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PHMSA il-2017-gas-program-evaluation
2017 IL NG Program Evaluation - il-2017-gas-program-evaluation (Illinois; Natural Gas State Program Evaluation)
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IL NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 1#
IL NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Illinois Rating: Agency Status: Date of Visit: 05/01/2018 - 05/03/2018 Agency Representative: Bill Riley, Assistant Director in Charge Pipeline Safety & One-Call Enforcement PHMSA Representative: David Lykken, Program Evaluator 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 2017 (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 48 43.5 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 117 112.5 State Rating................................................................................................................................................... 96.2 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 2#
IL NG Program Evaluation, 2017, 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: Appears completed and accurate. No issues noted. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Field days appear to correspond with inspection reports reviewed. The program exceeded the required minimum number of inspection person days. Total number of inspection days in CY2017 was 1017. 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 apparent issues. Information matches data found in PDM. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: route. Information listed in PR matches data found in PDM and incident reports filed by operator. Entry for single interstate incident listed not applicable. Entered on attachment because program responded to incident site to secure while PHMSA in 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Numbers appear to match programs database information. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Records readily available via agency's pipeline database. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. No issues noted. PR matches T&Q training records. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Latest (2017) amendments adopted within the two year timeframe. No issues noted. 1 1 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 3#
IL NG Program Evaluation, 2017, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 5 Pipeline Safety Analyst Trainee's will have core training completed within two years. New hires helping to surpass minimum number of field inspection days. Interim PM named as permanent Assistant Director in Charge Pipeline Safety & One-Call Enforcement. 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 4#
IL NG Program Evaluation, 2017, 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: No changes from CY2016. General Inspection Activities Section V - Pages 13 - 19 Pre-Inspection Activities - Section V(B) Page 13 Post Inspection 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: No change. Section V - Part "O" page 24 including monitoring of IM assessments and remedial action activities. DIMP (page 24/25) 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 (Part I - Training and Operator Qualification (OQ) Inspections) 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: No changes. Section V (Part N - Damage Prevention Activities) 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 - Operator Training) page 24 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: No changes. Section V (H-Design, Testing and Construction) Pages 20-22 1 1 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 5#
IL NG Program Evaluation, 2017, page 67 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 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 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: No changes from CY2016. 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) IV(B) Inspection Priorities pages 6-8 Time Intervals Section IV(C) page 8 Unit breakdown appropriate 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 6#
IL NG Program Evaluation, 2017, 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): 1017.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 9.95 = 2189.00 Ratio: A / B 1017.00 / 2189.00 = 0.46 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Inspection day interval met. Minimum day requirement (563), Actual (1017). Ratio is 0.46 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: To date Mr. Riley needs only compete the PL3257 course to complete cores for PM's. Five new Analyst Trainees on track to complete core courses within two years. They are also waitlisted to attend the PL3322 OQ course. Five inspectors have completed the Root Cause training. 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 Evaluator Notes: No issues. Mr. Riley on track to complete all PM required courses this CY. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 2 2 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PHMSA State Programs letter sent out 7/27/2017. Response received 9/29/2017. Issues addressed and working towards correction. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes. Pipeline Safety conference held 10/18-19/2017 in Effingham, IL. Agenda and presentations reviewed. 1 1 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 7#
IL NG Program Evaluation, 2017, page 86 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: Continued issues with US Steel facility not being inspected. Also, staffing shortages resulting in only 69% of "Private" operator units and 89% of Intrastate transmission operator units have been inspected since CY2015. Written inspection plan calls for intervals not to exceed 3 years for conducting standard inspections. 7 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Inspection forms appear complete. Use traditional PHMSA Non IA equivalent inspection forms are more comprehensive. Recommended updating inspection forms to IA equivalents for certain inspections types such as IM, DIMP, OQ, and PA to better assess when changes do occur. Recommended updating D&A forms to current version. 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: Yes. 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: Yes. ILPS Form 3 (Gas Distribution Record Audit) Page 3 1 1 10 Did the state review operator emergency response procedures for leaks caused by 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: Yes. ILPS Form 7 (Gas Distribution Record Audit) Page 3 Topic also covered at length during Oct 2017 Pipeline Safety seminar. 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 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 Evaluator Notes: Yes. Observed several inspection reports documenting review of operator Annual Reports. 2 2 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 8#
IL NG Program Evaluation, 2017, page 913 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 1 Evaluator Notes: Yes. Improvement form last evaluation. Question added to IPLS Form #6 Standard Inspection of Transmission pipeline (Records) under Regulatory Reporting section. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 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. 3 completed in CY2017, 2 in CY2016 and 93 completed in CY2015. Need to update D&A forms to most current. Recently posted on the PHMSA web site. 15 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 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 5 written plan reviews conducted in CY2017. Field verifications conducted mostly on DT&C inspections. Some during standard field inspections. 16 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? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement. Minimal days (5) devoted to transmission IM inspections due to past staffing issues. Senior inspection staff focused on training new inspectors on conducting standard inspection. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 1 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement. Minimal days (12) devoted to DIMP inspections due to past staffing issues. Senior inspection staff focused on training new inspectors on conducting standard inspection. 18 Is state verifying operators Public Awareness programs are up to date and being 2 2 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 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. A number of PA Effectiveness inspections completed as part of Standard comprehensive inspections. The next round of written plan reviews coming due in the next inspection cycle. 19 DUNS: 807886106 2017 Gas State Program Evaluation Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). 1 1 Illinois ILLINOIS COMMERCE COMMISSION, Page: 9#
IL NG Program Evaluation, 2017, page 10Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Inspection and enforcement documents, and other relevant pipeline safety information posted on ICC web site. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 0.5 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Needs improvement. Two SRC's reported by operator in CY2017. Program not providing monthly updates as requested by PHMSA Central Region. 21 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. Question asked on IPLS Form 3 Std. Insp. of a Gas Distribution Operator - Record Audit. 1 1 22 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. Program responded when requested. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 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: Waivers monitored via IPLS Form Dist. Std. Inspection Records and Field checklist. 1 1 24 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. Did attend national meeting in Columbus, Ohio. 1 1 25 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: Damages per 1000 miles continue to trend downward since 2010. Inspection days per 1000 miles starting to climb due to hiring of new inspection staff. Inspector Qualifications - Core Training on the rise to due accelerated training of new employees. Leak Repairs per 1000 miles continue to trend upward since 2012. Consequently the number of outstanding leaks is at a historic low. Enforcement Programs and Incident Investigations continuing at 100% for both. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: PM satisfied with data submission. Does not anticipate making any changes. Plans to fill two vacant positions due to retirements. DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 10#
IL NG Program Evaluation, 2017, page 1127 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: N/A. None currently in system. 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 43.5 Total possible points for this section: 48 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 11#
IL NG Program Evaluation, 2017, 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 25 (S) of the ICC written safety procedures for NOPV's to company officer. Page 27 (V) for the tracking of violations. Page 28 (W) 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. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Issues well documented. Correspondence addressed to company or local government official. Remedial actions taken by operator to resolve non-compliance follow-up on. Correspondence makes reference to state specific civil penalty amounts. Notices to operators of inspection findings currently well within the 30 and 90 day timeframes. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Reviewed inspection documentation and associated correspondence. Compliance actions correlate with numbers submitted under Attachment 3 of the Progress Report. 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. As noted in prior evaluations, correspondence to operators outline procedures for challenging 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 PM is familiar with the civil penalty process. Civil penalties are considered for repeat violations and several civil penalties have been assessed in prior years. No civil penalties assessed in CY2017. DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 12#
IL NG Program Evaluation, 2017, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes as previously noted in past evaluations. Several civil penalties assessed & collected in 2015 totaling $1,698.900. 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 13#
IL NG Program Evaluation, 2017, 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) pages 29-35 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. Has 24 Hrs. Incident Notification number. Inspection staff monitor during regular working hours. Contracted answering service utilized during after hours, holidays and weekends. Answering service notifies PM or alternate within one hour of receiving call. Understands MOU between NTSB and PHMSA and Federal/State cooperation. 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. Two reportable incidents related to third party excavation. 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: Both reportable incidents still open. Documentation/Reports not completed. Have historically been well documented and complete. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Yes. May be initiating corrective action as a result of findings. Case Number 0001-18. Have issued CA's as a result of past investigations. 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the 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. Program does maintain communication with PHMSA AID. In CY2017 the program responded to a reportable interstate incident to secure site while PHMSA personnel were in route. DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 14#
IL NG Program Evaluation, 2017, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. During NAPSR Regional and National meetings and state seminars. 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 15#
IL NG Program Evaluation, 2017, 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 O&M&Construction Checklist - Page 6 of 28. 2 2 2 Did the state inspector verify pipeline operators are following their 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 Pg. 3 of 9 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. Pg. 4 of 9 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: Yes. ILPS Form 3. Pg. 3 of 9. Also part of review of operator's annual reports. 2 2 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 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 16#
IL NG Program Evaluation, 2017, 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: Jim Watts, ICC Pipeline Safety Analyst Location of Inspection: Nicor Gas - Des Plaines operating area Date of Inspection: 05/15-17/2018 Name of PHMSA Representative: David Lykken Evaluator Notes: 5/15/2018 - Cathodic Protection system checks performed. Pipe to soil readings, isolated facilities, casing installations for adequate electrical isolation. Checked general condition of MSA. 5/16/2018 - Pressure regulating stations inspected for overall condition. Checked station valves for accessibility. Operated random station valves, Confirmed station inlet and outlet pressures. 5/17/2018 - Performed random checks of gas facility locates and for accuracy and completeness. 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. Operator had been notified and was well represented during inspection. 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 2 2 Evaluator Notes: Yes. Form ILPS #4 (Standard Inspection Report Of A Gas Operator Field Audit) utilized during inspection. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Inspector observations were well documented. Recorded findings noted and presented to the operator during exit interview. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes. No issues noted. 1 1 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) Evaluator Notes: DUNS: 807886106 2017 Gas State Program Evaluation 2 2 Illinois ILLINOIS COMMERCE COMMISSION, Page: 17#
IL NG Program Evaluation, 2017, page 18Yes. No issues noted. Inspector asked good questions during field observations. Communicated with operator each time an issue was identified instead of waiting until exit interview. Most items being addressed at time of exit interview. 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: Yes. Exit interview conducted. Issues expressed both during field observations and during exit interview. ICC Exit Meeting form filled out and electronically signed by operator representative. A signed copy provided to the operator via email at end of exit interview satisfying the 30 and 90 day notice requirement. 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: 4 "Issues Identified" 1) Low CP read on possible isolated service. 2) Missing screen on residential MSA pressure regulator. 3). Atmospheric corrosion on commercial MSA riser at air to soil interface. 4) Incomplete locate identified. Locate request stipulated entire property. Service extension partially located. Stub not located. The ICC defines "Issues Identified" as "observe conditions or operating practices that are not violations at the time, but could, if not corrected, result in a future violation or an unsafe situation." 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 q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization Info Only Info Only DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 18#
IL NG Program Evaluation, 2017, page 19v. 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: Inspector did a good job observing the overall condition of areas visited regardless of the specific operations, maintenance activity or gas facility being visited during the three days in the field. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 19#
IL NG Program Evaluation, 2017, 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: Not a Interstate Agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 20#
IL NG Program Evaluation, 2017, 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: Not a 60106 state Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 807886106 2017 Gas State Program Evaluation Illinois ILLINOIS COMMERCE COMMISSION, Page: 21#
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