2014 WY NG Program Evaluation - wy2014ngprogramevaluation (Wyoming; Natural Gas State Program Evaluation)

WY NG Program Evaluation, 2014, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2014 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 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 1#

WY NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Wyoming Rating: Agency Status: Date of Visit: Agency Representative: PHMSA Representative: Commission Chairman to whom follow up letter is to be sent: Name/Title: Agency: Address: City/State/Zip: 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2014 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 9 9 B Program Inspection Procedures 13 13 C Program Performance 44 44 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 106 105 State Rating................................................................................................................................................... 99.1 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 2#

WY NG Program Evaluation, 2014, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The jurisdictional authority listed looks accurate 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WYPSC uses a time/travel tracking system for all inspection work done in gas safety. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WYPSC has a good system for tracking the operators and their inspection units. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in Wyoming in 2014 for the WYPSC to investigate. 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, The compliance activities are tracked using GPLS inspection follow up spread sheet. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 No Issues, files are electronic on the WYPSC shared drive and backed up in hard copy and stored in the gas engineers office. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues, Discussed the importance of having more staff trained to lead TIMP, DIMP and CRM inspections in case of emergencies during the last evaluation and the WYPSC has sent an inspector to the DIMP course in 2015. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Issues. The rules are automatically being adopted at this time. However, the Program Manager said this would more than likely change in the near future with the efforts being made now to update their state statues under a request by the Governor to update all state agencies rules. DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 3#

WY NG Program Evaluation, 2014, page 49 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: 1 1 No Issues. All accomplishments on the progress report were described in sufficient detail. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 4#

WY NG Program Evaluation, 2014, page 5PART 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: David has added general guidance to the WYPSC procedures and plans to continue to refine the language and make it more detailed and specific to the inspections being done. 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: David has added general guidance to the WYPSC procedures and plans to continue to refine the language and make it more detailed and specific to the inspections being done. 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: David has added general guidance to the WYPSC procedures and plans to continue to refine the language and make it more detailed and specific to the inspections being done. 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: David has added general guidance to the WYPSC procedures and plans to continue to refine the language and make it more detailed and specific to the inspections being done. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This is covered in their procedures in section 3.E 1 1 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: David has added general guidance to the WYPSC procedures and plans to continue to refine the language and make it more detailed and specific to the inspections being done. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 5#

WY NG Program Evaluation, 2014, page 6a. 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: This is covered in their procedures in section 4 8 General Comments: Info Only = No Points Evaluator Notes: in all areas. Info Only Info Only The WYPSC procedures are getting better and cover the minimum of the requirements. They will continue to add more detail Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 6#

WY NG Program Evaluation, 2014, 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 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 177.14 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.53 = 336.60 Ratio: A / B 177.14 / 336.60 = 0.53 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The WYPSC did 177.14 inspection days for 2014 and had 1.53 person years for inspectors. This gives them a .53 ratio. 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: 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: David has been the program manager for ten years and has a great knowledge of the PHMSA State Pipeline Safety Program and the regulations. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the letter was mailed on January 16, 2015, and they received Zach's letter on November the 20, 2014. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Yes, the last seminar hosted by the WYPSC was on 4/4/2013. They are planning to schedule on e in 2016. 2 2 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: 5 5 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 7#

WY NG Program Evaluation, 2014, page 8Reviewed the records for all types of inspections and found them to have been conducted within the specified time intervals in the states procedures. No issues. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC uses the PHMSA forms 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: There is no cast iron in 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: There is no cast iron in 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 Evaluator Notes: No Issues - 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, these are reviewed by the Program Manager 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. State uses a spreadsheet to track annual report information. 2 2 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Evaluator Notes: Yes = 2 No = 0 Needs Improvement = 1 No issues. The program Manager is uploading the information. 2 2 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 8#

WY NG Program Evaluation, 2014, page 914 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: No issues. The program Manager checks their submissions and looks at the NPMS to see that new lines are being added. 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC uses the D&A field form and does one for each operator at least once every three years. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 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: The WYPSC have the OQ inspections set up on a 5 year rotation. 2 2 17 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The WYPSC has the transmission operators IMP inspections on a 5 year rotation. 2 2 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 The WYPSC completed the plan inspections on time and is scheduling the formalized field inspections starting in 2016. 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No Issues 2 2 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the state forwards bulletins to all operators. Discussed having the information available on the WY PSC website updated. DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 9#

WY NG Program Evaluation, 2014, page 1021 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WYPSC followed up appropriately on the one SRC filed in 2014 dealing with an over-pressure incident on a plastic pipe system. (Aldyla) Included required monthly leak surveys. 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes the WYPSC responded to all NAPSR surveys in 2014. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified 0 0 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: One operator, (MDU) has two waivers. The first for PE fusion qualifications. The second for doing atmospheric corrosion inspections on a four year schedule. 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: YES 0 0 26 Discussion on State Program Performance Metrics found on Stakeholder Communication site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points Evaluator Notes: Reviewed on PHMSA web site and discussed with Program Manager. 0 0 27 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 44 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 10#

WY NG Program Evaluation, 2014, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: The WYPSC meets the minimum requirements of this question, but still needs to improve the language and details of it's procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: The probable violations are reviewed for progress by the Program Manager and documented on the GPLS inspection follow up spread sheet. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, tracked the violations found in the 2014 inspection to insure compliance actions were taken. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, Yes. This is covered in State Statues, (37-2-128 & 37-2-129) 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the state program manager is very familiar with the process, and is considering the use of civil penalties in a case they are presently involved in. 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: They have not used their authority for assessing civil penalties in 2014, but are engaged in the process with an operator in 2015. 1 point will be deducted. 7 General Comments: Info Only = No Points DUNS: 110414138 2014 Gas State Program Evaluation Info Only Info Only Wyoming Public Service Commission, State of Wyoming, Page: 11#

WY NG Program Evaluation, 2014, page 12Evaluator Notes: D. 6 - They have not used their authority for assessing civil penalties in 2014, but are engaged in the process with an operator in 2015. 1 point will be deducted. Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 12#

WY NG Program Evaluation, 2014, page 13PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WY PSC has the (Major Event Management and Reporting Plan). State Rule #420 A-C 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes, this is found in section 1.3G of the WYPSC procedures. 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 reportable incidents in Wyoming in 2014 for the WYPSC to investigate. 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 reportable incidents in Wyoming in 2014 for the WYPSC to investigate. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no reportable incidents in Wyoming in 2014 for the WYPSC to investigate. 1 NA 6 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in Wyoming in 2014 for the WYPSC to investigate. 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 2014 Gas State Program Evaluation 1 1 Wyoming Public Service Commission, State of Wyoming, Page: 13#

WY NG Program Evaluation, 2014, page 14Yes, they share any information at the regional NAPSR annual meetings. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 14#

WY NG Program Evaluation, 2014, page 15PART 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: Yes, it is now part of the new form. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is completed during each Standard inspection. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WY PSC participates in P the PHMSA One Call Grant program. Buys advertising around the state to promote the use of the One Call system. Attends annual state One Call meeting. Meets with excavators in local towns meetings across the state. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WYPSC tracks the data through the annual reports, and the Wyoming One Call annual report. 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 15#

WY NG Program Evaluation, 2014, page 16PART 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: Source Gas Name of State Inspector(s) Observed: David Piroutek Location of Inspection: Choke Cherry Compressor Station, in Walcott Junction near Sinclair, WY Date of Inspection: 9/15/2015 Name of PHMSA Representative: Michael Thompson Evaluator Notes: This was a construction inspection to check on the progress of the new compressor station. Source Gas is nearing the in service date for the compressor and the WYPSC wanted to check all parts of the project. 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 notified in advance of the inspection and their Compliance Coordinator, (Rod Howe) was on site for the whole inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: guide for the inspection. Yes, the inspector used the new construction inspection form developed by the WYPSC gas safety staff as a check list and 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector kept notes on his form. 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: Yews, the inspector checked all equipment being used by the operator during the inspection. 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: The inspector reviewed all field activities taking place during the inspection. Point to point verifications on intake pressure and suction pressure, Fire eye operation and gas indictor accuracy and operation. DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 16#

WY NG Program Evaluation, 2014, page 177 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, the inspector demonstrated he has adequate knowledge of the pipeline safety program and the regulations. 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: 1 1 Yes, this is an ongoing inspection and the inspector discussed the issues found to date with the operators representatives. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, however the issue was corrected during the inspection. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance Info Only Info Only DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 17#

WY NG Program Evaluation, 2014, page 18E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 18#

WY NG Program Evaluation, 2014, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 19#

WY NG Program Evaluation, 2014, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 110414138 2014 Gas State Program Evaluation Wyoming Public Service Commission, State of Wyoming, Page: 20#