PHMSA pa2015ngprogramevaluation - 2015 PA NG Program Evaluation - pa2015ngprogramevaluation (Pennsylvania; Natural Gas State Program Evaluation) | Regulus

PA NG Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 Gas State Program Evaluation for PENNSYLVANIA PUBLIC UTILITY 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: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 1#

PA NG Program Evaluation, 2015, page 22015 Gas State Program Evaluation -- CY 2015 Gas State Agency: Pennsylvania Rating: Agency Status: Date of Visit: 06/06/2016 - 06/16/2016 Agency Representative: Paul J. Metro, Chief Engineer Gas Safety Division PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Gladys M. Brown, Chairman Agency: Pennsylvania Public Utility Commission Address: PO Box 3265 City/State/Zip: Harrisburg, Pennsylvania 17105-3265 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 2015 (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 50 50 D Compliance Activities 15 15 E Incident Investigations 10 10 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 117 117 State Rating................................................................................................................................................... 100.0 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 2#

PA NG Program Evaluation, 2015, 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 Evaluator Notes: No issues. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 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: No issues, Progress Report and Pipeline Data Mart match. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. All inspection records are kept under the Divisions CAI Inspection database. B. Biggard maintains records of Non Complaince records that are issued or closed. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. PA PUC rules automatically adopt amendments to federal regulations. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 3#

PA NG Program Evaluation, 2015, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 4#

PA NG Program Evaluation, 2015, 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: Standard inspection procedures were located in the Pennsylvania Public Utility Commission Gas Safety Inspector Handbook. Inspection protocols are listed along with Pre and Post inspection instructions that outline the steps for all inspections completed by the Division. 23 forms make up a Standard Inspection. 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: No issues. IMP and DIMP inspection procedures are located in PA PUC Gas Safety Inspector Handbook. Inspection Protocols found on Page 17 and 19. Pre-Inspection, Inspection and Post Inspection Activiyies are found on pages 12 and 13 Gas Safety Inspector Handbook. 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: No issues. OQ inspection procedures are located in PA PUC Gas Safety Inspector Handbook updated February 2016. Inspection Protocols are on Page 25, OQ 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: No issues. Damage Prevention Inspection procedures are located in PA PUC Gas Safety Inspector Handbook updated February 2016. One Call Verification is on page 24 and Third Party Damage is on page 14. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. On-Site Operator Training can be conducted under OQ Inspections on page 32 and Welding and Pipe Certification inspections. 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. Consturction inspections procedures are located in PA PUC Gas Safety Inspector Handbook updated February 2016. This item is covered under inspection protocols for Plastic Pipeline Construction on page 26, Steel Pipeline Construction on Page 29, and Compressor Station Construction on Page 16. DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 5#

PA NG Program Evaluation, 2015, 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: This list is contained in the PA PUC Gas Safety Inspector Handbook, Inspection Protocols, page 12, Procedures for determining inspection Priorities. PA PUC uses risk analysis for determining inspection criteria. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 6#

PA NG Program Evaluation, 2015, 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): 1461.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.05 = 2211.00 Ratio: A / B 1461.00 / 2211.00 = 0.66 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ratio of .66 exceeds needed ratio 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: No issues. A. Yes. A review of SABA transcript confirmed all isnpectors have completed the OQ training prior to performing an inspection B. Yes, a review of SABA transcript confirmed inspectors have completed DIMP/IMP course before conducting an inspection as lead. C. Yes, inspectors have completed the root cause course. D. Inspectors attended the AGMSC in Robert Morris in August 2015. E. Yes. A review of files found inspectors who performed standard inspections were qualified for the type of inspection assigned to them. 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: Yes. Paul Metro has over 14 years of experience in Pipeline Safety and has SR/PHMSA committees and as NAPSR Chair. 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: Response - within 60 days Corrections made 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: DUNS: 796091569 2015 Gas State Program Evaluation 2 2 Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 7#

PA NG Program Evaluation, 2015, page 8Yes. October 2014. 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 PA PUC use a combination of procedures and risk ranking to inspect the operators and inspection units. 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: Yes. The PA PUC uses modified Federal Inspection Forms. The review of files confirmed all sections of the federal inspection forms were completed with a U, S, or N/A 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. This was accomplished by a letter to all operators in the first quarter of each year. The Formal Letter (FL 1-16) lists this question. A review of FL 1-16 dated February 4, 2016 confirmed this item was listed. PA PUC reviews and tabulates data from the letters on cast iron and uses this in their risk ranking. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. This was accomplished by a letter to all operators in the first quarter of each year. The Formal Letter(FL 1-16) lists this question. A review of FL 1-16 dated February 4, 2016 confirmed this item was listed. PA PUC reviews and tabulates data from the letters on cast iron and uses this in their risk ranking. 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. This was accomplished by a letter to all operators in the first quarter of each year. The Formal Letter(FL 1-16) lists this question. A review of FL 1-16 dated February 4, 2016 confirmed this item was listed. PA PUC reviews and tabulates data from the letters under item number 6. 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: Yes. This item is described in PA PUC Gas Safety Handbook. Leak response is tracked on 3rd party damage Inspection , Leak verification, and Leak survey forms. All incident response times are captured in the Leak Investigation/Complaint forms. DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 8#

PA NG Program Evaluation, 2015, page 912 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: Yes. PA PUC staff members review the operators annual reports and record results into a risk assessment spreadsheet. During field inspections, the inspector will review the annual report with the operator. Reviewed spreadsheet of data. 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All OQ and IMP inspections have been entered into the database for 2015. 2 2 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: covered under item 14. Yes. This item is accomplished by Formal Letter FL 1-16 to all operators under the first quarter of each year. This is 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: Yes. This item is accomplished by Formal Letter FL 1-16 to all operators under the first quarter of each year. This is covered under item 12. This item is also reviewed with the operator during drug and alcohol inspections using the PHMSA form. PA PUC conducted 14 Drug inspections in 2015. 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: No issues. Yes. This item is listed in the PA PUC Gas Safety Inspector Handbook, OQ (Operator Qualification) Inspections, Page 24. 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: No issues. Yes. This item is listed in the PA PUC Gas Safety Inspector Handbook, Page 19, IMP (Intergrity Management) Inspections. They use the federal inspection form in verifying the operators compliance along with their state inspection form, Pipeline Integrity Field. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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 have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 9#

PA NG Program Evaluation, 2015, page 10Evaluator Notes: No issues. This is performed on the DIMP Federal Form. 19 Is state verifying operators Public Awareness programs are up to date and being 2 2 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 be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. This item is accomplished by the FL 1-16 letter to all operators in the first quarter of each year. This is covered by a question under item 9. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The PA PUC continues to hold monthly meeting with company officials about safety related items and general discussions on improvements with the safe transportation of natural gas. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was one Safety Related Condition Report for 10/28/15 in UGI PNG South Point. Information was reviewed and follow-up by PA PUC Inspectors. 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. This item is accomplished by form letter FL 1-16 to all operators in the first quarter of each year. This is covered under item 7. 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: Yes. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 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: Yes. There is currently one special permit waviers that is active dated 3/20/15 for Johnstown Regional Energy use of Fiberspar pipe. 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. 1 1 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 10#

PA NG Program Evaluation, 2015, page 1126 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: Yes. The website has been reviewed and the state agrees with the information presented. 27 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 11#

PA NG Program Evaluation, 2015, 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: A. Yes. This is listed in the PA PUC Gas Safety Inspector Handbook written procedures, under Enforcement Procedures, Pages 37. B. Yes. This item is listed in the PA PUC Gas Safety Inspector Handbook under Non-Compliance Follow Up Procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: A. A review of Notice of Probable Violation letters CY 2015 found 73 Letters. B. Yes. Letters contained all violations were listed with detailed information in the letters. C. Yes. Probable violations were corrected. D. Yes. PA PUC Adminstrative Assistant routinely reviews all probable violations sited and discuss action to correct with each Engineer. This is checked on a monthly time schedule. E. There is a comment on compliance actions about enforcement "This office is committed to ensuring that all natural gas companies comply with the provisions of the Public Utility Code. Therefore, you are advised that, if you fail to comply with the above requests this office will initiate all appropriate enforcement actions pursuant to the Public Utility Code against the utility and its officers, agents and employees.". 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. A review of inspection reports and letters confirm compliance action was taken by the Gas Safety Division. This is demonstrated in the 73 complaince actions taken in CY 2015. 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: Yes. Review of letters and procedures confirm the Gas Safety Division is providing the operator due process as listed under the Enforcement Procedures, Non Compliance Letters, Page 35. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Paul Metro, Manager of Gas Safety is familiar with imposing civil Penalties. In CY 2015, 75 compliance actions were taken and $30,000 was collected in penalties against operators.DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 12#

PA NG Program Evaluation, 2015, page 136 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, information on PA PUC 2015 Progress Report, Attachment 5, show enforcement fining authority was used. In the regard, 75 compliance actions were taken and $30,000 was collected in penalties against operators. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 13#

PA NG Program Evaluation, 2015, 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: Yes. PA PUC Gas Safety Inspector Handbook, Non Reportable Failure Insvestigation, Page 20 and Reportable Failure Investigations on Pages 26 -27 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. This is covered in PA PUC Gas Safety Inspector Handbook under Non Reportable and Reportable Failure Investigations. A. Yes. PA PUC Staff and Program Manager are aware of the MOU Between NTSB and PHMSA B.Yes PA PUC staff and Program Manager are familiar with Appendix E on the the Federal/State Cooperation in case of incidents/accidents 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All reportable and non- reportable incidents are investigated by PA PUC staff regardless it the operator considers the incident as Non-reportable. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes. The review of 1 incident that occurred in CY 2015 was conducted. The report was 7912 Ardleigh St, Philadelphia. The report was well documented. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no violations as a result of the incident Investigation at 7912 Ardleigh St. in Philadelphia. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. PA PUC staff members coordinated information about the incident to PHMSA Eastern Region Office.DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 14#

PA NG Program Evaluation, 2015, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes. Paul Metro continues to share the results of PA PUC's incident investigation in 2015 with NAPSR members at the 2015 Eastern Meeting. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 15#

PA NG Program Evaluation, 2015, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. This item is addressed by Formal Letter FL 1-16 question 10 to all operators in the first quarter of each year. Additionally, all operators responses are reviewed by PA PUC inspectors for compliance. 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: 2 2 Yes. This item is addressed in PA PUC Gas Safety Inspector Handbook titled One Call Verification , Page 24. 3 Did the state encourage and promote practices for reducing damages to all underground 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. This item is reviewed and discussed with operators at the annual PA PUC Pipeline Safety Seminar. 2 2 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The PA PUC Gas Safety Division continues to collect data on trends and the number of pipeline damages per 1,000 locate requests and posts the results on the PA PUC website. This is collected by form letter FL 1-16. In CY 2015, the pipeline damage ratio per 1,000 locate requests was 3.1 percent. The number decreased from 2014 to 2015. The highest recorded ratio of 8.2 occurred in 2005. Reviewed data. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 16#

PA NG Program Evaluation, 2015, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: 6/14 - Philadelphia Gas Works 6/15 & 6/16 - PECO Name of State Inspector(s) Observed: Terri Cooper Smith Location of Inspection: 6/14 - Philadelphia 6/15 - Delaware County 6/16 - Warminister Date of Inspection: 6/14 - 16/16/2016 Name of PHMSA Representative: Jim Anderson Evaluator Notes: 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 at all 3 locations. 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 at all 3 locations. Have copies of inspection forms. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes at all 3 locations. Inspector conducted very comprehensive inspections. 2 2 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 at all 3 locations. 1 1 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 odorization, plastic pipe construction and cathodic protection inspections. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) 2 2 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 17#

PA NG Program Evaluation, 2015, page 18Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Ms. Smith was very knowledgeable on PA pipeline safety rules and regulations. 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: Yes. No issues. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: None found. 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 E. Vault Maintenance Info Only Info Only DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 18#

PA NG Program Evaluation, 2015, page 19F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 19#

PA NG Program Evaluation, 2015, 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: 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 Evaluator Notes: 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 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: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 20#

PA NG Program Evaluation, 2015, 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: 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: 796091569 2015 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 21#