# 2022 WY NG Program Evaluation - wy-2022-gas-program-evaluation (Wyoming; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA wy-2022-gas-program-evaluation
- **title:** 2022 WY NG Program Evaluation - wy-2022-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:** 2022-01-01
- **effective on:** Not available
- **summary:** 2022 PHMSA natural gas program evaluation for Wyoming.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-state-evaluation-wy-ng-program-evaluation-wy-2022-gas-program-evaluation.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-state-evaluation-wy-ng-program-evaluation-wy-2022-gas-program-evaluation.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-state-evaluation-wy-ng-program-evaluation-wy-2022-gas-program-evaluation
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-12/wy-2022-gas-program-evaluation.pdf
**body:**

1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 Gas State Program Evaluation for Public Service Commission, State of Wyoming Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 1

2022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Wyoming Rating: Agency Status: Date of Visit: 07/10/2023 - 07/14/2023 Agency Representative: Perry Mccollum PHMSA Representative: David Appelbaum Commission Chairman to whom follow up letter is to be sent: Name/Title: Mary Throne, Chairman Agency: Wyoming Public Service Commission Address: 2515 Warren Avenue, Suite 300 City/State/Zip: Cheyenne, WY 82002 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2022 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 9 D Program Performance 50 41 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 90 State Rating................................................................................................................................................... 90.0 DUNS: 110414138 2022 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 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a & c: Inspection Unit totals by operator type on Attachment 3 are consistent with the Inspection Unit totals on Attachment 1, with only slight discrepancies because of undetermined gathering facilities. These units should be reconciled by next year. b: Minimum number of inspection days required was 229 - Actual was 241.5. d: Reviewed PDM data, all good. Compliance activity numbers match records kept by the program. Training verified through Blackboard. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Minor updates from prior year. a. Inspection Planning beginning on page 5, Pre-Inspection, Inspection and Post Inspection pages 5-7 and 10. b. Pre-Inspection, Inspection and Post Inspection pages 5-7 and 11. c. Pre-Inspection, Inspection and Post Inspection pages 5-7 and 11-12. d. Pre-Inspection, Inspection and Post Inspection pages 5-7 and 12. e. On-site operator training addressed on page 12. f. Pre-Inspection, Inspection and Post Inspection pages 5-7 and 12. g. LNG facilities records and field inspected annually. LNG procedures not to exceed every 3 years (page 4). 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: No changes. Items a through e covered on pages 3-5, and 11 of written procedures. Units apportioned appropriately. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Same as prior year. a, b, and c. Page 8 of 13 (Post Inspection Activities/Facilities Inspection Report). PHMSA recommends program clearly articulate timeline expectations for closing an inspection and ensure alignment with Guidelines 5.1.6 "...The State agency must conduct follow-up actions when noncompliance is discovered during an inspection. The determination of the appropriate procedure for ensuring that all noncompliance is corrected is the responsibility of the State agency. However, the State agency must maintain a complete record of each noncompliance found and have a review procedure that will ensure that proper and timely follow-up activity has been completed for each noncompliance. Procedures should outline when the program considers probable violations are closed...." 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? 3 3 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 4

Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Section 3 (Specific Instructions for the Inspection of Gas Utilities and Intrastate Gas Pipeline Operators), Part g (Incident/ Accident investigations). Each operator is to notify the gas pipeline safety section by telephone. If an incident occurs outside the commission's working hours, the operator contacts an employee of the gas pipeline safety section. The commission provides a list of pipeline staff and their telephone numbers to each operator. No reportable incidents in CY2022. 5 General Comments: Info Only = No Points Evaluator Notes: Program made some improvement to their procedures in the last year Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Yes. All lead inspectors and Program Manager have met the requisite training requirements. 5 5 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 4 Evaluator Notes: PM started as the Acting Director in Early 2023. Though he's been in the job less than a year, he has displayed an sufficient ability on applying code and directing resources to specific needs. He has obtained a substantial amount of knowledge on the role of a PM in a short amount of time. However, since he's been in the position for less than a year, one-point deduction. 3 General Comments: Info Only = No Points Evaluator Notes: One point deducted for PM in position for less than a year. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 10 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 6

PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 0 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: PSC was due to conduct an IMP and DIMP inspection of Dominion Energy by the end of 2022. These inspections were last done in April 2017. As of this evaluation these inspections have not been completed. All inspections were not completed within 60 days of established dates; five-point deduction. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: The program utilizes the IA for documenting inspection results including D&A inspections. The program has a separate inspection form for LPG inspections. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 5 days devoted to OQ activities. OQ field validation typically done as part of standard inspections. 2 2 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 7

Evaluator Notes: Yes. 20.75 days devoted to IM activities. Integrity Management Program inspections are conducted within two years of the notification of changes to an operator's Integrity Management Program. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? 2 2 Evaluator Notes: a & b: No CI remaining in WY. C: Covered under Procedures/Emergency Group in IA. d: Question covered under IA Records/O&M group. e. Question covered in IA under O&M Procedures. f. No low pressure systems remaining in WY. G. Program in place to remove existing inside installations. Addressed also in IA GD question set. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes. PHMSA Advisory Notices ADB-2020-01 (Inside Meters) and ADB-2020-02 (Low Pressure Systems). MDU and Black Hills Energy. Conversations with both. Last remaining low pressure removed in 2019. Black Hills has a program in place to relocate identified inside meter sets. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns 10 6 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 8

j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Following an inspection of Black Hills Energy in CY 2022, the PSC timely issued an appropriate NOPV, and received a timely response. However, program has not responded to the operator's response and the matter remains open. There's no evidence that the probable violations have been resolved or have been routinely reviewed for progress. Program lost two points last year for similar concerns (c. and d.) - 4-point deduction 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: Program had one incident in 2022 which was handled competently and per procedures. 10 10 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Chairman's letter was responsive and timely - no issues. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: A remote session was conducted in July 2021, next one scheduled for 2024. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Discrepancies noted but were due, in most part, to operator acquisitions and changes to portfolios Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Commission web site provides web links to PHMSA State Programs Overview page, Wyoming One-Call. Only enforcement cases brought to commission open meetings made available via public records request. DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 9

13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRCRs in CY 2022 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: No issues 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Program has six waivers on PHMSA's website that need to be resolved by next year to avoid loss of points. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: No issues, PM had no trouble accessing files Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: Yes. Tool is updated annually. No changes that affect staffing levels or days. PM is well versed in the mechanics of the SICT. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Info Only Info Only Program manager is sufficiently versed with performance metrics found in PDM. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Has discussed with operators. To date no operators have adopted the RP or implemented programs. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 10

Total points scored for this section: 41 Total possible points for this section: 50 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the Info Only Info Only comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: A standard inspection was conducted on Black Hills Energy's Transmission system located in Meeteetse, WY on 07/12/2023, and was last inspected in 2022. The operator was represented. Perry Mccollom has been with the WYPSC safety program since 2012. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Inspector is well versed with inspection protocols, however, he did not use a form or checklist as a guide for the inspection --- he did it from memory and experience. While he covered the requisite elements of the standard and construction inspections conducted, PHMSA recommended the Program use a checklist notwithstanding. 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: Inspector was very thorough in all aspects of the audit. He was observed asking multiple questions about the operator's procedures and recording their responses appropriately. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Inspector appears very competent with the pipeline safety regulations and inspection protocols. He conducted the inspection in a professional manner. Additionally, he asked excellent questions and insured the operator's records, procedures, and alike, reflected compliance with the pipeline safety regulations. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspector provided an exit interview to the operator and sufficiently articulated areas of concern and/or recommendations for improvement. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points DUNS: 110414138 2022 Gas State Program Evaluation Info Only Info Only Wyoming Public Service Commission, State of Wyoming, Page: 12

a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: All aspects of the field inspection were done safely - no concerns. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Generally, if annual reports have errors they are returned to the operator to make corrections. Program reviews the Operator Annual reports for accuracy and analyzed data for trends and operator issues. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the Program verifies that the operators analyze excavation damages for the purpose of determining root causes and minimizing the possibility of a recurrence. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: The Program verifies the root cause numbers reported against the data collected annually (internally). 4 4 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 14

Program has collected sufficient data to understand causes of excavation damage. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: WY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110414138 2022 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 16
- **truncated:** false
- **body characters:** 33292