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PHMSA il-2016-gas-program-evaluation
2016 IL NG Program Evaluation - il-2016-gas-program-evaluation (Illinois; Natural Gas State Program Evaluation)
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IL NG Program Evaluation, 2016, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2016 Gas State Program Evaluation for ILLINOIS COMMERCE 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 -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 1#
IL NG Program Evaluation, 2016, page 22016 Gas State Program Evaluation -- CY 2016 Gas State Agency: Illinois Rating: Agency Status: Date of Visit: 05/09/2017 - 05/11/2017 Agency Representative: Bill Riley PHMSA Representative: David Lykken Commission Chairman to whom follow up letter is to be sent: Name/Title: Brien J. Sheahan, Chairman Agency: Illinois Commerce Commission Address: 527 East Capitol Avenue City/State/Zip: Springfield, IL 62701 60105(a): Yes 60106(a): No Interstate Agent: No 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 49 42 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 118 111 State Rating................................................................................................................................................... 94.1 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 2#
IL NG Program Evaluation, 2016, 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues noted. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No discrepancies noted. Did not meet minimum inspection field day requirement but did meet total inspection person to total person day ratio. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues noted. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. Housekeeping suggestion. Suggest that any "rescinded" reports not be included in Progress Report(PR) if information is available prior to submission of PR. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. Numbers match ICC database. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. ICC maintains a robust inspection database and on-line document library. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. Information matches both State and T&Q transcripts. Five new inspection staff hired. Completed PL-1250 course. Currently scheduled or waitlisted for 4 other core classes. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. On track to adopt recent amendments no later than July 2017. 1 1 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 3#
IL NG Program Evaluation, 2016, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. No issues. 1 1 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 4#
IL NG Program Evaluation, 2016, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard 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. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: General Insp Activities Section V - Pages 13 - 19 Pre-Insp Activities - Section V(B) Page 13 Post Insp activities - Section V(R) Page 25 2 2 2 IMP and DIMP 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V - Part "O" Page 24 including monitoring of IM assessments and remedial action activities. DIMP (page25) 1 1 3 OQ 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V (I) Page 23 1 1 4 Damage Prevention 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V(N) page 24 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V (M) 1 1 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V (H) Pages 20-22 1 1 DUNS: 807886106 2016 Gas State Program Evaluation 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 Illinois ILLINOIS COMMERCE COMMISSION, Page: 5#
IL NG Program Evaluation, 2016, page 6b. 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 areas, 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: Four methods used. 1) Risk formula 2) length of time since last 3) Construction workload 4) Staff analyst review of inspection data Section IV (Operations) (B) Inspection Priorities pages 6-8 Time Intervals Section IV(6) page 8 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 6#
IL NG Program Evaluation, 2016, page 7PART 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): 563.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.60 = 1453.10 Ratio: A / B 563.00 / 1453.10 = 0.39 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Met 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 DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program 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: Acting PM and the five new analyst trainees have completed one core class (PL1250). All have additional courses (3-4) each scheduled or have been waitlisted. Root Cause training completed by four senior inspectors. Documentation reviewed indicate inspections led by qualified inspector(s) 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 2 2 Evaluator Notes: Discussions with acting PM demonstrated adequate knowledge of safety program, inspection and enforcement procedures, and state program guidelines. 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 2 2 Evaluator Notes: Chairman's letter out 8/19/16. Response received 10/18/16. Deficiencies corrected including improved written procedures, Corrected incident data in Progress Report, a 2016/17 budget was approved, Five Pipeline Safety Analyst Trainee positions filled. U.S. Steel jurisdictional issue addressed by the commission but determined that because PHMSA and the state has not promulgated rules regarding "Crossing Segments" for lines less than 1 mile in length the matter has been dismissed. Staff is required to file a report with the commission but no deadline was stated. Commission interpretation is in conflict with PHMSA interpretation. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 1 1 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 7#
IL NG Program Evaluation, 2016, page 8Yes = 1 No = 0 Evaluator Notes: Last seminar held in October 2014. Next scheduled October 18-19, 2017. 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 5 3 Evaluator Notes: Due to chronic staffing and budget issues restricting travel, not all operator units inspected within the stipulated time frames. U.S. Steel (Granite City) jurisdictional issue continues. Commission order findings in conflict with PHMSA opinion. The pipeline crossings are jurisdictional to the ICC The segments do not meet the definition of Transmission, Gathering, or Distribution Line Federal and State rules have not been adopted that apply to these types of facilities Directs ICC pipeline staff to submit a report outlining the need for a rulemaking, identify which rules would apply, and define which pipelines would be subject to these regulations. No deadline was set for commission staff to issue this report. 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: Forms appear to be complete. Good inspector notes. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: ILPS Form 3 (Gas Distribution Record Audit) Page 3 1 1 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: ILPS Form 3 (Gas Distribution Record Audit) Page 3 1 1 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: ILPS Form 7 (Gas Distribution Record Audit) Page 3 Program has identified issue with certain operators where response procedures have not been followed. Subject will be part of the 2017 Gas Safety seminar agenda. DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 8#
IL NG Program Evaluation, 2016, page 911 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 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. ILPS Form 3 (Gas Distribution Record Audit) Page 3 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Operator Annual Reports and incident reports reviewed annually. Data gleaned from reports are loaded into the ICC database for historical reference and risk analysis. 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a 2 1 timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement. Zero IMP activity uploaded into IMDB. All OQ activity completed in 2016 was uploaded into OQDB. The lone DIMP Plan review and field inspection was uploaded into the DIMP-DB. Encouraged use of the IA application for planning and documenting inspections eliminating the need to manually upload inspection results. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: No confirmations in 2016. Previously handled by retired employee. Improvements to be made in processes and forms to capture this information going forward. Suggested language provided to Interim PM for possible inclusion in inspection forms). 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 D&A inspections completed CY2016. No issues. 93 completed the prior CY. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 2 1 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 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement in number of OQ field validations performed. 42.5 field days devoted to DT&C inspections yet only 16 PHMSA Form 15's completed and uploaded. 52 plan reviews conducted in CY2015. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 1 up to date? This should include a previous review of IMP 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 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement. Only five field validations performed. One muni and four LDC. No IM records reviewed. No plan reviews conducted. DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 9#
IL NG Program Evaluation, 2016, page 1018 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. 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 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 1 Needs improvement. Only one DIMP plan review and one field validation check performed. Both on the same operator. 19 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 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Eight plan review/effectiveness evaluations completed. 2 2 20 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Pipeline inspection and enforcement documentation is posted and regularly updated on the ICC web site. Links to other important pipeline safety information for both consumers, pipeline operators and excavators provided as well. 21 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: Yes. Only one SRC reported 7/2016. Corrective action completed 9/2016. No other SRC's outstanding. 1 1 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. No issues. Question contained in IPLS Form 3. 1 1 23 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 24 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No new waivers issued in 2016. Three waivers currently active. Tracker developed to monitor activity and ensure waiver requirements are being met. DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 10#
IL NG Program Evaluation, 2016, page 1125 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. Attended the 2016 national meeting held in Indianapolis, IN. 1 1 26 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 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: Discussed state specific metrics. Noted continuing efforts to reduce miles of CI and bare steel main. 106 miles of CI main, 3 miles of services, and 140 miles of copper services replaced or retired in 2016. Excavation damages per 1000 tickets have trended downward since 2010. Currently at 2.7 per 1000 tickets. Inspection days per 1000 miles needs improvement. Result of chronic staffing issues. Five new inspector trainees hired late 2016. Likewise Inspector Qualifications ratings should improve once new staff get trained up. 27 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: Info Only Info Only Discussed tool submission data for accuracy. Puts number of inspectors needed at 12. Minimum inspection field day requirement rises to 997 days. Discussed scoring policy and the need to provide a plan to increase inspection staff. 28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: Will be addressing with operators as part of this year's gas safety seminar. Info Only Info Only 29 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: 49 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 11#
IL NG Program Evaluation, 2016, page 12PART 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: Page 26 of the ICC written safety procedures for NOPV's to company officer. Page 27 for the tracking of violations. Page 28 for the closing of outstanding PV's and NOA's 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 member 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: Inspections are well documented. Compliance correspondence sent to appropriate company officers. Staff makes good use of photographs to support inspection findings. Compliance process described under Section 7 of the ICC written procedures are followed. Correspondence references Illinois Gas Safety Act 220 ICLS 20/7 denoting civil penalty amounts. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. One civil penalty assessed in 2016. City of Thebes. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Correspondence to operators outline procedures for challenging inspection findings where a penalty or corrective action has been recommended. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The acting PM is familiar with the civil penalty process. Civil penalties are considered for repeat violations. One civil penalty assessed this year. 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: DUNS: 807886106 2016 Gas State Program Evaluation 1 1 Illinois ILLINOIS COMMERCE COMMISSION, Page: 12#
IL NG Program Evaluation, 2016, page 13Yes. Several civil penalties have been assessed over the years. $6500 in 2016, $1.7 million in 2015. 7 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 13#
IL NG Program Evaluation, 2016, page 14PART E - Incident 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: Yes. Section VI (Investigation of Incidents) of ICC procedures. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, 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: Yes. 24 Hr. Incident Notification number for reporting of incidents. No issues with records of notifications received. 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: Yes. No issues noted. 1 1 4 Were all incidents 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 when appropriate Yes No Needs Improvement Evaluator Notes: Yes. Incident investigations are well document. As with other inspection types all reports make good use of photographic images to support investigation findings. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Yes. One investigation ongoing. May be initiating corrective action as a result of findings. Have issued CA's as a result of past investigations. 6 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 operator incident 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: Yes. No issues noted. Several NRC reports have been rescinded in 2016 due to updated investigation information filed with Central Region. DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 14#
IL NG Program Evaluation, 2016, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Experiences shared with other program manages as part of annual NAPSR regional and national meetings, and state T&Q gas seminar. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 15#
IL NG Program Evaluation, 2016, page 16PART 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? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. ILPS Form 7 Operation and Maintenance Construction Checklist Page 6 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: Yes. ILPS Form 3 (Gas Distribution Record Audit) page 3. 2 2 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. ILPS Form 3 (Gas Distribution Record Audit) page 4 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: 2 2 Yes. ILPS Form 3 (Gas Distribution Record Audit) page 3. Also part of review of operator's annual reports. 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 16#
IL NG Program Evaluation, 2016, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Nicor Gas Name of State Inspector(s) Observed: Matt Smith Location of Inspection: Normal / Boomignton, Pontiac, IL Date of Inspection: 06/13-15/2017 Name of PHMSA Representative: David Lykken Evaluator Notes: 6/13-14/2017 - Observed integrity remediation digs at various locations resulting from ICDA and ECDA surveys performed on Nicor's 12-inch gas transmission pipeline. Anomaly assessments performed by third party contractor Shafer, Kline & Warren Inc. (SKW). 6/14-15/2017 Nicor's Underground Gas Storage Facility located at Pontiac, IL. 16-inch and 8-inch STW replacement project. 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. The operator was notified and key company and contractor personnel were on site. 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 Evaluator Notes: Yes. 2 2 PHMSA Form 16 - Gas IMP Field Verification form used for ICDA and ECDA anomaly assessments. PHMSA Form 5 - Gas Pipeline & Compressor Station Construction form used for gas storage replacement project. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Applicable items on inspection checklists were well documented. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes. Inspector observed anomaly assessment equipment (UT gauge and multi-meter) during integrity digs, welding equipment and pipe stringing operations at construction site. 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) 2 2 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 17#
IL NG Program Evaluation, 2016, page 18Evaluator Notes: Yes. For ICDA and ECDA digs inspector reviewed dig sheets, elevation profiles, and coating application procedures. Checked operator and contractor OQ cards. Written procedures for performing application of new coatings (Hot Wrap) found to be lacking in details. Procedure for applying wax tape not followed. Similar coating issues identified at underground storage replacement project. A general lack of awareness on the part of the contractor and company personnel regarding coating application procedures or concern over quality of work. Poor hot wrap job. Many holidays. Two inch service stub not properly inspected for coating condition. ICC inspector found additional damaged and blistered FBE coating not found by third party contractor. 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. Inspector demonstrated adequate knowledge. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Final exit interview not observed since inspection is ongoing. Status briefings conducted each day with operator. Primary concerns communicated regarding issues with lack of a detailed procedure for conducting coating or rewrapping operations of STW pipelines and fittings. Poor quality control quality assurance process. OQ issues - apparent lack of knowledge of individuals, both company and contractors who perform coating operations and at the field management level. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Issues with lack of a detailed procedure for conducting coating or rewrapping operations of STW pipelines. Poor Quality control/Quality assurance processes. OQ training issues - apparent lack of knowledge of individuals, both company and contractors who perform coating operations and at the field management level. 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 Info Only Info Only DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 18#
IL NG Program Evaluation, 2016, page 19q. 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 G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: As noted under question G-9. Issues with lack of a detailed procedure for conducting coating or rewrapping operations of STW pipelines. Poor Quality control/Quality assurance processes. OQ training issues - apparent lack of knowledge of individuals, both company and contractors who perform coating operations and at the field management level. Inspector identified other coating anomalies on FBE pipe not picked up by contractor. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 19#
IL NG Program Evaluation, 2016, page 20PART 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: Not a Interstate Agent 1 NA 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: Not a Interstate Agent 1 NA 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: Not a Interstate Agent 1 NA 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Not a Interstate Agent 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Not a Interstate Agent 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Not a Interstate Agent Yes = 1 No = 0 Needs Improvement = .5 1 NA 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: Not a Interstate Agent 1 NA 8 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 20#
IL NG Program Evaluation, 2016, page 21PART 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: Not a 60106 state 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: Not a 60106 state 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: Not a 60106 state 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 Evaluator Notes: Not a 60106 state 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Not a 60106 state 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: Not a 60106 state 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: 807886106 2016 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 21#
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