FREEPORT LNG DEVELOPMENT, L.P. — Safety Order

420193002S_Consent Order and Agreement_02142020_text.pdf, page 1Official PDFFebruary 14, 2020 Mr. Michael S. Smith Chairman and Chief Executive Officer Freeport LNG Development, LP 333 Clay Street Suite 5050 Houston, Texas 77002 Re: CPF No. 4-2019-3002S Dear Mr. Smith: Enclosed please find the Consent Order issued in the above-reference case, incorporating the terms of the fully executed Consent Agreement that resolves the issues underlying the Notice of Proposed Safety Order issued by PHMSA on August 27, 2019. Your receipt of this Consent Order constitutes service, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosures (Consent Agreement and Order) cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Shaw C. Ottis, Vice President and Deputy General Counsel, Freeport LNG Development, LP, 333 Clay Street, Suite 5050, Houston, Texas 77002 Mr. Mark W. Mallett, Senior Vice President – Operations and Projects, Freeport LNG Development, LP, 333 Clay Street, Suite 5050, Houston, Texas 77002 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Freeport LNG Development, LP, ) CPF No. 4-2019-3002S ) ) ) Respondent ) ____________________________________) CONSENT ORDER By letter dated August 29, 2019, the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Freeport LNG Development, LP (FLNG). In response to the Notice, Respondent requested an informal consultation, whereupon the parties engaged in good-faith settlement discussions that have resulted in the Consent Agreement attached to this Order that settles all of the allegations in the Notice. Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this Order. FLNG is hereby ordered to comply with the terms of the Consent Agreement, effective immediately. Pursuant to 49 U.S.C. 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil penalties as set forth in 49 C.F.R. § 190.223. The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. February 14, 2020 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 3DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION ) In the Matter of ) ) Freeport LNG Development, L.P., ) CPF No. 4-2019-3002S ) Respondent ) ) CONSENT AGREEMENT On August 29, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Southwest Region, issued a Notice of Proposed Safety Order (Notice) to Freeport LNG Development, L.P. (Respondent), which operates a natural gas liquefaction and export facility on Quintana Island, Texas (the Export Facility). The Notice was issued after an August 1, 2019, incident at the Export Facility in which Respondent was performing a cool down operation as part of the steps to commission Train 1. Respondent experienced a failure when attempting to reduce the time required to properly cool down the facility. FLNG flowed high pressure chilled natural gas at approximately 917 pounds per share inch (psig) through bypass piping into 6” piping designed for a maximum operating pressure of 90 psig. The 6” line consequently failed near the branch weld that joined it with the bypass piping, which resulted in an unintended release of natural gas. The Notice alleged that conditions exist at Respondent’s Export Facility that might pose an integrity risk to public safety, property, or the environment. The Notice also proposed that Respondent take certain corrective measures to remedy the alleged conditions and ensure that the public, property, and the environment were protected from the potential risk. Respondent responded to the Notice by timely submitting a written response and request for an informal consultation. An informal consultation was held on October 17, 2019. As a result of the informal consultation, PHMSA and Respondent agreed that settlement of this proceeding will avoid further administrative proceedings or litigation of this Notice and that entry into a Consent Agreement is the most appropriate means of addressing the alleged conditions raised in the Notice and is in the public interest. Therefore, pursuant to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and agreement of Respondent and the PHMSA (the Parties), the Parties agree as follows: I. General Provisions 1. Respondent acknowledges that as the operator of the Export Facility, Respondent and the Export Facility are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101 et seq. and the regulations and administrative orders issued thereunder. For purposes of this#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 4Consent Agreement, Respondent acknowledges that it received proper notice of the PHMSA’s action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101 et seq. and the regulations and orders issued thereunder. 2. Respondent does not admit or deny any of the alleged conditions or risks identified in the Notice but agrees, for purposes of this Consent Agreement, to address the alleged conditions and risks identified in the Notice by completing the actions specified in Part II of this agreement (Corrective Measures) and to abide by the terms of this Consent Agreement. This Consent Agreement does not constitute a finding of violation of any Federal law or regulation and may not be used in any civil or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this Consent Agreement. 3. After Respondent returns this signed agreement, the PHMSA’s representative will present it to the Associate Administrator for Pipeline Safety recommending that the Associate Administrator adopt the terms of this agreement by issuing an administrative order (Consent Order) incorporating the terms of this Consent Agreement. The terms of this agreement constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate Administrator will issue a Consent Order incorporating the terms of the agreement. 4. Respondent consents to the issuance of the Consent Order, and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all the rights to contest the adequacy of notice, or the validity of the Consent Order of this Consent Agreement, including all rights to administrative or judicial hearings or appeals, except as may be set forth herein. 5. This Consent Agreement shall apply to and be binding upon the PHMSA, and upon Respondent, its officers, directors and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Consent Agreement and any incorporated work plans and schedules to all of Respondent’s officers, employees, and agents whose duties might reasonably include compliance with this Consent Agreement. 6. For all transfers of ownership or operating responsibility of Respondent’s Export Facility, Respondent shall provide a copy of this Consent Agreement to the prospective transferee at least 30 days prior to such transfer and simultaneously provide written notice of the prospective transfer to the PHMSA Southwest Region Director (Director) who issued the Notice. 7. This Consent Agreement constitutes the final, complete and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Consent Agreement, and resolves any claims that have been or could have been alleged regarding the events or circumstances described in the Notice. The Parties acknowledge that there are no representations, agreements, or understandings relating to the settlement other than those expressly contained in this Consent Agreement, except that the terms of this Consent Agreement may be construed by reference to the Notice. 8. Nothing in this Consent Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the Federal pipeline safety laws,#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 549 U.S.C. § 60101 et seq., and the regulations and orders issued thereunder. Nothing in this Consent Agreement alters the PHMSA’s right of access, entry, inspection, and information gathering or, except with respect to the matters expressly settled under this Consent Agreement, the PHMSA’s authority to bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal or State law. 9. This Consent Agreement does not waive or modify any Federal, State, or local laws or regulations that are applicable to Respondent’s Export Facility. This Consent Agreement is not a permit, or a modification of any permit, under any Federal, State, local laws or regulations. Respondent remains responsible for achieving and maintaining compliance with all applicable Federal, State, and local laws, regulations and permits. 10. This Consent Agreement does not create rights in, or grant any cause of action to, any third party not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Consent Agreement. Respondent agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents and representatives from any and all causes of action arising from any acts or omissions of Respondent or its contractors in carrying out any work required by this Consent Agreement. 11. by PHMSA. The terminology “after the Agreement” shall mean after the Consent Order is issued II. Corrective Measures 12. Upon issuance of the Consent Order, Respondent agrees to perform the Corrective Measures set forth below. 13. Procedures Evaluation. Within 30 days after the Agreement, Respondent shall submit, for approval by the Director, the name of the proposed third-party that FLNG intends to use for the procedures evaluation. Within 60 days after receiving approval, Respondent shall evaluate, using the third-party, the current operations and maintenance manual and training requirements associated with personnel responsible for operations within the newly constructed FLNG Export Terminal. The review must include whether the procedures have adequate details, safety provisions, and instructions to properly implement the procedures. The evaluation must also include a determination that the roles and responsibilities of all personnel are clearly defined for each task and the level(s) of required approvals are clearly stated. The evaluation must also prescribe mandatory training requirements for the procedures and any re-training requirements that are needed as a result of the August 1, 2019 incident or revisions to the procedures that result from the evaluation. After completion, the procedures evaluation must be submitted to the Director for review and acceptance. 14. Procedures Revisions. Within 90 days of completion of Item 13 and acceptance by the Director, Respondent shall complete the procedures revisions and training identified by the evaluation and submit to the Director for review and acceptance.#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 615. Complete Inventory. Within 30 days after the Agreement, Respondent shall submit to the Director (or designees of the PHMSA Southwest Region) a complete inventory of piping installed in the Export Facility using all Heat Numbers associated with failed 6-inch and 2-inch piping, including but not limited to Heat Number 301881, manufactured by Salzgitter Mannesmann Stainless Tubes France. The documentation shall include, for each piping segment, P&ID’s showing the locations of all identified piping, manufacturing specifications, lengths, diameters, wall thicknesses, and specified minimum yield strength (SMYS), intended service (e.g., natural gas, LNG, refrigerant), maximum design pressures, and normal operating pressures. 16. Records Evaluation. Within 30 days after the Agreement, Respondent shall submit to the Director a tabulation showing results of an evaluation of materials properties of all Heat Numbers associated with the failed 6-inch and 2-inch piping, including but not limited to Heat Number 301881, manufactured by Salzgitter Mannesmann Stainless Tubes France SAS. This evaluation shall include a review and tabulation of the shop fabrication and site installation documentation, including materials specifications, MTR data, NDE reports, PMI reports and pressure test records. 17. Remedial Work Plan. Within 90 days after completing Items 13, 14, 15, 16, 18 and 19, FLNG must prepare and submit a Remedial Work Plan (RWP) to the Director for approval prior to commencing any work specified by the RWP. The remedial work plan must include actions to implement any actions and remedy any issues identified by Items 13, 14, 15, 16 and 19. The RWP must also include actions to remedy any other Identified Risk Conditions determined by the failure analysis and/or internal investigation of the incident. This may include, but is not limited to, removal of all substandard piping, fittings, and appurtenances. An Identified Risk Condition includes (1) performing any operation without an approved procedure; and (2) use of piping materials, fittings, and appurtenances that do not meet design specifications. a. The Director may incrementally approve parts of the RWP without approving the entire RWP. b. Once approved by the Director, the approved RWP increments or entire RWP is considered incorporated by reference into this Safety Order or Consent Agreement. c. The RWP must specify the tests, inspections, assessments, evaluations, and remedial measures FLNG will use to verify the integrity of the piping material, fittings and appurtenances. It must address all known or suspected factors and causes of the August 1, 2019 failure. d. The RWP must include provisions for the following: 1. Integrate the results of the metallurgical testing, failure analysis, and other corrective actions required by this Agreement with all relevant pre- existing operational and assessment data for the Identified Risk Condition. Pre- existing operational data includes, but is not limited to, construction, operations, maintenance, testing, repairs, prior metallurgical analyses, and any third-party consultation information. 2. Determine if conditions similar to those contributing to the failure on August 1, 2019, are likely to exist elsewhere within the Export Terminal. 3. Conduct additional field tests, inspections, assessments, and/or evaluations to determine whether, and to what extent, the conditions associated with the#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 7failure on August 1, 2019, are present elsewhere within the Export Terminal. At a minimum, this process must consider all failure causes and specify the use of mechanical and metallurgical testing, pressure testing, or other tests, inspections, assessments, and evaluations appropriate for the failure causes. Note: FLNG may use the results of previous tests, inspections, assessments, and evaluations if approved by the Director, provided the results ofthe tests, inspections, assessments, and evaluations are analyzed with regard to the factors known or suspected to have caused the August 1, 2019, failure. 4. Describe the inspection and repair criteria Respondent will use to prioritize, evaluate, and repair anomalies, imperfections, and other identified integrity threats. Include a description of how any defects will be graded and a schedule for repairs or replacement. 5. Based on the known history and condition of affected piping and components included in the Identified Risk Condition, describe the methods Respondent will use to repair, replace, or take other corrective measures to remediate the conditions associated with the pipeline failure on August 1, 2019, and to address other known integrity threats to the piping material, fittings and appurtenances. Any testing showing that any pipes do not have the strength and mechanical properties represented by the design specifications will require such piping be replaced, additional testing in additional locations to confirm the piping not identified for removal meets such design specifications, or other remediation of the noncompliance to the satisfaction of the Director. The repair, replacement, or other corrective measures must meet the criteria specified in Item 17(d)(4) above. 6. Define and implement continuing long-term periodic testing and integrity verification measures to ensure the ongoing safe operation of the Export Terminal considering the results of the analyses, inspections, evaluations, and corrective measures undertaken pursuant to the Agreement. e. Include a proposed schedule for completion of the RWP. f. Respondent must revise the RWP as necessary to incorporate new information obtained during the failure investigation and remedial activities, to incorporate the results of actions undertaken pursuant to this Agreement, and/or to incorporate modifications required by the Director. 1. Submit any plan revisions to the Director for prior approval. 2. The Director may approve plan revisions incrementally. g. Implement the RWP as it is approved by the Director, including any revisions to the plan.#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 818. Mechanical and Metallurgical Testing Protocols. Within 30 days after completing Items 15 and 16 of this Agreement, FLNG must prepare and submit mechanical and metallurgical testing protocols to the Director for approval prior to any sample removal or testing. At a minimum, the protocols must include the following: a. Procedures for the chain-of-custody for all parties handling, transporting or otherwise taking possession of the piping sample to be tested, including Respondent, its contractors, transporters, consultants and the materials testing laboratory b. Provisions for testing to be performed with PHMSA representative(s) present. Respondent must provide to the Director, the date, time and location of the testing and confirm availability of PHMSA inspector to be present during removal of test samples and mechanical/metallurgical testing. c. Visual and optical stereomicroscope examination, scanning electron microscope (SEM) examination, energy dispersive X-ray spectroscopy (EDS) microanalysis, metallographic examination, chemical composition analysis using optical emission spectroscopy (OES), and mechanical testing via a longitudinal full wall thickness tensile test, longitudinal and transverse Charpy V-notch (CVN) impact test and microhardness test. d. Destructive and non-destructive testing of both the pipe body material and associated welds. 19. Mechanical and Metallurgical Testing of Pipe Samples and Welds. Within 60 days after completing Item 18, Respondent shall perform additional mechanical and metallurgical testing on a statistically significant number of specimens. The following will be performed as part of the additional testing: a. b. c. d. e. Documentation of the chain-of-custody for all parties handling, transporting or otherwise taking possession of the piping sample to be tested, including Respondent, its contractors, transporters, consultants and the materials testing laboratory. Prior to the testing, the mechanical and metallurgical testing protocol shall be approved by the Director. Prior to the mechanical and metallurgical testing, provide the Director with the scheduled date, time and location of the testing to allow an opportunity for a PHMSA representative to witness the testing. Performance of visual and optical stereomicroscope examination, non-destructive evaluation of welds, scanning electron microscope (SEM) examination, energy dispersive X-ray spectroscopy (EDS) microanalysis, metallographic examination, chemical composition analysis using optical emission spectroscopy (OES), and mechanical testing via a longitudinal full wall thickness tensile test, longitudinal and transverse Charpy V-notch (CVN) impact test and microhardness test. Distribution of all analysis and reports, whether draft or final and in their entirety, to the Director at the same time they are made available to Respondent.#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 920. Verification of Safeguards. Within 30 days after the completion of all requirements in the RWP, Respondent shall submit to the Director a written summary of the revisions to the applicable cooldown procedures, P&ID’s, and evidence of implementation for the purpose of creating procedural safeguards to prevent similar situations from occurring in the future. 21. Consent Order Documentation Report (CODR). Respondent must create and submit on a monthly basis, a CODR. The intent is for the CODR to summarize all actions taken and documentation created in performing the requirements of the Consent Order. The CODR must also identify any activities or documentation for the period reflected in previous report activities so the status of each item in the Consent Order is reflected in each report. When the Respondent has concluded all the required items in the Consent Order, it will submit a final CODR to the Director. This will allow the Director to complete a thorough review of all actions taken by the Respondent with regards to the Consent Order prior to approving the closure of the Consent Order. 22. The Director may grant an extension of time for compliance with any of the terms of the Consent Agreement upon a written request timely submitted demonstrating good cause for an extension. The Director shall respond in writing to any such request. 23. Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator are final. III. Review and Approval Process 24. With respect to any submission under Part II of this Consent Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or in part, the submission, (b) approve the submission on specified conditions; (c) disapprove, in whole or in part, the submission, or (d) any combination of the foregoing. If the Director approves, approves in part, or approves with conditions, Respondent will take all actions as approved by the Director, subject to Respondent’s right to invoke the dispute resolution procedures in Section IV with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Respondent with a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. IV. Dispute Resolution 25. The Director and Respondent will informally attempt to resolve any disputes arising under this Consent Agreement. If Respondent and the Director are unable to informally resolve the dispute within 15 days, Respondent may request in writing, within 10 days, a written determination resolving the dispute from the Associate Administrator for Pipeline Safety providing all information that Respondent believes is relevant to the dispute. If the request is submitted as provided herein, the Associate Administrator will issue a final determination in writing. The existence of a dispute and the PHMSA’s consideration of matters placed in dispute will not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this agreement during the pendency of the dispute resolution process except as agreed by the Director or the Associate Administrator in writing.#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 10V. Enforcement 26. This Consent Agreement, as adopted by the Consent Order, is subject to all enforcement authorities available to the PHMSA under 49 U.S.C. § 60101 et seq. and 49 C.F.R. Part 190. VI. Recordkeeping and Information Disclosure 22. Unless otherwise required by this Consent Agreement, Respondent agrees to maintain records demonstrating compliance with all requirements of this Consent Agreement for a period of at least 5 years following completion of all work to be performed. For any reports, plans or other deliverables required to be submitted to the PHMSA pursuant to this Consent Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by the PHMSA, covering part or all of the information required to be submitted to the PHMSA pursuant to this agreement in accordance with C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a statement specifying the grounds for each claim of confidentiality. The PHMSA determines release of any information submitted pursuant to this Consent Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or the PHMSA policies, and other applicable regulations and Executive Orders. VII. Effective Date 23. The “Effective Date” as used herein is the date on which the Consent Order is issued by the Associate Administrator incorporating the terms of this Agreement. Unless specified to the contrary, all deadlines for actions required by this Consent Agreement run from the Effective Date of the Consent Order. VIII. Modification 24. The terms of this Consent Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties. IX. Termination 25. This Consent Agreement terminates upon completion of all terms set forth in Part II (Corrective Measures) as determined by the Director. Respondent may request written confirmation from the PHMSA when this Consent Agreement is terminated and the Director will provide such confirmation. Nothing in this Consent Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. X. Ratification 26. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Consent Agreement and to execute and legally bind such#

420193002S_Consent Order and Agreement_02142020_text.pdf, page 11party to this document. 27. The Parties hereby agree to all conditions and terms of this Consent Agreement. For Respondent: _______________________________ Mark Mallett, Senior Vice President, Operations & Projects _______________________________ Date For the PHMSA: _______________________________ Mary L. McDaniel, Director, Southwest Region _______________________________ Date#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED August 29, 2019 Michael S. Smith Chairman & CEO Freeport LNG Development, L.P. 333 Clay Street Suite 5050 Houston, Texas 77002 CPF 4-2019-3002S Dear Mr. Smith: Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The Notice proposes that you take certain measures to ensure facility safety with respect to Freeport LNG Development, L.P.’s Export Facility located on Quintana Island, Texas. Your options for responding are set forth in the Notice. Your receipt of the Notice constitutes service of that document under 49 C.F.R. § 190.5. We look forward to a successful resolution to ensure liquefied natural gas facility safety. Please direct any questions on this matter to me at (713) 272-2847. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Notice of Proposed Safety Order cc: Mr. Alan K. Mayberry, Associate Administrator for Pipeline Safety, OPS, PHMSA Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS, PHMSA#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 2Mr. Mark Roscoe, FERC Regulatory Compliance and Warranty Manager, Freeport LNG Development, L.P. Mr. Michael Stephenson, Regulatory Compliance Superintendent, Freeport LNG Development, L.P. Mr. Mark Mallet, Vice President, Operations & Engineering, Freeport Development, L.P. 2#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 33 DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY ____________________________________ In the Matter of ) Freeport LNG Development, L.P., ) CPF No. 4-2019-3002S ) ) ) Respondent ) ____________________________________) NOTICE OF PROPOSED SAFETY ORDER Background and Purpose Pursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has initiated an investigation of the safety of Freeport LNG Development, L.P.’s (FLNG or Respondent) Quintana Island Export Facility following an August 1, 2019, unintended release of natural gas after a piping failure occurred during commissioning. As a result of the investigation, it appears that a condition exists on your liquefied natural gas (LNG) facility that poses a pipeline integrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(l), PHMSA issues this Notice of Proposed Safety Order, notifying you of the preliminary findings of the investigation, and proposing that you take measures to ensure that the public, property, and the environment are protected from the potential risk. Preliminary Findings • The FLNG Export Facility is located on Quintana Island, Texas. The Export Facility includes three parallel liquefaction trains (Trains 1, 2, and 3). Each train is capable of producing approximately 4.4 million metric tons per annum of LNG for export, which equates to a total liquefaction capacity of approximately 1.8 billion cubic feet per day of natural gas. • The FLNG Export Facility is located in a maritime region adjacent to the Gulf of Mexico, experiences high humidity throughout a major portion of the year, and is subject to tropical storms and hurricanes. The land used to construct the FLNG Export Facility is on Quintana Island separated from the main portion of Freeport, Texas by the Gulf Intracoastal Waterway (GIWW). The FLNG site is low-lying with little elevation difference from the surrounding water and had to be stabilized prior to construction.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 44 • The FLNG Export Facility is located within an ecologically sensitive area and is also near recreational areas that include beaches and waterways used by the public. Additionally, the facility is located on the GIWW. The GIWW stretches from St. Marks, Florida to Brownsville, Texas. It is the nation’s third busiest waterway with the Texas portion handling over 58 percent of its traffic. • The 2010 U.S. Census reported Quintana, Texas had a population of 56. Freeport, Texas, which is just across the GIWW from Quintana, has a population of approximately 12,000 residents. Being on the Gulf of Mexico, the area also attracts recreational visitors and is close to Surfside Beach and Bryan Beach State Park. • On August 1, 2019, FLNG was performing a cool down operation as part of the steps to commission Train 1 of the newly constructed liquefaction facility. FLNG experienced a failure when attempting to reduce the time required to properly cool down the facility. FLNG flowed high pressure chilled natural gas at approximately 917 pounds per square inch (psig) through bypass piping into piping designed for a maximum operating pressure of 90 psig. The bypass line consequently failed around the area where a branch weld joined the pipes. The failure of the bypass line resulted in an unintended release of natural gas. • FLNG was in the process of a cool down operation that was outside the design parameters of the system. • FLNG informed the Federal Energy Regulatory Commission (FERC) of the event the same day, August 1, 2019. FERC notified PHMSA, Office of Pipeline Safety (OPS), Southwest Region staff of the event on August 6, 2019. PHMSA began its initial onsite investigation on August 7, 2019. FLNG did not make notification of the incident to the National Response Center. • FLNG’s preliminary investigation revealed that the piping was subjected to vibration as a result of this operation. A third-party forensic laboratory analysis concluded that there were potential issues with the characteristics of the weld and the failed segment of piping had a “lean chemistry.” Samples tested for materials verification also indicated the ultimate tensile strength was below the manufacturing standard for piping intended for service subject to 49 CFR Part 193. The failed piping was manufactured by Salzgitter Mannesmann Stainless Tubes (Salzgitter Mannesmann). PHMSA acquired documentation from FLNG indicating there may be approximately 1,408 feet of 6-inch piping from Salzgitter Mannesmann’s Heat Number associated with the failed piping installed at various locations throughout the FLNG facility • FLNG continues to operate the liquefaction train; the liquefaction facility may contain similarly flawed piping that does not meet design specifications. • The failed piping was seamless stainless-steel pipe manufactured to ASTM/ASME SA312 TP 304/304L Heat No: 301881; Manufactured by Salzgitter Mannesmann in Montbard, France.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 55 • FLNG reported the incident resulted in a release of approximately 315,000 cubic feet of natural gas. • FLNG provided PHMSA with a failure analysis report conducted by the third party forensic laboratory capturing the results of mechanical and chemical testing. The report found the fracture surface exhibited signs of brittle fracture possibly indicating that the material and/or weld did not possess the characteristics required for cryogenic service. Proposed Issuance of Safety Order Section 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after reasonable notice and the opportunity for a hearing, requiring corrective measures, which may include physical inspection, testing, repair, or other actions, as appropriate. The basis for making the determination that an LNG facility1 has a condition or conditions that pose a pipeline integrity risk to public safety, property, or the environment is set forth both in the above-referenced statute and 49 C.F.R. § 190.239, a copy of which is enclosed. After evaluating the foregoing preliminary findings of fact and considering the hazardous nature of the product, the temperature and pressure conditions required by the process, the characteristics of the geographical area where the LNG facility is located, the circumstances that resulted in the failure, and the likelihood that the issues could affect the safety of other areas of the LNG facility, it appears that continued operation of the affected LNG Facility without corrective measures may pose an integrity risk to public safety, property, or the environment. Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the proposed issuance of a safety order and to propose that Respondent take measures specified herein to address the potential risk. Response to this Notice In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written response to the official who issued the Notice. If you do not respond within 30 days, this constitutes a waiver of your right to contest this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Safety Order. In your response, you may notify that official that you intend to comply with the terms of the Notice as proposed, or you may request that an informal consultation be scheduled (you will also have the opportunity to request an administrative hearing before a safety order is issued). Informal consultation provides you with the opportunity to explain the circumstances associated with the risk conditions alleged in the notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to your position in any subsequent hearing. If you and PHMSA agree within 30 days of informal consultation on a plan and schedule 1 Section 190.239 applies to “a particular pipeline facility [that] has a condition or conditions that pose a pipeline integrity risk to public safety, property, or the environment.” An LNG facility is defined in § 193.2007 as “a pipeline facility that is used for liquefying natural gas or synthetic gas or transferring, storing, or vaporizing liquefied natural gas.” Therefore, LNG facilities are subject to § 190.239.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 66 for you to address each Identified Risk Condition, we may enter into a written consent agreement (PHMSA would then issue an administrative consent order incorporating the terms of the agreement). If a consent agreement is not reached, or if you have elected not to request informal consultation, you may request an administrative hearing in writing within 30 days following receipt of the Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with § 190.239, the Associate Administrator may issue a safety order Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). In your correspondence on this matter, please refer to CPF 4-2019-3002S and for each document you submit, please provide a copy in electronic format whenever possible. Proposed Corrective Measures Pursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, PHMSA proposes to issue to FLNG a safety order incorporating the following remedial requirements with respect to its Export Facility located on Quintana Island, Texas: 1. 2. Complete Inventory. Within 30 days of the date of the Safety Order, FLNG must submit to the Director, Southwest Region (Director), a complete inventory of piping installed in the liquefaction project using the Heat Number(s) associated with the failed 6-inch piping, including, but not limited to Heat No. 301881, manufactured by Salzgitter Mannesmann Stainless Tubes France SAS. The documentation must include for each segment, the P&ID designation, intended service, design and operating pressures. Records Verification. Within 60 days of the date of the Safety Order, FLNG must submit to the Director a complete evaluation showing the material properties of all inventoried piping and components meet the design specifications. This evaluation must list all pipe segments and components, the location of the pipe segment or component cross-referenced to a piping drawing, the identification numbers (heat and joint or component number), the length, diameter, specified minimum yield strength, wall thickness, service, the associated materials test report, and a statement verifying that each piping or component meets the design specifications. If there are any indications or uncertainty that a pipe segment or component may not meet the design specifications FLNG must replace the pipe segment or component or perform destructive testing of the materials in question in order to demonstrate that the required materials properties have been met.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 77 3. Mechanical and Metallurgical Testing. Within 30-days of date of the Safety Order, FLNG must complete additional mechanical and metallurgical testing and failure analysis of the failed 6-inch and branch connection. The testing and analysis, which must be conducted by an independent third-party entity, must include the following: a. Documentation of the complete chain-of-custody for all parties handling, transporting, or otherwise taking possession of the piping and components to be tested, including but not limited to FLNG, contractor(s), transporter(s), consultant(s), and the materials testing laboratory. b. Within 10 days of date of the Safety Order, develop and submit the mechanical and metallurgical testing protocol and the proposed third-party testing laboratory to the Director for approval prior to transportation to the testing laboratory and commencement of testing. c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the scheduled date, time, and location of the testing to allow for an OPS representative to witness the testing. d. Distribute all correspondence, analyses, and reports, whether draft or final, in their entirety, to the Director at the same time they are made available to FLNG. 4. Remedial Work Plan. Within 90 days following receipt of this Order, FLNG must submit a Remedial Work Plan (RWP) to the Director for approval. The remedial work plan must include actions to remedy any issues identified by Items 1, 2, and 3, above as well as any other Identified Risk Conditions determined by the failure analysis and/or internal investigation of the incident. An Identified Risk Condition is (1) operating without an approved procedure; and (2) use of piping materials that does not meet design specifications. This includes, but is not limited to, the circumstances that led the Operator to make the decision to operate the facility in manner inconsistent with the design and without proper operating procedures. a. The Director may incrementally approve parts of the RWP without approving the entire RWP. b. Once approved by the Director, the approved RWP increments or entire RWP is considered incorporated by reference into this Safety Order or Consent Agreement. c. The RWP must specify the tests, inspections, assessments, evaluations, and remedial measures FLNG will use to verify the integrity of the Export Terminal. It must address all known or suspected factors and causes of the August 1, 2019 failure. d. The RWP must include the following: i. Integrate the results of the metallurgical testing, failure analysis, and other corrective actions required by this Safety Order with all relevant pre- existing operational and assessment data for the Identified Risk Condition. Pre-existing operational data includes, but is not limited to, construction, operations, maintenance, testing, repairs, prior metallurgical analyses, and any third-party consultation information. ii. Determine if conditions similar to those contributing to the failure on August 1, 2019, are likely to exist elsewhere within the Export Terminal.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 85. 8 iii. Conduct additional field tests, inspections, assessments, and/or evaluations to determine whether, and to what extent, the conditions associated with the failure on August 1, 2019, are present elsewhere within the Export Terminal. At a minimum, this process must consider all failure causes and specify the use of pressure testing, or other tests, inspections, assessments, and evaluations appropriate for the failure causes. Note: FLNG may use the results of previous tests, inspections, assessments, and evaluations if approved by the Director, provided the results of the tests, inspections, assessments, and evaluations are analyzed with regard to the factors known or suspected to have caused the August 1, 2019, failure. iv. Describe the inspection and repair criteria FLNG will use to prioritize, evaluate, and repair anomalies, imperfections, and other identified integrity threats. Include a description of how any defects will be graded and a schedule for repairs or replacement. v. Based on the known history and condition of affected piping and components included in the Identified Risk Condition, describe the methods FLNG will use to repair, replace, or take other corrective measures to remediate the conditions associated with the pipeline failure on August 1, 2019, and to address other known integrity threats within the Export Terminal. The repair, replacement, or other corrective measures must meet the criteria specified in 6(d)(iv) above. vi. Implement continuing long-term periodic testing and integrity verification measures to ensure the ongoing safe operation of the Export Terminal considering the results of the analyses, inspections, evaluations, and corrective measures undertaken pursuant to the Order. e. f. Include a proposed schedule for completion of the RWP. FLNG must revise the RWP as necessary to incorporate new information obtained during the failure investigation and remedial activities, to incorporate the results of actions undertaken pursuant to this Safety Order, and/or to incorporate modifications required by the Director. i. Submit any plan revisions to the Director for prior approval. ii. The Director may approve plan revisions incrementally. g. Implement the RWP as it is approved by the Director, including any revisions to the plan. Procedure Evaluation. FLNG shall evaluate, using a third-party subject to the Director’s approval, the current operations and maintenance manual and the training requirements associated with personnel responsible for operations within the newly constructed Export Terminal. The review must include instructions to properly implement the procedures, and determine that roles and responsibilities are clearly defined. Mandatory personnel training must accompany all revisions to the procedures. This shall be completed within 90 days of the date of the Safety Order.#

420193002S_Notice of Proposed Safety Order_08292019_text.pdf, page 99 6. Reporting. Commencing on the date of the Safety Order, FLNG shall promptly report to the Director any unanticipated or sustained operation of other components of the plant outside their design parameters. Additionally, on a monthly basis, FLNG shall submit information regarding all available data and results of the testing and evaluations required in this Order, and describe the progress of all actions being undertaken pursuant to this Order. 7. Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. 8. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Safety Order and submit the total to Mary L. McDaniel, Director, Southwest Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies, and analyses, and 2) total cost associated with replacements, additions, and other changes to pipeline infrastructure. The actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive any requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal or state law. After receiving and analyzing additional data in the course of this proceeding and implementation of the RWP, PHMSA may identify other safety measures that need to be taken. In that event, Respondent will be notified of any proposed additional measures and, if necessary, amendments to the RWP or Safety Order. ___________________________________ __________________ Mary L. McDaniel, P.E. Date issued Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420193002S_Closure Letter_03102023_(15-150389S)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL March 10, 2023 Michael S. Smith Chairman and Chief Executive Officer Freeport LNG Development, LP 333 Clay Street, Suite 5050 Houston, Texas 77002 CPF 4-2019-3002S Dear Mr. Smith: On August 29, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), issued a Notice of Proposed Safety Order (Notice) to Freeport LNG Development, L.P. (FLNG). The Notice alleged that, as a result of an investigation into the unintended release of natural gas after a piping failure, a condition existed that the liquefied natural gas facility posed a pipeline integrity risk to public safety, property, and the environment. On February 14, 2020, PHMSA and FLNG entered into a Consent Agreement and Order (Agreement) to resolve the issues underlying in the Notice. On December 12, 2022, FLNG submitted a request for termination in accordance with Item 25 of the Agreement. PHMSA reviewed the responses provided to demonstrate compliance with the Agreement and determined that FLNG has completed the required corrective measures in the Agreement. This letter is to inform you that no further actions in this case are required, the Agreement is terminated, and this case is now closed. Thank you for your cooperation. Sincerely, Bryan Lethcoe Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Cc: Mark W. Mallett Sr. Vice President – Operations and Projects Freeport LNG Development, L.P. mmallett@freeportlng.com#

420193002S_Closure Letter_03102023_(15-150389S)_text.pdf, page 2Shaw Ottis Vice President, General Counsel and Secretary Freeport LNG Development, L.P. sottis@freeportlng.com Michael Stephenson Regulatory Compliance Manager Freeport LNG Development, L.P. mstephenson@freeportlng.com Andrew Kohout Director, Division of LNG Facility Reviews and Inspections Office of Energy Projects Federal Energy Regulatory Commission Andrew.Kohout@ferc.gov#