas Observed (check all that apply) Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP DUNS: 074152559 2009 Natural Gas State Program Evaluation Info Only Info Only Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 15#
FLPSC NG Program Evaluation, 2009, page 16r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: Other areas were inspected prior to and after the evaluation observation. The areas checked above were inspected during the evaluation observation. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The FLPSC generally complied with the requirements of Part F of this evaluation. No issues were identified. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 16#
FLPSC NG Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: The FLPSC identifies key threats on a statewide basis using data gathered from various sources. The FLPSC associates the key threats with gas systems for which the threats may be applicable. The FLPSC also considers the factors above when considering the scope of inspections it schedules for operators' inspection units. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Upon a review of the FLPSC's inspection units and discussions with Mr. Ed Mills, it appears that the FLPSC's inspection units are broken down in a manner that is consistent with the definitions contained in the Guidelines For States Participating in the Pipeline Safety Program. 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points SLR Notes: The DIMP rule was not in effect during 2009. Info Only Info Only 4 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC has viewed cast iron main as a key risk factor in the gas distribution pipeline portion of its regulatory oversight. The FLPSC has mandated that operators have cast iron main replacement programs. The FLPSC monitors the mileage of cast iron mains remaining in Florida by operator each year. Steel pipeline corrosion has been identified as a key threat by the FLPSC. The FLPSC requires operators to account for IR drop in their cathodic protection tests by utilizing current interruption when test points are read. Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: The FLPSC receives data from the Florida one call system operator and from the pipeline operators under its jurisdiction. The FLPSC includes third party damage data in its annual report to the Commissioners. 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The FLPSC requires that operators provide it with a copy of its Annual Reports submission to PHMSA each year. The FLPSC reviews the information for accuracy and comparison to the previous year report. Operators are notified of any inconsistencies found during the reviews. 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC reviews trends on leak repair information and lost and unaccounted for gas percentages. The FLPSC monitors the trend of cast iron and bare steel mains mileage remaining in each operator's system and the total within the state of Florida. 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 DUNS: 074152559 2009 Natural Gas State Program Evaluation .5 0.5 Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 17#
FLPSC NG Program Evaluation, 2009, page 18SLR Notes: Yes. The FLPSC reviews data on incident reports to ensure that the reports are complete and accurate and that the operator's stated cause of the gas release is reasonable and is consistent with the FLPSC's investigation. 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The FLPSC publishes a document titled Annual Natural Gas Pipeline Safety Report addressed to the Commissioners. The document includes several charts trending different aspects of pipeline safety. As an example of data utilized, one of the key measures outlined in the latest report indicates that gas leaks have trended downward 33% since 1995 while the mileage of gas mains increased by 52%. There are other performance measures outlined in the report that uses data for performance assessment. 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 SLR Notes: Upon a review of the FLPSC state page on the OQ database, OQ inspection protocol forms have been uploaded to the OQ database. .5 0.5 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 .5 0.5 SLR Notes: There was one notification from an interstate gas transmission operator with operations in Florida in the IMP database during 2009. The database indicated that Ed Mills provided comments on the notification. 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 .5 0.5 Yes = .5 No = 0 SLR Notes: Upon a review of the Gas IMP Database, the FLPSC has uploaded the Protocol forms for the IMP inspections that have been completed. Based upon a review of Attachment 3 in the FLPSC's 2009 Certification, it appears that the FLPSC has completed IMP inspections for all applicable operators. Four inspections were completed in 2009 and the protocols were uploaded. 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC covered the issue of plastic pipe failure data with its operators when the concern was brought to a national level some time ago. The latest Annual Pipeline Safety Report to the FLPSC Commissions indicates that a small amount of ABS pipe has been identified. 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 SLR Notes: Yes. The FLPSC has reviewed the NPMS and is satisfied that intrastate gas transmission pipelines are included in the system. .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The FLPSC presented an update of its program at the NAPSR Southern Region Meeting held in April, 2009. The FLPSC included a topic on the incidents that occurred in Florida since the previous NAPSR Southern Region meeting. 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Commissioners. There were no efforts from a source outside the FLPSC during 2009. The FLPSC gathers data concerning incidents for inclusion in its annual report to the DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 18#
FLPSC NG Program Evaluation, 2009, page 1917 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points SLR Notes: No. The FLPSC had not developed criteria during 2009. Info Only Info Only 18 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points SLR Notes: The FLPSC had not implemented this investigation technique into its incident investigation process in 2009. Info Only Info Only 19 Has state participated on root cause analysis training? (can also be on wait list) .5 0.5 Yes = .5 No = 0 SLR Notes: Upon a review of Training and Qualifications training system (SABA), the root cause analysis training has not been attended by any FLPSC inspectors. The waitlist did not show a FLPSC inspector on the waitlist for the course. Because this course is presently an elective on the traiing requirement tables, a point reduction will not be given for this evaluation. Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, .5 0.5 pub awareness, etc.) Yes = .5 No = 0 SLR Notes: The FLPSC participates in gas industry association functions and conferences. The FLPSC has a portal in its website that allows the public to view summary enforcement information and communicate with the Bureau of Safety on pipeline safety concerns. 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: docket system. Any enforcement action that results in a docketed case brought before the commission can be accessed by the public through the FLPSC's website and 22 Part G: General Comments/Regional Observations Info Only = No Points SLR Notes: The FLPSC has generally complied with the requirements in Part G of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 19#
FLPSC NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC continued making progress in completing IMP inspections of all gas transmission operators. The FLPSC was active in supporting NAPSR activities during 2009. An additional staff member was added to fill a position that was due to be vacant from a retirement. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC has continued to adopt the latest amendments to the federal pipeline safety regulations. 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC continues to monitor the cast iron replacement programs of its operators. The FLPSC has encouraged operators to replace cast iiron for some time and has provided financial incentives to operators during rate cases. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 SLR Notes: No instances could be found where the FLPSC did not respond to an information request. 1 1 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: The FLPSC provided a pipeline safety program update to other Southern Region states during the NAPSR Southern Region meeting in 2009. 6 Part H: General Comments/Regional Observations Info Only = No Points SLR Notes: The FLPSC has generally complied with the requirements in Part H of this evaluation. Info Only Info Only Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 20#
FLPSC NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 1 1 SLR Notes: inspections during 2009. Yes. The FLPSC covers drug and alcohol testing programs when conducting annual standard inspections. The FLPSC conducted 53 drug and alcohol 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The FLPSC reviews operators records to verify that operators are conducting the required testing as required in Part 199 and the operators' drug and alcohol plans. The FLPSC verifies that the operator has achieved the minimum random testing rate. 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The FLPSC reviews operators testing records. If the records reflect that positive test(s) have occurred, the FLPSC questions the operator on its handling of the positive test. The FLPSC verifies that the operator's response is consistent with the written requirements in its Drug and Alcohol Testing Plan. Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 1 1 SLR Notes: Yes. Upon a review of the Operator Qualification Inspection Database (OQID), the FLPSC has entered the results of OQ inspections. The FLPSC inspected operator's OQ Plans in 2003 and 2004. 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 0.5 Yes = .5 No = 0 SLR Notes: with Subpart N. Yes. The FLPSC utilized the federal OQ inspection protocol forms, including Protocol 9, to conduct reviews of operators' OQ programs and compliance 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: performing covered tasks. Yes. The FLPSC reviews operators' OQ records during its standard inspections and reviews qualification and requalification records for each employee 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Upon reviewing OQ records during standard inspections, the FLPSC checks the records for individuals designated by the operator to be qualified for covered tasks. The FLPSC also verifies that requalification intervals are being complied with each individual designated on each covered task. Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: The Gas IMP database indicates that the FLPSC has completed 32 IMP inspections. Based upon the number of operators contained in the FLPSC's 2101 Certification, it appears that each operator has received at least one inspection of their integrity management program. There were four IMP inspections completed in 2009. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? .5 0.5 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 21#
FLPSC NG Program Evaluation, 2009, page 22Yes = .5 No = 0 SLR Notes: covers this requirement. The FLPSC uses and completes all information in the protocol forms while conducting its inspections of Integrity Management Plans. The protocol form 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection .5 0.5 plan) Yes = .5 No = 0 SLR Notes: The FLPSC uses and completes all information in the protocol forms while conducting its inspections of Integrity Management Plans. The protocol form covers the requirements of Subpart O. 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 .5 0.5 SLR Notes: covers this requirement. The FLPSC uses and completes all information in the protocol forms while conducting its inspections of Integrity Management Plans. The protocol form 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance .5 0.5 of new HCAs? Yes = .5 No = 0 SLR Notes: The FLPSC has reviewed gas transmission operator Gas IMP programs to verify that the operators have procedures to identify new HCA's along the pipeline(s). The results are documented in each inspection's protocol forms completed during the inspection. Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The FLPSC participated in the Public Awareness clearinghouse review program. The FLPSC reviewed the results of clearinghouse reviews. The FLPSC provided written notifications to operators of any deficiencies found during the clearinghouse review. The FLPSC followed up with operators until the required revisions were made to their public awareness plans. 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 SLR Notes: Yes. The FLPSC participated in the Clearinghouse review. .5 0.5 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The FLPSC reviews operators public awareness plan documentation during its standard inspections. Operator plan effectiveness review requirements will not be effective until 2010. 16 Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points SLR Notes: The FLPSC did not perform this review in 2009 since the requirement is not effective until June, 2010. Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: The FLPSC has generally complied with the requirements in Part I of this evaluation. Info Only Info Only DUNS: 074152559 2009 Natural Gas State Program Evaluation Total points scored for this section: 9 Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 22#
FLPSC NG Program Evaluation, 2009, page 23Total possible points for this section: 9 DUNS: 074152559 2009 Natural Gas State Program Evaluation Florida FLORIDA PUBLIC SERVICE COMMISSION, Bureau of Safety, Page: 23#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.