PHMSA ma2014ngprogramevaluation - 2014 MA NG Program Evaluation - ma2014ngprogramevaluation (Massachusetts; Natural Gas State Program Evaluation) | Regulus

MA 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 MA DEPT. OF PUBLIC UTILITIES 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: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 1#

MA NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Massachusetts Rating: Agency Status: Date of Visit: 09/15/2015 - 09/17/2015 Agency Representative: Richard Wallace PHMSA Representative: Dave Lykken and Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Angela M. O Connor, Chairman Agency: Massachusetts Department of Public Utilities Address: One South Station City/State/Zip: Boston, MA 02110 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 7.5 B Program Inspection Procedures 13 8.5 C Program Performance 45 41.5 D Compliance Activities 15 15 E Incident Investigations 5 5 F Damage Prevention 8 8 G Field Inspections 11 10 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 107 95.5 State Rating................................................................................................................................................... 89.3 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 2#

MA 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 1 0.5 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Some inconsistencies noted between Attachments 1 and 2 regarding units inspected and field days claimed. For Operator Type "Distribution-Other" was incorrectly coded to indicate the state did not have jurisdiction. Revisions made to Progress Report based on review of documentation supporting changes. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: Field inspection days were not accurately accounted for when initially reported. A review of source information from old database and Self Serve Time and Attendance ("SSTA") supports new inspection day count. Revisions made to Progress Report based on review of documentation supporting changes. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues noted 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: One federally reportable (> 50K) not reported under Attachment 3. Date of incident 5/8/14. Reported to NCR on 8/26/14. Operator did not reported to MA-DPU. Agency unaware of incident. Will be following-up with operator. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Program originally reported "52" compliance actions taken. This is actually the number of PV's found during CY 2014. Progress report revised to reflect the "9" compliance actions actually taken. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 1 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Inspection files difficult to locate within agency's network hard drives. Only one staff person knowledgeable in understanding how files are organized. Program has developed and implemented a new pipeline data management system which will alleviate the inconsistencies. 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: No issues noted. Christopher Bourne reassigned to administrative support. Will need to identify one or more individuals to attend and complete Root Cause Training. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 084885826 2014 Gas State Program Evaluation 1 1 Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 3#

MA NG Program Evaluation, 2014, page 4Evaluator Notes: Automatic adoption of federal rules per state statute. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 No issues. Tendency to cut and paste from previous years. Encouraged to provide specifics in future progress reports. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 7.5 Total possible points for this section: 10 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 4#

MA NG Program Evaluation, 2014, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: General Inspection Procedures (Rev 10/2014), pages 5 & 6. Revisions needed detailing pre-inspection activities, inspection activities, post-inspection activities when conducting standard inspections. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 0.5 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: General Inspection Procedures (Rev 10/2014), page 6. Revisions needed detailing pre-inspection activities, inspection activities, post-inspection activities when conducting IMP and DIMP inspections. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 0.5 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: General Inspection Procedures (Rev 10/2014), page 6. Revisions needed detailing pre-inspection activities, inspection activities, post-inspection activities when conducting OQ inspections. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 0.5 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: General Inspection Procedures (Rev 10/2014), page 7. Revisions needed detailing pre-inspection activities, inspection activities, post-inspection activities when conducting Damage Prevention inspections. 5 Any operator training conducted should be outlined and appropriately documented as 1 0.5 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: General Inspection Procedures (Rev 10/2014), page 6. Revisions needed providing additional detail including established frequencies for scheduling on-site training. 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 0.5 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: General Inspection Procedures (Rev 10/2014), page 6. Revisions needed detailing pre-inspection activities, inspection activities, post-inspection activities when conducting Construction inspections. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 DUNS: 084885826 2014 Gas State Program Evaluation 6 5 Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 5#

MA NG Program Evaluation, 2014, page 6a. 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: General Inspection Procedures (Rev 10/2014), pg. 7.MA-DPU's written procedures for prioritizing inspection scheduling are general in nature and provide minimal instruction to inspectors. Inspectors are to consider in part, factors such as data contained in operator annual reports to PHMSA, compliance history, and incident reports. The process should include a comprehensive list of risk factors, how each factor is weighed, and how the results of the review will determine inspection priority. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8.5 Total possible points for this section: 13 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 6#

MA 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 5 5 A. Total Inspection Person Days (Attachment 2): 738.70 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 8.00 = 1760.00 Ratio: A / B 738.70 / 1760.00 = 0.42 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Field inspection days were not accurately accounted for when initially reported. A review of source information from old database and Self Serve Time and Attendance ("SSTA") supports new inspection day count. Revisions made to Progress Report based on review of documentation supporting changes. 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: Root Cause training: Christopher Bourne reassigned to support staff. Three additional staff on waitlist to attend training. 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 Evaluator Notes: No issues noted. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Evaluation letter sent 11/21/2014. Chairman's response dated 1/5/2015. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Yes. Vermont in 2013 and Maine in 2014. Both in association with NEPSR. 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 5 5 Evaluator Notes: DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 7#

MA NG Program Evaluation, 2014, page 8No issues noted. 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: No issues noted. Content of IA equivalent forms is used but selected modules are cut and pasted into own form depending on subject matter being evaluated at time of inspection. Item identified as deficiency (no inspection form used) in Chairman's letter dated 11/21/2014. 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 issues noted 1 1 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: Yes. As noted in past evaluations, state rules require operators to conduct winter surveys, provide regular operator updates, and submittal of quarterly leak status reports. 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. No issues noted. 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: No issues noted 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 Evaluator Notes: Yes. Operators submit required quarterly reports which staff review. 2 2 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 2 1 5.1 Evaluator Notes: DUNS: 084885826 2014 Gas State Program Evaluation Yes = 2 No = 0 Needs Improvement = 1 All OQ inspections uploaded to OQDB. OQ documentation complete and observations well noted. Only two IM inspections (one field validation and one plan review) uploaded into IMDB. Old inspection form used for review of operator written plan. Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 8#

MA NG Program Evaluation, 2014, page 914 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 0.5 Evaluator Notes: Program sends notices annually to operators reminding them of annual reporting requirements including # of inactive/ abandoned service lines, LNG Fire Prevention and Control Training communications, filing of PHMSA annual reports, and Cast Iron Replacement programs schedules. Program reviews and tracks data submited. Program will add NPMS information to list of annual operator submittal reminders. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 1 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: Last D&A inspection conducted in 2011. None completed in CY2014 per progress report. Program will add to inspection work plan. 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: No issues noted 2 2 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 1 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2.2 field days devoted to IM inspections in CY2014. Only one written plan review and one field validation inspection conducted. Discussed the need conduct regular reviews of IMP written plans, along with increased field monitoring of operator's integrity assessments and remediation of deficiencies identified. 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: Reviewed completed DIMP inspections Technical difficulties uploading completed inspection forms into the DIMP database. Staff working to rectify IT issues. 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues noted. 2 2 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 9#

MA NG Program Evaluation, 2014, page 1020 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: Stakeholder information such as Natural Gas safety, Dig Safe information, enforcement actions and other public record information posted on MA-DPU web site. Quarterly/monthly meetings held with pipeline operators. 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: No Safety Related Conditions reported 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: Items of concern raised and discussed at regularly scheduled quarterly/monthly meetings with pipeline operators. 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 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: No open waivers in 2014. 0 0 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: MA did attend the 2014 national meeting held in Springfield, IL 0 0 26 Discussion on State Program Performance Metrics found on Stakeholder Communication site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points Evaluator Notes: Items discussed. 0 0 27 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 084885826 2014 Gas State Program Evaluation Total points scored for this section: 41.5 Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 10#

MA NG Program Evaluation, 2014, page 11Total possible points for this section: 45 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 11#

MA 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: General Compliance Procedures. Page 5. 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: Probable violations well documented. Good use of photos when documenting violations involving gas pipe and appurtenances. No issues noted. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 9 enforcement actions taken in 2014. 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: Yes 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: Yes. Civil penalties assessed in CY2014 totaled $490,000. 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: 9 Enforcement actions taken. Civil penalties assessed in CY2014 totaled $490,000. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 084885826 2014 Gas State Program Evaluation Info Only Info Only Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 12#

MA NG Program Evaluation, 2014, page 13Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 13#

MA 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: Page 16 of General Inspection Procedures (Rev 10/2014) 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: Page 15 of General Inspection Procedures (Rev 10/2014). PHMSA Eastern Region Incident Notification Email address noted in procedures. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 NA 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: One federally reportable incident (>50K) not communicated to MA-DPU. Incident date 5/2014. Not reported by pipeline operator until 8/2014. 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: One federally reportable incident (>50K) not communicated to MA-DPU. Incident date 5/2014. Not reported by pipeline operator to NRC until 8/2014. 5 Did the state initiate compliance action for violations found during any incident/accident 1 NA investigation? Yes = 1 No = 0 Evaluator Notes: One federally reportable incident (>50K) not communicated to MA-DPU. Incident date 5/2014. Not reported by pipeline operator until 8/2014. 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 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 084885826 2014 Gas State Program Evaluation 1 1 Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 14#

MA NG Program Evaluation, 2014, page 15Yes = 1 No = 0 Evaluator Notes: Shared at monthly/quarterly pipeline operator meetings. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 15#

MA NG Program Evaluation, 2014, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. As part of operator Operations & Maintenance manual reviews. Discussed as part of regularly scheduled meetings held with operators. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. As part of standard inspections. Also review's for follow-up and possible enforcement, any Dig Safe Violation Report forms submitted to the DPU by excavators and the general public. 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: Yes. Dig Safe information posted on MA-DPU's web site including CGA Best Practices. Information sharing as part of regularly scheduled meetings with pipeline operators. 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: 2 2 Yes. Monthly data tracker for 2014/2015 and Dig Safe Report summary for 2012 thru 2015 (YTD) reviewed. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 16#

MA NG Program Evaluation, 2014, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Columbia Gas of MA Name of State Inspector(s) Observed: Paul Grieco, Glenn LaChance Location of Inspection: Brockton, MA Date of Inspection: 9/16/2015 Name of PHMSA Representative: Jim Anderson, David Lykken Evaluator Notes: Field validation of CP records reviewed in office. "E" Street between Littlefield and Main. No issues identified. Gas leak identified while on site. Crew called to investigate leak. Did not remain on site for leak investigation work. 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. Operator was notified prior to site visit and was present during inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: Form not complete. Corrosion Control - Procedures Review component taken from the PHMSA IA Equivalent form and pasted into a separate word document. The Corrosion - Records and Field component was not included. The inspection observed focused on the operator's cathodic protection system records and field validation of those records. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. No issues noted even though the inspection form used was not complete. The Corrosion Control - Procedures IA question set mirror the Records and Field Observations in sufficient fashion that the applicable items were not missed. 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: Yes 1 1 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. No issues noted 2 2 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 17#

MA NG Program Evaluation, 2014, 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 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes. No issues identified. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: No probable violations identified 1 NA 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: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 18#

MA NG Program Evaluation, 2014, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Inspector(s) compared CP annual survey records and conducted a field validation of CP readings taken by a third party contractor. No issues identified. Inspectors reviewed OQ records of CP technician on site. Checked technician's equipment for condition and calibration where applicable. Underground gas leak identified while on site. Distribution crew dispatched to site to evaluate. Total points scored for this section: 10 Total possible points for this section: 11 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 19#

MA 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: MA is not an interstate agent 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 20#

MA 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: 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: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 084885826 2014 Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 21#