2012 UT NG Program Evaluation - ut2012ngprogramevaluation (Utah; Natural Gas State Program Evaluation)

UT NG Program Evaluation, 2012, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2012 Natural Gas State Program Evaluation for Utah Division of Public Utilities 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: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 1#

UT NG Program Evaluation, 2012, page 22012 Natural Gas State Program Evaluation -- CY 2012 Natural Gas State Agency: Utah Rating: Agency Status: Date of Visit: 07/09/2013 - 07/12/2013 Agency Representative: Al Zadeh, Pipeline Safety Program Manager Connie Hendricks, Office Specialist Dave Hassell, Pipeline Safety Engineer PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Chris Parker, Director, Division of Public Utilities Agency: Utah Department of Commerce Address: Heber M. Wells Building, 4th Floor, 160 East 300 South City/State/Zip: Salt Lake City, UT 84114-6751 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 2012 (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 9 8 B Program Inspection Procedures 15 15 C Program Performance 44 44 D Compliance Activities 15 8 E Incident Investigations 8 8 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 111 103 State Rating................................................................................................................................................... 92.8 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 2#

UT NG Program Evaluation, 2012, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 0.5 Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review found 80 master meter operators listed do not agree with 76 shown on attachment 3, number of municipals (6) do not agree with inspection units (5) listed in attachment. Improvement is needed in correctly entering the number of operators and inspection units. Therefore, a loss of 0.5 points occured 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Verified number of inspection days on spreadsheet maintained by Program Manager were correct. Suggested information be posted on a separate spreadsheet to be maintained by Office Specialist member as a backup document. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 0.5 A review of Attachment 3 indicated the Master Meter operator, Logan 685 1/2 Darwin Avenue, was listed but inspection unit was not recorded. Improvement is needed in correctly providing each unit number, therefore a loss of 0.5 points occurred. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No reportable incidents occured in CY2012 evaluation period. NA. 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: CY2012. A review of Attachment 5 found the information correct. No civil penalties or compliance actions were issued or assesed in 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of office file folders found the official records of each inspection and other documentations were accessible and located outside the Program Manager's office. No issues. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of attachment 7 along with information from SABA confirm all employees listed have completed required training. No issues. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: UTDC loss two points regarding penalty amounts during the Progress Report Scoring. Allowed full score because all DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 3#

UT NG Program Evaluation, 2012, page 4information was recorded correctly. Discussed with Program Manager about taking action to increase their civil penalty amounts. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed planned performance description and suggest information needs to be enhanced. No issues or loss of points occurred. 10 General Comments: Info Only = No Points Evaluator Notes: Loss of points occurred in questions A.1 & A.3. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 9 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 4#

UT NG Program Evaluation, 2012, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of their procedures manual entitled, "State of Utah Pipeline Safety Policies and Procedures", revised July, 2012 indicated this item is addressed on page 27. 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes,"State of Utah Pipeline Safety Policies and Procedures",page 27 addressed this item. No issues. 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes,"State of Utah Pipeline Safety Policies and Procedures", page 27 addressed this item. No issues. No areas of concern. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: issues. Yes, a review of State of Utah Pipeline Safety Policies and Procedures manual found this item is addressed on page 26. No 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: issues. 1 1 Yes, a review of State of Utah Pipeline Safety Policies and Procedures manual found this item is addressed on page 26. No 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: issues. 1 1 Yes, a review of State of Utah Pipeline Safety Policies and Procedures manual found this item is addressed on page 26. No 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: issues. Yes, a review of State of Utah Pipeline Safety Policies and Procedures manual found this item is addressed on page 26. No 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 5#

UT NG Program Evaluation, 2012, page 6e. 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, a review of State of Utah Pipeline Safety Policies and Procedures manual indicate these items are addressed and located on page 24. Each inspection unit is risk ranked by each engineer prior to performing the inspection. No issues. 9 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 6#

UT NG Program Evaluation, 2012, 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 (A12) Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 299.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.37 = 520.67 Ratio: A / B 299.00 / 520.67 = 0.57 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 299 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=520.66652 Formula:- Ratio = A/B = 299/520.66652 = 0.57 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: Yes, all inspectors have completed the required OQ & IMP training courses. Three of the four inspectors which includes the Program Manager have successfully attended and completed the Root Cause course. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Al Zadeh has many years of experience in pipeline safety. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, response was provided on August 29, 2012. We reviewed the areas of concern in the letter with the Program Manager to insure improvements have been made to match the comments provided. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 2 2 Evaluator Notes: Yes, PHMSA TQ Seminar was held in Sandy, UT on August 3-4, 2010, 80 individuals were in attendance. UT DC will be hosting a TQ seminar in 2013 at Salt Lake Community College in Sandy, UT. No issues or areas of concern. DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 7#

UT NG Program Evaluation, 2012, page 86 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, a review of files and information indicate all operators werre inspected in accordance to their interval requirements. No issues. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: They use Federal Inspection Forms to conducted their inspections. No issues. 2 2 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 (B7) Yes = 1 No = 0 Evaluator Notes: No cast iron pipelines in the State of Utah. NA 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 (B8) Yes = 1 No = 0 Evaluator Notes: No cast iron pipelines in the State of Utah. NA 1 NA 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 (B9) Yes = 1 No = 0 Evaluator Notes: This is checked annually by UT DC staff members when the operator submits their O & M Plan. This is also listed in their Pipeline Safety Policies and Procedures Manual page 26. They are considering add a separate question to their inspection form to address this item in the future. 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: This is checked annually by UT DC staff member when the operator submits their O & M Plan. This is also listed in their Pipeline Safety Policies and Procedures Manual page 26. They are considering add a separate question to the Federal inspection form to address this item. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This is checked annually by UT DC staff members. A review of file folders found this was completed. This item is also listed in their Pipeline Safety Policies and Procedures Manual page 28. DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 8#

UT NG Program Evaluation, 2012, page 913 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of PHMSA Operator Qualification Database found twenty inspection reports have been uploaded. A review of IMP Database found three inspection reports have been entered. No issues 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this was accomplished via email messages to all intrastate transmission operators. No issues. 1 1 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is reviewed during the inspection visit. This is mentioned in their Pipeline Safety Policies and Procedures Manual page 24. 16 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of PHMSA data base indicate this item is being performed. No issues. 2 2 17 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). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of PHMSA data base indicate this item is being performed. No issues. 2 2 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 be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CY2013. Yes, they inspected Questar Gas Distribution system in CY2012. They are currently scheduling the other operators in 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 be complete by December 2013 2 2 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 9#

UT NG Program Evaluation, 2012, page 10Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this has been completed. No issues. 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this is accomplished via their website and pipeline safety staff members participating in the Utah Pipeline Association and Blue Stake meetings. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 One safety related condition report was filed by Questar on 9/15/2012. Yes, staff members were made aware of the anomaly on Feeder Line #18 South East side of the intersection of SR-193 and Hill Field Road in Layton, UT. No issues. 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this is covered on their inspection review forms. No issues. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, NAPSR survey and other related calls about the pipeline safety program. No issues. 1 1 24 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section. Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 44 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 10#

UT NG Program Evaluation, 2012, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 1 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) 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: Procedures to notify the operator's company officer or offical were described on page 28 of the Pipeline Safety Policies and Procedure manual. However, written procedures to routinely review progress of compliance action taken by the operator has not been established. Therefore, a loss of three points occurred. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 0 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) 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: A review of file folders for Cinnomon Tree Apartments dated March 31, Town of Hildale dated November 6, City of Blanding dated January 2, Summit Gas Gathering dated August 27, Anadarko Petroleum Corporation dated September 13, found compliance letters are not being send to the company officer or official representative. Inspection letters to Questar Company are being sent to the Vice President of the company. This is the third year this item was mentioned in the State Program evaluation letters requesting all correspondence be mailed to the official representative not To Whom It May Concern or Master Meter Operator. Improvement is needed and steps need to be taken to routinely monitor the progress of violations cited, corrected and closed within an established time schedule. A review of City of Nephi and Town of Mona found compliance action was sent to operator on April 11, 2012. However, operator's response letter due July 11, 2012, was not monitored or reviewed by UT DC staff in accordance with their written procedures. The program manager is familiar with imposing civil penalties for repeat violations but no action was taken to describe this item in the 2012 cover lettters or rountinely review with the operator.Therefore, a loss of four points occurred. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, a review of file folders found compliance action issued to Questar Gas Company was being performed and follow up action was monitored correctly. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes, this is addressed in Pipeline Safety Policies and Procedures manual located on page 25. 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, program manager is familiar with imposing civil penalties for repeated violations. Failure to not correct a violation(s) that may result in a fine is being considered by the program manager to be included in all future compliance letters. DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 11#

UT NG Program Evaluation, 2012, page 126 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, Questar Gas Company was issued a civil penalty in amount of $4,500 on June 23, 2011 for failure to mark lines in accordance to 192.614 (c) (5). No issues. 7 General Comments: Info Only = No Points Evaluator Notes: Loss of points occurred in D.1 & D.2. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 15 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 12#

UT NG Program Evaluation, 2012, page 13PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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 described in the State Of Utah Pipeline Safety Policies and Procedures manual located on page 33-34 and Appendix 2, pages 39-44. No issues. 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 No reportable incidents in CY2012. However, they have procedures established to perform onsite investigations. No issues. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) 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: No incidents investigated or reported in CY2012. However, they have procedures to perform incidents in the Pipeline Safety Policies and Procedure manual. No issues. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: NA. No reportable incidents/accidents occurred in CY2012. 1 NA 5 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they have communciated with Western Region office in areas of concern. No issues. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: Yes, this is accomplished at the NAPSR Western Region Meetings. No issues. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 143528862 2012 Natural Gas State Program Evaluation Info Only Info Only Utah Utah Division of Public Utilities, Page: 13#

UT NG Program Evaluation, 2012, page 14No loss of points occurred in this section. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 14#

UT NG Program Evaluation, 2012, page 15PART 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 (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is addressed in Pipeline Safety Policies and Procedures manual page 25 and is reviewed during the standard inspection. 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This is reviewed during the standard inspection review. They use the federal inspection forms. 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is accomplished by their participation in Blue Stakes training and meetings. They promote CGA Best Practices during their review of the operator's O & M manual reviews and inspection visits. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the number of pipeline damages per 1,000 locate request is discussed with Questar Gas Company. Questar is required to submit a quarterly damage report to their agency. A review of the trends on the number of damages in CY2012 from previous years indicate a downward trend. No issues. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occured in this section. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 15#

UT NG Program Evaluation, 2012, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Questar Gas Company Name of State Inspector(s) Observed: Dave Hassell, Pipeline Safety Engineer Location of Inspection: Henefer, Utah Date of Inspection: July 11, 2013 Name of PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Programs Evaluator Notes: This was a construction inspection pertaining to the replacement of an existing pipeline in Henefer, Utah. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, Mr. Justin Withers, System Integrity Supervisor for Questar Gas Company was notified on July 10, 2013. 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the inspector use the federal inspection form to review the construction project. He was observed recording information to a note pad that was entered into the form located in his computer. He was observed checking welding documentation, coating standards, OQ records, construction records and checking Questar Gas Company procedures. No issues. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No areas of concern. Yes, Dave Hassell thoroughly documented the results of his observations and items checked into the inspection report form. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) (F5) Yes = 1 No = 0 Evaluator Notes: Yes, it was observed Dave Hassell checked the construction equipment and other related items necessary for Questar Gas Company employees to perform their work. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes, Questar Gas Company construction records and procedures were checked. North Pipeline Company was the contractor DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 16#

UT NG Program Evaluation, 2012, page 17performing the welding and coating of a newly installed 6" steel pipeline. Contractor welding cards and certification documents on coating the pipeline was checked. No issues. 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, David Hassell has completed all TQ training courses and is knowledgeable of the pipeline safety regulations. No issues. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: Yes, it was observed an oral exit interview was conducted at the end of the day with Mr. Justin Withers and Questar Company Inspector Jerry Holton. Information on the items reviewed and checked were discussed and no violation(s) were found. No issues. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No probable violations were found or noted during the construction field inspection. No issues. 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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 DUNS: 143528862 2012 Natural Gas State Program Evaluation Info Only Info Only Utah Utah Division of Public Utilities, Page: 17#

UT NG Program Evaluation, 2012, page 18A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: This was a field inspection of a newly installed 6" high pressure feeder line in Henefer, UT. The pipeline was not placed in service because the line has not been pigged or pressure tested. Questar Gas Company will be performing a pig run in two weeks and pressure testing the line to 720 PSIG. During the inspection, observed the installation of a pig receiver, sand blasting a section of pipeline to apply a 3M epoxy coating, jeeping a section of the pipeline, and testing the pipeline coating depths. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 18#

UT NG Program Evaluation, 2012, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 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? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 19#

UT NG Program Evaluation, 2012, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 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? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 143528862 2012 Natural Gas State Program Evaluation Utah Utah Division of Public Utilities, Page: 20#