bring the Peoples Gas pipeline safety program into compliance with federal requirements and industry best practices; and (4)
prepare interim and final reports to the Commission regarding the results of its monitoring activities.
During the period from May 2007 through July 2008, Liberty acquired information from Peoples, interviewed employees,
observed field activities, conducted inspections, and took corrosion control readings.
In August 2008, Liberty provided the Commission with its Report on the investigation including 66 recommendations for
improvement. The Report states: “Liberty found many areas in which Peoples Gas has considerable room for improvement.
Common threads for the deficiencies were that (1) safety-related programs such as leak management and excavation damage
prevention did not have someone who had overall ownership and responsibility, (2) there was insufficient staffing in some areas
such that Peoples Gas was not performing important activities like field supervision, (3) training for many of the safety-related
programs was not sufficient, and (4) Peoples Gas did not monitor and measure its own performance and identify areas needing
Liberty subsequently began the verification-monitoring phase as specified in the contract where Liberty reports, on a quarterly
basis for two years, the progress that Peoples has made in implementing or addressing the 66 recommendations in Liberty’s
investigation report. Liberty will provide the final 8th quarterly report to the Commission in the near future.
Liberty provided the seventh of these quarterly reports on September 27, 2010. In the seventh report roughly covering the seven
quarters from December 2008 through August 2010, Liberty’s verification work is completed for 54 of the 66 recommendations
from the final investigation report. In the table starting on page 1 of the seventh report, Liberty highlights seven recommendations
that Liberty suggests ICC Staff continue verification work or monitor activities for those recommendations. Among Liberty’s many
observations in the seventh report, Staff believes the result of one recommendation was worth noting. Recommendation 111-17:
reduce the year end leak backlog. In reviewing results over the past two years Liberty observed:
“…an inadequate number of field repair crews, supervision, and miles of cast/ductile iron replaced for the past two years have
adversely affected Peoples Gas’ ability to reduce its leak backlogs at year-end…The challenge remaining for Peoples Gas
beyond the time period of Liberty’s verification audit is its ability to maintain an adequate number of experienced qualified field
personnel to accomplish all its safety code mandated requirements, reduce its leak backlog, and support its system
enhancement program. The issue of adequate resources to work leaks will be aggravated when Peoples Gas ramps up its
replacement efforts to almost 7-fold from 15 miles to over 100 miles of cast and ductile iron replacements during 2011 and years
following. During the past two years, it appears that Peoples Gas has not eliminated sufficient of its aging cast/ductile iron mains
and has not hired additional personnel at all levels including promoting and or hiring and training additional General Supervisors
to address its workload. Peoples Gas may not have accounted for the time and resources it takes to hire, train and qualify
personnel to perform code mandated gas O&M activities.”
The public versions of Liberty’s final investigation report and subsequent quarterly reports are available for downloading and
viewing from the Commission’s web site at http://www.icc.illinois.gov/naturalgas/ in the natural gas investigations section.
Investigation of Ameren’s Illinois Utilities’ Storm Outage
On July 19 and 21, 2006, windstorms struck the service areas of all three Ameren utilities in Illinois resulting in a loss of service
to more than 300,000 electric customers in Illinois. Restoring service to AmerenCILCO, AmerenCIPS, and AmerenIP customers
took over a week. On November 30, 2006, an ice storm struck central Illinois interrupting electric service to more than 200,000
Ameren Illinois customers. The Ameren utilities took about nine days to restore service to all their Illinois customers. The
Commission had previously adopted assessments of Ameren’s Illinois utilities’ electric service reliability that contained criticism
of Ameren utility tree trimming, other distribution line maintenance issues, and the placement of lightning arrestors and tap fuses.
These assessments had suggested that the condition of Ameren electricity delivery facilities could contribute to the effects of
storms on service to Ameren’s customers.
Recognizing the above facts, the Commission began an investigation of Ameren’s service restoration response to learn if it was
adequate and appropriate and to investigate the condition of Ameren’s electricity delivery facilities to learn if it contributed to the
large numbers of service interruptions during the storms. On August 29, 2007, the Commission signed a contract with The
Liberty Consulting Group (“Liberty”) to perform the Ameren investigation. Liberty began working under the contract immediately
and delivered its investigation report one year later on August 15, 2008. Liberty’s investigation report includes 157
recommendations for improving service reliability and shortening service restoration times after major storms. Liberty’s report is
available on the Commission’s web site at http://www.icc.illinois.gov/electricity/electricreliability.aspx; the file is labeled, “Liberty’s
Ameren Outage Investigation Report.”
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