State of Colorado Public Utilities Commission — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. S E Washington. DC 20590 FEB 2 0 2009 Mr. Stephan Pott, PE Chief, Gas Pipeline Safety State of Colorado Public Utilities Commission 1560 Broadway, Suite 250 Denver, CO 80202 Ref. No.: PI-08-0010 Dear Mr. Pott: The Pipeline and Hazardous Materials Safety Administration (PHMSA) reviewed your December 11, 2008, letter transmitting an October 22, 2008, petition received by the Colorado Public Utilities Commission (CO-PUC) from DCP Midstream for a finding that the endpoint of the gathering designation for an intrastate gas pipeline should be extended beyond a gas processing plant. Specifically, DCP Midstream requested a finding that the gathering designation for a rural section of the ANGI intrastate pipeline be extended an additional 7.8 miles from the DCP Midstream Greeley Plant to the DCP Midstream Mewboum Gas Plant, both of which are located in Weld County, Colorado. Per 49 CFR § 192.8 (a)(2) and Section 2.2 (a)(I)(A) of API RP 80, DCP Midstream included documentation they feel demonstrates that extending the gathering designation an additional 7.8 miles from the Greely Plant to the Mewboum Plant was justified based on sound engineering principles. Additional correspondence with DCP Midstream determined the following: • The Greeley Plant separates the methane out and sells it there; the liquids are placed in tanks at the facility and eventually transported to the intended destination via truck. • The remainder of the gas, including 90% ethane, 5% methane, and 2% C02 is then transported to the Mewboum Plant for additional processing. • The normal operating pressure ofthe line is apPJ:oximately 300 psig, down to approximately 150 psig when delivered to the downstream plant Based on the information provided in DCP Midstream's petition, the additional correspondence, and your recommendation, PHMSA finds that extending the endpoint of the gathering designation for the ANGI gas pipeline an additional 7.8 miles to the Mewbome Plant is warranted as long as the current operating parameters and operating pressures remain the same. Accordingly, to the extent this condition is met, PHMSA grants the petition. IfDCP Midstream#

Page 2Mr. Stephan Pott, PE State of Colorado Public Utilities Commission -- ANGI Intrastate Pipeline Ref. No.: PI-08-0010 makes any significant changes to the operation of this line, such as increasing the pressure to where the ethane might be in a liquid super critical phase, DCP Midstream will be required to contact the CO-PUC and/or PHMSA's Western Region to make a new detennination. Sincerely, "--I Director, Office of Regulations#

Page 3PUBLIC UTiUTIES COMMISSION Department of Regulatory Agencies . -= D. Rico Munn • . . , Ron Binz, Chairman Executive Director i ~~ .,. James K. Tarpey, Commissioner • , • Matt Baker, Commissioner Doug Dean, Director Bill Ritter, Jr. Govemor December 9,2008 Mr. Jeffrey D. Wiese Associate Administrator for Pipeline Safety U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration, PHP-l East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 DEC 1 12008 RE: Petition for Review-DCP Midstream ANGI Pipeline On October 22, 2008 DCP Midstream, a gathering and processing company operating in several producing gas field in Colorado has, under § 190.9, petitioned the Public Utilities Commission (PUC), for a review of extending the endpoint of gathering beyond a processing plant. This request for review involves a rural 7.8 mile long pipeline system between the DCP Midstream Greeley and the Mewbourn Gas Plants located in Weld County, Colorado. Although § 190.9 was not adopted by the Public Utilities Commission, Pipeline Safety staff has reviewed the petition from DCP Midstream (attached) under the alternative PUC rule 4904,4 Code of Colorado Regulations (CCR) 723-4 Rules Regulating Gas Utilities and Pipeline Operators. This review does not address applicability of §40-1-1 03, C.R.S. or whether it is a Henshaw pipeline, and pertains only to pipeline safety regulations found under 4 Code of Colorado Regulations (CCR) 723-4 Rules Regulating Gas Utilities and Pipeline Operators. The endpoint of gathering, under § 192.8(a)(2) and API Recommended Practice (RP) 80, may not extend beyond the first downstream natural gas processing plant, unless the operator can demonstrate, using sound engineering principles, that gathering extends to a further downstream plant. This system was reviewed using guidelines found in API RP 80, a field review, and as required under § 192.8(a)(2) an analysis by the DCP Midstream engineering Department. 1560 Broadway, Suite 250, Denver, Colorado 80202, 303-894-2000 www.dora.state.co.uslpuc Fax 303-894-2065 TTY Users 711 (Relay Colorado) Transportation Fax 303-894-2071 Permit and Insurance (Outside Denver) 1-800-888-0170 Consumer Affairs (Outside Denver) 1-800-456-0858 Consumer Affairs 303-894-2070#

Page 4Mr. Jeffrey D. Wiese Page 2 December 9,2009 Under Rule 4904 the Chief of the PUC Gas Pipeline Safety section, has reviewed and agrees with the following facts: • DCP Midstream is aware of PUC rule 4952(c) as it applies to the ANGI pipeline. • The ANGI pipeline is a 7.8 mile long rural (Class 1 as defined under § 192.5) gathering line connecting the Greeley and Mcwbourn Gas Plants. • The ANGI system's method of construction and materials used has been reviewed by the DCP Midstream Director of Asset Integrity and maximum allowable operating pressure determined in compliance with § 192.619. • The request is consistent with the "gathering function" as described in RP-80 2.4.2. • The dethanizer residue gas stream components from the Greeley Gas Plant to the Mewboum Gas Plant is 98.68% ethane, propane, and carbon dioxide. • The gross dry heating value of the dethanizer residue gas stream from the Greeley Gas Plant at 14.65 psi a is 1764.3 BTU. • The Mewbourn Gas Plant is not a production treatment facility but is designed to treat, dehydrate, and process gas. • The Mewbourn Gas Plant is a defined and recognized gathering endpoint. • Raw, untreated gas from local producing natural gas wells flows directly into the ANGI pipeline, commingled, and final treatment, dehydration, and processing take place at the Mewbourn Plant. Final treated residue gas is sold to an intrastate and interstate pipeline. • Pipeline markers are located and maintained at each public road and railroad crossing in compliance with § 192.707(d) and PUC Rule 4952(c). Based on these factors I recommend that the request to designate the 7.8 mile ANGI pipeline system as a gathering pipeline as it applies to § 192.8(a)(2) be approved. :Si;4Wtr Stephan Port, PE Chief, Gas Pipeline Safety Cc: Mr. Chris Hoidal, Regional Director PHMSA Western Region#

Page 5dc::p Midstream", October 22, 2008 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Tracking Number 91 71082133393290942642 Steve Pott, Chief Colorado Public Utilities Commission 1560 Broadway, Suite 250 Denver, CO 80202 ZDLt) CC1 23 Hi 3: 21 Re: Classifying Gathering Line under 192.8(a)(2) DCP Midstream Weld County Gathering System Weld County, Colorado Dear Mr. Pott: DCP Midstream (DCP) is petitioning the Colorado Public Utilities Commission (PUC) for a review for approval under § 190.9 for extending the endpoint of gathering beyond the first processing plant as defined under § 192.8(a)(2). The following information has been attached to this letter in order to support this petition: 1) Schematic illustrating 6" line between Greeley Plant and Mewbourn Plant (Figure 1) 2) Gas Analysis of the ethane stream (showing CO2) 3) Analysis to identify regulated onshore gathering lines §192.8(b)(1) (DCP Form 45) DCP has evaluated this onshore gathering line using 49 CFR Part 192 and API RP 80 to determine if the specified line would qualify as an onshore gathering line in accordance with 49 CFR 192.8(a)(2). The enclosed information supports DCP's request to classify the 6-inch pipeline between the Greeley and Mewbourn plants as gathering. Figure 1 schematic describes the justification for two plants to complete the processing. DCP plans to take the ethane stream off of the Greeley plant process and transport the gas stream via the 6-inch pipeline to the inlet of the Mewbourn plant. This ethane stream will be commingled with the other gas gathered from the area and treated, dehydrated, and processed at the Mewbourn Plant as a combined stream. It is necessary to recombine the ethane stream with the other unprocessed gas because the stream contains approximately 2.5 mole percent CO2. DCP believes this is adequate engineering justification to classify the 6-inch pipeline as gathering and move the endpoint of gathering to the Mewbourn Plant.#

Page 6OCP is documenting the line and its current regulatory status as follows and on the attached documentation (Form 45). The usage of the line meets the criteria as defined in ~OT § 192.8 (a)(2): The endpoint of gathering, under section 2.2(a)(1)(A) of API RP 80, may not extend beyond the first downstream natural gas processing plant, unless the operator can demonstrate, using sound engineering principles, that gathering extends to a further downstream plant. The line is a 6" diameter steel pipeline, 0.188 w.t., grade X42 with a MAOP of 1,440 psi. The pipeline operates between 60% SMYS and is Class 1. OCP respectfully requests that the PUC review this packet as cited in DOT §190.9(a) to determine if this meets "sound engineering principles" to justify the further downstream plant as the endpoint of gathering: In circumstances where a rule contained in parts 192, 193 and 195 of this chapter authorizes the Administrator to make a finding or approval, an operator may petition the Administrator for such a finding or approval In addition, the PUC rule §4904 provides for this same interpretation process under the state rule. (a) An operator may request a regulatory interpretation of any of these rules by submitting a written request to the Chief The requestor shall include his or her return address and the specific application and rule reference with the request. If you have any questions regarding the regulatory justification for line, please do not hesitate to contact me at (303) 605-1979. Please direct your written response to OCP Midstream Jeannette Jones 370 1 ih Street, Suite 2500 Denver, CO 80202 Sincerely, ~~ Director - Asset Integrity OCP Midstream Attachments: OCP Midstream Onshore Gas Gathering Line Evaluation Forms Schematic of line (Figure 1) Gas Analysis of Ethane Stream (Greeley Plant) Cc: J. Kuchinski (OCP), T. Olin (OCP), C. Smith (DCP) Page 2of2#

Page 7DCP Form 45 c:lc::p Midstream. Gas Pipeline Maximum Allowable Operating Pressure and % of SMYS Calculations Record Retention: Completed MAOP Calculation Forms are kept all file with the asset/or the lif e of the pipelille and made available. upon request. for impecfiofl. Cells requiring user entry; Used to automatically calculate MAOP - Blue Cells with automatic calculations based on info provided - Yellow ~~~----~~~~--~~~~--~~~----------------------------~-------------------.------, PODS Pipeline Segment Name ..;;;B;.;;I ______________________________ _ Pipeline System ANGI Weld County ()perating Asset PODS Station Begin: ~~~~~~~~~~~~~ 40° 21' 49.10" N End: 104°44'8.03"W 40° 16'3.21"N Date Constructed (nunldd/yyyy) o r Gas Transmission Line (Complete Sections 3 and 5) r All transmission lines are regulated by DOT regardless of class location Designated Start and End Points for regulated segments must be either latitude/longitude coordinates, or stationing addresses. Regulated Start Point: __ __ Regulated End Point: P' Onshore Gas Gathering (Complete Sections 3, 4, and 5) r Offshore Gas Gathering (Complete Sections 3 and 5) r Tl - M D = 61-6 (in.) t = 0.1 (in.) S = 42 000 (psi) P'Steel (Complete Section 3A) r Plastic (Complete Sections 3B) Section 3A: Calculations for Steel Pipelines: Outside Diameter of Pipe: Nominal Wall Thickness of Pipe: Specified Minimum Yield Strength (SMYS) for Steel: S = 24,000 Grade Unknown S = 30,000 Grade A S = 35,000 Grade B S = 42,000 Grade X42 S = 46,000 Grade X46 S = 52,000 Grade X52 r Design Factor Override - check to override current class location and default to class 3 design factor Design Factor Used for Steel based on Class Location: F = 0.72 I F = 0.72 for Class 1 Locations F '" 0.50 for Class 3 Locations F '" 0.60 for Class 2 Locations F '" 0.40 for Class 4 Locations Longitudinal Joint Factor (Using § 192.113): E= E '" 1.0 for Seamless, ERW, or DSA W E = 0.8 for other pipe manufactwing specification and pipe>4 inches E = 0.6 for furnace butt-weld E = 0.6 for other pipe manufactwing process and pipe 4 inches or less to I Temperature Derating Factor (Using § 192.115): T = 1.000 for 250 OF or less T = 0.967 for 300 OF T '" 0.933 for 350 O F T = T = 0.900 for 400 O F T = 0.867 for 450 OF DCP Form 45 §192.603(b) Page 1 of 3 Rev 3 June 2007#

Page 81,716.3 I(psig) 2,018.181(psig) [ 2.22o.o l(psig) HTFIL--_I_ .lo--,I DCP Form 45 c:Jcp Gas Pipeline Maximum Allowable Operating Pressure and % of SMYS Calculations Midstream_ Compare 1 - 5 to define lowest MAOP: 2 SI I. Design MAOP = x F x E x T D 2. TestMAOP = Hydrates, prf}!!ure HTF Hydrotest Pressure* .. Corrected test pressure at maximum elevation (lowest pressure) in test section. Where HTF= hydrotest factor detcnnincd under § 192.619(a)(2) (Use §192.619(a)(2» summarized below for HTF: Segment Segment Class Installed before Installed after Converted under Location (Nov 12, 1970) (Nov 12, 1970) §192.15 1 1.10 1.10 1.25 2 1.25 1.25 1.25 3 1.40 1.50 1.50 4 1.40 1.50 1.50 3. Operating Limited MAOP = MAOP limited by pipeline / system, fitting, or equipment. Itcm Flange Rating Pressure Rating I, .0 I (psig) 4. MAOP of Pipeline = Lowest of 1,2, and 3: MAOP = 1,440.00 I (psig) 5. lfno test records exist, use grandfathered MAOP (§ 192.619(a)(3» based on 5 year previous operating pressure: MonthlDayfYear: ________ Highest Operating Pressure: MAOP for Steel Pipeline based on lowest of 1 to 5: 6. Pressure at 100% Hoop Stress: 2 Sf P 1OO ". '" -0 I (psig) :==1 , = 44=0=.0~1 (psig) 2,383.7 I (psig) Where: P J()()"1n = Pressure that creates 1 00% hoop stress S = Tensile strength ofthe pipe D = Outside Diameter t = wall thickness MAOP x 100 7. Hoop Stress as a Percentage of SMYS = ~OO% Based on #7: P' MAOP produces a hoop stress >= 20% ofSMYS r MAOP produces a hoop stress <20% 60.41 1% SMYS D =~ (in.) t = (in.) T = Degrees Fahrenheit SDR= S = (psi) r F = 0.25 for Wet Gas Service I I (psig) Section 38: Calculations for Plastic Pipelines: Outside Diameter of Pipe: Nominal Wall Thickness of Pipe: Soil Temperature (for PE3408 pipe only, for all other pipe, eoter 100) Standard Dimension Ratio: Long Term Hydrostatic Strength: Design Service Factor: 1. Design MAOP "" P' F = 0.32 for DIy Gas Service 2 SI -----x F (D - t) 2. Alternate method for determining design pressure using SDR of plastic pipe. '-- __ .....,1 (psig) Design MAOP = 2 S x F (SDR - 1) DCP Form 45 §192.603(b) Page 20f3 Rev 3 June 2007#

Page 9c:Jcp Midstream_ '-- __ -JI(psig) '--_-.;...-\!(psig) I (psig) :======~I (psig) DCP Form 45 Gas Pipeline Maximum Allowable Operating Pressure and % of SMYS Calculations 3. Hydra test pressure TestMAOP = HTF Hydrotest Pressure'" '" Corrected test pressure at maximum elevation (lowest pressure) in test section. Where HTF~ Hydrotest factor determined under §192.619(a)(2)(i) (Use § 192.619(a)(2)(i» HTF = 1.5 for all plastic pipelines regardless of class location. 4. Operating Limited MAOP = MAOP limited by pipeline / system, fitting, or equipment. Item Pressure Rating 5. MAOP of Pipeline = Lowest of 1,2,3, and 4: MAOP "" 6. lfno test records exist, use grandfathercd MAOP (§ 192.619(a)(3» based on highest operating pressure the 5 years prior to July, I 1970 for transmission pipelines or the 5 years prior March 15, 2006 for gathering pipelines. MonthlDaylY ear: Highest Operating Pressure: I (psig) MAOP for Plastic Pipeline based on lowest of I to 6: I (psig) r MAOP is >= 125 psig r MAOP is <125 psig [Sf. · 0 HR · Determine if Pipeline is Regulated Type A or Type B based on MAOP or Percent SMYS and class location Designated Start and End Points for regulated segments must be either latitude/longitude coordinates, or stationing addresses. r N/A; Onshore vacuum line operating <0 psig; Exempt from DOT Part 192 P" N/A; Onshore gathering line in Class I location; not regulated r Regulated Type A steel & produces hoop stress >= 20% SMYS or Plastic & MAOP>'" I 25 psig; Class 2,3, or 4 Regulated Start Point: Regulated End Point: r Regulated Type B steel & produces hoop stress < 2oolo SMYS or Plastic & MAOP<125 psig; Area I (Class 3 or 4) Regulated Start Point: Regulated End Point: r Regulated Class 2 Type B steel & produces hoop stress < 2oolo SMYS or Plastic & MAOP<125 psig; Area 2 r Area 2 (a) Method = 220 yd by I mile; II to 45 houses (Traditional Class 2 Calculation) r Area 2 (b) Method = ISO ft by I mile; II to 45 r Area 2 (c) Method = ISO ft by 1000 feet 5+ houses Regulated Start Point: Regulated End Point: r Not Regulated Class 2 Type B; Area 2 Method used; Insufficient house count r Area 2 Method = 150 ft by I mile; 10 or fewer houses r Area 2 Method 0: ISO ft by 1000 feet; <5 houses ~~.'" An Dale: ate. DCP Form 45 §192.603(b) Page 3 of 3 Rev 3 June 2007#

Page 10.-: " ~~: (: c ~ ; I' '-lLl'l ii " FIGURE 1 EXTEND GATHERING TO MEWBOURN GAS PLANT UNDER DOT 192.8 (a)(2) ~ I (GA THERING SYSTEM) 1--- DC? MIDSTREAM GREELEY GAS PLANT PROCESSING AND FRACTIONA TION N w.' s - I I \ ~I--__ (_GA_T_H_ER_ING SYSTEM) - (GATHERING SYSTEM) / ! _ I ''-----I..-t ~I--L.....,. 1 DC? MIDSTREAM MEWBOURN GAS PLANT TREA TlNG D£HYDRA nON RESIDUE GAS .... .= ___ --f AND PROCESSING I---Ip~ NGL SCHEMATIC MEWBOURN GAS PLANT ADDITON WELD GATHERING SYSTEM di:;p Midstream. Weld County COLORADO DWG NO. \data\Drawlngs\Standords\J_Jones\MewbournSchematic#

Page 11, NATURAL GAS ANALYSIS PROJECT NO. 200810091 COMPANY NA MF. : Dcr MIOSTREAM - LP ACCOUNT NO. PRODUCER GREELEY PLANT LEASE NO. NAMEIl>ESCKIP : DETHANIZER OVERIIEAD '"PlELDDATA''' SAMPl.ED BY D.S. SAM PLE PR ES 278 SAMPLE TEMP 67 COMMENTS S POt' ANALYS IS NO.: 01 ANALYSIS DATE; OCTonER IG. 20 0~ SAMPLF DATE : OCTOBER 15.2008 TO: CYLI NDER NO. 0 ·8 COMPONENTS AMfl lENT TEMP.: GRAVITY VAPOR PRES. GPM @ 14.65 HELIUM HYDROGEN OXYGEN/ARGON NITROGEN CO2 METHANE ETHANE PROPANE ISOBUTANE N-BUTANE ISOPF.NTANE N·PENTANE HeXANES+ NORM MOLE% 0.00 0.00 0.00 0.01 2.50 1.31 90.90 5 28 0.00 0.00 0.00 0.00 0.00 100.00 (;PM (a! 14.13 24. IKO 1.4·17 0.000 0.000 0.000 0.000 0.000 24 .312 1.455 0.000 0.000 0.000 0.000 0000 TOTAL I3TU@60DWF GROSS DRY REAL = GROSS WET REA L = 25.627 14.65 25 .767 14.73 RELATIVE DENSITY (AIR- I @14('96PSIA60F) : 1764.3 17JJ.5 I 'c)78 3 1774.0 1741. 1 COM PRESSIBILITY FACTOR 0.991 4 5 NOtE.- R/;.'FERENCE CPA 1161(ASTM DI 9<15). ]U5, a 117] CURRENr PUBLICi nONS#