# 2016 VA HL Program Evaluation - va-2016-hazardous-liquid-program-evaluation (Virginia; Hazardous Liquid State Program Evaluation)

- **operation:** document
- **citation:** PHMSA va-2016-hazardous-liquid-program-evaluation
- **title:** 2016 VA HL Program Evaluation - va-2016-hazardous-liquid-program-evaluation (Virginia; Hazardous Liquid State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-01-01
- **effective on:** Not available
- **summary:** 2016 PHMSA hazardous liquid program evaluation for Virginia.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/2976/va-2016-hazardous-liquid-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2016 Hazardous Liquid State Program Evaluation for VIRGINIA STATE CORPORATION COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 1

2016 Hazardous Liquid State Program Evaluation -- CY 2016 Hazardous Liquid State Agency: Virginia Rating: Agency Status: Date of Visit: 06/13/2017 - 06/15/2017 Agency Representative: Massoud Tahamtani PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Judith Williams Jagdmann, Chairman Agency: Virginia State Corporation Commission Address: Tyler Building, 1300 E. Main Street City/State/Zip: Richmond, Virginia 23219 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2016 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 39 39 D Compliance Activities 15 15 E Accident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (if applicable) 6 6 I 60106 Agreement State (if applicable) 0 0 TOTALS 112 112 State Rating................................................................................................................................................... 100.0 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data and it appears correct. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data and it appears correct. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data and it appears correct. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed data and it appears correct. 2 NRC, PPL River Road in Goochland County, PPL Lansdowne Rd. Fredericksburg. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data and it appears correct. Three Interstate Liquid PV's sent to PHMSA ER and SR. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Inspection files are kept on the Commission server in the PIPES program. Also, many files kept in binders. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data and it appears correct. 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Virginia program states that it has automatic adoption of federal safety rules. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 3

Evaluator Notes: Reviewed data and it appears correct. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: For Standard Inspections Pre-Inspection Activities ? ? Section V, B2, Preparation for Inspection Inspection Activities- Section V, C, Types of Inspections, page 18-19, B3 pages 16 and 17 Post Inspection Activities ? Section V, B4, General Post Inspection record Guidelines, All types of inspections, and NOI/ NOPV-Compliance page 49. 2 IMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: For IMP Inspections Pre-Inspection Activities ? Section V, B3, General Inspection Guidelines Inspection Activities ? Sections VIII and X, page 32 Integrity Management Programs. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines, All types of inspections, and NOI/ NOPV-Compliance page 49. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: For OQ Inspections Pre-Inspection Activities ? Section V, B3, General Inspection Guidelines Inspection Activities ?Section V, G, pages 29-30 Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines, All types of inspections, and NOI/ NOPV-Compliance page 49. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: For Damage Prevention Pre-Inspection Activities - Section V, B3, General Inspection Guidelines, and Section VI (Pre-MURBI) page 30 Inspection Activities ? Section IV, pages 30 Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines, All types of inspections, and NOI/ NOPV-Compliance page 49. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 5

Evaluator Notes: Section VII, pages 32 Operator Training of the written procedures. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: For Construction Inspections Pre-Inspection Activities - Section V, B3, General Inspection Guidelines, and Section V, F, page 25 Inspection Activities ? Pages 25-29 Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines, and page 29, Conclusion of Inspection, and NOI/NOPV-Compliance page 49. 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic area, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Length of time since last inspection (Within five year interval) - 10 year Inspection Plan, page 11 and appendix 4. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) ? Section V, pages 10-15. Type of activity being undertaken by operators (i.e. construction) ? Facility, Form Inspections and PHMSA Annual Agreement Locations of operators inspection units being inspected - (HCA's, Geographic area, Population Density, etc.) ? Inspection units binder 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) ? Section V, pages 10-15 and the Risk Model Are inspection units broken down appropriately? ? Inspection Unit Binder, reviewed annually 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 67.40 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.56 = 123.20 Ratio: A / B 67.40 / 123.20 = 0.55 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: No issue. .55 ratio is greater than the needed .38 ratio. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Reviewed VA SCC staff on TQ SABA website. Only have 2 staff members qualified to conduct any type of hazardous liquid inspections. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Massoud Tahamtani is very knowledgeable of both state and federal pipeline safety programs. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No response requested for hazardous liquid program from CY2015 evaluation. 2 NA 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes. The VA SCC conducted TQ seminars in October 2014 and October 2016. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. No issues found in reviewing the Inspection Report binders. DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation 5 5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 7

7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: VA SCC uses the federal IA form along with Federal forms 3,13, and 15. 2 2 8 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 195.402(c)(5)? Yes = 1 No = 0 Evaluator Notes: Yes. The PPL Goochland County Leak. 1 1 9 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Annual Reports are entered into the PIPES database and semi-annually all leak data is reviewed for trends. Use information for risk ranking. 10 Did state input all applicable OQ, LIMP inspection results into federal database in a 2 2 timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: In OQ protocol 9 binder and LIMP inspections are inspected per 10 year inspection plan and are not due until 2017 for Intrastate Operators, Interstate Operators are done by IA System Inspections with the appropriate Region. Last conducted in 2013, none conducted in 2016. Within scheduling period. 11 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No changes from original submissions but are checked during Standard/System Inspections. 1 1 12 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Comprehensive Drug and Alcohol inspections have been scheduled in 2017 per inspection plan. 2 2 13 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ is verified during each inspection for contractors and operator personnel see Certification Qualification Records Binder, and PHMSA form 15's. DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 8

14 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All Operator plans are reviewed and uploaded into IM Database for Intrastate operators per 10 year inspection plan, last done 2013, due in 2017. Also IMP field verification is done for both Interstate and Intrastate operators. 15 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should have been completed by December 2013. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 195.440 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Form 21's done in 2013 due in 2017. 2 2 16 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State Website, Executive meetings, emails to operators, Pipeline Safety Conference Agenda. 1 1 17 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRC's in 2016. 1 NA 18 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes 1 1 19 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: None issued. 1 NA 20 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Yes. 1 1 21 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 Yes = 2 2 2 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 9

a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Website reviewed annually, and annual report data is entered into PIPES and used in conjunction with the risk model to identify negative trends. 22 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: Discussed the SIDC with program manager. Info Only Info Only 23 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Info Only Info Only Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: No operators in State have the means to execute flow reversals. 24 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 39 Total possible points for this section: 39 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 10

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Appendix 6, page 49 of the written procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: No closed cases to review for 2016 except three interstate violations. These violations were sent to PHMSA Regions for enforcement. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, 3 Interstate PV's for Hazardous Liquid operators sent to PHMSA. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Compliance actions enforced by PHMSA. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Evaluator Notes: Yes. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State has fined gas operators - in 2016 a total of $945,000. 1 1 7 General Comments: DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Info Only Info Only Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 11

Info Only = No Points Evaluator Notes: DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Total points scored for this section: 15 Total possible points for this section: 15 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 12

PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: State O&M Incident Investigation Procedures, Appendix 7. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Inspector on call rotation binder, PIPES incident report binder, and Section IV for MOU. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 2 and 3, pages 64 and 65 of written procedures. 1 1 4 Were all accidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Evaluator Notes: Reviewed Plantation Pipeline Goochland County Leak. All appeared correct. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: No PV's for incidents were cited in 2016. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator accident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All incidents were investigated and final reports if sent were reviewed by State and PHMSA. 1 1 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 13

7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Executive Meetings, Pipeline Safety Conference, Safety Stand down. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 14

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This question is asked every year as an ademdum to inspection form. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 When there is an investigation of damages and every pipeline safety inspection Miss Utility Tickets are checked. 3 Did the state encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. VA SCC is a leader throughout the country in damage prevention. 2 2 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: VA SCC does this. The damage rate was down to 1.26 damages per 1000 locate request. 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 15

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Plantation Pipeline Company (Interstate Operator) Name of State Inspector(s) Observed: Jim Fisher and Steve Moore Location of Inspection: South Central Virginia Date of Inspection: June 15, 2017 Name of PHMSA Representative: Jim Anderson Evaluator Notes: Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Uses federal IA Form. Completes inspection form on computer during inspection, also takes notes while away from computer and then completes form. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Conducted CP readings and block valve servicing. 2 2 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 16

7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 8 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) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: None found during inspection. 1 NA 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Info Only Info Only Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 17

E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 18

PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: As Interstate Agent VA SCC uses the federal IA form for inspections. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Used the Eastern Region/Southern Region Inspection Plan. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: 1 1 PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Probable violations for Plantation Pipeline and Colonial Pipeline were sent to PHMSA for enforcement. 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: None in 2016. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes. Yes = 1 No = 0 Needs Improvement = .5 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. CPL and PPL Violation packets contained needed documentation for PHMSA. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 19

PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 015946759 2016 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 20
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