2014 GA NG Program Evaluation - ga2014ngprogramevaluation (Georgia; Natural Gas State Program Evaluation)

GA NG Program Evaluation, 2014, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2014 Gas State Program Evaluation for GEORGIA PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 1#

GA NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Georgia Rating: Agency Status: Date of Visit: Agency Representative: PHMSA Representative: Commission Chairman to whom follow up letter is to be sent: Name/Title: Agency: Address: City/State/Zip: 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2014 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9.5 B Program Inspection Procedures 13 13 C Program Performance 45 45 D Compliance Activities 15 15 E Incident Investigations 11 11 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 114 113.5 State Rating................................................................................................................................................... 99.6 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 2#

GA NG Program Evaluation, 2014, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found with Attachment 1. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues with Attachment 2. The inspection days were supported by records kept by the GPSC. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: Needs Improvement. The total number of Master Meter Inspection Units in Attachment 1 did not match the total number in Attachment 3. Attachment 3 had 58 more inspection units than the total in Attachment 1. The GPSC had consolidated some Master Meter Systems owned and operated by Atlanta Gas and Light into larger inspection units. The number was reduced from 72 to 14. This reduction was reflected in Attachment 1 but not Attachment 3. The GPSC amended and resubmitted its 2014 Progress Report to correct the mistake. Therefore, a loss of half a point occurred. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, a review of Attachment 4 found two incidents were reported in CY2014. One did not meet Federal reporting requirements. Reviews of incident reports in the PipelineData Mart found the property amounts and cause code were entered correctly. No loss of points occurred. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No areas of concern. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: File folders and documentation of inspection reports were well organized. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: SABA training transcript is used to populate the training data in Attachment 7. No issues of concern. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 1 1 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 3#

GA NG Program Evaluation, 2014, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: GPSC will continue to take action to increase the maximum penalty amounts for violations of the pipeline safety standards to match the federal level. No issues except that Chairman's letter will mention points were deducted in Progress Report review portion. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A loss of half a point occurred in this section of Part A. Question A.3: The total number of Master Meter Inspection Units in Attachment 1 did not match the total number in Attachment 3. Attachment 3 had 58 more inspection units than the total in Attachment 1. The GPSC had consolidated some Master Meter Systems owned and operated by Atlanta Gas and Light into larger inspection units. The number was reduced from 72 to 14. This reduction was reflected in Attachment 1 but not Attachment 3. The GPSC amended and resubmitted its 2014 Progress Report to correct the mistake. Therefore, a loss of half a point occurred. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 4#

GA NG Program Evaluation, 2014, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Georgia Public Service Commission (GPSC) Facilities Protection Pipeline Safety Inspection Program Manual includes this item in Section III. - Procedures for Determining Inspection Priorities. No issues. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, GPSC Pipeline Safety Inspection Program Manual pages 6 & 9 address this procedure on IMP and DIMP inspections. The procedures identify frequencies of inspections which are once each 60 months. No issues. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, GPSC Pipeline Safety Inspection Program Manual page 11 addresses this procedure on OQ inspections. The procedures identify frequencies of once each 60 months. No issues. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, GPSC Pipeline Safety Inspection Program Manual page 9 addresses this procedure on Damage Prevention Inspections. The procedure identifies the frequency of once each 60 months. No issues. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, GPSC Pipeline Safety Inspection Program Manual page 8 addresses this procedure on On-Site Operator Training Inspections. The procedure identifies the frequency of the inspection which is as the need arises or requested by the operator. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, GPSC Pipeline Safety Inspection Program Manual page 8 addresses this procedure on Construction Inspections. The DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 5#

GA NG Program Evaluation, 2014, page 6procedure identifies the frequency of the inspection on as needed basis. 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) 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) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Yes, GPSC Pipeline Safety Inspection Program Manual addresses each of these items under Section III. Procedures for Determining Inspection Priorities. a. See Compliance History section of manual. b. Item 6 page 5. c. Item 7, page 5. d. All counties that have Gas service are identified as an inspection unit. e. The GPSC's relative risk assessment model was reviewed. No issues were identified. f. Yes 8 General Comments: Info Only = No Points Evaluator Notes: The GPSC generally met the requirements of Part B. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 6#

GA NG Program Evaluation, 2014, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 994.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.33 = 2273.33 Ratio: A / B 994.00 / 2273.33 = 0.44 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Inspection person days met for CY2014. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 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? 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 e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: a. All required base training courses have been completed by the pipeline safety staff members orthey are on track to complete. b. All DIMP and IMP inspections were led by inspectors that had completed the required training. The inspection database could cause someone to there is an issue since all inspectors involved in an inspection make seperate entries into the database. c. Five individuals have completed the root cause training course. d. NACE training e. Requirement added 12/31/2014. Zero point effect for this evaluation. 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 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Michelle Thebert has successfully completed several courses including PL1250. She has been with the Georgia Public Service Commission since 1996. She is scheduled to complete all pipeline safety training courses within five years or by January 31, 2019. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The GPSC responded in 31 days. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 2 2 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 7#

GA NG Program Evaluation, 2014, page 8Evaluator Notes: Yes, the GPSC holds seminars on an annual basis. The last seminar was held on April 7-10, 2014. 6 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 5 5 Evaluator Notes: The electronic data base of reports confirmed all types of operators and inspection units were performed in accordance with their pipeline safety plan. No issues. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the GPSC uses the federal inspection forms for all inspection types. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, this item is on the standard inspection form. GPSC has a Commission order that requires each operator to examine cast iron mains that have been exposed. If graphitization is found the pipeline must be replaced. 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 Yes = 1 No = 0 Evaluator Notes: Yes, this is listed and checked on the federal gas distribution standard inspection form. 1 1 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, this is listed and checked on the federal gas distribution standard inspection form. 1 1 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, GPSC Rule 515-9-4-.05 requires the facility owners and operators to report third party damages to the GUFPA section. GPSC reviews this reporting information along with accidents data to ensure the operator is complying with section 192.617 while completing the federal inspection form. DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 8#

GA NG Program Evaluation, 2014, page 912 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, GPSC reviews the annual reports during standard inspection and in Datamart. In developing their risk ranking model for inspections, they access the data mart files and check the annual reports for trends. No issues. 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 Evaluator Notes: Yes = 2 No = 0 Needs Improvement = 1 Upon a review of te OQ and IMP databases no issues were found in uploading results in a timely manner. 2 2 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: This item is covered in GPSC procedures manual section 3.2.f. This is reviewed against the operator's Operations and Maintenance Procedures, IMP inspection and often the inspector will call and verify by email. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is reviewed during the drug and alcohol inspection and described in GPSC Procedures Manual. The GPSC reported 19 Drug and Alcohol inspections during CY2014. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is reviewed during a review of the operator's O&M Plan and inspection. GPSC inspectors use PHMSA Form 13. The GPSC reported 82 inspection person days conducting OQ inspections during CY2014. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The GPSC reported 26 inspection person days conducting Gas IMP inspections during CY2014. No issues were found. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of files and database found all DIMP inspections were completed by December 31, 2014. 2 2 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 9#

GA NG Program Evaluation, 2014, page 1019 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 have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The database provided evidence that all operators were inspected before December 31, 2013. 2 2 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: GPSC docket system is a mechanism used to communicate with all stakeholders. All operators have been assigned a docket number and all inspections reports can be viewed on line at http://fp.psc.state.ga.us/pipelinesafety/default.aspx. 21 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: A review of Pipeline Data Mart found no safety related condition reports were filed in CY2014. 1 NA 22 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This issue is addressed as a stand-alone question on the GPSC Facilities Protection Unit inspection form. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No instances were found where the GPSC did not respond. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: The GPSC generally complied with Part C of this evaluation. 0 0 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: Michelle Thebert attended the National Meeting in Springfield, IL during CY2014. 0 0 26 DUNS: 110305872 2014 Gas State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points 0 0 Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 10#

GA NG Program Evaluation, 2014, page 11Evaluator Notes: The GPSC's metrics appeared to be at reasonable performance levels except for leak repairs which appears to be trending at higher levels each year. The GPSC should analyze the leak repair trend and develop Potential Accelerated Actions to cause leak repairs to trend downward over time. 27 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question C.2 b. No loss of points but the database can cause confusion because multiple inspectors make entries for the same inspection without a designator to whom is the lead inspector. Question C.26 - The GPSC's metrics appeared to be at reasonable performance levels except for leak repairs which appears to be trending at higher levels each year. The GPSC should analyze the leak repair trend and develop Potential Accelerated Actions to cause leak repairs to trend downward over time. This is a zero point question for CY2014. Total points scored for this section: 45 Total possible points for this section: 45 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 11#

GA NG Program Evaluation, 2014, page 12PART 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 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: a. This is listed in the GPSC Pipeline Safety Procedures Manual page 12, which states, "In accordance with the requirements of Commission Rule 515-9-3-.07, upon completion of an inspection, all probable violations shall be communicated verbally to the operator during the exit interview. The inspector shall attempt to conduct the exit interview with the appropriate company officer for private operators, or the manager/board member of a municipal gas operator. If these individuals are not available, the exit interview may be conducted with an appropriate company official; e.g. Service Center Supervisor, Gas Superintendent, Utility Director. b. Procedures for reviewing progress of compliance is accomplished via their docket reporting system and by the Director/ Supervisor. This review process is listed in the Procedures Manual. 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 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: A random sample of inspection reports were reviewed in the GPSC's inspection database. The following conclusions were derived from the review: a. Yes, this is listed in the Pipeline Safety Procedures Manual on page 13 under section VI. Preparation of Inspection Reports. b. Yes, a review of files and database confirm all probable violations were documented on inspection forms. c. Probable violations were resolved d. Yes, probable violations were routinely reviewed by Director/Supervisor by utilizing the docket filing system and data base. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: derived from the review: A random sample of inspection reports were reviewed in the GPSC's inspection database. The following conclusions were A review of 2014 inspection reports that contained a violation(s) cited indicated the operator was given due process to correct the violation or request a hearing. 80 notice of probable violations were issued in CY2014 resulting in a total of $6,115,000.00 in civil penalties assessed. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: 2 2 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 12#

GA NG Program Evaluation, 2014, page 13Yes, compliance action as described in GPSC Pipeline Safety Procedures Manual and commission rules meets this requirement. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Michelle Thebert is familiar with imposing civil penalties and compliance orders. In this regard, the total number of dollars assessed against operators for non-compliance in CY 2014 was $6,115,000. No issues. 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: Yes, the total number of dollars assessed against operators for non-compliance in CY 2014 was $6,115,000. No issues. 7 General Comments: Info Only = No Points Evaluator Notes: The GPSC generally met the requirements of Part D. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 13#

GA NG Program Evaluation, 2014, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: of concern. Yes, GPSC Pipeline Safety Inspection Program Manual page 9 addresses this procedure on Incident Investigations. No areas 2 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 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: Yes, this is described in section VII Procedures for Receiving Reporting of Incidents of the Pipeline Safety of GPSC Inspection Program Procedure manual. Records of incidents are maintained in the GPSC's data base and operator file folders. No issues. a. and b.: A discussion with Michelle Thebert, Director, Facilities Protection Unit, confirms she has an understanding about the MOU between NTSB and PHMSA and the Federal/State Cooperation agreement. No issues. 3 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC performs an on site investigation for all reportable incidents. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? 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: Yes, a review of the one incident report pertaining to Atlanta Gas Light Company that occurred in Snellville, GA. No issues were found with the investigation or report. No probable violations were found. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: NA. No probable violations were found. 1 1 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 14#

GA NG Program Evaluation, 2014, page 156 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues were known where the GPSC did not assist the Southern Region office. 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes, information on incidents and accident investigations was shared by Michelle Thebert at the NAPSR Southern Region meeting in Panama City, Florida in April 28, 2014. 8 General Comments: Info Only = No Points Evaluator Notes: The GPSC generally met the requirements of Part E. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 15#

GA NG Program Evaluation, 2014, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This item is listed on the Inspection Check list. A description of this item is provided in the Procedure Manual under Inspection Procedures, Construction. No issues. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. GPSC inspectors review this item during the standard and damage investigation inspections. Georgia state law and GPSC rules require all operators to be a member of the State Utility Protection Center and investigate third-party damages to their facilities and determine if a violation(s) has occurred by reporting the information to the One Call Center. 3 Did the state encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, GPSC adopted the Common Ground Alliance Best Practices under Rule 515-9-6-.01. 2 2 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, GUFPA continues to collect and review information on damages per 1,000 locate requests. This data is used by GPSC in risk ranking of operators to be inspected. 5 General Comments: Info Only = No Points Evaluator Notes: The GPSC generally met the requirements of Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 16#

GA NG Program Evaluation, 2014, page 17PART 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: Austell Natural Gas Name of State Inspector(s) Observed: Alan Towe, Inspector Location of Inspection: Austell, Georgia Date of Inspection: April 1-2, 2015 Name of PHMSA Representative: Don Martin, PHMSA State Programs Evaluator Notes: This inspection is a standard distribution inspection. Austell was represented by Eddie Wood, Director of Operations and Diane Woods, Operations Specialist. The inspection took place at Austell Gas's operations center at 5997 Hutcheson Drive, Austell, GA. The inspection activity focus was on pressure control equipment operations, maintenance and operator qualifications for pressure control. Records review of pressure control equipment and testing in the field. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, Mr. Towe notified the operator two weeks prior to the beginning of the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the inspector used Standard Inspection PHMSA Form 2, revised January 29, 2015, to record a review of records and reading taken at different pressure control locations on Austell's distribution system. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, observed the inspector recording readings and information about the operator's compliance with overpressure protection on PHMSA form 2. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, inspector checked the operator's overpressure protection testing equipment and verified proper calibration of the testing equipment. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) 2 2 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 17#

GA NG Program Evaluation, 2014, page 18Evaluator Notes: Yes, a very thorough review was performed by the inspector on Austell's written pressure control procedures, pressure control records, and pressure control reading taken during the field portion of the inspection. 7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes the inspector has over twenty years of experience and has completed all the required base Gas safety training courses at TQ. 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) Yes = 1 No = 0 Evaluator Notes: Yes, on June 10th, an exit interview was conducted with AGL representatives Eddie Wood and Diane Woods to discuss the results of the inspection. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector described any probable violation(s) found. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) 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 Info Only Info Only DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 18#

GA NG Program Evaluation, 2014, page 19y. 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 Evaluator Notes: The GPSC generally complied with the requirements of Part G of this evaluation. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 19#

GA NG Program Evaluation, 2014, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The GPSC 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 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 20#

GA NG Program Evaluation, 2014, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The GPSC does not have a Section 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The GPSC does not have a Section 60106 agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110305872 2014 Gas State Program Evaluation Georgia GEORGIA PUBLIC SERVICE COMMISSION, Page: 21#