# 2016 OH NG Program Evaluation - oh-2016-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA oh-2016-gas-program-evaluation
- **title:** 2016 OH NG Program Evaluation - oh-2016-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-01-01
- **effective on:** Not available
- **summary:** 2016 PHMSA natural gas program evaluation for Ohio.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/2531/oh-2016-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 2016 Gas State Program Evaluation for PUBLIC UTILITIES COMMISSION OF OHIO 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: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 1

2016 Gas State Program Evaluation -- CY 2016 Gas State Agency: Ohio Rating: Agency Status: Date of Visit: 05/12/2017 - 07/21/2017 Agency Representative: Peter Chace PHMSA Representative: Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Asim Z. Haque, Chairman Agency: The Public Utilities Commission of Ohio Address: 180 East Broad Street City/State/Zip: Columbus, Ohio 43125 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2016 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 49 48 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 7 7 I 60106 Agreement State (If Applicable) 0 0 TOTALS 125 124 State Rating................................................................................................................................................... 99.2 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Ohio Revised Code 4905.90 through .96 for jurisdictional authority. Data was cross checked with the Pipeline Data Mart. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspection days are tracked bi-weekly through the GPS Progress Reports. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Ohio removed six operators in 2016 and added eight operators in 2016. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Federally reportable incident reports were verified through the Pipeline Data Mart. All incident information is entered and tracked through Ohio's GPS Database 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All enforcement data is entered and tracked through Ohio's GPS Database. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 All files are stored on the GPS T2000 drive and referenced through the GPS Database. State Administrative Code Chapter 4901:1-16-06 states construction projects in excess of $500,000 operator must submit report to the PUCO. Attachment 6 in Gas Base Grant Report requires operators submit annual construction reports for projects in excess $200,000. Inform Carrie Winslow of correction. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Completed training was accurate and complete. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 3

OAC 4901:1-16-02(D) shows how Ohio incorporates rule changes and amendments, and was incorporated by reference with an effective date of August 1, 2016. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Accelerated Main Replacement Program (AMRP): 4 jurisdictional operators have cast iron. Total 315 miles of cast iron in State of Ohio end of 2015. Total 255 miles of cast iron in State of Ohio end of 2016. Columbia Gas has total of 153 miles of cast iron end of 2016. Ohio is looking to spend 10% of its reported field days on new construction projects. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part A of the Program Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Ohio needs to revise procedures to include Pre-Inspection Activities, Inspection Activities, Post-Inspection Activities on page 10-11 of State Operating Procedures. Also, needs to reference Standard Inspections in this procedures. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Ohio needs to revise procedures to include Pre-Inspection Activities, Inspection Activities, Post-Inspection Activities on page 10-11 of State Operating Procedures. Also, needs to reference IMP (including DIMP) Inspections in this procedure. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Ohio needs to revise procedures to include Pre-Inspection Activities, Inspection Activities, Post-Inspection Activities on page 10-11 of State Operating Procedures. Also, needs to reference OQ Inspections in this procedure. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Ohio needs to revise procedures to include Pre-Inspection Activities, Inspection Activities, Post-Inspection Activities on page 10-11 of State Operating Procedures. Also, needs to reference Damage Prevention Inspections in this procedure. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Procedure is included in the Ohio 2017 Inspection Plan, page 9. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Need to change procedures to include Pre-Inspection Activities, Inspection Activities, Post-Inspection Activities on page 8 of State Operating Procedures. Also, needs to reference Construction Inspections in this procedure. DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 5

7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Standard Operating Procedures classify risk based on size of operator due to incident causes and complexity of administering larger systems. Procedures need to be enhanced to include bullet points listed above. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Ohio's inspection plan needs to be revised to include pre-inspection, inspection, and post-inspection activities as part of their inspection process. The process is in the plan, but has not been identified in these specific categories. The Ohio Inspection Plan needs to be revised to include more detailed risk factors when prioritizing inspections. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 6

PART 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): 1764.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.67 = 2346.67 Ratio: A / B 1764.00 / 2346.67 = 0.75 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ohio satisfied the ratio of Total Inspection person days to total person days which calculated at 0.75. Ratio has to be >=.38. 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: All inspectors performing OQ inspections have completed the TQ OQ web based training. All DIMP and IMP leads have completed the TQ course track. Victor Omameh and Michael Purcell have completed Root Cause 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: Yes, program manager showed adequate knowledge of PHMSA program and regulations. 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: Yes, Chairman's Letter was issued 11/16/16, response dated 12/8/16 describing corrective action taken. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: The last pipeline safety seminar was 9/10/14 - 9/11/14. Next one is scheduled for 9/14/17 - 9/15/17. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: DUNS: 046289216 2016 Gas State Program Evaluation 5 5 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 7

Yes, reviewed distribution, transmission, and cooperative gas co. inspections and found that time intervals met written procedures. 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: Reviewed inspection reports for Columbia Gas Transmission, Ohio Rural Natural Gas Co., Dominion East Ohio, Winchester, Duke Energy, Summit Midstream, Lancaster Municipal Gas, and Columbia Gas of Ohio. Recommend that PUCO verify comments are added to inspection reports when N/C, N/A, or U is selected on inspection form. 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: Yes question included in the O&M inspection form, page 9 (under 192.459). 1 1 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the question is included in the O&M inspection form, page 13 (under 192.613). 1 1 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the question is included in the O&M inspection form, page 15 (under 192.615). 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: Yes, the question is included in the O&M inspection form, page 13 (under 192.617). 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Based on annual reports the PUCO is analyzing data for cast iron/bares steel pipe; excavation a damages; incidents/outages; miles of main/services bare steel; pipeline incidents by system type; and reportable incidents by cause. 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 1 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 8

There have been no DIMP inspections uploaded into database since 2013. Based on Ohio Inspection Plan the intervals for DIMP inspection is 2 yrs not to exceed 27 months. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, question is included in the O&M inspection form, page 2 (under 191.29). 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, question is included in the O&M inspection form, page 25. 2 2 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: Yes, Ohio uses PHMSA form 14 for all HQ inspections, PHMSA form 15 for all Records inspections. 2 2 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Ohio inspection plan, page 6, states that a, "A comprehensive review of an operators IM plan will be conducted for new operators, and after required reassessment intervals for existing operators" which could vary for each operator. The inspection plan needs to be revised to include a specific timeline for each review of an operator's IM Plan. 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Ohio inspection plan, page 6 for DIMP needs to be revised to include a timeline for the review of an operator's DIMP program. Presently, PUCO has performed DIMP implementation inspections base on the PHMSA form 24 checklists during the 2015 and 2016 calendar year. 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. PAPEI Effectiveness Inspections should have been completed by December 2013. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Public Awareness questions are included the Ohio O&M inspection form, page 16. 2 2 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 9

20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Ohio Gas Association annual meeting (PUCO guest speaker), PUCO web site, and public complaint response (excavation damage). 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: There were no open SRC reports in 2016. 1 1 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, question is included in the O&M Inspection form, page 13 (under 192.617). 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. NAPSR: Determining MAOPs of measuring Stations; electrofusion failures of tapping tees; and rules and policies of agency's gas quality from LDCs. PHMSA: Use or non-use of the Inspection Assistant; and How State's look at loss and unaccounted for gas during inspections. 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There were no waivers or special permits issues in 2016. 1 1 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Ohio attended the National NAPSR in Indianapolis in 2016. 1 1 26 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Discussed the State Program Performance Metrics with no negative trends noted based on analysis of the State of Ohio's Program performance metrics. DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 10

27 Discussion with State on accuracy of inspection day information submitted into State Info Only Info Only Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: There was one issues identified in Part C of the Program Evaluation pertaining to no DIMP inspections being uploaded into database since 2013. 28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Info Only Info Only Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: Ohio stated that they under estimated the person days spent on each type of inspections based on the assumption that there could be a possibility of not being able to meet days calculated by State Inspection Day Calculation Tool (SICT). PHMSA suggested PUCO should look at adding some days into the "Compliance Follow-up" category of the SICT which showed a total of zero days used for this item, whereas 26 person days was credited in Attachment 2 - CY2016 Gas Base Grant Progress Report. 29 General Comments: Info Only = No Points Evaluator Notes: for these items. Info Only Info Only Recommend question be added to the Ohio O&M inspection form in order to verify operators are taking appropriate action Total points scored for this section: 48 Total possible points for this section: 49 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 11

PART 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 c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Yes, the procedure is included in the Ohio Inspection Plan pages 11-13. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: Reviewed enforcement records on the T2000. There were no issues found. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Some were addressed through informal enforcement (Warning Letters). 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: The PUCO participated in a show cause hearing Case No. 16-1578-GA-COI in CY2016 against Ohio Rural Natural Gas disputing they installed a natural gas system without Operator ID. PUCO indicated operator did not have O&M plan, using unqualified staff to operate pipeline, and ignoring PUCO order to not operate pipeline until MAOP could be determined by pressure testing. Case is still open at the time of the State evaluation. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a civil penalty was assessed against Columbia Gas of Ohio in CY2016 for an incident that occurred in CY2015 for $400,000. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO Program Manager recommended a fine against Ohio Natural Gas Cooperative (16-1578-GA-COI), but their Commission ordered the operator to cease operation. This is still an open case at the time of the evaluation.DUNS: 046289216 Ohio 2016 Gas State Program Evaluation PUBLIC UTILITIES COMMISSION OF OHIO, Page: 12

7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part D of the Program evaluation. DUNS: 046289216 2016 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 13

PART 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: Yes, procedures included in the Ohio Inspection Plan pages 8-9. 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: Yes, Ohio has a 24-hour hot line with telephonic notice logs. After hour incident calls are forwarded to Pipeline Program Manager. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed telephonic notice logs on the T2000, and found that Ohio did obtain sufficient information from the operator when an on-site investigation was not made by Ohio Pipeline Safety Office. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, reviewed incident report from Columbia Gas Co. in CY2016 which indicated the PUCO did a thorough job of investigating, documenting, and determining that the incident was non-jurisdictional due to pipeline failure occurring downstream of customer residential meter. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, compliance actions were initiated against Cobra Pipeline, Duke Energy (Fairfield), and Columbia of Ohio (Columbus). 6 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 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: Yes, The PUCO did follow-up on incident with Spectra Energy when failed heater resulted in a frozen relief valve orifice. This follow-up was performed by calling the operator for more detail information pertaining to incident. DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 14

7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, the information is discussed at the NAPSR regional meetings and at Ohio Gas Association Technical meetings. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the Program evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 15

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the question is included in the O&M form, page 14. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the question is included in the O&M form, page 14. 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.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, with the recent ORC 3781 rule revision, Damage Prevention form questions, and the results of PHMSA survey on the application of the 9 elements. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, by which DIRT is being promoted by Ohio Utilities Protection Service. This is a voluntary program for the operators to submit their data for trend analysis. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the Evaluation program. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 16

PART 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: Dominion East Ohio Name of State Inspector(s) Observed: Christopher Domonkos Location of Inspection: 29555 Clayton Road, Wickliffe, OH 44092 Date of Inspection: May 9-11, 2017 Name of PHMSA Representative: Clint Stephens Evaluator Notes: The inspector performed a Standard Inspection on Dominion's gas distribution and intrastate transmission pipeline facilities. (2) Operator - Trans Canada (interstate operator) State Inspector - Mike Purcell Location - Lancaster, OH Date - June 7, 2017 PHMSA Representative - Jim Anderson 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, the operator was notified and given the opportunity to be present during the inspection. (2) Yes, operator notified and was present during the 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 2 Evaluator Notes: Yes. The Ohio State Program has its own inspection form, "Gas Intrastate Inspection Report", version 17.1, dated 1/2017. The form meets all current requirements of the Pipeline Safety Code. (2) Used IA form. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the inspector thoroughly documented the results of the inspection during the time of the evaluation. (2) Yes, the inspector thoroughly documented the results of the inspection during the time of the evaluation. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, the operator utilized pumps to drain water from station vaults and valve boxes; gauges to check pipeline pressures; valve keys to operate critical valves; and gas detectors to check for leaks. Yes, monitored the construction of new pipeline. DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 17

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) 2 2 Evaluator Notes: Procedures were reviewed at an earlier date for Dominion East Ohio by the Ohio State Program. However, odorant tests and atmospheric corrosion monitoring records were reviewed during the time of the evaluation. Field activities included pipeline pressure checks, critical valve operations, leak surveys, and the observation of marker signs and ROW conditions. (2) Yes, inspector reviewed welding procedures. 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector had adequate knowledge of the pipeline safety program and regulations. (2) Yes, the inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: An exit interview was conducted based on those areas discovered during the time of the evaluation. The inspection was not complete during my site visit. (2) An exit interview was conducted based on those areas discovered during the time of the evaluation. The inspection was not completed during the site visit. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The inspector identified possible probable violations found during the inspections. Those probable violations included a possible underground gas leak, atmospheric corrosion, and the use of above ground plastic pipe tubing on a pressure relief vent. (2) None found. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location Info Only Info Only DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 18

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 F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspector observed possible atmospheric corrosion on regulator stations; above ground plastic tubing used on gas relief vents; and operator's personnel responses to AOCs. The inspector was very observant; discussed issues with operator; maintained professionalism when questioned by operator; and was knowledgeable of the Code when identifying possible probable violations. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 046289216 2016 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 19

PART 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: Yes, per
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