# 2014 WA NG Program Evaluation - wa2014ngprogramevaluation (Washington; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA wa2014ngprogramevaluation
- **title:** 2014 WA NG Program Evaluation - wa2014ngprogramevaluation (Washington; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-01-01
- **effective on:** Not available
- **summary:** 2014 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 2014 Gas State Program Evaluation for Washington Utilities and Transportation Commission Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 1

2014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Washington Rating: Agency Status: Date of Visit: Agency Representative: PHMSA Representative: Commission Chairman to whom follow up letter is to be sent: Name/Title: Agency: Address: City/State/Zip: 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 2014 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9.5 B Program Inspection Procedures 13 13 C Program Performance 43 42 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 7 7 I 60106 Agreement State (If Applicable) 0 0 TOTALS 119 117.5 State Rating................................................................................................................................................... 98.7 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Issues found. The tracking for this information is done in their data base and uses information input on the inspectors time sheets. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found. The operators listed on the progress report are basically the same as found on the PHMSA Pipeline Data Mart. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, incidents reported on the progress report were match to those listed on the PHMSA Pipeline Data Mart. The WUTC also listed the Plymouth, WA. LNG incident that was not listed on the PHMSA Pipeline Data Mart because it is not closed yet. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WUTC claimed zero compliance actions on the progress report and had actually sent out 12 compliance action letters to natural gas operators in 2014. 0.5 points deducted. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the WUTC pipeline safety program files were well organized and accessible. Both electronic and hard copies. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, it was verified on the SABA system during the review. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are updated annually. 1 1 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 3

Note; They adopted civil penalty levels of $200,000.00 to $2,000,000.00 in October of 2014. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC was specific in describing their accomplishments for 2014. 1 1 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question A-5, The WUTC claimed zero compliance actions on the progress report and had actually sent out 12 compliance action letters to natural gas operators in 2014. 0.5 points was deducted from the natural gas program. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC procedure can be found in Sections, 14,15 and 16 of their manual. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC procedure can be found in Sections, 22 and 36 of their manual. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC procedure can be found in Section, 17 of their manual. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC procedure can be found in Sections, 15,16 and 31 of their manual. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No onsite operator training was conducted in 2014. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC procedure can be found in Section, 21 of their manual. 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 5

c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: After review of the WUTC procedures manual there were no issues found. 8 General Comments: Info Only = No Points Evaluator Notes: (Pre, During and Post) Info Only Info Only The WUTC has good procedures but needs to add the specific details that will be required to meet the inspection activities, Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 654.66 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.32 = 1389.30 Ratio: A / B 654.66 / 1389.30 = 0.47 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes, the WUTC had a ratio of .47 for natural gas 2014. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 4 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: The WUTC failed to verify that all inspectors obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. An inspector did NOT complete all required TQ training before conducting inspections as lead. An inspector was assigned as lead on (4) standard inspections and (7) OQ inspections before completing the required TQ training. Qualified inspectors were in attendance at all the standard inspections and all but (3) of the OQ inspections. The same inspector was involved in all instances. One point was deducted from the natural gas program. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Dave Lykken has been in the program for many years and has a great knowledge of the PHMSA program and the regulations. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No response was necessary for the 2013 evaluation. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 2 2 Yes = 2 No = 0 Evaluator Notes: Yes, the WUTC holds it's PHMSA TQ seminars with the states of Oregon and Idaho. Idaho hosted one on 12/5/12, and the WUTC hosted one on 5/13/15 in the Tri Cities area of Washington. DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 7

6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: The WUTC established the time intervals for OQ Programs about 4 years ago and have set an interval of 5 years. So, the inspections done in 2014 will show a longer than five year time span due to it being the first round since the procedure was developed. A protocol 9 form is completed with each standard inspection. All Standard inspection dates meet the time interval requirements established in their procedures. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC uses the federal inspection forms and adds their state rules. 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 Yes = 1 No = 0 Evaluator Notes: No cast iron 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 Yes = 1 No = 0 Evaluator Notes: No cast iron 1 NA 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the WUTC has added a question under their WAC -180-93-106 (leak evaluation) to the federal form. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the WUTC has added questions to the federal form under their WAC. Questions 116,120 and 130. The operators now use DIRT in Washington to help track and report damages. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the WUTC uses and verifies the mileage information from the annual report. They do not use the leak data because that information is collected directly from the operators in greater detail and used in their risk assessment and inspection scheduling. DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 8

13 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 Evaluator Notes: Yes, No issues found. Yes = 2 No = 0 Needs Improvement = 1 Verified input Gas IMP - inspections for Georgia Pacific, Avista, NW Natural and BP West Coast. Verified many OQ inspection. All were done quickly after completion. k 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: (B) Yes, the WUTC has added a question to the federal form to help accomplish this. Question number 1 (49USC 60132, Section 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the WUTC completes a D&A with each standard inspection. (Only one for each operator, not each unit) 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC does a OQ Plan inspection every five years and does a protocol 9 form with every standard inspection. The operators are required by state rule to submit all plan updates or changes to the WUTC. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC does IMP plan inspections every five years, and monitors assessments, tests and remedial actions using reports submitted by the operators on a regular basis. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WUTC completed all DIMP inspections in 2014 and has started the process of revisiting the operators to monitor progress. DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 9

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 have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the WUTC does a PA inspection of each operator every five years and has also done effectiveness reviews. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC has a web site that lists all inspections, reports and compliance actions that is available to the public. 21 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: No SRC's in 2014. 1 NA 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC has a materials defect report that operators are required by state rules to submit. They are also required to submit all planned pipe replacement projects with justification, (risk ranked) every two years. 23 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Reviewed an example of a survey conducted where Dave Lykken provided information to the NAPSR. 24 If the State has issued any waivers/special permits for any operator, has the state verified 0 0 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: The WUTC has no waivers on the books at this time. They do have an operator who is persuing a waiver for design on a planned LNG facility. 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: Yes, Dave Lykken attended the NAPSR National Meeting. 0 0 26 Discussion on State Program Performance Metrics found on Stakeholder Communication site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points Evaluator Notes: DUNS: 088967570 2014 Gas State Program Evaluation 0 0 Washington Washington Utilities and Transportation Commission, Page: 10

Yes, the WUTC has their own performance metrics for the program. 27 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The WUTC failed to verify that all inspectors obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. An inspector did NOT complete all required TQ training before conducting inspections as lead. An inspector was assigned as lead on (4) standard inspections and (7) OQ inspections before completing the required TQ training. Qualified inspectors were in attendance at all the standard inspections and all but (3) of the OQ inspections. The same inspector was involved in all instances. One point was deducted from the natural gas program. Total points scored for this section: 42 Total possible points for this section: 43 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 11

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: Yes, the procedures can be found in the WUTC's manual in Sections 25,26 and 34. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. 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: Yes, the WUTC does this using what they call the "Tracker System", and it is reviewed by the Chief Engineer on an ongoing basis. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, 2014 inspection files were reviewed and all probable violations where found in 12 compliance action letters sent to the natural gas operators by the WUTC. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, the WUTC has policy and procedures in place to insure all parties are given reasonable due process. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, in conversation with Dave Lykken, Program Director and Joe Subsits, Chief Engineer they both showed they were very knowledgeable of the enforcement process in their state. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No civil penalties were issued in 2014, but they did use this authority in 2013. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 088967570 2014 Gas State Program Evaluation Info Only Info Only Washington Washington Utilities and Transportation Commission, Page: 12

Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 13

PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC has procedures that cover from notification to completion including the completion of the 30day reports. Their procedures can be found in Sections 10,19,and 20 of their manual. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes, the WUTC procedures can be found in Sections 10 and 19 of their manual. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, each incident was well documented, including contact names, dates, events and evidence. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, no issues found. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: None were initiated in 2014, but they were in 2013. 1 1 6 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC is also an interstate agent and worked very closely with the PHMSA Western Region by participating in interstate incident investigations. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 DUNS: 088967570 2014 Gas State Program Evaluation 1 1 Washington Washington Utilities and Transportation Commission, Page: 14

Evaluator Notes: reviewed. Yes, the WUTC, "State, State of the State" report that was shared at the 2014 NAPSR Western Region meeting was 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 15

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the WUTC has added a question to the attachment to the federal inspection form to address this. Question number .311 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC as part of their attachment to the federal inspection form covers this in questions 107-114 for distribution and in questions 93-107 for Transmission. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WUTC has a dedicated position, (Damage Prevention Coordinator) the does the greatest majority of the programs out reach, education and presentations. They also have a seat on the State's Dig Law Safety Committee. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the WUTC uses information from the State's DIRT system and information from the PHMSA annual report. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 16

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Puget Sound Energy PSE Name of State Inspector(s) Observed: DAve Collum Location of Inspection: 6500 Ursula Place, Seattle, WA Date of Inspection: 9/24/2015 Name of PHMSA Representative: Michael Thompson Evaluator Notes: Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes the operator was given notice of the inspection and had representatives from their compliance division and field personnel on site during the inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the inspector used an appropriate inspection form that covered both the questions on the federal form and their own regulations to guide and track the inspection. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector kept notes on the inspection form and in a notebook to document the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, the inspector checked all equipment that was used during the inspection for calibration and compliance. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: No issues 2 2 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 17

7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the inspector showed he had adequate knowledge of the safety program and the regulations during the inspection. 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) Yes = 1 No = 0 Evaluator Notes: The inspection was not completed on this date, but the inspector did hold an interview with the operators representatives at the end of the day to cover issues and findings. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: No probable violations were found during this portion of the inspection. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 18

D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 19

PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, No Issues. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC uses a tracking sheet. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, all were submitted well within the 60 day window. 1 1 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, no issues. 1 1 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: None necessary in 2014. 1 1 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WUTC has set a 45 day bench mark for themselves. 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes 1 1 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: In a telephone conversation with Chris Hoidal, Director of the Western Region, PHMSA he stated that he had no issues with the WUTC as an interstate agent and that they were doing a good job. Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 20

PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 088967570 2014 Gas State Program Evaluation Washington Washington Utilities and Transportation Commission, Page: 21
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