High Priority Subsurface Installations


Members that own or operate underground facilities that transport petroleum and other highly-volatile products have special protections within Chapter 556, F.S., and special procedures for incidents as well as enforcement provisions.

What is a HIGH-PRIORITY subsurface installation?

High-Priority Subsurface Installations (HPSI) are underground transmission or distribution pipelines used to transport any refined petroleum product or hazardous/highly volatile liquid such as anhydrous ammonia or carbon dioxide. Chapter 556, F.S., requires special procedures when digging or an incident occurs near an HPSI and the pipeline owner or operator has identified the line as HPSI.

What is an HPSI Incident?

An HPSI incident is a damage to an underground transmission or distribution pipeline transporting any refined petroleum product or highly volatile liquid that has been identified as HPSI by member operators that owns the facility, according to the notification procedures in s.556.116(1) and results in:

  1. Death; or

  2. Serious bodily injury requiring inpatient hospitalization; or

  3. Property damage, including service-restoration costs, in an excess of $50,000 or an interruption of service to 2,500 or more customers.

Identifying HPSIs

  1. Member receives locate ticket and determine if the affected line is an HPSI facility and if it is within 15 feet of the excavators excavation or demolition site. If so, the member enters the 2C positive response: “2C Marked with Exceptions – High- priority subsurface installation in conflict. Excavator MUST notify the member operator of the excavation or demolition start date and time.”

  2. BEFORE any digging or demolition, notify the member operator with the start date and time. Exactix offers an easy way to provide and document that response online. (The pipeline operator may have additional instructions for you.)

  3. If the member operator does not provide timely notice, the excavator may proceed, after waiting the legal time period set forth in s.556.105(9)(a), F.S., to excavate without notifying the member operator of the excavation start date and time. NOTE: The Exactix ticket entry system records the date and time for all initial and subsequent positive response entries.

HPSI Incident Procedure

Within 24 hours of learning of an incident, member operators (utilities) and excavators must report the incident to Sunshine 811 and the State Fire Marshal. The report mechanism is currently under development.

When a member operator or excavator receives an allegation that an incident occurred, he or she must submit an incident report to the State Fire Marshal. Incident reports are currently under development.

The State Fire Marshal or his or her agents will conduct an investigation to determine if an incident occurred and if it was caused by a violation of s. 556.107(1)(a). Part of any HPSI incident field investigation is determining whether the excavator had a locate ticket for the area in question and whether that ticket was valid. For those steps, see HPSI Records Research.

If the incident occurred and violation of s. 556.107(1)(a) is the cause, a civil penalty can be issued to the violator not to exceed $50,000. This penalty is in addition to any noncriminal citation issued for violation s. 556.107(1)(a).

NOTE: State agencies or political subdivisions causing such incidents may not be fined more than $10,000.