# 2020 VT NG Program Evaluation - vt-2020-gas-program-evaluation (Vermont; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA vt-2020-gas-program-evaluation
- **title:** 2020 VT NG Program Evaluation - vt-2020-gas-program-evaluation (Vermont; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-01
- **effective on:** Not available
- **summary:** 2020 PHMSA natural gas program evaluation for Vermont.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2022-05/vt-2020-gas-program-evaluation.pdf
**body:**

1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for VERMONT DEPARTMENT OF PUBLIC SERVICE Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 1

2020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Vermont Rating: Agency Status: Date of Visit: 09/13/2021 - 09/15/2021 Agency Representative: Mr. William Jordan Director of Engineering PHMSA Representative: Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. June Tierney, Commissioner Agency: Vermont Public Service Department Address: 112 State Street City/State/Zip: Montpelier, Vermont 05620 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 48 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 98 State Rating................................................................................................................................................... 98.0 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: 1a. The information in Attachment 1 of Progress Report seems accurate. 1b. The information in Attachment 2 of Progress Report seems accurate. Verified by inspection activity spreadsheet kept by operator. 1c. The information in Attachment 3 of Progress Report seems accurate. 1d. There were no incidents in CY2020 to record in Attachment 4 of Progress Report. 1e. The information in Attachment 5 of Progress Report seems accurate. 1f. The information in Attachment 6 of Progress Report seems accurate. 1g. The information in Attachment 7 of Progress Report seems accurate. 1h. The information in Attachment 8 of Progress Report seems accurate. 1i. The information in Attachment 10 of progress Report seems accurate. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Reviewed the VTPSD operations procedures and found the pre-inspection procedures found, page 7; inspection procedures found, pages 8 ? 11; and post-inspection procedures found pages 12 -15. There were no issues. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: basis. The written procedures which addresses inspection priorities is found on page 8. Vermont Gas is inspected on an annual 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: The procedure for notifying a company officer is found on page 14; follow-up activities for compliance actions is found on page 13; and need to add procedures regarding closing outstanding probable violation (recommendation). 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: The procedures to receive, record, and respond to operator reports of incidents is located on page 15; procedures to not go on site for an incident investigation are found page 16.DUNS: 809376791 Vermont 2020 Gas State Program Evaluation VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 4

5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the program evaluation. DUNS: 809376791 2020 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See 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 b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: 1. No staff qualified to lead IM inspections. 2. Bill has completed Root Cause Course. 3. Both inspectors are qualified to lead standard, DIMP, OQ, LPG inspections. 4. Matthew has completed CRM course. 5 5 2 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 = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes. The state pipeline safety program manager indicated adequate knowledge of PHMSA program and regulations. He has been in the position as of January 2019. 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part C of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 6

PART D - Program Performance Points(MAX) Score 1 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 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 5 5 Evaluator Notes: Vermont Gas Systems Distr. ? Standard (8/22/18), PA (5/18/17), D&A (4/1/21 & 11/14/16), Construction (10/23/20), OQ (2/11/20 & 5/11/15), DIMP (3/1/17); Vermont Gas Systems Trans. ? Standard (8/17/18), PA (5/18/17), D&A (4/1/21 & 11/14/16), CRM (3/15/18), Construction (7/15/20), OQ(2/11/20 & 5/11/15), IMP (11/27/19); Blue Flame Gas Company, Inc. ? Standard (1/12/21 & 11/15/19 & 12/30/16), PA (9/4/19), OQ (2/12/20 & 6/12/15), DIMP (9/23/20 ? no previous inspection); Bournes Propane ? Standard (12/10/18, 1/12/21, 7/9/21), PA (5/6/19), OQ (8/21/20 & 7/8/15), DIMP (no 2020 inspection, 9/8/21, 11/16/15); Dead River Company ? Standard (3/18/21 & 12/30/16), PA (9/4/19), OQ (11/7/20 & 11/14/15), DIMP (10/21/20 & 12/4/15); Eastern Propane Oil ? Standard (4/5/21 & 1/17/17), PA (9/4/19), OQ (4/22/2020 & 9/18/15), DIMP (4/24/16, not jurisdictional 7/21 ? not confirmed ? scheduled 10/5/21); Freds Plumbling and Heating ? Standard (4/5/18), PA (9/4/19), OQ (8/25/20 & 7/10/15), DIMP (4/19/21 & 11/20/15 did not meet interval); Fyles Brothers, Inc. ? Standard (3/10/20 & 3/29/18, 11/28/17), PA (5/9/19), OQ (9/3/20 & 9/10/15), DIMP (11/11/20 & 11/11/15); Haskins Gas Service ? Standard (6/17/21 & 8/11/17), PA (7/2/19), OQ (6/25/20 & 9/16/15), DIMP (10/30/21 & 11/23/15 did not meet interval), Highland Fuel Delivery dba Irving Energy Distribution Marketing ? Standard (3/4/20 Records/Field & no previous inspection), PA (9/4/19), OQ (10/15/20 & 3/20/16), DIMP (4/19/21 & 12/2/15 did not meet interval); HOP Energy, LLC (Keyser Energy) ? Standard (6/5/18), PA (5/29/19), OQ (6/5/18), DIMP (4/18/18); Jack F. Corse Co. ? Standard ( 8/17/21 Records/Field & 4/6/18, 9/15/17), PA (7/29/19), OQ (8/8/17), DIMP (12/22/20 & 12/21/15); Jackman Fuels, Inc. - Standard (9/2/20 Records/Field & 4/6/18, 12/5/17), PA (9/4/19), OQ (9/2/20 & 9/14/15), DIMP (12/23/20 & 12/21/15); NGL Partners of Oklahoma (Osterman Propane) ? Standard (3/11-13/20 Records/Field, 5/8/18, 6/4/18), PA (5/9/19), OQ (8/11/20 & 6/8/15), DIMP (8/25/21 & 12/10/15 did not meet interval); Proctor Gas - Standard (3/3/21 & 9/14/16), PA (9/4/19), OQ (5/7/20 & 9/24/15), DIMP (7/20/21 & 12/7/15 did not meet interval); Rymes Heating Oils, Inc. ? Standard (1/8/21 & 12/30/16), PA ( 9/4/19), OQ ( 9/28/20 & 9/28/15), DIMP (12/9/15, no longer jurisdictional ? transferred to Suburban Propane Co. H on 2/10/21); Surburban Propane Co. H - Standard (5/17/21 & 8/24/17), PA ( 9/4/19), OQ (9/4/20 & 9/22/15), DIMP (5/10/18); UGI Corp. dba Amerigas - Standard (7/2/21 & 8/8/17), PA (9/4/19), OQ (4/22/20 & 7/1/15), DIMP (4/26/21 & 12/3/15 did not meet interval). Bill was not qualified to lead DIMP inspection until 8/2020. 2 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. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 9 Evaluator Notes: Reviewed inspection reports: (1) Vermont Gas Systems Distr. ? Construction (10/23/20), OQ (2/11/20); (2) Blue Flame Gas Company, Inc. ? OQ (2/12/20), DIMP (9/23/20); (3) Bournes Propane - OQ (8/21/20); (4) Dead River Company (10/7/20 ? still open ? email sent to operator on 10/7/20), DIMP (10/21/20 ? Still open ? will complete when records reviewed); (5) DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 7

Eastern Propane Oil ? OQ (4/22/2020); (6) Freds Plumbling and Heating - OQ (8/25/20); (7) Fyles Brothers, Inc. - Standard (3/10/20 Field/Records ? email sent on 6/10/2020 ? still open), OQ (9/3/20), DIMP (11/11/20); (6) Haskins Gas Service ? OQ (6/25/20 ? formed not filled out completely); (7) Highland Fuel Delivery dba Irving Energy Distribution Marketing ? Standard (3/4/20 Records/Field ? operator sent email no longer jurisdictional ? not confirmed); (8) Jackman Fuels, Inc. - Standard (9/2/20 Records/Field ? will breakup system to become non-jurisdictional ? not confirmed), OQ (9/2/20), DIMP (12/23/20 ? still open); (9) NGL Partners of Oklahoma (Osterman Propane) ? Standard (3/11-13/20 Records/Field ? form not filled out completely), OQ (8/11/20); (10) Proctor Gas - OQ (5/7/20); (11) Rymes Heating Oils, Inc. - OQ ( 9/28/20); (12) Surburban Propane Co. H - OQ (9/4/20); (13) UGI Corp. dba Amerigas - OQ (4/22/20). 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Reviewed OQ inspections: (1) Vermont Gas Systems Distr. ? OQ (2/11/20); (2) Blue Flame Gas Company, Inc. ? OQ (2/12/20); (3) Bournes Propane - OQ (8/21/20); (4) Dead River Company - OQ (11/7/20 ? still open ? email sent to operator on 11/7/20); (5) Eastern Propane Oil ? OQ (4/22/2020); (6) Freds Plumbling and Heating - OQ (8/25/20); (7) Fyles Brothers, Inc. - OQ (9/3/20); (6) Haskins Gas Service ? OQ (6/25/20 ? formed not filled out completely); (7) Highland Fuel Delivery dba Irving Energy Distribution Marketing ? OQ (10/15/20 & 3/20/16); (8) Jackman Fuels, Inc. - OQ (9/2/20); (9) NGL Partners of Oklahoma (Osterman Propane) ? OQ (8/11/20); (10) Proctor Gas - OQ (5/7/20); (11) Rymes Heating Oils, Inc. - OQ ( 9/28/20); (12) Surburban Propane Co. H - OQ (9/4/20); and (13) UGI Corp. dba Amerigas - OQ (4/22/20). There were no issues. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 Evaluator Notes: Reviewed DIMP inspections: (1) Blue Flame Gas Company, Inc. ? DIMP (9/23/20); (2) Dead River Company - DIMP (10/21/20 ? Still open ? will complete when records reviewed); (3) Fyles Brothers, Inc. - DIMP (11/11/20); and (4) Jackman Fuels, Inc. - DIMP (12/23/20 ? still open). Vermont Gas is the largest operator in the State and have different types of inspections performed annually. There is no low pressure distribution in the State. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; 2 2 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 8

d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: 5a. & 5b. N/A ? no cast iron pipe in Vermont. 5c. & 5d ? Meet with Vermont Gas on an annual basis to discuss excavation damage and third- party damage. 5e. ? Vermont Gas met with the State to discuss their boring procedures on 12/7/2020. 5f. ? Vermont has no operators with low pressure distribution systems. 5g. ? The VT DPS has communicated with Vermont Gas on inside regulators by email on August 13, 2020. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State is communicated the advisory bulletins to the operators by email. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 9 resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: VT DPS did not send out any compliance actions in CY 2020. All inspections that had identified issues were communicated to the operator as concerns. These concerns were emailed to the operator and a response is required from the operator. There still some open reports at the time of the evaluation. The VT DPS felt this was most efficient way to handle safety issues during the COVID time. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? 10 10 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 9

c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did 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? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: There were no reportable incidents in CY2020. 9 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 = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: during the evaluation. The VT DPS did not have to respond to Chair's letter for the CY2019 program evaluation. The State received a perfect score 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: The VT DPS had the most recent pipeline safety seminar on April 27 ? 29, 2021. This was part of the New England Pipeline Safety Representatives Seminar. 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Info Only Info Only The State has not confirmed with Vermont Gas that they have submitted information to NPMS database for CY2020. 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The VT DPS shares information through its States' website. Did a brief tour of website during the program evaluation. 13 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: VT DPS did not have any open SRCR's as of CY2020. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: DUNS: 809376791 2020 Gas State Program Evaluation 1 1 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 10

VT DPS has been responsive to information requests from NAPSR and/or PHMSA. There were no responses required through WMS. 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: VT DPS has not issued any waivers/special permits for its operators. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. Was able to access all pertinent files electronically during the program evaluation. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: VT DPS has submitted into State Inspection Day Calculation and updated the data. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed performance metrics with VT DPS and found no trends that could not be satisfactorily explained by the program manager. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Vermont Gas has a person responsible for Pipeline Safety Management Systems within their organization. Info Only Info Only 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The following issues were identified in Part D of the evaluation: (1) inspector did not fill out inspection forms completely for two inspections performed in 2020; (2) VT DPS classified all unsatisfactory on the inspection forms as concerns with some issues still being open; and (3) VT DPS did not confirm with Vermont Gas they had submitted information to NPMS database for CT2020. Total points scored for this section: 48 Total possible points for this section: 50 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Operator: Vermont Gas Systems Inspector: Matt Kiegler Location: Blueberry Lane, Jerico, VT Date: September 16, 2021 PHMSA Rep.: Clint Stephens Info Only Info Only The operator was installing 2" plastic main and installing EFV during the installation. Observed the operator perform fusion on main pipeline. Inspector reviewed fusion procedures and operator's OQ records. 2 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. The inspector used the "Main Installation Checklist" as a guide for the inspection. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: The inspector reviewed plastic pipe fusion procedures, OQ records, and observed the operator butt fuse plastic pipe and install service line with tracer wire. The inspection was of adequate length to properly perform the inspection. 4 From your observation 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: From my observation the inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Construction project was not complete during the field evaluation, so an exit interview was not performed at that time. DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 12

6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: The inspection was performed in a safe, positive, and constructive manner. The inspector observed plastic pipe fusion, installation of plastic main/service line with tracer wire. The inspector did an adequate job performing the inspection. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 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: VT DPS has reviewed Operator Annual report for accuracy and analyzed data for trends and operator issues since 2011. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Vermont Gas has tracked data on excavators who have repeatedly violated one-call laws and damaged their facilities and that information has been discussed with the VT DPS. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Yes. The state has reviewed the operator's annual report pertaining to Part D ? Excavation Damage. The information is complete and accurate with root cause numbers. 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 14

Yes. The VT DPS has collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests. They have identified which stakeholder group is causing the highest number of damages to the pipelines. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: VT DPS is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809376791 2020 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 16
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