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PHMSA pr-2023-gas-program-evaluation
2023 PR NG Program Evaluation - pr-2023-gas-program-evaluation (Puerto Rico; Natural Gas State Program Evaluation)
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PR NG Program Evaluation, 2023, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2023 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 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 1#
PR NG Program Evaluation, 2023, page 22023 Gas State Program Evaluation -- CY 2023 Gas State Agency: Puerto Rico Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 06/10/2024 - 06/14/2024 Agency Representative: Zuleika Ruiz Hernandez, Pipeline Safety Program Manager PHMSA Representative: Agustin Lopez, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Eileen M. Velez Vega, PE, Secretary Agency: Department of Transportation and Public Works Address: Government Center, Roberto Sanchez Vilella, PO Box 41269 City/State/Zip: San Juan, PR 00940-1269 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 2023 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 45 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 TOTALS 100 95 State Rating................................................................................................................................................... 95.0 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 2#
PR NG Program Evaluation, 2023, 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: Reviewed state files and PDM to verify data submitted on Progress Report. PR contiues to verify new systems to assure al jurisdictional facilities are being inspected. Reviewed Blackboard to verity inspector qualifications. PRDTOP is working on getting the civil penalty amounts to an acceptable level to meet federal amounts. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 3#
PR NG Program Evaluation, 2023, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. 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: Reviewed Procedures to verify inspection , pre-inspection and post-inspection activities. Pages 10-14 address these activites which provide guidance to isnpetors. Each type of inspection is identified. There are no jurisdicational LNG facilities in PR. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: Reviewed Procedures and pages 16-18 address the prioritization and time frames for inspections. Each inspection will be conducted every year. Integrity Management Program, Drug and Alcohol and CRM inspections are conducted every 5 years. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Pages 19-22 of procedures provide details for issuing compliance actions and steps taken to resolve probable violations. 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 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. Evaluator Notes: Have incident investigation but need to improve on mechanism on how notifications are received. Discussed with PM and procedures will be amended to include better details. DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 4#
PR NG Program Evaluation, 2023, page 55 General Comments: Info Only = No Points Evaluator Notes: The PRDTOP is mainly complying with Part B of the evaluation. DUNS: 180536567 2023 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 Puerto Rico PR Department of Transp. and Public Works, Page: 5#
PR NG Program Evaluation, 2023, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required 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) 5 5 Evaluator Notes: Verified that ispectors are qualified to conduct each type of inspection. Ms. Zuleika Ruiz Hernandez has not completed the OQ course nor the required IMP courses to lead both types of inspections. Prioritization needs to be given for her to complete these courses in order to conduct inspections and assure operators are in compliance with the regulations. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes , Zuleika Ruiz Hernandez has been PM since 2021 and is knwoledgeable of the pipeline safety program and regulations. SHe has completed all TQ core courses. 3 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Concern: C.1- Zuleika Ruiz Hernandez has not completed the OQ course or the IMP courses required to lead both types of inspections. Prioritization must be given to complete these courses in order to be able to conduct the inspections to assure operators are in compliance with the applicable regulations. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 6#
PR NG Program Evaluation, 2023, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 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) 5 3 Evaluator Notes: In reviewing inspection reports, it was identified that Operator Qualification and Integrity Managment Program inspections have not been conducted or records of past inspections could not be found. OQ and IMP inspections must be conducted at intervals not exceeding 5 years or in accordance with the intervals established in the procedures. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 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 forms covered all applicable reguations. Reviewed randomly selected inspection reports to verify completion and to assure adequate reviews were completed. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 1 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 Evaluator Notes: Ms. Zuleika Ruiz Hernandez conducts inspections but has not completed the OQ course which is required to lead an OQ inspection. Her attendance to the OQ course should be a prioritization in order to be qualified to perform OQ Protocol 9 inspections. 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 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? 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? 2 0 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 7#
PR NG Program Evaluation, 2023, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: In revieweing inspection reports, there was no records of IMP inspections being performed of LPG and transmission operators. A prioritization should be made to conduct IMP inspections as soon as Ms. Zuleika Ruiz Henandez completes all required courses needed to lead IMP inspections and to conduct yearly IMP reviews with the large operators. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator 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? 2 2 Evaluator Notes: There is no cast iron piping in PR. NTSB recommendations are reviewed with operators during inspections and seminars. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, discuss applicable bulletins with operators during inspections, seminars and letters. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. 10 10 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 8#
PR NG Program Evaluation, 2023, page 9i. 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: Yes, compliance procedures are being followed by the DOTP. Probable violaitons are issued and resolved per the procedures. There are old inspections which had open probable violations but multiple inspections have been conducted on those operators to assure compliance with regulations. 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? Evaluator Notes: No reportable incidents in 2023. Procedures are in place to assure incident investigations are conducted. 10 10 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, response was received. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Last seminar was on June 26-27, 2023. 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: NPMS is addressed during inpsections on inpsection forms. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes DOTP website has pipeline safety information. 1 1 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 9#
PR NG Program Evaluation, 2023, page 1013 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRCR in 2023. 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? Evaluator Notes: Yes, DOTP is responsive to surveys and whenever they receive tasks in WMS. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No waivers have been issued. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, files are well organized and accissible during evaluations. 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 3 3 Evaluator Notes: Discussed with PM and do not foresee any issues. DOTP is working on hiring another inspector so may have issue in meeting the 85 day requirement per inspector. 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: Discussed metrics and there are no issues or negative trends. 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: Most opeators are too small to utilize PSMS. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: Point Deduction: Info Only Info Only D.1- In reviewing inspection reports, it was identified that Operator Qualification and Integrity Managment Program DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 10#
PR NG Program Evaluation, 2023, page 11inspections have not been conducted or records of past inspections could not be found. OQ and IMP inspections must be conducted at intervals not exceeding 5 years or in accordance with the intervals established in the procedures. There was a 2 point deduction for this issue. D.3- Ms. Zuleika Ruiz Hernandez conducts inspections but has not completed the OQ course which is required to lead an OQ inspection. Her attendance to the OQ course should be a prioritization in order to be qualified to perform OQ Protocol 9 inspections. There was a 1 point deduction for this issue. D.4- In revieweing inpsection reports, there was no records of IMP inspections being performed of operators. A prioritization should be made to conduct IMP inspections as soon as Ms. Zuleika Ruiz Henandez completes all required courses needed to lead IMP inspections and to conduct IMP reviews. There was a 1 point deduction for this issue. Total points scored for this section: 45 Total possible points for this section: 50 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 11#
PR NG Program Evaluation, 2023, 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 Evaluator Notes: Empire Gas Zuleika Ruiz Hernandez- Lead inspector Rio Grande, PR June 12, 2024 Agustin Lopez- Evaluator a. Standard inspection conducted on Empire Gas The Outlets at Route 66 unit b. Last inspected on 10/16/2023 c. Yes pipeline representative was present. d. Zuleika is the only inpsector. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, inspector used a form at a guide and to document inspection results. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: Yes, the inspector reivewed procedures, records and conducted a field inspection of the facilites. 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 2 Evaluator Notes: in her inspection. Yes, Ms. Zuleika Ruiz Hernandez was knowledgeable of the pipeline safety program and regulations. She was very thorough 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, she conducted an exit interview at the end of the inspection. She requested further documentation and had issue with broken fence door. She adddressed the need to have it repaired. DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 12#
PR NG Program Evaluation, 2023, page 136 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: Yes, the inspection was conducted in a safe, positive and constructive manner. Info Only Info Only 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Ms. Zuleika Ruiz Hernandez condcuted a very thorough and detailed inspection. She is very knowledgeable of the LPG system and how it works. She is a great asset to the PRDTOP. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 13#
PR NG Program Evaluation, 2023, 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 2 2 Evaluator Notes: Yes, review annual reports for accuracy and trends. Have only had 1 excavation damage in 2023 and 2022, none in previos years. San Juan Gas is the only operator required to submit annual report. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, PR has a very impressive damage prevention program. Investigators investigate one-call tickets to verify accurate locates, timely locates, digs without tickets. Issue penalties for not making one-call ticket and for non locates. 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: San Juan Gas is only operator required to submit an Annual Report. They had one excavation damage that was investigated by pipeline safety along with damage prevention staff. Thorough investigation was performed and found that no one call was made by excavator. 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 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 14#
PR NG Program Evaluation, 2023, page 15Evaluator Notes: Yes one call ticket data is gathered and analyzied for trends. Very minimal damages in the last several years. 5 General Comments: Info Only = No Points Evaluator Notes: The PRDTOP is mainly complying with Part F of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 180536567 2023 Gas State Program Evaluation Puerto Rico PR Department of Transp. and Public Works, Page: 15#
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