2011 ME NG Program Evaluation - me2011ngprogramevaluation (Maine; Natural Gas State Program Evaluation)

ME NG Program Evaluation, 2011, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 Natural Gas State Program Evaluation for MAINE PUBLIC UTILITIES COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 1#

ME NG Program Evaluation, 2011, page 22011 Natural Gas State Program Evaluation -- CY 2011 Natural Gas State Agency: Maine Rating: Agency Status: Date of Visit: 07/23/2012 - 07/27/2012 Agency Representative: Gary Kenny, P.E PHMSA Representative: Dinubhai (Dino) N. Rathod Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Thomas L. Welch, Chairman Agency: Maine Public Service Commission Address: 101 Second Street City/State/Zip: Hallowell, Maine 04347 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 2011 (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 9 7 B Program Inspection Procedures 15 13.5 C Program Performance 41 38 D Compliance Activities 14 14 E Incident Investigations 4 4 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 103 96.5 State Rating................................................................................................................................................... 93.7 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 2#

ME NG Program Evaluation, 2011, 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 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Noted discrepency in Attachment 5. Prog Mgr Kenny agreed to revise and resubmit to PHMSA. 1 0.5 6 Were pipeline program files well-organized and accessible? - Progress Report 2 1 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Discussed need for enahnced capability of elctronic database to allow efficient use of inspection resources. Currently ME PUC maintains combination of hard copies and very limited capability for access to elctronic records. PUC Chairman has agreed to committing additional resources to enhance current capabilities. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: PUCstaff continues to take necesasry T&Q courses. PUC will review and correct errors on Attachment 7 for inspection time and ime charged to Program and resubmit revised Attchmnet 7 to PHMSA. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 3#

ME NG Program Evaluation, 2011, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 9 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 4#

ME NG Program Evaluation, 2011, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: Discussed with PUC need for revising description for Standard Inspection per Glossary pp vii and Chapter 5- Item 3(a) of PHMSA's State Guideline Manual (Dec 2011) and also maintain adequate level of supporting documentation including completed Inspection Check-Lists/ Forms to cover these inspection activities over certain time-frame as described in PUC's inspection procedures 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maine PUC Gas safety Proram Procedures- Item 4(B). 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maine PUC Gas safety Proram Procedures Item 4(B) 1 1 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maine PUC Gas safety Proram Procedures- Item 4(B) 5 On-Site Operator Training (B1e) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maine PUC Gas safety Proram Procedures-Discussed with PUC need to provide a brief description for On-Site Inspection per Chapter 5- Item 3(c) of PHMSA's State Guideline Manual (Dec 2011) and also maintain adequate level of supporting documentation including completed Inspection Check-Lists/ Forms to cover these inspection activities over certain time- frame as described in PUC's inspection procedures 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC Gas Safety Prorgam Inspection Procedures per Appendix D 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 5#

ME NG Program Evaluation, 2011, page 6d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: PUC GAs Safety Program Inspection Procedures- June 2011 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 9 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Discussed with PUC need to review, revise State Gas Safety Program Inspection Procedures to reflect PHMSA's current Guidelines for State Participating Total points scored for this section: 13.5 Total possible points for this section: 15 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 6#

ME NG Program Evaluation, 2011, 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 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 193.75 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.55 = 341.00 Ratio: A / B 193.75 / 341.00 = 0.57 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ratio is greater than 0.38, 5 points. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: Verified that both PUC inspector and Program Manager continue taking necesssary T & Q training courses. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Dunig CY 2011, ME PUC Program Manager Gary Kenny continued to gain necessary pipeline safety regulatory experience and required T&Q training courses. He works closely with NAPSR and PHMSA. He provides guidance to PUC inspection staff and damage prevention specialists. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: ME PUC responded Nov 9, 2011 and addressed items noted in PHMSA letter. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 2 2 Evaluator Notes: ME PUC hosted participated in a joint 2010 NEPSR T&Q seminar. ME also participated in CY 2011 NEPSR seminar. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: PUC inspected all juridictional operators per Gas Safety Program Procedures. 5 5 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 7#

ME NG Program Evaluation, 2011, page 87 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 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Discussed with PUC specific requirements for use and completion of various inspection forms/check lists and maintain documentation for PHMSA annual prorgam evalluation. PUC was to review and revise inspection forms to cover all applicable code requirements. 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 (B7) Yes = 1 No = 0 Evaluator Notes: PUC reviewed UNITIL (Northern Utilities) exposed CI procedure - Section 6.3.3. 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 (B8) Yes = 1 No = 0 Evaluator Notes: UNITIL (Northern Utilities) Model for CI and bare steel was reveiwed- It provided ranking and repalcement priorities. Operator is required to file Ranking information to PUC on an annual basis. 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 (B9) Yes = 1 No = 0 Evaluator Notes: PUC reviewed UNITIL's Procedures Section 6.3.1 1 1 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: MPUC Rule 420-Section 3- requires that gas operator submit monthly reports rleated Response Times to PUC. PUC reviews repsonse times greater that 60 minutes (without aeqaute expalnation by operator 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC reviewed Annual Reports along with Incident Reports for accuracy and possible trends. Example: PUC keeps track of "Unaccounted Gas" percentage since CY 2002. 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 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 1 During Annual review, it was noted that only one OQ inspection was conducted in 2011 but it was finalized in July 12, 2012. Discussed with PUC inpectors need for performing adeqaute level of OQ inspections and upload results in OQDB in a timely DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 8#

ME NG Program Evaluation, 2011, page 9manner. PUC agreed to perform sufficient level of OQ verification of LDC OQ Plans, procedures, records and protocl #9 field OQ activities. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: In CY 2011 PUC has confirmed that pipeline operator(s) have submitted necesasry information in NPMS. 1 1 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC verified D&A tests details of two gas operators (UNITIL and MNG) in CY 2011. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 2 1 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC conducted OQ plan reviews in CY 2005. Discussed with PUC need for OQ Program Plan, procedures and records inspections and field verification activities. PUC was advised and agreed to conduct OQ reviews ASAP. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 NA 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 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC did not have inspector with necessary IMP training in CY 2011. Prog Mgr was scheduled tattend Aug 2012 IMP course but was delayed and rescheduled IMP T&Q training in early 2013. PUC intnds to perform IMP inspections upon completing this requirement. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P Info Only = No Points Evaluator Notes: PUC plans to review DIMP Program specifics in 2012/2013. Info Only Info Only 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC conducted D&A inspections of small operators (LPG). Bangor Gas and Maine Natural gas (MNG) submitted D&A Palns Jul 2010 and recently April 2012. 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 002235294 2011 Natural Gas State Program Evaluation 1 1 Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 9#

ME NG Program Evaluation, 2011, page 10PUC website: http://mpuc.informe.org/ Docketed Case infomation is available to public. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: CY 2011- NO SRC in Maine 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MPUC Rule 420, Section 7A requires that each operator participate in Plastic Pipe data collection, share initiative and resport plastic pipe failure to PUC. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PUC participatd in NAPSR surveys and PHMSA requests for inormation. 1 1 24 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 38 Total possible points for this section: 41 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 10#

ME NG Program Evaluation, 2011, page 11PART 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 (B12-14, B16, B1h) 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: MPUC Enforcement Procedures & MPUC Rule Chapter 420- Section 8 ; Section 6 of Chapter 421 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 (B11,B18,B19) 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 Evaluator Notes: MPUC Enforcement Procedures & MPUC Rule Chapter 420- Section 8 ; Section 6 of Chapter 421 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: ME PUC issued compliance action letters. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: MPUC Enforcement Procedures & MPUC Rule Chapter 420- Section 8 ; Section 6 of Chapter 421 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes; Program Manager is very familiar with State process of imposing civil penalties. Pipeline safety stafffworks closely with Damage prevention specialists for One cal violations and resulting actions. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: MPUC Docket No. 2011-371. Local operator MNG was penalized for $1,000 for failure to follow purge procedures. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 14 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 11#

ME NG Program Evaluation, 2011, page 12PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: PUC inspectors have their cell tel listed as part of the Emergency Contact List 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Reportable Incidents in CY 2011. PUC works closely with damage prevention specialists and perform necesary follow- ups 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) 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: No Reportable Incidents in CY 2011 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 5 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: 1 1 ME PUC shared lessons learned in 2012 NAPSR meeting and 2011 NEPSR meeting (six New England states). 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 002235294 2011 Natural Gas State Program Evaluation Info Only Info Only Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 12#

ME NG Program Evaluation, 2011, page 13No Reportable Incidents in CY 2011 Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 13#

ME NG Program Evaluation, 2011, page 14PART 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 (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 ME PUC reviewed directional drilling procedures. UNITIL App 2G; MNG Section3 and bangor Gas Sections H, I & J. 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: ME requires operators be part of Dig safe system in the state. 2 2 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: MPUC Damage Preventio Specialist investigators perform necessay follow-up and investigations related to damages. PUC strongly encourages damage prevention activites; provides MUST trainining. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: ME PUC clollects and analyzes damage data for trends 2 2 5 General Comments: Info Only = No Points Evaluator Notes: ME has a strong and mature damage prevntion program Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 14#

ME NG Program Evaluation, 2011, page 15PART 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: UNITIL Name of State Inspector(s) Observed: Gary Kenny Location of Inspection: Portland Date of Inspection: 07/23/2012 & 07/23/2012 Name of PHMSA Representative: Dinubhai (Dino) N.Rathod Evaluator Notes: Observed review of Public Awareness and DIMP Plan implemntation; Critical valve & Pressure Regulation Station Maintenance 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Field work was conducted at UNITIL's Portland office; Critical valves & Pressure Reg Station maintenance observed in Portland. Company crew performed maintenance work 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC inspector Gary used PHMSA PA and OQ field verification forms. In addition he used PHMSA DIMP form and guidance material 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUC iused nspection check lists/ forms and e-mailed completed forms to me. 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.) (F5) Yes = 1 No = 0 Evaluator Notes: 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: maintenance. DIMP Implementaton status review; Public Awareness; Operator qualification; critical valves and Pressure Reg Station DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 15#

ME NG Program Evaluation, 2011, page 167 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 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) (F9) Yes = 1 No = 0 Evaluator Notes: PUC inspector Gary Kenny conducted an exit interview. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No major issues were found. However PUC was to follow thru on Critical valve related 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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 D. Valve Maintenance E. Vault Maintenance DUNS: 002235294 2011 Natural Gas State Program Evaluation Info Only Info Only Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 16#

ME NG Program Evaluation, 2011, page 17F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: DIMP and Public Awareness Status- implmentation reivew DUNS: 002235294 2011 Natural Gas State Program Evaluation Total points scored for this section: 12 Total possible points for this section: 12 Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 17#

ME NG Program Evaluation, 2011, page 18PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) 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? (C3) 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.) (C4) 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? (C5) 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? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: ME PUC is an intrastate gas safety program only Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 18#

ME NG Program Evaluation, 2011, page 19PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) 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? (B22) 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.) (B23) 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? (B24) 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? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: ME PUC is an intrastate Gas Program (60105(a); Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 002235294 2011 Natural Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 19#