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PHMSA va2011hlprogramevaluation
2011 VA HL Program Evaluation - va2011hlprogramevaluation (Virginia; Hazardous Liquid State Program Evaluation)
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VA HL Program Evaluation, 2011, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 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 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 1#
VA HL Program Evaluation, 2011, page 22011 Hazardous Liquid State Program Evaluation -- CY 2011 Hazardous Liquid State Agency: Virginia Rating: Agency Status: Date of Visit: 05/21/2012 - 05/24/2012 Agency Representative: Massoud Tahamtani, Director, Utility and Railroad Safety Jim Hotinger, Pipeline Safety Program Manager PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Mark C. Christie, Chairman Agency: Virginia State Corporation Commission Address: Tyler Building, P.O. Box 1197 City/State/Zip: Richmond, Virginia 232218 60105(a): Yes 60106(a): Yes 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 2011 (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 9 9 B Program Inspection Procedures 15 15 C Program Performance 42 42 D Compliance Activities 14 14 E Accident Investigations 5 5 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (if applicable) 3 3 I 60106 Agreement State (if applicable) 0 0 TOTALS 108 108 State Rating................................................................................................................................................... 100.0 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 2#
VA HL Program Evaluation, 2011, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues, all information on 2011 Progress Report is complete and accurate. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspection days are documented accurately. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Operators and Operator Inspection Units are documented accurately. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable hazardous liquid accidents under the VA SCC jurisdiction. 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. None found in CY 2011. 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes - Inspection reports kept electronictally and printed in hard copy. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 VA SCC rules contain automatic adoption language for adopting federal regulations. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 3#
VA HL Program Evaluation, 2011, page 4Evaluator Notes: Yes. Virginia only has 2 jurisdictional intrastate hazardous liquid pipelines and performs inspections of 3 interstate hazardous liquid lines for PHMSA. All necessary inspections were completed, information input into the various PHMSA databases, and inspection data submitted in a timely manner to PHMSA. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 4#
VA HL Program Evaluation, 2011, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Listed in the procedures manual to inspect all jurisdictional lines annually and conduct reviews of all records and any construction and facilities as needed. For Interstate HL inspections, will follow inspecton plan set by Eastern Region. 2 IMP Inspections (B1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Listed in procedures to conduct inspections as necessary to include pig digs, peg rund, etc. 1 1 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: inspection form. 1 1 Yes. In procedures to be included with the standard inspection while conducting field inspections. Reviewed completed 2011 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In procedures to be included with the standard inspection while conducting field inspections. Reviewed completed 2011 inspection form. Also, VA SCC has Damage Prevention Section. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: attendance list. Operator training is conducted at seminars and contractor meetings. Reviewed seminar attendance list and contractor training 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In procedures to be included with the standard inspection while conducting field inspections. 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Appendix 6 of the procedures. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 5#
VA HL Program Evaluation, 2011, page 6e. 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: Yes. Virginia only has 2 jurisdictional intrastate hazardous liquid pipelines operating less than 12 miles of pipeline in total. All records are reviewed annually. Any construction or IMP examinations or repairs are also reviewed. The interstate pipeline inspection plan is developed by PHMSA with Virginia's input. 9 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 6#
VA HL Program Evaluation, 2011, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 74.83 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.61 = 134.20 Ratio: A / B 74.83 / 134.20 = 0.56 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. Total Inspection person-days to total person days was acceptable. 5 5 2 Has each inspector and program fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: Yes. One inspector has a extention of time wavier to complete one hazardous liquid course. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Jim Hotinger, Program Manager, has extensive knowledge of the state's safety rules, state enforcement procedures and the working relationship of NAPSR and PHMSA as well as serving on several NAPSR/PHMSA committees. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Letter dated July 15, 2011 was sent to Chair, Jagdmann and response letter dated August 26, 2011 was sent to Zach Barrett, PHMSA Director, State Programs. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: Yes. Hosted TQ seminar in October 2011. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. SCC conducts inspections on all operators throughout the year. Inspections were conducted according to written procedures. DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 7#
VA HL Program Evaluation, 2011, page 87 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. the VA SCC used the USDOT inspection forms. These inspection forms are completed in the field and uploaded into the PIPES database. All inspections can be reviewed on the PIPES database. 8 Did the state review operator procedures for determining areas of active corrosion on liquid lines in sufficient detail? (NOTE: PHMSA representative to describe state criteria for determining areas of active corrosion) (B7) Yes = 1 No = 0 Evaluator Notes: Yes. Reviewed the inspection report and have a written copy of report. 1 1 9 Did the state adequately review for compliance operator procedures for abandoning pipeline facilities and analyzing pipeline accidents to determine their causes? (NOTE: PHMSA representative to describe state criteria for determining compliance with abandoning pipeline facilities and analyzing pipeline accidents to determine their causes) (B8) Yes = 1 No = 0 Evaluator Notes: 1 1 10 Is the state aware of environmentally sensitive areas traversed by or adjacent to hazardous liquid pipelines? (reference Part 195, review of NPMS) (B9) Yes = 1 No = 0 Evaluator Notes: Yes. Checked during IMP inspections - conducted in 2011. 1 1 11 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)? (B10,E5) Yes = 1 No = 0 Evaluator Notes: 1 1 Virginia monitors all failure investigations and leak repairs of each operator to ensure accuracy of data collection. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G5-8,G15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia only has 2 jurisdictional intrastate hazardous liquid pipelines operating less than 12 miles of pipeline in total. Any issues noted are addressed. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G9-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia uploaded 1 IMP inspection in 2011 for 1 of its 2 operators. The other operator's IMP plan will be reviewed again in 2012 and the information uploaded at the time the inspection is complete. Reviewed SMART database prior to evaluation - data uploaded. 14 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? (G13) 1 1 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 8#
VA HL Program Evaluation, 2011, page 9Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, for both the interstate and intrastate companies. In addition, Virginia monitors new construction and verifies that the operators provide information on any new or replacement transmission pipelines constructed as soon as it is available. This is the first question on federal inspection form - Form 3 - Hazardous Liquid Inspection form. 15 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 16 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia's inspectors review the OQ certifications for each inspection involving a covered task. The OQ modules are also reviewed for adequacy. 17 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 195.452 Appendix C (C8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Interstate Pipeline Companies plans and remedial actions are reviewed during ILI tool runs and subsequent anomaly digs and captured on PHMSA form 19. Colonial and Plantation both had Integrity digs in 2011. For the Intrastate hazardous liquid companies, NuStar Energy was inspected by Staff in 2011. The Integrity Management Inspection Protocols were used and put in the Liquid Integrity Management Data Base, scheduled inspection visit #979 filed January 26, 2011. 18 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 195.440 (I13-16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia reviewed both of the intrastate operators' processes. 2 2 19 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). (G19-20) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Virginia's enforcement cases are available through its website, by mail and/or telephone request. Virginia's website contains both pipeline safety and damage prevention information and links. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRCs in 2011. 1 NA DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 9#
VA HL Program Evaluation, 2011, page 1021 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Virginia responded to surveys and information requests from NAPSR or PHMSA as necessary. 1 1 22 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 42 Total possible points for this section: 42 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 10#
VA HL Program Evaluation, 2011, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: Yes. In Appendix 6 of the written pipeline safety 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 (B11,B18,B19) 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 Evaluator Notes: Yes. NuStar company official Todd Denton, Sr. VP of operation was sent the notice of noncompliance. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes. Procedure for "show cause" is in written procedures. 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) (B27) Yes = 2 No = 0 Evaluator Notes: Yes. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: Issued 1 civil penalty and collected $9500 in 2011. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 14 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 11#
VA HL Program Evaluation, 2011, page 12PART E - Accident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: The Pipeline Safety Section has a 24 hour number for operator to call incase of an accident. The call is forwarded to the inspector on call. 2 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The Pipeline Safety Section gets information from the operators. All explosions, fire, fatality aand Nation Response Center reports require onsite visit. 3 Were all accidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) 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: No liquid accident report in 2011. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: NA. 1 NA 5 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Talked to Byron Coy, Director, PHMSA Eastern Region and he said all communication on pipeline safety with the VA SCC went smooth for CY 20011. 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: When accidents occur, Virginia shares its findings at NAPSR meetings, pipeline safety conferences, etc. In addition, in an effort to mitigate the possibility of future incidents/accidents, Virginia also shares leak data trends, including damage prevention data, with its operators, NAPSR, and PHMSA. 7 General Comments: DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Info Only Info Only Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 12#
VA HL Program Evaluation, 2011, page 13Info Only = No Points Evaluator Notes: DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Total points scored for this section: 5 Total possible points for this section: 5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 13#
VA HL Program Evaluation, 2011, page 14PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia reviewed the procedures when they were initially developed, any revisions to them, and monitors compliance with them in the field. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia reviewed the procedures when they were initially developed, any revisions to them, and monitors compliance with them in the field. The effectiveness of damage prevention public education is continually monitored and revised annually as needed by each operator. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia adopts Best Practices as needed. Virginia provides information to its stakeholders on the various best practices, including marking, hand digging, and directional drilling. 4 Has the agency or another organization within the state collected data and evaluated 2 2 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Virginia monitors this data on a monthly basis. In addition, Virginia has developed a risk model for damage prevention that evaluates all notices of excavation received in real time to identify potential "high-risk" of damage areas. Virginia may then send its inspectors to these areas or notify operators of them to allow oversight of these excavations as needed. 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 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 14#
VA HL Program Evaluation, 2011, page 15PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: NuStar Energy LLC Name of State Inspector(s) Observed: Jim Fisher Location of Inspection: Virginia Beach Date of Inspection: 5/23/2012 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? (F2) 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Used inspection federal form. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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) (F5) Yes = 1 No = 0 Evaluator Notes: Yes. Reviewed maps in office. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation 2 2 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 15#
VA HL Program Evaluation, 2011, page 16Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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) (F9) 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) (F10) Yes = 1 No = 0 Evaluator Notes: Yes. 195.519(c) - test leads not connected to pipeline. 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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 E. Vault Maintenance F. Welding Info Only Info Only DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 16#
VA HL Program Evaluation, 2011, page 17G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 17#
VA HL Program Evaluation, 2011, page 18PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Viewed VA SCC and PHMSA ER correspondence on 2011 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? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Have copy of information sent to PHMSA. 1 1 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 015946759 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 18#
VA HL Program Evaluation, 2011, page 19PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) 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? (B22) 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.) (B23) 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? (B24) 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? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) 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 2011 Hazardous Liquid State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 19#
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