Atmos Energy : Response to NTSB's Jan. 2021 Meeting

In July 2015, the American Petroleum Institute (API) issued Recommended Practice 1173 (RP1173) outlining a Pipeline Safety Management System (PSMS). This is a voluntary measure, not required by code or regulation. The American Gas Association (AGA) recommended RP1173 for industry adoption in May 2019.

In 2016 Atmos Energy began working with an industry leading third party expert to examine its practices in the context of PSMS. Atmos Energy then conducted a PSMS self-assessment and gap analysis for its Virginia operations. Afterwards Atmos Energy continued to participate in industry discussion groups and workshops to gain expertise and better understand how to develop and implement PSMS across its entire organization.

After Feb. 23, 2018, Atmos Energy took additional voluntary and proactive measures to accelerate the implementation of PSMS. Atmos Energy updated its initial self-assessment and again engaged its industry leading third party expert, this time to perform an enterprise wide PSMS assessment and gap analysis. Atmos Energy has developed a roadmap and PSMS program documents to allow it to reach significant and widespread maturity across all elements of a PSMS - a task that RP1173 recognizes is a journey. A Director level resource has been added in within Atmos Energy's corporate structure to support this accelerated implementation effort.

These and other efforts in support of PSMS are supported at the highest levels of the organization, with a corporate officer primarily responsible for the design, adoption, and implementation of PSMS. The corporate Risk Management and Compliance Committee is responsible for ongoing governance and reporting to the Company's Management Committee.