WEBVTT 00:00:05.240 --> 00:00:09.779 Okay it's now 10:31, so I'm gonna go ahead and get 00:00:09.779 --> 00:00:12.429 started. Good morning everyone. Thank you for your 00:00:12.429 --> 00:00:16.550 time today, for being here. My name is Pete Longoria. 00:00:17.539 --> 00:00:21.250 I am a pipeline safety inspector out of the Corpus 00:00:21.250 --> 00:00:24.219 Christi region. I've been working with the Commission 00:00:24.230 --> 00:00:28.339 for three years now and currently I am on the master 00:00:28.339 --> 00:00:31.839 meter plan of correction review team and also I am 00:00:31.839 --> 00:00:34.429 the specialist team lead over public awareness and 00:00:34.429 --> 00:00:37.149 damage prevention. So today I'm going to be giving 00:00:37.149 --> 00:00:42.340 a presentation on making a plan of correction. 00:00:42.340 --> 00:00:45.509 A reminder that the PowerPoint presentation is available 00:00:45.509 --> 00:00:49.560 for download at the following link. Do not worry about 00:00:49.560 --> 00:00:51.780 having to write all this down or taking a screenshot 00:00:51.780 --> 00:00:54.890 of it. If you navigate over to the Q and A section 00:00:54.899 --> 00:00:59.619 of the presentation, the question should have already 00:00:59.619 --> 00:01:03.000 been posted asking for a link to the presentation and 00:01:03.000 --> 00:01:05.290 there should be an answer with the link provided. You 00:01:05.290 --> 00:01:08.519 can use that to navigate over and download for your 00:01:08.519 --> 00:01:15.090 use. So just a quick request. If you could please, 00:01:15.090 --> 00:01:19.450 at the end of the presentation, there is a link to a 00:01:19.599 --> 00:01:22.870 evaluation, this will give us feedback that's essential 00:01:22.870 --> 00:01:26.560 for us so that we can further educate you guys as operators, 00:01:26.939 --> 00:01:30.099 provide your feedback on how I did as a presenter, 00:01:30.120 --> 00:01:32.939 the content of my presentation, the length of the presentation, 00:01:32.950 --> 00:01:35.890 anything that you feel can be improved on, we would 00:01:35.890 --> 00:01:37.760 greatly appreciate if you would give us our feedback, 00:01:38.140 --> 00:01:41.560 and again that will be posted at the end of the presentation. 00:01:42.439 --> 00:01:45.599 Also the chat has been disabled for this presentation. 00:01:45.599 --> 00:01:48.939 So if you have any questions use the question and answer 00:01:48.939 --> 00:01:53.079 section of the presentation. I do have a moderator 00:01:53.079 --> 00:01:56.390 who will be a reviewing your questions as they come 00:01:56.390 --> 00:02:00.650 in and giving answers. If there are any questions that 00:02:01.540 --> 00:02:04.650 are not answered during the presentation we will 00:02:04.650 --> 00:02:07.359 take some time at the end to go ahead and answer those. 00:02:08.139 --> 00:02:12.300 So we'll go ahead and get started. Quick outline of 00:02:12.300 --> 00:02:14.539 everything that will be covered today. So I'm going 00:02:14.539 --> 00:02:17.360 to start off by defining what is a plan of correction. 00:02:18.539 --> 00:02:21.780 Next I'm going to go over submitting a response so 00:02:21.780 --> 00:02:24.879 how you as an operator go about submitting a response 00:02:24.889 --> 00:02:29.139 to an official letter from the Railroad Commission. Next 00:02:29.139 --> 00:02:32.090 we're going to cover what our expectations are for 00:02:32.090 --> 00:02:35.069 these responses that we received from you guys. We're 00:02:35.069 --> 00:02:38.219 going to define or give examples of supporting documentation 00:02:38.219 --> 00:02:41.849 which I will cover during the response expectation 00:02:41.849 --> 00:02:45.069 section. We're going to go over the difference between 00:02:45.080 --> 00:02:49.090 an approved POC and a complete POC. We're going to 00:02:49.090 --> 00:02:54.000 cover what exactly happens or what causes a plan of 00:02:54.000 --> 00:02:58.180 correction to become rejected. What the delinquent 00:02:58.180 --> 00:03:01.280 status of a plan of correction is, how to avoid delinquent 00:03:01.280 --> 00:03:06.639 status, and then my contact information. 00:03:06.639 --> 00:03:09.780 So we'll start off by, what is a plan of correction? 00:03:09.789 --> 00:03:13.080 So a plan of correction is you the operator's response 00:03:13.080 --> 00:03:17.030 to alleged violations. So as you all, I'm sure, know, we 00:03:17.030 --> 00:03:21.129 conduct safety evaluations that consists of various 00:03:21.129 --> 00:03:26.069 things. So whether it's a standard comprehensive 00:03:26.080 --> 00:03:29.810 gathering gas transmission, hazardous liquid or a specialist 00:03:29.810 --> 00:03:34.270 program that we're inspecting, during some inspections 00:03:34.270 --> 00:03:37.159 we do have findings. So whenever we have these findings 00:03:37.539 --> 00:03:39.680 you get an official letter from the Railroad Commission 00:03:39.680 --> 00:03:44.919 with each finding cited. So the plan of correction 00:03:44.930 --> 00:03:49.530 is your response to these deficiencies that we've identified 00:03:49.530 --> 00:03:53.939 during an inspection. So when you respond it's either 00:03:53.949 --> 00:03:56.569 your corrective action, wo what it is that you as an 00:03:56.569 --> 00:03:59.689 operator are doing, what you plan to do, and how you're 00:03:59.689 --> 00:04:02.650 going to correct any and all deficiencies identified. 00:04:03.240 --> 00:04:08.330 You can also request an extension. So if you receive 00:04:08.330 --> 00:04:11.400 the letter and you need additional time to correct 00:04:11.400 --> 00:04:13.949 the deficiency. You are also within your rights, and 00:04:13.949 --> 00:04:16.529 I'll cover exactly timelines and things like that in 00:04:16.529 --> 00:04:19.939 the next couple of slides. And also additionally it 00:04:19.939 --> 00:04:23.139 is your opportunity to contest any violations. If you 00:04:23.139 --> 00:04:27.870 believe that they were incorrectly cited, you can provide 00:04:27.870 --> 00:04:30.040 documentation and we'll also cover that later in the 00:04:30.040 --> 00:04:33.139 presentation. 00:04:33.139 --> 00:04:36.589 So whenever a response is submitted, please submit 00:04:36.600 --> 00:04:41.060 responses to either safety@RRC.Texas.gov 00:04:41.439 --> 00:04:45.399 or the address below which is 1701 North Congress Avenue 00:04:45.399 --> 00:04:50.120 PO box 12967. And when submitting these responses 00:04:50.120 --> 00:04:53.040 please make sure that you include the inspection package 00:04:53.040 --> 00:04:57.930 number. I know that I personally have received responses 00:04:57.930 --> 00:05:00.949 to plan of corrections or sorry responses to alleged 00:05:00.949 --> 00:05:05.449 violation of letters directly from the operator. They're 00:05:05.449 --> 00:05:08.300 actually supposed to go to safety@RRC if you're emailing 00:05:08.300 --> 00:05:11.680 them. So please again keep that in mind. The inspector 00:05:11.689 --> 00:05:15.139 who conducted the inspection won't always be the inspector 00:05:15.139 --> 00:05:18.990 who is reviewing your work or your response. So please 00:05:18.990 --> 00:05:20.850 keep that in mind and just make sure that you follow 00:05:20.850 --> 00:05:24.449 the process of emailing or mailing to the correct location. 00:05:27.439 --> 00:05:32.699 So what is it that we expect in a POC response? So 00:05:32.699 --> 00:05:36.250 we expect a detailed plan of action to be taken along 00:05:36.250 --> 00:05:41.600 with an estimated completion date. So from both experience 00:05:41.600 --> 00:05:44.360 reviewing master meter plan of corrections and public 00:05:44.360 --> 00:05:48.009 awareness damage prevention plan of corrections. When 00:05:48.009 --> 00:05:51.089 submitting a response, please make sure that you avoid 00:05:51.089 --> 00:05:54.259 giving a general response. And what I mean by a general 00:05:54.259 --> 00:05:58.490 response is there are times where we receive a letter 00:05:58.779 --> 00:06:02.639 and the letter indicates all deficiencies have been 00:06:02.639 --> 00:06:06.439 corrected and there's not much elaboration or under 00:06:06.439 --> 00:06:10.980 each alleged violation, there's a note stating 'has 00:06:10.980 --> 00:06:15.160 been corrected' and there's a date. So while the date 00:06:15.170 --> 00:06:19.949 is good, it's not sufficient enough to be an acceptable 00:06:20.339 --> 00:06:22.759 plan of correction. So again as I mentioned earlier 00:06:23.240 --> 00:06:25.839 the inspector who conducts the inspection is not always 00:06:25.839 --> 00:06:31.050 the inspector reviewing your responses. So the best 00:06:31.050 --> 00:06:34.259 course of action for you guys is to submit as much 00:06:34.639 --> 00:06:38.350 detail as you can in your plan, use supporting documentation, 00:06:38.350 --> 00:06:41.339 which again I'll cover exactly what that is later in 00:06:41.339 --> 00:06:44.790 the presentation, and just take advantage and tell us 00:06:44.790 --> 00:06:48.750 a story, tell us what it is that was identified, 00:06:48.759 --> 00:06:52.300 what steps you took to correct it, and again, any and 00:06:52.300 --> 00:06:55.500 all supporting documentation that you can give us whether 00:06:55.500 --> 00:07:00.220 it's pictures, work orders, things like that. And 00:07:00.220 --> 00:07:03.240 again I'll go into more detail 00:07:03.240 --> 00:07:05.850 on exactly what it is that we're looking for when it 00:07:05.850 --> 00:07:08.899 comes to supporting documentation. You can also request 00:07:08.899 --> 00:07:11.560 an extension. So again as I mentioned previously, if 00:07:11.560 --> 00:07:14.759 you receive the letter and you're expecting a response 00:07:14.759 --> 00:07:17.160 of what it is that you're going to do to address these 00:07:17.540 --> 00:07:21.040 deficiencies identified. And let's say you have a month 00:07:21.040 --> 00:07:23.639 to respond, you're within your rights as an operator 00:07:23.639 --> 00:07:27.000 to say we would like to request an extension. This 00:07:27.000 --> 00:07:30.160 is what we plan on doing but we need an extension until 00:07:30.170 --> 00:07:33.879 x date to complete it. You can do that and each of 00:07:33.879 --> 00:07:36.980 these are handled on a case by case situation. So basically 00:07:36.980 --> 00:07:40.269 it depends on how serious the violation is. If you 00:07:40.269 --> 00:07:44.560 have something where for example a relief valve 00:07:44.629 --> 00:07:47.240 was not properly functioning. That's probably something 00:07:47.240 --> 00:07:52.170 that you can't request a six months extension to get 00:07:52.170 --> 00:07:53.829 that corrected. That's probably gonna be something 00:07:53.829 --> 00:07:57.139 that you've got to address quickly. If it's something 00:07:57.139 --> 00:08:02.449 for example a procedure and there's, you know, several 00:08:02.449 --> 00:08:05.839 different, I 00:08:05.839 --> 00:08:10.980 forget the word, several different references that 00:08:10.980 --> 00:08:14.740 you have to go through. So whether it's a 00:08:14.740 --> 00:08:17.779 1104 for welding or things like that that require a 00:08:17.779 --> 00:08:20.769 little bit more research or development on your end, 00:08:20.779 --> 00:08:24.939 you can request an extension for that also. 00:08:24.939 --> 00:08:27.639 So supporting documentation, as I previously mentioned 00:08:27.639 --> 00:08:31.220 pictures. So pictures are worth 1000 words. If you 00:08:31.220 --> 00:08:34.409 can provide pictures with GPS coordinates on them, 00:08:34.419 --> 00:08:37.419 that's even better. Again, the inspector reviewing 00:08:37.419 --> 00:08:39.659 it may not have been the inspector in the field. So 00:08:40.039 --> 00:08:44.159 if you had a low cathartic protection reading and you've 00:08:44.159 --> 00:08:48.259 corrected it, you provide a picture that shows now 00:08:48.269 --> 00:08:53.210 the pipe to soil reading is meeting your criteria, 00:08:53.220 --> 00:08:55.559 and you can provide GPS coordinates that goes a long 00:08:55.559 --> 00:08:59.220 way or if you can match it to the location somehow 00:08:59.220 --> 00:09:01.980 if there's a physical address, that goes a long way 00:09:01.980 --> 00:09:05.519 for us as POC reviewers to understand that yes this 00:09:05.519 --> 00:09:08.740 is the actual location that had a deficiency and it 00:09:08.740 --> 00:09:12.289 has been corrected. So completed work orders, for example, 00:09:12.289 --> 00:09:17.370 if there was again that low CPI read, if you can provide 00:09:17.370 --> 00:09:20.679 the picture along with the work order showing it was 00:09:20.679 --> 00:09:26.350 identified on September 7, 2020, and it was completed 00:09:26.350 --> 00:09:31.460 on October 1, 2020. That's great. So again tell 00:09:31.460 --> 00:09:34.940 a story how it is, what it is that you did to 00:09:34.940 --> 00:09:41.000 go about correcting. If you had a procedural violation, 00:09:41.000 --> 00:09:44.259 so your procedure was inadequate or it was missing, 00:09:44.940 --> 00:09:47.549 you do not have to provide us the entire ONM Manual 00:09:47.549 --> 00:09:50.679 OQ manual, public awareness, anything like that you 00:09:50.679 --> 00:09:54.360 can send us the section that was cited and you can 00:09:54.360 --> 00:09:56.690 highlight any changes that were made to the procedure. 00:09:56.690 --> 00:09:59.080 So if you already have an existing procedure, you can 00:09:59.080 --> 00:10:02.720 go ahead and highlight the changes, we as a POC reviewer 00:10:02.720 --> 00:10:05.710 can see that and say, okay, previously it was lacking 00:10:05.720 --> 00:10:09.480 X and now it has it. Okay they're good to go. 00:10:09.490 --> 00:10:12.289 If the procedure was missing, you can just send a copy 00:10:12.299 --> 00:10:15.090 of the new procedure and just highlight it if it's 00:10:15.100 --> 00:10:18.429 incorporated into a section that has other content 00:10:18.429 --> 00:10:21.340 on it, you can do that. 00:10:21.340 --> 00:10:24.080 So training attendance roster sometimes with master 00:10:24.080 --> 00:10:28.009 meters, we conduct inspections and nobody on the property 00:10:28.009 --> 00:10:32.659 is qualified. So whenever employees are qualified, 00:10:33.039 --> 00:10:35.360 you either go through a third party contractor or something 00:10:35.360 --> 00:10:39.279 like that to get employees qualified. So when submitting 00:10:39.279 --> 00:10:43.309 a response like that, you can include everybody who 00:10:43.309 --> 00:10:49.049 participated in the training and what day it was and 00:10:49.049 --> 00:10:51.549 any certificates that were received from said training 00:10:52.039 --> 00:10:54.700 and also if you could include the training material 00:10:54.700 --> 00:10:57.389 that was provided to you by again your third party 00:10:57.389 --> 00:11:00.169 contractor, whoever it is that qualified you and that 00:11:00.169 --> 00:11:03.370 will be, that will help us understand what it is, what 00:11:03.370 --> 00:11:08.639 steps you took to correct the deficiency. 00:11:08.639 --> 00:11:13.080 So the difference between a approved POC and a completed 00:11:13.080 --> 00:11:17.580 POC. So a plan of correction is approved when you provide 00:11:17.590 --> 00:11:21.529 clear corrective action with dates. So again going 00:11:21.529 --> 00:11:24.370 back to the example of a low cathartic protection reading, 00:11:24.379 --> 00:11:29.509 so you receive the letter, you respond saying we corrected 00:11:29.509 --> 00:11:34.629 by October 2020, you have your picture, you have your 00:11:34.629 --> 00:11:38.460 work order, everything is clear to us of when and how 00:11:39.440 --> 00:11:43.889 your POC will be approved. And at that point since 00:11:43.889 --> 00:11:48.350 the deficiency is corrected, it will also be complete. 00:11:48.840 --> 00:11:51.149 So basically it's once all corrective actions have 00:11:51.149 --> 00:11:54.750 been complete and all supporting documentation is submitted 00:11:54.750 --> 00:11:57.299 that is considered complete. Now when it's just approved, 00:11:57.299 --> 00:12:00.129 let's say it's the initial letter and you haven't had 00:12:00.129 --> 00:12:02.549 a chance to work on it. So you submit a response saying 00:12:03.340 --> 00:12:06.740 we plan to have this corrected by, let's say you received 00:12:06.740 --> 00:12:09.769 the letter in August and you say we plan to have this 00:12:09.769 --> 00:12:12.610 deficiency corrected by September. So what we will 00:12:12.610 --> 00:12:15.960 do if that is an adequate timeline we will say yes 00:12:16.340 --> 00:12:19.299 this is adequate, we will approve and then we will 00:12:19.299 --> 00:12:23.549 wait for an additional response from you saying or 00:12:23.549 --> 00:12:26.399 again demonstrating with your supporting documentation 00:12:26.409 --> 00:12:29.710 that everything has been corrected and at that point 00:12:29.720 --> 00:12:32.279 it would get moved to complete. And in both stages, 00:12:32.279 --> 00:12:36.860 so when the POC is approved you do get a letter and 00:12:37.539 --> 00:12:39.860 also once it's completed, you also get a letter saying 00:12:39.860 --> 00:12:44.440 that everything has been corrected. 00:12:44.440 --> 00:12:49.210 So what causes a rejection? So a plan of correction is 00:12:49.220 --> 00:12:52.610 rejected when there is inadequate or no documentation 00:12:52.610 --> 00:12:55.769 provided. So again like I said the general response 00:12:55.779 --> 00:12:58.750 of this has been corrected. That's going to result 00:12:58.750 --> 00:13:01.340 in a rejection 00:13:01.340 --> 00:13:04.830 Inadequate. So if you just provide us with dates. So 00:13:04.830 --> 00:13:07.919 going back to that same example of this was corrected 00:13:07.919 --> 00:13:12.049 on September 1, 2020, but there's no supporting documentation 00:13:12.539 --> 00:13:16.149 then at that point the plan of correction would be rejected. 00:13:16.840 --> 00:13:19.700 If you submit a response saying and you have a very 00:13:19.700 --> 00:13:22.149 detailed plan saying what exactly you're going to do 00:13:22.149 --> 00:13:25.179 to correct any identified deficiencies but there's 00:13:25.179 --> 00:13:29.720 no date, that will also result in a rejection. And then 00:13:29.720 --> 00:13:33.279 also as I previously mentioned, if it's a life safety 00:13:33.279 --> 00:13:37.120 issue that's a little bit more urgent to get taken 00:13:37.120 --> 00:13:40.549 care of and you request, you know, a year to do it 00:13:40.940 --> 00:13:42.690 is going to get rejected and you're going to be asked 00:13:42.690 --> 00:13:48.600 to provide a sooner timeline. And so whenever a plan 00:13:48.600 --> 00:13:52.299 of correction is rejected you will receive new correspondence. 00:13:52.299 --> 00:13:55.509 So just as you did with the initial letter and any 00:13:55.509 --> 00:13:58.629 approved POC letters that you've got, you'll receive 00:13:58.629 --> 00:14:02.620 one and it will detail exactly why the plan of correction 00:14:02.620 --> 00:14:06.740 was rejected. 00:14:06.740 --> 00:14:10.610 So delinquent plan of corrections. So how does the 00:14:10.620 --> 00:14:13.570 plan of correction become delinquent? So the plan of 00:14:13.570 --> 00:14:16.840 correction is considered delinquent when we have no 00:14:16.840 --> 00:14:21.220 response received from the operator. So typically the 00:14:21.220 --> 00:14:26.870 process is when the correspondence is sent after an 00:14:26.870 --> 00:14:31.210 evaluation. You have approximately 40 days and again 00:14:31.220 --> 00:14:33.480 you're going to want to go based off of whatever date 00:14:33.490 --> 00:14:35.769 is in the official letter sent to you. But typically 00:14:35.769 --> 00:14:39.360 it's 40 days to respond with your plan of correction 00:14:39.370 --> 00:14:43.590 as far as what you're going to do. Additionally, if 00:14:43.590 --> 00:14:46.740 you say we will have this complete by September 1, 00:14:46.740 --> 00:14:52.830 2020, and it's now September 11. The inspection 00:14:52.830 --> 00:14:55.649 package will then be placed into a delinquent state. 00:14:56.340 --> 00:14:59.429 Just because it's been 10 days since the date of completion. 00:14:59.429 --> 00:15:03.129 So make sure that whenever you do inform us that it 00:15:03.129 --> 00:15:05.190 will be corrected by a certain date that you submit 00:15:05.190 --> 00:15:07.360 your response with enough time that we receive it and 00:15:07.360 --> 00:15:10.039 it doesn't become delinquent. 00:15:10.039 --> 00:15:12.960 And then follow up inspection. So when an inspection 00:15:12.960 --> 00:15:16.809 has become delinquent, if we continue to periodically 00:15:16.809 --> 00:15:20.470 send you letters and follow up waiting for a response. 00:15:20.480 --> 00:15:24.490 If no response is received within one year we will 00:15:24.490 --> 00:15:26.690 send an inspector. It may not be the same inspector. 00:15:26.690 --> 00:15:31.590 Maybe another inspector. To go and evaluate and see 00:15:31.590 --> 00:15:34.740 if the deficiencies have been corrected. If they haven't, 00:15:34.750 --> 00:15:37.649 at that point we assign repeat violations and those 00:15:37.649 --> 00:15:41.769 do come with a monetary fine. Otherwise if everything's 00:15:41.769 --> 00:15:45.169 been corrected, the inspector verifies. A new executive 00:15:45.169 --> 00:15:48.519 closing summary is generated and you don't have to 00:15:48.519 --> 00:15:54.740 worry about the violations anymore. 00:15:54.740 --> 00:15:58.509 So how do you avoid delinquent status? So at the end 00:15:58.509 --> 00:16:01.309 of every single inspection conducted by a pipeline 00:16:01.309 --> 00:16:04.149 safety inspector, there is an executive closing summary. 00:16:04.740 --> 00:16:07.480 So throughout the inspection, the inspector is noting 00:16:07.480 --> 00:16:10.490 any deficiencies that they have identified and they 00:16:10.490 --> 00:16:16.460 come up with list of things. And so this list is then 00:16:16.460 --> 00:16:18.559 presented to you through the executive closing summary 00:16:18.570 --> 00:16:23.029 It will detail any regulatory code that was cited along 00:16:23.029 --> 00:16:28.350 with why the regular or why the item was cited. So 00:16:28.350 --> 00:16:32.289 that can be locations, it can be dates, whatever 00:16:32.289 --> 00:16:37.830 it might be to support the the violation. So these 00:16:37.830 --> 00:16:40.259 are done at the end of the inspection and typically 00:16:40.269 --> 00:16:44.460 it takes about two weeks at the most for an inspection 00:16:44.460 --> 00:16:48.470 to go from the executive closing summary to the point 00:16:48.470 --> 00:16:50.860 at which correspondence is sent to you as an operator. 00:16:51.340 --> 00:16:53.730 The only time that this will be delayed is if it's 00:16:53.730 --> 00:16:57.240 an incident or accident investigation, the process 00:16:57.240 --> 00:16:59.429 is a little bit longer because it does have to go through 00:16:59.429 --> 00:17:01.649 our pipeline safety director and then the oversight 00:17:01.649 --> 00:17:06.119 and safety director. The same thing if you have a 00:17:06.119 --> 00:17:10.690 system or systems that had more than five violations 00:17:10.700 --> 00:17:14.109 on the inspection package. Those also go through the 00:17:14.109 --> 00:17:17.759 same review process where there's two additional reviewers 00:17:19.039 --> 00:17:21.539 before correspondences sent. So in that case it may be 00:17:21.539 --> 00:17:25.019 three weeks before the end of the inspection before 00:17:25.019 --> 00:17:28.690 correspondence is sent. So with those time frames in 00:17:28.690 --> 00:17:31.839 mind if it's been two or three weeks and you still 00:17:31.839 --> 00:17:35.039 have not received the letter, you can contact the inspector 00:17:35.039 --> 00:17:38.039 who conducted the inspection and ask them if anything 00:17:38.039 --> 00:17:42.289 has been sent out. If it has, the inspector will notify 00:17:42.289 --> 00:17:44.650 you exactly who was sent to whether it was by mail 00:17:44.660 --> 00:17:47.859 or by email and if it hasn't, you can request from the 00:17:47.859 --> 00:17:50.710 inspector. Well if it hasn't, the inspector will give 00:17:50.710 --> 00:17:53.720 you a timeline of when it will be sent, and if it 00:17:53.720 --> 00:17:56.670 was sent but it was sent to an incorrect person, the 00:17:56.670 --> 00:18:00.460 inspector can provide you a copy. So on the topic of 00:18:00.470 --> 00:18:06.349 incorrect personnel, when conducting an inspection 00:18:06.359 --> 00:18:09.849 we have what we call a company representative and correspondence 00:18:09.849 --> 00:18:12.750 is sent to them. So if you have any organizational 00:18:12.750 --> 00:18:16.529 changes, a new vice president over operations for 00:18:16.529 --> 00:18:19.619 example. And you know that it's changed since the last 00:18:19.619 --> 00:18:23.549 time the company was evaluated. You can present that 00:18:23.549 --> 00:18:25.690 to the inspector and make sure that they get that taken 00:18:25.690 --> 00:18:28.720 care of so that whenever correspondent to send it gets 00:18:28.720 --> 00:18:30.990 sent to the appropriate person and you're avoiding 00:18:30.990 --> 00:18:36.240 that delinquent status. And so 00:18:36.240 --> 00:18:40.730 the inspectors are there as a resource 00:18:40.730 --> 00:18:44.940 for you when it comes to this. 00:18:44.940 --> 00:18:47.579 So this is my contact information again. My name is 00:18:47.579 --> 00:18:51.160 Pete Longoria. My email address is pete.longoria@rrc.Texas.gov 00:18:51.170 --> 00:18:55.269 And my phone number is 512-318-0113 00:18:55.640 --> 00:18:59.650 And just real quick. I wanted to take the 00:18:59.650 --> 00:19:03.779 time to let you guys know that if you do receive 00:19:03.789 --> 00:19:06.859 a letter where a plan of correction has been rejected 00:19:07.839 --> 00:19:10.480 and you're needing some clarification from the inspector 00:19:10.480 --> 00:19:13.089 You can call the phone number that's listed at the 00:19:13.089 --> 00:19:18.200 bottom of the letter and you can request to speak with 00:19:18.200 --> 00:19:20.710 the inspector and they can provide clarification as 00:19:20.710 --> 00:19:24.430 far as what exactly you were missing. Why it is that 00:19:24.430 --> 00:19:28.190 it was rejected or why your extension request was denied. 00:19:28.200 --> 00:19:32.410 Things like that. So again us as inspectors are 00:19:32.410 --> 00:19:35.630 a very good resource for you guys if you need or have 00:19:35.630 --> 00:19:38.789 any questions. You can contact me either by email or 00:19:38.789 --> 00:19:41.140 by phone. 00:19:41.140 --> 00:19:44.880 And so here is the link to the evaluation which I believe 00:19:44.880 --> 00:19:47.579 will also be posted in the Q and A section. And if 00:19:47.579 --> 00:19:50.769 not, if you just follow the first link that was provided 00:19:51.539 --> 00:19:53.799 and download the presentation you can click on the 00:19:53.799 --> 00:19:56.460 hyperlink and it will take you straight to the evaluation 00:20:00.740 --> 00:20:05.000 So at this time I'll verify, Nicholas, were there any 00:20:05.009 --> 00:20:11.839 unanswered questions? 00:20:11.839 --> 00:20:16.480 So I got a question here: is correspondence sent through 00:20:16.480 --> 00:20:19.175 both email and regular mail? 00:20:19.199 --> 00:20:21.410 Yes. So correspondence 00:20:21.420 --> 00:20:25.059 is sent through both mail and email. Again you're 00:20:25.059 --> 00:20:27.769 going to want to verify whenever an inspection is conducted 00:20:28.140 --> 00:20:30.660 that the email addresses and the mailing addresses 00:20:30.660 --> 00:20:34.349 are correct. As long as we have a email address for 00:20:34.349 --> 00:20:36.950 the company representative it will be emailed as well 00:20:36.950 --> 00:20:47.440 as regular mail. 00:20:47.440 --> 00:20:52.140 Was that the only question? 00:20:52.140 --> 00:20:54.043 Yes that's all we have. 00:20:54.067 --> 00:20:57.220 Okay well I'd like to thank everybody 00:20:57.220 --> 00:21:01.099 for their time today. That was my presentation on 00:21:01.099 --> 00:21:03.769 making a plan of correction. I hope that I was able 00:21:03.769 --> 00:21:07.369 to provide you some information that's useful to you 00:21:07.369 --> 00:21:10.599 as an operator and if not just give me a call, put 00:21:10.599 --> 00:21:13.559 it in the evaluation, however you feel more comfortable, 00:21:13.940 --> 00:21:17.460 and we can go ahead and address those those issues 00:21:17.460 --> 00:21:18.956 with you. So thank you. 00:21:18.980 --> 00:21:21.000 Pete, hold on one second, you have 00:21:21.000 --> 00:21:26.740 some more questions coming in. 00:21:26.740 --> 00:21:29.880 Is there a POC needed for a violation corrected during 00:21:29.880 --> 00:21:34.690 an inspection? So yes we don't, we no longer do corrected 00:21:34.690 --> 00:21:37.430 during the evaluation. So if it is on the executive 00:21:37.430 --> 00:21:40.970 closing summary whenever you receive that letter 00:21:40.980 --> 00:21:44.950 you just respond again with your supporting documentation 00:21:45.740 --> 00:21:51.009 and your dates as far as what you did and once 00:21:51.019 --> 00:22:27.839 we received a response, we can approve that. 00:22:27.839 --> 00:22:31.099 Okay I'll give it about another minute for any additional 00:22:31.099 --> 00:22:34.579 questions and if there's no further questions at that 00:22:34.579 --> 00:22:38.559 point then I'll go ahead and end the presentation.