# 2022 AR NG Program Evaluation - ar-2022-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ar-2022-gas-program-evaluation
- **title:** 2022 AR NG Program Evaluation - ar-2022-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-01-01
- **effective on:** Not available
- **summary:** 2022 PHMSA natural gas program evaluation for Arkansas.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-12/ar-2022-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 2022 Gas State Program Evaluation for ARKANSAS PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 1

2022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 09/26/2023 - 09/28/2024 Agency Representative: Jason Donham PHMSA Representative: Joe Subsits Commission Chairman to whom follow up letter is to be sent: Name/Title: Doyle Webb, Chairman Agency: Arkansas Public Service Commission Address: 1000 Center Street 72201 City/State/Zip: Little Rock, AR 72203-0400 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2022 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 48 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 98 State Rating................................................................................................................................................... 98.0 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: Attachment 1 lists 151 gas operators, 4 LDCs with 38 units, 6 municipals with 6 units, 3 LPG with 3 units and 124 master meters with 183 units. 12 intrastate transmission systems with 25 units. There is no LNG in Arkansas. There are also 2 gathering systems with 3 units. Attachment 1 numbers come from the data base. b. There were 887 total inspection days in 2022. 132 days were design and construction days. There were 501 SICT days. 20 % construction days is 100 days. SICT criteria was met. Inspection days were collected from the pipe database. c. The unit count on attachment 3 matches Attachment 1. d. One significant incident was reported by Black Hills Energy Transmission. This is on the progress report and Pipeline Data Mart. An NRC report was submitted. When looking at this event it was determined that this event did not meet the financial criteria and was not reportable. Jason was directed to reach out to Carrie to determine if the progress report needed to be modified. e. Errors from last year's progress report were corrected and 2022 compliance numbers added up correctly. f. The records list appears appropriate. g. All inspectors have the required classes except for Greg Rhinehart. Greg is core qualified. h. The last adoption was 12/16/2022. Arkansas Adopted the $200,000/$2,000,000 penalty amount. i. Planned performance and past performance activities were identified by state. No issues identified. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Pre inspection is covered in Section II. Post inspection is covered in section III. a. a. Standard inspection addressed in section III. Public awareness is addressed in section IX. Drug and Alcohol is addressed in section X. Control room management is addressed in Section XI. b. IMP is addressed in section VI and DIMP is addressed in section VII. c. OQ is addressed in section V. d. Damage Prevention is addressed in Section III as part of the standard inspection. e. On-site training is addressed in section XII. f. Construction inspections are addressed in section VIII. g. There is no LNG in Arkansas 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Inspection planning is addressed in Section I. Factors that impact inspection prioritization are: 1. Length of time since last inspection. 2. Significant change in mode of operation, such as management/personnel. 3. Reported high leakage and lost and unaccounted for gas. 4. Increased or significant construction activity 5. History of the operator. 6. Risk/Threat base data analysis. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: a. Procedures to notify operator of probable violations are found in Section III. Compliance letters go the Chief Executive DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 4

Officer. b. Compliance follow up activities are found in Section III and IV. A suspense file is used to track outstanding compliance issues. c. Closure of probable violations is addressed in Section III. Closed violations need to be closed in data base. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 Evaluator Notes: a. Incident notification is addressed in section XIII. Calls come in by e-mail or phone. b. Arkansas PUC will clarify that a no go decision will require a justification memo. The current language is vague. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues with Part B. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Core trained inspectors are Jason Donham, Eric Harbort, Jerome Huckaby, Jerry Harris, John Ray, Keith Price, Larry Eslick, and Greg Rhinehart. a. OQ Qualified inspectors are Jason Donham, Eric Harbort, Jerome Huckaby, Jerry Harris, John Ray, Keith Price and Larry Eslick. b. DIMP/IMP qualified inspectors are Jason Donham, Eric Harbort, Jerome Huckaby, Jerry Harris, John Ray, Keith Price and Larry Eslick. c. LNG trained inspectors are Jason Donham, Eric Harbort, Jerry Harris, John Ray, Keith Price and Larry Eslick. d. Root Cause trained inspectors are Jason Donham, Eric Harbort, Jerome Huckaby, Jerry Harris, John Ray, Keith Price and Larry Eslick. e. Staff attended a one-call conference. f. Staff qualifications were checked with blackboard and found to be compliant with certification criteria. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: required T & Q classes. Jason Donham is the new program manager. Jason has been with pipeline program for 15 years. He has completed all 3 General Comments: Info Only = No Points Evaluator Notes: There are no issues with Part C. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 6

PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 4 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Inspection intervals for all type of required inspections were reviewed. Several previous inspection frequencies were found to exceed the 5-year criteria. a. Standard inspection frequencies were found to be within the 5-years interval. b. Public awareness inspections were within the required 5-year frequency. c. Previous drug and alcohol inspection frequencies were exceeded Arkansas Oklahoma Gas Corporation and Tucker Energy Solutions. The most recent inspection frequency for Oklahoma Gas Corporation was 4/6/2022, the previous inspection was 7/11/2016. For Tucker Energy Solutions. the most inspection was conducted on 3/15/2022 and the previous inspection was conducted on 8/8/2016. d. Control Room Management inspections previous inspection intervals were exceeded for Arkansas Oklahoma Gas Corporation. The most recent inspection was conducted on 2/14/2022 and the previous inspection frequency was 9/15/2015. e. There is no LNG in Arkansas. f. The 20% inspection day criteria was met. There were 132 construction days and 100 days were required. g. OQ previous inspection frequencies were exceeded for Acme Brick Company, Arkansas Oklahoma Gas Company, Tucker Energy Solutions and AECC-Oswald Generating Station. The most recent inspection frequency for Acme Brick Company was 11/18/2021 and the previous inspection was conducted on 4/28/2015. The most OQ recent inspection frequency for Arkansas Oklahoma Gas Corp was 2/17/2022 and the previous inspection frequency is 9/14/2015. The most recent inspection for AECC-Oswald Generating Station was 3/15/2022 and the previous inspection frequency was 8/9/2016. h. Previous IMP/DIMP inspection frequencies were exceeded for ACME Brick Company and Tucker Energy Company. The most recent IMP/DIMP inspection for ACME Brick Company 11/19/2021 and the previous inspection frequency was 12/16/2014. The most recent inspection for Tucker Energy was 3/22/2022 and the previous inspection was 12/22/2016. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: a. APSC uses the IA equivalent form supplemented by a state form. b. For Public Awareness, APSC used an IA equivalent form. c. For Drug and Alcohol inspections, the state uses an IA equivalent form. d. For Control Room Management Inspections, the state uses an IA Equivalent form. DUNS: 096796201 2022 Gas State Program Evaluation 10 10 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 7

e. There is not LNG in Arkansas. f. Federal/State forms are used for construction activates. g. For Operator Qualification Inspections, an IA equivalent form is used. h. For IMP/DIMP inspections, an IA equivalent form is used. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ inspection frequencies were checked, some previous inspection frequencies were exceeded. Protocol 9 inspections are usually performed during each standard inspection. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 2 should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: IMP/DIMP inspections are periodically conducted. Some previous inspection frequencies were exceeded. a. Kieth Price reviews IMP programs annually. He reviews plan changes. b. Leak prone pipe is evaluated during DIMP inspections. Leaks are investigated by the LDC's. Summit has some bare steel. pipe has also been replaced. c. Summit has low pressure systems. They are working on eliminating the systems. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: a&b) There is no cast iron in Arkansas but cast iron questions are addressed in a supplemental checklist. c) Checking for multiple leaks after excavation damage in addressed in a supplemental checklist DUNS: 096796201 2022 Gas State Program Evaluation 2 2 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 8

d) reviewing records to ensure appropriate operator response to third party damage incidents is addressed in a supplemental checklist. e) Directional boring excavation damage prevention procedures are addressed in the supplemental checklist. f) Most low pressure system have been eliminated. g) Compliance for regulators inside buildings is addressed in the supplemental checklist. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There is no evidence that APSC took action on the 2022 geological hazard advisory bulletin. 1 0 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 10 resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Compliance actions were reviewed from random operators records. All probable violation were addressed using acceptable compliance processes. a. Compliance letters were submitted to the proper corporate level manager. b. Probable violations were properly documented. c. Probable violations that were reviewed were properly resolved. d. Each inspector has a suspense file. Due date also in data base. Ongoing violations are discussed during meetings. APSC is Looking to building in tickler system. A data base upgrade is anticipated. e. Compliance measures were taken for all probable violations that were reviewed. f. A $150,000 penalty was assessed in 2021. g. All compliance activity goes through Jordon for review and approval. h. Show cause is addressed in the APSC procedures. i. Exit interviews were conducted within 30 of the final date of inspection. j. Compliance letters were submitted within 90 days of the inspection. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? 10 10 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 9

d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: There were no federally reportable incidents in 2023. An incident by Black Hills was listed in PDM and the progress repost but his event was found to not meet the $120,000 threshold. a. A process is in place to accept phone or email incident notifications. b. There were no federally reportable incidents in 2022. c. There were no federally reportable incidents in 2022 but APSC was aware of the requirement to document justification of no-go decisions. d-g. There were no federally reportable incidents in 2022. h. There were no AID requests for assistance in 2022 i. Lessons are shared at NAPSR regional meetings. 9 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 = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A Letter to Katie Anderson went out 11/30,2022. The state provided a satisfactory response on 1/25/2023. Doyle Webb is the new and existing Chairman. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: The next pipeline seminar is scheduled for 8/14/2023 in Louisiana. Louisiana combines with Arkansas to conduct pipeline safety seminars. The previous seminar was in 2019. Later seminars were postponed due to covid restrictions. 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Info Only Info Only This question is addressed as a supplemental question in the transmission checklist. 12 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: The web page is the top rated web site in the pipeline safety trust web page evaluation. The web page includes regulations, safety tips emergency numbers, enforcement information ang damage prevention information. Mailouts are also used as a tool to disseminate information. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no SRC's in 2022. This was confirmed in PDM. 1 1 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 10

14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: a. Jordon filled out one survey so far. He was reminded to retain proof that surveys were filled out. b. The Black Hills investigation is still open. Carrie is working on getting Jordon Access to WMS. 1 1 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Jordon was instructed to review waivers to determine if they are needed or additional monitoring needs to be done. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Jordon is still getting acquainted with the filing system. Changes to the system are anticipated. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: SICT days for 2022 were 501. Construction days were 100 days. There were 887 actual days and 132 construction days. Peer comment were that risk concerns need to be identified for larger operators. Jordon was informed about SICT process and the need to address comments. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Jordon was directed to the metrics page and we went through the metrics. Info Only Info Only 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: SMS is encouraged during meetings. Info Only Info Only 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There were two-point deductions in Part D. One point was deducted for exceeding previous inspection frequencies and another point was deducted for not addressing the geological hazards advisory bulletin. Total points scored for this section: 48 Total possible points for this section: 50 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Kieth Price performed the field portion of standard inspection of Summit Arkadelphia unit on 9/28/2023. a. This was part of the field evaluation for a standard inspection. b. This unit was last inspected in 2021. c. Operator representatives for Summit were present during the evaluation. d. Kieth has 12 years of experience. Info Only Info Only 2 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: Arkansas uses the IA equivalent form for their inspections. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: a. procedures review were performed during other portions of this inspection. b. Exposed pipe reports were reviewed to prepare for this visit. c. This inspection was spent observing exposed pipes and the coating condition of those pipes. d. Blind flange plates for no flow meters were inspected. e. The inspection appeared to be the proper length. 4 From your observation 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: Kieth appeared knowledgeable of pipe operational and safety issues. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: An exit interview was conducted at the end of the day. Follow up, and evaluation results were discussed. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? DUNS: 096796201 2022 Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 12

Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: a. The inspection was conducted in a safe manner. b. Kieth looked at exposed pipes, coating conditions, exposed pipe records and blind plates for no flow meters. c. Inspected blind plates for no flow meter sets were inspected. d. N/A 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues with Part E. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 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: Jerry Harris will now be responsible for reviewing annual reports and will evaluate trends. 2 2 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: APSC receives monthly and quarterly damage prevention reports. Causal information is in the reports. Data review was done by Angela and will be done by Jerry. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: a-j. Jerry and Angela are evaluating causal data reports. APSC is looking into performing damage prevention inspections. Jordon and Angela were presented with the appendix D summary and were instructed on the use of that data. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: Damage prevention information is tabulated by Angela and Jerry. DUNS: 096796201 2022 Gas State Program Evaluation 2 2 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 14

a. Most damage is caused by excavators and owners not calling for locates. b,d. Damage prevention training and education is addressed during the Public Awareness inspections. c. Damage prevention reports are periodically reviewed by APSC. 5 General Comments: Info Only = No Points Evaluator Notes: There are no issues with Part F. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: AR PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2022 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 16
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