2015 KS NG Program Evaluation - ks2015ngprogramevaluation (Kansas; Natural Gas State Program Evaluation)

KS 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 KANSAS CORPORATION 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: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 1#

KS NG Program Evaluation, 2015, page 22015 Gas State Program Evaluation -- CY 2015 Gas State Agency: Kansas Rating: Agency Status: Date of Visit: 05/01/2016 - 05/06/2016 Agency Representative: Leo Haynos, Chief of Gas Operations & Pipeline Safety PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Jay Scott Emler, Chairman Agency: Kansas Corporation Commission Address: 1500 SW Arrowhead Road City/State/Zip: Topeka, Kansas 66604-4027 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 10 B Program Inspection Procedures 13 13 C Program Performance 49 45 D Compliance Activities 15 15 E Incident Investigations 7 7 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 114 110 State Rating................................................................................................................................................... 96.5 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 2#

KS 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 1 1 Evaluator Notes: A1. Yes. Attachment 1 is correct and is consistent with attachment 3 and attachment 8. KS will add comments to Attachment 3 & 8 to address a problem with KS law which currently fails to authorize the KSCC to exercise authority over jurisdictional gathering lines. Per discussion KS will amend Attachments 1 & 3 to show gathering line Operators and Units. The purpose is to not lose track of those operators and Units as the law should be corrected within 3 years. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A2. Yes. Conducted a review of the 2014 KSCC Progress Report and found the number of inspection days entered matched the office files. No issues were found. 692 inspection days 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: A3. Yes. Verified the number of operators and inspection units on Attachment 3 matched the office records maintained by Kansas Corporation Commission (KSCC) by reviewing office files. No issues and information is correct. KS will add comments to Attachment 3 & 8 to address a problem with KS law which currently fails to authorize the KSCC to exercise authority over jurisdictional gathering lines. Per discussion KS will amend Attachments 1 & 3 to show gathering line Operators and Units. The purpose is to not lose track of those operators and Units as the law should be corrected within 3 years. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A4. Yes. Attachment 4 correctly shows that there were zero significant Gas incidents in 2015. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A5. Yes. Reviewed Attachment 5, No issues found. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A6. Yes. Official files are still paper but transitioning to electronic. The files are still adequate but not as well ordered as last year. I cautioned KSCC to diligently monitor the transition to electronic files. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes. A detailed review of employees listed on Attachment 7 was conducted and compared to the SABA training transcript. No areas of concern. 4.25 inspector-years DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 3#

KS NG Program Evaluation, 2015, page 48 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A8. Yes. A review of PHMSA State Program rules and regulations in SharePoint indicated civil penalty amount for a single violation is below the required amount of $100,000. KSCC amount is $25,000. We discussed increasing the amount to the federal level in the future. All rules and amendments listed in Attachment 8 have been adopted within the required time schedule of three years after the effective date. KS will add comments to Attachment 3 & 8 to address a problem with KS law which currently fails to authorize the KSCC to exercise authority over jurisdictional gathering lines. Per discussion KS will amend Attachments 1 & 3 to show gathering line Operators and Units. The purpose is to not lose track of those operators and Units as the law should be corrected within 3 years. 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: A9. Yes. A review of Attachment 10 found a good summary of planned and past performances by KSCC. No issues of concern. 10 General Comments: Info Only = No Points Evaluator Notes: A10. No loss of points occurred in this section. KSCC has generally met the requirements of Part A. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 4#

KS 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 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: B1. Yes. A review of KSCC Pipeline Safety Section Procedures, Section 5.1.4.1 found the following: Gas Pipeline Safety Section inspectors shall perform a formal standard audit of each inspection unit at least once every three years or as determined by the Risk Model. No issues. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B2. Yes. KSCC Pipeline Safety Section Procedures, Sections 5.1.4.4 and 5.1.4.5 address these items as listed below: (IMP) All transmission inspection units will be audited for changes in the HCA mileage as part of the formal standard inspection. (DIMP) All DIMP inspection results will be uploaded into the PHMSA DIMP database. Within three years of the initial inspection, each identified segment in a distribution operator's DIMP plan will be evaluated to assure an adequate evaluation of the effectiveness of its DIM plan is complete and the risk ranking is appropriate. Re-inspection interval is 5 years. 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: B3. Yes. KSCC Pipeline Safety Section Procedures, Section 5.1.4.6 address this item as listed below: Protocol 9 field inspections for OQ will be completed as part of each formal standard inspection. All Protocol 9 results will be recorded on PHMSA inspection form 15_GT_OQ_Inspection _IA and loaded into the PHSMA OQ database. Re-inspection interval is 5 years. 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. This is covered during Standard inspections under 192.614. KSCC Pipeline Safety Section Procedures, Section 7.1. address this item as listed below: Damage prevention inspections or "One Call" inspections are driven by complaints. Staff will try to facilitate resolution of the complaint by getting the two parties, (excavator and utility), to communicate. If violations of the statute persist or are egregious, Staff will issue a Probable Noncompliance to the party believed to have violated the statutes or the regulations. Procedures for completion of the Notice of Probable Noncompliance process can be found in Section 5.1.6 of this manual. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes, KSCC Pipeline Safety Section Procedures, Section 5.1.4.3 address this item as listed below. Municipal operator training will be coordinated with the Flint Hills group and Kansas Municipal Utilities. If available, inspectors will participate as observers in the training exercises and load the results in the PHMSA database as Protocol 9 inspections if applicable: 1. Any municipal operator in need of training will be directed to one of the municipal groups that provide such training. If possible, the inspector will attend a portion of the training session to verify that personnel are effectively trained in DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 5#

KS NG Program Evaluation, 2015, page 6emergency response requirements; 2. Pipeline Safety and Damage Prevention inspectors will also provide training on excavator awareness and utility locator issues as appropriate. This includes onsite training after a damage occurs or when other organized opportunities are available for presenting to larger groups. 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, KSCC Pipeline Safety Section Procedures, Section 5.1.4.2. This item is listed below. Construction inspections will be done on a random basis. The Gas Pipeline Section will review at least 30% of those construction activities that are submitted to the department pursuant to K.A.R. 82-11-7. If appropriate, and depending on the availability of procedures, construction inspections will include an OQ inspection using the PHMSA form 15. All Protocol 9 inspections will be loaded into the PHMSA OQ database. 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: B7. Yes x 6. this information is listed in KSCC Pipeline Safety Section Procedures, Section 5.1.2.1. For formal standard inspections, inspections for each inspection unit will be derived based on a risk ranking. Factors to be included and their rationale are: * Date of last inspection - All inspection units are scored such that each unit is inspected at least once every two years. * Noncompliance history for last three years - More than 4 nopv will require annual follow up; more than 1 nopv may require annual followup * Percentage of Lost & Unaccounted for gas - L&U greater than 5% increases risk and may require followup; usually accounting error but it indicates a possible lack of understanding and recordkeeping shortcomings. * Percentage of miles of unprotected bare steel pipe - More than 5% UPBS increases risk and may require inspection. * Percentage of miles of bare pipe - More than 35% BS (protected and unprotected) will require annual inspection; more than 5% Bare steel increases risk and may require annual inspection. * Number of meters located at inspection unit - Surrogate for population density since almost all distribution is Class 3. If more than 10,000 meters will require annual inspection as towns of that size will also have the most Class 4 piping if any or a larger business district therefore higher risk. * Employee attrition/ experience level for small operators (assigned by KCC Staff) * Subjective assignment based on operators abilities as observed by Staff. Special considerations/Confidence level (assigned by KCC Staff. This also includes the type of activity being undertaken by operator) - Subjective assignment based on knowledge of staff regarding the experience level of the operator. Also considers the operator's compliance culture. 8 General Comments: Info Only = No Points Evaluator Notes: B8. No loss of points occurred in this section. KSCC has generally met the requirements of Part B. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 6#

KS 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 A. Total Inspection Person Days (Attachment 2): 692.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.25 = 935.00 Ratio: A / B 692.00 / 935.00 = 0.74 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes. 4.25 IPY, 935 IPD, 692 afo days, 692/935= 0.740, >.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, yes, yes, yes, yes. The PM & all inspectors with 3+ years employment have completed training, Doug Fundis has completed IM training and is the IM Lead. Doug, Lyle, & Leo have specialized training, Nace, Management, investigator, etc. Doug, Lyle & Leo have Root Cause. 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, Leo Haynos has over 17 years of experience in pipeline safety, understands the requirements in submitting a grant application and payment agreement documents. 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 0 Evaluator Notes: C4. NO. 0 of 2 points. KS responded in about 173+- days, 7/23/15 to 1/13/16. Initial response was in September but there is no record that it was ever mailed. Both items of concern were addressed in the letter. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 2 2 Yes = 2 No = 0 Evaluator Notes: C5. Yes, KS conducts a Training Seminar every year. the last seminar was conducted in October 22-23, 2015 in Manhattan, KS. The number of participants who attend was over two hundred. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 5 5 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 7#

KS NG Program Evaluation, 2015, page 8Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: C6. Yes. Gas IMP- 36 intrastate operators - inspections are current. Internal KSCC records must be used as the Gas IMDB is incomplete. OQ program inspections were an area of emphasis in 2015 and are current. 81 DIMP inspections have been performed and are current. Standard Inspections are current. The two CRM inspections are current. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 1 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. N.I. 1 of 2 points. Review of 7 inspections; 15-604, 15-304, 15-104, 15-216, 15-206, 15-447, & 15-232, the inspections showed to be proper and internally consistent inspections except for inspection 15-104. That inspection showed numerous N/C items that were not explained and many were not reasonable to have been marked N/C. This inspection will be used by the KSCC as an example of how NOT to do an inspection. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C8. Yes, this item is question 167 on the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 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, this item is question number 9, under Continue Surveillance Procedures, in the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. 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: C10. Yes, this item is question 32, under Emergency Procedures, in the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. 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: C11. Yes, this item is questions 41 & 152, under Failure Investigation & Operations and Maintenance Procedures, in the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. 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, operator's annual reports are reviewed when submitted to KSCC and prior to the inspector performing the standard inspection. KSCC includes this report data in the risk model program they use in establishing their inspection visits. DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 8#

KS NG Program Evaluation, 2015, page 913 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a 2 1 timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C13. N.I. 1 of 2 points. It was found that several TIMP Protocol A inspections have not been uploaded into an appropriate database. It has become SOP for Protocol A to be included in a Standard Inspection and they were filed with the Standard Inspections. KSCC understands that the Protocol A inspections need to be broken out and uploaded. 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: issue. C14. Yes, KSCC Pipeline Safety Procedures require each inspector to check this item prior to performing an inspection. No 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, this item is addressed in the KSCC's Pipeline Safety Procedures Manual page 13, section 5.1.4.9. No issues. 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: C16. Yes, this is checked during a review of the operator's O&M Plan, see questions 170-172 in the Operations and Maintenance Procedures, in the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. This is also addressed in the KSCC's Pipeline Safety Procedures Manual page 12, section 5.1.4.6. No issues. 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, these items are reviewed and checked against the operator's Operations and Maintenance Procedures during Standard inspections. See questions 122-150 in the Operations and Maintenance Procedures, in the Standard Inspection Report of a Transmission Operator form. Additionally, verification is described and addressed in the KSCC's Pipeline Safety Procedures Manual page 11, section 5.1.4.4. No issues. 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 have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C18. Yes, this is reviewed and checked against the operator's Operations and Maintenance Procedures during the DIMP inspection. Additionally, verification is described and addressed in the KSCC's Pipeline Safety Procedures Manual page 12, section 5.1.4.5. Also is addressed during a Standard Inspection; see questions 173-178 in the Operations and Maintenance Procedures, in the Standard Inspection Report of a Municipal or Small Gas Distribution Operator form. No issues. DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 9#

KS 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: 2 2 C19. Yes, a review of records indicated all 84 operators were inspected for PAPEI on or before December, 2013. Results were submitted into PHMSA's data base starting on August 26 to October 3, 2013 by KSCC staff members. No issues. 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: C20. Yes, KSCC web site located at http://www.kcc.ks.gov/pipeline/index.htm provides information about their enforcement procedures and regulations to the public. No issues. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 NA Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C21. NA. Procedures are in place for responding to a SRC, see Section 6. However, there have been no SRC in 2013, 2014, or 2015. 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C22. Yes, this is listed in questions 153 & 176 on KSCC Standard Inspection form. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C23. Yes, they have responded to NARUC and NAPSR on all requests pertaining to cast iron, leakage and damages per 1,000 ticket requests. No issues. 24 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: C24. Yes. There was one historical waiver regarding plastic pipe joining that has since become part of the Federal regulations. There are no State initiated waivers or special permits that are currently active. FYI, there was a waiver granted in 2016 with PHMSA concurrence. 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: C25. Yes. 1 1 26 DUNS: 102979593 2015 Gas State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 2 2 Kansas KANSAS CORPORATION COMMISSION, Page: 10#

KS NG Program Evaluation, 2015, page 11a. 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: C26. Yes Yes. Attrition, new employees, and new employee training is apparent through the metrics. The Fed metrics show promise but KSCC has this information, and more, internally. 27 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C27. Cast Iron should be out of service in KS by 2020. 4 points were lost in Section C, but 2 of those points were due to mishandling a letter. The other points highlighted a need to get some inspections uploaded into the federal database and for better quality control of finished inspection reports. The new inspectors show promise and efforts are being made to get them trained quickly. Total points scored for this section: 45 Total possible points for this section: 49 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 11#

KS 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: D1. Yes. Yes. KSCC Pipeline Safety Procedures Manual page 13, section 5.1.6 entitled, "Procedures for notifying an operator when noncompliance is identified" addresses these two items. No issues. 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. 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: D2. Yes, yes, yes, Yes, a random review of 2014 inspection reports indicated correspondence is being sent to the City Mayor, Board Member or company officer. All probable violations are reviewed during the exit interview with the operator's representatives who acknowledge the discussion by his or her signature. KSCC maintains and annually updates a data base of company officers or managers. This information is also reviewed and checked with the operator during their field inspection visits. No issues. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: D3. Yes. A review of files and data base indicated compliance action was taken in accordance with KSCC pipeline safety procedures. In this regard, 119 violations were issued in CY2015. 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, KSCC Pipeline Safety Procedures Manual describe their due process in section 5.1.11 No issues. 2 2 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: D5. Yes. It is known and used. While there were no penalties assessed outside of the $41K in One-Call violations, an $8k penalty was assessed and collected in 2014. 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: DUNS: 102979593 2015 Gas State Program Evaluation 1 1 Kansas KANSAS CORPORATION COMMISSION, Page: 12#

KS NG Program Evaluation, 2015, page 13D6. Yes. Civil penalties are used. An $8k penalty was assessed and collected in 2014. 7 General Comments: Info Only = No Points Evaluator Notes: D7. No loss of points occurred. KSCC has generally met the requirements of Part D. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 13#

KS 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/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: E1. Yes, See KSCC Pipeline Safety Procedures Manual, page 17, Section 6. 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, yes. KSCC Pipeline Safety Procedures Manual in Section 6, Failure Investigation and Safety-Related Conditions, address both of these items. 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, KSCC Pipeline Safety Procedures Manual, Section 6 states, KCC Pipeline Safety Staff will conduct an investigation of each reportable incident involving jurisdictional pipeline facilities. They respond to all incidents. KSCC had no significant jurisdictional incidents in 2015. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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. NA. no incidents in 2015. It is KSCC practice to conduct an on-site investigation of all significant incidents. 5 Did the state initiate compliance action for violations found during any incident/accident 1 NA investigation? Yes = 1 No = 0 Evaluator Notes: E5. NA. no incidents in 2015. All significant incidents & most other incidents are investigated and actions are taken through a Docketed case, to the Commission, when violations are found. 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: 1 1 E6. Yes, KSCC continues to respond to PHMSA Central Region about operator incident reports. No issues. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 102979593 2015 Gas State Program Evaluation 1 1 Kansas KANSAS CORPORATION COMMISSION, Page: 14#

KS NG Program Evaluation, 2015, page 15Yes = 1 No = 0 Evaluator Notes: E7. Yes, at the NAPSR Central Region Meeting and also during the Pipeline Safety Seminars. 8 General Comments: Info Only = No Points Evaluator Notes: E8. No loss of points occurred. KSCC has generally met the requirements of Part E. Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 15#

KS 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 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, this question is listed as number 148 on the standard inspection form. 2 2 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: F2. Yes, a review of inspection reports indicates this item was checked and reviewed with the operator. The question is number 146. 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, this is accomplished at the CGA, Kansas One Call, and Underground Coordinating committee meetings. 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: F4. Yes, the natural gas companies are required to file with KSCC information on their locate request. KSCC has a virtual dirt program they use to review the damages per 1,000 locate request and they upload the data from the operators into CGA's Virtual Dirt Program. Hits per 1000 locates for Kansas City metropolitan areas have been as follows: cy2008 2.4, cy2009 2.5, cy2010 2.5, cy2011 2.3, cy 2012 2.8, cy2013 1.9, cy 2014 2.0, and cy 2015 2.4. 5 General Comments: Info Only = No Points Evaluator Notes: F5. No loss of points occurred. KSCC has generally met the requirements of Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 16#

KS NG Program Evaluation, 2015, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Kansas Gas Service, opid 31159 Name of State Inspector(s) Observed: Lyle Powers & Jon Bolinder, KSCC Inspectors Location of Inspection: 301 N 8th St, Marysville, KS 66508 Date of Inspection: 5/3/16 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. Kansas Gas Service, opid 31159, Lyle Powers & Jon Bolinder, KSCC Inspectors; 301 N 8th St, Marysville, KS 66508; 5/3/16; Patrick Gaume; Procedures and Records of a Standard Inspection were observed. 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: G2. Yes. 5 operator personal were present and participated. The inspection was at their office. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G3. Yes. They used a State Form that incorporates the Fed Distribution Standard Inspection Form & the OQ Field inspection Form. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes. The Procedures and Records inspection was completed and the Field inspection was scheduled for Wednesday May 4, 2016. 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 G5. Yes. This was an Office review; Office facilities, computers, records, and procedures were all used and available. 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: G6. Yes. Procedures and Records were reviewed in detail. 2 2 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 17#

KS 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: 2 2 G7. Yes. Lyle & Jon conducted a cordial and professional inspection. They demonstrated knowledge of the regulations. 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. There was an Exit interview of the day's work; the Procedures and Records were in good order, and no violations were found. 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. There was an Exit interview of the day's work; the Procedures and Records were in good order, and no violations were found. 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: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 18#

KS 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: following day. G10. I observed the Procedures and Records portion of a Standard Inspection. The Field inspection was scheduled for the Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 19#

KS 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 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: H1-7 NA Not an Interstate Agent State 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H1-7 NA Not an Interstate Agent State Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 20#

KS 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: I1-6 NA Not a 60106 Agreement State 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: I1-6 NA Not a 60106 Agreement State 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: I1-6 NA Not a 60106 Agreement State 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: I1-6 NA Not a 60106 Agreement State 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: I1-6 NA Not a 60106 Agreement State 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: I1-6 NA Not a 60106 Agreement State 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I1-6 NA Not a 60106 Agreement State Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102979593 2015 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 21#