# 2013 NC NG Program Evaluation - nc2013ngprogramevaluation (North Carolina; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA nc2013ngprogramevaluation
- **title:** 2013 NC NG Program Evaluation - nc2013ngprogramevaluation (North Carolina; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-01-01
- **effective on:** Not available
- **summary:** 2013 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 2013 Natural Gas State Program Evaluation for NORTH CAROLINA UTILITIES COMMISSION 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: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 1

2013 Natural Gas State Program Evaluation -- CY 2013 Natural Gas State Agency: North Carolina Rating: Agency Status: Date of Visit: 10/20/2014 - 10/22/2014 Agency Representative: John Hall, Director, Pipeline Safety PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Edward S. Finley, Jr., Chairman Agency: North Carolina Utilities Commission Address: 430 North Salisbury Street City/State/Zip: Raleigh, North Carolina 27603-5918 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 2013 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 15 15 C Program Performance 44 42 D Compliance Activities 15 15 E Incident Investigations 7 7 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 111 109 State Rating................................................................................................................................................... 98.2 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No inaccuracies found in operators and inspection units. Office records matched the information. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspection person days were accounted for correctly. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Records verified the information on Attachment 3. Units on Attachment 1 matched the total number on Attachment 3. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 There were one incident reported by operators in 2013 which matched information in the Pipeline Data Mart. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Attachment 5. No inaccuracies found on Compliance Activities. Inspection report information supported the information entered into 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues needing improvement were found in the organization of office records. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Employees listed was accurate. TQ traininig records were uploaded to Attachment 7. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues were found with the adoption of amendments on Attachment 8. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) 1 1 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 3

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues with Attachment 10. 10 General Comments: Info Only = No Points Evaluator Notes: The NCUC complied with the requirements of Part A of this evaluation. DUNS: 780414723 2013 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 4

PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: year. 2 2 Standard inspections were covered in the inspection procedures. Each operator and unit are inspected once each calendar 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures cover IMP and DIMP. Intervals between inspections should be established. 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: inspections. 1 1 OQ inspections are covered in the inspection procedures. Intervals should be established for plan reviews and field 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage prevention inspections were covered in the inspection procedures. Damage Prevention are covered during standard inspections when covering 192.614. Each operator and unit are inspected once each calendar year. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On site training is scheduled on an as needed basis. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Construction inspections were covered in the inspection procedures. Construction inspections are scheduled as needed. 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Incident investigations are described in the inspection procedures. They are conducted as they occur. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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) DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 5

f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: The NCUC inspects each operator and unit once each year. The NCUC considers all of the factors above and analyzes risk factors to determine the priority of inspections within the calendar year. 9 General Comments: Info Only = No Points Evaluator Notes: The NCUC generally complied with the requirements of 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 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 6

PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 433.37 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.75 = 825.00 Ratio: A / B 433.37 / 825.00 = 0.53 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The NCUC exceeded the minimum ratio of 0.38 with a ratio of 0.53. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 3 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: The NCUC does not have an inspector that has completed all of the required Gas Transmission Integrity Management Program (TIMP) training courses. The NCUC conducted TIMP inspection during 2013 but did not have an inspector that met the training requirements to lead a TIMP inspection. Two points were deducted. The NCUC was notified in the CY2012 Program Evalution letters that this could be a potential issue for CY2013. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Mr. Hall has been in the program manager role for less than one year but was an inspector for over 23 years prior to being a program manager. He exhibited excellent knowledge of the regulations and managing a state program under PHMSA's certification. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC responded in 49 days. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: The last seminar was held in 2013. Three year requirement was met. 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 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 5 5 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 7

Evaluator Notes: The NCUC inspected all operators and units during 2013. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC utilizes the standard inspection federal forms for distribution and transmission to conduct inspections. OQ and Drug and Alcohol questions on standard forms are located on forms specific to those types. Compressor station questions are located on a compressor station form that covers both distribution and transmission. LNG inspections utilize the federal form. All federal code requirements appear to be covered. 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 (B7) Yes = 1 No = 0 Evaluator Notes: There is no cast iron pipe in service in North Carolina. This is verified in the Pipeline Data Mart. 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 (B8) Yes = 1 No = 0 Evaluator Notes: There is no cast iron pipe in service in North Carolina. This is verified in the Pipeline Data Mart. 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 (B9) Yes = 1 No = 0 1 1 Evaluator Notes: During its annual review of operator Operation and Maintenance Procedures, the NCUC has checked all operators' procedures to insure that leak repair procedures include this requirement. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 (B10,E5) Yes = 1 No = 0 Evaluator Notes: The NCUC reviews operators' records of incidents, leaks and failures when it covers 192.617 requirements as part of the standard inspection of an operator each year. The NCUC's standard inspection form includes a section on Part 192.617 requirements. The form is used for all annual standard inspections. Leak repairs is a key item reviewed and analyzed each year on operator's annual reports. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC reviews operators' annual reports each year. Operators are required to submit their annual reports to the NCUC in addition to PHMSA by March 15 of each year. The NCUC has entered data from operators' annual reports into spreadsheets that display the data over a period years. DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 8

13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues were identified with the timeliness of entering OQ and IMP results into the federal databases. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: This is covered in standard inspections while using the federal standard inspection form for transmission operators. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC did not conduct any Drug and Alcohol Plan reviews during 2013; however, the NCUC did verify random testing rates and verified operators' actions if any positive tests were experienced. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC reviewed operators' OQ programs for compliance within two years after the rule was published. During Standard Inspections, the NCUC condcucted Protocol Nine (field verification) inspections since the programs were reviewed. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC has completed the review of the IMP programs of all gas transmission pipeline operators. Inspections monitoring the progress of assessmentquestionins and the implementation of remedial actions have been conducted. The NCUC is refocusing with operators about decision processes to excavate and examine possible anomalies. 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 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: At the time of the evaluation all but three operators received inspections of their DIMP plans. These three are scheduled for completion prior to the end of 2014. DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 9

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 be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC completed all PAPEE inspections during 2012. 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC has page for pipeline safety on the Commission's web site. On its web page, the NCUC has posted summary information that it includes on Attachment 5 of the annual Progress Report. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were two safety related condition reports during 2013. One is closed and one is open. The NCUC followed up on the open report and communicated corrective action was completed. However, information in the Pipeline Data Mart indicates the SRC has not been closed. 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC encouraged operators to participate in the American Gas Association's (AGA) plastic pipe initiative by submitting failure information to the AGA's database. The NCUC has requested operators to monitor its plastic pipe mains and service lines for failures of the pipe and fittings. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was no information available that warranted a reduction in evaluation points. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified Info Only Info Only conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Info Only = No Points Evaluator Notes: The NCUC has nine waiver applications that were processed through the commission. The program manager is aware of those waivers and will follow up on the validity of the waivers. 25 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Question C.2 - The NCUC does not have an inspector that has completed all of the required Gas Transmission Integrity Management Program (TIMP) training courses. The NCUC conducted TIMP inspection during 2013 but did not have an inspector that met the training requirements to lead a TIMP inspection. Two points were deducted. The NCUC was notified in the CY2012 Program Evalution letters that this could be a potential issue for CY2013. DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 10

Total points scored for this section: 42 Total possible points for this section: 44 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 11

PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) 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 NCUC requires written notification be sent to an operator when a non-compliance is found. The NCUC procedures states that non-compliance notifications must be sent to a company officer. The NCUC requires that the operator respond in writing, within 30 days, describing its corrective action plans. A log is kept regarding the status of the inspection report. The NCUC follows up with operators until corrective action is completed. 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 (B11,B18,B19) 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: Upon a review of randomly selected 2013 inspection report files, all reports containing probable violations documented the actions or lack of actions that the operator took that caused the probable violations. The NCUC reviewed the responses to written notifications during 2013. All compliance notifications reviewed were responded to by the operator. All actions were acceptable to the NCUC and the reports were closed. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected 2013 inspection report files, all reports containing probable violations had compliance letters sent to the operators. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: 2 2 Operators are given the opportunity to respond to non-compliance notifications and provide evidence that a probable violation did not take place. An operator can petition for a hearing to present its case before the Commissioners of the NCUC. 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The program manager explained the authority for civil penalties, process for requesting show cause hearings and the factors considered for initiating civil penalty proceedings. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 780414723 2013 Natural Gas State Program Evaluation 1 1 North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 12

There were no probable violations found during 2013 that met the NCUC's criteria for the issuance of civil penalties. 7 General Comments: Info Only = No Points Evaluator Notes: The NCUC has generally complied with the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 13

PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: The NCUC communicated contact information and instructions to its operators. NCUC rules require that operators contact the NCUC directly when an incident is discovered. The NCUC also understands the cooperation with PHMSA that is required when an incident occurs. The NCUC is aware of the MOU between NTSB and PHMSA. 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: One reportable incident ocurred in 2013. The NCUC sent two inspectors on site to investigate the incident. 1 NA 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) 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: The NCUC utlizes PHMSA's incident investigation form to document investigations on site. The form contains Observations, Factors and Recommendations. It is recommended that the NCUC write a formal report that details the Observations, Factors and Recommendations. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: No probable violations resulted from the investigation of the one incident in North Carolina. 1 NA 5 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues were identified with the NCUC's follow up actions. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: Yes. The NCUC presented incident information at the Southern Region meetings. 1 1 7 General Comments: DUNS: 780414723 2013 Natural Gas State Program Evaluation Info Only Info Only North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 14

Info Only = No Points Evaluator Notes: The NCUC generally complied with the requirements of Part E of this evaluation. Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 15

PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This item is covered when the NCUC conducts a review of operators' Operation and Maintenance Procedures that are required under 192.605. The NCUC uses an inspection form that is derived from the federal inspection which covers this requirement. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This area is covered when the inspector is completing the Standard Inspection form in the section reviewing operators' damage prevention programs required by 192.614. Locating records are reviewed when the NCUC conducts a standard inspection of pipeline operators. 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC encourages operators to adopt and support implementation of best practices in their operations and other stakeholders such as the state's One Call System. The NCUC works closely with the One Call System. The NCUC staff participate in local utility coordinating committee meetings that are sponsored by the North Carolina One Call System. The NCUC supported legislation to improve its damage prevention law. The North Carolina damage prevention law was revised in 2013 with significant improvements. The NCUC promoted the Common Ground Alliance Best Practices document with operators. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Operators are now required to report damages on the federal annual reports. The NCUC is utilizing information compiled by NC 811 (One Call Center). This information is reviewed for trends and focus areas (on a county basis) for improvement. 5 General Comments: Info Only = No Points Evaluator Notes: The NCUC has generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 16

PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Piedmont Natural Gas Name of State Inspector(s) Observed: Steve Woods - Lead Inspector and Anna Williams - Assisting Location of Inspection: 2611 Greengate Dr., Greensboro, NC 27406 Date of Inspection: 10/22/2014 Name of PHMSA Representative: Don Martin Evaluator Notes: Info Only Info Only One day of a Standard Inspection focused on the testing of overpressure protection equipment that was randomly selected. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Two weeks notice was confirmed by the operator. 1 1 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The standard insepction form developed from the federal for was utilized. The focus of the inspection was observing overpressure equipment testing. The portion of the form covering this area was used. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: documented. Yes. The NCUC uses worksheets to capture the results of the overpressure protection inspection. The worksheet was being 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.) (F5) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. Pressure testing equipment was reviewed by the inspector to verify the appropriateness for the tasks involved. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: During the day of the evaluation observation field activities were being conducted. Inspecting overpressure protection equipment and visually observing signs, markers, right of way and atmospheric corrosion. DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 17

7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues were identified with the knowledge of Mr. Woods. Mr. Woods has been an inspector for over ten years and was employed by an operator prior to the NCUC. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: There were no probable violations discovered which was communicated to the operator's representatives. There were some recommendations provided. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: It was stated none were found on this day. 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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 Info Only Info Only DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 18

D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The areas covered were limited in scope. The primary focus involved inspecting overpressure protection equipment with secondary observations of signs, markers, right of way and atmospheric corrosion. No issues were found during the observation of the inspection on 10/22/2014. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 19

PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 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? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The NCUC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 780414723 2013 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 20

PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a 60106(a agreement with PHMSA. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a 60106(a agreement with PHMSA. 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NC
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