# 2012 AR NG Program Evaluation - arog2012ngprogramevaluation (Arkansas; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA arog2012ngprogramevaluation
- **title:** 2012 AR NG Program Evaluation - arog2012ngprogramevaluation (Arkansas; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-01-01
- **effective on:** Not available
- **summary:** 2012 PHMSA natural gas program evaluation for Arkansas.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2012 Natural Gas State Program Evaluation for ARKANSAS OIL AND GAS 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: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 1

2012 Natural Gas State Program Evaluation -- CY 2012 Natural Gas State Agency: Arkansas Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 05/13/2013 - 05/17/2013 Agency Representative: Gary Looney, Assistant Director & Michael Gray, Pipeline Program Manager PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Chad White, Chairman Agency: Arkansas Oil and Gas Commission Address: PO Box 634 City/State/Zip: Magnolia, Arkansas 71754 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 2012 (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 9 7 B Program Inspection Procedures 13 13 C Program Performance 32 32 D Compliance Activities 15 15 E Incident Investigations 2 2 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 91 89 State Rating................................................................................................................................................... 97.8 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS 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 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A1. Yes. Attachment 1 is consistent with Program records, Attachment 3 and Attachment 8. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: A2. NO, 0 of 1 pt. Program records show 43 AFOD, not the 41 days reported. Attachment 2 was corrected to show '43' before the Evaluation was completed. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A3. Yes. All 6 operators identified. 1 1 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: 1 NA A4. . NA. There have been no federally reportable incidents since AOGC became a Federal partner in 2008. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: A5. No. 0 of 1 pt. The final number; 'Number to be corrected?' was incorrectly shown as '0'. The correct number is '4'. Attachment 5 was corrected to show '4' before the Evaluation was completed. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A6. Yes. The paper records are still the official records and they are kept in the El Dorado Office. Almost all of the records are also available electronically. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes. Attachment 7 is a direct import of TQ data & agrees with AOGC records. 1 1 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: A8. Yes. Commission General Rule D-17 (e) states that 49 CFR 190, 191, 192 Subpart A through Subpart O, and 199 (all as amended) are incorporated by reference. DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 3

9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A9. Yes, AOGC is in it's 6th year as a State Partner, Michael is approaching his 2nd anniversary with AOGC, (after 3 years with APSC), and is participating in NAPSR. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A10. This evaluation addresses 2012, which was the fifth year of the program partnership. TQ Training meets all Gas Standard inspection requirements for both Mike & Gary. The Program Manual is finished. Total points scored for this section: 7 Total possible points for this section: 9 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 B1. Yes, AOGC Pipeline Inspection Manual, Section III. Inspection Procedures, 2nd paragraph. Every 3 years. 2 IMP Inspections (including DIMP) (B1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B2. NA, IMP is NOT required of any Gathering line. 1 NA 3 OQ Inspections (B1c) 1 NA Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B3. NA, OQ is NOT required of Type B Gathering. Type A Gathering has only a general statement concerning operator training that is generally unenforceable unless something egregious happens. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B4. Yes, is part of the Standard Inspection. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 B5. Yes, AOGC Pipeline Inspection Manual, Section VII. Informal Operator Training is part of every Inspection. 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B6. Yes, AOGC Pipeline Inspection Manual, Section III, paragraph 4. 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: B7. Yes, AOGC Pipeline Inspection Manual, Section III, paragraph 5. 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 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) DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 5

f. Are inspection units broken down appropriately? Evaluator Notes: B8. Yes, AOGC Pipeline Inspection Manual, Section III, paragraph 3. Yes No Needs Improvement 9 General Comments: Info Only = No Points Evaluator Notes: It is AOGC goal to inspect every Operator every year, and with few exceptions that practice is achieved. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS 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 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 43.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.50 = 110.00 Ratio: A / B 43.00 / 110.00 = 0.39 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. YES. 43 AFOD, 0.50 Inspector-yrs, 43/0.5*220=.391, .391>.38, okay 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: C2. Yes. Both Gary and Mike are fully qualified as NG Standard Inspectors. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C3. Yes, Both Gary & Mike are trained and knowledgeable. 2 2 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 2 2 Evaluator Notes: C4. Yes, the Chairman letter was 1/9/13, and the Chairman response was 2/25/13. All items of concern were addressed. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) 2 2 Yes = 2 No = 0 Evaluator Notes: C5. Yes, the seminar was co-sponsored with AR PSC & LDNR and was held in New Orleans in July, 2012. TQ personnel were there and made presentations. AOGC is scheduled to co-host the TQ Seminars in North Little Rock on June 5-6, 2013 and in New Orleans on July 22-26, 2013. 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 5 5 Evaluator Notes: C6 Yes. Standard inspections are generally performed every year. No Operator in 2012 had an established need to implement IM or OQ. One Operator will need to implement OQ during 2013. DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 7

7 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 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C7. Yes, use the Fed Forms. 2 2 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: C8. NA, no cast iron pipe. 1 NA 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: C9. NA, no cast iron pipe. 1 NA 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: C10. NA, no jurisdictional leaks from 2008 to year to date 2013. No jurisdictional distribution pipe. 1 NA 11 Did the state review operator records of previous accidents and failures including 1 NA 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: C11. NA, none, this is a new program, started in 2008. There were no reportable incidents in 2008-5/2013. None of the 6 Operators have had any line hits due to excavation for their jurisdictional pipe. This question has been added onto the Std Insp addendum sheet effective 7/13/10. 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: C12. Yes, five operators have more than a mile of regulated pipe and those annual reports are received and reviewed. It is addressed in the SOP and the regulations. The annual reports are reviewed for completeness and possible errors. There is no value at this time for making trending efforts as the total regulated mileage is very small. When all gas gathering lines become regulated then the need for trending will be revisited. There have been no incident reports from 2008 to present. This is a small and new program, there is little if any data available to evaluate. 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: DUNS: NA 2012 Natural Gas State Program Evaluation 2 NA Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 8

C13. NA, none, OQ & IMP have not been required of any Operators to date. One OQ review, as applicable to a Type A, Class 2 Gathering System, is scheduled to be performed in the 2nd half of 2013. 14 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 NA Evaluator Notes: C14. NA, not yet, E&P Operators have not been confirmed to have Transmission Lines in AR. This question will be NA until transmission lines are identified or gathering line data starts being required. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 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: C15. Yes. AOGC added this question to their Standard Inspection addendum sheet effective 7/13/10. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 2 NA 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: C16. NA, not part of type B gathering or of type A gathering in Class 2. Will include when Type A in a Class 3 or 4 location and/or Transmission lines are confirmed. 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: C17. NA, not part of type A or B gathering. Will include when Transmission lines are confirmed. 2 NA 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 NA Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: distribution system. C18. NA, AOGC is not jurisdictional to any distribution system, and is highly unlikely to become jurisdictional to any 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 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C19. Yes, all six operators have Public Awareness Plans that were developed per API 1162. Most operators have been required to make some amendments. All seven Public Awareness Plans were reviewed in 2008 or 2009. The plans were reviewed relative to API 1162 during Standard inspections; and also during some Operational Records and Field inspections. DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 9

PAPE Inspections were started in 2012. In 2008 and 2009 most of the operators were developing their Damage Prevention Programs for the first time. They were inspected per API 1162 and were directed to come into compliance with API 1162. They are well aware of the requirement for continuous review and revision. 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C20. Yes, AOGC participates in the AR and LA Pipeline Safety Seminars; and continues to push Damage Prevention and One-call in almost every contact with E&P operators. AOGC issued and wore approved work shirts that have One-Call info and the 811 logo. All Hearings are public information and on the web site. Notices are public information too, but they have to be requested. 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: C21. NA, none from 2008 to the present. 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: C22. Yes. Operators are asked about plastic pipe during visits to determine the existence of regulated pipe and during Inspections. If any plastic pipe is identified then they are asked about the quality, condition, and manufacture of it. 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: C23. Yes, AOGC has responded to all known requests. 1 1 24 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C24 2012 was the 5th year of the AOGC/PHMSA partnership. This partnership is unique in that this partnership focuses on E&P operators with regulated gathering lines. Total points scored for this section: 32 Total possible points for this section: 32 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 10

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 (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: D1. Yes. AOGC has statutes, rules and procedures. They send notices to the regulated entity's representative as reported on the AOGC Form 1 Organization Report and also to Corporate Officers per PHMSA Guidelines. AOGC has internal procedures and Commission rules. See AOGC Rule A-5, & also A-2 & A-3. File review shows that AOGC has followed its own procedures and Commission rules. 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: D2. Yes, In 2012 there were 20 PV that were mailed to the Operators; 16 were resolved in 2012 in a timely manner, and the remaining 4 were resolved in early 2013 by Operator response within the required time frames. The Inspection record, Operator notification, and Operator response are all in the files. AOGC sends notices to the regulated entity's representative as reported on the AOGC Form 1 Organization Report and also to Corporate Officers per PHMSA Guidelines. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: D3. Yes, the inspection results and the notification letters are in agreement. All inspection Unsatisfactory findings are included in the notification letters. 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: D4. Yes, Any penalty requires a Hearing. AOGC has not needed to demand a show cause hearing with an Operator relative to a jurisdictional pipeline. The procedures and program are in place. See AOGC Rules A-5, A-2, & A-3. 5 Is the program manager familiar with state process for imposing civil penalties? Were 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: D5. Yes. AOGC has a well-established procedure for issuing fines, and issued a $10,000 fine in 2011. 2 2 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, The AOGC has issued fines of $6000 and $10,000 for violations of Part 192. See AOGC Rules A-5, A-2, & A-3. DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 11

7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D7. The AOGC has authority to issue advisory notices, notices of probable violations, corrective action orders, consent agreement orders, and to issue fines. See AOGC Rules A-5, A-2, & A-3. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 12

PART 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: E1. Yes. The incident regulations are created and the internal program is in place. There have been no reportable incidents since AOGC became a State Partner (2008-5/2013). Operators are told often of their responsibility to report incidents. We discussed chapter 6.1 of the State Guidelines. Appendix D (MOU between NTSB & PHMSA) has been reviewed and understood. 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: E2. NA, No incidents. Plan to do on-site investigations. 1 NA 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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: E3. NA, No incidents. They will use Fed Forms and follow Fed guidelines. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: E4. NA, No incidents. 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: E5. NA, No incidents. 1 NA 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: E6. NA, There have been no jurisdictional incidents. They have full plans to share lessons learned. 1 NA 7 General Comments: Info Only = No Points DUNS: NA 2012 Natural Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 13

Evaluator Notes: E7. AOGC is happy to observe that there have been no jurisdictional incidents since they have become a state partner. They are working to keep the trend continuing. Total points scored for this section: 2 Total possible points for this section: 2 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 14

PART 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: F1. Yes, and it is on the Standard Inspection addendum sheet. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written 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: F2. Yes, it is in the Std Insp Form, under Damage Prevention. PAPEI were started in 2012. 2 2 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: F3. Yes, AOGC has a One-Call link on its web site. Damage Prevention is addressed in the every 3rd year T&Q Seminars and AOGC co-sponsors the seminars with APSC. It is reviewed during every Standard Inspection. In '08 AOGC supported efforts to establish an Arkansas CGA Regional Partnership. Specifically AOGC has supported One-Call efforts by encouraging all E&P operators to become One-Call members. AOGC has made One-Call membership required for operators of any natural gas line (including flow-lines, gathering lines, and other) that is within any city limits. They also recognize that enforcement has not been effectively addressed for excavators who violate the One-Call Rule. 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: F4. Yes, ARKUPS, the pipe locating service of AR One-Call, tracks the number of locates per damage. There is no perceived applicability to use DIRT at this time. If there is ever a line hit this question will be re-addressed. 5 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: F5. AOGC is committed to safe pipe and damage prevention. AOGC participates within Arkansas Regulatory Partnership Program (ARPP) by participating in meetings and other public outreach efforts. All 6 AOGC Part 192 regulated operators are members of ARPP in addition to several other E&P operators throughout the State. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 15

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: BHP Billiton Petroleum (Arkansas) Inc, OPID 32649 Name of State Inspector(s) Observed: Michael Gray Location of Inspection: the Shirley gas gathering system, Van Buren Co., AR Date of Inspection: 5/13-16/2013 Name of PHMSA Representative: Patrick Gaume, State Liaison Evaluator Notes: G1. BHP Billiton Petroleum (Arkansas) Inc, OPID 32649, the Shirley gas gathering system, Van Buren Co., AR; Michael Gray, Pipeline Program Manager, AOGC; 5/13-16/2013; Patrick Gaume, State Liaison. 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: G2. Yes, and three BHP personnel participated in 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 Evaluator Notes: G3. Yes, the Federal Form plus the AR addendum sheet were used. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes, for the Field portion which is what I Evaluated. 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: G5. Yes, hand tools, keys, half cell & multi-meter, man lift equipment, 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: G6. Yes, for the Field Inspection. 2 2 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 16

7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G7. Yes, Michael is very capable, is fully qualified, and has many years of experience in the industry. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: G8. Yes, it was noted that there had been water erosion under a security fence that would need correction, everything else was in very good shape. 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: G9. Yes, it was noted that there had been water erosion under a security fence that would need correction, everything else was in very good shape. 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 Info Only Info Only DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 17

D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: G10. Fencing, locks, signs, markers, ROW, air-soil interface, rectifier, pressure relief valve, pig launcher & receiver assy,s, flanges, threads, bolts, plugs, atmospheric corrosion, CP, evidence of soil erosion, water bars, silt fences, rip rap, valves and valve actuation, pressure readings. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 18

PART 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: H.1-8, NA. 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: H.1-8, NA. 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: H.1-8, NA. 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: H.1-8, NA. 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: H.1-8, NA. 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: H.1-8, NA. 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: H.1-8, NA. Not an interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H.1-8, NA. Not an interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 19

PART 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: I.1-7, NA. Not a 60106 State Program Partner. 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: I.1-7, NA. Not a 60106 State Program Partner. 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: I.1-7, NA. Not a 60106 State Program Partner. 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: I.1-7, NA. Not a 60106 State Program Partner. 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: I.1-7, NA. Not a 60106 State Program Partner. 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: I.1-7, NA. Not a 60106 State Program Partner. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I.1-7, NA. Not a 60106 State Program Partner. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 20
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