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PHMSA wi-2016-gas-program-evaluation
2016 WI NG Program Evaluation - wi-2016-gas-program-evaluation (Wisconsin; Natural Gas State Program Evaluation)
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WI 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 WISCONSIN PUBLIC SERVICE 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: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 1#
WI NG Program Evaluation, 2016, page 22016 Gas State Program Evaluation -- CY 2016 Gas State Agency: Wisconsin Rating: Agency Status: Date of Visit: 09/18/2017 - 09/22/2017 Agency Representative: Tom Stemrich, Program Manager PHMSA Representative: Agustin Lopez, State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Ellen E. Nowak, Chairperson Agency: Wisconsin Public Service Commission Address: 610 N. Whitney Way City/State/Zip: Madison, Wisconsin 53707 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 9.5 B Program Inspection Procedures 13 13 C Program Performance 46 46 D Compliance Activities 15 13 E Incident Investigations 6 6 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 110 107.5 State Rating................................................................................................................................................... 97.7 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 2#
WI 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 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified operator with PDM and WI PSC database. The numbers seem to be accurate. Operators inspected are tracked on database and the travel logs. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Accuracy of inspection days reported on Progress Report were compared with database and inspector day logs. There seems to be a discrepancy with the type of inspections but the total number of days is accurate. This was due to an inspector changing the type of inspection on the log after the Progress Report was submitted. In the future the inspection day logs are going to be read only after submitting the progress report. There was also an IMP inspection conducted in 2016 from January 19-20 with two inspectors but there is only 1 IMP inspection day in Attachment 2. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Compared operator and unit numbers with Attachment 1 and 3 for accuracy. Attachment 1 shows 64 private distribution units and Attachment 3 shows 62. This was due to inspecting Northern Natural farm taps but not including them in Attachment 3 because they are interstate operator and the change of farm tap rule. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no federally reportable incidents in 2016. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed database for the tracking of probable violations. There seems to be a difference in the definition of carry over. The WI PSC only considers carry over violations that have not been corrected or will take months to correct and will carry over from one year to the next. They do not consider carry over if the violation isn't closed out by the end of year. So if the WI PSC sends a NOPV at the end of 2016 and receive the operators response in 2017 they do not consider it a carry over. The WI PSC should start counting any open probable violations that carry over from one year to the next if they have not been closed out by the operator stating they have resolved the probable violation. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Files are kept electronically which are available to review and print. Only have old accident investigations that are kept in paper form. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed SABA and compared with Progress Report. No issues found. DUNS: 969115450 2016 Gas State Program Evaluation 1 1 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 3#
WI NG Program Evaluation, 2016, page 48 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Have adopted all updates within 2 years of implementation. 1 1 9 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: Yes, have goals outlined in the Progress Report. Met goal of dedicating inspection days to construction inspections. Hired two new inspectors and program manager will try to spend most of his time reviewing inspection reports and commit less time to inspections. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A.2 -Have issue with accuracy of tracking inspection days. Need to make sure that data used to input into Progress Report is not changed or altered to assure inspection days can be verified. Program Manager will start locking/read only the database document once the Progress Report is submitted so no changes can be made. A.5-There is an issue with the way compliance actions are being tracked. The WI PSC does not carry over violations from 2016 that were corrected in 2017. For example, if an operator misses a valve inspection by 2 months the PSC will issue a probable violation but considers it corrected even thought the operator has not responded to the Compliance Letter. Whenever the WI PSC issues NOPV in one year and the operator doesn't respond or the case isn't closed until the following year, the violations need to be counted as carry over. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 4#
WI 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 2 2 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: Pipeline Safety Program Plan has Standard inspection procedures. Has exit interview which inspector discusses any findings or issues. Explains what forms to use for the type of inspection being conducted. Has pre inspection activities that give guidance to inspector on how to prepare and what to review before inspections. Post Inspections activities are included in procedures. It explains what the inspector need to do after completing the inspection. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 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: Have procedures for both IMP and DIMP inspections to give guidance to the inspectors. Have a pre and post inspection activities to prepare for inspetions. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 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: OQ inspection procedures are in Pipeline Program Plan to give guidance to inspectors. Have pre and post inspection activities. 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: Damage Prevention inspection procedures are in the plan. The procedures give guidance to the inspector. 1 1 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Operator Training procedures are in the Pipeline Program Plan. Inspectors must record days spent on operator training. 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: Have construction inspection procedure that give guidance to the inspectors to perform the inspectors. 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? 6 6 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 5#
WI NG Program Evaluation, 2016, page 6Yes = 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: a. The inspection interval is 5 years. b. Yes, the inspection plan addresses the prioritization of inspections which include previous inspection, violations, operating history, length since last inspection, and type of activities undertaken. c. Inspection plan has prioritization of activities being completed by operator. d. Location is also a priority of inspections. e. Risk ranking considers types of threats the operator has on it's systems. f. Yes, inspection units are broken down appropriately by operating areas. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Inspection procedures are in their Pipeline Program Plan. The WI PSC is mainly complying with Section B of the Evaluation. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 6#
WI 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): 586.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 5.58 = 1228.33 Ratio: A / B 586.00 / 1228.33 = 0.48 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes, the WI PSC met the total inspection person days to total person days 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: a. Yes, inspector must complete all required TQ training before leading an inspection b. Yes, inspectors conducting IMP/ DIMP and OQ inspections have completed the required training. c. There are several inspectors that have taken the Root Cause Analysis course. d. There was no outside training in 2016. e. Yes, lead inspectors have completed all required training before leading an inspection. 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: Yes, Tom Stemrich is very knowledgeable of the pipeline safety program and regulations. 2 2 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 Evaluator Notes: Yes, the state responded to the Chairman's letter within 60 days. 2 2 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, the WI PSC conducts a seminar every two years The lasts seminar was in January 26-30, 2015. 1 1 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 7#
WI NG Program Evaluation, 2016, 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 Evaluator Notes: Yes, reviewed inspection reports and seems that the WI PSC is following their inspection cycle frequency. 5 5 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: Have a database which includes all code requirements. The inspector can download all questions applicable to the type of inspection he/she is conducting. 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: There is no cast iron pipe in the state of Wisconsin. 1 NA 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: There is no cast iron in the state of Wisonsin. 1 NA 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, Inspection question is on form and is covered during the inspections. 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, inspectors review any accidents to assure appropriate follow up is conducted. 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, the WI PSC reviews annual reports for accuracy and analyze data for trends. Also review, incidents if any occur which there was no incidents in 2016. 13 DUNS: 969115450 2016 Gas State Program Evaluation Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 2 2 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 8#
WI NG Program Evaluation, 2016, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, checked Database and seems that the WI PSC has uploaded their OQ, IMP, and DIMP inspections. 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 Evaluator Notes: The WI PSC Transmission Inspection form covers the verification of NPMS updates by the operator. 1 1 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, conducted drug and alcohol inspections in 2016. 2 2 16 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: Yes, the WI PSC conducts OQ program inspections and field verification inspections. Verified inspections in OQDB. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 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: Yes, IMP Plans are reviewed on 5 year inspection cycle per their procedures. Reviewed reports and database to assure inspections are being performed. 18 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: Yes, conducted 20 inspection days of DIMP inspections in 2016. 2 2 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: 2 2 Review Public Awareness programs during their standard inspections. There were no PAPEI inspections in 2016. DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 9#
WI NG Program Evaluation, 2016, page 1020 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: The WI PSC website has information about pipeline safety. Enforcement cases can be seen thru Electronic Regulatory Filing (ERF) in their website. 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: There were no SRCR filed in 2016. 1 NA 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WI PSC monitor failures on the annual reports and types of pipe. Have sent out questionnaires about know pipeline defects in the past but do not send out yearly. WI PSC needs to document that they are verifying that operators are mitigating any known defects of pipeline components. There is a type of pipe (extron-red pipe) that is known to become brital which three operators have about 2 miles each. 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, respond to NAPSR and PHMSA surveys. 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: There is one waiver that was issued in 2010 due to the use of plastic miter joints. It was a one time waiver which there were no extra stipulations. The WI PSC needs to keep a record of the waiver until the miter joints are removed just in case there is an issue with the joints in the future. A record of the waiver is in their database (ERF) system. 25 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. Mr. Tom Stemrich attended the national meeting. 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: WI PSC perform their own metrics with the number of accidents per pipeline miles and review annual reports and compare data from previous years. Review leaks per operator per mile to try to find ways to lower the amount of leaks. DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 10#
WI NG Program Evaluation, 2016, page 1127 Discussion with State on accuracy of inspection day information submitted into State Info Only Info Only Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: There is no issue with the SICT inspection days. WI PSC has 6 inspectors so do not foresee any problems with meeting their inspection person days. 28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Info Only Info Only Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: There has not been any flow reversals in Wisconsin. The question will be added to their inspection questions database. 29 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C.22- The WI PSC monitor failures on the annual reports and types of pipe. Have sent out questionnaires about know pipeline defects in the past but do not send out yearly. WI PSC needs to document that they are verifying that operators are mitigating any known defects of pipeline components. There is a type of pipe (extron-red pipe) that is known to become brital which three operators have about 2 miles each. Total points scored for this section: 46 Total possible points for this section: 46 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 11#
WI 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: a. Yes, the procedures state that any correspondence will be sent to a company official, mayor or owner. b. Yes, there is procedures in place to review the progress of compliance action to avoid breakdowns. c. Yes, there is procedures regarding the process to close out outstanding probable violations. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 3 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: a. Yes, compliance letters are sent to company officials. b. Yes, probable violations were documented on letters and inspection reports. c. Yes, reviewed files and the probable violations were resolved. d. Yes, inspectors and Program Manager review the progress of cases. e. The correspondence do not outline the civil penalty amounts. The state took the wording several years ago. Need to include in the letters in future. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all probable violations discovered were addressed in a compliance action. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, the WI PSC gives reasonable due process to all parties. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 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, he is familiar with the civil penalty process. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? 1 0 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 12#
WI NG Program Evaluation, 2016, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No, the WI PSC has not issued Civil Penalties in many years. The WI PSC needs to improve on the use of their fining authority on serious violations. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D.2.e. -The correspondence does not outline the civil penalty amounts. The state took the wording several years ago. Will include in the letters in future. D.6-The WI PSC has not issued Civil Penalties in many years. The WI PSC needs to improve on the use of their fining authority on serious violations. Total points scored for this section: 13 Total possible points for this section: 15 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 13#
WI 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/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WI PSC has procedures that outline when and how to conduct an incident investigation. The WI PSC will conduct an onsite investigation on all reportable incidents. The procedures give detail and guidance to the inspectors on how to conduct an incident investigation. 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: a. the WI PSC is aware of the MOU between NTSB and PHMSA. b. Yes, the WI PSC Is aware of the federal/state cooperation in case of incident. The WI PSC sends letters to operators giving instructions on how to telephonically report an incident to the state. The operator must call the inspector assigned to the them and he program manager if no answer. The operator must call next inspector if no answer by program manager. 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: There were no reportable incidents in 2016 in the state of Wisconsin. 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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: There were no reportable incidents in 2016. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no reportable incidents in 2016 so no compliance actions were initiated due to incidents. 1 NA 6 Did the state assist region office 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/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was no assistance requested by PHMS region in 2016. DUNS: 969115450 2016 Gas State Program Evaluation 1 1 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 14#
WI NG Program Evaluation, 2016, 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 There were no incidents in 2016 but do share any lessons learned in the "State of the State' during the NAPSR Meetings. 8 General Comments: Info Only = No Points Evaluator Notes: The WI PSC is mainly meeting the requirements of Part E of the evaluation. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 15#
WI 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 2 2 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, the inspection question database has the question dealing with directional boring procedures. The inspectors review the procedures during their O&M Inspections. 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: 2 2 Yes, their inspector checks procedures for excavation, marking and one call response during their inspections. 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, the WI promotes damage prevention during seminar and Digger's meetings. 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, the program manager collects the data and reviews for any trends. Data is also shared during Digger's meetings. 5 General Comments: Info Only = No Points Evaluator Notes: The WI PSC is mainly complying with Part F of the evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 16#
WI NG Program Evaluation, 2016, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Alliant Energy/Wisconsin Power and Light Name of State Inspector(s) Observed: Andrew Miller Location of Inspection: Southwestern Wisonsin; Mineral Point, Dodgeville, Platteville Date of Inspection: September 18, 2017 Name of PHMSA Representative: Agustin Lopez Evaluator Notes: Mr. Andrew Miller conducted a field inspection of Alliant Energy's regulator stations. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Yes, the operator was notified with enough notice to allow any representative to be present during the inspection. 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, the inspector used inspection form as a guide and to document results of inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, results of inspection are documented on inspection form. 2 2 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, the inspector verified the operator had proper equipment to operate and inspect regulators. 1 1 2 2 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: The inspector reviewed records and procedures of regulator inspections. During the field he verified the regulators were operating and checked for set points. DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 17#
WI NG Program Evaluation, 2016, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector was knowledgeable of the pipeline safety regulations. He asked appropriate questions relating to the task being performed. 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 No = 0 Evaluator Notes: 1 1 Yes, an exit interview was performed at the conclusion of the field inspection. He summarized any issues to the operator. 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: There were no probable violations found during the inspection. The inspector did mention concerns with atmospheric corrosion which may be a problem in the future. 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 v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 18#
WI NG Program Evaluation, 2016, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspector checked regulator stations to assure they are in good shape and operate at the set points. He also checked for CP, atmospheric corrosion, line markers, signs and the condition of the ROW. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 19#
WI 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 an 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 an 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 an 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 an 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 an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Not an Interstate Agent. 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 an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 20#
WI 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: Wisconsin PSC does not have a 60106 Agreement. 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: Wisconsin PSC does not have a 60106 Agreement. 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: Wisconsin PSC does not have a 60106 Agreement. 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: Wisconsin PSC does not have a 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Wisconsin PSC does not have a 60106 Agreement. 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: Wisconsin PSC does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Wisconsin PSC does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2016 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 21#
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