# 2018 IA NG Program Evaluation - ia-2018-gas-program-evaluation-revision2 (Iowa; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ia-2018-gas-program-evaluation-revision2
- **title:** 2018 IA NG Program Evaluation - ia-2018-gas-program-evaluation-revision2 (Iowa; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-01-01
- **effective on:** Not available
- **summary:** 2018 PHMSA natural gas program evaluation for Iowa.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2020-03/ia-2018-gas-program-evaluation-revision2.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Gas State Program Evaluation for IOWA UTILITIES BOARD 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: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 1

2018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Iowa Rating: Agency Status: Date of Visit: 08/05/2019 - 08/09/2019 Agency Representative: Yousif Magid, Acting Program Manager PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Geri D. Huser, Chair Agency: Iowa Utility Board Address: 1375 East Court Avenue, Room 69 City/State/Zip: Des Moines, Iowa 50319 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 2018 (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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 45 43 D Compliance Activities 15 15 E Incident Investigations 9 9 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 6 6 I 60106 Agreement State (If Applicable) 0 0 TOTALS 118 116 State Rating................................................................................................................................................... 98.3 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The IUB utilizes its Gas Inspection Database as the source for information input into Attachment 1. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A spreadsheet is kept on the M: drive in the safety engineering folder which tallies the inspection person days from inspector data on inspections. No issues found. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The source documentation was verified and inspection unit totals were consistent with the information on Attachment 1. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There was two reportable incidents listed on Attachment 4. These were incident reported by an interstate gas transmission pipeline operator. Since the IUB is an Interstate Agent it is appropriate for the IUB to list them. No incident reports were listed for intrastate operators which is consistent with the information contained in PHMSA's Pipeline Data Mart (PDM). 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The accuracy of the information was verified from the Gas Inspection Database. No issues were found. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Most records are in electronic files. No issues found. 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: No issues identified. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues identified. 1 1 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 3

9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues identified; however it should be noted that the Performance Plan should be reviewed and revised, if necessary, each year. 10 General Comments: Info Only = No Points Evaluator Notes: The IUB met the requirements in Part A of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 4

PART 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (a. of the procedures describes Standard Inspection procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (d. of the procedures describes IMP and DIMP Inspection procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (e. of the procedures describes Operator Qualification (OQ) Inspection procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (g. of the procedures describes Damage Prevention Inspection procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (c. of the procedures describes Operator Training procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 5

6 Construction 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 4, Paragraph (b. of the procedures describes Construction Inspection procedures. Element 3 describes the Pre-Inspection, Inspection and Post Inspection activities to be used for all types of inspections. No issues found. 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: The IUB's SAFETY & ENGINEERING SECTION PIPELINE SAFETY PROGRAM INSPECTION AND COMPLIANCE PROCEDURES were reviewed. Element 2 of the procedures describes factors to be considered for priority and scheduling. The IUB's PROCEDURES FOR SCHEDULING PIPELINE INSPECTIONS states "Risk is accounted for in the inspection schedule through more frequent inspection of small operator units, an aggressive follow-up inspection program, and visits to new operators or personnel. Iowa does not have operators or inspection units with histories, activities, or high risk that would justify extraordinary inspection frequency or conduct. Additional inspections may be conducted if a need is identified. In addition or as an alternative to additional inspections, periodic reports may be required from operators." The IUB's inspection units appear to be appropriate. 8 General Comments: Info Only = No Points Evaluator Notes: The IUB met the requirements of Part B of this evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 505.60 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.56 = 1003.20 Ratio: A / B 505.60 / 1003.20 = 0.50 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The IUB exceeded the minimum number of inspection person days required with a ratio of 0.5. 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: Upon reviewing reports queried from PHMSA Training and Qualification Division's SABA database no training deficiencies were found. No outside training was received by the inspectors. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 0 Evaluator Notes: The Program Manager at the time of evaluation is Acting as a new Program Manager has not been named as yet. 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 IUB responded prior to the 60 day deadline. The response addressed the deficiencies. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: The IUB conducted February 2016. The previous seminar was conducted in 2014. The most recent was conducted in February 2019. 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 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 7

Evaluator Notes: Upon a review of randomly selected inspection reports completed during CY2018 there were no issues identified involving the inspection interval of the operators or units. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Beginning in approximately June 2018, the IUB utilizes IA to create its inspection form questions. Prior to this time, the IUB used PHMSA's form except for Standard Inspections of gas distribution and transmission pipelines. The IUB created its own form for Standard Inspections. Upon a review of the two Standard Inspection forms no code requirements were found to be omitted. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The last segment of cast iron was removed in 2015. There is no known cast iron pipe remaining in Iowa. 1 NA 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The last segment of cast iron was removed in 2015. There is no known cast iron pipe remaining in Iowa. 1 NA 10 Did the state review operator emergency response procedures for leaks caused by 1 1 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: The IUB has a question on the Standard Inspection Form for Gas Distribution operators. Upon a review of randomly selected Standard Inspections the results to this question were documented. 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: The IUB has a question on the Standard Inspection Form for Gas Distribution operators. Upon a review of randomly selected Standard Inspections the results to this question were documented. 12 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 reports are reviewed for accuracy. Operators are notified of any errors found and requested to amend their submittals. This information was documented on the Standard Inspection forms. 13 DUNS: 026552171 2018 Gas State Program Evaluation Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? 1 1 Iowa IOWA UTILITIES BOARD, Page: 8

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The IUB has a question on the IA Standard Inspection Form for Gas Transmission operators. Upon a review of randomly selected Standard Inspections the results to this question were documented. 14 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The IUB conducted 35 drug and alcohol inspections in CY2018. 2 2 15 Is state verifying operators OQ programs are up to date? This should include verification 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: The IUB spent 24.6 inspection person days on Operator Qualification inspections in CY2018. 2 2 16 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). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The IUB spent 0.5 inspection person days on Transmission IMP in CY2018. 2 2 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The IUB spent 31.2 inspection person days on distribution pipeline integrity management inspections (DIMP) during CY2018. 18 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. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The IUB conducted 26 Public Awareness Inspections during CY2018. 2 2 19 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: Yes, Iowa has a website for pipeline safety. Anyone can access the Iowa electronic filing system to review information including all inspections and reports. DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 9

20 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: None were reported during CY2018 per the Pipeline Data Mart and the IUB's records. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The IUB has a question on the IAC inspection form. The IUB started using IA in June 2018. Upon a review of randomly selected inspections the results to this question were documented. 22 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 IUB did not cooperate. 1 1 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: All special permits were reviewed. The IUB is continuing to follow-up on the one special permit with conditions; however, it is possible that the special permit is no longer needed because regulations now allow the issue. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Beverly Ohman attended the meeting in Santa Fe, New Mexico. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: 1. Damage Prevention Program: The gas distribution damages per 1,000 tickets trended downward from approximately 3.1 damages per 1,000 tickets to approximately 2.3 damages per 1,000 tickets in 2015. The trend has increased to approximately 2.7 damages per 1,000 tickets in 2017 and 3.0 damages per 1000 tickets in 2018. The damages per 1000 locates is a focus area to improve metrics whose trend is basically in a negative direction. The IUB is analyzing data to identify problem areas and mitigating actions. 2. Inspection Activity: a. Gas Pipelines: The Inspection Days per 1,000 miles of pipeline have trended in a positive direction since 2014. No mitigating actions are warranted. LPG Units: With only two LPG inspection units in Iowa, trending of this metric are difficult to analyze. Ensuring the units are inspected within established intervals is a better indicator of performance. No mitigating actions are warranted. 3. Inspector Qualification: The trend has moved in a negative direction since 2013. A focus and commitment to completion of required courses by staff replacements will reverse the trend. A new program manager hired in February 2018 that has not taken any training has impacted this metric. The position is vacant again. The new Program Manger to be hired should make completing TQ courses a high priority. DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 10

4. Leak Management: Leak repairs per 1,000 miles are on a slight positive trend with hazardous leaks repaired per 1,000 miles relatively flat. A slight Improvement occurred in 2018. The number of known leaks outstanding per 1,000 miles has trended in a negative direction since 2011 which may need some attention if the trend continues. 5. Enforcement (PHMSA's Evaluations): The IUB's performance has improved on this metric over the last four years including a perfect score for 2016. Continued follow through with its enforcement process of non-compliance findings will ensure satisfactory performance of this metric. 6. Incident Investigation: There was a considerable drop in this metric in 2016 which was a result of four evaluation points deducted for an incident that was not investigated and a report not completed. The proper follow through with the IUB's incident investigation procedures should result in improvement related to this metric. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: There no significant issues found during the review of SICT results performed in CY2018. DIMP implementation inspection for MidAmerica was included in the recent SICT as suggested by the peer review. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Upon review by the IUB with operators, no flow reversals occurred during 2018. 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only The Program Manager at the time of evaluation is Acting as a new Program Manager has not been named as yet. Total points scored for this section: 43 Total possible points for this section: 45 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 11

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 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 c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: The IUB's PIPELINE SAFETY ENFORCEMENT PROCESS document was reviewed. Enforcement steps were covered, operator notification was described and defined, resolution process was covered along with the process for report closure. 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? (Incident Investigations do not need to meet 30/90 day requirement) 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. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2018 there were no deficiencies found regarding (a., (b, (c, (d, (e or (f. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2018 there were no instances found where the IUB failed to issue compliance action when probable violations were identified. 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Operators were given opportunity to dispute any probable violations alleged in compliance notices. Operators may also request a hearing of their case. 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, the Acting Program Manager provided a list of criteria that are considered when deciding if a civil penalty is warranted. Repeat violations and violations contributing to an incident were on the list. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 026552171 2018 Gas State Program Evaluation 1 1 Iowa IOWA UTILITIES BOARD, Page: 12

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The IUB has not issued civil penalties since 2012. The IUB has not had a case since 2012 where the violations met the criteria considered for issuing a civil penalty. 7 General Comments: Info Only = No Points Evaluator Notes: The IUB has met the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 13

PART 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: Element 4, Paragraph (f., describes the procedures for responding and investigating incidents. Procedures should add three areas to be addressed in the investigation report; 1. Observations and document review, 2. Contributing factors 3. Recommendations to prevent reoccurrence. 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: The Iowa Utilities Board (IUB) has established by regulations the rotating additional duty of Duty Officer. The Duty Officer will receive notices of incidents and relay the information to the appropriate section, ie pipeline safety. The telephone number is in the regulation. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 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: There were no reportable incidents on intrastate pipeline facilities during CY2018. The IUB investigated two interstate pipeline as an interstate agent. One was a third party incident that was investigated by electronic document transfer and telephone conversations. Cause was obvious upon discovery that the One Call Center was not notified by the excavator. The remaining interstate incident was investigated on-site. No issues were found. 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: There were no reportable incidents on intrastate pipeline facilities during CY2018. The two interstate incidents investigated were documented and contributing factors noted. Recommendations were not applicable. 5 Did the state initiate compliance action for violations found during any incident/accident 1 NA investigation? Yes = 1 No = 0 Evaluator Notes: There were no reportable incidents on intrastate pipeline facilities during CY2018. Compliance actions on interstate incidents would be handled by PHMSA as described in the interstate agent agreement. 6 Did the 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? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 026552171 2018 Gas State Program Evaluation 1 NA Iowa IOWA UTILITIES BOARD, Page: 14

There were no reportable incidents on intrastate pipeline facilities during CY2018. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 The IUB has presented lessons learned at past NAPSR Central Region Meetings. The interstate incidents were discussed. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only There were no reportable incidents on intrastate pipeline facilities during CY2018. The IUB did conduct investigations on two interstate pipeline incidents as an interstate agent. The IUB met the requirements of Part E of this evaluation. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 15

PART 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: A question is on the Operation and Maintenance (O&M) Procedures inspection form that inspects the procedures about drilling/boring near an operator's pipeline. It is reviewed when conducting an inspection of operators' O&M Procedures. Upon a review of randomly selected inspection files completed during 2018 the IUB documented covering this requirement. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 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: There are several questions on the O&M procedures inspection form related to its Damage Prevention program required by 192.614. Upon a review of randomly selected inspection files completed during 2018 the IUB documented covering this requirement. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The IUB is a partner with the Iowa One-Call System. The IUB participates in activities of the Damage Prevention Councils. The IUB opened INU-2017-0001 which brought together excavation stakeholders with utilities, Attorney General's office and Iowa One-Call System to discuss changes in IUB regulations related to damage prevention. One objective was to increase effectiveness of procedures related to One Call. This initiative continued in 2018. 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: The IUB reviews the data collected for the Performance Metric in PRIMUS which originates from operators' annual reports. It reviews pipeline damages per 1000 locates to identify trends with an operator and problem geographical areas that need improvement. 5 General Comments: Info Only = No Points Evaluator Notes: The IUB has met the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 16

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Manning Municipal Gas Utilities Name of State Inspector(s) Observed: Dan O'Connor Location of Inspection: Pipeline construction project between Carroll and Templeton, IA Date of Inspection: August 7, 2019 Name of PHMSA Representative: Don Martin Evaluator Notes: The IUB conducted a construction inspection of a new gas transmission pipeline. The project consists of approximately 25 miles of high density polyethylene plastic pipeline installed in a farmland area. The pipeline consists of 10, 8 and 6 inch pipe, pressure control station, water bath heater and odorizer. 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. The operator was represented by the General Manager of Utilities and two USDI inspectors. 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: Manning-9010-2019. The inspector utilized the Inspection Assistant (IA) Form for Gas Transmission Construction. The IA inspection file is Insp- 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues were found with the documentation. 2 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: The primary equipment necessary was required during fusion of pipe joints. The inspector inspected calibration of the pyrometer, observed that pipe joiner was using pressure readings on the joiner equipment and that a timer was available to observe times during fusion and cooling. 2 2 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) Evaluator Notes: Pipe condition and specifications, pipe joining and pipe lay into ditch were observed. The inspector reviewed construction DUNS: 026552171 2018 Gas State Program Evaluation Iowa IOWA UTILITIES BOARD, Page: 17

procedures for polyethylene plastic pipe. Qualifications of joiners were reviewed. Above facilities fabrication was observed. The qualifications of the welder were reviewed. 7 Did th
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