PHMSA ok2014ngprogramevaluation - 2014 OK NG Program Evaluation - ok2014ngprogramevaluation (Oklahoma; Natural Gas State Program Evaluation) | Regulus

OK NG Program Evaluation, 2014, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2014 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 1#

OK NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Oklahoma Rating: Agency Status: Date of Visit: 04/06/2015 - 05/22/2015 Agency Representative: Dennis Fothergill, Manager of Pipeline Safety Department PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Bob Anthony, Chairman Agency: Oklahoma Corporation Commission 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 2014 (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 44 42 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 10 10 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 110 108 State Rating................................................................................................................................................... 98.2 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 2#

OK NG Program Evaluation, 2014, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The OCC's records and database confirm the operator and units information contained in Attachment 1. The number of inspection units in Attachment 1 are consistent with Attachment 3. No issues found. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The OCC's records and database confirm the inspection person days entered into Attachment 2. No issues identified. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC's records and database confirm the entries into Attachment 3. No issues found. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There were three reportable incidents shown on Attachment 4. A review of the incident data in the Pipeline Data Mart is consistent with the OCC's Attachment 4 incidents. No issues found. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC's records and database confirm the data entries into Attachment 5. No issues found. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 A review of the OCC's files and database indicated that they are organized and easy to obtain. No issues found. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Employee listing was correct. The training is downloaded from PHMSA TQ's SABA database. No issues identified. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found with the OCC's entries on Attachment 8. 1 1 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 3#

OK NG Program Evaluation, 2014, page 49 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 The OCC provided adequate detail on accomplishments of its program in Attachment 10. No improvements identified. 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 4#

OK NG Program Evaluation, 2014, page 5PART 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 May1, 2015, 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. 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 May1, 2015, 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. 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, revised May1, 2015, 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, revised May1, 2015, states Construction Inspections are scheduled as they occur. 1 1 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 5#

OK NG Program Evaluation, 2014, page 67 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, revised May1, 2015, states procedures that comply with elements (a. through (f. above. 8 General Comments: Info Only = No Points Evaluator Notes: The OCC has generally complied with 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 6#

OK NG Program Evaluation, 2014, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1202.99 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 8.99 = 1977.80 Ratio: A / B 1202.99 / 1977.80 = 0.61 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The OCC's inspection person days during 2014 exceeded the minimum ratio of 0.38 (ratio was 0.61). 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 3 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: Program Manager Requirement - Program Manager has not completed the required courses within five years from the effective date of 1/1/2009 (effective date of Guidelines revision that added this requirement). The Program Manager successfully completed PL3251 - Safety Evaluation of Pipeline Corrosion Control Systems I but did not complete PL3252 - Safety Evaluation of Pipeline Corrosion Control Systems II before it was discontinued. PL3293 has now replaced PL3251 and PL3252. Program Manager has not completed PL3293. Two points are deducted. Inspectors and Supervisors - All have completed training requirements or are progressing on schedule to meet the five year successful completion requirement. 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 2 2 Evaluator Notes: No issues. Dennis Fothergill has been the manager of the OCC's program for over twenty five years. Dennis is very knowledgeable of pipeline safety regulations and the pipeline safety grant program. 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: The OCC responded in 22 days. No issues. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Seminar is held every 12 to 18 months. Last seminars were held November, 2014 and May, 2013. DUNS: 150235299 2014 Gas State Program Evaluation 2 2 Oklahoma Oklahoma Corporation Commission, Page: 7#

OK NG Program Evaluation, 2014, page 86 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. Attachment 1 of the Progress Report shows percentages inspected for operators and inspection units that illustrate the OCC is meeting its time intervals. 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. A random sample of inspections conducted during 2014 showed that 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 pipe 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 Evaluator Notes: This safety issue is covered on the federal inspections form. The OCC utilizes the federal inspection form. 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: The OCC utilizes the federal inspection forms. 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: trends. Program Manager enters data from annual reports into Microsoft Access. Reports are written to observe certain data and DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 8#

OK NG Program Evaluation, 2014, page 913 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 2 2 5.1 Evaluator Notes: manner. No issues. Yes = 2 No = 0 Needs Improvement = 1 Upon a review of the OQ and Gas Transmission IMP databases the OCC has entered inspection information in a timely 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 1 1 Evaluator Notes: The OCC uses the federal form. The NPMS question is at the top of the federal form. The OCC confirms that operators have submitted their information while covering this issue on the federal form. 15 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 reported conducting 139 Drug and Alcohol field inspections during 2014. The records confirmed these inspections. 16 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 reported 144.5 inspection person days spent conducting Operator Qualification inspections during 2014. The OCC records confirmed these inspection person days. 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). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The OCC reported 35.5 inspection person days spent conducting Gas Transmission IMP inspections during 2014. The OCC records confirmed these inspection person days. 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). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The OCC reported 88.5 inspection person days spent conducting IMP inspections of gas distribution operators during 2014. The OCC records confirmed these inspection person days. Program inspections for all gas distribution operators were completed prior to December31, 2014. 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. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 9#

OK NG Program Evaluation, 2014, page 10Evaluator Notes: The OCC completed the PAPEI inspections prior to December 31, 2013 as confirmed in the CY2013 evaluation. 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: The OCC participates in the Okie One Call (OPAL) public awareness program. There are 5 to 10 small operator training seminars given around the State each year. All Operators have access to the OCC's docket system. The OCC is progressing to establish a Pipeline Safety website where all finalized inspection reports, along with findings of violations, will be available to the public. The Public has rights to request and receive paper and electronic records. 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: No issues with Safety Related Condition Report follow up on the three SRC Reports during 2014. 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: The OCC covers this issue when conducting DIMP inspections. 1 1 23 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 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.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: The OCC does not have any open waivers with an operator. 0 0 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: Yes, the OCC attended the NAPSR National Meeting in Springfield, IL. 0 0 26 Discussion on State Program Performance Metrics found on Stakeholder Communication 0 0 site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points Evaluator Notes: The OCC is aware of the Metrics for Oklahoma that is found in the PRIMIS website maintained by PHMSA. The OCC will be focusing on any actions that can be taken to improve pipeline safety and the associated metrics. DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 10#

OK NG Program Evaluation, 2014, page 1127 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question C.2 - Program Manager has not completed the required courses within five years from the effective date of 1/1/2009 (effective date of Guidelines revision that added this requirement). The Program Manager successfully completed PL3251 - Safety Evaluation of Pipeline Corrosion Control Systems I but did not complete PL3252 - Safety Evaluation of Pipeline Corrosion Control Systems II before it was discontinued. PL3293 has now replaced PL3251 and PL3252. Program Manager has not completed PL3293. Two points are deducted. Total points scored for this section: 42 Total possible points for this section: 44 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 11#

OK NG Program Evaluation, 2014, page 12PART 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 Evaluator Notes: Yes, the Inspection Guidelines provide these procedures on pages 7 to 9. The Commission Rules & Practice also provide procedures identifying steps. Also contained in Oklahoma Administrative Code Title 165: Chapter 20. 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. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2014, 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: violations. No issues. Upon a review of randomly selected inspection reports completed in 2014, compliance actions were taken for all probable 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: Upon a review of randomly selected inspection reports completed in 2014, no instances were observed 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: Actions caused damage to a third party or public. Repeat violation. Severity of violation. Ability to pay can determine amount of penalty. Cooperation of operator. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 150235299 2014 Gas State Program Evaluation 1 1 Oklahoma Oklahoma Corporation Commission, Page: 12#

OK NG Program Evaluation, 2014, page 13Civil penalty issued to OneOK Gas Transportation in 2014. 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 13#

OK NG Program Evaluation, 2014, page 14PART 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: The OCC's Inspection Guidelines states the actions it will take in the event of an incident that meets federal reporting requirements. This information is stated on Page 8. The OCC will investigate each incident on site unless an inspector is not available. 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, the MOU between NTSB and OPS is understood, and OCC fully cooperates with NTSB. The OCC understands the written statement of cooperation between states and PHMSA in case of an incident. Gas incidents are investigated and reports placed in the files. 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: All three incidents during 2014 were investigated on site. 1 1 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: Upon a review of the incident investigation reports, all expectations were met. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no probable violations found during the incident investigations. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PHMSA's Southwest Region Office did not provide any feedback that indicated a need for improvement. 1 1 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 14#

OK NG Program Evaluation, 2014, page 157 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 The Program Manager shares incident experiences with the other states during the Southwest Region meeting in 2014. 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: 10 Total possible points for this section: 10 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 15#

OK NG Program Evaluation, 2014, page 16PART 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: The OCC added this question to the inspection form addendum. It is covered during Standard Inspections. 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, this is covered during Standard Inspections when covering 192.614. 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, the OCC now will have authority to enforce violations of the Oklahoma Underground Facilities Damage Prevention Act for damages to regulated pipeline only. 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: Damage information is collected from operators' annual reports. The OCC requests additional information from the operators. The information is farther broken down by damages caused by the operator or a third party excavator. The information is analyzed and trended by the program manager. 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 16#

OK NG Program Evaluation, 2014, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Arkansas Oklahoma Gas Corp. (AOG) Name of State Inspector(s) Observed: Mitch Skinner Location of Inspection: AOG's Fort Smith office and field locations in Eastern Oklahoma Date of Inspection: 4/6/2015 to 4/8/2015 Name of PHMSA Representative: Don Martin Evaluator Notes: Standard Inspection of AOG's pipeline system in Oklahoma. 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 Evaluator Notes: Yes, the operator was notified prior to the inspection and provided representatives. 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: The OCC inspector utilized PHMSA's Form 2 inspection form during the inspection, revised 1/29/2015. 2 2 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All appropriate information was documented. The check boxes were checked and explanations were given for any boxes checked NC or NA. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector verified the acceptability of testing equipment. 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Procedures are reviewed at a seperate time. Records were reviewed in the office and tests were observed in the field. DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 17#

OK NG Program Evaluation, 2014, page 187 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: 2 2 The OCC inspector has completed all required TQ courses and has several years experience inspecting operators. 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: The exit interview was conducted after the evaluation observation. 1 NA 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The evaluator was not present during the exit interview. 1 NA 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 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 18#

OK NG Program Evaluation, 2014, page 19E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: evaluation. No issues was identified with the topics covered. The OCC generally complied with the requirements of Part G of this Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 19#

OK NG Program Evaluation, 2014, page 20PART 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: The Oklahoma Corporation Commission is not an interstate agent. 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: The Oklahoma Corporation Commission is not an interstate agent. 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: The Oklahoma Corporation Commission is not an interstate agent. 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: The Oklahoma Corporation Commission is not an interstate agent. 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 Evaluator Notes: The Oklahoma Corporation Commission is not an interstate agent. 1 NA 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 The Oklahoma Corporation Commission is not an interstate agent. 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: The Oklahoma Corporation Commission is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The Oklahoma Corporation Commission is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 20#

OK NG Program Evaluation, 2014, page 21PART 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: The Oklahoma Corporation Commission does not have a Section 60106 agreement. 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: The Oklahoma Corporation Commission does not have a Section 60106 agreement. 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: The Oklahoma Corporation Commission does not have a Section 60106 agreement. 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 Evaluator Notes: The Oklahoma Corporation Commission does not have a Section 60106 agreement. 1 NA 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 The Oklahoma Corporation Commission does not have a Section 60106 agreement. 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: The Oklahoma Corporation Commission does not have a Section 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The Oklahoma Corporation Commission does not have a Section 60106 agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2014 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 21#