PHMSA wv2013ngprogramevaluation - 2013 WV NG Program Evaluation - wv2013ngprogramevaluation (West Virginia; Natural Gas State Program Evaluation) | Regulus

WV NG Program Evaluation, 2013, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2013 Natural Gas State Program Evaluation for PUBLIC SERVICE COMMISSION OF WEST VIRGINIA 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: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 1#

WV NG Program Evaluation, 2013, page 22013 Natural Gas State Program Evaluation -- CY 2013 Natural Gas State Agency: West Virginia Rating: Agency Status: Date of Visit: 09/08/2014 - 09/12/2014 Agency Representative: David Hippchen, Manager, Gas Pipeline Safety Ed Clarkson, Technical Analyst PHMSA Representative: Glynn Blanton, DOT PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Michael A. Albert, Chairman Agency: Public Service Commission of West Virginia Address: 201 Brooks Street, PO Box 812 City/State/Zip: Charleston, West Virginia 25323 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 2013 (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 10 B Program Inspection Procedures 15 15 C Program Performance 46 43 D Compliance Activities 15 15 E Incident Investigations 9 9 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 115 112 State Rating................................................................................................................................................... 97.4 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 2#

WV NG Program Evaluation, 2013, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of progress report Attachment 1 found information was correctly entered with the jurisdictional authority over all natural gas facilities. Four new distribution operators were added to the list. They were Hometown Gas, A.V. Company, Ajax Pipeline Company and C and J Wells. No areas of concern. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A review of Attachment 2 found information to be correct. The number of inspection days is determined by time sheets submitted by the Engineer. The time is posted in a data base showing an Inspection Days Code for each type of inspection. Total inspection days are determined by adding all inspection days from each Engineer's time sheet. No areas of concern. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of Attachment 3 found information to be correct and totals of units were correct. No issues. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 A review of Attachment 4 found information to be correct. Three accidents occurred in CY2013. A review of accident report for Dominion Hope on 10/08/2013 found the information to be detailed with findings of facts. No areas of concern. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A review of Attachment 5 found information to be correct. The $5,200 civil penalty was against Standard Gas Company for failure to document regulator station inspections and other relative information. Please provide information about civil penalities in the note section of the attachment 5. No issues. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of inspection reports and violations cited by PSC WV was accessible on the agency's "S "drive. However, several inspection reports were performed but not listed in the data base by the inspector for a period of three to six months. Improvement is needed in posting all reports in a timely manner. Documentation on the damage prevention inspections and meetings was not fully available. Improvement is needed by listing individuals who attended the meetings and assigning an inspection number for these activities. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, a review of employees listed on attachment 7 was conducted using the SABE training document. Each inspector category and number of months was listed correctly. Progress has been made by individuals attending the following courses in CY2013, PL3291 SCADA, PL3292 Inline Inspection, PL31C Int Corrosion WBT, & PL3306 ECDA. It was suggested DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 3#

WV NG Program Evaluation, 2013, page 4Edwin Clarkson needs to attend the HL Safety Evaluation course PL2258 before conducting an inspection on hazardous liquid operator. No issues of concern. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC WV has automatic adoption of regulations. No issues. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues of concern in a review of Attachment 10. Information about the planned and past performance was detailed correctly. 10 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 4#

WV NG Program Evaluation, 2013, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.2 Standard, page 2. 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.11 Distribution Integrity Management (DIMP), page 4. 3 OQ Inspections (B1c) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.9 Operator Qualification Program, page 3. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.13 Damage Prevention, page 4. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.15 Operator Training, page 4. 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.7 Design, Testing and Construction, page 3. 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 2. Inspection Descriptions, 2.6 Incident or Accident Investigations, page 3. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 5#

WV NG Program Evaluation, 2013, page 6e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: This information is listed in the West Virginia Public Service Commission Gas Pipeline Safety Section, Inspection and Enforcement Procedures, Section 3. Priority of Inspections, section 3.2.6, page 5 9 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 6#

WV NG Program Evaluation, 2013, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 (A12) Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 463.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.81 = 837.28 Ratio: A / B 463.00 / 837.28 = 0.55 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 463 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7) =837.28326 Formula:- Ratio = A/B = 463/837.28326 = 0.55 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement Evaluator Notes: A. All staff members have completed the OQ training course PL3OQ except for Corey Boggess. B. All DIMP/IMP courses have not been completed by David Hippchen. C. David Hippchen has completed the Root Cause Training on 9/17/2010. D. William Youse and Corey Boggess are scheduled for TQ training courses in CY2014 and anticipate completing all seven required natural gas courses by year end. No issues. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, David Hippchen has 33 years of service with the PSC WV serving in several roles in Engineering Utilities. The last 17 years of experience has been in the Pipeline Safety Program. No issues. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Chairman Albert response letter to Zach Barrett was received on February 20, 2014. No issues. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: DUNS: 134236632 2013 Natural Gas State Program Evaluation 2 2 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 7#

WV NG Program Evaluation, 2013, page 8Yes, TQ Seminar was held in Charleston, West Virginia on February 20-21, 2013. The number of participants was 146 operators and consultants. No issues. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, a review of inspection files found all inspection units and operators were inspected in accordance to West Virginia Public Service Commission Gas Pipeline Safety Section Inspection and Enforcement Procedure Inspection Intervals time schedule listed on page 1, Inspection Intervals. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Public Service of West Virginia uses the federal forms for their inspection program. A review of files and reports indicated all sections of the federal form were completed and filled out correctly. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: Yes, they reviewed this item with Blue Field Gas Company during an inspection on March 23, 2011. A review of their DIMP plan is underway and anticipates a discussion with Blue Field Gas Company will result in a replacement program for the removal of the case iron. No issues. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: Yes, this was performed on Blue Field Gas Company. No issues. 1 1 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 (B9) Yes = 1 No = 0 Evaluator Notes: Yes, PSC WV staff members reviewed Blue Field Gas Company's emergency procedures during the Public Awareness inspection conducted on December 3, 2013. No issues. 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, this information is reviewed by verifying leakage records, damage reports and trends on third party damage reports. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 DUNS: 134236632 2013 Natural Gas State Program Evaluation 2 2 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 8#

WV NG Program Evaluation, 2013, page 9Evaluator Notes: Yes, PSC WV staff did review CY2013 Annual Reports filed and conducted a trend analysis. No issues. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 1 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Improvement is needed by PSC WV staff in entering input of all OQ & IMP inspection results into federal database in a timely manner. A review of database on September 3, 2014 found the results for CY2013 inspections conducted in the third and fourth quarter of 2013 had not been entered. This represents a period of nine months from the date of inspection until the date the data was entered. Improvement is needed; therefore a loss of one point occurred. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: No. A review of files and discussion with state program manager confirm this item was not discussed or listed on the intrastate transmission operator inspection review documents. Improvement is needed and this item was cited in the 2012 state program evaluation. Therefore, a loss of one point occurred. 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is reviewed during a standard inspection or when an IA inspection is scheduled. 2 2 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of Mountaineer Gas Company inspections conducted in CY2013 by PSC WV staff indicated the OQ program was up to date. The review included a check of the covered tasks performed by employees and contractor personnel. No issues. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 1 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: In CY2013 Union Oil Integrity Management Program was reviewed, However, Cabot Gas Company was last reviewed in CY2008, Union Carbide was last reviewed in CY2007 and Hampshire Gas Company was last reviewed in CY2008. Improvement is needed in scheduling a review of each of the operators within a reasonable time to insure their IMP plans are up to date. Therefore, a loss of one point occurred. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 9#

WV NG Program Evaluation, 2013, page 10Evaluator Notes: Yes, DIMP reviews were conducted for Mountaineer Gas and Dominion Hope Gas Company Equitable Gas Company & Union Gas Company. All remaining operators will be reviewed in CY2014. 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of files and inspection reports indicated twenty-nine PAPEI inspections were performed. No issues. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Public Service Commission of West Virginia has a web site that provides information about the pipeline safety program. No areas of concern. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, a review of DataMart found one Safety Related Condition Report. Markwest Liberty Midstream & Resources on August 26, 2013 this was actually an accident and the report was filed in error. No issues. 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is reviewed with the operator during DIMP plan inspection. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they participated in all surveys requested from NAPSR or PHMSA. No issues. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified Info Only Info Only conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Info Only = No Points Evaluator Notes: A review of the special permit documents for West Viriginia at PHMSA web site found one waiver was issued on May 14, 1986 to Manus Corporation of the requirements of 49 CFR 192.63 Marking of Materials relative to 14,000 feet of 8 inch Phillips Driscopipe 1000 ASTM-F-714 plastic pipe to transport gas from the Berkley County landfill to the VA Medical Center near Martinsville, WV. Discussion with David Hippchen, PSC WV, determined he was not aware of the waiver but would investigate and provide feedback on the status of the waiver. 25 General Comments: DUNS: 134236632 2013 Natural Gas State Program Evaluation Info Only Info Only West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 10#

WV NG Program Evaluation, 2013, page 11Info Only = No Points Evaluator Notes: Loss of points occurred in Questions C.13, C.14 & C.17 of this section. DUNS: 134236632 2013 Natural Gas State Program Evaluation Total points scored for this section: 43 Total possible points for this section: 46 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 11#

WV NG Program Evaluation, 2013, page 12PART 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 (B12-14, B16, B1h) Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: Improvement has been made since last state program evaluation. In this regard, a review of West Virginia Public Service Commission Gas Pipeline Safety Section Inspection and Enforcement Procedures Section 6 Compliance, section 6.2 Written Formal Notice of Violations found notification to company officer or board member was listed. Additionally, procedures to routinely review progress of compliance action were also listed. 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 (B11,B18,B19) Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Yes, a review of Standard Gas Company compliance letter dated February 8, 2013 indicated the information was sent to the company officer. The probable violation section 192.739 & 192.747 were well documented and resolved by the operator. Action was taken by staff members to review the probable violation routinely until the violation was corrected. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of files found this action was taken. No issues. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes, this is listed in West Virginia Public Service Commission Gas Pipeline Safety Section Inspection and Enforcement Procedures section 6.3 - Options Open to the Operator. No issues. 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, in CY2013 a civil penalty in the amount of $5,200 was assessed against Standard Gas Company. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the civil penalty assessed against Standard Gas Company in CY2013 demonstrates their enforcement authority. DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 12#

WV NG Program Evaluation, 2013, page 137 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. DUNS: 134236632 2013 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 13#

WV NG Program Evaluation, 2013, page 14PART E - Incident Investigations Points(MAX) Score 1 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 (A2,D1-3) Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: A. Improvement has been noted in a review of West Virginia Public Service Commission Gas Pipeline Safety Section Inspection and Enforcement procedures Section 4 & 5 found a written description on receiving and responding to Incident/ Accidents was added. Additionally, information on receiving notifications, during normal and after hours from the operator was provided. It was suggested, additional inspectors names and telephone numbers been added to the procedures. B. Procedures contain acknowledgment of Federal/State Cooperation of incident/accident. This information is listed in Section 4. No issues of concern. 2 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, a review of files pertaining to the three incidents in CY2013 found sufficient information was obtained from the operator. No issues. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, incidents were thoroughly documented and investigated. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: Yes, compliance action was taken against Dominion Hope. 1 1 5 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, discussion with PHMSA Region Director on Mountaineer Gas Company. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, at the NAPSR Eastern Region Meeting information on accidents and compliance items was discussed. DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 14#

WV NG Program Evaluation, 2013, page 157 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. DUNS: 134236632 2013 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 15#

WV NG Program Evaluation, 2013, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Improvement was noted. A review of files found this question was asked during an inspection of Bluefield Gas Company on December 3, 2013. It was suggested this question be included in the IA inspection format in the future for all operators reviewed. 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Improvement was noted. A review of files found this question was asked during an inspection of Mountaineer Gas Company in Charleston, WV on March 6-7, 2013. 3 Did the state encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, in CY2013, PSC WV promoted the safe digging month of April by using their web site address. 2 2 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the Public Service Commission of West Virginia request and receives from the natural gas operators damages per 1,000 locate request. They review and track the data and trend information on a spreadsheet. In 2013, the results show a higher percentage damage rate for smaller operators than larger operators. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred on this section of the review. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 16#

WV NG Program Evaluation, 2013, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Dominion Hope Gas Company Name of State Inspector(s) Observed: Ed Clarkson, Technical Analyst/Dave Hippchen, Program Manager Location of Inspection: Parkersburg, West Virginia Date of Inspection: September 9, 2014 Name of PHMSA Representative: Glynn Blanton, State Evaluator Evaluator Notes: This was an IA inspection on Dominion Hope Natural Gas Distribution system located in Parkersburg, WV. The inspection was conducted at their office located at 55 Ashby Ridge Road. Dominion Hope representatives present are listed below: John Marlow, Supervisor Construction & Maintenance, Gas Operations Kenneth Smith, Manager Gas Operations John Marlow, Construction and Maintenance Daniel Kukoly, Engineer Tammy Maze, Supervisor Gas Infrastructure Richard Thompson, Supervisor, Dominion Hope Janette Jones, Compliance Jim Bradly, Supervisor C&M 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Yes, Ed Clarkson, PSC WV, contacted Janette Jones, Compliance officer, via email on March 18, 2014. A review of email confirmed this action was completed. No issues of concern. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Ed Clarkson, PSC WV used PHMSA IA form. A complete list of questions was developed by Ed Clarkson using the IA format. Over sixty questions were developed and used for the inspection. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, observed Ed Clarkson asking questions and reviewing documentation provided by Dominion Hope personnel on maintenance and operation activities. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) (F5) Yes = 1 No = 0 Evaluator Notes: Yes, Ed Clarkson, WV PSC reviewed electronic documents with the operator representatives prior to conducting the inspection. No issues. DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 17#

WV NG Program Evaluation, 2013, page 186 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures 2 2 b. Records c. Field Activities d. Other (please comment) Evaluator Notes: This was a records review of the activities of Dominion Hope distribution system in Parkersburg, WV. 7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Ed Clarkson, WV PSC has over thirty years of experience in pipeline safety and has completed all required TQ courses for natural gas. No issues. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No violations were noted or found during the inspection. 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings DUNS: 134236632 2013 Natural Gas State Program Evaluation Info Only Info Only West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 18#

WV NG Program Evaluation, 2013, page 19u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: This was an office records review. No outside field inspection was conducted. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 19#

WV NG Program Evaluation, 2013, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 20#

WV NG Program Evaluation, 2013, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 134236632 2013 Natural Gas State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 21#