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PHMSA wi-2020-gas-program-evaluation
2020 WI NG Program Evaluation - wi-2020-gas-program-evaluation (Wisconsin; Natural Gas State Program Evaluation)
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WI NG Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for WISCONSIN PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 1#
WI NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Wisconsin Rating: Agency Status: Date of Visit: 07/12/2021 - 07/15/2021 Agency Representative: Alex Kirschling PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Becky Valcq, Chairman Agency: Public Service Commission of Wissconsin Address: 4822 Madison Yards Way City/State/Zip: Madison, Wissconsin 53705 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 45 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 95 State Rating................................................................................................................................................... 95.0 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 2#
WI NG Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: Progress report reviewed, the following were discussed with the program manager. > Civil Penalties not the same as PHMSA > What steps are being taken to get authority over LPG operators > Attachment1 = 53 operators, and attachment 2 = 44. Whats the difference > WIPSC has 2 supervisors. Should one be in the indirect cost category. If left in budget, must explain their duties and responsibilities. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 3#
WI NG Program Evaluation, 2020, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Yes the WI PSC procedures for conducting inspections are found in section V of their manual. 5 5 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Yes, the required information can be found in Section IV of the WI PSC procedures manual 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Yes, the required information is in Section V Part Q of the WI PSC procedures manual 3 3 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Yes, the required information can be found in Section VI of the WI PSC procedures manual 3 3 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 4#
WI NG Program Evaluation, 2020, page 55 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 5#
WI NG Program Evaluation, 2020, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 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 b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Reviewed all training records on PHMSA TQ Blackboard and verified training status of lead inspectors while reviewing last years inspection documents. TQ has been doing Virtual Training almost exclusively during CY 2020 2 Did state records and discussions with state pipeline safety program manager indicate 5 5 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, my discussions with Alex, (Program Manager) he showed he possesses an adequate knowledge of PHMSA programs and regulations 3 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 6#
WI NG Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 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 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 5 0 Evaluator Notes: Reviewed records and documents from 2020 inspections and the Random Operators List and founds that no inspections were made on master meter operators for over 5 years. However the program did work in 2020 to verify how many master meter operators they actually have. They worked from a data base list of over 250 and narrowed it down to 35 and then 22 thru letters and physical visits. They plan to start the inspection process next year while working with the MM operators to have their systems converted back to the local DC. (self reported by state). A loss of 5 points 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: The program has updated their forms and process for inspections. 10 10 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they are conducting OQ Program evaluations in accordance with their procedures, and check employee certifications during filed inspections. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? 2 2 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 7#
WI NG Program Evaluation, 2020, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes, they are conducting IMP field verification inspections in accordance with their procedures. They also meet in person with their largest operators in 2020. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: The state has no known cast iron facilities. NTSB recommendations P-00-20 and P-00-21 questions added to states forms. There are no low pressure systems operated in the state. They have meet with their operators on inside meter and regulator sets and have even written them up for not performing surveys in the established times. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, They have added questions to their inspection forms and have let operators know of the concerns surrounding inside meter and regulator sets. 7 (Compliance Activities) 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 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) 10 10 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 8#
WI NG Program Evaluation, 2020, page 9h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: The state has rewritten their procedures and changed the process for notifying the operator of findings (probable violations) so that letters to the operator go out within 90 of completing the inspection. They have also have a process for tracking the PV's until cleared. The state exercised their fining authority and used their civil penalty process in 2020. Air Liquide was fined $52,395.50 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did 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? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: Review of 2020 incident investigations found no issues. 10 10 9 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 = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Chairman's letter was sent on 10/26/2020 and the response was sent on 12/23/2020. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes, the state hosted an in-person seminar in 2019 and held a virtual seminar in 2020. They hope to be back in person this coming year. 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes, reviewed letter sent by WPSC to operators who didn't submit in 2020. Info Only Info Only DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 9#
WI NG Program Evaluation, 2020, page 1012 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: Yes the WPSC has a web site for the public that they did several updates to in 2020. 1 1 13 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's for 2029 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, reviewed responses by state to NAPSR surveys and questions. The PM keeps a list of these. 1 1 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: They have a single waiver that has been reviewed and approved by PHMSA that is not on the PHMSA website. They will contact the appropriate person to get this fixed. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Info Only Info Only Yes, however the inspection process for Standard Comprehensive inspections is still hard to follow for inspections conducted in 2020. However, the state has redone their inspection forms and format and the inspections in 2021 are easier to follow. 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: Discussed with PM and noted that they had been required to complete 558 days and they completed 655 during 2020. Encouraged the PM to make sure that the numbers of what is needed to complete the years required inspections and to not worry about low balling the number to cover the unexpected loss of an inspector or more. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Reviewed the state performance metrics found in the PHMSA web-site, and discussed the changes and trending for each metric with the program manager. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ Info Only Info Only DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 10#
WI NG Program Evaluation, 2020, page 11b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Yes, they have added questions to their inspection forms. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D1. Reviewed records and documents from 2020 inspections and the Random Operators List and founds that no inspections were made on master meter operators for over 5 years. However the program did work in 2020 to verify how many master meter operators they actually have. They worked from a data base list of over 250 and narrowed it down to 35 and then 22 thru letters and physical visits. They plan to start the inspection process next year while working with the MM operators to have their systems converted back to the local DC. (self reported by state). A loss of 5 points Total points scored for this section: 45 Total possible points for this section: 50 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 11#
WI NG Program Evaluation, 2020, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Field Inspection of service line leak survey conducted by Wisconsin Electric and Gas WEGO. Evan Uphoff was the state inspector observed. (Inspection observed virtually on iphone). Company rep was present. Info Only Info Only 2 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 the states forms for leak survey and OQ. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: The inspector had electronic access to the companies procedures. The inspector observed the company employee conduct the survey and asked appropriate questions. The inspector asked for and reviewed the employees OQ certification. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the inspector showed he possessed adequate knowledge of the pipeline safety program and the regulations. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The inspectors do a short exit at the end of each day to discuss violations and concerns with the operators representatives that are on site. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points Info Only Info Only DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 12#
WI NG Program Evaluation, 2020, page 13a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: Yes, the inspection was conducted in a safe, positive and constructive manner. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: This field evaluation was conducted virtually using Microsoft Teams on the PM's phone. Observation of the entire area around the inspection was hard to see. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 13#
WI NG Program Evaluation, 2020, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, and the have asked operators for more information, including on 1st and 2nd party damages. They receive these reports and review each one. They have asked for some operators that had a lot of incidents listed as other to go back and put them under a category. The state is in the process of writing a procedure for this. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The state started collecting and reviewing this data in 2020. They have also added questions to their inspection forms to cover this. Operators have started using a tiered enforcement process to address bad excavators. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: The state is evaluating the cause of damages and working with operators to get a accurate root cause for each one. The state has NO formal certification process for locators. The state law requires locate requests to be submitted three days before excavating so the have very few instances where the locates are not done on time. The state is adding questions to their records review to cover this. 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? Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 14#
WI NG Program Evaluation, 2020, page 15a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: Yes, the state has started to ask for and collect this information. Added questions to inspection forms. State one call is doing online training and in person training. Operators have personnel involved with the One Call Board. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 969115450 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 15#
WI NG Program Evaluation, 2020, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: WIPSC is not an Interstate Agent Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: WIPSC is not an Interstate Agent 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: WIPSC is not an Interstate Agent Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: WIPSC is not an Interstate Agent Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: WIPSC is not an Interstate Agent Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: WIPSC 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 2020 Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 16#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.