2014 IN NG Program Evaluation - in2014ngprogramevaluation (Indiana; Natural Gas State Program Evaluation)

IN 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 INDIANA UTILITY REGULATORY 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: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 1#

IN NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Indiana Rating: Agency Status: Date of Visit: 07/07/2015 - 07/17/2015 Agency Representative: Steve Allen, Director, & Bill Boyd, Division Manager PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Carol A. Stephan, Chair Agency: Indiana Utility Regulatory Commission Address: 101 West Washington Street, Suite 1500 East City/State/Zip: Indianapolis, Indiana 46204-3407 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 10 B Program Inspection Procedures 13 13 C Program Performance 45 45 D Compliance Activities 15 15 E Incident Investigations 10 10 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 113 113 State Rating................................................................................................................................................... 100.0 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 2#

IN 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 1 1 Evaluator Notes: A1. Yes. Okay enough. Attachment 1 needs to be corrected due to confusion with previous directions. Attachment 1 will be submitted for correction by 7/17/15. Attachment 1 as amended will be in agreement with Attachments 3 & 8. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A2. Yes. Attachment 2 is consistent with internal records (a database that is exported to a spreadsheet). 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A3. Yes. Attachment 3 is consistent with internal records. 1 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: A4. Yes. Attachment 4 is correct. (We found that PHMSA'S DataMart has an suspected error for Indiana). 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A5. Yes. Attachment 5 is consistent with internal records. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 A6. Yes. Most of the records in Attachment 6 are now electronic, but several of these records also have paper files. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes. Attachment 7 appears to be consistent with internal records. 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: A8. Yes. Attachment 8 is consistent with IN Law. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 3#

IN NG Program Evaluation, 2014, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A9. Yes. Attachment 10 is a well-developed report. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A10. Yes. The IURC has done a good job with documenting and tracking its inspection activities for annual reporting purposes. The 2014 Annual Progress Report was complete and accurate. With that said, the effort involved with tracking these activities within the current IT systems is Herculean. The replacement Pipeline Safety Information System (currently being developed) should greatly enhance the IURC's abilities in this regard. Also, in Attachment 10 of the Annual Progress Report (Performance and Damage Prevention Questions), it is clear the IURC has a very strong Damage Prevention Program in place for which it should be commended. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 4#

IN 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 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: 2 2 B1. Yes. Inspection procedures including risk model, selection, assignment, pre-inspection, inspection, post inspection, write up, violation handling & closing for all types of inspections are described in Sections V & VI of the program manual. 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: B2. Yes. Inspection procedures including risk model, selection, assignment, pre-inspection, inspection, post inspection, write up, violation handling & closing for all types of inspections are described in Sections V & VI of the program manual. 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: 1 1 B3. Yes. Inspection procedures including risk model, selection, assignment, pre-inspection, inspection, post inspection, write up, violation handling & closing for all types of inspections are described in Sections V & VI of the program manual. 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: B4. Yes. Inspection procedures including risk model, selection, assignment, pre-inspection, inspection, post inspection, write up, violation handling & closing for all types of inspections are described in Sections V & VI of the program manual. In addition, IURC has developed a Damage Prevention Inspection Form which is used as an addendum to the standard inspection form and expands the Damage Prevention review. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes. Operator Training is addressed in Section V of the program manual under its own sub-heading. 1 1 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: B6. Yes. Inspection procedures including risk model, selection, assignment, pre-inspection, inspection, post inspection, write up, violation handling & closing for all types of inspections are described in Sections V & VI of the program manual. Construction Inspection is addressed in Section V of the program manual under its own sub-heading. DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 5#

IN NG Program Evaluation, 2014, page 67 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: B7. Yes. See Section IV of the program manual, "Data-Driven Risk Model and ?" sub-heading. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: B8. Yes. The IURC made significant progress in developing its overall program guidance and documentation during the year. The continued development and refinement of the Data-Driven Risk Model which drives the annual Inspection Plan, was significant. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 6#

IN 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): 784.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 7.48 = 1645.60 Ratio: A / B 784.50 / 1645.60 = 0.48 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes. 784.5 AFOD, 7.48 inspector-years, 784.5/(7.48*220)=.477, >.38, okay. 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: C2. Yes. All inspectors with 3+ years have completed their training. New inspectors are in the training cycle. All Inspectors attend one of the Purdue NACE corrosion courses annually. 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: C3. Yes. Steve & Bill make a great tag team! They are running a fine program. They show great knowledge. 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 2 Evaluator Notes: C4. Yes. The Chairman letter was 11/20/14, the Chairman response was 1/16/15. The response addressed both issues. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: C5. Yes, in May of 2013 & May of 2015. Practice is for every other year. 2 2 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 Evaluator Notes: C6. Yes. Reviewed for Standard, GIMP, LIMP, DIMP, PAPEI, CRM, & OQ; All okay. DUNS: 086329518 2014 Gas State Program Evaluation 5 5 Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 7#

IN NG Program Evaluation, 2014, page 87 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: C7. Yes. IURC uses the Federal Forms and addendum questions for its State Forms. I noted that some inspections are spread out over multiple years. I advised IURC that it is likely that portions of the inspection will be missed and fall out of the 5 yr inspection period if that practice continues. It was also noted that some special inspections need better explanations for the purpose and scope of the inspection. It was also noted that the inspection files are disjointed; that consolidation of the files is strongly advised. I further advised that NA, NC, & U are best explained in the inspection form itself, and not to rely on the Violation Letter or other notes to file. 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: C8. Yes it is on the Std Insp Form. 1 1 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: C9. Yes it is on the Std Insp 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: C10. Yes it is on the Std Insp Form. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C11. Yes. It is question 11 on the Std Insp Form. 1 1 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: C12. Yes. The annual reports are scored against a checklist, and data from the annual reports is used in the Risk Model. 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 DUNS: 086329518 2014 Gas State Program Evaluation 2 2 Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 8#

IN NG Program Evaluation, 2014, page 9C13. Yes, the OQ, GIMP, DIMP, & LIMP databases were reviewed and are properly populated. 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: C14. Yes. Annual report mileage is compared to NPMS mileage for all transmission operators as an annual exercise. 15 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: 2 2 C15. Yes. All operators receive the long form and/or short form D&A inspection within the inspection interval. 16 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: C16. Yes. Full OQ re-inspections are current; OQ Field inspections are part of most Standard Inspections. 2 2 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: C17. Yes. The GIMP, LIMP, & DIMP re-inspections are current, HCA and new constructions are investigated relative to IMP during most standard inspections. 18 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). 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: C18. Yes. The DIMP inspections are current, and new constructions are investigated relative to DIMP during most standard inspections. 19 Is state verifying operators Public Awareness programs are up to date and being 2 2 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: C19. Yes. The PAPEI inspections were finished in 2013, and Public Awareness is touched on during all Standard Inspections. 20 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 086329518 2014 Gas State Program Evaluation 1 1 Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 9#

IN NG Program Evaluation, 2014, page 10C20. Yes, bi-annual TQ Safety Seminars, email announcements as appropriate, ad hoc & inspection training, MM training seminars, and has a website for information for all stakeholders. 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: C21. NA. no SRC in 2014. 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: C22. Yes. Aldyl is a Question on the form, conducted during DIMP inspections. That question drives a conversation about other PE pipe. 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: C23. Yes. Steve is presently serving on the NAPSR Board, and IURC responds to all NAPSR requests. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified 0 0 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: C24. Yes, a time limit waiver that was issued in 2013 and is no longer applicable. IURC will contact PHMSA about this before 7/17/15. 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: C25. Yes. Steve & Bill attended Nat'l NAPSR, and Steve got elected to the Board. 0 0 26 Discussion on State Program Performance Metrics found on Stakeholder Communication 0 0 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 Evaluator Notes: C26. Yes. The IN state metrics were reviewed, the metrics show promise of being useful. However, whether these metrics are ALL of the appropriate measures for pipeline safety is yet to be determined. 27 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C27. Yes. The IURC has in place a very sophisticated risk model along with the associated tools for tracking and scheduling inspections. The overall number of inspection days completed by the IURC was satisfactory based on the number of dedicated pipeline safety inspection staff and the number of operators, miles of main and number of services within the state. The IURC should develop a better system for recording, tracking, organizing and consolidating individual inspection documents. This should be addressed with the new Pipeline Safety Information System. DUNS: 086329518 2014 Gas State Program Evaluation Total points scored for this section: 45 Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 10#

IN NG Program Evaluation, 2014, page 11Total possible points for this section: 45 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 11#

IN 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: D1. Yes. See Section VI in the Program 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: D2. Yes. The process as described in Section VI is used every time. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D3. Yes. The violations found were identified in the violation letters. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: D4. Yes. Due process is given to all. 2 2 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: D5. Yes. IURC has developed a matrix for fine assessment. 2 2 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: D6. Yes. Assessed $180,000 fine in CY2013. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only D7. Yes. The IURC has shown it uses several of the enforcement methods available to it to ensure operators comply with DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 12#

IN NG Program Evaluation, 2014, page 13pipeline safety regulations. In addition to the use of Warning Letters, Notices of Probable Violations and the issuance of civil fines, etc., the IURC also will work collaboratively with operators to gain compliance. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 13#

IN 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/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: E1. Yes. See Section IX of the Program Manual. 2 2 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: E2. Yes. The 24 hr no. is 317-232-2707. IURC is very aware of appendix D & E. 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: E3. Yes. Most significant incidents/accidents are investigated on-site. The others are reviewed telephonically, with emails, with 30 day reports, and with other timely written reports. 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: E4. Yes, Attachment 4 of the Base Grant Progress Report is adequate, and the Incident/Accident files are complete. It was also noted that the Incident/Accident files are disjointed; that consolidation of the files is strongly advised. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: E5. NA. No probable violations were discovered during an incident/acident in CY 2014. 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: E6. Yes, Appendix E in the Guidelines is understood and IURC will assist whenever requested. 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: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 14#

IN NG Program Evaluation, 2014, page 15Evaluator Notes: E7. Yes, during the Central Region NAPSR meetings. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: E8. CY 2014 had an unusually high number of significant incidents. Each incident was investigated thoroughly for compliance with the regulations and for lessons learned. One investigation is still ongoing. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 15#

IN 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 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: F1. Yes, It is a question on the Std Insp Form. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 F2. Yes, the question are on the IN State -Damage Prevention Form which is used as an addendum to the Std Insp Form. 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: F3. Yes, the IURC is actively engaged with the various Damage Prevention Councils that exist throughout the state. They are also actively engaged with the state's Underground Plant Protection Advisory Committee and are aggressively enforcing the state's One-Call Law. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F4. Yes, hits per thousand is rolled into the risk management model. 2 2 5 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: F5. In Indiana, fines collected for One-Call violations are dedicated to damage prevention efforts. This is accomplished by developing programs related to Public Awareness, Training and Incentives designed to reduce excavation damages. This is clearly an area of high interest in Indiana. The IURC has also developed a Damage Prevention specific Inspection Form and is doing a good job holding all operators accountable for damage prevention through inspections and enforcement of the state's One-Call law. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 16#

IN NG Program Evaluation, 2014, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Citizens Gas, opid 2392 Name of State Inspector(s) Observed: Howard Friend, Inspector Location of Inspection: 3244 Allison Av. Indianapolis, IN Date of Inspection: 7/15/15 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. Citizens Gas, opid 2392 Howard Friend, Inspector 3244 Allison Av. Indianapolis, IN 7/15/15 Patrick Gaume Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: G2. Yes. They had been contacted and knew we would be visiting a construction site. The Operator's inspector joined us at the job site. 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: G3. Yes. IURC INSPECTION REPORT OF CONSTRUCTION. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes. He filled out the form. 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: G5. Yes. The crew had a fully rigged out truck, back hoe, and bulldozer. They had all of the specialty tools for installing a PE service line. 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: DUNS: 086329518 2014 Gas State Program Evaluation 2 2 Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 17#

IN NG Program Evaluation, 2014, page 18G6. Yes. Field activities, with procedures and records check. This was an on-site visit to a construction site. The work plan and OQ certifications were on-site. 7 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: G7. Yes. Howard was very knowledgeable about the regulations and about the job he was inspecting. 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: G8. Yes. Timing for some of the fusions were done by counting rather than by using a clock. The paperwork was in order. The procedures were being followed. 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: G9. Yes. Timing for some of the fusions were done by counting rather than by using a clock. The paperwork was in order. The procedures were being followed. 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 Info Only Info Only DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 18#

IN NG Program Evaluation, 2014, page 19A. 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: G10. Yes. a,b,i, j,k,l,q,s,u,v,w,y,z,C,H,I. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 19#

IN 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 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: H1-8. NA. Not an Interstate Agent Program. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H1-8. NA. Not an Interstate Agent Program. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 20#

IN 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: I1-7. NA. Not a 60106 Program. 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: I1-7. NA. Not a 60106 Program. 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: I1-7. NA. Not a 60106 Program. 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: I1-7. NA. Not a 60106 Program. 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: I1-7. NA. Not a 60106 Program. 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: I1-7. NA. Not a 60106 Program. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I1-7. NA. Not a 60106 Program. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 086329518 2014 Gas State Program Evaluation Indiana INDIANA UTILITY REGULATORY COMMISSION, Page: 21#