# 2016 AL NG Program Evaluation - al-2016-gas-program-evaluation (Alabama; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA al-2016-gas-program-evaluation
- **title:** 2016 AL NG Program Evaluation - al-2016-gas-program-evaluation (Alabama; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-01-01
- **effective on:** Not available
- **summary:** 2016 PHMSA natural gas program evaluation for Alabama.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/2711/al-2016-gas-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2016 Gas State Program Evaluation for Alabama Public Service Commission Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 1

2016 Gas State Program Evaluation -- CY 2016 Gas State Agency: Alabama Rating: Agency Status: Date of Visit: 06/26/2017 - 08/11/2017 Agency Representative: Wallace Jones, Sr. - Director, Gas Pipeline Safety Division PHMSA Representative: Patrick Gaume & Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Twinkle Andress Cavanaugh, President Agency: Alabama Public Service Commission Address: 100 N. Union St., Suite 800 City/State/Zip: Montgomery, Alabama 36104 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 2016 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9.5 B Program Inspection Procedures 13 13 C Program Performance 49 46 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 117 113.5 State Rating................................................................................................................................................... 97.0 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: A1. NI. 0.5 of 1pt. The Attachment 1 Unit counts were incorrect. Revision has already been made. The revision will be in agreement with Attachment 3. Attachment 1 is in agreement with Attachment 8. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A2. Yes. The inspection person days on Attachment 2 matched the APSC's 2016 inspection records 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A3. Yes. The APSC's listing of operators and units matched the spreadsheet listing kept by the APSC. The number of units on Attachment 3 demonstrated the Attachment 1 errors. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A4. Yes. There were two significant incidents or accidents in 2016. Both were investigated on-site. It is APSC practice to onsite investigate all significant incidents or accidents. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A5. Yes. There were no errors found on Attachment 5. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A6. Yes. Attachment 6 is accurate. APSC paper records are now 'old' records. The official records for current records are now electronic. There is an effort to scan recent paper records and place them into the electronic database. Currently the 'official' records are in paper form (older) and electronic (newer). The records are found as appropriate on the 9th floor. The electronic files are backed up onto the server. I recommended that the server be backed up to off-site storage. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes. Attachment 7 appears to be correct. These time allocations are submitted to accounting and are applied to the following year. There appears to be a small time allocation variation from year to year. 100% time is dedicated to pipeline safety with some employees having time split between HL & NG. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 3

Evaluator Notes: A8. Yes. Attachment 8 appears to be correct. No discrepancies were found with the APSC's Attachment 8 information. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A9. Yes. No issues identified with Attachment 10. It is s a good description of the APSC's program. 1 1 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A10. Yes. The error in Attachment 1 resulted in a 0.5-point reduction. It is noted that, effective June 26, 2017, the Director now has authority to recommend civil penalties for violations of the regulations through an administrative process and not have to go through a Formal Hearing. Operator privilege to request a Hearing is preserved. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: B1. Yes. APS Operations Plan Sec V subsection B&C; &G; & S,T,& U. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B2. Yes. APS Operations Plan Sec V subsection B&C; & N & P; & S,T,& U. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B3. Yes. APS Operations Plan Sec V subsection B&C; &I; & S,T,& U. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B4. Yes. APS Operations Plan Sec V subsection B&C; &M; & S,T,& U. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes. APS Operations Plan Sec V subsection L. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B6. Yes. APS Operations Plan Sec V subsection H. Also B&C; & S,T,& U. APSC uses its State Form, and The State Form appears adequate, but they will also use the federal construction forms, Form 05 & Form 07, which are the federal construction forms for NG & HL as needed. 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 5

b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: B7. YES, 6 of 6 points. APSC uses a detailed spreadsheet and also APS Operations Plan Appendix D (mostly for Standard insp), Also Sec VI subsection A Background (specifically for construction, incidents & accidents). Yes for parts a,b,c,d,e,& f. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only B8. Yes. The APSC procedures are well developed and highly functional. Full points were awarded in this Section. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 942.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 7.30 = 1605.27 Ratio: A / B 942.50 / 1605.27 = 0.59 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes. NG Total Insp Person Days is 942.5. Total insp person days charged to the Program is 7.30 years or 1606 days. The ratio is 942.5/1606=0.587. 0.587>0.38. 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: C2.Yes, Yes, Yes, Yes, Yes. All lead inspectors are qualified to Standard, imp, OQ, & 3 inspectors have taken Root Cause. Outside training includes several inspectors with extensive industry experience, H2S training, Offshore Training, & current HAZWOPER Certification. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: C3. Yes. Wallace Jones demonstrates a professional knowledge of the Pipeline Safety Program. He has also completed the required TQ classes and most electives too. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: C4. Yes. Letters, dated 12/1/16 & 1/19/17, are within the 60 day response time, especially considering mail time. All eight required items were addressed. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: C5. Yes. The last seminar was held in November of 2016. The APSC conducts its seminar annually. In addition, APSC co- hosts the annual TQ Seminar in New Orleans. DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 7

6 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 5 4 Evaluator Notes: C6. NI. 4 of 5 points. The frequency of Standard Inspections are in good order. PAPEI are in good order. Construction & incident inspections are fine. All 8 LIMP inspections are within the 5 yr frequency. All TIMP inspections are now current save two. Those two are currently being performed and waiting on additional information from the operators. This is a best effort considering their available manpower. It was discovered that 137 of 141 OQ Program inspections (NG & HL total) were beyond the 5 yr frequency during the CY2014 Program Evaluation. 64 Operators were OQ re-inspected by the CY2015 Program Evaluation. 50 more Operators were OQ re-inspected by the CY2016 Program Evaluation. Operator count has been reduced from 141 to 134 currently (126 NG & 8 HL). A plan is in place to perform the remaining 16 operator OQ inspections during the remainder of 2017. This is a best effort considering their available manpower. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C7. Yes. Seven files of inspections with probable violations were reviewed which included both NG & HL. All were found to be satisfactory. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C8. Yes. it is covered on the Standard Inspection forms 1 1 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C9. Yes, it is covered on the Standard Inspection forms. 1 1 10 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) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C10. Yes, it is covered on the Standard Inspection forms. 1 1 11 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? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C11. Yes, it is covered on the Standard Inspection forms. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 961833431 2016 Gas State Program Evaluation 2 2 Alabama Alabama Public Service Commission, Page: 8

C12. The APSC reviews the data from annual reports and utilizes a major portion of the data in its risk model. The APSC has been utilizing trend charts for cast iron replacement since 2008. 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C13. Yes. the OQ and IMP databases show regular and recent uploading of inspections. 2 2 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: C14. Yes, The APSC uses Form 1, the federal form for the inspection of gas transmission pipelines. The requirement for NPMS is on Page 3 of the federal form. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C15. Yes. The APSC reviews program changes during each standard inspection. The APSC conducted 108 drug and alcohol inspections as a part of standard inspections during 2016. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C16. Yes. All operators' OQ programs have been inspected. The APSC reviews compliance with Protocol 9 during each Standard Inspection. The APSC performed and uploaded several OQ Program reviews and field portion (Protocol 9) reviews during 2016. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C16. Yes. All operators' OQ programs have been inspected. The APSC reviews compliance with Protocol 9 during each Standard Inspection. The APSC performed and uploaded several OQ Program reviews and field portion (Protocol 9) reviews during 2016. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 1 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C18. NI 1 of 2 points. All DIMP have been done and have successfully uploaded 92 into the database. The remaining 11 have been uploaded but are not showing in the database. APSC contacted its inspection staff to find and upload (or re- upload) the missing 11 inspections. They were not found. The 11 DIMP re-inspections are now scheduled for 2017. DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 9

19 Is state verifying operators Public Awareness programs are up to date and being 2 1 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should have been completed by December 2013. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C19. NI 1 of 2 points. All PAPEI have been done and 95 have been successfully uploaded into the database. APSC contacted its inspection staff to find and upload (or re-upload) the missing 10 inspections. They were not found. The 10 PAPEI re-inspections are now scheduled for 2017. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C20. Yes. The APSC posts pipeline safety information on the Commission's website. The APSC participates in and makes presentations at Alabama Natural Gas Association meetings; Also the annual Alabama Damage Prevention Summit. 21 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: C21. YES. The SRC reported in 2016 was addressed. 1 1 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C22. Yes. The APSC has included Question 39 on their inspection forms which cover the issue of plastic pipe and component failures. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C23. Yes. APSC fully participates with NAPSR & PHMSA. 1 1 24 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: C24. Yes. APSC has been involved with five waivers, and two are still active. The inactive waivers were for short term and special case and they expired. An active waiver was issued in 2009 to Alabama Gas Corp for un-odorized gas to be delivered to Hunt Oil Corp. That contract is still active and the waiver is still active. New for 2015, Exxon-Mobil installed some new reinforced thermoplastic pipe (RTP); the PHMSA contact was Max Kieba. It will be a 5 yr study. 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being 1 1 evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: C25. Yes. The APSC sent three employees to the National NAPSR Meeting, including the Program Manager. DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 10

26 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: C26. Yes. The PM pulled up the data. The information appears to be accurate. The PM plans to compare this data with his internal data. This information appears to hold promise to be of value. Damage Prevention Program; leaks per thousand are generally flat. Inspection Activity; AL is meeting its inspection goals and is looking to fill its open position ASAP Inspector Qualification; AL is fully focused on inspector training. Leak Management; AL is monitoring; no significant threats identified at this time. Enforcement; The GPS Director now has authority to recommend civil penalties for violations of the regulations through an administrative process and not have to go through a Formal Hearing. Operator privilege to request a Hearing is preserved. Incident Investigation; two significant incidents in 2016, including an injury due to fire. The recent rule, GPS Rule 13, to remove abandoned service lines, was influenced by this incident. 27 Discussion with State on accuracy of inspection day information submitted into State Info Only Info Only Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: C27. Yes. It is a learning process to learn how much time each type of inspection takes for each type of operator. Bigger operators require more time as they are more complicated. Applying those times back to your actual personnel is also a learning curve. This is an ongoing, living, iterative process. 28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Info Only Info Only Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: C28. No information: APSC is not aware of any PL flow reversals, product changes, or conversion to service in the state. Recommended that this question be added to the Standard Inspection as an addendum item. 29 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only C29. Yes. APSC is actively engaged in inspecting operators and pipelines for safety. They are aware of the need to perform OQ and IM inspections and to successfully upload certain inspections into the databases. 3 points were lost in this Section. Total points scored for this section: 46 Total possible points for this section: 49 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 11

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: D1. Yes, Yes, & Yes. The APSC's procedures include a matrix of response timeframes depending on the nature of the probable violation. It is described on Page 22 & 23 of the APSC's inspection and enforcement procedures. Response date required and the actual response date are kept by each lead inspector for follow-up. Written compliance action correspondence must be sent to an officer of a private company. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: D2. Yes, yes, yes, yes & Yes, 4 of 4 points. Upon a review of randomly selected inspection files, the files generally contained responses from operators within the deadlines given by the APSC. APSC has a written policy in their procedures to perform follow-up every quarter until compliance is achieved. Compliance notifications were sent to company officer when a private company was involved. APSC is outlining potential civil penalties in correspondence with operators. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: D3. Yes. Upon a review of randomly selected inspection files completed during 2016, all inspections with discovered probable violations had letters of non-compliance in the files. 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: D4. Yes. The APSC's rules and procedures provide operators with an opportunity to argue their position as to whether a probable violation occurred. The operator is provided with an opportunity to present its case in a "show cause" hearing before a presiding officer or the commission. Upon a review of randomly selected inspection files the APSC followed its procedures. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D5. Yes. Page 21 of the APSC's inspection and enforcement procedures identify the criteria to be considered to determine a level of civil penalty fine. It addresses the severity of the probable violation, if the probable violation was repeated, the operator's ability to pay, and whether or not an accident resulted in an injury or fatality. DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 12

6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D6. Yes. APSC assessed a Civil Penalty in 2014. It is noted that, effective June 26, 2017, the GPS Director now has authority to recommend civil penalties for violations of the regulations through an administrative process and not have to go through a Formal Hearing. Operator privilege to request a Hearing is preserved. 7 General Comments: Info Only = No Points Evaluator Notes: D7. Yes. APSC has established Compliance processes. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 13

PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: E1. Yes. APS Operations Plan Sec VI subsections A-G. The APSC investigates incidents as they occur. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: E2. Yes. The APSC publishes and disseminates contact information to operators. A contact listing is also maintained on the Commission's web site. After hour contact instructions are also included. The Program Manager is knowledgeable of the MOU and understands the cooperation between the state and PHMSA as outlined in the Appendices of the Guidelines. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E3. Yes. It is APS policy to perform on-site investigations of significant incidents/accidents. Both significant incidents were investigated on-site in 2016. If an on-site investigation is not made, then there is provision to receive necessary information telephonically. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: E4. Yes, Yes, & Yes. The onsite investigations were complete. The Federal Form was used. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: E5. NA. There were no probable violations for incidents or accidents in 2016 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E6. Yes. APSC is cooperative with PHMSA Southern Region. 1 1 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 14

7 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: E7. Yes. Wallace Jones communicates this information during Southern Region Meetings & in the State hosted Pipeline Safety Seminars both in AL & in New Orleans. 8 General Comments: Info Only = No Points Evaluator Notes: E8. Yes. APSC responds to notices of incidents and accidents. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 15

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F1. Yes. The APSC conducts reviews of operators' OM procedures on a three year rotational basis. Directional drilling/ boring procedures are a part of the review. The APSC uses the federal standard inspection form which covers this requirement. It is also on the State Form and is addressed during construction too. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F2. Yes. The APSC's standard inspection form Question 25 has the inspector review the operator's damage prevention program and records. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F3. Yes. The Program Manger participates in the Alabama Damage Prevention Alliance where he has encouraged stakeholder representatives to use CGA Best Practices. The APSC includes damage prevention topics during its annual pipeline safety seminar. It is also addressed during the Damage Prevention Summit. In addition, the Director is a member of the One Call System Study Commission which is tasked to improve the existing One Call Law in AL. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F4. Yes. The APSC collects this information each year and uses the information in its relative risk ranking model. The data is insufficient to establish any trends at this time. 5 General Comments: Info Only = No Points Evaluator Notes: efforts. Info Only Info Only F5. Yes. The APSC generally complied with the requirements of Part F of this evaluation and supports Damage Prevention Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 16

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: East Central Alabama Gas District, opid 30530 Name of State Inspector(s) Observed: Randy Hammond, Sr. Gas Pipeline Safety Investigator, APSC Location of Inspection: 40717 Hwy 77, Ashland, AL 36251 Date of Inspection: 8/9-10/17 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. East Central Alabama Gas District, opid 30530 Randy Hammond, Sr. Gas Pipeline Safety Investigator, APSC. 40717 Hwy 77, Ashland, AL 36251 8/9-10/17 Patrick Gaume Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: G2. Yes. 10 operator personnel participated in this inspection, in the Office, the Field, or both. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G3. Yes. The Federal Form for NG Std Insp. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes, The entire form was filled out. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: G5. Yes. CP equipment, hand tools, keys, valve handles, paint. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: G6. Yes, yes, yes, NA, Performed a Full Std insp. 2 2 DUNS: 961833431 2016 Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 17

7 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 Evaluator Notes: G7. Yes. Randy performed his duties in a professional manner. 2 2 8 Did the insp
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