# 2022 NC NG Program Evaluation - nc-2022-gas-program-evaluation (North Carolina; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA nc-2022-gas-program-evaluation
- **title:** 2022 NC NG Program Evaluation - nc-2022-gas-program-evaluation (North Carolina; 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 North Carolina.
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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 NORTH CAROLINA UTILITIES COMMISSION 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: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 1

2022 Gas State Program Evaluation -- CY 2022 Gas State Agency: North Carolina Rating: Agency Status: Date of Visit: 09/25/2023 - 09/28/2023 Agency Representative: Steve Wood, Director - Pipeline Safety Section PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Charlotte A. Mitchell, Chair Agency: North Carolina Utilities Commission Address: 430 North Salisbury Street, Dobbs Building City/State/Zip: Raleigh, North Carolina 27603 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 10 D Program Performance 50 46 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 96 State Rating................................................................................................................................................... 96.0 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, 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. No inaccuracies found in comparison to list in NC Procedures document. b. The NCUC provided information in spreadsheets that supported the information entered into Attachment 2. No issues. c. Listing is maintained in the NCUC's Procedures document. No discrepancies were found. d. Attachment 4 listed three incidents. There were four listed in the Pipeline Data Mart. The NCUC provided the information to Carrie Winslow so the Progress Report could be corrected. e. The NCU provided a spreadsheet covering non-compliance information. The spreadsheet provided the information that supported the entries on Attachment 5. There were no probable violations found during 2022. No issues. f. No issues. g. Training information in Attachment 7 was imported from Training and Qualification Division's (TQ) training database. h. No issues found. The NCUC has automatic adoption authority. i. No issues found. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, 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: The NCUC's PIPELINE SAFETY PROGRAM PROCEDURES MANUAL was reviewed. Procedures for pre-inspection, conducting inspection and post inspection activities are described on Pages 9 through 19. a. Procedures for conducting Standard Inspections are described on Pages 13 and 14. No issues. b. Procedures for Transmission Integrity Management Program and Distribution Integrity Management Program Inspections on Pages 18 and 19. No issues. c. Procedures for conducting Operator Qualification Inspections are described on Pages 13 and 14. d. Procedures for conducting Damage Prevention Inspections are described on Page 18. No issues. e. Procedures for conducting on site operator training is described on Page 18. No issues. f. Procedures for conducting Design, Testing and Construction Inspections are described onPages 14 through 17. No issues. g. Procedures for conducting Standard Inspections are described on Pages 13 and 14. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 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? Evaluator Notes: The NCUC's PIPELINE SAFETY PROGRAM PROCEDURES MANUAL was reviewed. a. - e. Section 4. B. describes the NCUC's inspection priorities. The inspection priorities meet PHMSA's requirements. Although not required in its procedures, the NCUC conducts an inspection on each operator annually. f. There were no issues found with inspection units. 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: a. The second paragraph of Section 5 R states letter to be addressed to the appropriate operator contact (which should be a company officer, system owner, mayor or other responsible party). DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 4

b. Section 5. T. on Pages 21 and 22 meets the requirements. c. Section 5. U. on Pages 22 and 23 meets the requirements. 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 actions in the event of an incident/accident? 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: a. PIPELINE SAFETY PROGRAM PROCEDURES MANUAL Sections VI. B., E. and H contain procedures that meets these requirements. b. Section VI. B. meets these requirements. 5 General Comments: Info Only = No Points Evaluator Notes: There were no findings that resulted in the loss of points in Part B of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 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: The training records in TnQ's Blackboard system were reviewed. Richard Turk and Frank Terry left the NCUC during 2022. a. Steve Wood, Harry Bryant, Michelle Flowers, Hillary King, Brooks Tate, and Anna Williams have completed the training requirements for leading a Operator Qualification inspection. b. Steve Wood, Harry Bryant, Michelle Flowers, Hillary King, Brooks Tate, and Anna Williams has completed the required training to lead a Transmission Integrity Management Program inspection. Steve Wood, Harry Bryant, Michelle Flowers, Hillary King, Brooks Tate, and Anna Williams have completed the required training to lead a Distribution Integrity Management Program inspection. c. Harry Bryant, Michelle Flowers, Hillary King, Brooks Tate, Anna Williams and Steve Wood have completed the training requirements for leading a Standard Inspection of a LNG facility. d. All but one inspector have completed Root Cause training. e. No outside training. f. Harry Bryant, Michelle Flowers, John Hall, Hillary King, Brooks Tate, Anna Williams and Steve Wood have completed the training requirements for leading a Standard Inspection of gas pipeines. 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 5 Evaluator Notes: The program manager has work experience in gas distribution systems operations, twenty two years as a gas program inspector and state program manager. He has completed all of the required courses to lead Standard Inspections of gas pipelines and LNG facility. 3 General Comments: Info Only = No Points Evaluator Notes: There were no findings that resulted in the loss of points in Part C of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, 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 3 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: Needs Improvement. Two points are deducted. Inspection dates were reviewed for a random sample of operators and inspection units. The operators and units consisted of three Distribution operators covering 14 inspection units, one transmission operator covering one inspection unit and three LNG operators covering four inspection units for a total seven operators covering 19 inspection units. a. Standard inspections were completed within the five-year interval. b. Public Awareness Effectiveness inspection five-year interval for Cardinal Operating, a transmission operator, was not met. c. Drug and Alcohol plan inspections were completed within five- year interval requirement timeframe. d. Control Room Management inspections were completed within the five-year interval. e. LNG Standard inspections were completed within the five-year interval. f. Design and Construction inspection person days were 31% of total inspection person days. g. Operator Qualification Plan inspections for Shelby Gas Department, Toccoa Natural Gas System and Cardinal Operating Company did not meet the five-year requirement. h. DIMP inspections for Shelby Gas Department and Piedmont Natural Gas did not meet the five-year interval. TIMP inspections for Cardinal Operation Company did not meet the five-year interval. 2 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. 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) 10 10 Evaluator Notes: Inspection files were reviewed for a random sample of operators and inspection units. Files for CY2022 inspections of the operators on the randomly selected list were reviewed. The inspection forms appeared to cover all applicable code requirements but legacy Forms 1 and2 should be replaced with the IA equivalent forms for future transmission and distribution standrd inspections, respectively. All questions were documented as satisfactory, unsatisfactory, not covered or not applicable. Comments were provided for any questions that were marked unsatisfactory, not covered or not applicable. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 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: Protocol 9 requirements are covered during Design and Construction Inspections. Inspection dates were reviewed for a random sample of operators and inspection units. The NCUC inspections met the intervals required for Standard InspectionDUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 7

4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 0 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? Evaluator Notes: Needs Improvement. Two points were deducted. Inspection dates were reviewed for a random sample of operators and inspection units. The NCUC could not provide documentation that an annual DIMP review was conducted for Piedmont Natural Gas, one of the largest gas distribution operators in North Carolina. 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? Evaluator Notes: No issues. a. - e. NTSB recommendations in (a. - (e. covered in inspection forms. f. and g. NTSB recommendation in (f. and (g. covered on DIMP inspection form when covering threats. 2 2 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: The NCUC provided the Advisory Bulletin page that is included in the inspection checklist for Standard Inspections. Advisory Bulletins issued since the last inspection are discussed with the operator. 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 10 10 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 8

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 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: There were 22 probable violations found during CY2022. 21 Probable Violations were corrected during CY2022. Probable violations carried over from 2021 were corrected and closed per procedures. There were one probable violations carried over into 2023. a. - e. No issues. CY2017. the operators. h. Yes. i. and j. No issues found. f. No civil penalties were assessed in CY2022 for the 22 probable violations found. Civil penalties were last assessed during g. The Program Manager reviews, signs non-compliance letters and follows up until corrective actions are documented by 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? 10 10 Evaluator Notes: There were 10 reportable incidents during 2022. Three were on distribution systems and seven were on transmission systems. a. The NCUC has an adequate mechanism to receive and respond to incidents. b. The NCUC listing of incidents in a MSWord document matched the incidents in the PDM and the 2022 Progress Report. c. The NCUC investigated all 10 incidents on site. d. No issues. e. The NCUC agreed with contributing factors contained in operators' written reports. f. Recommendations were not appropriate in these incidents. g. Non-compliance was not identified in any of the incidents investigated. DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 9

h. No issues were identified. i. Yes, at the NCUC discussed the incidents that occurred in CY2022 during the NAPSR Southern Region virtual meeting in 2023. 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: There was no response required for the CY2020 Program Evaluation. 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: The NCUC is current with its pipeline safety seminars. 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: There is a question on the Standard inspection form that is completed during the inspection. 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: The NCUC website provides pipeline safety information that is accessible by all stakeholders. Also pipeline safety related cases can be reviewed by use of docket numbers. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no SRC reports during 2022. All are closed from prior years. There was one report submitted in 2023 (reported on 2/28/2023) that the NCUC failed to complete initial report in WMS but was out of the scope of this evaluation since it did not occur in CY2022. 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? 1 1 Evaluator Notes: a. There were no known instances where the NCUC did not respond to surveys or information requests. b. No issues requiring a loss of points were found with IM notifications. c. No issues with Integrity Management Notifications. A Safety Related Condition report was not reported during CY 2022. There was one report submitted in 2023 (reported on 2/28/2023) that the NCUC failed to complete initial report in WMS but was out of the scope of this evaluation since it did not occur in CY2022. 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: There are no open Waivers/Special Permits that have conditions requiring follow up. DUNS: 780414723 2022 Gas State Program Evaluation 1 1 North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 10

16 Were pipeline program files well-organized and accessible? Info Only Info Only Info Only = No Points Evaluator Notes: The NCUC was required by the administration to convert files into electronic format. The evaluation was conducted during the transition. Some inspection files were not found which impacted the documentation for five-year intervals found in Question D.1. 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: The SICT files in the PDM were reviewed along with feedback from the Peer Review. No deficiencies were noted that required improvement by the NCUC. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: The performance metrics in PRIMIS were reviewed. Excavation damages have trended downward to approximately 1.9 damages per 1000 tickets in CY2022. The NCUC continues to identify opportunities to reduce damages to pipelines. Inspection days per 1000 has trended in a positive direction with 14 inspection person days per 1000 miles achieved in CY2021. Inspection person days per Master Meter/LPG operator has remained constant at approximately 1 inspection person day per Master Meter/LPG operator but increased significantly to 6 inspection person days in CY2021 due to inspection interval scheduling. The percentage of staff completing required qualification training has averaged approximately 85% during CY2017 to CY2022 due to staff turnover. Leak repairs per 1000 miles has trended up over the last ten-year period but has trended downward in the most recent three years. Hazardous leaks which require immediate repair has trended downward in the most recent four years. Also notable is that the inventory of leaks scheduled for repair at the end of each year has trended slightly downward in the most recent four years with an uptick in 2020 and 2022. Enforcement and Incident Investigation has achieved 100% over the last ten years except for a drop in 2016. 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 Info Only Info Only Evaluator Notes: The NCUC has actively discussed PSMS with operators in North Carolina. The three large gas distribution operators and one large municipal have taken steps to implement PSMS into their operations. The NCUC is monitoring their efforts. The NCUC is currently promoting PSMS to the remainder of the municipal operators and has covered the topic during the pipeline safety seminar. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There were two points deducted on Question D.1 due to some inspections not meeting the five-year interval. There were two points deducted on Question D.4 due to NCUC not conducting an annual review of Piedmont Natural Gas's Distribution IMP, one of the largest distribution operators in North Carolina. Total points scored for this section: 46 Total possible points for this section: 50 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, 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. The NCUC conducted the field portion of a Standard inspection of Dominion Energy's (OPID 15938) T-30 transmission pipeline on September 28, 2023. b. April 29, 2022 c. Dominion was represented by Scotty Jordan, Transmission Supervisor. d. The NCUC inspectors were Ryan Duffy, new inspector, and Brooks Tate and Steve Wood. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the proper transmission standard inspection form was utilized. The form was used as a guide while conducting the inspection. 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: a. The Operator's procedures were reviewed prior to and during the inspection. There were no issues with the inspector's questions. All questions were determined to be appropriate for determining compliance with regulations and procedures. b. All records were reviewed and found compliant. c. The focus on this inspection was field testing of over-pressure protection facilities along with valve inspections and cathodic protection readings. No issues with testing equipment. d. No other items. e. Yes, the length was appropriate for the activities being performed on this day. 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: Ryan Duffy is a new inspector with the NCUC. He has considerable experience from working for a gas pipeline operator but has not received all of the training courses at PHMSA's Training and Qualifications Facility. He was assisted and mentored by Brooks Tate and Steve Wood, both who have more than adequate knowledge of the regulations. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 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 1 1 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 12

Evaluator Notes: The NCUC conducted an exit interview on 9/28/2023 at the conclusion of the inspection. PHMSA's evaluator was present during the exit interview. There were no probable violations found for the activities inspected on September 28, 2023. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only Info Only Info Only = No Points 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: a. The inspectors wore all necessary personal protection equipment, attended a safety presentation with the operator at the beginning of the inspection and potential hazards were avoided. b. Pipe specifications were noted, joining processes were observed, excavation and facility locating was observed. c. No best practices were noted that warranted sharing. d. None 7 General Comments: Info Only = No Points Evaluator Notes: There were no findings that resulted in the loss of points in Part E of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, 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: The NCUC provided a spreadsheet that summarized the its review during CY2022. The results included trend analysis of excavation damage and leaks in a spreadsheet. Trend charts are in the spreadsheet. No 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: Verification was completed during Damage Prevention Plan inspections in 2022. Reducing the possibility of recurrence is addressed in their TIMP/DIMP plans. Most operators are mitigating risks through their TIMP/DIMP and PA outreach plans. Larger operators conduct monthly meetings (through committees) that review monthly excavation damages. A NCUC inspector interacts with a company's damage prevention committee representative. The committee analyzes root causes of the monthly damages. Approximately once each three months, the NCUC Program Manager interacts with the operators individually to discuss what actions the operators are taking as a result of the monthly meetings. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 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: a. - e. The NCUC provided a spreadsheet titled "2010-2022 Excvtr Annual Operator Reports". The spreadsheet contains the information requested in parts a. - e. of this Question F.3. On a periodic basis discussions and evaluation of damage data occurs with an operator. All cause categories reported on the Annual Report are reviewed with the operators during Damage Prevention inspections in 2022. Locating practices are part of the inspections. f. 38% of damages caused by Locating Practices No Sufficient are due to mismarks. g. 62% of damages caused by Locating Practices No Sufficient are due to no-shows. h. and i. The NCUC covers mapping errors during Damage Prevention inspections. j. j. Yes. 35% of excavation damages were caused by excavation practices not insufficient in 2022. 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 2 2 DUNS: 780414723 2022 Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 14

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? Evaluator Notes: a. Telecommunications fiber construction has caused the most damages in NC in recent history. Stakeholder group data is compiled by each operator and varies by operator. These types of data were discussed with the operators during the 2022 Damage Prevention inspections. b. The operators and NC811 are both providing training for all excavators and put more effort in covering contractors for NCDOT and fiber companies. Utilities Coordinating Committee meetings communicate with representatives of the excavating community including NCDOT and fiber companies. Operator's focus on education and training with stakeholders causing most damage was addressed during the 2022 Damage Prevention inspections with operators. c. The reason
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