Pipeline Inspections

​​​​< Pipeline Safety Prog​ram

This page explains the inspections that the Wisconsin Pipeline Safety Program conducts.  All inspections involve ensuring operators adhere to the requirements in 49 CFR Part 192, PSC Chapter 135, and any order points issued by the Commission.
Inspections must be conducted at a minimum frequency indicated for each inspection type. Some inspections, such as construction, are conducted many times throughout the year as operators perform work on their facilities. Other inspections are scheduled so the operator can retrieve the necessary documents.
Some types of inspections are conducted in the field observing individuals acting on pipeline facilities. Other inspections are conducted in operator offices to review their paperwork including procedures and records. 

Operation and Maintenance (O&M) Plan

• Annual or every two years
• Procedures

Every operator is required to have an O&M plan containing procedures covering a wide range of topics that they must follow to operate and maintain their pipeline facilities. State and federal code specify what topics these plans must cover at a minimum to ensure they operate safely for many years. The pipeline safety team regularly reviews each operator’s O&M plan using an internally developed tool to ensure they meet code minimums and adequately address topics that the pipeline safety team have concerns about from other inspections, field visits, or industry-wide concerns.

Emergency Plan

• Annual or every two years
• Procedures 

Every operator is required to have an Emergency Plan containing procedures they follow if an emergency occurs on or near their facilities. Preparing procedures in advance ensures that operators are ready to act if there is an emergency. Operators are required to communicate with local emergency responders to inform them of where their facilities are located, the specific characteristics of their facilities, and what actions the emergency responders or the operator is responsible for in different emergencies.
The pipeline safety team regularly inspects each operator’s Emergency Plan to ensure it meets code requirements and covers all emergencies that can be anticipated on the operator’s specific facilities. The team also inspects records of previous times the Emergency Plan was use to respond to a situation and what could be done for future emergencies to improve the response.

Records

• Annual
• Records

Every operator is required to create and maintain records of the important actions they perform on their pipeline facilities. Each year the pipeline safety team reviews each operator’s records using an internally developed tool to ensure that they are performing the required activities, they are doing them at the appropriate frequency, and they perform follow-up necessary to correct any potential issues they find. 

Construction

• Many times each year
• Operations (in the field)

New natural gas construction and maintenance construction activities happen across the state throughout the entire year.  The pipeline safety team is required to complete a minimum of 20% of their inspection days in the field auditing construction activities with all the operators in the state.  Historically though that number has been closer to 30% due to the importance of audit.
While at the construction sites inspectors check to make sure that personnel have the correct training and qualifications for the activities being performed, the operator’s procedures are being followed correctly, and that all the work being performed conforms to required PSC Chapter 135 and Part 192 regulations and statutes.

Regulator Stations

• Annually with each station inspected at least once every five years
• Operations (in the field)

Operators are required to annually inspect and perform maintenance on their pressure regulating stations to ensure reliable operation and adequate over-pressure protection.  To verify that this work is being performed regularly the pipeline safety team visits different areas for each operator annually to inspect the stations such that all stations are inspected in any five-year period.
Inspectors utilize an internally created inspection form that summarizes the applicable requirements of Part 192 and PSC Chapter 135 to check that each station meets those requirements.  That includes items such as the condition of piping and regulators, electrical protection levels of the pipe, location and access of valves, security fencing, and overall site conditions.  

Operations and Maintenance Field Activities

• Annually 
• Operations (in the field)

Every operator is required to perform periodic maintenance and inspections on their system such as performing leak surveys, maintenance on emergency valves, checking odorant levels throughout their system, taking reads on their electrical protection system, and performing maintenance on their regulator stations.  The pipeline safety team goes out in the field to different areas of the state each year to confirm that these tasks are both being performed as they are required and that the operator personnel have adequate knowledge and skills to do the specific work being observed.
The inspectors go to each area of the state at a minimum once every five years and make sure that the operator personnel follow the applicable Part 192 and PSC Chapter 135 regulations in addition to the operators’ own internal procedures.

Public Awareness Program (PAP)

• At least once every five years

• Procedures and Records

Every operator is required to have a PAP. These programs must include procedures for informing members of the public, excavators, emergency officials, and public officials of their pipeline facilities. The information includes recognizing gas leaks or unsafe situations, what to do in these situations, contacting Diggers Hotline to dig safely, and how to request additional information from the operator. Additionally, the operator conducts surveys to ensure that this information reaches these different groups and changes their messaging if needed. 
The pipeline safety team regularly inspects each operator’s PAP plan using an inspection form provided by PHMSA. The team’s inspection includes verifying that the operator’s PAP covers all appropriate facilities, that the messages to different groups contain the requisite and relevant information, that surveys are being conducted for each group, the results of the surveys are being analyzed, metrics such as the number of leaks are taken into consideration for a successful program, and the program is adjusted if the surveys or metrics indicate concerning trends. 

Anti-Drug and Alcohol (D&A) Plan

• At least once every five years

• Procedures and Records

Every operator is required to have a D&A plan. These plans contain procedures for ensuring personnel performing activities that directly impact the pipeline are not under the influence of drugs or alcohol. Employees and contractors in these roles must be tested before starting their role and randomly throughout the year.
The pipeline safety team regularly inspects each operator’s D&A plan’s procedures and records. These inspections include verifying that the labs used have been certified, tests adhere to code requirements, an appropriate percentage of employees and contractors are randomly tested annually, employees are informed of an employee assistance program, test results are confidential and reported appropriately, employees have access to the D&A plan, employees are aware of their expectations, among other topics. 

Operator Qualification (OQ) Program

• At least once every five years

• Procedures, Records, and Operations (in the field)

Before individuals can perform certain actions on an operator’s facilities, the individuals must be qualified. Each operator has a plan explaining what an individual must do to qualify to perform each specific task and how frequently they must requalify. Operators and contractors train their employees about all the details of how to perform a specific task, how to recognize if something is going wrong with that task, and what to do in the situation that something goes wrong. Operators can also revoke an individual’s qualifications if the individual performs a task incorrectly or the operator has concerns that the individual cannot successfully perform the task. If an individual’s qualifications have been revoked, they may be able to retrain and requalify depending on what an operator’s OQ program specifies.
The pipeline safety team regularly inspects operator’s OQ programs. They ensure the procedures meet code requirements; the operator uses appropriate hands-on assessments, tests, certifications, or other methods to qualify individuals, the operator maintains records of its activities for qualifying, disqualifying, or requalifying individuals; and checking individuals in the field are qualified to perform tasks that the pipeline safety team is observing.

Integrity Management Program (IMP) 

• At least once every five years for procedures and records and as needed when field activities are conducted
• Procedures, Records, and Operations (in the field)

Transmission pipelines are defined in 49 CFR 192.3. These are often pipelines carrying gas at a higher pressure than main pipelines.
Operators that have a transmission pipeline must have an Integrity Management Program. In these programs operators are required to analyze the risks to their transmission facilities. In areas frequented by members of the public operators must also conduct regular assessments of these pipelines to catch signs of potential issues well before they become serious. These inspection methods often utilize advanced tools and specialized contractors. If an issue arose on these lines, the consequences would be serious. Because of this, these assessment methods can spot issues early so they can be corrected before becoming safety concerns.
The pipeline safety team regularly inspects operator’s procedures and records using inspection forms developed by PHMSA to ensure these meet federal and state code requirements. The procedures are inspected to ensure that operators analyze the risks to their transmission pipelines appropriately, they pick appropriate assessment methods, they perform assessments on an acceptable schedule, and they use the assessment results to address any issues that came up.
The pipeline safety team also inspects the field assessments that operators conduct using internally developed inspection forms to ensure that procedures are followed appropriately. These inspections happen in the field on an ad hoc basis, but the largest operators conduct at least one assessment every year.

Distribution Integrity Management Program (DIMP)

• At least once every five years
• Procedures and Records

Similarly to transmission operators, operators of a distribution system are required to have an Integrity Management program where they are required to identify and analyze risks to their distribution system. Through typical construction, operations, and maintenance activities operators are required to collect information of their system and then use that information to identify potential risks to their system and evaluate those risks then rank which of those risks are most dangerous to their system.  Finally, they are required to come up with measures to address the specific risks to their system and periodically re-evaluate everything previously described.
The pipeline safety team utilizes an inspection form developed by PHMSA to ensure that each distribution integrity management program meets all federal and state code requirements and conducts this inspection at least every 5 years where inspectors go through the program procedures for compliance with the regulations and then go through all the records since the last audit was completed.

Control Room Management (CRM)

• At least once every five years
• Procedures, Records, and Operations (in the field)

Certain operators that have a controller that can operate all or part of their system through supervisory control and data acquisition are required to have a control room management plan unless they are a distribution operator whose control room covers less than 250,000 customers.  The pipeline safety team inspects these control rooms utilizing an inspection form created by PHMSA. As part of the audit inspectors go through procedures and records pertaining to controller training, controller fatigue mitigation, how controllers handle alarms and emergency events, the capabilities of the control room and the controllers, and how they incorporate lessons learned from operating events into procedures.

Damage Prevention

• Annual
• Procedures and Records

192.614 requires operators to have a program to prevent damage from excavation activities.  There is no audit specific to this program, however it is reviewed regularly with operators once every year or two years as part of the operations and maintenance audits and records audits that are done with each operator.

Liquefied Natural Gas (LNG)

• At least once every three years
• Procedures, Records, and Operations (in the field)

There are several liquefied natural gas plants that are operating in Wisconsin or are in the process of being built.  Due to the nature of these plants the pipeline safety team inspects them on an accelerated cycle, once every 3 years.  This audit is comprised of 3 different parts: procedures, records, and a field inspection portion.  Each piece of this audit utilized an inspection form created by PHMSA to ensure compliance.
During the procedures portion inspectors go through their operation and maintenance procedures as well as their emergency plan.  During the records portion inspectors go through operating and maintenance records for the prior 3 years, including if there were any sort of emergency events then the inspectors would look at those with extra scrutiny.  Finally, for the field portion inspectors will go out in the field to the plant and walk down the entire area, checking for adequate security and lighting, overall condition of pipe, pipe racks, and pipe insulation, tank and impoundment condition, the fire protection system, and overall condition of the plant grounds.

Excavation Damage Complaints

• As needed
• Data requests

Wisconsin’s one-call statutes allow individuals to file complaints with the Diggers Hotline Enforcement Center.  Damage to a buried utility is not required for a complaint to be filed, but here are limitations on who can file a complaint and for what circumstances:

1. The incident must involve natural gas or other hazardous materials.
2. Submissions may not be filed more than 120 days after the discovery and an alleged violation.
3. Submissions can only be filed by facility owners, excavators, and underground line locators.

Complaints are then reviewed by a Diggers Hotline panel comprised of industry stakeholders who determine whether there is probable cause that there was a violation of the one-call statutes.  If there is probable cause, then the panel will either refer the excavator for education or refer the complaint to the PSC depending on the severity of the violation.
Once the PSC receives a complaint then Commission staff begins by reviewing the information that was forwarded by the Diggers Hotline Panel then reaches out to all the parties involved in the incident through data requests to gather as much information as possible to come up with a complete picture of what happened.  There can sometimes be several rounds of data requests needed to capture all needed information.
Once there is enough information, then Commission staff analyzes everything for compliance with the state one-call statutes then provides their analysis and conclusion to the Commissioners at which point there is 3 possible outcomes the Commissioners can decide upon: dismissing the complaint, issue a fine per violation, or enter into a consent agreement with both parties.