# 2018 OK HL Program Evaluation - ok-2018-hazardous-liquid-program-evaluation (Oklahoma; Hazardous Liquid State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ok-2018-hazardous-liquid-program-evaluation
- **title:** 2018 OK HL Program Evaluation - ok-2018-hazardous-liquid-program-evaluation (Oklahoma; Hazardous Liquid State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-01-01
- **effective on:** Not available
- **summary:** 2018 PHMSA hazardous liquid program evaluation for Oklahoma.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/4121/ok-2018-hazardous-liquid-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 2018 Hazardous Liquid State Program Evaluation for Oklahoma Corporation Commission Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 1

2018 Hazardous Liquid State Program Evaluation -- CY 2018 Hazardous Liquid State Agency: Oklahoma Rating: Agency Status: Date of Visit: 09/23/2019 - 09/27/2019 Agency Representative: Dennis Fothergill Kelly Phelps John Harper PHMSA Representative: David Appelbaum Rex Evans Commission Chairman to whom follow up letter is to be sent: Name/Title: Todd Hiett, Chairman Agency: Oklahoma Corporation Commission Address: 2101 N. Lincoln Blvd. City/State/Zip: Oklahoma City, OK 73105 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 2018 (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. 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 43 43 D Compliance Activities 15 15 E Accident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (if applicable) 0 0 I 60106 Agreement State (if applicable) 0 0 TOTALS 111 111 State Rating................................................................................................................................................... 100.0 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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: The OCC's inspection database contained the information used to complete Attachment 1. The number of operators and inspection units in the PDM database was slightly different than the Attachment 1 entries. Investigation found the PDM entries were off, but attachment 1, and the OCC's database was correct. OCC will follow up with PHMSA to reconcile PDM. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed inspection-person day activity results to individual time sheets. Inspection days appear to be reflected appropriately. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 3 information is taken from the OCC inspection database. A report generated from the database verified that Attachment 3 information was accurate. The total number of inspection units shown on Attachment 3 matched the total number on Attachment 1. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All federally reportable incident reports were listed correctly. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review shows attachment 5 is accurate. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Files appear to be well organized. Program Manager and other staff were capable of readily accessing requested documents. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed information on each inspector and compared completion courses to TQ records. All employees participating in the pipeline safety program were listed properly. 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues were found with rules and amendment adoption as shown on Attachment 8. 1 1 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 3

9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes. Attachment 10 was sufficiently completed. 10 General Comments: Info Only = No Points Evaluator Notes: The OCC generally complied with the requirements of Part A of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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: The OCC's Guidelines states Standard Inspections will be conducted as follows: HVL, CO2, Crude - All systems will be inspected once ever one to five years. Low Stress Systems - All systems will be inspected once ever one to three. Pre- inspection activities, inspection activities, post-inspection activities are sufficiently covered. 2 IMP 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: All operators will have their Integrity Management Program (see 49 CFR Part 195.452) reviewed as follows: - The department will review all programs within one to five years of the department determining the pipeline facilities are subject to the Commission's authority. - After the initial review, the department will conduct follow-up reviews to determine if the operator is meeting all required evaluation time frames and are modifying their Integrity Management Plan based on the results of their reviews. These reviews will conducted within five years of conducting the last review. . Reviews will be conducted based on the following order: - Pipelines which have experienced accidents - Operators with the most miles of HCA pipelines - Operators with the least miles of HCA pipelines IMP Field Review: The department will conduct onsite reviews to evaluate the operator's compliance with integrity management requirements and construction requirements. If an inspector is not available at the time of the dig, a record review will be conducted at a later date. Pre-inspection activities, inspection activities, post-inspection activities have been included in the procedures on pages 4 and 5. 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: Initial: All pipeline operators will have their Operator Qualification Plan reviewed within one to five years of the department determining they are a regulated pipeline operators. Follow-up: A follow-up review of each operator's operation qualification plans will be conducted once every five years. Field OQ Review: Field OQ review Inspections will be conducted during either a standard or specialized inspection, based on the following: Small Operators: A field OQ review will be conducted during each standard inspection. Large Operators: A field OQ review will be conducted at least once in every inspection unit during each standard inspection. Since the department inspects on a system level, there is a good possibility during any given year, more than one audit will be conducted in a previously inspected inspection unit. At the discretion of the inspector and the availability of new operator personnel during the subsequent inspection, a second field OQ review may be conducted. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage Prevention inspections are conducted as part of Standard Inspections and follow the same intervals as Standard Inspections. 5 Any operator training conducted should be outlined and appropriately documented as needed. 1 1 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 5

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Individual Operator Training: As part of their personnel performance, each inspector is required to conduct 5 training session each year. The training sessions shall cover recent regulation changes and areas of concern. Small Operator Training: The department will conduct 5 to 10 small operator group training sessions each year. The training sessions shall cover recent regulation changes and areas of concern. Industry Training: The department will conduct once every three calendar years and industry wide training seminar. 6 Construction 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. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC procedures states that construction inspections will be scheduled as projects occur and as time permits. 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 area, 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: The OCC's Inspection Guidelines contains procedures that comply with elements a. through f. above. No issues with the OCC's determination of inspection units, but PHMSA did recommend procedures be enhanced to better the articulate how priorities are determined. 8 General Comments: Info Only = No Points Evaluator Notes: The OCC generally complied with the requirements of Part B of this evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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 A. Total Inspection Person Days (Attachment 2): 325.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.42 = 532.40 Ratio: A / B 325.50 / 532.40 = 0.61 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The OCC's ratio of 0.61 far exceeded the minimum ration of .38. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram 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 lead inspectors in 2018 have met the TQ requirements. 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: Program Manager displayed a proficient understanding of the pipeline safety program. 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 2 2 Evaluator Notes: Yes, Chairman Dana Murphy's response letter to Zach Barrett was received on October 3, 2018. PHMSA's outbound letter was dated SEPTEMBER 14, 2018, thus the State responded within the 60-day time requirement. 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: Seminar was held in November 2018. 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 5 5 Evaluator Notes: Yes. The OCC is on a five year schedule to complete all inspection types. There was no evidence of the OCC not meeting DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 7

this schedule. See question A.8. for PHMSA recommendation regarding this topic related to the OCC's 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: The OCC uses the federal inspection forms for its inspections. Upon a review of randomly selected 2018 inspection files all applicable portions of the forms were completed appropriately. 8 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 195.402(c)(5)? Yes = 1 No = 0 Evaluator Notes: 1 1 The OCC utilizes PHMSA's inspection forms. This requirement is covered on the PHMSA inspection form. 9 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: Data is entered from annual reports into Microsoft Access. Reports are written to observe certain data and trends. The information is also used for assessing risk to help determine inspection scheduling. 10 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The OCC covers operators' NPMS submissions while utilizing PHMSA's inspection form. For the most part, OCC has met this requirement with only a couple minor discrepancies - no point deduction. PHMSA recommended OCC revisit the "NPMS vs. Annual Report" report and reconcile any differences in stated mileage. 11 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 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: The OCC conducted 11 Drug and Alcohol field investigations utilizing Form 13 during 2018. No issues were found with this requirement. 12 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The OCC spent 21 inspection person-days conducting OQ inspections. Several OQ plans were reviewed and over a hundred field inspections (Protocol 9) were conducted. 13 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are up to date? This should include a previous review of LIMP 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? Are replies to Operator IM notifications addressed? (formerly part of Question C-10)). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation 2 2 Oklahoma Oklahoma Corporation Commission, Page: 8

Evaluator Notes: OCC is compliant with this requirement. 14 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 be conducted every four years by operators. 49 CFR 195.440 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OCC is compliant with this requirement. 2 2 15 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: The OCC's website has a section for Pipeline Safety. The OCC participates in the Okie One Call (OPAL) public awareness program. There are several small operator training seminars given around the State each year. All Operators have access to the OCC's docket system. The Public has rights to request and receive paper and electronic records. 16 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: OCC is providing appropriate follow-up actions to Safety Related Condition (SRC) Reports. 1 1 17 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No instances were found where the OCC did not respond. 1 1 18 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. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: The OCC does not have any open waivers with any operators. 1 1 19 Evaluator Notes: Yes Did the state attend the NAPSR National Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 1 1 20 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 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: All of the metrics are trending in the direction of improvement. It was clear from the discussion with the Program Manager and Supervisors that the drivers of the trends are understood. DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 9

21 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: SICT was discussed at length and is well understood by OCC staff. 1 1 22 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: No pipeline flow reversals done in 2018. 1 1 23 General Comments: Info Only = No Points Evaluator Notes: The OCC generally complied with the requirements of Part C of this evaluation. Info Only Info Only Total points scored for this section: 43 Total possible points for this section: 43 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 10

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 Inspection Guidelines provide for these procedures. The Commission Rules & Practice also provide procedures identifying steps. Also contained in Chapter 20 of Oklahoma Administrative Code Title 165. 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? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director 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. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2018, all aspects of these requirements were handled appropriately. No issues. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, reviewed several written compliance letters sent to operators pertaining to non-compliance with the pipeline safety regulations. Letters and attached inspection reports listed the violations found and action that needed to be taken to correct those violations. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: 2 2 No instances were discovered where the operator was not given due process to argue the allegations of non-compliance. 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Evaluator Notes: 2 2 Yes, the Program Manager illustrated the following criteria: Actions caused damage to a third party or public; repeat violations; severity of violations and cooperation of the operator. Ability to pay can also determine amount of penalty. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, Page: 11

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The OCC issued a civil penalty of $1,010,000 in 2016. The penalty was collected in 2016. OCC is also in process of assessing a $1MM fine for an NOPV resulting in a reportable accident in 2018. PHMSA again encouraged the OCC to utilize their fining authority to drive regulatory compliance and enhance pipeline safety. 7 General Comments: Info Only = No Points Evaluator Notes: The OCC has generally complied with the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 12

PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the Inspection Guidelines provide these procedures. Additionally, the Commission Rules & Practice provide procedures identifying steps and is also contained in Chapter 20 of Oklahoma Administrative Code Title 165. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, 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: Process for telephonic notification is covered in Oklahoma Administrative Code 165:20-5-11. The instructions for contact is also contained in the operators' procedure manuals. The OCC verifies the contact information during an inspection. There is a voice mail message that directs who to call after hours. The on-call inspector is changed each week. 3 If onsite investigation was not made, did state obtain sufficient information from the 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: OCC responds (on-site) to all incidents covered by 49 CFR 191.3 1 1 4 Were all accidents 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 where appropriate Yes No Needs Improvement Evaluator Notes: Accidents reviewed appeared to be sufficiently investigated and documented. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: 1 1 All applicable accidents that had probable violations identified were issued written non-compliance notifications. 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator accident 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: The Southwest Region, nor Accident Investigation Division, provided any feedback that indicated the OCC needed improvement in its follow-up actions. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, Page: 13

Yes = 1 No = 0 Evaluator Notes: Yes 8 General Comments: Info Only = No Points Evaluator Notes: The OCC has generally complied with the requirements of Part E of this evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 14

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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The OCC includes this question in the standard inspection form addendum. It is covered during Standard Inspections. 2 Did the state inspector verify pipeline operators are following their 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, this is covered during Standard Inspections when covering 195.442. 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, as of August 27, 2015 the OCC has authority to enforce violations of the Oklahoma Underground Facilities Damage Prevention Act for damages to Part 192 and 195 regulated pipelines. The OCC is using that enforcement authority and continues to participate and make presentations at the one call system's Damage Prevention Expo. 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: The OCC primarily uses the data on PHMSA's stakeholder website for trending analysis. PHMSA discussed other data sources that can be evaluated (i.e. annual reports) during operator inspections. 5 General Comments: Info Only = No Points Evaluator Notes: The OCC has generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 15

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Holly Energy Partners Name of State Inspector(s) Observed: Bruce Campbell and Randy Synder Location of Inspection: Tulsa, OK Date of Inspection: 6/4/2019 to 6/6/2019 Name of PHMSA Representative: David Appelbaum Evaluator Notes: Info Only Info Only This was a Public Awareness and Drug and Alcohol inspection on both Holly Energy's Gas and HL Pipeline Safety program. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, operator was given three month's notice of 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 Evaluator Notes: Yes, OCC used checklists extracted from the PHMSA IA program. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, inspectors took thorough notes during evaluation. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,valve keys, half cells, etc) Yes = 1 No = 0 Evaluator Notes: Inspection was limited to office and records. 1 NA 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Conducted a field visit at operator's testing facility. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation 2 2 Oklahoma Oklahoma Corporation Commission, Page: 16

Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OCC demonstrated proficiency with PAP and D&A inspections. 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: Yes, inspectors did an outstanding job describing what they found, what the relevant application of code was, and what the OCC's expectations were for correcting deficiencies. Inspectors displayed a good command presence, while communicating in a courteous and professional manner. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, deficiencies and probable violations were discussed and acknowledged by the operator. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance Info Only Info Only DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 17

E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Inspection was for Drug and Alcohol, and public awareness. DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Total points scored for this section: 11 Total possible points for this section: 11 Oklahoma Oklahoma Corporation Commission, Page: 18

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: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 19

PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2018 Hazardous Liquid State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 20
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