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PHMSA pr-2020-gas-program-evaluation
2020 PR NG Program Evaluation - pr-2020-gas-program-evaluation (Puerto Rico; Natural Gas State Program Evaluation)
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PR NG Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for PR Department of Transp. and Public Works Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 1#
PR NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Puerto Rico Rating: Agency Status: Date of Visit: 11/01/2021 - 11/05/2021 Agency Representative: Jorge L. Cotto P?rez, PE Interim Program Manager PHMSA Representative: David Appelbaum Commission Chairman to whom follow up letter is to be sent: Name/Title: Eileen M. V?lez Vega, PE, Secretary Agency: Department of Transportation and Public Works Address: PO Box 41269, Minillas Station City/State/Zip: San Juan, PR 00940-1269 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 11 C State Qualifications 10 5 D Program Performance 50 38 E Field Inspections 15 0 F Damage prevention and Annual report analysis 10 8 G Interstate Agent/Agreement States 0 0 TOTALS 100 62 State Rating................................................................................................................................................... 62.0 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 2#
PR NG Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: PR's Progress Report had a number of errors to include: 1. Attachment # 1 listed 7 operators in Private Distribution when they should have been listed in the LPG section. Also of note, PR's 2022 Grant Application identifies two Master Meter Operators, but no mention of these operators in the PR. 2. Inspection days were identified in Private Distribution --- they belong in LPG. 3. PR identifies 7 [LPG] operators. However, only 5 of them have OPID numbers, and only 1 of those (San Juan Gas) has submitted an annual report. ** There is confusion of the jurisdictional authority over several operators. State will need to conduct an assessment and determine the extent of their 60105 authority. 4. Carry over numbers in Attachment 5 were incorrect. Also, State was not able to provide documentation to support the Compliance Actions or Probable Violations entered. 6. The State had a change in personnel in CY 2021 and it appears that some files/records were lost in this transition. 7. A review of TQ Blackboard minimum training records confirm Alice Velazquez and Zuleika Ruiz have completed all courses for standard gas inspector. These two inspectors left the program in 2021. 8. PR DTOPW civil penalties are not essentially the same as PHMSA and loss of points occurred during the progress report reviews. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 3#
PR NG Program Evaluation, 2020, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 4 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Procedures for Pre-Inspection Planning and Inspection Activities are insufficient and lacks sufficient detail to ensure the efficient, effective and consistent completion of state conducted inspection activities. They provide a high-level of activities that should happen but doesn't give sufficient direction on how to conduct those activities. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 3 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Procedures appear to have migrated from conducting an annual inspection on each operator to a five year cycle. This appears to have been done since all inspectors were not inspected according to their procedures in CY 2020. Procedures are unclear and ambiguous - one point deduction. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Procedures could be made to be clearer on this, but otherwise appear to satisfy this question. 3 3 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 1 Evaluator Notes: DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 4#
PR NG Program Evaluation, 2020, page 5Procedures attempt to "incorporate by reference" the requisite State Guidelines for this topic and do not specify the items listed for this question. They are silent on the details/instructions. Loss of two points. 5 General Comments: Info Only = No Points Evaluator Notes: Four point loss for this section. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 15 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 5#
PR NG Program Evaluation, 2020, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: A review of TQ Blackboard data found in CY2020 inspectors met all requisite qualifications. In CY2021, these inspectors left the program. 2 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 = 5 No = 0 Needs Improvement = 1-4 5 0 Evaluator Notes: The current Interim Program Manager, Jorge L. Cotto P?rez, PE, has no pipeline experience, has not completed any TQ courses or participated in any operator inspections. He was put in the interim PM role until a qualified inspector can be hired. At the time of this evaluation, the Program's one inspector does not meet the 3 or 5 Year requirement and a temporary extension has not been granted. Five point deduction 3 General Comments: Info Only = No Points Evaluator Notes: No points given for Part C. Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 10 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 6#
PR NG Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: The Interim PM gathered the 2020 reports of the inspections and stated they could not inspect all the sites due to the pandemic. No points taken due to COVID 19. The Units that were not inspected during the CY 2020 are the following: Operator: Empire Gas (Empresas de Gas) ? Escorial Shopping Village ? Las Catalinas Mall Operator: Tropigas ? Monte Sur ? Las Casitas ? Centro M?dico ? Cardio Vascular Operator: Light Gas ? Plaza San Miguel 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Yes, PR DOTPW uses the federal PHMSA Inspection form for all types of inspections. 10 10 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 7#
PR NG Program Evaluation, 2020, page 8Evaluator Notes: Yes, verification of QO program is reviewed during the standard inspection. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 Evaluator Notes: a. Ecoelectric has provided information on their integrity management program to the program manager. The manager has made recommendations about the plan under a separate communication. b & c This is checked and reviewed during the standard inspection audit. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: a & b. PR does not have cast iron pipelines in their state. c thru g. This is accomplished and reviewed during the standard inspection audit. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Only advisory bulletins that are relative to LPG systems are provided to the operators via State Program Manager letters and presentations. All relative advisory documents are reviewed with the operator during the inspection audit. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 10 0 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 8#
PR NG Program Evaluation, 2020, page 9a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: All evaluations conducted in CY2020 were reviewed. There were over 50 instances where an inspection identified one or mores "UNSATs." The appropriate CFR was applied to all UNSATs. There was no evidence that these "UNSATs" lead to a probable violation, was followed up on, documented or resolved (systemic deficiencies). The compliance actions the Program did have (there were some) were done in accordance with Guidelines. In summary, Program was compliant with a, h, i and j. Program was deficient with b, c, d, e and g. The Program is six years old so "f" is N/A. Per evaluator guidance: - four points taken for "b" (systemic deficiency) - four points taken for "c" (systemic deficiency) - four points taken for "d" (systemic deficiency) - four points taken for "e" (systemic deficiency) - one point taken for "g" Itemized deductions exceed scoring maximum - no points awarded. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 9 Evaluator Notes: No incidents/accidents occurred in CY2020. As stated in question B-4, procedures attempt to "incorporate by reference" the requisite State Guidelines for this topic and are not specific. They are silent on the details/instructions on the mechanism to receive and respond to operator reports of DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 9#
PR NG Program Evaluation, 2020, page 10incidents. It was understood in the past that question "a." was accomplished by correspondence between the program manager and operators. Contact was apparently provided in letters to operators and presented at damage prevention seminars. At the time of this evaluation there was no evidence to support this claim - one point deduction. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Program requested an extension, which was granted. Outbound letter 10/26/2020, inbound letter received 2/26/2021. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: PR DTOPW conducted a pipeline safety training seminar on June 25-26, 2019 in San Juan. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes, this item was reviewed with San Juan Gas during the standard inspection audit. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 0.5 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Half point deduction - no change since last evaluation. Last year's entry: "Information about the pipeline safety program and inspection performed had previously been developed to be posted on PR DTOPW website but IT department has not completed this work. This item was listed in last year's evaluation review Part C- Program Performance, Question D.19, as Needs Improvement. Improvement again is needed." 13 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: Reviewed Pipeline Data Mart and found no safety related condition reports for CY2020. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 0.5 Evaluator Notes: half point deduction. WMS ticket 20-172605 remains open. Program needs to verify the work below has been completed and close-out this ticket - From WMS: "On January 7th, 2020, an earthquake of magnitude 6.4 in the Richter Scale was experienced in the southern part of Puerto Rico. A replica of 6.0 and tremors of lesser magnitude followed. EcoEl?ctrica personnel first inspected the natural gas pipeline following the events and found the following conditions: 1. Pipeline integrity was not affected. 2. All welds were visually found in good condition. 3. Two concrete fixed supports were damaged. 4. Lateral guides were damaged. DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 10#
PR NG Program Evaluation, 2020, page 11On January 8th and January 9th, 2020, EcoEl?ctrica hired a certified contractor to evaluate the identified conditions. Refer to Appendix 1 for the inspection report. Inspector concluded that integrity of the pipeline is satisfactory but supports and lateral guides repair are required to be corrected prior to returning the pipeline to service." 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No waivers/special permits have been issued in CY2020 and prior years. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Program brought in help from another department who was able to organize their file system. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: Program is in-between Program Managers. SICT numbers appear to have been entered sufficiently. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Interim PM is new to pipelines and not aware of these metrics. Info Only Info Only 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Yes, this item was last presented at a TQ Pipeline Safety Seminar in June 25-26, 2019. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 38 Total possible points for this section: 50 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 11#
PR NG Program Evaluation, 2020, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Info Only Info Only Evaluator Notes: On November 3rd, Tropigas and Liquiluz facilities, both LPG operators, were visited in San Juan. Both facilities appear to have been inspected in CY2020, and representatives from both were present when visited. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 0 Evaluator Notes: The PR Program experienced personnel changes in June 2021. At the time of this evaluation, the interim manager, Jorge Cotto P?rez, had no experience, knowledge, or capability to sufficiently conduct a field evaluation. As a formality, two operators in San Juan, Tropigas and Liquilux, were selected and visited. At both locations it was validated that the Program is/was not capable of performing an inspection. There are no points awarded for Part E. 3 Did the inspector adequately review the following during the inspection 10 0 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: The PR Program experienced personnel changes in June 2021. At the time of this evaluation, the interim manager, Jorge Cotto P?rez, had no experience, knowledge, or capability to sufficiently conduct a field evaluation. As a formality, two operators in San Juan, Tropigas and Liquilux, were selected and visited. At both locations it was validated that the Program is/was not capable of performing an inspection. There are no points awarded for Part E. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 0 Evaluator Notes: The PR Program experienced personnel changes in June 2021. At the time of this evaluation, the interim manager, Jorge Cotto P?rez, had no experience, knowledge, or capability to sufficiently or conduct a field evaluation. As a formality, two operators in San Juan, Tropigas and Liquilux, were selected and visited. At both locations it was validated that the Program is/was not capable of performing an inspection. There are no points awarded for Part E. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 0 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PR Program experienced personnel changes in June 2021. At the time of this evaluation, the interim manager, Jorge Cotto P?rez, had no experience, knowledge, or capability to sufficiently conduct a field evaluation. As a formality, two DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 12#
PR NG Program Evaluation, 2020, page 13operators in San Juan, Tropigas and Liquilux, were selected and visited. At both locations it was validated that the Program is/was not capable of performing an inspection. There are no points awarded for Part E. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: Though this field evaluation was essentially a visit, not an inspection, there were no unsafe acts observed. PHMSA shared the importance of safety during field work, and emphasized that safety should never be compromised for the sake of an inspection. 7 General Comments: Info Only = No Points Evaluator Notes: No points awarded for Part E. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 15 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 13#
PR NG Program Evaluation, 2020, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Program was unable to provide any evidence/documentation that this requirement was covered for CY 2020. 2 0 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Puerto Rico recorded no excavation damages on regulated operators in CY 2020, therefore, full credit awarded. PR only has one operator that submits a GDAR, San Juan Gas, OPID 18116. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Puerto Rico recorded no excavation damages on regulated operators in CY 2020, therefore, full credit awarded. PR only has one operator that submits a GDAR, San Juan Gas, OPID 18116. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 14#
PR NG Program Evaluation, 2020, page 15Puerto Rico recorded no excavation damages on regulated operators in CY 2020, therefore, full credit awarded. PR only has one operator that submits a GDAR, San Juan Gas, OPID 18116. 5 General Comments: Info Only = No Points Evaluator Notes: Two points deducted for Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 10 DUNS: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 15#
PR NG Program Evaluation, 2020, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: N/A Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: N/A 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: N/A Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: N/A Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: N/A Info Only Info Only 6 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: 180536567 2020 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 16#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.