RegulusPipeline researchPHMSA la-2022-hazardous-liquid-program-evaluation
LA HL Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 Hazardous Liquid State Program Evaluation for Louisiana Department of Natural Resources Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1#
LA HL Program Evaluation, 2022, page 22022 Hazardous Liquid State Program Evaluation -- CY 2022 Hazardous Liquid State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 08/28/2023 - 09/01/2023 Agency Representative: Michael Peikert, Assistant Director PHMSA Representative: Agustin Lopez, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Monique M. Edwards, Commissioner Agency: Louisiana Department of Natural Resources-Office of Conservation Address: 617 North Third Street City/State/Zip: Baton Rouge, LA 70802 INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2022 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 6 6 G Interstate Agent/Agreement States 0 0 TOTALS 96 96 State Rating................................................................................................................................................... 100.0 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2#
LA HL Program Evaluation, 2022, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a. Verified operators with PDM and annual reports. Reviewed LDNR inspections and spreadsheets to verify data. b. Reviewed LDNR CY 2022 Composite spreadsheet and tracking of inspection days to verify inspection activity. c. Verified operators with PDM and annual reports. d. Verified incident investigation with PDM. There were no reportable incidents in 2022. e. Compliance Actions 2022 data is tracked on spreadsheet by the LDNR. Reviewed to verify data on Progress Report. f. Keep electronic records of inspections. Onlines SONRIS keeps all records which is accessible to the public. g. Compared training with Blackboard. Inspection staff qualifications are accurate. No issues identified. h. Have adopted all regulations within the 2 year requirement. i. List accomplishments and goals for coming year. Continue to work on reducing the damages per 1,000 tickets. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 3#
LA HL Program Evaluation, 2022, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. IMP Inspections c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) Evaluator Notes: LDNR Pipeline Safety Programs Guidelines Section 5 has detailed inspection procedures which include pre and post inspection activities that provide guidance to inspectors which include IMP, OQ, Damage Prevention, Opertor Training, PAPEI, Drug and Alcohol, and Construction. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: LDNR Pipeline Safety Programs Guidelines Section 5 has intervals established for inspections which is five years. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: LDNR Standard Operating Procedures Section 10a includes the state's enforcement procedures for when a non compliance is found to the resolution of the non compliance. Section 4.7 of SOP includes a re-inspection for closing out non compliance cases. Title 43 Subpart 3, Chapter 5 provides the LDNR the enforcement authority. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 Evaluator Notes: LDNR Standard Operating Procedures Section 5 (4.5) and 9 include incident/accident investigation procedures and has DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4#
LA HL Program Evaluation, 2022, page 5mechanism to respond to incident notifications. The LDNR investigates all reportable incidents. LDNR has procedures to form an Accident Response Team (ART) in case of large or significant incidents/accidents are reported. 5 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part B of the evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 5#
LA HL Program Evaluation, 2022, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required IMP Training before conducting inspection as lead c. Root Cause Training by at least one inspector/program manager d. Note any outside training completed e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Verified that each lead inspector is qualified to lead each type of inspection. Reviewed qualifications in TQ Blackboard and state files. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Michael Peikert is very knowledgeable of the pipeline safety program and regulations. He has been with the LDNR as an engineer and with Pipeline Safety for many years. 3 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part C of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 6#
LA HL Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Construction (did state achieve 20% of total inspection person-days?) f. OQ (see Question 3 for additional requirements) g. IMP (see Question 4 for additional requirements) Evaluator Notes: Reviewed randomly selected operator units to verify LDNR is inspecting units at intervals per their procedures not to exceed 5 years. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Construction f. OQ (see Question 3 for additional requirements) g. IMP (see Question 4 for additional requirements) 10 10 Evaluator Notes: Yes, reviewed randomly selected inspection reports to verity forms are being utilized to document results of inspections and for completeness. Inspection reports are electronically kept in their SONRIS online database/ 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR Part 195 Subpart G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the LDNR is conducting OQ inspection to assure operator's plans are meeting the regulations. Field OQ Protocol 9 inspections are also performed during inspections. Reviewed randomly selected OQ inspection to assure the inspections are being conducted and documented. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR Part 195 Subpart F & G Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? 2 2 Evaluator Notes: LNDR reviews large operator IMP for any changes or progress on an annual basis. Inspection is named "Specific-IM". Recommend to create a form to document what was reviewed or discussed during the visits/inspections. DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 7#
LA HL Program Evaluation, 2022, page 85 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 195.402; and b. 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; Evaluator Notes: NTSB questions are included as part of the standard inspections. 2 2 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discuss ADB with operators during seminars and inspections and are also posted on the website. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) 10 10 Evaluator Notes: Randomly reviewed compliance cases to verify procedures are being followed and are being processed in a timely manner. 8 (Accident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation 10 10 Louisiana Louisiana Department of Natural Resources, Page: 8#
LA HL Program Evaluation, 2022, page 9h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: years accidents. There were no reportable accidents in 2022, but the LDNR has procedures and have demonstrated investigation of previous 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No response was required 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Last seminar was July 2022. Have a seminar annually. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes, question is on inspection forms. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State has an annual seminar and also holds small operator seminars annually. Website has all inspection reports availble to the public. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Have 6 open SRCR that the LDNR is pending investigations in NG and HL. Have been having issues with WMS but they are aware of SRCs. Closed out 4 SRCR. Recommend to go into WMS and enter a date for the next update. Currently no dates have been entered so the SRCR show up as being overdue. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, LDNR responds to NAPSR surveys and PHMSA requests. Work with WMS on operator notifications. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Have 3 open waivers: Maurepas which is now ET crude Operating on the schedule is currently idle with nitrogen; IMTT has DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 9#
LA HL Program Evaluation, 2022, page 10same type of waiver as Maurepas but was never built, and Harvest ? flexsteel crude line installed earlier this year and is currently operating. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, files are very organized. Inspection reports are kept electronically online. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: Discussed SICT with LDNR, no concerns or issues in meeting the inspection days. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Damages per 1,000 tickets is ticking up a little which is mainly due to construction activities after hurricanes. LDNR works with operators to educate on one-call before digging. Trained inspectors has decreased due to retirements and inspectors leaving LDNR. Repaired leaks has increased, hazardous leaks is lower as is scheduled leaks for repair which is are good trend.(NG) 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: 2022. PSMS presentations are made at the annual Pipeline Safety Seminar. World Net presented in 2023. API made presentation if 20 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part D of the evaluation. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10#
LA HL Program Evaluation, 2022, page 11PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Operator: IMTT Inspector:Joshua Musso, Conservation Program Manager Location: St. Rose, LA Date: July 31-August 2, 2023 PHMSA Evaluator: Agustin Lopez a. Comprehensive Inspection b. First Comprehensive inspection due to new operator c. Yes, operator representatives were present during inspection. d. Have not evaluated Joshua in the past. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, inspector utiilzes LDNR Empire database program which stores all inspection forms. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: a. Reviewed procedures with great detail. b. Reviewed records as part of the comprehensive inspection. c. Conducted a field inspection of the pipeline facilities. d. No other type of inspection. e. Yes the lenght of inpection was adequate. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Joshua was very knowledgeable of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 11#
LA HL Program Evaluation, 2022, page 12Conducted exit briefing after completing the procedures and records inspection. Will do field inspection when the contractor that performs cp readings is present to peform yearly survey. No issues identified only recommendations to improve O&M Manual. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: The inspection was conducted in a safe, positive and constructive manner. Info Only Info Only 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Joshua Musso was evaluated while conducting a comprehensive inspection (Procedures, records and Field) of IMTT diesel pipeline. He performed an excellent inspection and was very knowledgeable of the pipeline safety regulations. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 12#
LA HL Program Evaluation, 2022, page 13PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Review Annual Reports and accident reports for accuracy and use to prioritize inspections. 2 2 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the LDNR verify operators analyze accidents and damages to find root cause and prevent reurrence. With the enforcement of excavation damages the LDNR can identify and have data on excavators who violate the one-call laws. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation Info Only Info Only Damage? Info Only = No Points a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Attachment D is only for NG Operators. This is being performed by the LDNR but is covered under the NG Program Evaluation. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 13#
LA HL Program Evaluation, 2022, page 14The LDNR collects data from annual reports and enforcement to be able to analyze and trend excavation damages. With the LDNR now having enforcement more data is readily available to analyze and trend in the near future. 5 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part F of the evaluation. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 14#
LA HL Program Evaluation, 2022, page 15PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: LA DNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2022 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 15#
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