# 2020 MI NG Program Evaluation - mi-2020-gas-program-evaluation (Michigan; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA mi-2020-gas-program-evaluation
- **title:** 2020 MI NG Program Evaluation - mi-2020-gas-program-evaluation (Michigan; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-01
- **effective on:** Not available
- **summary:** 2020 PHMSA natural gas program evaluation for Michigan.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2022-05/mi-2020-gas-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for MICHIGAN PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 1

2020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Michigan Rating: Agency Status: Date of Visit: 10/18/2021 - 10/22/2021 Agency Representative: David Chislea, Program Manager PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Dan Scripps, Chairman Agency: Michigan Public Service Commission Address: PO Box 30221 City/State/Zip: Lansing, MI 48909 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: Review of state documents and records showed no issues at time of inspection. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: For all inspections: - Pre-Inspection Activities can be found in Section 2.10. - Inspection activities are in Section 2.11 (beginning) - Post Inspection Activities can be found in Sections 2.16 & 2.17 For each specific inspection type: A) For Standard Inspections - Standard Inspections are ongoing annual inspections. Guidance can be found in Section 2.11 B) TIMP & DIMP - TIMP/DIMP Information can be found in Section 2.11a. TIMP C) OQ Inspections - OQ Inspection Information can be found in Section 2.11 D) Damage Prevention Inspections - Damage Prevention Inspection Information can be found in Section 2.11 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, 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: A) Section 3.1 discusses this process. ? Length of time since last inspection - Section 3.1 B) Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) - Section 3.1 C) Type of activity being undertaken by operators (i.e. construction) - Section 3.1 D) Locations of operator's inspection units being inspected ‐ (HCA's, Geographic area, Population Centers, etc.) - Section 3.1 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) - Section 3.1 F) See Risk Based Inspection Documentation. Also refer to Inspection Unit Risk Analysis documentation. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: A) Procedures to notify an operator (company officer) when a noncompliance is identified - Section 5.3 (Written NC Letter) of the PG. Also, Sections 2.16 (Exit Summary - 30-day briefing) and 2.17 (Post-Inspection 90-day Notification) B) Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Section 5.9 (Follow-up) DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 4

and Section 5.5 (resolution of NC) of the PG. C) Procedures regarding closing outstanding probable violations Section 5.5 (Resolution of NC) and Section 5.10 (Verification). 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: See Sections 6 and 7 of the PG A) (New 2020) See Section 6.6 (Staff Expectations) of the PG ? Manager on-Call under development. - Records of notifications ? See Section 6.5 (Internal Notification) of the PG. - MOU between PHMSA and NTSB is reference in the PG (Appendix K) - Cooperation See Section 7.3 (failure Investigation Categories). B) Procedurally addressed in Section 7.4 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See 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 b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: MPSC does track PHMSA TQ training for each inspector for qualification. They also have an in-house training process in their procedures that allows them to do training of new inspectors and get them out on their own. This process was improved by adding to being better able to document the steps taken to qualify each inspector for each type of inspection conducted. It also has a formal approval process that includes the actual sign off responsibility and authority. The line supervisors can sign off on completion of training steps made by the state, but only the Program Manager is allowed to say the inspector is qualified to do the work. They are continuing to make small adjustments for improvement. 2 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 = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, the Program Manager, (David Chislea) has been with the MPSC for many years and showed he has a good knowledge of the PHMSA program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 6

PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: The Random Operator List was reviewed and found to have dates and documents to show all inspection types were completed within the states inspection intervals. The Standard inspection process is separated into a four year cycle, and all cycles were reviewed. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 10 Evaluator Notes: A review of the inspections and forms showed that the forms used by the MPSC covered all applicable code requirements addressed on federal inspection forms. The form and process used covers all CFR regulations. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of OQ inspections showed that the MPSC is now verifying that operator personnel, (including contractors) that are performing covered tasks are properly qualified and re qualified at the intervals indicated in the operator's plan while conducting field inspections. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? 2 2 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 7

c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: The MPSC is also receiving ILI updates from DTE and CE to facilitate annual field inspections. Annual communication meetings and presentations on TIMP and DIMP topics are taking place with the "big 4." 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: Yes, the MPSC covers these in their inspection cycles. 2 2 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the state uses questions on inspection forms to verify. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns 10 10 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 8

j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Yes, the state has made changes to their enforcement process and is now documenting the routine review of progress on probable violations to ensure compliance has been meet by the operator. The task also includes the designation of responsibilities to inspectors and supervisors. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: Yes, the state is doing a good job of investigating and documenting the investigation of incidents. a. (New 2020) ? On Call System: Section 6.6 (Staff Expectations) of the PG b. Section 6.5 (Internal Notification) of the PG. All calls are recorded in the database system (section 6.3). c. Section 7.4. d. Section 7.4 (Incident Investigation Procedures) & Section 7.8 (Reporting) e. Section 7.4 (Incident Investigation Procedures) & Section 7.8 (Reporting f. Section 7.4 (Incident Investigation Procedures) & Section 7.8 (Reporting). MPSC DB for examples. g. Section 7.8. h. Yes. Staff provides monthly updates to PHMSA. I. Yes, state does share at NAPSR Region meetings 9 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 = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, PHMSA letter sent to MPSC on 11/9/2020, and they responded on 1/5/2021 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes. 2019 (October 8 through October 10) and previously 2016 Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes. Verified during Cycle 'D,' last inspected in Second Half 2014 and in Second Half 2018. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 9

Evaluator Notes: MPSC website. Yes. Michigan performs annual "communications meetings" with operators in the state. Information is also posted on the 13 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: Had 12 in 2020, with three carry overs. 9 - 12 months 1 1 14 Was the State responsive to: 1 1 Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: a. Program Manager provided E-Mail Responses. b. Staff has an IMP SME (KRF) to handle IM notifications and inspections. Additionally, IM information is received annually from the larger operators in the state at communications meetings. c. Is still making progress on this one. 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The state worked with PHMSA to clean these up and has two active intrastate waivers at this time. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, Documentation is stored primarily in the MPSC Gas Safety Database Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: completed 990. Discussed the SICT with the Program Manager and Supervisor Tim Wolf. They needed to do 860 days in 2020 and 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Info Only Info Only Discussed the state program metrics with the Program Manager and Supervisors Tim Wolf and Eleanor M. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: The MPSC is still working to put a process in place to address this. Info Only Info Only DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 10

20 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: 1. Observed Jotham Povich conduct a Cathodic Protection system inspection. (Virtually) Did two operators during the week. Breitburn was one and and Layline the other. Did a review of the operators procedures and records, then did verification visits in the field. Company reps were present during the inspection. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector used the states form. It covers all applicable PHMSA regulations. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: A. Yes, the inspector asked very probing questions of the operator during the records/procedures reviews. B. Yes. C. N/C unable to attend the field portion of inspection. D. None E. The inspection was of adequate length. 4 From your observation 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, Jotham seemed to have adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the inspector also provided a written copy of issues and findings to the operators representatives. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points Info Only Info Only DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 12

a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: Unable to physically attend, but the inspector checked reads and conditions at chosen sites on the operators system. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 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: Recently the MPSC has developed a damage prevention form that reviews and further inspects the information provided by the operators on their annual report and specifically damage reporting. The form includes further investigation into several rules including: 192.1007, 192.805, 192.614, and Michigan Rule 460.20504 (Related to Part 191 reporting requirements). Additionally, the MPSC risk-based inspection calculation includes data related to operator damages. Annually, the MPSC reviews operator annual reports for significant changes compared to years prior. These reviews are documented on a completed inspection form and stored in the MPSC database. All outstanding incidents are reviewed and updated monthly, and the report is provided to PHMSA. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: As noted in F-1, the MPSC has developed a form that was recently reviewed with the largest operators in the state and will be reviewed periodically going forward. This form addresses repeated damagers. As noted above, this form further inspects several rules including: 192.1007, 192.805, 192.614, and Michigan Rule 460.20504 (Related to Part 191 reporting requirements). Pilot inspections for this form were completed. Form improvements are currently underway; full inspections are planned to begin in 2022. Michigan's damage prevention law requires operators to file damage data. The MPSC has developed requirements that this data be submitted quarterly. Annually this data is analyzed with an emphasis on the larger operators. Additionally, at least quarterly damage prevention meetings are held with the MPSC and Damage Prevention teams for Michigan's biggest distribution operators (DTE/CE/SEMCO). "Frequent damagers" is a recurring topic for this meeting. Plans to have quarterly meetings with MGU starting in 2022. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: As noted above, operator annual reports are reviewed for significant changes compared to years prior. These reviews are documented on a completed inspection form and stored in the MPSC database. Annual report damage data is analyzed and shared with the largest operators annually.DUNS: 148674265 Michigan 2020 Gas State Program Evaluation MICHIGAN PUBLIC SERVICE COMMISSION, Page: 14

Regarding the elements of this question, as noted above in F-1 and F-2, the MPSC has developed a form that was recently reviewed with the largest operators in the state and will be reviewed periodically going forward. This form includes repeat damagers. As noted above, this form further inspects several rules including: 192.1007, 192.805, 192.614, and Michigan Rule 460.20504 (Related to Part 191 reporting requirements). Pilot inspections for this form were completed. Form improvements are currently underway, full inspections are planned to begin in 2022. 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: This information is analyzed and shared with several stakeholder audiences. This data is shared and presented at Communications meetings with the largest operators in the state, shared with other states at the Regional NAPSR meeting, and shared with MISS DIG (811) at their annual meeting. These presentations are maintained by the MPSC. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: Yes. MIPSC used the IA on all inspections, including construction inspections requested by them. Input provided by Central Region PHMSA Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: Yes. MI-PSC identified NOPVs during welder qualifications on a construction project that they were inspecting on independent of a PHMSA inspection. The immediately contacted PHMSA, provided the details, and we were able to get a WL out by the next day. Input provided by Central Region PHMSA 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: Information same as 1 and 2 Input provided by Central Region PHMSA Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: Info Only Info Only Yes. MIPSC requested the WMS activity number and kept PHMSA informed of the status of the inspection. Input provided by Central Region PHMSA 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: Yes, the MI PSC works with PHMSA AID Input provided by Central Region PHMSA Info Only Info Only 6 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: 148674265 2020 Gas State Program Evaluation Michigan MICHIGAN PUBLIC SERVICE COMMISSION, Page: 16
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