# 2022 NJ NG Program Evaluation - nj-2022-gas-program-evaluation (New Jersey; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA nj-2022-gas-program-evaluation
- **title:** 2022 NJ NG Program Evaluation - nj-2022-gas-program-evaluation (New Jersey; 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 New Jersey.
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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 NEW JERSEY BOARD OF PUBLIC UTILITIES 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: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 1

2022 Gas State Program Evaluation -- CY 2022 Gas State Agency: New Jersey Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 06/06/2023 - 06/08/2023 Agency Representative: Mr. Juan Urena, Bureau Chief NJBPU PHMSA Representative: Mr. David Lykken, Transportation Specialist, PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Joseph L. Fiordaliso, President Agency: New Jersey Board of Public Utilities Address: 44 S. Clinton Avenue City/State/Zip: Trenton, NJ 08625 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 45 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 95 State Rating................................................................................................................................................... 95.0 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, 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. Operator/Inspection Unit totals on Attachment 1 are consistent with the Operator/Inspection Unit totals on Attachment 3. b. No issues. C. No issues. Breakdown of Operators consistent with information found in the PDM. D. PDM shows 2 GD incidents. Matches PR under attachment 4. e & f No issues. g. Information verified through T&Q Blackboard training site. Training for personnel found to be complete and accurate. h. New amendments adopted up through 10/5/2022. PR scoring 50 pts. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, 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: a thru g. Sections 7.1 Types of Inspections, 7.2 Inspection Priorities, 7.3 Inspection Intervals, 7.4 Inspection Procedures, e: 5.2 Operator Training and/or Seminars. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: a thru f. 7.2 Inspection Priorities, 7.3 Inspection Intervals, 7.5 Inspection Documentation and Recordkeeping. Appendix B - List LDC Inspection Units and map provided noting unit breakdown and location. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 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 thru c. Section 8 Post-Inspection Evaluation and Enforcement 3 3 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: Section 9 Incident Investigation Procedures. The program receives operator incident notifications using a rotating on-call duty schedule. DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 4

5 General Comments: Info Only = No Points Evaluator Notes: No issues identified. No point deductions under Part B. DUNS: 189737682 2022 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: Yes. Staff who conducted all inspection types as Lead have completed the necessary T&Q Gas Core and Gas IM learning paths as required. A waiver has been approved for E. Weaver and A. Moses to perform IM inspections as leads while awaiting rescheduling of the T&Q ECDA course. Both are currently waitlisted. 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: Yes. Juan Urena has been with the pipeline safety program since 2014 and demonstrates sufficient knowledge of PHMSA programs and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part C. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, 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: Two-points deducted. Reviewed CY2022 inspection reports. The NJBPU was able to complete those outstanding inspections identified during last year's program evaluation. Missed program time intervals for the following operators/inspection types. TIMP: Elizabethtown Gas 12/27/22 & 12/13/2016; NJ Natural Gas 11/29/22 & 12/9/2016; South Jersey Natural Gas 12/19/22 & 12/29/16. PAPEI: South Jersey Gas & Elizabethtown Gas 11/1/22 & No Record of prior inspection; NJ Natural Gas 11/28/22 & No record of prior inspection; PSE&G 11/22/22 & No record of prior inspection. The program is expected to be caught up on inspections/intervals during by the end of the CY2023. 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 8 Evaluator Notes: Two-points deducted for not completing all applicable portions of TIMP inspection forms for 2 of the 4 IM inspections conducted in CY2022. PSE&G (12/30/2022) & New Jersey Natural (11/29/22). Forms either did not document inspection results and/or lacked necessary notes to explain N/A and N/C when checked. 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: No issues identified. Program policy is to complete a OQ review during most field inspections. Reviewed a random sampling of completed DT&C forms completed in CY2022. A total of 12 days were devoted to OQ activities. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 7

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: a-c: Yes. No issues. Four TIMP inspections conducted in CY2022. No DIMP inspections conducted. A total of 13.5 days were devoted to IM activities. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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: a: NJBPU Form GS-2 Corrosion Control, GS-9-PL Visual Construction - Question #18, GS-9-ST Visual Construction - Question #20 b: Form GS-3 Inspection & Maintenance Requirements Section B Question 4 c: Form GS-3 Section B Question 8.a.7. d: Form GS-3 Section B Question 8.b.10. e: GS-Form 25 Damage Prevention Program Inspection, Question 16. f: GS-Form 35 (PHMSA Form 22) - DIMP System Knowledge - Information Considered. g: Two operators currently replacing all remaining CI pipe and services. Insides meters are moved to the outside when possible. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued 1 0 since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: One-point deducted for not notifying/verifying with operators of PHMSA ADB-2022-1 (Potential Damage caused by earth movement). 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? 10 10 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 8

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: a thru j. Yes. No issues identified. All PV's identified in 2022 related to a single DT&C inspection resulting in issuance of a civil penalty. The program demonstrated its fining authority in CY2022 issuing and collecting a civil penalty in the amount of $318,250.00. Case number GS-22110688. Written notices typically sent to operators via email usually after completion of the exit interview meeting the 30 & 90-day requirement. 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: a: Telephone Notice of Gas Incidents mechanism in place to receive calls and emails (BPU.PipelineSafety@bpu.nj.gov). Bureau Chief and Assistant Bureau Chief typically receive operator reports and assign to staff inspector to investigate. b: Yes. c: Yes. d thru h: Yes. The program has demonstrated maintaining good communications with both PHMSA AID and the ER office. I: State of the State presentation at NAPSR Eastern Regional meetings and state operator seminars. 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 1 1 Evaluator Notes: State Programs letter out 9/1/2022. Response received on 10/17/2022. Items 1 & 3. Committed to hiring additional inspection staff in order to meet minimum inspection interval requirements. Item 2: Refresher training conducted to address completion of all applicable inspection form questions. Item 4: Re-training of inspection staff to ensure probable violations are handled appropriately form discovery to resolution. The program hired 2 new inspectors in CY2021, 3 in CY2022, and are expected to hire two additional in CY2023. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Info Only Info Only DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 9

Evaluator Notes: Yes. An operator seminar was conducted on 11/30/2022 in Edison, NJ. Reviewed agenda and participant roster. 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: Info Only Info Only Form GS-3 Section E, Question #4. Program inspectors also go to the NPMS site to verify operator submittals. 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: NVBPU website contains Pipeline Safety information found under the Reliability & Security page. The pipeline page provides links to Federal and State pipeline Safety regulations, Links to the four NG utility companies, NJBPU pipeline staff contact information, PHMSA State Page, NPMS, and NJPBU Bureau of Underground Damage Prevention. The program conducts quarterly meetings with the state's four gas LDC's. Quarterly meetings held prior to Covid-19 shutdown are expected to start up again later in 2022. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No new in CY2022. None currently open. Verified in the WMS. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: The program responded to 13 of 16 NAPSR surveys in CY2022. There were no IM notifications submitted in CY2022. Verified in the WMS. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No new in CY2022. Last issued in 2003. No longer active. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. No issues. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: Discussed past SICT estimates. The SICT is to be updated in July 2023. For CY2022, DT&C actual days were 486 (70.94%) of SICT estimated total days (685). Actual total program field days were 1036. DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 10

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: Discussed 2022 results. Pipeline damages per 1000 locate tickets up from CY2021. Now at approximately 2.0. The national average is 2.55. Significant increase in inspection days in CY2022 over past years devoted to MMO's. % Core Training at approximately 65%. 2 LDC's continue their CI replacement programs. Total mileage remaining at the end of CY2022 is 2915 miles, down from 3175 miles at the end of CY2021. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Yes. The four LDC's in the state have each adopted elements of RP 1173. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: established. conducted in CY2022. movement). Info Only Info Only D-1: Two-points deducted for not inspecting all types of operators/inspection units within the maximum time intervals D-2: Two-points deducted for not completing all applicable portions of TIMP inspection forms for 2 of the 4 IM inspections D-6: One-point deducted for not notifying/verifying operators of PHMSA ADB-2022-1 (Potential Damage caused by earth Total of five-points deducted under Part D. Total points scored for this section: 45 Total possible points for this section: 50 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the 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 Info Only Info Only Evaluator Notes: Observed a DT&C inspection of the Elizabethtown Gas 16-inch cast iron replacement project located in Union, NJ. This 3600 ft of CI is being replaced with 16-inch STW pipe. The company was present during this inspection. NJBPU inspector Mehnaz Moon has been with the pipeline safety program since 2018. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector utilized NJBPU form GS-9-ST for documenting inspection results. 2 2 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: Yes. No issues. Contractor job package was reviewed, discussed, and associated company written procedures on job site. Ms. Moon did a good job ensuring that construction personnel were qualified on all tasks observed including welding certifications. She observed the production of a 16-inch steel butt weld and inspected the quality of joint. Installation of a shrink sleeve on the completed weld joint was also observed. She checked the general condition of pipe materials and discussed with the job foreman the necessity for proper shading, backfill, depth of cover and the jeeping of pipe prior to lowering pipe segments into the trench. Equipment and associated appurtenances were checked for general condition as well as equipment calibration records. Site location visit was of appropriate length to determine compliance. 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 Evaluator Notes: Yes. Inspector demonstrated good knowledge of regulations and program specifics. 2 2 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 Evaluator Notes: A exit was conducted at the end of the inspection. No non-compliance or areas of concern's were identified. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? DUNS: 189737682 2022 Gas State Program Evaluation Info Only Info Only New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 12

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: Yes, Ms. Moon performed the inspection in a safe, positive, and professional manner. She observed specific activities of the replacement project as well as worker performance and qualifications to assure compliance with both state and federal regulations. 7 General Comments: Info Only = No Points Evaluator Notes: No issues identified. No point deductions under Part E. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, 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: Yes. No change from prior years. The state reviews Operator Annual reports, along with Incident/Accident reports for accuracy and analyzed data for trends and operator issues. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No change. The program verifies that the operators analyze excavation damages for the purpose of determining root causes and minimizing the possibility of recurrence. The operators must report to the Bureau of One-Call those excavators who repeatedly damage their facilities. The program discusses with the operators during the DIMP inspections the ways the steps the operator has taken to mitigate those risks. New form GS-25 Damage Prevention Program Inspections developed in 2023 to further assist in verifying operator analysis. 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: The program reviewing the operator's annual reports and evaluating causes for the damages. Shared and discussed details of CY2022 Excavation Damage worksheet. The New Jersey One Call Center tracks damages resulting from mismarks; locating within time requirements; mapping errors; and following written procedures. The information for reasons of excavation damages is discussed and recorded in the GS-35 DIMP inspection form, and as mentioned under question F.3 a new form GS-25 Damage Prevention Program Inspections has been created to further assist the program in verifying operator analysis. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? 2 2 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 14

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: No changes from prior years. The program collects data and evaluates trends on the number of pipeline damages per 1,000 locate requests. The New Jersey One Call Center host a Damage Prevention Seminar for the public and excavators monthly. The information for reasons of excavation damages is discussed and recorded in the GS-35 DIMP inspection form. 5 General Comments: Info Only = No Points Evaluator Notes: No issues. No point deductions under Part F. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: NJ BPU is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 189737682 2022 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 16
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