{"operation":"document","citation":"PHMSA flpsc2009ngprogramevaluation","title":"2009 FLPSC NG Program Evaluation - flpsc2009ngprogramevaluation (Florida; Natural Gas State Program Evaluation)","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-01-01","effective_on":null,"summary":"2009 PHMSA natural gas program evaluation for Florida.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-flpsc-ng-program-evaluation-flpsc2009ngprogramevaluation.json","markdown":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-flpsc-ng-program-evaluation-flpsc2009ngprogramevaluation.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-flpsc-ng-program-evaluation-flpsc2009ngprogramevaluation","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/471/flpsc2009ngprogramevaluation.pdf","body":"1200 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\n\n2009 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\n\nPART 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\n\n7 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\n\n13 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\n\nPART 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\n\nThere 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\n\nSLR 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\n\n23 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\n\nPART 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\n\nPART 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\n\nThe 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\n\nPART 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\n\nPART 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\n\nd. 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\n\nr. 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\n\nPART 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 ","truncated":true,"body_characters":57760}