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PHMSA la2010hlprogramevaluation
2010 LA HL Program Evaluation - la2010hlprogramevaluation (Louisiana; Hazardous Liquid State Program Evaluation)
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LA HL Program Evaluation, 2010, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Hazardous Liquid State Program Evaluation for Louisiana Department of Natural Resources 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 -- Accident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1#
LA HL Program Evaluation, 2010, page 22010 Hazardous Liquid State Program Evaluation -- CY 2010 Hazardous Liquid State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 06/27/2011 - 07/01/2011 Agency Representative: James Mergist, Asst Director Pipeline Division PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: James H. Welsh, Commissioner Agency: Louisiana Department of Natural Resources-Office of Conservation Address: 617 North Third St. City/State/Zip: Baton Rouge, Louisiana 70802 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 2010 (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 26 25 B Inspections and Compliance - Procedures/Records/Performance 25 25 C Interstate Agent States 0 0 D Accident Investigations 7 7 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 9.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 101 99.5 State Rating................................................................................................................................................... 98.5 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2#
LA HL Program Evaluation, 2010, page 3PART A - General Program Qualifications Points(MAX) Score 8 7 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 Hazardous Liquid and CO2 facilities (1) b. Total state inspection activity (2) c. Hazardous Liquid facilities subject to state safety jurisdiction (3) d. Hazardous Liquid pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the Hazardous Liquid pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: A.1 Improvement needed, 7 of 8 pts. All items are listed and reported in the Hazardous Liquid Certification Document. A. Attachment 1 (intrastate trunklines=55 units)does not agree with Attachment 3 (intrastate trunklines=61 units); C. Op ID was not listed in Attachment 3, Warning only as OPID is not specified as required in Guidelines 2.5.3. 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 (accident criteria as referenced in 195.50? - Mechanism should include receiving "after hours" reports) (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: A.2. LA DNR meets the Federal reporting requirements. The emergency response number is covered 24-7-365. LaDNR also compares NRC reports against reports to the LaDNR to assure full reporting compliance. 3 Has the state held a pipeline safety T & Q seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar 2 2 or if 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.5 Yes = 2 No = 0 SLR Notes: A.3. Yes, in the 3rd week of July 2010 & the 2nd week of July 2009. Practice is to schedule every year over the last week of July. The next Seminar is scheduled for July 25th week, 2011. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.6 Yes = 1 No = 0 SLR Notes: A.4. Yes, the paper files are in the File Room in the Pipeline Division area. 1 1 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.7 Yes = 2 No = 0 Needs Improvment = 1 SLR Notes: A.5. Yes, The Program Manager & records review show a professional knowledge of the regulations. 2 2 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.9 Yes = 1 No = 0 SLR Notes: A.6. Yes, the letters were sent on December 14th, 2010, and response was sent on February 9th, 2011. 1 1 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (Chapter 8.1) Previous Question A.10 Yes = 1 No = 0 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 3#
LA HL Program Evaluation, 2010, page 4SLR Notes: A.7 Yes, all 3 issues were addressed and a plan of action is in place for all three. All items are a work in progress. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year T&Q training requirement? If No, has the state been granted a waiver regarding T&Q courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all T&Q 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.11 Yes = 3 No = 0 3 3 SLR Notes: A.8 Yes, for 2010 they are in compliance with the State Guidelines with the 3 yr attend & 5 yr complete rule for new staff. The long term inspector needing 2 courses repeated one course, was waitlisted for the other and retired in January, 2011. 9 Brief Description of Non-T&Q training Activities Info Only = No Points Info Only Info Only For State Personnel: A.9. State- Most inspectors attend the annual 195 Seminar & the 192 Seminar. In addition, several staff attended the 8 hr LSU HAZWOPER REFRESHER COURSE. For Operators: Operators ? Held the annual T&Q Pipeline Safety Seminar. There were also several individual operator training sessions, usually associated with an inspection. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Non-operator/public ? no activities in 2010. SLR Notes: REFRESHER COURSE. inspection. A.9. State- Most inspectors attend the annual 195 Seminar & the 192 Seminar. In addition, several staff attended the 8 hr LSU HAZWOPER Operators ? Held the annual T&Q Pipeline Safety Seminar. There were also several individual operator training sessions, usually associated with an Non-operator/public ? no activities in 2010. 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.13 Yes = 1 No = 0 1 1 SLR Notes: A.10. Yes. Dana Arabie (TSI 299 11/03) & Jacques Rotolo (TSI 299 9/04) are the OQ Leads. Two other inspectors & two Supervisors are OQ certified. 11 Did the lead inspectors complete all required T&Q Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.14 Yes = 1 No = 0 1 1 SLR Notes: completed). A.11. Yes, IMP Leads are Dana Arabie (TSI 297 6/05, TSI 294 8/02, CBT are completed) & Jacques Rotolo (TSI 297 4/06, TSI 294 7/04, CBT are 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.14 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 170.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.98 = 435.60 Ratio: A / B 170.00 / 435.60 = 0.39 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: A.12 A=170 person days. B=1.98 man years * 220 = 435.6 person days. A/B= .39027. .39>.38, okay. 5 5 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4#
LA HL Program Evaluation, 2010, 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: A.13 No, authorized staffing levels at 19 personnel are constant from 2007-6/2011. 2007 to early 2008 had no staffing changes. There were two retirements in 2008 & two new hires in November 2008. An attempt to increase staff in 2009 was turned down due to State Budget constraints. In 2009 one inspector (Kenneth Peltier) passed away and Marvin Reed was hired to replace the vacancy. In 2010, 5 personnel resigned or retired and 3 personnel were hired. Two authorized positions were carried forward into 2011 as vacancies. To date on 6/27/2011 those vacancies have been filled. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: A.14 LDNR continues to be very active in NAPSR; by actively participating on five committees: Control Room Management; Gas Gathering, Public Awareness Program, Liquid Pipeline Task Group; and Staffing Formula Task Group. They also support NAPSR and PHMSA requests for information. LDNR actively participates in the quarterly Louisiana Regional Common ground alliance meetings. LDNR participates with and supports the efforts of Coastal And Marine Operators (CAMO) Pipeline Industry Initiative whose main purpose is to explore and discuss issues and challenges in preventing spills, releases, and damage to coastal and marine pipelines and environments. LDNR helps organize and co-sponsors the annual Pipeline Safety Seminars for Hazardous Liquid and Natural Gas operators. LDNR works closely with the State Police and LaOneCall to promote 811 and implement safe excavation practices. Total points scored for this section: 25 Total possible points for this section: 26 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 5#
LA HL Program Evaluation, 2010, 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) (Chapter 5.1) 6.5 6.5 Previous Question B.1 + Chapter 5 Changes 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: B.1. Yes, all are addressed: Pipeline Safety Operations Manual, General Criteria Section, Section 6, - Std-not to exceed 45 mo limit; IMP- 10 yr limit, reasons include IM reassessment intervals of 7 to 10 years, & personnel resource availability due to other inspection initiatives; OQ- 10 yr limit; Damage Prevention- is part of a Std insp;, Operator Training-formal is per oper requests, Seminars, & conferences, informal is during any operator contact or inspection as requested; Constr- construction notice is required and inspection is 'as needed' with actual practice to concentrate on major construction sites; Accident- as determined by the Program Manager and generally includes all significant events; & Follow-up ? within a reasonable amount of time (not to exceed 90 days) after the expiration of the time allowed to achieve compliance. 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: B.2. Yes, 'Gas Operator Prioritization Model', 'Liquid Operator Prioritization Model' & Pipeline Safety Operations Manual, General Criteria Section, Section 6, - Items a, b, c, & d are okay. 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: B.3. Yes, Units are being inspected in accordance with the Manual Guidelines. Units are tracked through a spread sheet program which tracks Std and special inspections. Other inspections are tracked on the spreadsheet 'as needed'. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 1 1 SLR Notes: B.4. Yes, the LaDNR Forms for OQ, IMP, & Standard inspections are created from the current Federal Forms. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.6 1 1 Yes = 1 No = 0 SLR Notes: B.5. Yes, CAUTION. Checked Std, & Special inspections, mostly complete, but unit descriptions are missing. Unit descriptions must be readily available to Pipeline Section staff. Richard- Comp-Atmos Pineville distr- 20616 okay Brian Flores-Special-centerpoint-Opelousas-distr -19335 okay- would like more information in the 'NA' comments. DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 6#
LA HL Program Evaluation, 2010, page 7Jacques-Comp-25508- Golden Meadow-distr 192.479, .465a, 469, okay Paul-Comp-24116-Varibus-trans 192.465a, okay Paul-Magellan-Terminal-25285 Special HL 195.589c, okay. Tina- Calumet-Cotton Valley-25141-Comp HL 195.428a, .573c, 573a, 579a, 583a, okay. 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.7 Yes = .5 No = 0 SLR Notes: B.6. Yes, SRCR are tracked by Steve Giambrone & Mark Champagne, & updates are sent to the Feds. .5 0.5 7 Did the state review operator procedures for determining areas of active corrosion on liquid lines in sufficient detail? (NOTE: PHMSA representative to describe state criteria for determining areas of active corrosion) Previous Question B.8 Yes = .5 No = 0 SLR Notes: B.7. Yes, it is in the Haz Liq Std Inspection Form. See subpart H, 195.589( c), 195.573(b). .5 0.5 8 Did the state adequately review for compliance operator procedures for abandoning pipeline facilities and analyzing pipeline accidents to determine their causes? (NOTE: PHMSA representative to describe state criteria for determining compliance with abandoning pipeline facilities and analyzing pipeline accidents to determine their causes) Previous Question B.9 Yes = .5 No = 0 SLR Notes: B.8. Yes, it is in the Haz Liq Std Inspection Form. 195.402(c )(10), 195.402(c )(5). .5 0.5 9 Is the state aware of environmentally sensitive areas traversed by or adjacent to hazardous liquid pipelines? (reference Part 195, review of NPMS) Previous Question B.16 Yes = .5 No = 0 .5 0.5 SLR Notes: B.9. Yes. Safety Division uses NPMS & State Coastal zone maps to monitor & compare with operator maps. 195.402(c )(1) of inspection form. 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 195.402(c)(5)? Previous Question B.11 Yes = 1 No = 0 SLR Notes: B.10. Yes it is on the Std Insp Form, and all accidents are followed up with most having on-site investigation. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.13 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: current B.11. Yes, the inspections reports are placed in the subject Unit File and the violation letter with evidence are kept together in a violation file. The violation report & evidence are moved to the subject Unit file when it is closed. Records are retained as long as space is available, & at least for 4 years plus 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question C(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.12. Yes, in LAC 33:V subpart 3 Chapter 313. 1 1 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 C (1).2 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 7#
LA HL Program Evaluation, 2010, page 8SLR Notes: B.13. Yes, in the LA Administrative Code (LAC 33 LIQUID, & LAC 43 GAS), & is cross referenced to the Pipeline Operations Manual. Through experience, a standard form has been developed. 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 C(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: B.14 Yes, in the LA Administrative Code (LAC 33 LIQUID, & LAC 43 GAS), & is cross referenced to the Pipeline Operations Manual. Through experience, a standard form has been developed. The compliance action specifies the time available for response, and each inspector is responsible to ensure the time frames are adhered to or time extensions are justified. Managers hold inspectors accountable for the timely handling of compliance actions. 15 Has the State issued compliance actions for all probable violations discovered? (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 C(1).4 Yes = 1 No = 0 SLR Notes: B.15. Yes, there were 3 Haz Liq actions in 2010. Reviewed the violation files and the Safety Division is following its procedures. 1 1 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 C(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.16. Yes, the Pipeline Division uses a spread sheet maintained by Arlene Andrus to track dates of inspection, citation, time limit for response, targeted re- inspection due date, actual re-inspection date, outcome, & closure dates. 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 C(1).6 No = 0 Yes = 1 1 1 SLR Notes: B.17. Yes, minor violations were handled informally or with a letter and verified by re-inspection. For 2010, there were no actions where 'show cause' hearings were requested by Pipeline Division, which means that all cited operators complied (or are in the process of complying) with the enforcement actions. The process for 'show cause' hearings is in place. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 C(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: compliance action. B.18. Yes, they use an internal document ? 'Re-Inspection Form' & if the operator response is sufficient, the form is used to document closure of the 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question C(1).8 Yes = .5 No = 0 SLR Notes: B.19. Yes, See Form PLS-OR-1: Organization Report, Also see Pipeline Operations Manual, Glossary, Noncompliance. .5 0.5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question C(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: B.20. Yes, due process is afforded all & is stated in the violation letters. See LA Administrative Code (LAC 33: V subpart 3 Chapter 313 LIQUID, & LAC 43: XI subpart 3 Chapter 5 GAS) Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question C(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation 1 NA Louisiana Louisiana Department of Natural Resources, Page: 8#
LA HL Program Evaluation, 2010, page 9B.21- B.26. NA, is a 60105(a) program. 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question C(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 23 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 C(2).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 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 C(2).4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question C(2).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 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 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 27 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Info Only = No Points Info Only Info Only SLR Notes: B.27. Yes, The Program Manager is familiar with the state process for imposing civil penalties. James Mergist and Steve Giambrone are part of a committee to develop procedures and identify precedents for determining civil penalties. 28 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: B.28. LDNR's goal of achieving 100% Haz Liq inspections per year, either Std or special, was missed in 2010 (at 69.6%) due to experienced personnel leaving the Gas program resulting in HL inspectors needing to cover Gas inspections. LDNR continues to make personnel available to support NAPSR and PHMSA initiatives. Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 9#
LA HL Program Evaluation, 2010, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use an inspection form that was approved by the Regional Director? Previous Question C(3).1 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question C(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, NOT 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 C(3).3 Yes = 1 No = 0 SLR Notes: C.1-8. NA, NOT 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 C(3).4 Yes = 1 No = 0 1 NA SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT 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 C(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question C(3).6 Yes = 1 No = 0 SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question C(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: C.1-8. NA, NOT INTERSTATE AGENT Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10#
LA HL Program Evaluation, 2010, page 11PART D - Accident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an accident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question D.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.1. Yes. Pipeline SOP, General Criteria, Accident Investigations. Appendix C specifies: 1. Determine if safety violations occurred. 2. Determine root causes of the accident if asked by NTSB. 3. Cooperate with NTSB. 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 D.2 Yes = .5 No = 0 SLR Notes: D.2. Yes, the MOU between NTSB and OPS is understood, and LDNR Pipeline Division fully cooperates with NTSB. .5 0.5 3 Did the state keep adequate records of accident notifications received? Previous Question D.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.3. Yes, 2 reportable accidents, 2 reports, plus follow up of several non-reportable accidents when notification was received. 1 1 4 If an onsite investigation of an accident 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 D.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.4. Yes, telephonic contact is made, and the 'Telephonic Leak Report' is used. The information received is used to determine if an on-site visit is required. 1 of the 1 Federally reportable accidents had a field visit. 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? 2 2 Previous Question D.5, , comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations Yes No Needs Improvement b. Contributing factors c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Yes No Needs Improvement SLR Notes: D.5. Yes Yes, Yes, LaDNR uses the federal pipeline failure investigation form when an on-site investigation is made. The events are documented and Appendix C is followed. Including findings of fact, probable cause, and to determine if Pipeline Safety Regulations were followed. 6 Did the state initiate enforcement action for violations found during any accident investigation(s)? Previous Question D.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.6. Yes, of the 1 accident, 1 review is complete and no violations have been found. 1 1 7 Did the state assist region office by taking appropriate follow-up actions related to the operator accident (and forward to PHMSA within 10 Days per 195.58) reports 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 D.7/D.8 and A.4 Yes = .5 No = 0 .5 .5 SLR Notes: were no such requests in 2010. D.7 Yes, The Safety Division has regular contact with PHMSA SW Region and DC to ensure that accident/incident reports are accurate & updated. There 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 11#
LA HL Program Evaluation, 2010, page 12D.8 There was only 1 reportable accident and there were no fatalities or injuries due to reportable accidents in Louisiana in 2010. Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 12#
LA HL Program Evaluation, 2010, 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.12 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: E.1. Yes, it is on LDNR's advisory bulletin list attached to the Std Insp Form. Starting in 2009, this question was also added to the Std Insp Form, subpart F, Damage Prevention module - item 195.442(a). 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: E.2. Yes, it is in the Std Insp Form, Subpart F, Damage Prevention, 195.442(b ), 195.442(c )(4), & (c )(5) . 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.8 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: E.3. Yes, LDNR helped create the Louisiana Common Ground Alliance in 2008. LDNR has been promoting the Best Practices document for the past several years. The State Police are issuing citations and fines for excavation damages. 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: E.4. Yes, the Louisiana One Call is tracking this data in the form of number of locate requests per damage event. In 2007 it was 176 locates per damage, in 2008 it was 185 locates per damage, in 2009 it was 221 locates per damage, and in 2010 it was 192 locates per damage. I advised LDNR that other states have implemented DIRT or Virtual DIRT and strongly recommended that they implement DIRT or equivalent. 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 195.402 (c)(5)? Yes = 2 No = 0 2 2 SLR Notes: E.5. Yes, it is addressed during Std Inspections, Subpart F, per 195.402(c)(5). 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: E.6. LDNR helped create the Louisiana Common Ground Alliance in 2008. The State Police are committed to inspect dig sites & investigate One-Call violations and are issuing citations and fines for excavation damages and violations. There is increasing effort to have operators capture and evaluate ALL excavation damages to maximize opportunities for lessons learned. The Governor's office declared April, 2010 as Damage Prevention month and encouraged calling 811 before digging. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 13#
LA HL Program Evaluation, 2010, 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: Chevron Midstream Piplines LLC Name of State Inspector(s) Observed: Paul Arabie Location of Inspection: Paradis, Louisiana Date of Inspection: 4/6/2011 Name of PHMSA Representative: Dale Bennett SLR Notes: Paul arabie inspected Chevron Midstream Piplines LLC'S, pump stations, valves, linemarkers, cathodic protection, rights-of-way and signs. 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: Chevron Midstream Pipelines LLC was notified in March, 2011. 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 E.2 Yes = 2 No = 0 SLR Notes: The inspector used the Federal Liquid Inspection Form. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question E.3 Yes = 2 No = 0 SLR Notes: The inspector completly filled out the inspection form. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, valve keys, half-cells, etc.) New 2008 Yes = 1 No = 0 SLR Notes: The inspector reviewed with the operator all equipment need for the inspection. 1 1 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 SLR Notes: Field part of a Standard Inspection. Info Only Info Only 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 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) 2 2 SLR Notes: DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 14#
LA HL Program Evaluation, 2010, page 15Yes 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question E.8 Yes = 2 No = 0 SLR Notes: The inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 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 E.10 Yes = 1 No = 0 SLR Notes: The inspector conducted an exit interview. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question E.11 Yes = 1 No = 0 SLR Notes: No probable violations were found during 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: Pump station, cathodic protection test points, right-of-way, line markers, overpressure safety devices, signs and valve maintenance. 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: No best practices was shared. 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 r. Moving Pipe s. New Construction t. Navigable Waterway Crossings DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 15#
LA HL Program Evaluation, 2010, page 16u. 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: See above 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: The inspector was very knowledgeable and did an excellent job. DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 Louisiana Louisiana Department of Natural Resources, Page: 16#
LA HL Program Evaluation, 2010, 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: G.1. Yes, a prioritization risk model spreadsheet has been developed (originally from IMP) that is being adapted to all Operators. It impacts the areas of emphasis during the annual inspections. Elements include compliance issues, accidents, leaks, product transported, population density, MOP as a % of SMYS, total miles of pipeline, corrosion control, & operator responsiveness. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: G.2. Yes, Units are created by Operator, pipe location, Operator management unit, etc. .5 0.5 3 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: G.3. Yes, the risking program has been in use since IMP. .5 0.5 Use of Data to Help Drive Program Priority and Inspections 4 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) Yes = .5 No = 0 .5 0 SLR Notes: G.4. No, o points. have # calls and # damages by region but as yet it is not disaggregated into more specific information. DIRT was not used in 2010. 5 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: monitored. G.5. Yes, the reports are reviewed by an Engineer and compared with prior years. Also, pipeline mileage is used for assessing user fees so it is closely 6 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: G.6. Yes, LNDR reviews the Form for completeness, miles of pipe, & spill/leak data and trends it relative to prior years. .5 0.5 7 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: G.7. Yes, Reportable accidents are investigated relative to minimizing future events, including those due to excavation damage. .5 0.5 8 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: G.8. Yes, performance indicators include accidents per 1000 miles of pipe; # of inspections performed; # of probable violations; # of probable violations corrected. Tracking data includes accidents per 1000 miles of jurisdictional pipe; total miles of jurisdictional pipe; # of reportable accidents; costs due to DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 17#
LA HL Program Evaluation, 2010, page 18reportable accidents; injuries due to reportable accidents; & deaths due to reportable accidents; these numbers are disaggregated to determine national numbers and LDNR State numbers. 9 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? Yes = .5 No = 0 .5 0.5 SLR Notes: G.9. Yes, all of the Standard and Protocol 9 OQ inspections for 2010 have been uploaded, typically within 1 month of the inspection. The focus in 2010 was to conduct Protocol 9 inspections of operators with emphasis on the covered task for valves and corrosion control, & to close out any open OQ violations. 10 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Yes = .5 No = 0 SLR Notes: G.10. Yes. For both GIMP & LIMP .5 0.5 11 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: G.11. Yes. For both GIMP & LIMP. .5 0.5 12 Did the State use the Federal Protocols to conduct IMP Inspections? (If the State used an alternative inspection form(s) please provide information regarding alternative form(s)) Previous Question C(2).6 Yes = .5 No = 0 SLR Notes: G.12. Yes, the Federal Protocols are used. .5 0.5 13 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: G.13. Yes, This has been added (during 2009) onto question 195.402(c)(1) on the Standard Inspection. .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 14 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: G.14. Yes, LDNR makes a report during the SW Region NAPSR Meeting, and responds as appropriate to email correspondence. A fully OQ qualified Contractor/Operator who also teaches & certifies others to OQ failed to follow procedures and got himself and a co-worker burned at a location. This was a classic example of a trained individual being over-confident in his abilities and failing to use industry best practices. The story was told in SW NAPSR 2011. 15 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: G.15. Yes, reports are received, followup is made, paperwork is checked, lessons learned are derived, Accident causes and regulatory compliance are determined, and site visits are usually made. Inspector duties are strongly outlined in SOP section 11. 16 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only SLR Notes: G.16. LDNR does not have a criteria for a formal Root Cause Analysis at this time. Several inspectors will be taking the Root Cause class after they have completed the prerequisites. Five inspectors have completed the course. They do search for probable cause. 17 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Does state conduct root cause analysis on incidents/accidents in state? Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 18#
LA HL Program Evaluation, 2010, page 19Info Only = No Points SLR Notes: G.17. LDNR does not have a criteria for a formal Root Cause Analysis at this time. Several inspectors will be taking the Root Cause class after they have completed the prerequisites. Five inspectors have completed the course. They do search for probable cause. 18 Has state participated on root cause analysis training? (can also be on wait list) .5 0.5 No = 0 Yes = .5 SLR Notes: do search for probable cause. G.18 Several inspectors will be taking the Root Cause class after they have completed the prerequisites. Five inspectors have completed the course. They Transparency - Communication with Stakeholders 19 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: G.19. Yes, is providing a Pipeline Safety Seminar every year instead of every 3rd year, Helped create the Louisiana Common Ground Alliance, Have a close association with LA One Call and with the State Police for excavation enforcement. 20 Does state share enforcement data with public? (Website, newsletters, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: G.20. Yes, the LDNR website is up and running. The public has access to all pipeline inspections on the website since March, 2008. Access to prior inspections requires an office visit. 21 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: G.21. LDNR is dedicated to being transparent, is making data easily available to the public, is committed to data evaluation for self improvement, understands the emphasis on accident/incident investigations, and has scheduled its personnel for additional training. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 19#
LA HL Program Evaluation, 2010, 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.) Previous Question A.15 Yes = .5 No = 0 .5 0.5 SLR Notes: H.1. In 2010 LDNR is active on five NAPSR Committees. LDNR continues to provide associate staff to TQ. LDNR continues to work closely with LA CGA, LA One-Call and the State Police to encourage the use and enforcement of Damage Prevention. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe .5 0.5 initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) A.16 Yes = .5 No = 0 SLR Notes: H.2. LDNR enforces current Federal Regulations and provides technical information to the LA Legislature to make changes as needed in State Laws. LDNR has helped create the LA Common ground Alliance and has established a working relationship with the State Police to enforce excavation damage violations. 3 Any Risk Reduction Accomplishments/Projects? (i.e. Replacement projects,bare steel,third-party damage reductions, HCA's/USA mapping, internal corrosion, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.3. Yes; Risk Reduction: The Pipeline Division works closely with the State Police and LA One Call to improve compliance with the one call law and enforcement efforts as well as with the LA Regional CGA to enhance the one call law. In addition, the Pipeline Division's goal of inspecting 100% of operators and units annually results in increased visibility throughout the state which enhances our public safety efforts. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: H.4. Yes, LDNR works with NAPSR, T&Q, NTSB, PHMSA, and is on various committees. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: H.5. Yes, through SW Region NAPSR, correspondence with other States, other NAPSR & PHMSA committees. 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: H.6. In 2010 LDNR continues to provide associate staff to TQ. LDNR is active on five NAPSR Committees. LDNR enforces current Federal Regulations and provides technical information to the LA Legislature to make changes as needed in State Laws. LDNR has helped create the LA Common Ground Alliance. The Pipeline Division works closely with the State Police and LA One Call to improve compliance with the one call law and enforcement efforts as well as with the LA Regional CGA to enhance the one call law. In addition, the Pipeline Division's goal of inspecting 100% of operators and units annually results in increased visibility throughout the state which enhances our public safety efforts. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 20#
LA HL Program Evaluation, 2010, 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 SLR Notes: I.1. Yes, since the inception of the D&A Program, and verifies with all new Operators. 1 1 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: own program. I.2. Yes, D&A inspections have been added to the SOP. LA has adopted the Federal D&A Forms. The Fed Forms address operators complying with their 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: I.3. Yes, this issue is addressed on the Fed Form #3.1.11 on question A.02.b. .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 195 Subpart G) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: I.4. Yes. All Operators have been OQ inspected and re-inspected. Several Protocol 9 inspections are done every year. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 SLR Notes: I.5. Yes, All OQ inspections are in complete compliance with the federal guidelines. .5 0.5 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 SLR Notes: I.6. Yes, it is covered in the OQ inspections, particularly in Protocol 9. .5 0.5 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 SLR Notes: I.7. Yes, OQ records are checked during every OQ inspection and every Protocol 9 inspection. .5 0.5 Hazardous Liquid Pipeline Integrity Management (49 CFR Part 195.452) 8 Has the state verified that all operators with hazardous liquid pipelines have adopted an integrity management program (IMP)? Yes = 1 No = 0 1 1 SLR Notes: rate of one per quarter. I.8. Yes, Most Operators have been inspected twice. Five new Operators have been identified. One has been inspected and the rest will be inspected at the 9 Has the state verified that in determining whether a plan is required, the operator properly applied the definition of a high consequence area? Yes = .5 No = 0 SLR Notes: DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation .5 0.5 Louisiana Louisiana Department of Natural Resources, Page: 21#
LA HL Program Evaluation, 2010, page 22I.9. Yes, Most Operators have been inspected twice, and the protocols were reviewed to prove HCAs and inclusion in LIMP or prove the lack of HCAs and exclusion from LIMP. 10 Has the state reviewed operator IMPs for compliance with 195.452? Yes = .5 No = 0 SLR Notes: I.10. Yes, it is the LIMP Regulation and most Operators have been inspected twice. .5 0.5 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, which includes the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: I.11. Yes, most Operators have been inspected twice. All violations, tests, and remedial actions have been properly addressed. .5 0.5 12 Is the state verifying operators are periodically examining their hazardous liquid piplines for the appearance of new HCAs? Yes = .5 No = 0 SLR Notes: I.12. Yes, Haz Liq Operators are submitting annual reports which include HCA data. Changes of HCA reported are followed up on. .5 0.5 Public Awareness (49 CFR Section 195.440) 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)? Yes = .5 No = 0 SLR Notes: I.13. Yes; LDNR has verified the status of every operators' public awareness program. .5 0.5 14 Has the state reviewed the content of these programs for compliance with 195.440 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 .5 0.5 SLR Notes: I.14. Yes; either by use of the Clearinghouse or by direct submission of their plans to LDNR. Detail review is a work in progress. The reviews were originally done as stand-alone inspections. With the new inspection form the plan is that they will continue as stand alone inspections. 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: I.15. Yes; it is a work in progress. Operators are being reviewed during stand-alone inspections initially and with the new inspection form the plan is that they will continue as stand alone inspections. 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: I.16. No, not yet. Info only. LDNR expects to start these inspections in late 2011. Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: I.17. LDNR is aware of the Public Awareness requirements and is working the program. It will take some time. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 809927387 2010 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 22#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.