# 2020 GA NG Program Evaluation - ga-2020-gas-program-evaluation (Georgia; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ga-2020-gas-program-evaluation
- **title:** 2020 GA NG Program Evaluation - ga-2020-gas-program-evaluation (Georgia; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-01
- **effective on:** Not available
- **summary:** 2020 PHMSA natural gas program evaluation for Georgia.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2022-05/ga-2020-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 2020 Gas State Program Evaluation for GEORGIA 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: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 1

2020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Georgia Rating: Agency Status: Date of Visit: 11/01/2021 - 11/05/2021 Agency Representative: Michelle L. Thebert PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Tricia Pridemore, Chairman Agency: Georgia Public Service Commission Address: 244 Washington Street, SW City/State/Zip: Atlanta, GA 30334 60105(a): Yes 60106(a): No Interstate Agent: No 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 2020 (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 47 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 97 State Rating................................................................................................................................................... 97.0 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only Info Only = No Points Stats On Operators Data - Progress Report Attachment 1 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 Evaluator Notes: Attachment 10* A. Verified-No Issues. B. Verified total number of inspection days entered into Attachment 2 with their database. C. They have 198 on attachment 3 and 211 on attachment 1. They need to explain the difference. D. Incidents reviewed - No Issues E. Compliance actions reviewed - No Issues H. "All regulations adopted. Civil penalty levels for 07/2020 Adopted ($222,504/$2,225,034) State of Georgia adopted the same maximum penalties as DOT/PHMSA -July 2020 Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110305872 2020 Gas State Program Evaluation GEORGIA PUBLIC SERVICE COMMISSION, Page: 3 Georgia

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 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: Procedures for conducting inspections are in Section 1 of the manual. 5 5 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: Yes, this is covered in Section 1. General 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 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: Yes, found in R - Notice of Enforcement Yes, found in T - Notice of Probable Violation Tracking Yes, found in U - Closure of a Probable Violation 3 3 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. Evaluator Notes: Yes, found in Section VI. - Investigation of Incidents 3 3 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 4

5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead 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) 5 5 Evaluator Notes: After review of inspection documents inspectors have completed the required training before conducting specific inspections. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, Michelle Thebert showed she has adequate knowledge of the PHMSA program and regulations. 5 5 3 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA 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 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) 5 2 Evaluator Notes: A review of the inspections for operators on the CY 2020 list showed that the inspection interval set in the GPSC procedures had been missed for several different types of inspections. All inspection types had both recent and prior dates. Due to the effects on business of the Covid 19 outbreak, there is a loss of 3 points 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) 10 10 Evaluator Notes: Yes, the GPSC utilizes the Federal form and has created a State Form that covers NTSB and ADB questions. A reviewed inspection reports showed all applicable portions were completed. 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: Yes, The GPSC also performs OQ Protocol 9 during every inspections to assure operator personnel are qualified to perform tasks. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 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 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/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? 2 2 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 7

Evaluator Notes: Yes, the GPSC started meeting with their largest operator on an annual basis 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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. 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? 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 1 1 Evaluator Notes: Yes, the have questions from their State and PSC rules page that are included in their comprehensive inspections. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to 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 10 10 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 8

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: Yes, verified thru review of records and documentation 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? 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? 10 10 Evaluator Notes: a. Yes, the GPSC has an adequate mechanism to receive incident reports from operators. Each operator is given the inspectors contact phone numbers and all inspectors are on-call to receive notifications. b. Yes, verified thru review c. Yes, verified thru review d. Yes e. Yes f. Yes g. No violations cited in reports h. Yes I. Yes, at NAPSR Region 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 Evaluator Notes: Yes, Letter to state on 10/27/2020. The state received a 30 day extension and responded on 1/20/2021 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: State held a virtual seminar in November 2020 Info Only Info Only 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: yes Info Only Info Only DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 9

12 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the GPSC has a website with their enforcement cases listed for public review. 1 1 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRC reports for 2020 1 1 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: Yes, verified responses to NAPSR surveys. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State had two waivers on the PHMSA web site. After discussing the state will contact Jenny Donohue to remove one that is no longer relevant and will monitor the other. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, the records are electronically saved on a database. (Data Base is older version) 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 Evaluator Notes: SICT ? 994 2020 Progress Report ? 995 3 3 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: Discussed them with the PM and Jeff Baggett 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: DUNS: 110305872 2020 Gas State Program Evaluation Info Only Info Only Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 10

The GPSC has added a question to their inspection forms and will discuss at this years safety seminar with operators. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D1. A review of the inspections for operators on the CY 2020 list showed that the inspection interval set in the GPSC procedures had been missed for several different types of inspections. All inspection types had both recent and prior dates. Due to the effects on business of the Covid 19 outbreak, there is a loss of 3 points Total points scored for this section: 47 Total possible points for this section: 50 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA 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 Info Only Info Only Evaluator Notes: b. N/A a. Construction inspections were conducted and reviewed 10/19-10/21. c. Atlanta gas contractors were inspected. d. Georgia performs team inspections. The inspectors evaluated were Alan Towe, Jeff Bagget and Jack Hewett. 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 2 2 Evaluator Notes: The inspectors used a state construction form and OQ protocol 9. These form were filled out during the inspection. 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. Weld, fusing and coating application procedures were reviewed during the inspection. b. Calibration and OQ records were reviewed during the inspection. c,d. A thorough inspection of steel and plastic construction was conducted during the certification inspection. Projects were inspected in Atlanta, Rockmart and Acworth. Damage prevention, pipeline specifications, trenching, joining, coating application, backfilling, tapping, valve placement, pressure testing, purging and operator qualifications were evaluated. e. The inspections lasted the entire day. Follow up will be scheduled on the Atlanta steel main project once trenching is completed. 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 2 2 Evaluator Notes: The inspectors were experienced and knowledgeable. The asked appropriate questions, follow up and validation for the various construction activities. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 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: Exit interviews were conducted at the end of the inspections. Follow up will be required on damage prevention classification and valve placement issues.DUNS: 110305872 Georgia 2020 Gas State Program Evaluation GEORGIA PUBLIC SERVICE COMMISSION, Page: 12

6 Was inspection performed in a safe, positive, and constructive manner ? Info Only Info Only 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. Inspector wore the appropriate PPE, participated in initial safety briefing, were aware of traffic and heavy equipment. b. Projects were inspected in Atlanta, Rockmart and Acworth. Damage prevention, design, pipeline specifications, trenching, joining, coating application, backfilling, tapping, valve placement, pressure testing, purging and operator qualifications were evaluated. Follow up will occur for damage prevention classification concerns and valve placement issues. c,d. Georgia conducts team inspections of operators. 7 General Comments: Info Only = No Points Evaluator Notes: No issues identified Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA 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 2 2 Evaluator Notes: Yes. Annual report data for each operator is consolidated into the risk ranking chart that PHMSA State Programs provided several years ago. The results of that risk ranking are reviewed and considered in scheduling operator inspections and annual DIMP reviews. 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: Yes. Excavation damages from Part C and D of the operators annual 7100 reports are reviewed during standard comprehensive inspections, and during regularly scheduled and annual DIMP reviews. 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. Yes. Excavation damages from Part C and D of the operators annual 7100 reports are reviewed during standard comprehensive inspections, and during normal and annual DIMP reviews. 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? 2 2 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 14

Evaluator Notes: Yes. Annual report data for each operator is consolidated into the risk ranking chart that PHMSA State Programs provided several years ago. Excavation damages from Part C and D of the operators annual 7100 reports are reviewed during standard comprehensive inspections, and during normal and annual DIMP reviews. (See attached work sheets) In addition, the GUFPA Case Manager (State Damage Prevention) reviews annual data from the Utility Protection Center in conjunction with the states annual data submission for the Common Ground Alliance. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA 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: The Georgia Public Service Commission is NOT an interstate agent 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: The Georgia Public Service Commission is NOT an interstate agent 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: The Georgia Public Service Commission is NOT an interstate agent 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: The Georgia Public Service Commission is NOT an interstate agent 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: The Georgia Public Service Commission is NOT an interstate agent Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The Georgia Public Service Commission is NOT an interstate agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110305872 2020 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 16
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