# 2017 RI NG Program Evaluation - ri-2017-gas-program-evaluation (Rhode Island; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ri-2017-gas-program-evaluation
- **title:** 2017 RI NG Program Evaluation - ri-2017-gas-program-evaluation (Rhode Island; 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 Rhode Island.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-state-evaluation-ri-ng-program-evaluation-ri-2017-gas-program-evaluation.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-state-evaluation-ri-ng-program-evaluation-ri-2017-gas-program-evaluation
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/3671/ri-2017-gas-program-evaluation.pdf
**body:**

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 RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1

2017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 06/12/2018 - 06/14/2018 Agency Representative: Lateef Olajide PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Macky McCleary, Administrator Agency: Rhode Island Division of Public Utilities and Carriers Address: 89 Jefferson Blvd. City/State/Zip: Warwick, Rhode Island 02888 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 8 B Program Inspection Procedures 13 13 C Program Performance 45 38 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 112 103 State Rating................................................................................................................................................... 92.0 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. RI PUC resubmitted a corrected 2017 Progress Report prior to the evaluation. A couple of numbers were transposed incorrectly. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: Needs Improvement. Submitted 112 inspection days and there were actually 123 inspection days during 2017. 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. Operator and Inspection Units correct. 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: Yes. The 2017 Progress Report listed 1 incident and the PDM also listed the same incident. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Needs Improvement. During the evaluation there were more violations found than were submitted on the Progress Report. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 1 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs Improvement. Previous program manager departed prior to training to training new personnel. Records were difficult to gather during evaluation. 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: No issues. 2017 progress report listed both staff employees and their training. Only 1 current staff member and he is on track to complete TQ training within time frame. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI PUC rules adopts most recent edition of Parts 190-199 plus Part 40. 1 1 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3

9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. No issues. 1 1 10 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: 10 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, 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: All types of inspections are listed starting on Page 8, IV Inspection Planning, C-Time Intervals for Inspections. Time frame set for 1 year. Standard Inspections are listed in the written procedures manual. Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. 2 IMP and DIMP 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: DIMP Inspections are listed in the written procedures manual on Page 14 (N). Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. As of end of 2017, RI does not have any T lines. 1 1 3 OQ 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: DIMP Inspections are listed in the written procedures manual on Page 14 (I). Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DIMP Inspections are listed in the written procedures manual on Page 14 (M). Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 623014990 2017 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5

DIMP Inspections are listed in the written procedures manual on Page 14 (I). Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. 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: DIMP Inspections are listed in the written procedures manual on Page 12 (II). Pre-inspection activities listed on Page 10, V Conducting Inspections: Preparation for Inspection. Inspection Activities are noted in each type of inspection listed. Post-inspection activities are listed for activities involving NOPVs. 1 1 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: Yes, these were listed on Page 8, IV Inspection Planning, B- Priorities. 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 0 A. Total Inspection Person Days (Attachment 2): 112.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.80 = 396.00 Ratio: A / B 112.00 / 396.00 = 0.28 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: RI PUC pipeline safety staff did not have enough inspection days to meet the .38 inspection day ratio. 0 points 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: Don Ledversis had completed all requiredtraining and left toward the end of the calendar year. New employee, Lateef Olajide, is working on completing TQ training within 2 years. 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: Don Leversis, for 2017, was knowledgeable on the PHMSA pipeline program and regulations. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 2 2 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Letter to Administrator sent on January 31, 2018 and response letter was sent on February 20, 2018. All issues were addressed. 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: Yes, last seminar was October 20, 2016. 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: 623014990 2017 Gas State Program Evaluation 5 5 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7

Yes. Written procedures state LDCs inspected every year and LP anf MM inspected every 5 years. Review of inspections show time frames were met. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 1 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs Improvement. There were no inspection forms for MM operators. Had proper inspection forms LDCs and LP operators. 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: 1 1 National Grid has completed a review of the cast iron in the system and are in a cast iron replacement program. 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: 1 1 National Grid has completed a review of the cast iron in the system and are in a cast iron replacement program. 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. RI PUC uses PHMSA form 2 for inspections and this question is on the 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: Yes, 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: Reviewed National Grid CY2016 annual report (only LDC in state). Discussed information on annual report and how to gather information and build data base for trending operators mileage, leaks, type of pipe and etc. 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: 623014990 2017 Gas State Program Evaluation 1 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8

No Tlines after 2017. 14 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Conducted annually - reviewed 2017 inspection report. Conducted with annual standard inspection. 2 2 15 Is state verifying operators OQ programs are up to date? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. On 12/12/17 inspection form 14 was conducted on National Grid. 2 2 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 National Grid reduced the pressure on 2 pipelines, one 8 feet/the other 60 feet, to a pressure of less than 20% SMYS in 2017. 17 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). (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: Needs improvement. Could not find DIMP inspection report that was conducted in September 2017. 2 1 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: Public Awareness program was reviewed in December 2017. No issues. 2 2 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: There is a link on the RI PUC webpage for pipeline safety section for the public to gather information. 1 1 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: DUNS: 623014990 2017 Gas State Program Evaluation 1 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9

NO SRCs in 2017. 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: National Grid participates with the PPDC. 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: Yes. 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: RI has approved two granted waivers - one in 1976 and one in 1993. Both expired. 1 NA 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. 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: Discussed Meaningful Metrics with program manager and reviewed State performance metric page. 26 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed SCIT with program manager and noted RI PUC needs to update SCIT. 1 1 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 Evaluator Notes: There are no Tlines. 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10

Total points scored for this section: 38 Total possible points for this section: 45 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, 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. Procedures note in writing to notify company officers. Reviewed NOPV and letter was sent to company officer (company president). Page 15-Section Q - Notice of Probable Violation Actions. Prevent delays - Written Procedures - Page 15-Section R - Notice of Probable Violation Tracking. Closing out violations - Page 15 - Section S- Removal or Correction of a Probable Violation. 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: Reviewed only NOPV in 2017 sent to National Grid. No issues. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 7 NOPVs documented and sent to National Grid. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Possible civil penalties and due process were noted in the notification to the operator. 2 2 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: Yes. Civil penalties were issued in 2017. 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: 623014990 2017 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12

Yes. Civil penalties were issued in 2017. 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13

PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. On page 16 of the written procedures, Section VI - Investigation of Incidents. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. Program manager's cell phone listed as contact for reporting incidents. It is monitored 24/7. 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: RI PUC investigates all reportable incidents. 1 NA 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. One incident in 2017 and it was investigated. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: Yes. $100,000 fined issued as a result of the incident. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) 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: 1 1 Incident occured on March 29, 2017. There was communication with PHMSA"s AI Division on 4/28/2017 and 5/22/2017. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 623014990 2017 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14

Yes. 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, 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: Reviewed National Grid's Construction Procedures - CNST 001001 and CNST 001002. 2 2 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: This is covered in every informal review on DIG Safe Probable Violation meetings. 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. Dig Safe breakfasts and most recently a booths at Public Works Convention and League of City/Town seminar. 4 Has the agency or another organization within the state collected data and evaluated 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: PUC staff collects data. In 2017 the rate was 2.37 damages per 1000 locate request. 2 2 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, 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: National Grid Name of State Inspector(s) Observed: Lateef Olajide Location of Inspection: Bristol, RI - E Street and Cole Date of Inspection: June 14, 2018 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 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. Inspector receives daily notice of construction crew locations and National Grid was given notice of our construction inspection intentions. 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. A construction inspection checklist was used. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No issues. 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. No issues. 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: Observed a 4 inch plastic main tie-in. 2 2 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17

7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 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 detected. 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 Info Only Info Only DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18

E. Vault Maintenance F. 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19

PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20

PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2017 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 21
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