Southern Natural Gas Company, LLC — Pipeline Special Permit

SNG Class 1 to 3 - GA MS - SPAF, page 1Official PDFU.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION Special Permit Analysis and Findings Class 1 to 3 Locations Special Permit Information: Docket Number: PHMSA-2020-0007 Requested By: Southern Natural Gas Company, LLC Operator ID#: 18516 Original Date Requested: December 23, 2019 Original Issuance Date: July 27, 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 Southern Natural Gas Company, LLC (SNG), 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. SNG requested that PHMSA waive compliance from the 49 Code of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for natural gas transmission pipeline segments, where the class location has changed from Class 1 to a Class 3 locations. Pipeline System Affected: This special permit application applies to the SNG request for a waiver of the class location change requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 0.621 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 Southern Natural Gas Company, LLC is owned by Kinder Morgan, Inc. PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 1 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 2miles of gas transmission pipelines located in Effingham and Harris Counties, Georgia; and Clarke County, Mississippi. 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 Seam Line Name Diameter Installed Type Coating Type MAOP Grade Thickness Pressure Test (psig) (inches) (inches) (psig) Factor Cypress Line 24 2007 ERW-HF FBE X70 0.298 1,250 1,602 1.28 South Main 2nd Loop Line 26 1967 DSAW Coal Tar Enamel X60 0.375 1,200 1,600 1.33 South Main 3rd Loop Line 36 2003 / 2004 DSAW Polymer Concrete X70 0.562 0.438 / 1,200 1,552 / 1,881 1.29 Notes: ERW-HF is Electric Resistance Welded-High Frequency. DSAW is double submerged arc welded pipe weld seam type. PSIG is pounds per square inch gauge. Without this special permit, 49 CFR 192.611(a) would require SNG 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 23, 2019, SNG 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 location on the 24-inch diameter Cypress Line, 26-inch diameter South Main 2nd Loop Line, and 36-inch diameter South Main 3rd Loop Line Pipelines in Effingham and Harris Counties, Georgia; and Clarke County, Mississippi. This special permit applies to the special permit segments and special permit inspection areas described and defined as follows, using the SNG survey station references: PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 2 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 3Special Permit Segments: This special permit applies to the special permit segments in Table 2 – Special Permit Segments and are identified using the SNG mile post (MP) and survey station (SS) references. Table 2 – Special Permit Segments Special Permit Outside Start Survey End Survey Segment Diameter Line Name Number3 Length (feet) County, No. Year Seam MAOP Station (MP Station (MP State Dwellings Installed Type (psig) (inches) - SS) - SS) 1 (KM 555) 24 Cypress Line 1,503.00 2 – 3968 3 – 191 GA Effingham, 1 2007 ERW- HF 1,250 2 (KM 556) 26 South Main 2nd Loop Line 224.78 77 – 1899 77 – 2124 Clarke, MS 3 1967 DSAW 1,200 4 (KM 558) 36 South Main 3rd Loop Line 329.96 77 – 1728 77 – 2058 Clarke, MS 4 2003 DSAW 1,200 5 (KM 559) 36 South Main 3rd Loop Line 1,220.32 315 – 1862 315 – 3083 Harris, GA 7 2004 DSAW 1,200 Note: ERW-HF is a high frequency electric resistance welded pipe longitudinal seam. DSAW is double submerged arc welded pipe longitudinal seam. Special Permit Inspection Areas: The special permit inspection areas are defined as the area that extends 220 yards on each side of the centerline as listed in Table 3 – Special Permit Inspection Areas. Table 3 – Special Permit Inspection Areas Special Special Permit Outside Start Survey End Survey Permit Length4 Inspection Diameter Line Name Master Segment Station Station Segment(s) (miles) Area (inches) (SS) (SS) Included Number 24 87.63 1 1 (KM 555) Cypress Line Cypress Line 1 00 – 24.78 87 – 4810 2 2 (KM 556) 26 South Main 2nd Loop Line Enterprise to York 67 – 1394 102 – 4372 35.57 3 4 (KM 558) 36 South Main 3rd Loop Line Enterprise Station 67 – 1631 97 – 2268 30.06 4 5 (KM 559) 36 South Main 3rd Loop Line D/S of Ellerslie 311 - 3355 328 - 1743 16.46 Public Notice: On January 22, 2021, PHMSA posted a notice of this special permit request in the Federal Register (86 FR 6737) with a closing date of February 22, 2021. PHMSA received no comments 3 On February 3, 2022, SNG rescinded requested special permit segments number 3 (KM 557) and 6 (KM 560). These segments were withdrawn at the request of PHMSA 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-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 3 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 4on this special permit application during the comment period. PHMSA has reviewed this special permit application to ensure the special permit conditions address pipeline safety and integrity threats to the pipeline in the special permit segments and special permit inspection areas. The special permit will require SNG’s Operations and Maintenance (O&M) Manual and Procedures to provide a systematic program to review and remediate the pipeline for safety concerns. Additional operational integrity reviews and remediation requirements will be required by this special permit for these special permit segments for Class 1 to 3 location changes. The SNG special permit application letter, Federal Register notice, Final Environmental Assessment and Finding of No Significant Impact, special permit with conditions, special permit analysis and findings document, and all other pertinent documents are available for review in Docket No. PHMSA-2020-0007 in the Federal Docket Management System (FDMS) located on the internet 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 through a special permit. First, certain threshold requirements should be met on a pipeline special permit segment 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 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 integrity management provides 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 SNG special permit request. PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 4 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 51) No pipeline segments in a class location changing to Class 4 location will be considered. • This special permit request is for the special permit segments the 24-inch diameter Cypress Line, 26-inch diameter South Main 2nd Loop Line, and 36-inch diameter South Main 3rd Loop Line Pipelines, where a change has occurred from a Class 1 location to a Class 3 location. • SNG has met this requirement. 2) No bare pipe will be considered. • The special permit segments are externally coated with poly concrete, epoxy, coal tar enamel, or fusion bonded epoxy. • SNG has met this requirement. 3) No pipe containing wrinkle bends will be considered. • There are no wrinkle bends in the special permit segments. • SNG has met this requirement. 4) No pipe segments 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. • SNG has met this requirement. 5) Records must be produced that show a hydrostatic test to at least 1.25 times MAOP and 90% of SMYS. The records should include test pressure, year of the test, test duration, and pressure test percent of MAOP for each pipeline: • The special permit segments on the Cypress Line, South Main 2nd Loop Line, and South Main 3rd Loop Line Pipeline were all pressure tested for 8 hours to at least 1.25 times the pipeline MAOP. • SNG has met this requirement. 6) Inline inspection (ILI) must have been performed with no significant anomalies identified that indicate systemic problems such as stress corrosion cracking (SCC). • SNG ran ILI tools on the Cypress Line Pipeline in 2016. • SNG ran ILI tools on the South Main 2nd Loop Line Pipeline in 2010. • SNG ran ILI tools on the South Main 3rd Loop Line Pipeline one segment was completed in 2014 and the other in 2019. • SNG has met this requirement. PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 5 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 67) 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). • A special permit would be contingent upon SNG’s incorporation of the special permit segments in its written integrity management program as covered segments in a high consequence area in accordance with 49 CFR 192.903 and to assess and remediate threats to the special permit inspection areas. Criteria Matrix: The data submitted by SNG for the special permit segments have been compared to the class location change special permit criteria matrix and are as follows: • The special permit segments fall in the probable acceptance column of the criteria matrix for: o Design stress, test failures, pressure fluctuations, safety related condition reports, program, ILI type, direct assessment, coating assessment, and damage prevention. • The special permit segments fall in the possible acceptance column of the criteria matrix for: o Class 1 to 3 location, pipe manufacture, pipe girth welds, pipe coating, test pressure, depth of cover, local geology, leaks and failures, service, cathodic protection (CP), ILI timeframe, and inspection findings. • The special permit segments fall in the requires substantial justification column of the criteria matrix for: o Kinder Morgan, Inc. overall enforcement findings fall in the requires substantial justification category. SNG’s 11-year enforcement findings do not fall within this category. o This special permit requires SNG to implement the special permit conditions that include safety requirements on the operations, maintenance, and integrity management of the special permit segments (approximately 0.621 miles) and the special permit inspection areas (169.72 miles). Therefore, the safety benefits are obtained well beyond the portion of the pipeline that experienced a class location change. PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 6 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 7o SNG will be required to submit to PHMSA an annual report for this special permit on integrity threats to the pipeline in the special permit segment 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 areas. This integrity information was used to design 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, CP 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 CP system to be ineffective. PHMSA has carefully designed a comprehensive set of conditions that SNG 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, SNG was cited in four (4) enforcement actions. PHMSA issued one (1) Notice of Amendment, one (1) Notice of Probable Violation and two (2) Warning Letters to SNG. Tables 4 and 5 below show PHMSA’s enforcement actions and civil penalties for SNG: Table 4: SNG 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 0 1 1 0 2 4 OPEN 0 0 0 0 0 0 Total 0 0 1 0 2 4 PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 7 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 8Table 5: SNG Enforcement Civil Penalty Status January 1, 2011 through January 31, 2022 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $72,900 $0 $72,900 $0 $72,900 Summary of Enforcement Findings for SNG includes: Reporting, welding, conversion of service, operations and maintenance procedures, records, and integrity management: • 49 CFR 192.161, 192.163, 192.3, 192.465, 192.475, 192.605, 192.705, 192.709, 192.735, 192.745, and 192.911, Table 6 below shows PHMSA’s enforcement actions and civil penalties for SNG and the specific 49 CFR Part 191 and 192 violations: Table 6: Summary of Enforcement Findings for SNG January 1, 2011 through January 31, 2022 Notice of Amendment OME Procedural Manual 4 Integrity Management 7 Notice of Amendment Total: 11 Notice of Probable Violation Corrosion Control 2 Operation and/or Maintenance 1 Integrity Management 3 OME Procedural Manual 2 Design 1 Notice of Probable Violation Total: 10 Warning Letter Design 1 Operation and/or Maintenance 2 Warning Letter Total: 3 Grand Total: 24 Summary 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 NGPL, was cited in 64 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 sixteen (16) Notice of Amendments, twenty-two PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 8 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 9(22) Notices of Probable Violations, twenty-one (21) Warning Letters, one (1) Safety Order, and six (6) 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: reporting, design, welding, compliance with specifications or procedures, corrosion control, operations and maintenance procedures, continuing surveillance, public awareness, emergency plans, maximum allowable operating pressure, control room management, relief devices, maintenance of valves, qualification of operating personnel, and integrity management: • 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: PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 9 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 10Table 9 – Summary of Enforcement Findings for CIG, EPNG, Tejas, NGPL, SNG, 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 Findings: Based on the information submitted by SNG and PHMSA’s analysis of the technical, operational, and safety issues, PHMSA finds that granting this special permit to SNG to operate the special permit segments on the 24-inch diameter Cypress Line, 26-inch diameter South Main 2nd Loop Line, and 36-inch diameter South Main 3rd Loop Line Pipelines in Harris and Effingham Counties, Georgia, and Clarke County, Mississippi, for approximately 0.621 miles of Class 1 location pipe in a Class 3 location is consistent 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 areas, 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 SNG properly implements the special permit conditions, SNG will be required to give PHMSA an annual review of their compliance with the special permit. PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 10 of 11#

SNG Class 1 to 3 - GA MS - SPAF, page 11PHMSA finds that no significant negative impact to human safety and the environment will result from the issuance and full implementation of a special permit that waives the requirements of 49 CFR 192.611 for class location changes to a Class 3 location. This special permit requires SNG to implement the special permit conditions that include safety requirements on the operations, maintenance, and integrity management of the special permit segments and the special permit inspection areas. SNG will be required to implement the special permit conditions along the special permit segments and special permit inspection areas in pipeline segments that are not high consequence areas and would not normally be required by 49 CFR Part 192 to be assessed on a periodic interval for threats. Completed in Washington DC on: July 27, 2022 Prepared by: PHMSA - Engineering and Research Division Final Page of the Special Permit Analysis and Findings PHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA Page 11 of 11#

SNG Class 1 to 3 - GA MS - LOD LD, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 July 27, 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-2020-0007 Special Permit from July 27, 2022 to July 27, 2032 Dear Mr. Grubb: On December 23, 2019, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Southern Natural Gas Company, LLC (SNG)1 applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for a special permit. SNG 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 four (4) pipeline segments for approximately 0.621 miles of 24-inch, 26-inch, and 36-inch diameter gas transmission pipelines (Pipelines) located in Effingham and Harris Counties, Georgia; and Clarke County, Mississippi. 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 January 22, 2021, PHMSA published a Federal Register notice (86 FR 6737) 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-2020-0007 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 SNG 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 Southern Natural Gas Company, LLC is owned by Kinder Morgan, Inc. 2 https://www.regulations.gov/docket?D=PHMSA-2020-0007.#

SNG Class 1 to 3 - GA MS - LOD LD, page 2regulations for the Pipelines and requires SNG 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 SNG elects not to implement the special permit conditions, SNG 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, LINDA GAIL DAUGHERTY Digitally signed by LINDA GAIL DAUGHERTY Date: 2022.07.27 15:42:54 -04'00' (on behalf of) Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure: Special Permit – PHMSA-2020-0007 Special Permit: PHMSA-2020-0007 – Southern Natural Gas Company, LLC Letter of Decision – Class 1 to 3 – Georgia and Mississippi Page 2 of 2#

Final Signed LOD SPAF 2020-0007-1 - Extension, page 1Official PDF1200 New Jersey Avenue, SE Washington, D.C. 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration December 19, 2025 Zach Ragain Director – Engineering: Codes and Standards Kinder Morgan 1001 Louisiana St, Suite 1000 Houston, TX 77002 Re: Docket No. 2020-0007 – Southern Natural Gas Company, LLC – Harris County, Georgia Dear Mr. Ragain: On September 26, 2024, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Southern Natural Gas Company, LLC1 (SNG) applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) seeking an extension to a special permit segment to be incorporated in the special permit PHMSA-2020-0007, effective through July 27, 2032. The special permit waives compliance with 49 CFR §§ 192.611(a) and (d) and 192.619 for Class 3 pipeline segments and allows SNG to continue operation of the original Class 1 design pipe in Class 3 locations subject to the conditions set forth in the special permit. SNG has requested one special permit segment extension, 0.19 miles of 36-inch-diameter natural gas transmission pipeline located in Harris County, Georgia. The amended special permit would consist of two special permit segments of 0.70 miles in total of 24-inch and 36-inch-diameter natural gas transmission pipeline located in Effingham and Harris Counties, Georgia. On October 31, 2025, PHMSA published a Federal Register notice (90 FR 209) announcing the special permit request and seeking public comment. The special permit amendment request letter and other pertinent documents are available for review under Docket No. PHMSA-2020-0007 in the Federal Docket Management System (FDMS) located at www.regulations.gov. 2 Summary of Public Comments: PHMSA received two public comments submitted by anonymous commenters during the 30-day comment period. Both commenters opposed the modification request; one commenter cited concerns of pipeline incidents related to deregulation, 1 Southern Natural Gas Company, LLC is a subsidiary of Kinder Morgan Inc. 2 https://www.regulations.gov/docket?D=PHMSA-2020-0007 Modification of Class Location Special Permit PHMSA-2020-0007 Letter of Decision and Special Permit Findings and Analysis – Georgia Page 1#

Final Signed LOD SPAF 2020-0007-1 - Extension, page 2and the other communicated concerns of increased risk associated with grant of waivers from the Federal pipeline safety regulations in areas of population growth. PHMSA Response: PHMSA has authority to grant amendments to waivers from compliance with class location change requirements to applicants who demonstrate that their request is not inconsistent with pipeline safety. PHMSA has conducted a review of this request and decided that the incorporation of the extended special permit segments would not require a material change in conditions. Based on the information provided by SNG, PHMSA decided that amendment of the special permit would not be inconsistent with pipeline safety. Details of the incorporated segments and access to maps were published previously and can be viewed in the FDMS. On September 25, 2025, PHMSA reviewed the special permit request for compliance with the National Environmental Policy Act (NEPA). PHMSA determined that the following Categorical Exclusion (CE) is applicable to the special permit segment extension: Granting, renewing, or denying a special permit related to waiving class location or odorization requirements, following the procedures set forth in 49 CFR § 190.341, including the identification of any enforceable conditions, imposed pursuant to 49 CFR § 190.341(d)(2), that are required to prevent and address pipeline safety and environmental risk. PHMSA has further determined that no extraordinary circumstances apply. In order to ensure continued human and environmental safety, the operator must fulfill the mitigation conditions of the special permit; continue to employ good operating practices; and continue to follow any additional applicable permitting requirements, State laws, or other pre-existing Federal requirements related to environmental protection. Should conditions change, or should extraordinary circumstances materialize, the operator must contact PHMSA for reevaluation. The proposed action is hereby categorically excluded from further NEPA review, and the finalized CE will be published online.3 Accordingly, pursuant to 49 CFR § 190.341, by this Order—and as outlined in the existing special permit—PHMSA grants the amendment of special permit PHMSA-2020-0007, effective through July 27, 2032, to SNG. This special permit amendment Order continues to waive compliance with certain Federal regulations in 49 CFR §§ 192.611(a) and (d) and 192.619(a). My staff would be pleased to discuss this special permit or any other regulatory matter with you. Max Kieba, Director of Engineering and Research Division, may be contacted at (202) 420-9169 for 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, Linda Daugherty Acting Associate Administrator for Pipeline Safety 3 https://www.phmsa.dot.gov/planning-and-analytics/environmental-analysis-and-compliance/implementing-procedures Modification of Class Location Special Permit PHMSA-2020-0007 Letter of Decision and Special Permit Findings and Analysis – Georgia Page 2#