# 2017 OK NG Program Evaluation - ok-2017-gas-program-evaluation (Oklahoma; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ok-2017-gas-program-evaluation
- **title:** 2017 OK NG Program Evaluation - ok-2017-gas-program-evaluation (Oklahoma; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-01-01
- **effective on:** Not available
- **summary:** 2017 PHMSA natural gas program evaluation for Oklahoma.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/3656/ok-2017-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 2017 Gas 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 -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 1

2017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Oklahoma Rating: Agency Status: Date of Visit: 07/23/2018 - 08/10/2018 Agency Representative: Dennis Fothergill, Manager of Pipeline Safety Department Kelly Phelps, Program Manager 1 John Harper, Program Manager 1 PHMSA Representative: David Appelbaum Leonard Steiner Commission Chairman to whom follow up letter is to be sent: Name/Title: Dana Murphy, Chairman Agency: Oklahoma Corporation Commission (OCC) Address: 2101 North Lincoln Blvd. City/State/Zip: Oklahoma City, Oklahoma 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 2017 (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 9.5 B Program Inspection Procedures 13 13 C Program Performance 47 47 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) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 116 115.5 State Rating................................................................................................................................................... 99.6 DUNS: 150235299 2017 Gas 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 database matched Attachment 1 entries. No issues with accuracy were found. 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 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: OCC had one incident missing in attachment 4. The incident should have been included because the criteria met the estimated gas loss of more than three million cubic feet (? 191.3). OCC pointed out that instructional language on attachment 4 addressing the use of the word "significant" was ambiguous and caused confusion. OCC was counseled and will amend attachment 4 in FedSTAR to include this incident. No points taken due to the reasonable confusion on progress report instructions. 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 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 DUNS: 150235299 2017 Gas State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, Page: 3

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues were found with rules and amendment adoption as shown on Attachment 8. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 0.5 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: OCC did not sufficiently provide their planned annual and long-term goals. What was provided was a (past) 2015 accomplishment, albeit a significant accomplishment. Additionally, when identifying past performances, OCC's answer was limited to "...enforced state damage prevention statutes." OCC was informed that part of attachment 10 was designed to demonstrate progress against stated goals. Attachment 10 needs improvement (1/2 point deduction) 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: 9.5 Total possible points for this section: 10 DUNS: 150235299 2017 Gas 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, revised states Standard Inspections will be conducted on all Municipal, Master Meter and small Public Utility systems once every one to three years. Gas Transmission, Gathering and Large Public Utility will be inspected once every five years. Pre-inspection activities, inspection activities, post-inspection activities have been included in the 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: The OCC's Guidelines, revised August, 2016, states Gas Transmission IMP inspections will be conducted with three years of becoming jurisdictional with follow up inspections once every five years. Distribution IMP inspections will be conducted as soon as jurisdictional with follow up inspection once every five years. Pre-inspection activities, inspection activities, post- inspection activities have been included in the procedures. 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: Operator Qualification inspections are conducted as part of the Standard Inspections and follow the same interval as Standard Inspections. 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 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC's Guidelines states that inspectors are required to conduct five training sessions per year for individual operators. The OCC will conduct five to ten sessions each year for small operators. Industry wide training sessions are to be conducted once every 18 months in conjunction with PHMSA TQ training staff. 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC's Guidelines states Construction Inspections are scheduled as they occur. DUNS: 150235299 2017 Gas State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, 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: The OCC's Guidelines states procedures that comply with elements (a. through (f. above. The OCC guidelines state that all inspection types will be completed within five years; however, there some operator types that are scheduled more frequent than five years such as master meters and small municipals due to some risk factors that are more prevalent with those operators. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The OCC generally complied with the requirements of Part B of this evaluation. PHMSA recommended the OCC develop a table of contents, for ease of use, in their written procedures. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 150235299 2017 Gas 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): 1735.49 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 11.78 = 2591.60 Ratio: A / B 1735.49 / 2591.60 = 0.67 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The OCC's ratio of 0.67 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 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 lead inspectors in 2017 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 August 30, 2017. PHMSA's outbound letter was dated July 31, 2017, 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: Last seminar was held in May 2016 and has scheduled the next seminar for 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 Evaluator Notes: DUNS: 150235299 2017 Gas State Program Evaluation 5 5 Oklahoma Oklahoma Corporation Commission, Page: 7

Yes. The OCC is on a five year schedule to complete all inspection types. There was no evidence of the OCC not meeting this schedule. 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 2017 inspection files all applicable portions of the forms were completed appropriately. 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: There is no cast iron reported by operators in Oklahoma. 1 NA 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: There is no cast iron reported by operators in Oklahoma. 1 NA 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 1 1 Evaluator Notes: The OCC utilizes PHMSA's Standard Inspection Form. This requirement is covered on the federal inspection form. Upon a review of randomly selected inspection files, the forms were completed for this requirement. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: These requirements are covered when completing PHMSA's Standard Inspection Form. Upon a review of randomly selected inspection files, the forms were completed for this requirement. 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: The Program Manager's Administrative Assistant enters data from annual reports into a Microsoft Access database. Queries are written to report and observe certain data and trends. The information is also used to assess risk factors for individual operators and systems. The information is also compared to the Performance Metrics contained on the PRIMIS webpage. 13 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: DUNS: 150235299 2017 Gas State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, Page: 8

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. 14 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 135 Drug and Alcohol field investigations utilizing Form 13 during 2017. No issues were found with this requirement. 15 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 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The OCC spent 108.5 inspection person-days conducting OQ inspections. Several OQ plans were reviewed and over a hundred field inspections (Protocol 9) were conducted. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 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? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 72 inspection person days were spent on integrity management inspections during CY2017. 26 inspections were conducted. 17 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The DIMP inspections were completed prior to December, 2014. The implementation inspections began in August, 2016. The OCC completed 130 implementation inspections during CY2017. 18 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 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Five Plan and/or PPAEI inspections were conducted on gas operators in CY2017. The OCC conducted 33 in 2016. 19 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 Evaluator Notes: 1 1 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 DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 9

the OCC's docket system. The Public has rights to request and receive paper and electronic records. PHMSA recommended that OCC consider providing a summary of the information contained in attachment 5 on their website. 20 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: Yes 1 1 21 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: The OCC covers this issue when conducting DIMP and IMP inspections. 1 1 22 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 23 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: The OCC does not have any open waivers with any operators. 1 1 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, the OCC attended the NAPSR National Meeting in Columbus, OH. 1 1 25 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: 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. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: The OCC's inspection person days increased substantially with the new calculation tool. Because the OCC has minimal travel time, the average number of inspection person days per inspector is approximately 120, much higher than the accepted 85. The OCC's average allows it to achieve the number of inspection person-days with the same level of staff that it has presently. DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 10

27 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 1 1 Evaluator Notes: In CY2017, the OCC made an inspection Form Addendum to their Standard Inspection and added this topic. 28 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: 47 Total possible points for this section: 47 DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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 Inspection Guidelines provide these procedures on pages 11 to 12. The Commission Rules & Practice also provide procedures identifying steps. Also contained in Chapter 20 of Oklahoma Administrative Code Title 165. Regarding #c. the OCC allows supervisors to sign for the closure of probable violations, though compliance correspondence is sent and received by the program manager. PHMSA recommended the OCC program manager be the signatory if that position is going to be the corresponding party. 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. 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 2017, 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 Needs Improvement = 1 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. DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 12

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: Yes. The OCC issued a civil penalty of $1,010,000 in 2016. The penalty was collected in 2016. 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 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the Inspection Guidelines provide these procedures on pages 9 to 10. 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 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: 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: N/A. OCC responded (on-site) to all incidents covered by 49 CFR 191.3 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 3 Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There was one reported incident on intrastate operators' facilities in CY2017. The investigation report was reviewed and there were no issues identified. 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 incidents 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 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: The Southwest Region, nor Accident Investigation Division, provided any feedback that indicated the OCC needed improvement in its follow-up actions. DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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 1 1 Evaluator Notes: Yes 8 General Comments: Info Only = No Points Evaluator Notes: The OCC 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 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, 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: 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: The OCC reviews compliance of these requirements while covering 192.614 in its Standard Inspections. 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 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. damages resulting from locator no-shows) 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 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 16

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Minco Gas Authority Name of State Inspector(s) Observed: Brandon Lee, Pipeline Safety Specialist Location of Inspection: 212 NW Main, Minco, OK 73059 Date of Inspection: August 7-8, 2018 Name of PHMSA Representative: David Appelbaum and Leonard Steiner Evaluator Notes: The OCC conducted a Standard Inspection. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Minco notified of inspection in June. Matt Harris, Operator, was present. 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: State used their Form 2, revised March 2018, and combines PHMSA Gas Distribution and Transmission forms. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The OCC inspectors entered the results of each question on the appropriate form. Any non-compliance was noted as unsatisfactory and described on the form. 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 used a volt meter and half cell to conduct cathodic protection readings. The OCC inspected the equipment to verify it was appropriate. 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: Inspector was very thorough in all aspects of the inspection. 2 2 DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 17

7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The inspector has completed all of the requisite Training and Qualifications training and has several years of experience inspecting pipeline operators. The inspection was conducted in a very professional and organized manner. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: 1 1 A partial exit interview was conducted towards the end of day 2, and was done sufficiently to satisfy this requirement. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. The inspector described possible probable violations that were found during the inspection. The inspector stated that after consulting with supervision, the operator would receive written notification of the probable violations within 90 days. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 18

D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Meter protection, locate and mark. The OCC inspectors complied with the requirements of Part G of this evaluation. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 150235299 2017 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 19

PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection fo
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