Tennessee Gas Pipeline Company, LLC — Pipeline Special Permit

2017-0161-Tennessee Gas Pipeline Co SPAF, page 1Official PDFU.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION Special Permit Analysis and Findings Class 1 to 3 Location Special Permit Information: Docket Number: PHMSA-2017-0161 Requested By: Tennessee Gas Pipeline Company, LLC Operator ID#: 19160 Original Date Requested: December 7, 2017 Original Issuance Date: August 11, 2022 Code Section(s): 49 CFR 192.611(a) and (d) and 192.619(a) Purpose: The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), 1 provides this information to describe the facts of the subject special permit application submitted by Tennessee Gas Pipeline Company, LLC (TGP)2 to discuss any relevant public comments received with respect to the application, to present the engineering and safety analysis of the special permit application, and to make findings regarding whether the requested special permit should be granted and, if so, under what conditions. TGP requested that PHMSA waive compliance from the 49 Code of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for a natural gas transmission pipeline segment, where the class location has changed from Class 1 to a Class 3 location. Pipeline System Affected: This special permit application by TGP requests a waiver from the class location change requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 1.050 miles of the 20-inch diameter gas 1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety. 2 TGP is a wholly owned subsidiary of Kinder Morgan, Inc. PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 1 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 2transmission pipeline located in Kanawha County, West Virginia. Pipe specifications including outside diameter, year installed, seam type, coating type, pipe grade, wall thickness, maximum allowable operating pressure (MAOP), minimum pressure test pressure, and pressure test factor based on the minimum test pressure are detailed in Table 1 – Pipe Specifications by Line Name. Table 1 – Pipe Specifications by Line Name Outside Wall Min. Test Pressure Year Line Name Diameter Installed Seam Type MAOP Coating Type Grade Thickness Pressure Test (psig) (inches) (inches) (psig) Factor 100-1 20 1984 DSAW Fusion bonded epoxy X52 0.25 936 1,198 1.28 Note: DSAW is double submerged arc welded pipe weld seam type. Psig means pounds per square inch gauge. Without this special permit, 49 CFR 192.611(a) would require TGP to replace the special permit segments with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change. Special Permit Request: On December 29, 2020, TGP applied to PHMSA for a special permit seeking relief from 49 CFR 192.611(a) and (d) and 192.619(a) for the below-listed special permit segments, where a class location change occurred from the original Class 1 to a Class 3 on the 20-inch diameter Line 100-1 Pipeline (Pipeline) located in Kanawha County, West Virginia. TGP’s special permit applies to the special permit segments and special permit inspection area described and defined as follows, using the TGP survey station references: Special Permit Segments: This special permit applies to the special permit segments identified using the TGP valve and station references as detailed in Table 2 – Special Permit Segments. PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 2 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 3Table 2 – Special Permit Segments Special Permit Outside Line Diameter Name Length (feet) Segment Number3 (inches) Start Survey Station (Valve/MP– Station) End Survey Station County/Parish, State No. Year Installed Seam Type MAOP (psig) 451 20 100-1 4,249.18 120-1 – 14819 (Valve/MP – Station) 120-1 – 15995 Dwellings Kanawha, WV 13 1984 DSAW 936 452 20 100-1 1,816.56 120-1 – 19928 120-1 – 21744 Kanawha, WV 2 1984 DSAW 936 453 20 100-1 845.38 120-1 - 23426 120-1 – 24271 Kanawha, WV 1 1984 DSAW 936 Special Permit Inspection Area: The special permit inspection area is defined as the area that extend 220 yards on each side of the centerline as shown in Table 3 – Special Permit Inspection Area. Table 3 – Special Permit Inspection Area Special Permit Inspection Area Number Special Permit Outside Line Diameter Segment Name Start Survey Station (Valve/MP – Station) End Survey Station (Valve/MP – Station) Length4 (miles/feet) (inches) Number 1 451.452, 453 20 100-1 118-1 – 18.79 121-1 – 27219.53 46.02/ 242,989.49 Public Notice: On April 5, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR 19735) with a closing date of May 5, 2022. PHMSA did not receive any comments concerning this special permit request. The TGP special permit application letter, Federal Register notice, Final Environmental Assessment, Finding of No Significant Impact, and all other pertinent documents are available for review in Docket No. PHMSA-2017-0161 in the Federal Docket Management System (FDMS) located at www.Regulations.gov. Analysis: Background: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the criteria it uses for the consideration of applications for class location change waivers, now being granted or denied 3 On February 3, 2022, TGP rescinded requested special permit segments 454, 455, 456, 457, 458, 459, 462, and 463. 4 If the special permit inspection area footage does not extent from launcher to receiver then the special permit inspection area would need to be extended. PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 3 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 4through a special permit. First, certain threshold requirements should be met on a pipeline special permit segments for a class location change special permit to be granted. Second, the age and manufacturing process of the pipe; system design, and construction; environmental, operating and maintenance histories; and integrity management (IM) program elements are evaluated as significant criteria. These significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket No. PHMSA–RSPA-2004-17401. Third, special permits will only be granted when pipe conditions and active IM provide a level of safety greater than or equal to a pipe replacement or pressure reduction. The operator’s Federal pipeline safety regulation compliance history is also evaluated as part of the criteria matrix for acceptability prior to issuance of a special permit. Threshold Requirements: Each of the threshold requirements published by PHMSA in the June 29, 2004, Federal Register notice is discussed below regarding the TGP special permit request. • No pipeline segment in a class location changing to Class 4 location will be considered. • This special permit request is for three (3) special permit segments where a change has occurred from a Class 1 location to a Class 3 location. • TGP meets this requirement. • No bare pipe will be considered. • The special permit segments are externally coated with fusion bonded epoxy. • TGP meets this requirement. • No pipe containing wrinkle bends will be considered. • There are no reported wrinkle bends in the special permit segments. • TGP meets this requirement. • No pipe segment operating above 72% of the specified minimum yield strength (SMYS) will be considered for a Class 3 special permit. • The special permit segments operate at or below 72% SMYS. • TGP meets this requirement. • Records must be produced that show a hydrostatic test to at least 1.25 times the MAOP. The records should include test pressure, year of the test, test duration, and pressure test percent of MAOP for the pipeline: • TGP has provided records to PHMSA that the special permit segments have been tested to at least 1.25 times the MAOP. PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 4 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 5• TGP meets this requirement • Inline Inspection (ILI) must have been performed with no significant anomalies identified that indicate systemic problems such as stress corrosion cracking (SCC). • TGP ran an ILI for corrosion and deformation and an ILI for denting in all special permit segments. • Criteria for consideration of a class location change waiver, being considered through the special permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection area (special permit inspection area) as up to 25 miles of pipe on either side of the waiver segment (special permit segment). • TGP has identified a longer segment surrounding the special permit segments as the special permit inspection area. The special permit inspection area is the entire segment length between the upstream launcher and downstream receiver on the ILI segment that contains the special permit segments. • A special permit would be contingent upon TGP’s incorporation of the special permit segments into its written IM program as a covered segment in a high consequence area in accordance with 49 CFR 192.903. Criteria Matrix: The data submitted by TGP for the special permit segment has been compared to the class location change special permit criteria matrix. • The special permit segments fall in the probable acceptance column of the criteria matrix for: • Pipe material and toughness, coating type, design stress, depth of cover, test pressure, test failures, local geology, type of service, pressure fluctuations, safety related conditions, ILI type, ILI timeframe, and damage prevention program. • The special permit segments fall in the requires substantial justification column of the criteria matrix for: • Kinder Morgan, Inc. overall enforcement findings fall in the requires substantial justification category. TGP’s 11-year enforcement findings do not fall within this category. • This special permit requires TGP to implement the special permit conditions that include safety requirements on the operations, maintenance, and IM of the special permit segments (1.050 miles) and the special permit inspection area (46.02 miles). Therefore, the safety benefits are obtained well beyond the portion of the pipeline that experienced a class location change. PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 5 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 6• TGP will be required to submit an annual report for this special permit on integrity threats to the pipeline in the special permit segments and the special permit inspection area. Operational Integrity Compliance: To inform PHMSA’s decision about whether a special permit could provide a level of safety greater than or equal to a pipe replacement or pressure reduction and is consistent with pipeline safety, PHMSA reviewed this special permit request to understand the known type of integrity threats that are in the special permit segments and special permit inspection area. This integrity information was used to consider special permit conditions to provide a systematic program to review and remediate the pipeline for safety concerns. Additional operational integrity review and remediation requirements are required by this special permit to ensure that the operator has an ongoing program to locate and remediate safety threats. These threats to integrity and safety include any issues with the pipe coating quality, cathodic protection effectiveness, operations damage prevention program, pipe depth of soil cover, weld seam and girth weld integrity, anomalies in the pipe steel and welds, and material and structures either along or near the pipeline that could cause the cathodic protection system to be ineffective. PHMSA would have to carefully design a comprehensive set of conditions that TGP must implement to comply with this special permit. Past Enforcement History – January 1, 2011 through January 31, 2022: During January 1, 2011, through January 31, 2022, TGP was cited in 27 enforcement actions with a total of $257,600 in assessed civil penalties. PHMSA issued four (4) Corrective Action Orders, six (6) Notices of Amendment, ten (10) Notices of Probable Violation, one (1) Safety Order, and six (6) Warning Letters to TGP. Tables 4 and 5 below show PHMSA’s enforcement actions and civil penalties for TGP: Table 4: TGP Enforcement Matters from January 1, 2011 through January 31, 2022 Notice of Status Corrective Action Order Notice of Safety Probable Amendment Order Warning Letter Total Violation CLOSED 3 5 9 1 6 24 OPEN 1 1 1 0 0 3 Total 4 6 10 1 6 27 PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 6 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 7Table 5: TGP Enforcement Civil Penalty Status January 1, 2011 through January 31, 2022 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $384,200 $0 $257,600 $126,000 $257,000 Summary of Enforcement Findings for TGP includes: Reporting, welding, compliance with specifications or procedures, corrosion control, operations and maintenance procedures, continuing surveillance, public awareness, MAOP, control room management, relief devices, maintenance of valves, qualification of operating personnel, and IM: • 49 CFR 191.22, 191.27, 192.225, 192.229, 192.303, 192.469, 192.479, 192.481, 192.603, 192.605, 192.613, 192.615, 192.616, 192.619, 192.631, 192.705, 192.706, 192.709, 192.713, 192.735, 192.736, 192.739, 192.743, 192.745, 192,805, 192.905, 192.921, and 192.937. Table 6 below shows PHMSA’s enforcement actions and civil penalties for TGP and the specific 49 CFR Part 191 and 192 violations: Table 6: Summary of Enforcement Findings from TGP January 1, 2011 through January 31, 2022 Notice of Amendment Construction 1 Control Room Management 3 OME Procedural Manual 2 Operation and/or Maintenance 2 Reporting 2 Welding of Steel in Pipelines 1 Notice of Amendment Total: 11 Notice of Probable Violation Control Room Management 1 OME Procedural Manual 7 Public Awareness 1 Corrosion Control 3 Operation and/or Maintenance 8 Reporting 1 Integrity Management 3 Operator Qualification 3 Welding of Steel in Pipelines 1 Notice of Probable Violation Total: 28 Warning Letter OME Procedural Manual 2 Operation and/or Maintenance 4 Reporting 1 Notice of Amendment Total: 7 Grand Total: 46 PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 7 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 8Summary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG, NGPL, SNG, TEJAS, and TGP: From January 1, 2011, through January 31, 2022, Kinder Morgan, the operator of TGP, was cited in 69 enforcement actions with a total of $1,077,800 in assessed civil penalties on its Colorado Interstate Gas Company (CIG), El Paso Natural Gas Company (EPNG), Natural Gas Pipeline of America (NGPL), Southern Natural Gas Company (SNG), Tejas Pipeline (TEJAS), and Tennessee Gas Pipeline Company (TGP) pipeline systems. PHMSA issued seventeen (17) Notice of Amendments, twenty-two (22) Notices of Probable Violation, twenty (21) Warning Letters, one (1) Safety Order, and eight (8) Corrective Action Orders to Kinder Morgan. Tables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for Kinder Morgan on these pipeline systems – CIG, EPNG, NGPL, SNG, TEJAS, and TGP with operator identification numbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160. Table 7: Kinder Morgan Enforcement Matters from January 1, 2011 through January 31, 2022 Notice of Status Corrective Action Order Notice of Safety Probable Amendment Order Warning Letter Total Violation CLOSED 5 16 21 1 21 64 OPEN 3 1 1 0 0 5 Total 8 17 22 1 21 69 Table 8: Kinder Morgan Enforcement Civil Penalty Status January 1, 2011 through January 31, 2022 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $1,461,500 $0 $1,077,800 $383,700 $1,077,800 The type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline systems from January 1, 2011 through January 31, 2022, were as follows: Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, TEJAS, and TGP includes: The type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline systems from January 1, 2011, through January 31, 2022, included reporting, design, welding, compliance with specifications or procedures, corrosion control, operations and maintenance PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 8 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 9procedures, continuing surveillance, public awareness, emergency plans, MAOP, control room management, relief devices, maintenance of valves, qualification of operating personnel, and IM: • 49 CFR 191.5, 191.14, 191.15, 191.22, 191.25, 191.27, 192.12, 192.14, 192.161, 192.199, 192.225, 192.227, 192.229, 192.303, 192.459, 192.463, 192.465, 192.469, 192.475, 192.479, 192.481, 192.603, 192.605, 192.613, 192.615, 192.616, 192.619, 192.625, 192.631, 192.705, 192.706, 192.707, 192.709, 192.713, 192.735, 192.736, 192.739, 192.743, 192.745, 192,805, 192.807, 192.905, 192.911, 192.917, 192.921, 192.933, 192.935, and 192.937. Table 9 below gives a complete summary of the findings and the specific 49 CFR Part 191 and 192 violation: Table 9: Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, TEJAS, and TGP January 1, 2011, through January 31, 2022 Notice of Amendment OME Procedural Manual 11 Operation and/or Maintenance 2 Operator Qualification 3 Public Awareness 8 Reporting 3 Transportation of Gas 5 Integrity Management 10 Control Room Management 4 Construction 1 Welding of Steel in Pipelines 3 Notice of Amendment Total: 50 Notice of Probable Violation Corrosion Control 13 OME Procedural Manual 14 Operation and/or Maintenance 26 Operator Qualification 7 Public Awareness 2 Reporting 5 Integrity Management 10 Control Room Management 1 Welding of Steel in Pipelines 1 Design 2 Notice of Probable Violation Total: 81 Warning Letter Corrosion Control 10 OME Procedural Manual 9 Operation and/or Maintenance 31 Operator Qualification 2 Public Awareness 4 Reporting 1 Transportation of Gas 1 Integrity Management 1 Design 1 Notice of Amendment Total: 60 Grand Total: 191 PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 9 of 10#

2017-0161-Tennessee Gas Pipeline Co SPAF, page 10Findings: Based on the information submitted by TGP and PHMSA’s analysis of the technical, operational, and safety issues, PHMSA finds that granting this special permit with conditions for TGP to operate the special permit segments defined in Table 1 at its current MAOP for a Class 1 to 3 location change would not be inconsistent with pipeline safety. PHMSA has designed the special permit conditions to effectively assess and remediate threats to the special permit segments and special permit inspection area, including pressure testing, obtaining pipe material records, and conducting assessments to evaluate pipe girth welds that have not been non- destructively tested, any pipe with missing material records, and SCC. To ensure TGP properly implements the special permit conditions, TGP will be required to give PHMSA an annual review of their compliance with the special permit. PHMSA finds the issuance and full implementation of this special permit that waives the requirements of 49 CFR 192.611 for a class location change to a Class 3 location is not inconsistent with pipeline safety. This special permit requires TGP to implement the special permit conditions that include safety requirements on the operations, maintenance, and IM of the special permit segments and the special permit inspection area. TGP will be required to implement the special permit conditions in the special permit segments and special permit inspection area, which include areas along the pipeline where periodic assessment is not required by 49 CFR Part 192. Completed in Washington DC on: August 11, 2022 Prepared by: PHMSA - Engineering and Research Division Final Page of the Special Permit Analysis and Findings PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV Page 10 of 10#

2017-0161-Tennessee Gas Pipeline Co Class 1 to 3 SP-LOD-08-11-2022, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 August 11, 2022 Mr. Kenneth W. Grubb Chief Operating Officer Kinder Morgan Natural Gas Division 1001 Louisiana Street, Suite 1000 Houston, Texas 77002 Re: Docket No. PHMSA-2017-0161 Special Permit from August 11, 2022 to August 11, 2032 Dear Mr. Grubb: On December 7, 2017, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Tennessee Gas Pipeline Company, LLC (TGP)1 applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for a special permit. TGP requested a special permit to waive compliance with 49 CFR §§ 192.611(a) and (d), and 192.619(a) for Class 1 to Class 3 location changes on three (3) pipeline segments for approximately 1.050 miles of 20-inch diameter gas transmission pipelines (Pipelines) located in Kanawha County, West Virginia. A gas transmission pipeline operator is required by 49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure of a pipeline segment where the class location has changed as defined in 49 CFR § 192.5. On April 5, 2022, PHMSA published a Federal Register notice (87 FR 19735) announcing the Special Permit Request. The Special Permit Request letter, Final Environmental Assessment (FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings (SPAF), and all other pertinent documents for this special permit are available in Docket No. PHMSA-2017-0161 in the Federal Docket Management System located at www.regulations.gov.2 Subject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based on the information provided by TGP and the findings set forth in the SPAF, FEA, and FONSI. This special permit provides relief from certain provisions of the Federal pipeline safety 1 Tennessee Gas Pipeline Company, LLC is owned by Kinder Morgan, Inc. 2 https://www.regulations.gov/docket?D=PHMSA-2017-0161.#

2017-0161-Tennessee Gas Pipeline Co Class 1 to 3 SP-LOD-08-11-2022, page 2regulations for the Pipelines and requires TGP to comply with conditions and limitations designed to maintain pipeline safety as defined in the special permit. Note that in accordance with 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or modify this special permit if circumstances occur in which its continuance would be inconsistent with safety. If TGP elects not to implement the special permit conditions, TGP must notify PHMSA within 60 days and comply with 49 CFR § 192.611 within 18 months of the date of this letter. My staff would be pleased to discuss this special permit 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; and James Urisko, Director, Office of Pipeline Safety, Southern Region, may be contacted at 404-832-1150, for operational matters specific to this special permit. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure: Special Permit – PHMSA-2017-0161 Special Permit: PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Letter of Decision – Class 1 to 3 Location – West Virginia Page 2 of 2#