CHATTANOOGA GAS CO — Notice of Amendment

220063002M_Order Directing Amendment_05182006.pdf, page 1Official PDFU.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Pipeline and Administration Hazardous Materiais Safety MAY 18 2006 Ms. Jodi Gidley Vice President Gas Operations Atlanta Gas Light Company 10 Peachtree Place Atlanta, GA 30303 RE: CPF No. 2-2006-3002M Dear Ms. Gidley: Enclosed is the Order Directing Amendment issued by the Associate Administrator for Pipeline Safety in the above-referenced case. It makes a finding of inadequate procedures and requires that you amend your operations, maintenance, and emergencies procedures. When the terms of the Order are completed, as determined by the Director, Southern Region, OPS, this enforcement action will be closed. Your receipt of the Order Directing Amendment constitutes service of that document under 49 C.F.R. § 190.5. Sincerely, James Reynolds Pipeline Compliance Registry Office of Pipeline Safety Enclosure cc: • Ms. Linda Daugherty, Director, Southern Region, OPS CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

220063002M_Order Directing Amendment_05182006.pdf, page 2• DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, DC 20590 In the Matter of Atlanta Gas Light Company, CPF No. 2-2006-3002M Respondent. ORDER DIRECTING AMENDMENT On August 22-24, 2005, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), conducted an on-site pipeline safety inspection of Respondent's Chattanooga Gas Company liquified natural gas (LNG) plant plans and procedures. As aresult of the inspection, the Director, Southern Region, OPS, issued to Respondent, by letter dated January 19, 2006, a Notice of Amendment (NOA). In accordance with 49 C.F.R. § 190.237, the NOA alleged inadequacies in Respondent's operations, maintenance, and emergencies- procedures and proposed that Respondent amendment its procedures. On February 21, 2006, Respondent requested an extension of time to respond to the Notice. Respondent was granted fourteen days to submit a response to the Notice. Respondent responded to the NOA by letter dated, March 7, 2006 (Response). Respondent submitted amended Operations, Maintenance and Emergencies procedures. Respondent did not contest the NOA and did not request a hearing, consequently Respondent waived its right to one. The Southern Region reviewed the amended procedures. Respondent addressed five (5) of the eight (8) alleged inadequate procedures cited in the NOA. Although Respondent submitted amended procedures, these procedures do not address all of the inadequacies described in the Notice. Respondent advised that it is in the process of revising the other three inadequate procedures cited in the NOA. Accordingly, based on the results of this review, I find that Respondent's plant procedures are inadequate to ensure safe operation of its pipeline system. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237, Respondent is ordered to make the following revisions to its Operations, Maintenance and Emergencies procedures. Respondent must - Amend procedures to include a definition of safety related conditions, with adequate reporting time requirements and submission requirements that are consistent and in accordance with 49 C.F.R. § § 193.2605, 191.23 and 191.25.#

220063002M_Order Directing Amendment_05182006.pdf, page 3• 2 Amend procedures to include a definition of abnormal operating conditions and describe in sufficient details the actions to be taken in response to abnormal operating conditions, in accordance with 49 C.F.R. § 193.2503. Amend procedures to ensure that your emergency response procedures are consolidated and provide consistent guidance on how to respond to in the event of an emergency, in accordance with 49 C.F.R. § 193.2509. Submit the amended procedures to the Regional Director, Southern Region, OPS within 30 days following receipt of this Order Directing Amendment. The Regional Director may extend the period for complying with the required items if the Respondent requests an extension and adequately justifies the reasons for the extension. The terms and conditions of this Order Directing Amendment are effective upon receipt. Failure to comply with this Order may result in the assessment of civil penalties of up to $100,000 per violation per day, or in the referral of the case for judicial enforcement. MAY 18 2006 Stacey Gerard - Date Issued Associate Administrator for Pipeline Safety#