2013 AL NG Program Evaluation - al2013ngprogramevaluation (Alabama; Natural Gas State Program Evaluation)

AL NG Program Evaluation, 2013, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2013 Natural 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 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 1#

AL NG Program Evaluation, 2013, page 22013 Natural Gas State Program Evaluation -- CY 2013 Natural Gas State Agency: Alabama Rating: Agency Status: Date of Visit: 03/31/2014 - 04/04/2014 Agency Representative: Wallace Jones, Sr. - Administrator, Gas Pipeline Safety PHMSA Representative: Don Martin 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 2013 (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 10 B Program Inspection Procedures 15 15 C Program Performance 45 43 D Compliance Activities 15 14 E Incident Investigations 8 8 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 113 110 State Rating................................................................................................................................................... 97.3 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 2#

AL NG Program Evaluation, 2013, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No inaccuracies were found on Attachment 1. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The inspection person days on Attachment 2 matched the APSC's 2013 inspection records. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC's listing of operators and units matched the spreadsheet listing kept by the APSC. The number of units on Attachment 3 matched Attachment 1 tally. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A comparison to PHMSA's incident reporting data for 2013 did not show an incident report missing. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no accuracy errors found on Attachment 5. 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 No issues identified concerning the APSC's file organization. The APSC maintains hard copy files and electronic files. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: All entries were consistent with APSC employee files and training files of PHMSA's Training and Qualifications Division. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No discrepancies were found with the APSC's Attachment 8 information. The APSC does not have civil penalty levels substantially the same as PHMSA. Legislation has been introduced to raise the APSC's civil penalty level to be substantially the same as PHMSA. DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 3#

AL NG Program Evaluation, 2013, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 No issues identified with Attachment 10. Very good description of the APSC's program. 10 General Comments: Info Only = No Points Evaluator Notes: The APSC generally complied with the requirements of Part A of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 4#

AL NG Program Evaluation, 2013, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC inspection procedures utilizes a risk ranking model to priortize operators and units to be inspected each year. The procedures state that each operator and unit must be inspected annually. The annual inspection can be one of seven possible inspection types. A Standard inspection can be one of those inspections. 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC inspection procedures utilizes a risk ranking model to priortize operators and units to be inspected each year. The procedures state that each operator and unit must be inspected annually. The annual inspection can be one of seven possible inspection types. An IMP or DIMP inspection can be one of those inspections. 3 OQ Inspections (B1c) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC inspection procedures utilizes a risk ranking model to priortize operators and units to be inspected each year. The procedures state that each operator and unit must be inspected annually. The annual inspection can be one of seven possible inspection types. An OQ inspection can be one of those inspections. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC inspection procedures utilizes a risk ranking model to priortize operators and units to be inspected each year. The procedures state that each operator and unit must be inspected annually. The annual inspection can be one of seven possible inspection types. A Damage Prevention inspection can be one of those inspections. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On-site operator training is scheduled on as needed basis. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Construction inspections are scheduled when operator notification of construction plans is provided to the APSC. 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Incident investigations are included in the APSC's inspection procedures. The APSC investigates incidents as they occur. DUNS: 961833431 2013 Natural Gas State Program Evaluation 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection Yes No Needs Improvement 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 Alabama Alabama Public Service Commission, Page: 5#

AL NG Program Evaluation, 2013, page 6d. 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: The APSC has implemented a risk ranking model (which includes the elements above) to provide trends on certain threats such as third party damage for each operator and unit. The results of the model are used to schedule inspections in the annual inspection plan. Each operator and inspection unit will receive an inspection annually. The risk model determines the interval of each type but a Standard Inspection will be conducted at least once each three years. Inspection units appear to be broken down appropriately. 9 General Comments: Info Only = No Points Evaluator Notes: The APSC generally complied with the requirements of Part B of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 6#

AL NG Program Evaluation, 2013, page 7PART 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 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1051.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 8.58 = 1887.05 Ratio: A / B 1051.00 / 1887.05 = 0.56 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The APSC's ratio was 0.56 which far exceeded the minimum ratio of 0.38. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: All inspectors and program manager have satisfied the training requirements or is on schedule to complete them. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Mr. Jones has been the program manager for six years and had extensive experience with a private distribution company prior to his appointment as program manager. Mr. Jones is very active in the National Association of Pipeline Safety Representatives and has represented the organization in PHMSA initiatives to improve the pipeline safety program. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC responded in 58 days. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: The last seminar was held in December of 2013. The APSC conducts its seminar annually. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: The APSC met its timeframe for inspecting operators and units. 5 5 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 7#

AL NG Program Evaluation, 2013, page 87 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 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC uses the federal standard inspection forms on standard inspections once each three years. The APSC uses standard inspection forms it has developed for years in between. The forms were evaluated for covering federal requirements and were sufficient. Construction inspection forms developed by the APSC were also determined to cover federal requirements. The APSC uses federal forms for IMP, DIMP, LNG and OQ inspections and uses the federal incident investigation form to obtain facts surrounding an incident. Upon a review of randomly selected inspection files all applicable sections of inspection forms were completed. 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 (B7) Yes = 1 No = 0 Evaluator Notes: 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 (B8) Yes = 1 No = 0 Evaluator Notes: 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 (B9) Yes = 1 No = 0 Evaluator Notes: 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: 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 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC reviews the data from annual reports and utilizes a major portion of the data in its risk model. The APSC has been utilized trend charts for cast iron replacement since 2008. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues were identified upon reviewing the OQ and IMP databases. DUNS: 961833431 2013 Natural Gas State Program Evaluation 2 2 Alabama Alabama Public Service Commission, Page: 8#

AL NG Program Evaluation, 2013, page 914 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC reviews program changes during each standard inspection. The APSC conducted 95 drug and alcohol inspections as a part of standard inspections during 2013. 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All operators' OQ programs have been inspected. The APSC reviews compliance with Protocol 9 during each Standard Inspection. The OQ database also shows that the APSC has continually uploaded the results of Protocol 9 inspections. The APSC continued reviewing the field portion (Protocol 9) of Part 192, Subpart N during 2013. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 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). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The APSC has conducted the integrity management programs of all gas transmission operators. The APSC is in the process of completing the second round of IMP inspections. The APSC is planning to complete the second round as soon as practical. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: database. The APSC has completed inspections on all but four operators. Several of the inspections need uploading to the DIMP 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC was not able to complete all of the inspections by the end of December, 2013. There are less than five programs that did not get completed. DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 9#

AL NG Program Evaluation, 2013, page 1020 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC posts pipeline safety information on the Commission's website. The APSC participates in and makes presentations at Alabama Natural Gas Association meetings. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no safety related condition reports filed by operators during 2013. 1 NA 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC has included Question 39 on its inspection forms which covers the issue of plastic pipe and component failures. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues with participation were discovered. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Info Only = No Points Evaluator Notes: Info Only Info Only The APSC has not followed up on waivers recently. The APSC has issued waivers on four seperate occasions. Following this program evaluation the APSC will follow up on the waivers along with any conditional actions of the operators. 25 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C.19 - The APSC was not able to complete all of the inspections by the end of December, 2013. There are less than five programs that did not get completed. One point was deducted. Total points scored for this section: 43 Total possible points for this section: 45 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 10#

AL NG Program Evaluation, 2013, page 11PART 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 (B12-14, B16, B1h) 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 Evaluator Notes: Yes. The APSC's procedures were revised to include a matrix of response timeframes depending on the nature of the probable violation. It is described on Page 24 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 (B11,B18,B19) 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. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection files, the files contained responses from operators within the deadlines given by the APSC. No instances were found where the APSC failed to follow-up on probable violation corrections. Compliance notifications were sent to company officer when a private company was involved. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected inspection files completed during 2013, 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. (B17, B20) Yes = 2 No = 0 Evaluator Notes: 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Page 23 of the APSC's inspection and enforcement procedures was revised to establish the criteria to be considered to determine a level of civil penalty fine. The severity of the probable violation, if the probable violation was repeated, the operator's ability to pay and whether or not an incident resulted involving injury or fatality. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 961833431 2013 Natural Gas State Program Evaluation 1 0 Alabama Alabama Public Service Commission, Page: 11#

AL NG Program Evaluation, 2013, page 12The APSC has not assessed a civil penalty in several years. Therefore, the APSC can't demonstrate that it has used its fining authority. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question D.6 - The APSC has not assessed a civil penalty in several years. Therefore, the APSC can't demonstrate that it has used its fining authority. One point was deducted for not meeting this requirement. Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 12#

AL NG Program Evaluation, 2013, page 13PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: 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 knowledgable of the MOU and understands the cooperation between the state and PHMSA as outlined in the Appendices of the Guidelines. 2 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 There were three reportable incidents during 2013. The APSC conducted onsite investigations on all three incidents. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) 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: Three incidents that occurred in 2013 were investigated on site. The APSC utilized PHMSA's Incident Investigation Report form to document observations and documentation. The investigation process is still in progress. The APSC has not provided conclusions and recommendations at this time. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: There were no probable violations found by the APSC. 1 NA 5 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues identified with this requirement. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: Yes. Wallace Jones has communicated this information during Southern Region Meetings. 1 1 7 General Comments: DUNS: 961833431 2013 Natural Gas State Program Evaluation Info Only Info Only Alabama Alabama Public Service Commission, Page: 13#

AL NG Program Evaluation, 2013, page 14Info Only = No Points Evaluator Notes: The APSC has generally complied with the requirements of Part E of this evaluation. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 14#

AL NG Program Evaluation, 2013, page 15PART F - Damage Prevention 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? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 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. 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Program Manger participates in the Alabama Damage Prevention Council where he has encouraged stakeholder representatives to use CGA Best Practices. The APSC includes damage prevention topics during its annual pipeline safety seminar. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 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: The APSC generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 15#

AL NG Program Evaluation, 2013, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Brewton Gas Department Name of State Inspector(s) Observed: Judy Ramsey Location of Inspection: Brewton, AL Date of Inspection: 04/03/2014 Name of PHMSA Representative: Don Martin Evaluator Notes: Info Only Info Only City of Brewton was represented by Ray Madden. The APSC conducted a standard inspection of Brewton Utilities. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: The APSC provided two weeks notice of the inspection. 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The APSC used the standard inspection form developed by the APSC during the evaluation. The federal form will be utilized upon a return visit during 2014. The APSC inspector used the form as a guide to progress through the procedures and records portion of the inspection. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all findings were documented on the inspection form. 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.) (F5) Yes = 1 No = 0 Evaluator Notes: Yes, cathodic protection testing equipment was verified during the inspection. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: No issues with the subject matter covered by the inspector during the evaluation observation. 2 2 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 16#

AL NG Program Evaluation, 2013, page 177 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Ms. Ramsey has completed all of the TQ training and has been an inspector for several years. She is well versed in the regulations and Alabama's pipeline safety program. 8 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) (F9) Yes = 1 No = 0 Evaluator Notes: Yes, an exit session was held with the operator at the end of the day. 1 1 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: Yes. The operator was asked to revise its procedures to include calibration of test equipment and the timeframes for calibration. Several cathodic protection low test point readings were identified. A rectifier was identified as the problem. The operator was given expectations for follow up by the APSC. 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other. 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 r. 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 DUNS: 961833431 2013 Natural Gas State Program Evaluation Info Only Info Only Alabama Alabama Public Service Commission, Page: 17#

AL NG Program Evaluation, 2013, page 18D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: this evaluation. The inspection was very comprehensive in its coverage. The APSC generally complied with the requirements of Part G of Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 18#

AL NG Program Evaluation, 2013, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 4 Were 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The Alabama Public Service Commission is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 19#

AL NG Program Evaluation, 2013, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 3 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The Alabama Public Service Commission does not have a 60106(a) agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 961833431 2013 Natural Gas State Program Evaluation Alabama Alabama Public Service Commission, Page: 20#