High-Priority Subsurface Installations

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. They carry special procedures for excavators and member operators when there is an incident and the pipeline owner or operator has identified the line as an HPSI.

What is an HPSI Incident?

An HPSI incident is defined as an event that involves damage to a high-priority subsurface installation that has been identified as such by the operator according to the notification procedures in s.556.116(1) and that 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 operators determine whether one of its HPSI facilities is within 15 feet of an excavator’s excavation or demolition site and enters the 2C positive response code BEFORE any digging begins. The code reads: “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. The excavator must notify the member operator by email or phone call with the start date and time.

  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 repsonse entries.

HPSI Incident Procedure

  1. 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.

  2. 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.

  3. 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 556.107(1)(a).

  4. If the incident occurred and violation of s.556.105(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 incident may not be fined more than $10,000.