# 2017 WY NG Program Evaluation - wy-2017-gas-program-evaluation (Wyoming; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA wy-2017-gas-program-evaluation
- **title:** 2017 WY NG Program Evaluation - wy-2017-gas-program-evaluation (Wyoming; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-01-01
- **effective on:** Not available
- **summary:** 2017 PHMSA natural gas program evaluation for Wyoming.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/3771/wy-2017-gas-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for Public Service Commission, State of Wyoming 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: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 1

2017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Wyoming Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 09/18/2018 - 09/20/2018 Agency Representative: David Piroutek, Engineering Supervisor, Wyoming Public Service Commission (WYPSC) PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Bill Russell, Chairman Agency: Wyoming Public Service Commission Address: 2515 Warren Avenue, Suite 300 City/State/Zip: Cheyenne, Wyoming 82002 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 2017 (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 13 13 C Program Performance 45 45 D Compliance Activities 15 14 E Incident Investigations 5 5 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 108 107 State Rating................................................................................................................................................... 99.1 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 2

PART 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: GPLS Trip Record Database contains all of the information for operators and units including which operators and units received an inspection during the year. Operator information is captured from Annual Reports and entered into a spreadsheet to verify operator information. Intrastate LNG operator was transposed as Interstate when entering information into "Wizard". Request for correction was made. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Inspection person days are accounted for on half hour increments. The GPLS Trip Record Database contains inspection person days assigned to inspections. No discrepancies were found between the GPLS information and Attachment 2 information. 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: The tally of units on Attachment 1 (49 Units) matched the unit totals on Attachment 3. Operator information entered on Attachment 3 were verified with office records. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 4 of the WYPSC's 2017 Progress Report listed no reportable incidents in 2017. A review of incident data in the Pipeline Data Mart showed the same result. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: GPLS database inspection follow up spreadsheet accounts for probable violations by operator and inspection. The information compiled from the spreadsheets. No issues with accuracy were found for 2017. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. Most files are electronic instead of hard copy. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All information on Attachment 7 was accurate and supported by documentation. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 3

Evaluator Notes: No issues with Attachment 8. 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: No issues for improvement on Attachment 10. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: The WYPSC generally complied with the Part A requirements of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" contains guidance on what the Standard Inspection should entail on Pages 10 and 11. Pre- inspection activities, inspection activities, post-inspection activities are described in the document on pages 5 -7. The procedures meet expectations. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" provides guidance on what the IMP and DIMP should entail on page 11. Pre-inspection activities, inspection activities, post-inspection activities are described in the document on pages 5 -7. The procedures meet expectations. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" provides guidance on what the OQ inspection should entail on page 11. Pre-inspection activities, inspection activities, post-inspection activities are described in the document on pages 5 -7. The procedures meet expectations. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" revised as of 9/9/2016 was reviewed. Guidance is given on what the Damage Prevention Inspections should entail on page 12. Pre-inspection activities, inspection activities, post-inspection activities are described in the document on pages 5 -7. The procedures meet expectations. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" provides guidance on when operator training will be provided on page 12. Operator training is not an inspection. Pre-inspection activities, inspection activities, post-inspection is not applicable. The procedures meet expectations. DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 5

6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" provide guidance on when the Construction Inspections will be conducted on page 12. Pre- inspection activities, inspection activities, post-inspection activities are described in the document on pages 5 -7. The procedures meet expectations. 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 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: "INSPECTION PROCEDURES FOR THE FACILITIES ENGINEERING STAFF OF THE PUBLIC SERVICE COMMISSION OF WYOMING" provides guidance on what considerations will be involved to schedule inspections on Page 3. The procedures cover the Elements (a through (e above. Inspection units appear to be appropriate. 8 General Comments: Info Only = No Points Evaluator Notes: The WYPSC has generally complied with the Part B requirements of this evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, 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): 247.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.63 = 358.60 Ratio: A / B 247.50 / 358.60 = 0.69 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The WYPSC's ratio of 0.69 exceeded the minimum ratio of 0.38. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 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 inspection staff has either completed the required training or is on schedule to complete the training. No deficiencies found. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: David Pitourek has been the program manager for 14 years. He has completed all of the required courses at PHMSA's Training and Qualifications Division. David is very knowledgeable of the regulations and PHMSA's Guidelines. 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: The WYPSC responded in 58 days. Deficiencies were addressed in the response. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: The WYPSC participated in a seminar with ND and SD in 2017. The last seminar was in 2016. 1 1 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 Evaluator Notes: DUNS: 110414138 2017 Gas State Program Evaluation 5 5 Wyoming Public Service Commission, State of Wyoming, Page: 7

Upon a review of randomly selected inspection reports completed during CY2017, the inspection dates were within the timeframe described in the WYPSC's procedures and did not extend past PHMSA's five year interval requirement. The WYPSC should develop a tracking system that will monitor the status of inspection units along with inspection types. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC utilizes PHMSA's Inspection Assistant (IA) system. The IA system covers all applicable code requirements for the areas covered in the inspection. Upon a review of randomly selected inspection reports completed during CY2017, there were no instances found where documentation was lacking. 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: Upon a review of PHMSA's Pipeline Datamart there is no Cast Iron pipeline in the state of Wyoming. 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: Upon a review of PHMSA's Pipeline Datamart there is no Cast Iron pipeline in the state of Wyoming. 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 1 1 Evaluator Notes: The WYPSSC utilizes PHMSA's IA Standard Inspection form. When using the form the WYPSC documents the results of this question in the section on leaks. Upon a review of randomly selected inspection forms this requirement was reviewed. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The WYPSSC utilizes PHMSA's IA Standard Inspection form. This form covers this requirement. Upon a review of randomly selected inspection forms this requirement was reviewed. 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: The WYPSC enters the data from Annual Reports into a spreadsheet. The spreadsheet is reviewed for possible inaccuracies. Damages per 1000 locate tickets is analyzed and trended over multiple years. Miles, leaks (and types of leaks), age of infrastructure, percent of unknown vintage, cathodically unprotected mains and service lines and lost and unaccounted for gas. The WYPSC trends data for gas distribution operators individually. DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 8

13 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: The WYPSSC utilizes PHMSA's IA Standard Transmission Inspection form. This form cover this requirement. Upon a review of randomly selected inspection forms the results of this requirement's review was completed on the form. 14 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 The WYPSC did not conduct a full Drug and Alcohol Program review for any operators in 2017; however, the WYPSC has conducted them in previous years. There are no operators that have not had a D&A inspection outside of five years. 15 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: One distribution operator and one transmission operator received OQ Plan inspections in 2017. Time spent on Protocol 9 inspection is included under Standard Inspections. The WYPSC is within the five year interval for OQ Program Inspections. 16 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). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC is within the five year interval for IMP Program Inspections. 10 inspection person-days on TIMP during CY2017. 17 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 14.5 inspection person-days on DIMP Program. The WYPSC is within the five year interval for DIMP Program Inspections. 18 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. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The WYPSC conducted Public Awareness inspections during 2017. The WYPSC is within the five year interval. 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 110414138 2017 Gas State Program Evaluation 1 1 Wyoming Public Service Commission, State of Wyoming, Page: 9

Yes, the WYPSC forwards advisory bulletins to all operators. The WY PSC website has a section on Pipeline Safety. Information is updated in this section. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: There were no SRC Reports filed by operators in the state of Wyoming. This was confirmed in the Pipeline DataMart. 21 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WYPSC utilizes the PHMSA IA Standard Inspection Form. This requirement is covered on the form. 1 1 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No instances were found where the WYPSC did not respond. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: The WYPSC is aware of the special permits (waivers) and has followed up to make sure they are being met. The WYPSC needs to evaluate the waiver given for the use of "Clock Spring" to make repairs. The WYPSC should communicate to PHMSA Regulations those waivers listed on PHMSA's web site that are not valid so they can be removed. 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being 1 1 evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: David Piroutek attended the meeting. 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: The metrics for Wyoming shown on the Stakeholder Communication Site were discussed. None of the trends indicated a need for Accelerated Actions be taken by the WYPSC. All metrics were trending in a positive direction except for CY2017 of Inspection Person Days per 1000 miles of pipeline and Inspector Training. Staff turnover has impacted these two metrics. The action to improve these metrics is dependent upon retaining qualified inspection staff. The WYPSC has documented its annual review of the metrics. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: The WYPSC's results look reasonable. The WYPSC has adjusted the estimates during the past two cycles to make the inspection person-days as accurate as possible. DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 10

27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: No flow reversals took place during CY2017. 28 General Comments: Info Only = No Points Evaluator Notes: The WYPSC has generally complied with the requirements of Part C of this evaluation. Info Only Info Only Total points scored for this section: 45 Total possible points for this section: 45 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, 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 c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: The WYPSC has a requirement, in its procedures, that notifications be sent to a company officer when it involves a private company. The WYPSC requires operators to provide written responses within 30 days. Compliance actions are monitored to ensure operators respond and take corrective action. A written notification of closure is provided to the operator upon closure of the inspection file. 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. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2017 there were no instances of not documenting probable violations. The WYPSC requires operators to respond to non-compliance notifications. There were no reports found where the operator did not respond within thirty days. If corrective actions are not completed within 30 days evidence was available that showed the WYPSC continued to follow-up until corrective action was completed. The WYPSC, in the last paragraph of each non-compliance notice, provides a statement providing the civil penalties that could be levied regarding non-compliance. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected inspection reports, compliance actions were issued for all probable violations. 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Upon a review of randomly selected inspection reports completed in 2017 there were no instances identified where the WYPSC did not give reasonable due process. According to Commission rules operators are allowed to request show cause proceedings to argue their case. 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 110414138 2017 Gas State Program Evaluation 2 2 Wyoming Public Service Commission, State of Wyoming, Page: 12

Yes, the program manager is aware of the process and the criteria that would justify seeking a civil penalty from the Commission. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 0 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Needs improvement. As identified in previous evaluations the WYPSC has not demonstrated the use of civil penalties. It was noted in the Chairman's letter for CY2014, CY2015 and CY2016 evaluations. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question D.6 - Needs improvement. As identified in previous evaluations the WYPSC has not demonstrated the use of civil penalties. It was noted in the Chairman's letter for CY2014, CY2015 and CY2016 evaluations. Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, 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: As noted in previous evaluations, the WY PSC provides for these procedures in Commission Rule, Chapter 3 - Section 27 (d. 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: See Question E.1 comments for mechanism to receive operator reports. Yes, the acknowledgement is confirmed in the WYPSC procedures, Section 3(g. 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: There were no incidents reported in CY2017. 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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: There were no incidents reported in CY2017. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no incidents reported in CY2017. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents reported in CY2017. 1 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 110414138 2017 Gas State Program Evaluation 1 1 Wyoming Public Service Commission, State of Wyoming, Page: 14

The WYPSC discussed the incident that occurred in CY2016 at the NAPSR Western Region meeting in 2017. 8 General Comments: Info Only = No Points Evaluator Notes: The WYPSC generally complied with the requirements of Part E of this evaluation. Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, 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 The WYPSC covers this requirement when O&M procedures are inspected under 192.614 (c. Upon a review of randomly selected inspection reports completed in 2017 all inspection forms included a review of 192.614(c requirements. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 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: The WYPSC reviews operator records documenting their 811 calls for their excavation activities. This is covered in a Standard Inspection when reviewing requirements for 192.614. 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: The WY PSC participates in the PHMSA One Call Grant program. The grant purchases advertising around the state to promote the use of the One Call system. The WYPSC attends the annual state One Call meeting. The WYPSC, in conjunction with the One Call System and the gas association, on occasion meets with excavators in local town meetings across the state. 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC collects and trends information obtained from operators' Annual Reports. The data is now viewed on an operator basis also. See comments on Question C.12. 5 General Comments: Info Only = No Points Evaluator Notes: The WYPSC generally complied with Part F requirements of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 16

PART 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: Williams Gathering MLP, OP ID 31703 Name of State Inspector(s) Observed: David Piroutek Location of Inspection: Douglas, WY Date of Inspection: September 19, 2018 Name of PHMSA Representative: Don Martin Evaluator Notes: The WYPSC conducted a Standard Inspection, excluding O&M Procedures, of the operator's facilities that are jurisdictional in the Douglas, WY area. The operator was represented by Thomas Dark and Jake Welle. 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 provided with at least one week notification. The operator was represented by Thomas Dark and Jake Welle. 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 IA form was populated with questions for a Standard Inspection of a Gas Transmission System (O&M Procedures Review was not part of the scope). The inspector progressed through the IA Form. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The results of each question was completed prior to moving on to the next question. 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: Yes, and any calibration dates were verified if calibration was required. 1 1 2 2 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: conditions of facilities. Procedures were not in the scope of this inspection. The inspector reviewed records and observed testing in the field and DUNS: 110414138 2017 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, 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: Yes, the inspector exhibited an excellent knowledge of pipeline safety regulations. 2 2 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) Yes = 1 No = 0 Evaluator Notes: Yes, an exit briefing was conducted. 1 1 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes. The inspector notified the operator that two issues were found during the inspection. Overpressure protection equipment was not tested during CY2017 and on line patrol was not completed during CY2017. The operator was informed these would be at least Issues of Concern if not Probable Violations. The WYPSC stated that further review will be needed for a final determination. The determination would be communicated to the operator in a non-compliance letter. 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. Inspe
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