RegulusPipeline researchPHMSA ildnr-2020-underground-natural-gas-storage-program-evaluation
IL UNGS Program Evaluation, 2020, page 1Official PDFPHMSA UNDERGROUND NATURAL GAS STORAGE (UNGS) IL DNR PROGRAM EVALUATION – CY2020 CONDUCTED 8/23-27/2021 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW 9 of 9 B – PROGRAM INSPECTION PROCEDURES 13 of 14 C – PROGRAM PERFORMANCE 30 of 31 (34) D – COMPLIANCE ACTIVITIES 12 of 12 (21) E – INCIDENT INVESTIGATIONS 4 of 4 (13) F – DAMAGE PREVENTION 4 of 4 G – FIELD INSPECTIONS 12 of 12 H - 60106 AGREEMENT STATE (if applicable) 6 of 6 TOTAL PROGRAM EVALUATION POINTS 90 of 92 (113)#
IL UNGS Program Evaluation, 2020, page 2PHMSA UNGS STATE PROGRAM EVALUATION – CY2020 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW THIS SECTION ANALYZES ACCURACY AND COMPLETENESS OF ANNUAL PROGRESS REPORT SCORE 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data – Progress Report Attachment 1 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 1 correlates with Attachment 3 and Program Partner records. 1 2 Review of Inspection Days for accuracy – Progress Report Attachment 2 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Two versions of the IL Progress report are in FedStar. The version showing 103.814 is the correct version. Attachment 2 agrees with Partner records. 1 3 Accuracy verification of Operators and Operators Inspection Units in State – Progress Report Attachment 3 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 3 agrees with Partner records. 1 4 Accuracy verification of Compliance Activities – Progress Report Attachment 5 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 5 agrees with Partner records. 1 5 Were UNGS program files well-organized and accessible? - Progress Report Attachment 6 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The records are in an easily accessible Database. 2 6 Was employee listing and completed training accurate and complete? – Progress Report Attachment 7 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 7 is consistent with IL OOGRM records. (.66 inspector years) 1 7 Verification of Part 192 and 199 Rules and Amendments – Progress Report Attachment 8 (Yes= 1 point, No= 0 Points) Comments: Yes, Attachment 8 agrees with internal records. Discussed that these rules need to be adopted prior to becoming a 60105 Partner. No immediate plans for becoming a 60105 partner. 1 8 List of Planned Performance - Did State describe accomplishments on Progress Report in detail – Progress Report Attachment 10 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 10 is an accurate report of 2020 activities. 1 9 General Comments: Ms. Colleen Callahan, Director, Illinois Department of Natural Resources, One Natural Resources Way, Springfield, Illinois, 62702-1271; Ernest Kierbach, Field Manager OOGRM; Patrick Gaume, Evaluator. UNGS PROGRESS REPORT REVIEW score is 44 of 50: 6 pt. reduction due to 60106 jurisdiction. No incidents were reported in UNGS for 2020. Part A scored 9 of 9 points. 9#
IL UNGS Program Evaluation, 2020, page 3B – PROGRAM INSPECTION PROCEDURES Does State Inspection Plan include procedures that address the following elements? (See Guidelines Section 5.1) 1 Does State have written inspection procedures? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Underground Natural Gas Storage Intrastate – 60106 Agreement Procedures Manual. Also, the Well Inspector’s Field Manual. 2 2 Standard Inspections Do Standard Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Review of Procedures, Records, or Field Items to complete a PHMSA UNGS IA Question Set (RESERVOIR or CAVERN) – 2019.12.31) • Pre-Inspection Activities • Inspection Activities Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See 60106 Procedures Manual Section IV; and Well Inspector’s Field Manual. 2 3 Integrity Management Inspections • Do Integrity Management Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Integrity Testing and Maintenance: Observing Integrity Testing (Tubing, Casing, Cement), reservoir integrity monitoring, & FLIR Camera inspections.) • Pre-Inspection Activities • Inspection Activities Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See 60106 Procedures Manual Section IV; and Well Inspector’s Field Manual. 2 4 Design, Testing, and Construction Inspections Do Design, Testing, and Construction Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Review of procedures, records, and field activities to complete PHMSA UNGS IA Question Set (RESERVOIR or CAVERN CONSTRUCTION) – 2019.12.31. Inspection activities for well design, drilling and completion activities, well workover, reservoir maintenance/repair activities, and abandonment (Plugging and cementing), temporary abandonment, and restoration.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See 60106 Procedures Manual Section IV; and Well Inspector’s Field Manual. 1#
IL UNGS Program Evaluation, 2020, page 45 Wellhead Inspections Do Wellhead Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See 60106 Procedures Manual Section IV; and Well Inspector’s Field Manual. 1 6 Drug and Alcohol Inspections Do Drug and Alcohol Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Using AI to complete the federal Comprehensive Drug and Alcohol program (Form 3.1.11). Includes time conducting joint inspections with other agencies for this type of inspection.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See 60106 Procedures Manual Section IV. 1 7 Does inspection plan address inspection priorities of each inspection unit, based on the following elements? • Length of time since last inspection (Within five-year interval per inspection unit) • Operating history of operator/unit and/or location (includes leakage, incident, Integrity Testing, and compliance activities) • Type of activity being undertaken by operators in inspection units (i.e. construction) • Locations of operator’s inspection units being inspected - (Geographic area, Population Density, etc.) • Process to identify high-risk inspection units considering integrity threats * Are inspection units broken down appropriately? (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: NI 4 of 5 points. See Chapter V. Appendices, Section B. Inspection Priorities. It includes PHMSA’s UNGS Risking spreadsheet. The bulleted items still need to be more clearly stated and better integrated with other IL OOGRM priorities. Continued improvement is needed. 4 8 General Comments: Part B scored 13 of 14 points. Question 7 was ‘NI’. 13#
IL UNGS Program Evaluation, 2020, page 5C – PROGRAM PERFORMANCE 1 Was ratio of Total Inspection Person-Days to Total Person-Days acceptable? (Chapter 4.2) A = Total Inspection Person Days (Attachment 2) B = Total Inspection Person Days Charged to the program (220 x Number of Inspection person years from Attachment 7) Ratio = A/B If Ratio >= .38 then score = 5 points. If Ratio < .38 then score = 0 points. (Yes= 5 points, No= 0 Points) Comments: Yes, 103.814 inspection days, .66 inspector years, 103.814/.66*220=.715 okay. 5 2 Has each Inspector and Program Manager fulfilled the TQ Training Requirements? (See Guidelines Appendix C for requirements and Chapter 4.3.1) (Yes= 5 points, No= 0 Points, NI=1-4) Comments: Yes. All inspectors are within the 3 years to acquire the necessary training. 5 3 Does State use the PHMSA Inspection Assistant (IA) program to document inspections? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, Inspections from 2019-2021 are in IA. 2 4 Did records and discussions with Program Manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Ernest has been the Program Manager for almost 3 years and demonstrates competence in this position. 2 5 Did State respond to PHMSA's Evaluation Letter within 60 days and correct or address any noted deficiencies? Chapter 8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. 10/13 to 11/30 all good. All deficiencies were addressed. 2 6 Did State inspect all types of operators and inspection units in accordance with time intervals established in their written procedures? Chapter 5.1 (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: Yes, on a 5-year inspection cycle for initial inspections and thereafter, with the exception of wellhead inspections being required annually. 5 7 Did State Inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Chapter 5.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The IA form is being used. 2 8 Did State complete all applicable portions of inspection forms? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The IA form questions and being answered. 2 9 Has the State reviewed Operator Annual reports, along with Incident reports, for accuracy and analyzed data for trends and operator issues? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The annual reports have been downloaded, disaggregated, and studied for trends and missing information. There have been no incidents. 2#
IL UNGS Program Evaluation, 2020, page 610 11 12 13 14 15 16 Is the State verifying operators are conducting drug and alcohol tests required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (Yes= 2 points, No= 0 Points, NI= 1 point) Comments: NI 1 of 2 points, IL DNR has participated with IL CC on their first D&A in 2021. Discussed with IL DNR to upload the D&A results into IA. Expect successful compliance for 2021. 1 Does the State have a mechanism for communicating with stakeholders regarding the inspection and enforcement program? (This should include making enforcement cases available to public). (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes, IL OOGRM has a website that includes contact information, regulations, and forms; IL OOGRM has operator contact information and communicates needed information to the operators; IL OOGRM has an open-door policy. 1 Did State execute appropriate follow-up actions to Safety Related Condition Reports (SRCR)? Chapter 6.3 (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: NA. No SRCs in this program’s history. NA Did the State participate in/respond to surveys or information requests from PHMSA? (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes, IL OOGRM responds to PHMSA requests. 1 Did the State forward any potential waivers/special permits to PHMSA for review prior to issuing them to operators? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA, there are none. New Partner effective 2018 NA 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. (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA, there are none. New Partner effective 2018 NA General Comments: Part C scored 30 of 31 points. 3 questions, #12, 14, & 15, were NA. Question #10 was NI. 31#
IL UNGS Program Evaluation, 2020, page 7D – COMPLIANCE ACTIVITIES 1 Does the State have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 • Procedures to notify an operator (company officer) when a noncompliance is identified (60105 States) • Procedures to routinely review progress of compliance actions to prevent delays or breakdowns • Procedures regarding closing outstanding probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: Yes, see IL OOGRM Administrative Rule 62-240, Sub Part A, Sections 240.125- 240.186; also Section 240.1854 2 Did the State follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 • Were compliance actions sent to company officer or manager/board member if municipal/government system (60105 States)? • Document probable violations • Resolve probable violations • Routinely review progress of probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: Yes. Communication with the Operators is well established, and contact with PHMSA, Eastern Region, for UNGS enforcement actions has improved. There have been no NOPV to date. Concerns are documented. 3 Did State within 30 days of the end of an inspection conduct a post-inspection briefing with the owner or operator of the UNGS facility inspected outlining any concerns identified during the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, there is a ‘Post Inspection Briefing’ performed at the close of every inspection. 4 Did State within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, the Exit interview is reviewed and revised as necessary and emailed to the operator and PHMSA Eastern Region within 60 days. 5 Did the State issue compliance actions for all probable violations discovered (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, is a 60106 partner. They have issued violations of State regulations. They have also identified concerns and unsatisfactory items while performing federal UNGS inspections and have forwarded them to PHMSA for handling. 6 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary (60105 States). (Yes= 2 points, No= 0 Points) Comments: NA, is a 60106 Partner. Good communication is established with operators and the Eastern Region, PHMSA. 4 4 2 2 NA NA#
IL UNGS Program Evaluation, 2020, page 87 Is the Program Manager familiar with State process for imposing civil penalties (60105 States)? (describe any actions taken) (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, is a 60106 partner. IL DNR staff is familiar with the process for imposing civil penalties. 8 Were civil penalties considered for repeat violations, violations which can’t be corrected by other means, or violations resulting in incidents (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, is a 60106 partner. 9 Can the State demonstrate it is using their enforcement fining authority for safety violations (60105 States)? (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: NA, is a 60106 partner. 10 General Comments: Part D scored 12 of 12 points. Questions 5 - 9 were NA. NA NA NA 12#
IL UNGS Program Evaluation, 2020, page 9E – INCIDENT INVESTIGATIONS 1 Does the State have written procedures to address State actions in the event of an incident? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, it is in the General Field Manual which is referenced by the UNGS Procedures Manual. 2 2 Does State have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, see IL DNR Regulations Sections 240.1853, 24.1854, & 240.1880. See Form OG 21A and others. 2 3 Did the State keep adequate records of Incident notifications received? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, none. It would be kept electronically as a sub-part of the Operator file and in the Enforcement File if a violation was found. NA 4 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 point, No= 0 Points, NI= .5 point) Comments: NA, none. Per Field Procedures manual all incidents that meet State criteria for reporting, (see Section 240.1880) must be on-site investigated within 48 hours. Per 240.1805 the IL definition of ‘incident’ is more stringent than the Federal definition of ‘significant incident’. NA 5 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? • Observations and document review • Contributing Factors • Recommendations to prevent recurrences where appropriate (Yes= 3 points, No= 0 Points, NI=1-2 points) Comments: NA, none. This is a new partnership since 2018. NA 6 Did the State initiate compliance action for violations found during any incident investigation? (60106 States forward violations to PHMSA) (Yes= 1 point, No= 0 Points) Comments: NA, none. This is a new partnership since 2018. NA 7 Did the State assist the Region Office or Accident Investigation Division (AID) by taking 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 and investigate discrepancies) Chapter 6 (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: NA, none. This is a new partnership since 2018. They are willing to do so. NA 8 Does State share lessons learned from incidents with PHMSA? (Yes= 1 point, No= 0 Points) Comments: NA, none. This is a new partnership since 2018. They are willing to do so. NA#
IL UNGS Program Evaluation, 2020, page 109 General Comments: Part E scored 4 of 4 points. 6 questions, #2-8, are NA. 4#
IL UNGS Program Evaluation, 2020, page 11F – DAMAGE PREVENTION 1 Did the State inspector verify UNGS operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (API 1171 Section 11.10 Public Awareness and Damage Prevention) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. The IA question set address Public Awareness and Damage Prevention and verifies excavation, marking, etc. 2 Did the State encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (Common Ground Alliance Best Practices, support excavation damage prevention legislation, etc.) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes, with the operator. ILCC is the lead with Damage Prevention; will support ILCC as requested. 3 General Comments: Part F scored 4 of 4 points. 2 2 4#
IL UNGS Program Evaluation, 2020, page 12G – FIELD INSPECTIONS 1 Operator, Inspector, Location, Date and PHMSA Representative Comments: Ameren opid 32513, Jared Rubsam acting Dist Manager, virtual & Sciota, IL, 8/25-27/21, Patrick Gaume. Sciota Storage Field inspection. IA title is ‘21-220265_Ameren Ill CO_32513_Sciota UNGS_88702-2021’ 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (Yes= 1 point, No= 0 Points) Comments: Yes. Ameren was notified and 8 Ameren personnel participated in the inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. IA inspection form for UNGS Reservoirs. 4 Did the inspector thoroughly document results of the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. All entries other than ‘Sat’ were documented. This was mostly a ‘records only’ inspection. Concerns from prior inspections were also addressed. A Field inspection was also performed 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Yes= 1 point, No= 0 Points) Comments: Yes. All resources needed for the office and field inspections were made available. 6 Did the inspector adequately review the following during the field portion of the State Program Evaluation? • Procedures • Records • Field Activities/Facilities • Other (please comment) (Yes= 2 points, No= 0 Points, NI=1 Point) Procedures: Yes, Records, Field, and some Procedures were addressed. 7 Did the inspector have adequate knowledge of the UNGS safety program and regulations? (Evaluator will document reasons if unacceptable) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. Jared conducted the inspection well. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (Yes= 1 point, No= 0 Points) Comments: Yes. Six Concerns were identified, most were issues that the operator is already working on. Progress by the operator was noted on some of the Concerns. 1 2 2 1 2 2 1#
IL UNGS Program Evaluation, 2020, page 139 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (Yes= 1 point, No= 0 Points) Comments: Yes. Six Concerns were identified, most were issues that the operator is already working on. Progress by the operator was noted on some of the Concerns. 10 General Comments: • What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) • Best Practices to Share with Other States - (Field - could be from operator visited or State inspector practices) • Other Field Observation Areas Observed (check all that apply) Field items inspected included 3 Gas wells and 1 observation well. Flanges, valves, threads, atmospheric corrosion, site cleanliness, well pad and barriers, signs, markers, site security, Open tubing noted at the observation well. Monitored the Operator’s monthly site inspection and their form; noted that the leak testing was thorough. Site Emergency Response Plans & Procedures. Competent practices were observed but no new ‘Best Practices’ noted. Part G scored 12 of 12 points. 1 12#
IL UNGS Program Evaluation, 2020, page 14H - 60106 AGREEMENT STATE (if applicable) 1 Did the State use the current federal inspection form(s)? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. IA was used in 2020. 1 2 Are results documented demonstrating inspection units were reviewed in accordance with State inspection plan? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes, all operators are being visited every year, Risk ranking is being adopted and implemented starting in 2020, and communication with Eastern Region, PHMSA is established. 1 3 Were all probable violations identified by State referred to PHMSA for compliance action? (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 point, No= 0 Points, NI=.5 point) Comments: Yes. Only Concerns were found in 2020, but they are documented in IA and IL OOGRM has established good communication, and includes notices, to PHMSA Eastern Region within 60 days. 1 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 point, No= 0 Points, NI=.5 point) Comments: Yes. Process is in place. No imminent safety hazards in 2020. 1 5 Did the State give written notice to PHMSA within 60 days of all probable violations found? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. PHMSA is now being notified on all inspections within 60 days regardless of violation status. 1 6 Did the State initially submit adequate documentation to support compliance action by PHMSA on probable violations? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Okay, no NOPV in 2020 but the process for documentation is in place. 1 7 General Comments: Part H scored 6 of 6 points. 6#
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