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PHMSA wi-2017-gas-program-evaluation
2017 WI NG Program Evaluation - wi-2017-gas-program-evaluation (Wisconsin; Natural Gas State Program Evaluation)
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WI 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 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 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 1#
WI NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Wisconsin Rating: Agency Status: Date of Visit: 09/10/2018 - 09/13/2018 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: Lon E. Roberts, Chairman Agency: Public Service Commission of Wisconsin Address: 4822 Madison Yards Way City/State/Zip: Madison, Wisconsin 53705 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 46 45 D Compliance Activities 15 14 E Incident Investigations 10 10 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 114 112 State Rating................................................................................................................................................... 98.2 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 2#
WI 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 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There is a total of 12 operators but only 9 units. The 3 units missing are due to 3 linefill pipelines. The 3 linefill units were submitted as "other". There is no change in the total number of units reported but need to amend Progress Report to change landfill units into intrastate transmission. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified Progress Report data with PSCW data for accuracy. The total inspection days were accurate. 1 1 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: Verified operators with PDM to check for accuracy. The number of operators reported were accurate when compared to PDM. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Checked with PDM and PSCW files. There were no reportable incidents in 2017. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified compliance activities and total number of compliance is accurate. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, files are kept electronically and are well organized and accessible. 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, verified employee training with SABA. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Do not have jurisdiction over LPG Operators and civil penalty is not equivalent to DOT/PHMSA. Points are deducted on the Base Grant Progress Review. DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 3#
WI NG Program Evaluation, 2017, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, PSCW listed their planned activities and past performance. 10 General Comments: Info Only = No Points Evaluator Notes: The PSC is mainly complying with Part A of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 4#
WI 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 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: Procedures has guidance for inspectors on how to conduct a standard inspection. Procedures have pre and post inspection activities and performing an exit interview 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: Procedures are in place to give inspectors guidance on performing IMP inspections. The procedures include yearly review of IMP for large operators. 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: Procedures include guidance for performing OQ Inspections which include Program and field inspections to verify qualification of operators. 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: Procedures include guidance for performing Damage Prevention inspections 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Procedures include guidance to performing operator training and how to document the activities. 1 1 6 Construction 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: Procedures include guidance on performing Construction Inspections. Procedures are very well written with detail on how to conduct an construction inspection. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 5#
WI NG Program Evaluation, 2017, page 6a. 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: Yes, inspection plan addresses the priority of inspections based on different elements. a. Every type of inspection will be conducted within a 5 year interval. b. Operating history is taken into account for inspection prioritizing. c. Activities undertaken by operators is considered for inspections. d. Location of pipeline is considered for inspections. e. High risk threats are considered during inspection prioritizing which include operator activities, location and previous compliance issues. f. Yes, units are broken down by operating areas. 8 General Comments: Info Only = No Points Evaluator Notes: The PSC of Wisconsin is mainly complying with Part B of the Evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 6#
WI 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 5 5 A. Total Inspection Person Days (Attachment 2): 662.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.08 = 1338.33 Ratio: A / B 662.00 / 1338.33 = 0.49 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: report and PSCW data. The ratio of total inspection person days to total person days is .662 which is acceptable. The ratio was verified with progress 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 inspectors are qualified before leading an inspection. b. All DIMP/IMP lead inspectors are qualified before leading inspections. c. Yes, there are several inspectors who have taken the Root Cause course. d. Yes, three inspectors attended an MEA (Midwest Energy Association) pipeline courses. e. Verified that all lead inspectors are qualified to lead inspections. 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, Mr. Stemrich is very knowledgeable of PHMSA 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 2 2 Evaluator Notes: Yes, the Chairman responded within the 60 days. Sent on December 29, 2017 and received on February 7, 2018. 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: Last seminar was on February 2017. 1 1 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 7#
WI NG Program Evaluation, 2017, page 86 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, reviewed inspection reports for inspection intervals and the PSC seems to be meeting the intervals established in their procedures. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 1 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the PSC has a database of all applicable code sections and is used by the inspectors during their inspections. The inspector can download any applicable question which applies to the type of inspection being conducted. Reviewed the 2017 Northern State Power Company(Excel) inspection report and found that some sections were incomplete. The field portion was not completed in accordance with the procedures. The PSC needs to assure all applicable portions of the inspection report are completed. 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 in the state of Wisconsin. The inspectors do verify if they find any cast iron. 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 Wisconsin. 1 NA 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Question on form dealing with 615(a)(3)i has guidance which includes the review of procedures for leaks caused by excavation damage near buildings and for possibility of multiple leaks. 11 Did the state review operator records of previous accidents and failures including 1 1 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 incidents/accidents to ensure appropriate operator response during inspections and accident investigations. 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: DUNS: 969115450 2017 Gas State Program Evaluation 2 2 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 8#
WI NG Program Evaluation, 2017, page 9Yes, PSC reviews annual reports on a yearly basis. 13 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: Yes, the database question dealing with 192.13(c) 1 1 14 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, conduct drug and alcohol program inspection in accordance with their procedures. 2 2 15 Is state verifying operators OQ programs are up to date? This should include verification 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 PSC conducts OQ Program evaluations in accordance with their procedures. 2 2 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 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: Yes, the PSC conducts IMP inspections at least every five years. 2 2 17 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, PSC is mainly conducting DIMP inspections at 3-5 year intervals. Reviewed inspection reports to verify intervals. 18 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 be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the PSC conducts Public Awareness at every 4-5 years intervals. 2 2 19 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 969115450 2017 Gas State Program Evaluation 1 1 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 9#
WI NG Program Evaluation, 2017, page 10The PSC files all cases and correspondence in the Electronic Regulatory Filing (ERF) on their website which is accessible by the public. 20 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 in Wisconsin in 2017. 1 NA 21 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: Yes, the PSC reviews annual reports and compares with previous years to check for any changes or discrepancies. Operator with plastic pipe with known defects have a removal program. 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, Mr. Stemrich responds to PHMSA and NAPSR surveys. 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: There are no waivers with special or more stringent operating conditions. 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, Mr. Stemrich attended the National NAPSR meeting in 2017. 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: The PSC analysis the performance metrics and find ways to improve the trends. Most trends have a positive trend. Only negative trend is the qualification of inspectors. There seems to be a downward trend on the 5 year retention of qualified inspectors. This is due to inspectors leaving the PSC and hiring new inspectors. 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: There does not seem to be any issue in meeting the inspection days as calculated by using the SICT. The PSC has lost 3 inspectors in the last two years which may impact meeting the number of inspection person days in the future. DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 10#
WI 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 Evaluator Notes: Conversion of service is covered in the inspection form which includes flow reversals. 1 1 28 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C.7- Reviewed the 2017 Northern State Power Company(Excel) inspection report and found that some sections were incomplete. The field portion was not completed in accordance with the procedures. The PSC needs to assure all applicable portions of the inspection report are completed. Total points scored for this section: 45 Total possible points for this section: 46 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 11#
WI 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: a. Yes, procedure is in Section Q of the Pipeline Safety Program Plan. b. Yes, the procedure is in Section S of the Pipeline Safety Program Plan. c. Yes, procedures are outlined in Section T and U Program Plan. 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: Yes, reviewed inspection files and compliance activities and they are very well documented. a. Yes, compliance actions are sent to company officers. b. Yes, probable violations were documented. c. Yes, probable violations are documented and resolved accordingly. d. Program Manager routinely reviews the progress of open cases. e. Yes, conduct post inspection briefing within 30 days. f. Yes, provide operator with preliminary findings within 90 days. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: addressed. Yes, reviewed inspection reports and compared with compliance actions to assure all probable violations discovered were 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 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: 2 2 Yes, the Program Manager is familiar with the civil penalty process. There were no civil penalties issued in 2017. DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 12#
WI NG Program Evaluation, 2017, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 0 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PSC has not issued a civil penalty in many years. The PSC needs to reconsider their civil penalty process and issue civil penalties were serious violations are discovered. For example, in reviewing the inspection reports and talking with Program Manager there have been some issues with inspector qualifications discovered by PSC inspectors during construction activities in particular dealing with fusing and welding inspector qualifications. Although the PSC is making the operator dig up and correct previous fusion and welding locations this is a good example that may have warranted civil penalties. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D.6- The PSC has not issued a civil penalty in many years. The PSC needs to reconsider their civil penalty process and issue civil penalties were serious violations are discovered. For example, in reviewing the inspection reports and talking with Program Manager there have been some issues with inspector qualifications discovered by PSC inspectors during construction activities in particular dealing with fusing and welding inspector qualifications. Although the PSC is making the operator dig up and correct previous fusion and welding locations this is a good example that may have warranted civil penalties. Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 13#
WI 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/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PS 104.4 has definition of accidents and reporting criteria. In addition Program Plan Section V! has Investigation of Incident procedures which addresses state actions taken during an incident. 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, the PSCWI has mechanism to receive and respond to incidents. Operators are notified every year on the which inspector to contact during an incident. If there is no answer the operator is instructed to call the next inspector in line. a. Yes, the PSCW is aware of the MOU between NTSB and PHMSA. b. Yes, the PSCW is aware of the federal/state cooperation in case of an incident. They are aware of the change of PHMSA's Accident Investigation Division. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 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 2017. The PSCW did go out on a house explosion which turned out not to be gas related. 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: There were no reportable incidents in 2017. The PSCW did go out on one house explosion to investigate. The explosion turned out not to be gas related. 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 investigated in 2017 1 NA 6 Did the state assist 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/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 14#
WI NG Program Evaluation, 2017, page 15The AID did not request assistance on any incidents but the PSCW is aware of the cooperation between PHMSA and states and would assist if requested. 7 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: PSCW shares any lessons learned during the regional NAPSR meeting. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: the PSC is mainly complying with Part E of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 15#
WI 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, the PSC has form which includes directional drilling procedures review during an inspection. 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, the PSC reviews the operators procedures during their inspections. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 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 PSC promotes damage prevention and the use of best practices during seminars, inspections and meetings. 4 Has the agency or another organization within the state collected data and evaluated 2 2 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: The PSC gathers and analysis the data per operator to find who has the most hits. PSC compares the operators that have pipelines in other states and compares the data. The PSC contacts and meets with operators with high number of hits to find why the numbers are high and find ways to try to lower the number of hits. 5 General Comments: Info Only = No Points Evaluator Notes: The 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 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 16#
WI 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: Wisconsin Public Service Name of State Inspector(s) Observed: Dagmar Vanek, Pipeline Safety Engineer Location of Inspection: Sheboygan, WI Date of Inspection: September 12, 2018 Name of PHMSA Representative: Agustin Lopez, State Programs Evaluator Notes: Evaluated Ms. Dagmar Vanek while conducting a construction inspection of Wisconsin Public Service replacing a main and service pipelines. Ms. Vanek conducted herself very professionally and is very knowledgeable of the pipeline safety rules and regulations. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, the operator was notified with enough notice to have representatives present. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Ms. Vanek took notes and documents findings in the construction form. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Ms. Vanek took notes of what she inspected and observed. 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, Ms. Vanek checked and inspected the equipment the operator was using during the fusion of PE pipe. 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: Yes, the inspector checked fusion procedures and OQ records of technicians performing the fusion. 2 2 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 17#
WI NG Program Evaluation, 2017, 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, Ms. Vanek is very knowledgeable of the pipeline safety program and regulations. She performed an outstanding inspection and was in charge at all times. She is a very good asset to the PSC. 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, she performed a brief exit interview after the inspections. Due to it being an ongoing project a final exit will be performed at a later date. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: There were no probable violations identified during the exit interview. 1 1 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 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 18#
WI NG Program Evaluation, 2017, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Ms. Vanek conducted a construction inspection of Wisconsin Public Service while replacing a main pipeline. She reviewed procedures and qualifications of the technicians while fusing PE pipe. She observed to assure procedures were being followed and verified pipe specifications. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 19#
WI 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: WPSC is 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: WPSC is 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: WPSC is 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: WPSC is 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: WPSC is 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: WPSC is 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: WPSC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: WPSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 20#
WI 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: The WPSC 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: The WPSC 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: The WPSC 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: The WPSC 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: The WPSC 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: The WPSC does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The WPSC 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 2017 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 21#
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