2015 ID NG Program Evaluation - id2015ngprogramevaluation (Idaho; Natural Gas State Program Evaluation)

ID NG Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 Gas State Program Evaluation for IDAHO PUBLIC UTILITIES 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: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 1#

ID NG Program Evaluation, 2015, page 22015 Gas State Program Evaluation -- CY 2015 Gas State Agency: Idaho Rating: Agency Status: Date of Visit: 08/15/2016 - 08/19/2016 Agency Representative: Joe Leckie PHMSA Representative: Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Paul Kjellander, President Agency: Idaho Public Utilities Commission Address: 472 West Washington Street City/State/Zip: Boise, Idaho 83720-0074 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 2015 (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 46 45 D Compliance Activities 6 6 E Incident Investigations 9 9 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 104 102.5 State Rating................................................................................................................................................... 98.6 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2#

ID NG Program Evaluation, 2015, 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: Data is accurate and each unit was inspected in 2015. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Data is accurate for inspection days in 2015. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 0.5 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Data is inaccurate for number of operator inspection units based on the numbers not being in correlation with Attachment 1 and Attachment 3 of Progress Report. 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: Yes, one reportable incident was reported in 2015, and was listed in Progress Report and Pipeline Data Mart. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no compliance actions in 2015. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Inspection reports are kept in a filing cabinet in order of operators. 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: Yes, three inspectors started their T&Q training in 2015. 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: Idaho's rules and amendments for adoption has been reported accurately. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 3#

ID NG Program Evaluation, 2015, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Idaho described past and present accomplishments in damage prevention (establishment of Board); and the increase in construction inspections. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There were two issues identified in Part A, the inaccuracy of operator inspection units, and the non-implementation of civil penalties which do not meet DOT requirements. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 4#

ID NG Program Evaluation, 2015, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Process for Standard Inspection is included in Attachment E of Program Operation Procedures (POP). 2 2 2 IMP and DIMP 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: Process for IMP/DIMP Inspections is included in Attachment E of Program Operation Procedures (POP). 1 1 3 OQ 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: Process for OQ Inspections is included in Attachment E of Program Operation Procedures (POP). 1 1 4 Damage Prevention 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 Process for Damage Prevention Inspections is included in Attachment E of Program Operation Procedures (POP). 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Process for On-Site Operator Training is included in Attachment E of Program Operation Procedures (POP). 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: Process for Construction Inspections is included in Attachment E of Program Operation Procedures (POP). 1 1 DUNS: 102589939 2015 Gas State Program Evaluation 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 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 5#

ID NG Program Evaluation, 2015, page 6c. 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: Process is included in Section 8.0, Attachment B of the Program Operations Procedures (POP). 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 6#

ID NG Program Evaluation, 2015, 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 5 5 A. Total Inspection Person Days (Attachment 2): 250.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.09 = 679.62 Ratio: A / B 250.50 / 679.62 = 0.37 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: Idaho's ratio of calculated inspection person-days was 250.5/679.8=.368 which did not meet the requirement >=.38 for the 2015 calendar year. Idaho had no full time inspectors in 2015 with 12 months of pipeline safety experience. Per discussion with the States Program Director there will be no deduction in points for the 2015 calendar year due to the ratio of inspection days not meeting requirement by .01. However, State must meet the ratio of inspection days during the next evaluation period or expect a deduction in points. 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: Idaho has three inspectors that started employment in 2015 and were completing their T&Q core courses. 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, Pipeline Safety Program Manager indicated adequate knowledge of PHMSA program and regulations. 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 2 1 Evaluator Notes: Chairman's letter was sent on 10/29/15, and the response was received by PHMSA on January 13, 2016. This exceeded the 60 day required response time frame by 16 days. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Yes, there was a consolidated TQ Seminar with the States of WA, OR and ID in May 2015. 2 2 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 7#

ID NG Program Evaluation, 2015, page 86 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 Evaluator Notes: Idaho inspected 100% of its operators and units in 2015. 5 5 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: State completed all applicable portions of inspection form; however State needs to establish an inspection form for construction inspections. 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: No cast iron pipe in Idaho. 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: No cast iron pipe in Idaho. 1 NA 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 1 1 Evaluator Notes: The process for reviewing the operator emergency response procedures for leaks caused by excavation damage is included in section 3.2 of Program Operation Procedures. Also, information included in the IPUC Inspection Forms 1 and 2. 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: Idaho analyzed risk for each operator based on information taken from annual reports and included this information in a Leak Cause Spreadsheet that is updated on an annual basis. 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: Performance metrics identifies repairs and outstanding leaks that do not correlate from 2014 to 2015. Outstanding leaks have decreased from 2014 to 2015, but repairs have remained the same from 2014 to 2015. Idaho stated that this data will be discussed with their LDCs in 2016. DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 8#

ID NG Program Evaluation, 2015, page 913 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a 2 2 timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There were six OQ field inspections uploaded into database in 2015, and no IM inspections were performed in 2015. 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 Evaluator Notes: Yes, included in PHMSA Form 2 - Standard inspection form. 1 1 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, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection Activity Sheet. 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, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection Activity Sheet. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 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: Yes, process in included in section 1.2.2 of the Program Operations Procedures. Also, information included in the Inspection Activity Sheet. 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 have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There was one follow-up inspection performed in 2015. 2 2 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 9#

ID NG Program Evaluation, 2015, 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 be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There were no Public Awareness programs audited in 2015, but one scheduled for 2016. 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: IPUC website has mechanism for communicating with stakeholders, but no enforcement cases are on website. State is in process of discussing with legal on what should be posted on website. 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: There were no SRCRs in 2015. 1 NA 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Idaho has one LDC (Avista Utilities) with plastic aldalay tap fittings that are under a 20 year replacement program. 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: Yes, the state participated and responded to surveys or information request from NAPSR and PHMSA. 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No active waivers//special permits. 1 NA 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, in Phoenix, AZ. 1 1 26 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: DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 10#

ID NG Program Evaluation, 2015, page 11Performance metrics identifies repairs and outstanding leaks that do not correlate from 2014 to 2015. Outstanding leaks have decreased from 2014 to 2015, but repairs have remained the same from 2014 to 2015. Idaho stated that this data will be discussed with their LDCs in 2016. 27 General Comments: Info Only = No Points Evaluator Notes: There was one issue identified in Part C, the Chairman's letter response was not received within 60 days. Info Only Info Only Total points scored for this section: 45 Total possible points for this section: 46 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 11#

ID NG Program Evaluation, 2015, 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: State has process included in sections 5.5 - 5.7 of the Program Operations Procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 NA 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. 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. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: There were no compliance actions sited in 2015. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There were no compliance actions sited in 2015. 2 NA 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: There were no compliance actions cited in 2015. 2 NA 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The program manager is familiar with state process for imposing civil penalties; however there were none imposed in 2015. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no violations identified by State in 2015. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 102589939 2015 Gas State Program Evaluation Info Only Info Only Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 12#

ID NG Program Evaluation, 2015, page 13There were no issues identified in Part D. Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 13#

ID NG Program Evaluation, 2015, 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: Procedures. Process to address state actions in the event of an incident/accident are included in section 6.0 of the Program Operations 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: Process to receive and respond to operator reports to incidents, including after-hours reports is included in section 6.2 and 6.5 of the Program Operations Procedures. 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: There was no onsite investigation made during the 2015 calendar year. 1 NA 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 was one incident in 2015; a failure of regulator due to temperature (frozen). However, this incident was not investigated but a report was submitted by operator. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no compliance actions or violations in 2105. 1 NA 6 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: The State is available to assist region office when needed. 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 1 1 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 14#

ID NG Program Evaluation, 2015, page 15Evaluator Notes: State program. Idaho did a presentation at NAPSR Western Region meeting in 2015. Presentation provided insight on current affairs of 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 15#

ID NG Program Evaluation, 2015, 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: Process for the review of directional drilling/boring is included in section 3.4 of the Program Operations Procedure, and the information also included in Form 2 - Standard inspection form used by the IPUC. 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: Process is included in section 3.12 of the Program Operations Procedures, and the information included in Form 2 - Standard inspection form used by IPUC. There are two one-call centers in Idaho (PASSWORD and Digline). 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: A new law was passed by the legislature creating a damage prevention council that will enforce the damage prevention laws. The Council will hold its first meeting in September 2016. Joe Leckie will be representing the IPUC on the council. 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 IPUC collects data for each operator on the number of pipeline damages per 1,000 miles of pipeline based in information in the operator's annual reports. Also, operators on a voluntary basis are entering data into DIRT. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 16#

ID NG Program Evaluation, 2015, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Intermountain Gas Company Name of State Inspector(s) Observed: Darrin Ulmer and Bob Jamison Location of Inspection: 5555 South Cole Road, Boise ID Date of Inspection: August 17 & 18, 2016 Name of PHMSA Representative: Clint Stephens Evaluator Notes: The State inspectors performed a Standard inspection by reviewing records and field observations. Info Only Info Only 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 notified and given the opportunity to be present during 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 Evaluator Notes: Yes, the inspector used the appropriate form as a guide during the inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector thoroughly documented the results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, the operator used pressure gauges to test regulators, and voltmeters with half cells to check pipe-to-soil potentials. 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: Yes, the inspector observed testing of regulators; cp monitoring; marker signs; above ground leaks (soap test); exposed piping (bridge crossing; regulator test records; pipeline maps; and cp monitoring records. DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 17#

ID NG Program Evaluation, 2015, page 187 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 Evaluator Notes: Yes, the inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: The inspection was not complete during the audit; however the operator was made aware of issues found at the time of discovery. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The inspection was not complete during the audit; however the operator was made aware of issues found at the time of discovery. 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 y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 18#

ID NG Program Evaluation, 2015, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The items checked above were observed during field observations with no non-compliance issues found during the audit. A relief valve failed to seat during test, but was repaired during audit with no further issues. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 19#

ID NG Program Evaluation, 2015, 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: 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: 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: 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: 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: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 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: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Idaho is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 20#

ID NG Program Evaluation, 2015, 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: 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: 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: 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 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 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: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Idaho does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102589939 2015 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 21#