Texas Gas Transmission Company — Pipeline Special Permit

Texas Gas Transmission LOD Extension, page 1Official PDFof Transportation U.S. Department SEP 19 2019 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Washington, D.C. 20590 Administration Mr. Tony Rizk Vice President, Technical Services Texas Gas Transmission Company 9 Greenway Plaza, Suite 2800 Houston, TX 77046 Docket No. PHMSA-2008-0158 Dear Mr. Rizk: On May 14, 2019, Texas Gas Transmission LLC (TXGT) requested the Pipeline and Hazardous Materials Safety Administration (PHMSA) to extend the segments in special permit PHMSA-2008-0158 by 1,123 feet, and 1,145 feet respectively for the TXT's 20-inch diameter pipeline EUT Line 20-1 and the 26-inch diameter pipeline EUT 26-1. This existing special permit waives compliance from the 49 Code of Federal Regulations (CFR) 192.611(a) for two (2) natural gas transmission pipelines located in Iberia Parish, Louisiana. 49 CFR 192.611(a) requires natural gas pipeline operators to confirm or revise the maximum allowable operating pressure of a pipeline segment after a change in class location. After reviewing your application materials, the technical and safety issues involved, and the performance of TXT under the special permit, PHMSA is granting your request for an extension of the special permit segments, provided the special permit conditions are met. My staff would be pleased to discuss this matter or any other regulatory matter with you. Sentho White, Director of PHMSA Engineering and Research Division, may be contacted at 202-366-2415, on technical matters specific to this special permit segment extension. James matters specific to this special permit segment extension. Urisko, Director of PHMSA Southern Region, may be contacted at 404-832-1150, on operational Sincerely, lan K. Mayberry Y Associate Administrator for Pipeline Safety Enclosure: Special Permit - PHMSA-2008-0158#

Texas Gas Transmission Extension - Signed Gran, page 1Official PDFU.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT- Class 1 to 3 Special Permit Segments- Extension Special Permit Information: Docket Number: Requested By: Operator ID#: Original Date Requested: Original Issuance Date: Segment Modification Request: Effective Dates: Code Section(s): PHMSA-2008-0158 Texas Gas Transmission, LLC 19270 May16, 2008 February 27, 2009 May 14, 2019 September 19, 2019 to September 19, 2029 49 CFR 192.611(a) Grant of Special Permit: The Pipeline and Hazardous Materials Safety Administration (PHMSA) grants an extension of this special permit to Texas Gas Transmission LLC (TXGT) waiving compliance from 49 Code of Federal Regulations (CFR) 192.6 11(a) for two (2) natural gas transmission pipelines located in Iberia Parish,Louisiana. The Federal Pipeline Safety Regulations in 49 CFR 192.611(a) require natural gas pipeline operators to confirm or revise the maximum allowable operating pressure (MAOP) of a pipeline segment after a change in class location. The original special permit (Docket No. PHMSA-2008-0158) was granted on February 27, 2009. This special permit modification extends specialpermit segment 1 on EUT Line 20-1 by 1,123 feet and specialpermit segment 2 on BUT Line 26-1 by 1,145 feet. Condition 26 of the original special permit allows PHMSA to extend the existing specialpermit segments to include contiguous segments under certain circumstances. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 1 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 2Special Permit Segments and Inspection Areas: Iberia Parish, Louisiana PHMSA waives compliance from 49 CFR 192.611(a) for two (2) natural gas transmission pipeline segments on the EUT Lines 20-1 and 26-1 pipelines located in Iberia Parish, Louisiana, where a change has occurred from a Class 1 to a Class 3 location. This special permit allows TXGT to continue to operate each specialpermit segment at its current maximum allowable operating pressure (MAUP) of 1052 pounds per square inch gauge sig) for the 20-inch diameter pipeline EUT Line 20-1 and MAUP of 1080 psig for the 26-inch diameter pipeline BUT Line 26-1. This special permit applies to the specialpermit segments' defined using the TXGT mile post (MP) references as follows Specialpermit segment 1- EUT Line 20-1- 1805 feet, MP 50+3236 to MP 50+504 1.2 Specialpermit segment 2- EUT Line 26-1- 1859 feet, MP 50+3222 to MP 50+5081. This special permit applies to the specialpermit inspection areas defined using the TXGT mile post references as follows: EUT special permit inspection areas-means the area that extends 220 yards on each side of the centerline along the entire length of the BUT Lines 20-1 and 26-1 pipelines as follows: ¯ Specialpermit inspection area 1- EUT Line 20-1- MP 40+0505 to MP 75+503 1 ¯ Specialpermit inspection area 2- EUT Line 26-1- MP 40+0505 to MP 75+5023 The specialpermit inspection areas are in Lafayette, Vermillion, Theria, and St. Mary Parishes, Louisiana. The specialpermit inspection areas start upstream of the Morgan City Compressor Station and terminate at the Youngsville Compressor Station for 35.8 miles. PHMSA grants this special permit based on the findings set forth in the "Special Permit Analysis and Findings" document, which can be read in its entirety in Docket No. PHMSA-2008-0158 in 1 Specialpermit segment(s) refer to either or both specialpermit segment 1 and specialpermit segment 2. 2 The original special permit segment 1 was defined in the original special permit using TXGT mile post references: EUT Line 20-1-682 feet, MP 50+4349 to MP 50+5031. The original special permit segment 2 was defined in the original special permit using TXGT mile post references: EUT Line 26-1-714 feet, MP 50+4309 to MP 50+5023. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 2 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 3the Federal Docket Management System (FDMS) located on the internet at www.Regulations.gov. Conditions: PHMSA grants this special permit subject to the following conditions: 1) TXGT must continue to operate the specialpermit segments at or below their existing MAOP as follows: EUT Line 20-1- MAOP 1052 psig; and EUT Line 26-1- MAOP 1080 psig. 2) TXGT must incorporate the specialpermit segments into its written integrity management program (IMP) as a "covered segment" in a "high consequence area (HCA)" per 49 CFR 192.903, except for the reporting requirements contained in 49 CFR 192.945. TXGT need not include the specialpermit segments described in this special permit into its IMP baseline assessment plan unless those areas meet the conditions of an HCA per 49 CFR 192.905. 3) TXGT must perform a close interval survey (CIS) of the EUT Line 20-1 and EUT Line 26-1 pipelines along the entire length of all specialpermit inspection areas not later than one (1) year after the grant of this special permit and remediate any areas of inadequate cathodic protection. A CIS and remediation need not be performed if TXGT has performed a CIS and remediation on the EUT Line 20-1 and EUT Line 26-1 pipelines along the entire length of all specialpermit inspection areas less than four (4) years prior to the grant of this special permit. If factors beyond TXGT's control prevent the completion of the CIS and remediation within one (1) year, a CIS and remediation must be completed as soon as practicable and a letter justifying the delay and providing the anticipated date of completion must be submitted to the Director, PHMSA Southern Region4 not later than one (1) year after the grant of this special permit. PHMSA Note:5 TXGT reported that a CIS was conducted for the special permit inspection areas in 2018. No pipeline coating areas were found out of criteria due to inadequate cathodic protection that required remediation. ' If PHMSA changes the region that is responsible for this TXGT special permit, the Director, PHMSA Southern Region will instruct TXGT on the appropriate PHMSA Region Director to contact for the reporting requirements of this special permit. "PHMSA Note" is to document information provided by TXGT for specialpermit segments 1 and 2 extensions. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 3 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 44) TXGT must perform a periodic CIS of the specialpermit segments at the applicable reassessment interval(s) for a "covered segment" determined in concert and data integrated with in-line inspection (ILl) in accordance with 49 CFR 192 Subpart 0 reassessment intervals as contained in 49 CFR 192.937 (a) and (b) and 192.939. 5) TXGT must perform a Direct Current Voltage Gradient (DCVG) survey or an Alternating Current Voltage Gradient (ACVG) survey of each specialpermit segment not later than one (1) year after the grant of this special permit to verify the pipeline coating conditions and to remediate any integrity issues in the specialpermit segments. A DCVG or ACVG survey and remediation need not be performed on specialpermit segments, if TXGT has performed a DCVG or ACVG survey and conducted remediation on the EUT Line 20-1 and BUT Line 26-1 pipelines along the entire length of all specialpermit inspection areas less than four (4) years prior to the grant of this special permit. TXGT must remediate any damaged coating indications found during these assessments that are classified as moderate (i.e. 35% JR and above for DCVG or 50 dBtV and above for ACVG) or severe based on NACE International Recommended Practice 0502-2002, "Pipeline External Corrosion DirectAssessment Methodology ", (NACE RP 0502-2002). A minimum of two (2) coating survey assessment classifications must be excavated, classified and/or remediated per each survey crew each time the survey is performed. If factors beyond TXGT's control prevent the completion of the DCVG or ACVG survey and remediation within one (1) year, a DCVG or ACVG survey and remediation must be performed as soon as practicable and a letter justifying the delay and providing the anticipated date of completion must be submitted to the Director, PHMSA Southern Region not later than one (1) year after the grant of this special permit. ¯ TXGT must conduct DCVG surveys and remediation by September 30, 2020, for the new special permit segments.6 ¯ PHMSA Note: DCVG surveys were performed in the special permit segments in 2009 for the original issuance of the special permit in 2009: o On August 18, 2009, two (2) DCVG investigation digs were performed on the BUT Line 20-1. One (1) excavation was performed at MP 50+4368 for a 3% JR DCVG defect. The other excavation was performed at MP 50+4777. The 6 Surveys, tests, and remediation that are specified as one (1) year throughout this special permit will have the later of one (1) yearafter the special permit renewal grant date or until September 30, 2020 for TXGT to complete for the new specialpermit segments extension footage. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 4 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 5coating defects were confirmed, and the pipes were recoated and backfihled at both excavations. o On August 19, 2009, two (2) DCVG investigation digs were performed on the EUT Line 26-1. One (1) excavation was at MP 50+5030 where a 5% JR DCVG coating defect was confirmed, excavated, and repaired. At MP 50+5 139 another 5% DCVG defect was excavated and repaired. 6) TXGT must evaluate the EUT Line 20-1 and EUT Line 26-1 pipelines for stress corrosion cracking (SCC) as follows: a) TXGT must perform a stress corrosion cracking direct assessment (SCCDA) or other appropriate assessment method for SCC [such as pressure test or ILl with a crack detection tool] of the BUT Line 20-1 and BUT Line 26-1 pipelines along the entire length of the specialpermit inspection areas according to the requirements of 49 CFR 192.929 and/or NACE RP 0204-2008 not later than one (1) year after the grant of this special permit. The SCCDA or other approved method must address both high pH SCC and near neutral pH SCC. An SCCDA need not be performed if TXGT has performed an SCCDA of the BUT Line 20-1 and EUT Line 26-1 pipelines along the entire length of the specialpermit inspection areas less than four (4) years prior to the grant of this special permit. If factors beyond TXGT' s control prevent the completion of the SCCDA survey and remediation within one (1) year, an SCCDA and remediation must be performed as soon as practicable and a letter justifying the delay and providing the anticipated date of completion must be submitted to the Director, PHMSA Southern Region not later than one (1) year after the grant of this special permit. TXGT may eliminate this Condition 6(a), provided TXGT provides an engineering assessment showing that the pipeline does not meet any of the criteria for both near neutral and high pH SCC per the applicable edition of the American Society of Mechanical Engineers Standard B31.8S, "Managing System Integrity of Gas Pipelines" (ASME B31.8S) Appendix A3, or NACE 0204 -2008, "Stress Corrosion Cracking (SCC) Direct Assessment Methodology ", Sections 1.2.1.1 and 1.2.2. b) If the threat of SCC exists as determined in Condition 6(a), and when the TXGT BUT Line 20-1 and BUT Line 26-1 pipelines are exposed for any reason to comply with the special permit and integrity management activities in the specialpermit Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 5 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 67) inspection areas and the coating has been identified as poor during the pipeline examination, then TXGT must directly examine the pipe for SCC using an accepted industry detection practice such as dry or wet magnetic particle tests. Poor coating is a coating that has become damaged and is losing adhesion to the pipe which is shown. by falling off the pipe, is porous, has pin holes, and/or shields the cathodic protection. Visual inspection is not sufficient to determine 'poor coating'; it is expected that a holiday detection test at the correct voltage will be performed. TXGT must keep coating records at all excavation locations in the specialpermit inspection areas to demonstrate the coating condition. . PHMSA Note: SCCDA was performed in the special permit segments in 2016 by excavating both EUT Line 20-1 and EUT Line 26-1 pipelines. During the prescribed examinations and validation excavations, no SCC was discovered along the entire length of the specialpermit inspection areas. TXGT must conduct a new 5CC assessment for the special permit segments by September 30, 2020, see Condition 23. TXGT will use pressure testing for assessment of the SCC threat in the special permit segments. TXGT must submit the DCVG or ACVG, CIS and SCCDA {or other approved methods of determining SCC] findings including remediation actions in a written report to the Director, PHMSA Southern Region, not later than two (2) years after the grant of this special permit. 8) TXGT must amend applicable sections of its operations and maintenance (O&M) manual(s) to incorporate the inspection and reassessment intervals by in-line inspection (ILl) including both metal loss and geometry tools of the EUT Line 20-1 and EUT Line 26-1 pipelines along the entire length of the specialpermit inspection areas at a frequency consistent with 49'CFR Part 192, Subpart 0. 9) TXGT must amend applicable sections of its 0&M manual(s) to incorporate the inspection and reassessment intervals by CIS of the EUT Line 20-1 and BUT Line 26-1 pipelines special permit segments at a frequency consistent with 49 CFR Part 192, Subpart 0. 10) The assessments of the BUT Line 20-1 and BUT Line 26-1 pipelines along the entire length of the specialpermit inspection areas using ILl must conform to the required maximum reassessment intervals specified in 49 CFR 192.939. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 6 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 711) TXGT must schedule future reassessment dates for the BUT Line 20-1 and BUT Line 26-1 pipelines along the entire length of the specialpermit inspection areas according to 49 CFR 192.939 by adding the required time interval to the previous assessment date. 12) TXGT must ensure its damage prevention program incorporates the applicable best practices of the Common Ground Alliance (CGA) within the specialpermit inspection areas. 13) TXGT must give a minimum of 14-day notice to the Director, PHMSA Southern Region to enable him/her to observe the excavations relating to Conditions 5, 6b, 19, 20, 21, 22 and 23 of field activities in the specialpermit inspection areas. Immediate response conditions do not require a 14-day notice, but the PHMSA Southern Region Director should be noticed by TXGT no later than two (2) business days after the immediate condition is discovered. 14) TXGT must not let this special permit impact or defer any of the operator's assessments for HCAs under 49 CFR Part 192, Subpart 0. 15) Within three (3) months following the grant of this special permit and annually7 thereafter, TXGT must provide an annual report of the following to the Director, PHMSA Southern Region and a copy placed on Docket PHMSA-2008-0158 at www.regulations.gov. a) In the first annual report, TXGT should describe the economic benefits of the special permit extension including both the costs avoided from not replacing the pipe and the added costs of the inspection program. Subsequent annual reports should address any changes to these economic benefits. b) The number of new residences, other structures intended for human occupancy and public gathering areas built within the specialpermit inspection areas. c) Any new integrity threats identified during the previous year and the results of any ILl or direct assessments performed (including any un-remediated anomalies over 30% wall loss, cracking found in the pipe body, weld seam or girth welds, and dents with metal loss, cracking or stress riser) during the previous year in the specialpermit segments including their survey station, failure pressure ratio, anomaly depth and length, class location and whether they are in an HCA. Annual reports must be received by PHMSA by the last day of the month in which the special permit is granted. For example, the annual report for a special permit granted on May 15, 2009, must be received by PHMSA no later than May 31 each year beginning in 2009. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 7 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 8d) e) Any reportable incident, any leak normally indicated on the DOT Annual Report and all repairs on the pipeline that occurred during the previous year in the specialpermit inspection areas. Any on-going damage prevention initiatives affecting the special permit inspection areas and a discussion of the success of the initiatives. f) Any mergers, acquisitions, transfer of assets, or other events affecting the regulatory responsibility of the company operating the pipeline. 16) At least one (1) cathodic protection (CP) pipe-to-soil test station must be located within each HCA with a maximum spacing between test stations of one-half mile within an HCA. In cases where obstructions or restricted areas prevent test station placement, the test station must be placed in the closest practical location. This requirement applies to any HCA within the specialpermit inspection areas. 17) If any annual CP test station readings on the EUT Line 20-1 and EUT Line 26-1 pipelines within the specialpermit inspection areas fall below 49 CFR Part 192, Subpart I requirements, remediation must occur within six (6) months and include a CIS on each side of the affected test station to the next test station and any identified corrosion system modifications to ensure corrosion control. If factors beyond TXGT' s control prevent the completion of remediation within six (6) months, remediation must be completed as soon as practicable and a letter justifying the delay and providing the anticipated date of completion must be submitted to the Director, PHMSA Southern Region no later than the end of the six (6) month completion date. 18) Interference Currents Control: Control of induced AC from parallel electric transmission lines and other interference issues in the specialpermit inspection areas, that may affect the pipeline must be incorporated into the operations of the pipeline and addressed. An induced AC program to protect the pipeline from corrosion caused by stray currents must be in place within one year of the date of this special permit. ¯ PHMSA Note: TXGT reports that based upon the original application and latest imagery there are no major electric transmission powerlines in the specialpermit inspection areas right of way. AC survey was conducted in 2010; no interference issues were found in the specialpermit inspection areas. 19) Field Coating: The coatings used on the pipeline and girth weld joints in the specialpermit Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 8 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 9segments must be non-shielding to CP. If the coating type is unknown or is known to shield CP for girth weld joints, then TXGT must take special care to: a) Analyze ILl logs in the areas of girth welds for potential corrosion indications. b) Any ILl corrosion indications above 30% wall loss at girth welds where the coating type is unknown or is known to shield CP, girth weld joints must be exposed and evaluated each time the ILl is run or until the girth weld coating is replaced. c) A minimum of two (2) girth weld joints at locations most likely to have shielding and corrosion shall be exposed and evaluated each time ILl is run. If corrosion is found, the next most likely joint is to be exposed and evaluated until no corrosion is found. 20) Anomaly Evaluation and Repair: a) General: TXGT must account for ILl tool tolerance8'9and corrosion growth rates in scheduled response times and repairs, and document and justify the values used. b) Dents: TXGT must repair dents to the EUT Line 20-1 and EUT Line 26-1 pipelines in the specialpermit inspection areas in accordance with 49 CFR 192.933 repair criteria. Specialpermit inspection areas must have a geometry tool inspection as part of the initial ILl. The geometry tool can be from past ILl inspections. The timing for these dent repairs should follow TXGT's O&M Manual but must not be longer than one (1) year after discovery. 8 ILl tool calibration excavations may include previously excavated anomalies or recent anomaly excavations with known dimensions that were field measured for length, depth, and width, externally re-coated, CP maintained, and documented for ILl calibrations prior to the ILl tool run. ILl tool calibrations must use ILl tool run results and anomaly calibrations from either the specialpermit inspection areas or from the complete ILl tool run segment, if the continuous ILl segment is longer than the special permit inspection areas. A minimum of four (4) calibration excavations must be used for unity plots. Note: Other known and documented pipeline features that are appropriate for the type ILl tool used may be used as calibration excavations for ILl tool calibration with technical documentation of their validity. To use other known and documented pipeline features as calibration excavations for ILl tool calibration TXGT must complete both of the following: (1) submit a plan for using known and documented pipeline features as calibration excavations to, and receive a "No Objection" from, the Director, PHMSA Southern Region prior to performing the ILl tool calibration using pipeline features. PHMSA must reply to TXGT within 90-days of TXGT's request. The plan must include at least the following information: reason that known and documented pipeline features will be used in place of anomalies on the pipelines; the pipeline features that will be used for the ILl tool calibration, and the technical justification for using the pipeline features for ILl tool calibration. (2) submit a report to the Director, PHMSA Southern Region and the Director, PHMSA Engineering and Research Division with the results of the use of pipeline features for the ILl tool calibration that includes technical documentation establishing the validity of using the pipeline features for the ILl tool calibration. TXGT must submit the report to PHMSA within 90-days after completion of the ILl tool calibration. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 9 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 10c) Repair Criteria: Repair criteria apply to anomalies located on the EUT Line 20-1 and EUT Line 26-1 pipelines within the specialpermit inspection areas when they have been excavated and investigated in accordance with 49 CFR 192.485 and 192.933 as follows: i) Specialpermit segments- Repair any anomaly that meets either: (1) a failure pressure ratio (FPR) less than or equal to 1.39 for original Class 1 location pipe in a Class 3 location operating up to 72% of the specified minimum yield strength (SMYS); (2) an anomaly depth greater than 40% of pipe wall thickness. ii) Special permit inspection areas- Anomaly evaluations and repairs in the special permit inspection areas must be performed in accordance with 49 CFR 192.485 and 192.111 incorporating appropriate class location design factors, except HCAs outside of the specialpermit segments may be repaired in accordance with 49 CFR 192.933. iii) Specialpermit inspection areas- the response time must be in accordance with 49 CFR Part 192, Subpart 0, the applicable edition of the American Society of Mechanical Engineers Standard B31.8S, "Managing System Integrity ofGas Pipelines" (ASME B31.8S) and TXGT's Integrity Management Program. d) Response Time for ILl Results: The following guidelines provide the required timing for excavation and investigation of anomalies based on ILl results. Reassessment by ILl will "reset" the timing for anomalies not already investigated and/or repaired. TXGT must evaluate ILI data by using either the ASME Standard B31G, "Manual for Determining the Remaining Strength ofCorroded Pzpelines" (ASME B3 1 G), the modified B3 1 G (0.85dL) or R-STRENG for calculating the predicted FPR to determine anomaly responses. i) Specialpermit segments: - Immediate response: Any anomaly within a specialpermit segment operating up to 72% SMYS that meets either: (1) an FPR equal to or less than 1.1; or (2) an anomaly depth equal to or greater than 80% wall thickness loss. - One-year response: Any anomaly within a special permit segment with original Class 1 location pipe in a Class 3 location operating up to 72% SMYS that meets either: (1) an FPR equal to or less than 1.39; or (2) an anomaly depth equal to or greater than 40% wall thickness loss. - Monitored response: Any anomaly within a specialpermit segment with original Class 1 location pipe in a Class 3 location operating up to 72% SMYS that meets Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 10 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 11both: (1) an FPR greater than 1.39; and (2) an anomaly depth less than 40% wall thickness loss. The schedule for the response must take tool tolerance and corrosion growth rates into account. ii) Specialpermit inspection areas: The response time must be in accordance with 49 CFR Part 192, Subpart 0, or TXGT's Integrity Management Program, which ever is shorter. Anomaly evaluations and repairs must be performed in accordance with 49 CFR 192.485 and 192.111 incorporating appropriate class location design factors, except HCA's outside of the specialpermit segments may be repaired in accordance with 49 CFR 192.933. . PHMSA Note: In 2014, TXGT performed ILl along the entire length of the special permit inspection areas: a Eight (8) anomalies were excavated on EUT 20-1 in the specialpermit inspection areas. One anomaly was repaired with a sleeve, and the other seven (7) anomalies were removed by replacing the pipes. No anomalies were found in the specialpermit segments. a Three (3)anomalies were excavated on EUT 26-1 in the special permit inspection areas. Two (2) anomalies were repaired with a sleeve, and the pipe at the other anomaly was recoated. No anomalies were found in the special permit segments. a TXGT will perform ILl on EUT 20-1 in the special permit inspection areas from Youngsville to Berwick Header by August 3, 2021, and will perform ILl on EUT 26-1 in the special permit inspection areas from Youngsville to Morgan City by October 21, 2021 21) TXGT must provide records to PHMSA to demonstrate the girth welds on the EUT Line 20- 1 and EUT Line 26-1 pipelines were nondestructively tested at the time of construction in accordance with: a) The Federal pipeline safety regulations at the time the pipelines were constructed or at least. 1% of the girth welds in each specialpermit segment were non-destructively tested after construction but prior to the application for this special permit provided at least two girth welds in each special permit segment were excavated and inspected. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 11 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 12b) If TXGT cannot provide girth weld records to PHMSA to demonstrate either of the above in Condition 21(a), TXGT must accomplish either (i) or ((ii) and (iii)) of the following: i) Certify to PHMSA in writing that there have been no in-service leaks or breaks in the girth welds on the EUT Line 20-1 and EUT Line 26-1 pipelines within the entire specialpermit inspection areas for the entire life of the pipelines, or ii) Evaluate the terrain along the special permit segments for threats to girth weld integrity from soil or settlement stresses and remediate all such integrity threats; and iii) Excavate10, visually inspect and nondestructively test at least two girth welds on the BUT Line 20-1 and EUT Line 26-1 pipelines in each specialpermit segment in accordance with the American Petroleum Institute Standard 1104, "Welding of Pipelines and Related Facilities" (API 1104) as follows: A. Use the edition of API 1104 current at the time the pipelines were constructed; or B. Use the edition of API 1104 recognized in the Federal pipeline safety regulations at the time the pipelines were constructed; or C. Use the edition of API 1104 currently recognized in the Federal pipeline safety regulations. c) If any girth weld in any of the specialpermit segments is found unacceptable in accordance with API 1104, TXGT must repair the girth weld immediately and then prepare an inspection and remediation plan for all remaining girth welds in the special permit segments based upon the repair findings and the threat to the specialpermit segments. TXGT must submit the inspection and remediation plan to the Director, PHMSA Southern Region and remediate girth welds in the special permit segments in accordance with the inspection and remediation plan within 60 days of finding girth welds that do not meet this Condition 21(c). d) Additionally, all oxy-acetylene girth welds, mechanical couplings and wrinkle bends in specialpermit segments must be removed. 10 TXGT must evaluate for SCC any time the EUT Lines 20-1 and 26-1 pipelines are uncovered in accordance with Condition 6(b) of this special permit. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 12 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 13e) TXGT must complete the girth weld testing, and the girth weld inspection and remediation plan, within six (6) months after the grant of this special permit. If factors beyond TXGT's control prevent the completion of these tasks within six (6) months, the tasks must be completed as soon as practicable and a letter justifying the delay and providing the anticipated date of completion must be submitted to the Director, PHMSA Southern Region not later than six (6) months after the grant of this special permit. . PHMSA Note: TXGT performed X-ray examinations on the EUT Line 20-1 at MP 50+4368 and MP 50+4777 and on the EUT Line 26-1 at MP 50+5030 and MP 50+5139 on August 24, 2009. All welds passed evaluation. There have been no in-service leaks or breaks in the girth welds on the EUT Line 20-1 and EUT Line 26-1 pipelines within the entire special permit inspection areas. No additional girth weld examinations are required for the specialpermit segment extension. 22) TXGT must identify all shorted casings within the specialpermit segments not later than six (6) months after the grant of this special permit and classify any shorted casings as either having a "metallic short" (the carrier pipe and the casing are in metallic contact) or an "electrolytic short" (the casing is filled with an electrolyte) using a commonly accepted method such as the Panhandle Eastern, Pearson, DCVG, ACVG or AC Attenuation. a) Metallic Shorts: TXGT must clear any metallic short on a casing in the specialpermit segments not later than six (6) months after the short is identified. b) Electrolytic Shorts: TXGT must remove the electrolyte from the casing/pipe annular space on any casing in the specialpermit segments that has an electrolytic short not later than six (6) months after the short is identified. c) All Shorted Casings: TXGT must install external corrosion control test leads on both the carrier pipe and the casing in accordance with 49 CFR 192.471 to facilitate the future monitoring for shorted conditions and may then choose to fill the casing/pipe annular space with a high dielectric casing filler or other material which provides a corrosion inhibiting environment provided an assessment and all repairs were completed. If TXGT identifies any shorted casings within the specialpermit segments, they must monitor all casings within the specialpermit segments for shorts at least once each calendar Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 13 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 14quarter, but at intervals not to exceed 100 days, for four consecutive calendar quarters after the grant of this special permit. The intent is to identify through monitoring the calendar quarter(s) when electrolytic casing shorts are most likely to be identified. TXGT must then monitor all casings for shorts within the special permit segments at least once each calendar year during the calendar quarter(s) when electrolytic casing shorts are most likely to be identified. Any casing shorts found in the specialpermit segments at any time must be classified and cleared as explained above. ¯ PHMSA Note: TXGT reports no cased pipes under road crossings in the special permit segments. 23) Pipe Seam Evaluations: TXGT must identify any pipeline in a special permit inspection areas that may be susceptible to pipe seam issues because of the vintage of the pipe, the manufacture of the pipe, or other issues. Once TXGT has identified such issues, they must complete one or all of the following as required: a) TXGT must perform an engineering analysis to determine if there are any pipe seam threats on the EUT Line 20-1 and EUT Line 26-1 pipelines located in the special permit inspection areas. This analysis must include the documentation that the processes in 'M Charts' in "Evaluating the Stability ofManufacturing and Construction Defects in Natural Gas Pipelines" by Kiefner and Associates updated April 26, 2007 under PHMSA Contract DTFAA-COSPO212O and Figure 4.2, 'Framework for Evaluation with Path for the Segment Analyzed Highlighted' from TTO-5 "Low Frequency ERW and Lap Welded Longitudinal Seam Evaluation" by Michael Baker Jr., and Kiefner and Associates, et. al. under PHMSA Contract DTRS56-02-D-70036 were utilized along with other relevant materials. If the engineering analysis shows that the pipe seam issues on the EUT Line 20-1 and EUT Line 26-1 pipelines located in the specialpermit inspection areas are not a threat to the integrity of the pipeline, TXGT does not have to complete Conditions 23(b) through 23(e). If there is a threat to the integrity of the pipeline, then one or more of Conditions 23(b) through 23(e) must be completed; or b) The specialpermit segment pipeline must be hydrostatically tested to a minimum pressure of 100 percent SMYS, per 49 CFR Part 192, Subpart J requirements for eight continuous hours, within One (1) year of issuance of this special permit if no 49 CFR Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 14 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 15Part 192, Subpart J had been performed since 1971. The hydrostatic test must confirm no systemic issues with the weld seam or pipe. A root cause analysis, including metallurgical examination of the failed pipe, must be performed for any failure experienced to verify that it is not indicative of a systemic issue. The results of this root cause analysis must be reported to the Director, PHMSA Southern Region within 60 days of the failure; or c) If the pipeline in the specialpermit inspection areas has experienced a seam leak or failure in the last five (5) years and no hydrostatic test meeting the conditions per 49 CFR Part 192, Subpart J was performed after the seam leak or failure, then a hydrostatic test must be performed within one (1) year after the grant of this special permit on the specialpermit segment pipeline; and d) If the pipeline in the specialpermit segments has any LF ERW seam or EFW seam conditions as noted in i, ii, or iii below, the specialpermit segment pipeline must be replaced: i) constructed or manufactured prior to 1954 and has had any pipe seam leaks or ruptures in the specialpermit inspection areas, ii) has unknown manufacturing processes, or iii) has known manufacturing or construction issues that are unresolved [such as concentrated hard spots, hard heat-affected weld zones, selective seam corrosion, pipe movement that has lead to buckling, have had past leak and rupture issues; or any other systemic issues]. e) If the pipeline in the specialpermit segments has a reduced longitudinal joint seam factor, below 1.0, as defined in 49 CFR 192.113 the specialpermit segment pipeline must be replaced. PHMSA Note: TXGT reports that EUT Line 20-1 was originally constructed with electric flash welded pipes (EFW) in the special permit segments in 1956. EUT Line 26-1 was originally constructed with EFW welded pipes in the special permit segments in 1962, with several replaced pipes manufactured with double submerged arc welded (DSAW) seam. TXGT reports that there are no known manufacturing or construction issues such as hard spots, hard heat-affected weld zones, selective seam corrosion or buckling. Hydrotests were performed for the special permit segments in 2009 at 1462 psig for Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 15 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 16eight (8) hours. TXGT must conduct hydrotests for the new specialpermit segments for EUT 26-1 by December 31, 2019, and BUT 20-1 by September 30, 2020. 24) Not/Applicable 25) TXGT must maintain the following records for each specialpermit segment: a) Documentation showing that each specialpermit segment has received a 49 CFR 192.505, Subpart J, hydrostatic test for eight (8) continuous hours and at a minimum pressure of 1.25 times MAOP. If TXGT does not have hydrostatic test documentation, then the specialpermit segment must be hydrostatically tested to meet this requirement within one year of receipt of this special permit. b) Documentation (mill test reports) showing that the pipe in each specialpermit segment meets the wall thickness, yield strength, tensile strength and chemical composition of either the American Petroleum Institute Standard 5L, 5LX or 5LS, "SpecJIcationfor Line Pipe" (API 5L) approved by the 49 CFR Part 192 code at the time of manufacturing or if pipe was manufactured and placed in-service prior to the inception of 49 CFR Part 192 then the pipe meets the API 5L standard in usage at that time. Any specialpermit segment that does not have mill test reports for the pipe can not be authorized per this special permit. c) Documentation of compliance with all conditions of this special permit must be kept for the applicable life of this special permit for the referenced specialpermit segments and special permit inspection areas. 26) PHMSA may extend the original specialpermit segments to include contiguous segments of the BUT Line 20-1 and BUT Line 26-1 pipelines up to the limits of the specialpermit inspection areas pursuant to the following conditions. TXGT must: a) Provide at least 90 days advanced notice to the Director, PHMSA Southern Region and the Director, PHMSA Bngineering and Research Division of a requested extension of any BUT Line 20-1 and BUT Line 26-1 specialpermit segment based on actual class location change and include a schedule of inspections and of any anticipated remedial actions. If PHMSA makes a written objection before the effective date of the requested special permit segment extension (90 days from receipt of the above notice), the requested special permit extension does not become effective. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 16 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 17b) c) Complete all inspections and remediation of the proposed special permit segment extension to the extent required of the original EUT Line 20-1 and EUT Line 26-1 pipelines specialpermit segments. Apply all the special permit conditions and limitations included herein to all future extensions. 27) Certification: A senior executive officer of TXGT must certify in writing the following: a) TXGT pipeline specialpermit inspection areas and specialpermit segments meet the conditions described in this special permit; b) The written manual of O&M procedures for the TXGT pipeline has been updated to include all additional operating and maintenance requirements of this special permit; and c) That TXGT has implemented all conditions as required by this special permit. TXGT must send a copy of the certification required in Condition 27 with the required senior executive signature and date of signature to the Director, PHMSA Southern Region within one (1) year of the date of this special permit. Limitations: PHMSA grants this special permit subject to the limitations set forth in 49 CFR 190.341 as well as the following limitations: 1) PHMSA has the sole authority to make all determinations on whether TXGT has complied with the specified conditions of this special permit. Failure to comply with any condition of this special permit may result in revocation of the permit. 2) Any work plans and associated schedules for the specialpermit segments and specialpermit inspection area are automatically incorporated into this special permit and are enforceable in the same manner. 3) Failure by TXGT to submit the certifications required by Condition 27 (Certification) within the time frames specified may result in revocation of this special permit. 4) As provided in 49 CFR 190.341, PHMSA may issue an enforcement action for failure to comply with this special permit. The terms and conditions of any corrective action order, compliance order or other order applicable to a pipeline facility covered by this special permit will take precedence over the terms of this special permit. Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 17 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#

Texas Gas Transmission Extension - Signed Gran, page 185) 6) If TXGT sells, merges, transfers, or otherwise disposes of all or part of the assets in the specialpermit segments or specialpermit inspection areas, TXGT must provide PHMSA with written notice of the change within 30 days of the consummation date. In the event of such transfer, PHMSA reserves the right to revoke, suspend, or modify the special permit if the transfer constitutes a material change in conditions or circumstances underlying the permit. This special permit, including the original special permit and the extension, is granted by PHMSA for a term of no more than ten (10) years from the date of issuance of this action. If TXGT elects to seek renewal of this special permit, TXGT must submit its renewal request at least 180 days prior to expiration of the ten (10) year period to the PHMSA Associate Administrator for Pipeline Safety with copies to the; Director, PHMSA Southern Region; and Director, PHMSA Engineering and Research Division. All requests for a renewal must include a summary report in accordance with the requirements in Condition 15 (Annual Report) above and must demonstrate that renewal of the special permit would not be inconsistent with pipeline safety. PHMSA may seek additional information from TXGT prior to granting any request for special permit renewal. AUTHORITY: 49 U.S.C. 60118 (c)(1) and 49 CFR 1.97. Issued in Washington, DC on SEP 19 2019 Associate Administrator for Pipeline Safety Special Permit: PHMSA-2009-0158, Texas Gas Transmission Page 18 of 18 Modification of Special Permit Segments for EUT Line 20-1 and EUT Line 26-1#