# 2010 CT NG Program Evaluation - ct2010ngprogramevaluation (Connecticut; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ct2010ngprogramevaluation
- **title:** 2010 CT NG Program Evaluation - ct2010ngprogramevaluation (Connecticut; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-01-01
- **effective on:** Not available
- **summary:** 2010 PHMSA natural gas program evaluation for Connecticut.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Natural Gas State Program Evaluation for Connecticut Department of Public Utility Control Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 1

2010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: Connecticut Rating: Agency Status: Date of Visit: 05/02/2001 - 05/04/2011 Agency Representative: Karl Baker, Supervisor of Technical Analysis PHMSA Representative: Jim Anderson, Transportation Specialist Commission Chairman to whom follow up letter is to be sent: Name/Title: Kevin M. DelGobbo, Chairman Agency: Connecticut Department of Public Utility Control Address: 10 Franklin Square City/State/Zip: New Britain, Connecticut 06051 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2010 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 25 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 4 4 D Incident Investigations 2.5 2.5 E Damage Prevention Initiatives 9 9 F Field Inspection 11 11 G PHMSA Initiatives - Strategic Plan 9 9 H Miscellaneous 3 3 I Program Initiatives 6 6 TOTALS 94 94 State Rating................................................................................................................................................... 100.0 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 2

PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: All sections of the 2011 Certification were completed accurately. 8 8 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: GPSU of the CT DPUC has 3 staff members on call 24 hours a day/7 days a week to receive incident reports from regulated operators. All operators are provided staff contact information to receive any incident reports. GPSU Administration Procedures address this in Section 18.4-Actions With Respect To Accidents. 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Connecticut along with other New England states paticipates in a region formed group called the New England Pipepine Safety Representatives (NEPSR). NEPSR host annual TQ training seminars rotated annually among the states. CT attended and participated in the Maine hosted seminar in October 2010. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: Yes. Inspection reports and GPUC correspondence with PHMSA and operators are stored electronicaly (backed up 3 times daily on server) and/or hard copies in centrally located file cabinets. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. Karl Baker, Supervisor of Technical Analysis, is the GPSU program manager. Karl was a pipeline safety engineer for 16 years prior to being promoted to program manager in Janauary 2010. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: Yes. PHMSA evaluation was conducted June 21-25, 2010, the letter to the Chair was sent August 17, 2011 and the Chair responded on October 6, 2010. DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 3

7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 1 NA SLR Notes: There were no issues raised during the 2009 evaluation. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: All engineers have either completed their TQ training within the timeframe or on schedule to complete their training. 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: None taken in 2010. 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: Bruce Benson is the designated OQ inspection leader and has completed all required TQ OQ training courses and computer based training. 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: Dan Nivison is the designated IMP inspection leader and has completed all required TQ IMP training courses and computer based training. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 383.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.77 = 829.40 Ratio: A / B 383.00 / 829.40 = 0.46 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: Yes. The ratio exceeded the required total inspection person days. 5 5 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 4

13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: Yes. In October 2010 the GPSU hired Eugene Osei. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 5

PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: All applicable type of inspections are included in the inspection plan. Karl Baker, program manager, plans to update inspection plan in 2011. The update will include DIMP inspections. These are listed in the GPSU Administrative Procedures Section 5. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: These are listed in the GPSU Administrative Procedures Section 6. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 SLR Notes: CT GPSU alternate yearly on comprehensive instections. LDC - O&M in 2009/2011, LNG - 2010, LP - 2010. 2 2 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: Yes. CT GPSU uses the federal form for LNG inspections. It uses the federal form with state additional regulation and NTSB questions added. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 SLR Notes: Yes. There were many redundant comments. 1 1 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 .5 NA DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 6

SLR Notes: N/A. None in 2010. 7 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Yes. This question is on the inspection form. .5 .5 8 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) Previous Question B.8 Yes = .5 No = 0 SLR Notes: Yes. This question is on the inspection form. .5 .5 9 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) Previous Question B.9 Yes = .5 No = 0 SLR Notes: Yes. This question is on the inspection form. .5 .5 10 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: Yes. This question is on the inspection form. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Each inspected operator received a copy of the inspection report summary with included a section on probable violations. 1 1 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. This is in Section 10 of the GPSU Administrative Procedures. 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. This is in Section 11 of the GPSU Administrative Procedures. 1 1 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. It is in the GPSU Administrative Procedures. DUNS: 957636095 2010 Natural Gas State Program Evaluation 1 1 Connecticut Connecticut Department of Public Utility Control, Page: 7

15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: Yes. In 2010 96 violations were found and 35 compliance actions were sent to regulated operators. 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. This is in the Administrative Procedures but this is one of the areas the GPSU plans expand upon in its Administrative Procedures update. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: Yes. In Section 10 of the GPSU Administrative Procedures. 1 1 18 SLR Notes: Yes. Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 SLR Notes: Yes. It is stated in the GPSU Administrative Procedures, Section 10. Not only sent to but the GPSU assures a response is received by a company officer. 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Section 10 of the GPSU Administrative Procedures covers this. 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: N/A. 1 NA 22 SLR Notes: N/A. Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 957636095 2010 Natural Gas State Program Evaluation 1 NA Connecticut Connecticut Department of Public Utility Control, Page: 8

SLR Notes: N/A. 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: N/A. 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: N/A. 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: N/A. 27 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) Info Only = No Points Info Only Info Only SLR Notes: 28 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 9

PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. CT followed inspection plan submitted by the Eastern Region. 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 1 1 SLR Notes: Yes. Inspection information was submitted to Eastern region within 30 days. 4 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.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: N/A. No probable violations found during the inspections in 2010. 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? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: N/A. 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: N/A 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: N/A. 1 1 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 10

PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Guidelines were followed. 1 1 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: Yes. .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: N/A. No incidents in 2010. 1 NA 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: N/A. No incidents in 2010. 1 NA 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: N/A. No incidents in 2010. 2 NA Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: N/A. No incidents in 2010. 1 1 7 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 annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: N/A. No incidents in 2010. .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 11

Total points scored for this section: 2.5 Total possible points for this section: 2.5 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 12

PART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2009 and early 2011. Also state regulations, 16-345-4(a)(5), states "?If the excavator is utilizing trenchless excavation, the excavator shall, if such excavation is expected to cross or encroach within the approximate location of underground facilities either horizontally or vertically, prior to the crossing or encroaching, determine the precise location of such underground facilities expected to be so crossed or encroached." 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? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes. Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2009 and early 2011. This is also accomplished during normal review of one-call damages that are reported to the GPSU. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: program. The GPSU has performed a review of the CGA Best Practices document and determined that all pertinent best practices are included in the state regulations. They are currently working on revising the underground damage prevention laws and are reviewing the CGA Best Practices to see if they can strengthen the 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? New 2008 Yes = 1 No = 0 SLR Notes: Yes, GPSU collects and evaluates this data. Damages per 1000 tickets - 2006 ? 4.39 total 2007 ? 4.26 total 2008 ? 4.10 total 2009 ? 3.21 total 2010 ? 3.53 total; 1.73 gas 1 1 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes. Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2009 and early 2011. This is also accomplished during normal review of one-call damages that are reported to the GPSU. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Connecticut Natural Gas Name of State Inspector(s) Observed: Ed Fabrycki and Dan Nivison Location of Inspection: East Hartford, CT Date of Inspection: May 4, 2011 Name of PHMSA Representative: Jim Anderson SLR Notes: Observed Ed Fabrycki conducting new construction inspection and Dan Nivison conducting a Damage Prevention procedures inspection. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: Yes. Company personnel were present at both inspections. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 2 2 SLR Notes: Yes. Due to inclimate weather, notes were taken at construction site and later entered on a construction inspection form on the inspectors laptop. A copy of the inspection report was given to the PHMSA representative prior to the completion of the evaluation. The damage prevention inspection was conducted on the PHMSA inspection form with state damage prevention regulations attached. 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: Yes. No Concerns. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 SLR Notes: Yes. Heating irons were tested with pyrometer. 1 1 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: Construction and Damage Prevention Procedures. Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) DUNS: 957636095 2010 Natural Gas State Program Evaluation 2 2 Connecticut Connecticut Department of Public Utility Control, Page: 14

SLR Notes: Records were reviewed at operator operation center during the inspection. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: Yes. 2 2 9 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) Previous Question F.10 Yes = 1 No = 0 SLR Notes: Yes. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: None found. 1 NA 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: replacement program. DPUC inspector observed the installation of a new 2" PE main being installed to replace a high risked older cast iron main in the companies cast iron 12 SLR Notes: Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points Info Only Info Only 13 Field Observation Areas Observed (check all that apply) 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 Info Only Info Only DUNS: 957636095 2010 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 15

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 D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 957636095 2010 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 Connecticut Connecticut Department of Public Utility Control, Page: 16

PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: Yes. Section 8 of the DPUC Administrative Procedures states "Inspections" are ordinarily conducted pursuant to one of the following criteria. (a) Routine scheduling (b) A complaint received from a member of the public (c) Information obtained from a previous inspection (d) Pipeline accident or incident (e) Whenever deemed appropriate by the Department Every operator and every inspection unit will be inspected in accordance with 6c above, with priority given to inspecting systems with greater risk potential. In determining the potential risk of a facility, the following factors may be considered. (a) The length of time since the last inspection (b) The history of the inspection unit (leak history, unaccounted-for gas, prior non-compliances, accident/incident history, etc.) (c) Types of activities being undertaken by the inspection unit (construction, recent changes in personnel and procedures, etc.) (d) For multi-unit operators, rotation of inspection units to be inspected (e) The nature of the facility (pipeline, LNG plant, propane plant) (f) Pressure classification (low, elevated-low, high) (g) Material involved (cast iron, steel, plastic) (h) History of the type of facility (i) Population density (j) Threats to the facilities (Excavation damage, corrosion, natural forces, other outside forces, material or welds, equipment, operations)" 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points SLR Notes: N/A at this time. Info Only Info Only 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. Approximately twice per year the damage prevention data is reviewed to determine trends. These trends are reviewed to determine where emphasis needs to be placed. These trends are also reviewed with the Call Before You Dig Public Awareness Committee and where appropriate, the public awareness campaigns are modified. 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 DUNS: 957636095 2010 Natural Gas State Program Evaluation .5 0.5 Connecticut Connecticut Department of Public Utility Control, Page: 17

SLR Notes: Yes. Program manager has many spreadsheets showing data and trends of the operators pipelines, services, damages and other information. 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 SLR Notes: Yes. Program manager has many spreadsheets showing data and trends of the operators pipelines, services, damages and other information. 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: Yes. As part of their investigation of incidents/accidents. .5 0.5 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: program data. Yes. They evaluate their program using leak response time data, class 2 leak backlog data, third-party damage data and cast iron/bare steel replacement 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 SLR Notes: Yes. Viewed the state's OQ data base web page to verify database entry. .5 0.5 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: Yes. Viewed the state's IMP data base web page to verify database entry on participation on interstate pipeline IMP inspection. .5 0.5 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: N/A ? No intrastate transmission lines in Connecticut. .5 NA 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. All data on class 1 and 2 leaks are required to be submitted to the GPSU on a monthly basis. This data is reviewed to determine trends including any plastic pipe issues. Also, during the O&M audits, this is reviewed under 192.617. 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 SLR Notes: N/A ? No intrastate transmission lines in Connecticut. .5 NA Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: DUNS: 957636095 2010 Natural Gas State Program Evaluation Yes. Incidents/accidents lessons learned information have been presented at NAPSR meetings and pipeline safety seminars. In addition, all incident/ accident reports are sent to all applicable operators in the state for their review and response to any applicable recommendations included in the report. Connecticut Connecticut Department of Public Utility Control, Page: 18

16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The state ensures that operators correctly file appropriate PHMSA incident forms. 17 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only SLR Notes: Yes. All incidents/accidents are investigated to determine the root cause. Staff has completed root cause analysis training classes. Info Only 18 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points SLR Notes: The state works in conjunction with their operators to perform root cause analysis. Info Only Info
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