# 2009 WA NG Program Evaluation - wa2009ngprogramevaluation (Washington; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA wa2009ngprogramevaluation
- **title:** 2009 WA NG Program Evaluation - wa2009ngprogramevaluation (Washington; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-01-01
- **effective on:** Not available
- **summary:** 2009 PHMSA natural gas program evaluation for Washington.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for Washington Utilities and Transportation Commission Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 1

2009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Washington Rating: Agency Status: Date of Visit: 04/19/2010 - 04/21/2010 Agency Representative: David Lykken, Pipeline Safety Director Steven King, Director Safety & Consumer Protection Joe Subsits, Chief Engineer Jim Fernald, Operations Manager Alan Lundeen, Policy & Outreach Manager PHMSA Representative: Glynn Blanton, DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Jeffrey D. Goltz, Chairman Agency: Wasington Utilities and Transportation Commission Address: 1300 S. Evergreen Park Drive SW, PO Box 47250 City/State/Zip: Olympia, WA 98504-7250 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 25 24.3 C Interstate Agent States 6 6 D Incident Investigations 7 7 E Damage Prevention Initiatives 9 9 F Field Inspection 12 10 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 107 104.3 State Rating................................................................................................................................................... 97.5 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 2

PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: WUTC has distribution authority over 26 private, 3 municipal, 15 master meter, 2 LPG, 1 LNG, 3 hydrogen and 1 Bio-gas pipelines. On the transmission jurisdication authority it has responsible for 10 intrastate, 12 interstate and 1 liquified natural gas facility and pipelines. A review of all inspection units, activities, records, personnel, and compliance requirements found the information to be in compliance. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 SLR Notes: Incident reporting is required under WUTC's rule 480-93-200, section 1. The telephone number for reporting is 1-888-321-9146. 1 1 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes, the T&Q seminar was held in Portland, OR on June 17-18, 2009. This was a cooperative effort between Oregon, Washington and Idaho to sponsor this seminar to help provide a central location for the operators in their states to attend this meeting. File folder did not contain list of attendees at the meeting. However, this information was requested during the evaluation review from Michael Thompson's office and was provided and filed in file folder by David Lykken. A majority of the operators located in Washington State did attend the seminar. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: Yes, I reviewed WUTC's Pipeline Safety Data Base with David Lykken. This program is location on the network drive and can be assessed by field personnel via VPN. File folders and information provided during the review were well organized in individual file folders. I reviewed the record center location where all these files are maintained and it was in a security location and fire protected. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, David Lykken has a good working knowledge about documents that need to be submitted. He was successful in logging-in to FedStar and demonstrated his abilities to use the Standards Library program. Information on financial dollars spend by WUTC on the pipeline safety program is entered by the WUTC accounting people and David Lykken reviews and submits the final documents. All documents are reviewed before being submitted into the Annual Certification and Year End Payment Request. David Lykken was promoted and moved into the Program Manager's position in November, 2009. He started his career with the WUTC in 2000 and has over10 years of experience in pipeline safety serving as Chief Engineer for 6 years. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 SLR Notes: DUNS: 088967570 2009 Natural Gas State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 3

No response necessary. Letter sent to the WUTC Chairman on December 21, 2009 did not required a response. 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: No action was required by WUTC because the letter to the Chairman did not describe any items of concern. 1 1 Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: Yes, all WUTC pipeline safety engineers have completed the three year requirement courses except Stephanie Zuehlke who has completed six T&Q courses and under the three year time schedule. She completed course PL3291 in 09/2009 and scheduled to attend the remaining courses in 2010. Currently, she is attending the OQ seminar in Denver this week, pigging class in June & ECDA class in Sept, 2010. 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: On October 13, 2009 staff attended a Shoring/Excavation Safety class conducted by the state Labor & Industry Office. All Engineers except one attended the training. Listed below are the individuals that attended: Kuang Chu, Lex Vinsel, Alan Lundeen, Stephanie Zuehlke, Scott Rukke, Jim Fernald, Anne Soiza and Al Jones. Stephanie Zuehlke also attended Hazwoper training in January 12-16, 2009. For Operators: None. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Key staff attended the Citizens Committee on Pipeline Safety meetings in part to provide educate to members on pipeline safety related issues and general pipeline 101 information. Info Only Info Only SLR Notes: 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: Yes, all lead and non-lead engineers have completed the required T&Q courses and computer based training before conducting OQ inspections. 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 SLR Notes: Yes, Joe Subsits, Scott Rukke, Al Jones, Chu Kuang are the lead engineers and have completed all courses. 1 1 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 5 5 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): Ratio: A / B DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 4

If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 SLR Notes: five points in this category. A. 636.14 total inspection person days: B: (220 x 6.36=1399.2) A/B= 636.14/1399.2= 0.4546 meets the larger amount of .38 requirement for an award of 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: No. However, if approval is granted by State Legislature next year, 2011. They will grow the program by one or two engineers to assume enforcement authority for damage prevention. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: No comments or observations noted. Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 5

PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) 6.5 5.75 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: a: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 14, 15 & 16 address this item. b: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 22. c: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 17. d: Needs Improvement, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 31 (Under development). A placeholder has been established but information was not completed on Damage Prevention. e: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 27 (Operator Training & Technical Assistance) ? Has been developed and the effective date is Feb. 1, 2010. This was one of two items mentioned in Tom' Finch's letter to program manager. f: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 21. g: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 20 h: Needs Improvement, WUTC Pipeline Safety Section Policy & Procedures Manual, Section 26 (Under development). A placeholder has been established but not complete with information on follow-up. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Yes, WUTC Pipeline Safety Section Policy & Procedures Manual and data base program includes these items. Each inspection is determined by a risk ranking method and not to exceed three years. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: Yes. WUTC has identified 15 master meter operators to be inspected during calendar year 2010 to meet their procedures for Prioritizing Operator Inspections in accordance to Section 13. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 SLR Notes: Yes. A review of the inspection forms indicated all items in the federal inspection document match their forms. 1 1 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 6

Yes = 1 No = 0 SLR Notes: used by staff members. Yes, WUTC has included WUTC's commission rules with the federal regulations on their inspection forms. The form was found to be complete and being 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, two safety related reports were submitted and followed up on by staff members in 2009. The company and locations are Cascade Natural Gas Corporation at 2009 Lewis River Road in Cowlitz County on 2/28/09 and Cascade Natural Gas Corporation on R15 Jones Road in Sedro Woolley on 12/2/09. The follow-ups were performed by Al Jones and Patricia Johnson. I reviewed the file and reports and found them to be complete and accurate. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence .5 .5 of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Yes, the State of Washington does not have cast-iron pipelines. All cast-iron was removed by the natural gas distribution operators and verified by staff members in July, 2007. However, this item is in their inspection review and check list. 8 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) Previous Question B.8 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, the State of Washington does not have cast-iron pipelines. All cast-iron was removed by the natural gas operators and verified by WUTC staff members in July, 2007. However, this item is in their inspection review and check list. 9 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, WUTC has a state rule, WAC 480-93-186 Leak Evaluation, that address this requirement and it is included in their inspection form. 10 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? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: Yes, this information is covered in the standard inspection report for intrastate gas distribution listed under item 100. A review of the inspection report for the system of Pullman/Clarkston District on 8/27-29/09 indicated this information was checked. Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, A review of the probable violations cited against Avista Utilities Corporation on June 7 and June 21-23, 2009 was checked. The documentation was followed in accordance with their procedures. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this information is completed and described in WUTC Pipeline Safety Policy & Procedures Manual in Section 34, Safety & Consumer Protection Division Compliance & Enforcement Manual. 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 DUNS: 088967570 2009 Natural Gas State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 7

Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this information is completed and described in WUTC Pipeline Safety Policy & Procedures in Section 34, Safety & Consumer Protection Division Compliance & Enforcement Manual, pages 49 thru 65. 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, this is information is located in the WUTC "Project Tracking System". The Pipeline Safety Policy & Procedures section 25 identifies this process. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: Yes. They do issue compliance action in the form of either accepting the operators response to their letter on the violations found or may offer a proposed settlement before going to a formal complaint. 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, WUTC Pipeline Safety Policy & Procedures in Section 26, Compliance Follow-up Inspection is under development but they do perform this requirement via the standard inspection guidelines. Section 16 states, "Review the company's response. If appropriate, schedule a follow-up inspection to conduct field verification." 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 SLR Notes: Yes, WUTC requested a formal complaint and action was taken against the City of Enumclaw (City) on August 24, 2009. The Commission issued a complaint against the City for 651 violations of the Commission's rules and a maximum penalty of $11 million. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, City of Enumclaw. Letter was sent to the Mayor pertaining to the areas of non-compliance. A formal hearing was conducted on June 25, 2009. A settlement was proposed and entered into by the City. The case was closed on August 24, 2009. 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, a review of the letter sent to the Mayor of the City of Enumclaw indicated all compliance actions were being sent to the manager of the city. All correspondence to each city Mayor or Manager includes a copy of the letter to each council members. All compliance letters to private companies go to the President or Vice-President Representative. 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Enforcement Manual. Yes, this information is described in WUTC's Pipeline Safety Policy & Procedures in Section 34, Safety & Consumer Protection Division Compliance & Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 DUNS: 088967570 2009 Natural Gas State Program Evaluation 1 NA Washington Washington Utilities and Transportation Commission, Page: 8

Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 24.25 Total possible points for this section: 25 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 9

PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: requirement. Yes, they are using the federal documents. I also reviewed the inspection performed on Puget Sound Energy on July 13, 2009 by Al Jones to verify this 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, this information was well documented and demonstrated the inspection units were reviewed in accordance with "PHMSA directed inspection plan". 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: Yes, information is submitted by WUTC to PHMSA within thirty days as provided in their "Project Tracking System". 1 1 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 1 SLR Notes: Yes, per the letter of concerns pertaining to Cascada Natural Gas-Kelso-Beaver Pipeline Interstate. The inspection was conducted on June 29-July 3, 2009. Another example, the inspection performed on TransCanada's GTN System on August 24-27 and September 8-11, 2009. 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: No imminent safety concerns were reported in 2009. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: Yes, information is submitted by WUTC to PHMSA within thirty days as provided in their "Project Tracking System". 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this information is submitted by WUTC along with the federal reporting form. 1 1 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 10

PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, they follow their written procedures pertaining to working with PHMSA in cases involving an incident. I reviewed the Williams Gas Pipeline incident that occurred on 1/08/09. The report and file contained information shared with PHMSA about the pin leak on the 30 inch girth weld that was found and corrected. I reviewed the Puget Sound Energy-King County East incident. This incident occurred when a contractor excavated next to the 6 inch high pressure pipeline and damaged a 1 1/4 inch stub. All information reviewed indicated state personnel are following the procedures for Federal/State cooperation regarding incidents. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 .5 .5 SLR Notes: Yes, David Lykken and Joe Subsits response, "the memorandum of understanding is located in the Guidelines for States Participating in the Pipeline Safety". Each WUTC staff member has a copy of the 2009 Guidelines for States Participating in the Pipeline Safety Program in their office. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, all six federally required incident reports were recorded and maintained by WUTC. Additionally, WUTC had 97 state reportable incidents in calendar year 2009. WUTC requires each operator to report leaks and damages that occur on their facilities to their agency. This requirement is found in WUTC rule WAC 480-93-200 "Reporting Requirements". 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. Onsite investigation was not performed on Cascade Natural Gas in Yakima County, Cascade Natural Gas in Bremerton and Puget Sound Energy in King County due to the circumstances of the incidents. Category D and H. 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Information reviewed in the files and folders indicate the investigations were thorough and conclusive to the findings of fact. 2 2 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, no enforcement action was required by WUTC on the gas incidents that occurred in 2009. However, they have taken action against Cascade Natural Gas Corporation on the safety related reporting requirement pertaining to the overpressure event that occurred on Jones Road and east Birch Lane on 12/2/09. 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: WUTC has been responding to the PHMSA Western Region within ten days of an accident or information pertaining to DOT Form 7100. (Information provided by PHMSA Western Region office) Per our Accident Incident Coordinator Peter Katchmar - "I would answer a resounding yes for both questions D.6 & D.7". DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 11

8 Part D: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 12

PART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. This item was mentioned in the 2008 state evaluation and corrective action letter to David Lykken. Action was taken to correct this item per David Lykken letter dated December 30, 2009. A review of WUTC Form "V": Intra Gas, Procedure and Plan Review, section 297 shows this item is included and meets this requirement. 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? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes, this requirement is located on WUTC inspection form C. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Yes, WUTC staff members are encouraging stakeholder groups at local and regional meetings to use the Common Ground Alliance Best Practices document as a means to prevention damages from occurring to underground facilities. Alan Lundeen is working closely with several stakeholder groups in proposing changes in their state damage prevention law to have WUTC be the enforcement agency. 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? New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes, WUTC has a State Damage Prevention Statistics Mandatory Reporting form requirement for those operators under their commission's jurisdiction to report damages. They have recently implemented the Virtual DIRT program. One company is reporting this information into Virtual DIRT and additional companies will be using the program in the future. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes, this item is reviewed by staff members on their inspection visits and available on the federal standard inspection form. This review is found on WUTC's Form C Intrastate Gas Distribution, Section 36-40. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 088967570 2009 Natural Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: City of Ellensburg Energy Service Department & City of Enumclaw Gas Department Name of State Inspector(s) Observed: Patti Johnson, Pipeline Safety Engineer Location of Inspection: Ellensburg & Encumclaw, WA Date of Inspection: May 19-20, 2010 Name of PHMSA Representative: Glynn Blanton, PHMSA State Programs SLR Notes: Patti Johnson was observed two days performing random inspections of two natural gas distribution operators. Gas pipeline operators are required by WAC 480-93-160 to notify the Commission 45 days prior to beginning construction of transmission pipeline equal to or greater than 100 feet in length. This allows Pipeline Safety Staff (PSS) time to carefully review company plans and to confer with the company regarding any potential issues. During the construction phase, operators are required to submit their daily construction schedules no later than 10:00 AM the day construction takes place. Generally, the operator emails the construction schedule to the PSS and, based on the nature of the construction and staff time, an engineer may conduct an inspection of the construction site. On May 19th, the following individuals were present during the first field inspection performed in Ellensburg, WA. Mr. Steve Prue, Gas Engineer & Mr. Rodney Paul, Welder, Mr. Mike Helgeson & Mr. Marcell Martinez. On May 20th, the following individuals were present during the second field inspection performed at the gate station on Auburn Academy Way & Enumclaw Highway in Encumclaw, WA. Mr. Ed Hawthorne, Gas Manager and Mark VanWergien, Gas Superintendent. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 1 1 SLR Notes: inspection period. Yes, each operator was notified prior to the inspection by a telephone call from Patti Johnson and their representatives were present during the entire 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 2 0 SLR Notes: The WUTC Random Inspection Form - Gas Distribution Revised January, 2007, was given to this observer at the start of the first inspection. The inspector used a note pad to record information from the operator on items asked and reviewed during the two day inspection visits. The form was not used as a guide to perform the inspection. Information on items checked and reviewed was transferred from the note pad to an electronic version of the form at the end of the day or inspection visits. The form lacks a reference regulation or rule next to the items checked by the inspector in determining areas of compliance or non- compliance. Suggest the WUTC Random Inspection form be updated to include the federal regulations and WUTC rules in items checked and reviewed by the inspector. Two points are being deducted due to failure of inspector to indicate each item on the form was "inspected or not applicable "as a guide during the inspections performed. 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: Yes. Patti John
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