{"operation":"document","citation":"PHMSA wi2010ngprogramevaluation","title":"2010 WI NG Program Evaluation - wi2010ngprogramevaluation (Wisconsin; Natural Gas State Program Evaluation)","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-01-01","effective_on":null,"summary":"2010 PHMSA natural gas program evaluation for Wisconsin.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wi-ng-program-evaluation-wi2010ngprogramevaluation.json","markdown":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wi-ng-program-evaluation-wi2010ngprogramevaluation.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-wi-ng-program-evaluation-wi2010ngprogramevaluation","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/126/wi2010ngprogramevaluation.pdf","body":"1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Natural Gas State Program Evaluation for WISCONSIN PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 1\n\n2010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: Wisconsin Rating: Agency Status: Date of Visit: 09/12/2011 - 09/16/2011 Agency Representative: Thomas Stemrich, Pipeline Safety Program Manager PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Phil Montgomery, Chairman Agency: Public Service Commission of Wisconsin Address: 610 North Whitney 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 2010 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 25 B Inspections and Compliance - Procedures/Records/Performance 23.5 23.5 C Interstate Agent States 0 0 D Incident Investigations 7 7 E Damage Prevention Initiatives 9 8 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 8 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 99.5 95.5 State Rating................................................................................................................................................... 96.0 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 2\n\nPART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as \"needs improvement\". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Yes, all information was submitted correctly. Wisconsin Public Service Commission (WIPSC) does not have jurisdictional authority over LPG operators and their state damage prevention law penalty only applies to pipeline operators. Minor corrections to attachments 1, 7 & 10 of the annual certification document were suggested to the Program Manager. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving \"after hours\" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: Yes, WI PSC Regulation 104.05 addresses this required information. At the end of each calendar year, WI PSC provides an annual written notification to all operators on who and how to notify the Commission regarding incidents. 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes, WI PSC held their pipeline safety seminar on February 15-18, 2011 in Wisconsin Dells, WI. They had 147 participates at the seminar. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: Yes, a review of their inspection file folders and other related documents found them accessible and well organized. The use of the agency's Electronic Regulatory Filing (ERF) system is a method they use to record and monitor their letters, inspection reports and response from the company officer pertaining to compliance with the pipeline safety regulations. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, Tom Stemrich has a good understanding of the regulations, compliance action the operator needs to take in making corrections to violations cited and submittal of certification and payment agreements pertaining to the pipeline safety grant. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark \"Yes\") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: period. Yes, Chairperson Eric Callisto response letter to Zach Barrett, PHMSA State Programs, dated November 22, 2010 was within the 60 day requested time DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 3\n\n7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark \"Yes\") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: Yes, in Chairperson Callisto letter he mentioned if the opportunity presents itself, we will again attempt to gain jurisdictional authority over LPG pipeline facilities. This opportunity has not be available during the latest legislative session. In regard to data being more transparent to the public, a hearing was conducted on December 7, 2010, for adoption of new state pipeline safety rules. One of the rules would require the operators to either participate in the CGA DIRT Program or submit their data through the Commission. No objections were submitted by the operators on the new proposed rules and the Commission is concerning adopting the rules. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: Yes, all pipeline safety personnel have completed the T&Q training courses except for Jeff Kluge who was hired on September 27, 2010. Jeff Kluge attended the PL1250, Safety Evaluation course on May 6, 2010 and is scheduled to attend two T&Q courses in calendar year 2011. As a reminder, Tom Stemrich and other individuals need to complete Int Corrosion Web Base Course (PL31C) in order to be qualified to perform Integrity Management Inspections. 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: No activity performed for calendar year 2010. For Operators: On October 21 & 22, 2010, Tom Stemrich presented information about pipeline safety regulations and new initiatives at PHMSA before the Utility Workers Coalition members at their meeting in Wisconsin Rapids, WI. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: No activity performed for calendar year 2010. Info Only Info Only SLR Notes: 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: year 2010. Yes, a review of training records indicate the lead inspectors have completed the required training prior to the time inspections were conducted in calendar 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 0 SLR Notes: No, a review of T&Q training records indicate lead inspectors Tom Stemrich and Jeff Murley have not completed the Int Corrosion WBT course PL31C. Therefore, a loss of one point was assessed. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 380.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.83 = 843.33 Ratio: A / B 380.00 / 843.33 = 0.45 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 DUNS: 969115450 2010 Natural Gas State Program Evaluation 5 5 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 4\n\nSLR Notes: A. Total Inspection Person Days (Attachment 2) = 380 B. Total Inspection Person Days Charged to the program (220*Number of Inspection person years (Attachment 7) =842.6 Formula:- Ratio = A/B = 380/843.33 = 0.450985 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 Yes, WIPSC had 380 inspection person days during 2010. The resulting ratio is 0.45 which exceeds the minimum ratio of 0.38, thus a 5 point score is awarded. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: Yes, on September 27, 2010, WI PSC hired a new pipeline safety inspector, Mr. Jeff Kluge. Mr. Kluge has a mechanical engineering degree and graduated from Marquette University in May, 2010. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: See question 11. Lose of one point due to lead inspectors not completing all Integrity Management courses prior to performing inspections. Tom Stemrich and Jeff Murley have not completed the Int Corrosion WBT course PL31C. Total points scored for this section: 25 Total possible points for this section: 26 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 5\n\nPART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: The revised and updated written procedures manual is titled, \"Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections. Several new items have been added to the document. A: Yes, page 1, item 1 B: Yes, page 4 C: Yes, page 4 D: Yes, page 1, item 1 and page 3 E: Yes, page 3 F: Yes, page 1, item 1 G: Yes, page 7 & 8 H: Yes, page 4 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: A: Yes, page 1, item 1 B: Yes, page 4 C: Yes, page 4 D: Yes, page 1, item 1 and page 3 Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: Safety Inspections. Yes, all operators and inspection units were inspected in accordance with the Public Service Commission of Wisconsin, Policy for Conducting Pipeline 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: checked by this writer. Yes. All questions in their database form are the same as the federal inspection questions. A review of the federal inspection form to their state forms was DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 6\n\n5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 SLR Notes: Yes. A review of several inspection reports found all information was complete and accurate with items found or noted. 1 1 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 .5 NA SLR Notes: NA. During calendar year 2010, there were no safety related condition reports submitted by intrastate natural gas operators located in the State of Wisconsin. 7 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: NA. The State of Wisconsin does not have cast-iron mains, service lines or pipelines located in their state. .5 NA 8 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) Previous Question B.8 Yes = .5 No = 0 SLR Notes: NA. The State of Wisconsin does not have cast-iron mains, service lines or pipelines located in their state. .5 NA 9 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) Previous Question B.9 Yes = .5 No = 0 SLR Notes: Yes. This item is reviewed during the standard inspection on a natural gas distribution system. .5 .5 10 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: Yes, this information is addressed in the standard inspection. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, information located in their Electronic Regulatory Filing (ERF) system database indicates documentation is being used to monitor probable violations. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the \"Guidelines for State Participating in the Pipeline Safety Program\"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: this item. Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections, page 4, Notification & Follow-up Procedures, addresses 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the \"Guidelines for States Participating in the Pipeline Safety Program\"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 969115450 2010 Natural Gas State Program Evaluation 1 1 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 7\n\nSLR Notes: this item. Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections page 4, Notification & Follow-up Procedures addresses 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the \"Guidelines for States Participating in the Pipeline Safety Program\"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections items 3 & 4 on page 4, Notification & Follow-up Procedures addresses this item. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: been corrected. Yes, a review in Electronic Regulatory Filing System (ERF) indicated all probable violations are issued and tracked for compliance until the violations have 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the \"Guidelines for States Participating in the Pipeline Safety Program\"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: System. Yes, this is addressed in the Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections, and Electronic Regulatory Filing 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a \"Show Cause Hearing\" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: Yes, WIPSC has the authority to issue a show cause against the operator for non-compliance. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, their written procedures and files indicate they adequately documented all probable violations. 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 SLR Notes: addresses this item. Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections items 5 on page 4, Notification & Follow-up Procedures 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, Wisconsin Public Service Commission rules 196.26 or 196.28 address this requirement. 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DUNS: 969115450 2010 Natural Gas State Program Evaluation 1 NA Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 8\n\n22 SLR Notes: Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 SLR Notes: Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA 25 SLR Notes: Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 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) Info Only = No Points Info Only Info Only SLR Notes: plastic fusion. Yes, Tom Stemrich is familiar with this process and has used civil penalties on Mid West Natural Gas in 2001 for failure to properly qualify individuals on 28 Part B: General Comments/Regional Observations Info Only = No Points SLR Notes: No Comments. Info Only Info Only Total points scored for this section: 23.5 Total possible points for this section: 23.5 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 9\n\nPART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 2 Are results documented demonstrating inspection units were reviewed in accordance with \"PHMSA directed inspection plan\"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 1 NA SLR Notes: 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 NA SLR Notes: 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 10\n\nPART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in \"Guidelines for States Participating in the Pipeline Safety Program\") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections, Incident Investigations, page 7, addresses this item. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in \"Guidelines for States Participating in the Pipeline Safety Program\") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 .5 .5 SLR Notes: Yes. However, consideration should be taken to include this memorandum of understanding between NTSB and PHMSA in the Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections document. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, Wisconsin Public Service Commission keeps telephonic incident reports by year in a file folder. 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Wisconsin Public Service Commission policy is to response to all potential incidents. 1 1 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: No incidents occurred in 2010. 2 2 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: No incidents occurred in 2010. 1 1 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: Form F 7100.1 Yes. Wisconsin Public Service Commission has responded to PHMSA Central Region within ten days of an accident or information pertaining to the DOT 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: No comments. DUNS: 969115450 2010 Natural Gas State Program Evaluation Info Only Info Only Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 11\n\nTotal points scored for this section: 7 Total possible points for this section: 7 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 12\n\nPART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, this requirement is reviewed by the engineer during a damage prevention review of the operator's O & M Plan. 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? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes, this is reviewed during the standard inspection. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Yes, they continue to promote the adoption of the Common Ground Alliance Best Practices at the Wisconsin Digger Committee for Damage Prevention meetings. The commission's proposed rules will require all natural gas operators under their jurisdiction to report all damages via the DIRT program. 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? New 2008 Yes = 1 No = 0 1 0 SLR Notes: No. They continue to encourage operators to report damages via the DIRT program on CGA's website, but the collection and review of data on the number of pipeline damages per 1,000 locate requests is not available. The agency's proposed rule making will require this data to be filed with the WI PSC in the future. The proposed rules may be effective at the end of calendar year 2012. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes, this is reviewed in the standard inspection form and all operators are required under their commission's rule to report all accidents or incidents. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: Loss of one point pertaining to question E.4. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 9 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 13\n\nPART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Wisconsin Gas Company (We Energies) Name of State Inspector(s) Observed: Tom Stemrich, Jeff Kluge and JeffMurley Location of Inspection: Milwaukee, WI Date of Inspection: September 15, 2011 Name of PHMSA Representative: Glynn Blanton, US DOT/PHMSA SLR Notes: This inspection was conducted in We Energies conference room located at their service center location in Milwaukee, WI. Tim Strommen, Manger- Regulatory Compliance Pete Schneider, Standards Analyst, Gas Regulatory Compliance Leif Monson and Scott Olson, Engineer- Regulatory Compliance Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: Yes, the operator's offical representatives were contacted by Tom Stemrich two weeks prior to the standard inspection. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: Yes, the inspectors used the Microsoft software program entitled, \"WGC 2011\" to perform the standard inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: Yes, the inspectors thoroughly documented each of the responses from the operator on compliance questions asked about their O & M procedures. 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.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes, the operator representatives had available their O & M plan or other relative information pertaining to the standard inspection being conducted. 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: Standard inspection. 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records DUNS: 969115450 2010 Natural Gas State Program Evaluation 2 2 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 14\n\nc. Field Activities/Facilities d. Other (Please Comment) SLR Notes: This was an office records review of the operator's O & M procedures and records. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: Yes, each inspectors adequately demonstrated their working knowledge of the pipeline safety and WI PSC regulations. 2 2 9 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) Previous Question F.10 Yes = 1 No = 0 SLR Notes: Yes, the inspectors conducted an exit interview with the operator providing information on areas of compliance. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: No areas of probable violations were found or noted during this inspection. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Info Only = No Points SLR Notes: This was an office records review and no outside field inspection was performed. Info Only Info Only 12 SLR Notes: Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points Info Only Info Only 13 Field Observation Areas Observed (check all that apply) 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 DUNS: 969115450 2010 Natural Gas State Program Evaluation Info Only Info Only Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 15\n\nr. 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 D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: Due to time limitations a field inspection was not observed. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: distribution system. The engineers conducted a very professional inspection and discussed with the operator representative areas of change that will improve their natural gas Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 969115450 2010 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 16\n\nPART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: Yes, Wisconsin Public Service Commission's Criteria for Inspecting Natural Gas Utilities address these items on page 2, section 7. 1.5 1.5 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Inspection units are broken down appropriately using the guidelines for states participating in the pipeline safety program and other information available to them. Consideration should be taken to add the definition of \"inspection unit\" to the Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections. 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points Info Only Info Only SLR Notes: WIPSC staff members have contacted their natural gas operators inquiring about the status of the operator's DIMP plan by email and letter. Staff members anticipate reviewing all DIMP plans by year end 2011. 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: .5 0.5 Yes, Public Service Commission of Wisconsin, Policy for Conducting Pipeline Safety Inspections page 2, section 7 addresses this item. Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0 Yes = .5 No = 0 SLR Notes: No. The agency is encouraging all gas operators under the Wisconsin Public Service Commission jurisdiction to participate in the CGA DIRT Program but no analysis is being reviewed or performed. Therefore a loss of 0.5 point was assessed. 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: Yes. This is a requirement in WIPSC rules and regulations Section 135.016. .5 0.5 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: known to be of concern. Yes, this is reviewed as the document is filed by staff members to see if the operator has an increase in leakage or removal of plastic pipelines that have been 8 Has state reviewed data on Incident/Accident reports for accuracy? Ye","truncated":true,"body_characters":53805}