Inspectionhistorical
PHMSA ms2009hlprogramevaluation
2009 MS HL Program Evaluation - ms2009hlprogramevaluation (Mississippi; Hazardous Liquid State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA ms2009hlprogramevaluation
MS HL Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Hazardous Liquid State Program Evaluation for MISSISSIPPI PUBLIC SERVICE COMMISSION 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 Initatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 1#
MS HL Program Evaluation, 2009, page 22009 Hazardous Liquid State Program Evaluation -- CY 2009 Hazardous Liquid State Agency: Mississippi Rating: Agency Status: Date of Visit: 05/17/2010 - 05/21/2010 Agency Representative: Mark McCarver, Director - Pipeline Safety PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Brandon Presley, Chairman Agency: Mississippi Public Service Commission Address: 501 N. West Street, Suite 201A City/State/Zip: Jackson, Mississippi 39201 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2009 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 25 25 C Interstate Agent States 0 0 D Accident Investigations 7 6.5 E Damage Prevention Initiatives 9 8 F Field Inspection 12 12 G PHMSA Initatives - Strategic Plan 10 9.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 101 99 State Rating................................................................................................................................................... 98.0 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 2#
MS HL Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over 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: violation up to $200,000. Attachment 8 states that the MPSC has not adopted civil penalties. The MPSC has not adopted the federal level but it has adopted $1000 per day per 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance 1 1 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 SLR Notes: Yes. The MPSC maintains an electronic logging of the incident. A file is created when an incident is reported. A file is created in the report filing system on the MPSC's computer network drive. 3 Has the state held a pipeline safety T & Q seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar 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: Yes. The MPSC conducts a pipeline safety seminar for its operators each year. The MPSC conducted seminars in 2008 and 2009. 2 2 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: Yes. The file systems were organized and provided the information needed to perform the program evaluation. 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 2 2 SLR Notes: Mr. McCarver has been the program manager for the MPSC for over seven years. He was a MPSC investigator for several years prior to assuming the program manager job responsibilities. Mr. McCarver is knowledgable of pipeline safety regulations and the requirements for a state pipeline safety program outlined in the Guidelines For A State Pipeline Safety Program. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.9 Yes = 1 No = 0 SLR Notes: The 2008 Program Evaluation Letter to the Chairman of the MPSC did not identify any issues requiring a response from the MPSC. 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: 878639368 2009 Hazardous Liquid State Program Evaluation 1 1 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 3#
MS HL Program Evaluation, 2009, page 4SLR Notes: No items were identified in the Chairman's letter that required action on the part of the commission. Items were identified in the Program Manager's letter that required action to achieve the maximum number of evaluation points. Those items were reviewed in the specific evaluation questions for the 2009 evaluation. 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: Only certain MPSC inspection staff have responsibilities to inspect hazardous liquid pipelines. These inspectors are Lyla Carnley, Michael Sharp and Wiley Walker. Wiley Walker has not reached the deadline starting from the first class of enrollment. Michael Sharp has completed the required courses. Lyla has not completed but is scheduled for class to complete the traiining. 9 Brief Description of Non-T&Q training Activities Info Only = No Points For State Personnel: Two inspectors attended training at Leak City facility in Athens, AL. For Operators: MPSC staff attended annual Trade Show in March 3, 2010 and Annual Gas Conference in Orange Beach, Al. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: MPSC staff attended Damage Prevention Committee meetings and utility coordinating committee meetings. SLR Notes: See notes above. Info Only Info Only 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: inspections were conducted. Yes. Upon a review of the OQ database and training records, the inspectors assigned to lead OQ inspections completed the required training prior to the time 11 Did the lead inspectors complete all required 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: Lyla Carnley and Michael Sharp conduct the Integrity Management inspections for the MPSC. Lyla and Michael have one remaining course to complete, External Corrosion Direct Assessment. ECDA was an added requirement for which additional time to obtain the completion of all courses. The MPSC should obtain the training as quickly as possible to prevent the loss of points in future evaluations 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): 5 5 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): Ratio: A / B If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 SLR Notes: Yes. The MPSC had 35 inspection person days during 2009. The MPSC assigned .15 person years to the natural gas program during 2009. The resulting ratio is 1.06 which exceeds the minimum ratio of 0.38. DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 4#
MS HL Program Evaluation, 2009, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Question B.13 Info Only = No Points SLR Notes: Info Only Info Only There were no changes to the inspector staffing levels during 2009. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The MPSC has generally complied with Part A of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 5#
MS HL Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators) (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: The MPSC has written procedures which state that each operator and unit will have a standard inspection completed once every two years. OQ field and damage prevention are covered in standard inspections. Construction inspections are scheduled as the MPSC is notified of construction plans. The MPSC has a construction notification rule for operators. Followup inspections are scheduled after each inspection that contains a probable violation(s). Incident and training inspections are scheduled on an as needed basis. 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: Yes. The primary factor for selecting operators to be inspected is the length of time since the last inspection. The time frequency can be over-riden if concerns were found during previous or recent inspections. The MPSC has developed a relative risk ranking tool to prioritize its inspections but has not revised its procedures to include consideration of the rankings at this time. 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 SLR Notes: Yes. The MPSC complied with its inspection frequency procedures. 2 2 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: Yes. The MPSC uses the federal inspection forms for all inspections except for construction inspection. The MPSC developed its own construction inspection form. Upon a review of the form, it appears to cover all items covered on the federal construction inspection form. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.6 Yes = 1 No = 0 SLR Notes: Upon a review of randomly selected inspection reports, all portions of the forms were completed. 1 1 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.7 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation .5 0.5 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 6#
MS HL Program Evaluation, 2009, page 7Yes = .5 No = 0 SLR Notes: There were no safety related conditions reported by intrastate natural gas operators during 2009. 7 Did the state review operator procedures for determining areas of active corrosion on liquid lines in sufficient .5 0.5 detail? (NOTE: PHMSA representative to describe state criteria for determining areas of active corrosion) Previous Question B.8 Yes = .5 No = 0 SLR Notes: Yes. The MPSC reviews this issue when conducting an operator headquarter's inspection which covers operation and maintenance of the operator. The MPSC also provides a listing of advisory bulletins to operators when conducting standard inspections. 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: Yes. These concerns are addressed during the MPSC's annual operation and maintenance procedures review. .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: The MPSC discusses environmentally sensitive areas with the Mississippi Department of Environmental Quality. The MPSC uses this resource to confirm that operators have these areas noted in their Integrity Managment Program. 10 Did the state review operator records of previous accidents and failures including reported third party damage 1 1 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: Yes. The MPSC covers Part 195.402 requirements when it conducts standard inspections of operators. The MPSC reviews operator's response times when reviewing operator's pipeline repair records. 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: Upon a reveiw of randomly selected inspection reports completed in 2008, probable violations were documented with descriptions of the operator's actions or lack of actions that resulted in a probable violation. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question C(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The MPSC office procedures state the steps to be taken until the probable violations are corrected. The MPSC issues a non-compliance notification to an operators when a probable violation is found. Operators are given 30 days to respond to the notice. Followup inspections are conducted to monitor the progress of corrective actions. Operators are given the opportunity to povide information showing that a probable violation did not occur or an opportunity to request a hearing before the Commissioners to argue that a probable violation did not occur. 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 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The MPSC's office procedures state that a written non compliance notification is sent to an operator whenever a probable violation is identified. Operators are given 30 days to respond. DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 7#
MS HL Program Evaluation, 2009, page 814 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: Yes. The MPSC's procedures state that follow up inspections will be scheduled after written notification of probable violation has been sent to an operator. 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: There were no probable violations found during 2009. There was not a need to issue any compliance actions. 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 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: There were no follow up actions required in 2009. 1 1 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 SLR Notes: There were no non-compliance actions taken in 2009. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question C(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: There were no probable violations found during 2009. 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question C(1).8 Yes = .5 No = 0 SLR Notes: There were no written letters of non-compliance during 2009. .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 SLR Notes: There were no compliance proceedings during 2009 due to no probable violations being found during inspections. 1 1 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: 1 NA 22 SLR Notes: 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 1 NA DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 8#
MS HL Program Evaluation, 2009, page 923 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question C(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question C(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question C(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The MPSC has generally complied with Part B of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 9#
MS HL Program Evaluation, 2009, 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 SLR Notes: The MPSC was not an interstate agent during 2009. 1 NA 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: The MPSC was not an interstate agent during 2009. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 10#
MS HL Program Evaluation, 2009, 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 SLR Notes: Yes. The MPSC has followed the procedures contained in the Guidelines detailing the procedures and expectations for cooperation. 1 1 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 .5 0.5 SLR Notes: Yes. The MPSC exhibited knowledge of the cooperation statements contained in the MOU between PHMSA and the NTSB. There were no incident investigations in 2009 whereby the MOU was needed. 3 Did the state keep adequate records of accident notifications received? Previous Question D.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: There were two intrastate hazardous liquid pipeline incidents that were reported by operators during 2009. One was reported by Transmontaigne, accident occurred on 4/11/2009, and the other was reported by Genesis Pipeline USA, accident occurred on 11/30/2009. Adequate records were kept for both incidents. 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 SLR Notes: All reportable incidents that occurred in 2009 were investigated by the MPSC. 1 1 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: Upon a review of the completed PHMSA accident investigation forms, it appeared that the MPSC was thorough in its investigation. 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 1 1 SLR Notes: enforcement actions. There were no probable violations found in both reportable hazardous liquid pipeline accidents that occurred in 2009. There was no cause to intiate 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 0 SLR Notes: Needs Improvement. One ODES follow-up on incident reports filed by operator's has been closed, there are several open. Southern Region Office has had difficulty getting word back on the review of the information ? the MPSC provides verbal resonse that they are working on it, but Southern Region has not received written communication back on it being worked/reviewed and completed 8 Part D: General Comments/Regional Observations Info Only = No Points DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 11#
MS HL Program Evaluation, 2009, page 12SLR Notes: Point Reductions: Question D.7 - Needs Improvement. One ODES follow-up on incident reports filed by operator's has been closed, there are several open. Southern Region Office has had difficulty getting word back on the review of the information ? the MPSC provides verbal resonse that they are working on it, but the Southern Region has not received written communication back on it being worked/reviewed and completed. This resulted in a 0.5 point reduction. Total points scored for this section: 6.5 Total possible points for this section: 7 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 12#
MS HL Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Previous Question B.12 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: reviewed annually. Yes. The MPSC verifies that operators include directional/boring procedures in their Operation and Maintenance Procedures. Operator's procedures are 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes. During standard inspections, the MPSC verifies that operators follow through with their damage prevention programs required by Part 195.442. 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: Yes. The MPSC promoted the best practices in presentations at industry gatherings. The MPSC includes an item on its standard inspection form to promote discussion of best practices with operators. 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 0 SLR Notes: not given for this question. No. The MPSC or another organization within the state has not collected data on the number of pipeline damages per 1000 locate requests. One point was 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: Yes. The MPSC reviews operator's records on leaks and failures during its review of operator's records documenting compliance with 195.402 (c)(5). 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Point Deductions: Question E.4 - The MPSC or another organization within the state has not collected data on the number of pipeline damages per 1000 locate requests. One point was deducted. Total points scored for this section: 8 Total possible points for this section: 9 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 13#
MS HL Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Hunt Crude Oil Supply Name of State Inspector(s) Observed: Wiley Walker and Mike Sharp Location of Inspection: Melvin, Alabama Date of Inspection: 4/8/2010 Name of PHMSA Representative: Dale Bennett SLR Notes: This was a field inspection of the receivers, pumps, launchers and several sections of the pipeline ROW on Hunt's East Mississippi Pipelines. Mark McCarver was present during the inspection. 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: Hunt Crude Oil Supply was notified of the planned inspection on 1/26/2010. 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 PHMSA'S inspection checklist form for hazardous liquid pipelines. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question E.3 Yes = 2 No = 0 SLR Notes: The inspector marked the appropriate blocks for each requirement on the federal 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 the operator's test equipment that he used in the field. 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: The inspector's conducted a standard inspection of Hunt Crude Oil Supply's operation and maintenance field activities. 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: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 14#
MS HL Program Evaluation, 2009, page 15The inspectors compared the procedures to the field activities. 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 inspectors exhibited excellent knowledge of the requirements in 49CFRPart 195 which as applicable for this inspection. 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 inspectors conducted an exit interview with the operater upon completion of their inspection. 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: The inspectors reviewed the results of the inspection conducted on this day. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: This was a field inspection of the receivers, pumps, launchers and several sections of the pipeline ROW on Hunt's East Mississippi Pipelines. Excellent inspections were performed by Mr Walker and Mr Sharp. 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only = No Points SLR Notes: There were no best practices identified that warrant communicating. 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: 878639368 2009 Hazardous Liquid State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 15#
MS HL Program Evaluation, 2009, 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: This was a field inspection of the receivers, pumps, valves, cathodic protection, line markers, signs, launchers and several sections of the pipeline ROW on Hunt's East Mississippi Pipelines. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Mr Walker and Mr Sharp performed a thorough review of comparing the operators procedures to the field. They conducted themself in a professional manner and treated the operator with respect. They exhibited a good understanding of the pipeline safety regulations. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 16#
MS HL Program Evaluation, 2009, page 17PART G - PHMSA Initatives - 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: Yes. The MPSC has developed a spreadsheet that quantifies relative risk of each operator. The relative risk spreadsheet considers a number of possible threats. The MPSC has not revised its procedures to include this process in its inspection planning. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The inspection units are broken into units as described in the "Guidelines For States Participating in the Pipeline Safety Program" (Guideline). 3 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC assigns it investigators with geographical areas of the state. The investigator manages and coordinates inspections of operators within the areas they are responsible. The investigators are very knowledgable (subject matter experts) of each operator's systems and operations. The MPSC utilizes the investigators knowledge to identify high risk areas and conduct focused inspections. The MPSC has focused on threats of third party excavation and pipe materials. The MPSC has developed a relative risk ranking spreadsheet during 2009. 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) .5 0.5 Yes = .5 No = 0 SLR Notes: in CGA's DIRT system. The MPSC reviews data from non- compliance issues from inspections and operator data related to damages to pipelines. The MPSC reviews data contained 5 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC requires that operators provide it with a copy of its Annual Reports submission to PHMSA each year. The MPSC reviews the information for accuracy and comparison to the previous year report. The operators are informed of any inconsistencies found during the reviews. 6 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC monitors the mileage and age of pipe materials that operators report in their annual reports. The MPSC also monitors the data operators provide on integrity management inspections and remedial actions reported on the Annual Reports. 7 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC reviews data on incident repots to ensure that the reports are complete (all entries are completed), the proper status is checked (original, supplemental or final), and that the operator's stated cause of the liquid spill is reasonable and is consistent with the MPSC's investigation. 8 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures,trends,etc.) Yes = .5 No = 0 SLR Notes: DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation .5 0.5 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 17#
MS HL Program Evaluation, 2009, page 18The MPSC reviews data on Annual reports from operators. The MPSC reviews data on pipe material to monitor the replacement of aging pipe. The MPSC reviews the data on integrity management assessments and number of repairs shown in the Annual Reports and compares to previous years. The MPSC monitors the number of inspections that it performs and the number of non-compliance findings during its inpsections. 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: The MPSC uploaded the results of its inspections of operator's OQ plans since 2004. The MPSC was very active in uploading these results. The MPSC continues to upload the results of inspections on operator's performance related to their plans as documented on Protocol 9 forms. 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 .5 0.5 SLR Notes: The MPSC responded to all notifications it received during 2009. 11 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 .5 0 Yes = .5 No = 0 SLR Notes: The Liquid IMP data base contains one uploaded inspection. The MPSC has not complied with this requirement. 0.5 points is deducted. 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: Upon a review of the MPSC's Liquid IMP inspection files, all inspections were conducted utilizing the federal protocol forms. .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 .5 0.5 SLR Notes: submittals due to changes. Yes. This is verified during comprehensive inspections. The operator is questioned as to whether they have made their submittals and any subsequent 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: Yes. The MPSC presented an update of its program at the NAPSR Southern Region Meeting held in April, 2009. The MPSC included a topic on the incidents that occurred in Mississippi since the previous NAPSR Southern Region meeting. 15 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: The MPSC has not been contacted about a request for data related to incidents or accidents. The MPSC has cooperated with any requests from the Southern Region Office related to incidents reported to the National Response Center. 16 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points SLR Notes: Root cause is a new method for the MPSC and has not been incorporated as yet. Info Only Info Only 17 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points SLR Notes: DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 18#
MS HL Program Evaluation, 2009, page 19Not at this time. 18 Has state participated on root cause analysis training? (can also be on wait list) No = 0 Yes = .5 .5 0.5 SLR Notes: Wiley Walker completed the root cause training in 2009. Michael Sharp is scheduled to attend in 2010. 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: Yes. The MPSC participates in the Mississippi Damage Prevention Committee. The MPSC participates in Mississippi Gas Association meetings and conferences. Mark McCarver authors an article each month in the damage prevention magazine circulated in Mississippi. The MPSC participates in local Utility Coordinating Committee meetings. 20 Does state share enforcement data with public? (Website, newsletters, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The public has access to the MPSC docket system where enforcement cases seeking civil penalties or other Commission action is available. The MPSC provides access to the Commission's website and the MPSC produces an Annual Newsletter that is provided to the public. 21 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Points Deducted: Question G.11 - The Liquid IMP data base contains one uploaded inspection. The MPSC has not complied with this requirement. 0.5 points is deducted. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 19#
MS HL Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Previous Question A.15 Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC has been instrumental in supporting changes to the underground facility damage prevention laws in Mississippi. The MPSC works very closely with the one call system in Mississippi and has partnered with them on damage prevention initiatives. The MPSC has developed a system to risk rank operators' systems and operations on a relative basis. The MPSC completed Liquid IMP inspections for all hazardous liquid operators during 2009. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) A.16 Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC participated in an effort to get legislation passed to enhance damage prevention. Mississippi now requires utilities to install underground facilities in such a manner that they are locatable with standard methods and that utility operators must positively respond to individuals that provide excavation notification. 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: The MPSC has partnered with stakeholders in Damage Prevention to propose legislative changes in Mississippi law related to damage to underground utilities. The MPSC developed a relative risk ranking model to determine inspection priorities. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: Yes. The MPSC adequately responded to all requests that it received. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC is sharing information with Texas and Lousiana during the seminar that occurs each year in Lousiana. 6 Part H: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only The MPSC has generally complied with Part H of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 20#
MS HL Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 1 1 SLR Notes: Yes. The MPSC has completed the review of all operators' drug and alcohol testing programs and has followed up with reviews when Part 199 rules have been amended or operator's plans have been revised. 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Operators records are reviewed during standard inspections to verify random drug testing rates exceed 25 percent. The MPSC checks records of tests for cause or post incident tests of employees who may have been involved in an incident. 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. If positive results are shown in an operator's records, the MPSC questions operators of the actions taken as a result of the positive test(s). The MPSC compares the action taken with the procedure described in the operator's plan. Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 1 1 SLR Notes: OQ database. Yes. The MPSC has completed the review of all operators' Operator Qualification Plans. The results of these inspections have been uploaded to PHMSA's 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 Yes = .5 No = 0 SLR Notes: Yes. The MPSC utilized the protocol forms to inspect operators' OQ Plans. The protocol forms were uploaded into PHMSA's OQ database. 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 .5 0.5 SLR Notes: Yes. The MPSC reviews OQ Qualification records as a part of its standard inspections. The verifies that requalifications are performed within the timeframes established in the operator's OQ Plan. The MPSC also conducts Protocol 9 inspections to randomly verify that qualified individuals can perform the covered tasks as outlined in operators' plans. 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC verifies qualification records during its standard inspections to insure that operators are requalifying individuals according to the operators' requalification intervals outlined in their plans. 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: Upon a review of the MPSC's Liquid IMP inspection files, all hazardous liquid pipeline operators' integrity managment plans have been reviewed. The MPSC's 2010 Certification shows that there are ten hazardous liquid pipeline operators. 9 Has the state verified that in determining whether a plan is required, the operator properly applied the definition of a high consequence area? DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation .5 0.5 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 21#
MS HL Program Evaluation, 2009, page 22Yes = .5 No = 0 SLR Notes: covers this requirement. The MPSC uses and completes all information in the protocol forms while conducting its inspections of Integrity Management Plans. The protocol form 10 Has the state reviewed operator IMPs for compliance with 195.452? Yes = .5 No = 0 .5 0.5 SLR Notes: 195.452. The MPSC uses the Integrity Management Plan inspection protocols while conducting its IMP inspections. The protocol forms covers the requirements in 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: The MPSC has conducted these reviews while completing the protocol forms. .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: The MPSC has reviewed this requirement while conducting Liquid IMP inspections as evidenced in the completed protocol forms. .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 .5 0.5 SLR Notes: Yes. The MPSC partiicpated in the Public Awareness Clearinghouse review of operator's plans. The MPSC verified that all operators submitted their Public Awareness Plans within the timeframe prescribed by the regulations. 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: The MPSC participated in the review conducted by the Public Awareness Clearinghouse. The MPSC reviewed the results submitted by the Clearinghouse. The MPSC followed up with operators on any deficiencies identified by the Clearinghouse. 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The MPSC reviews an operator's activity records when conducting standard inspections. The MPSC will need to review operators' effectiveness evaluations beginning June of 2010. 16 Is the state verifying that operators have evaluated their public awareness programs for effectiveness as described in RP1162? Info Only = No Points SLR Notes: The MPSC has not begun this effort since the due date for operators to complete their evaluations until June of 2010. Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only The MPSC has generally complied with Part I of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. DUNS: 878639368 2009 Hazardous Liquid State Program Evaluation Total points scored for this section: 9 Total possible points for this section: 9 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, 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.