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PHMSA la2015hlprogramevaluation
2015 LA HL Program Evaluation - la2015hlprogramevaluation (Louisiana; Hazardous Liquid State Program Evaluation)
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LA HL Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 Hazardous Liquid State Program Evaluation for Louisiana Department of Natural Resources Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1#
LA HL Program Evaluation, 2015, page 22015 Hazardous Liquid State Program Evaluation -- CY 2015 Hazardous Liquid State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 07/11/2016 - 07/15/2016 Agency Representative: Steven Giambrone PHMSA Representative: Leonard Steiner Commission Chairman to whom follow up letter is to be sent: Name/Title: Richard Ieyoub, Commissioner Agency: Louisiana Department of Natural Resources-Office of Conservation Address: 617 North Third Street 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 2015 (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 progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): 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 G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 43 40 D Compliance Activities 15 15 E Accident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (if applicable) 0 0 I 60106 Agreement State (if applicable) 0 0 TOTALS 111 108 State Rating................................................................................................................................................... 97.3 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2#
LA HL Program Evaluation, 2015, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Records are on electronic databases and accessible. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate as reported 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 3#
LA HL Program Evaluation, 2015, page 4Evaluator Notes: Yes 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4#
LA HL Program Evaluation, 2015, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes Have procedures for Standards Inspections 2 2 2 IMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes Have procedures for Integrity Management Inspections 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes Have procedures for Operator Qualification Inspections 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes Have procedures for Damage Prevention Inspections 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes properly documented. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes Have procedures for Construciton Inspections. Louisiana has notification requirements for construction of pipelines. 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 5#
LA HL Program Evaluation, 2015, page 6b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic area, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 6#
LA HL Program Evaluation, 2015, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 262.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.20 = 484.00 Ratio: A / B 262.00 / 484.00 = 0.54 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ratio = .54 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Outside training: 7 attended the Louisiana Pipeline Association training. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: 4 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, address all areas that needed improvement. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Conducted a TQ supported seminar in July, 2015. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 2 Evaluator Notes: Needs much improvement. Operator Qualification inspections: only 23 of 62 operators has current inspections. Integrity DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 7#
LA HL Program Evaluation, 2015, page 8Management inspection: only 20 of 62 operators had a current inspection. Standard inspections: only 8 of 62 had a current inspection. 7 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Mpire records systems provides adequate inspection forms. 2 2 8 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)? Yes = 1 No = 0 Evaluator Notes: Yes, reviewed records of accidents and failures. 1 1 9 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: Yes, Reviewed Annual Reports for accuracy and analyzed for trends. 2 2 10 Did state input all applicable OQ, LIMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Inspections were uploaded in a timely manner. 2 2 11 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: DataMart. yes, has a question of inspection form and reviewed the Annual Report versus NPMS mileage report in the Pipeline 12 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Louisiana is conducting Drug and Alcohol inspections. 2 2 13 Is state verifying operators OQ programs are up to date? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: yes Louisiana is conducting OQ inspections. 2 2 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 8#
LA HL Program Evaluation, 2015, page 914 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. conducting IM inspections, but have a back log of LIMP inspections to conduct as noted in Question C.6. 15 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 195.440 PAPEI Effectiveness Inspections should be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Louisiana is conducting PA effectiveness inspections. 2 2 16 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Louisiana has a Website. 1 1 17 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, monitored and followed up. 1 1 18 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes 1 1 19 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. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: No requests for waivers were received. 1 NA 20 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Yes 1 1 21 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Louisiana Louisiana Department of Natural Resources, Page: 9#
LA HL Program Evaluation, 2015, page 10Evaluator Notes: Reviewed with Program Manager, The number of probable violations were less but were corrected. Louisiana uses there civil penalty authority. The number of inspection days per 1000 miles of pipeline has decreased from 2012. 22 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 40 Total possible points for this section: 43 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10#
LA HL Program Evaluation, 2015, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: Yes, have procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: Yes, all of these compliance actions were used. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: If a unsatisfactory condition is entered into their database, a compliance is required. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes 2 2 5 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) Yes = 2 No = 0 Evaluator Notes: Mr. Giambrone is familiar with the process for imposing civil penalties. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Louisiana uses their fining authority. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 11#
LA HL Program Evaluation, 2015, page 12Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 12#
LA HL Program Evaluation, 2015, page 13PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, They have procedures for receiving and responding to the report of an accident. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes, they familiar with the agreements. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, 1 1 4 Were all accidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Evaluator Notes: Yes, conducts adequate accident investigations. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: No probable violations were discovered. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator accident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maintains communications with the Southwest region office. 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 13#
LA HL Program Evaluation, 2015, page 14Yes 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 14#
LA HL Program Evaluation, 2015, page 15PART F - Damage Prevention 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, They have a question on their standard inspection form. 2 2 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: They inspect the receiving of the notification of locate, and marking. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Louisiana One-Call has damage prevention meetings, and the Governor sigs a proclamation in April for Safe Digging month. 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: They use data from the one-call. 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 15#
LA HL Program Evaluation, 2015, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Maurepas Pipeline, opid is applied for Name of State Inspector(s) Observed: Sarah Kreitzer, inspector, & Mark Champagne, supervisor Location of Inspection: main construction site near Sorrento, LA Date of Inspection: 08/8-11/2016 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. Maurepas Pipeline, opid is applied for; Sarah Kreitzer, inspector, & Mark Champagne, supervisor; main construction site near Sorrento, LA; 8/8-11/2016, Patrick Gaume 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: G2. Yes. The Operator & major contractors were notified and 24+ personnel participated in the inspection. 3 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 2 2 Evaluator Notes: G3. Yes. A LDNR Form which is based on the Federal Form and a specialized Guidance Form which is project specific. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: G4. Yes. It is a work in progress; it is near the end of the procedures phase and at the beginning of the construction phase. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,valve keys, half cells, etc) Yes = 1 No = 0 Evaluator Notes: G5. Yes. This is a specialized pipeline and the operator and contractors are assembling and supplying the needed equipment as needed for each phase. Site inspection and quality control is extensive. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: G6. Yes, yes, & yes. Procedures, chloride records, and start-up of field construction were observed during the evaluation. DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 16#
LA HL Program Evaluation, 2015, page 177 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: 2 2 G7. Yes. The inspector was well briefed on the project and was diligently reviewing the procedures for completeness. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: G8. Yes. Sarah addressed various procedure deficiencies and directed that certain AOCs and negative test results be addressed in the procedures. The deficiencies will be followed up on next week. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: G9. Yes. Sarah addressed various procedure deficiencies and directed that certain AOCs and negative test results be addressed in the procedures. The deficiencies will be followed up on next week. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other 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 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 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 17#
LA HL Program Evaluation, 2015, page 18D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: G10. Yes. Joint field coating was observed. b, i, k, j, m, o, r, s, B. DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Total points scored for this section: 12 Total possible points for this section: 12 Louisiana Louisiana Department of Natural Resources, Page: 18#
LA HL Program Evaluation, 2015, page 19PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Were 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 19#
LA HL Program Evaluation, 2015, page 20PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2015 Hazardous Liquid State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 20#
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