Tennessee Gas Pipeline Company, LLC — Pipeline Special Permit

2022-0035 - TGP - Class 1 to 3 SP - 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-2022-0035 Requested By: Tennessee Gas Pipeline Company, LLC Operator ID#: 19160 Original Date Requested: March 1, 2022 Original Issuance Date: July 24, 2023, to July 24, 2033 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 natural gas transmission pipeline segments, 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 2.19 miles of the 30-inch diameter 500-1 Line, 3.41 miles of the 30-inch diameter 800-1 Line and 2.41 miles of the 36-inch diameter 500- 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-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 1 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 22 Line Pipelines located in Cheatham, Robertson, Dickson, and Hickman Counties, Tennessee. 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 Minimum Outside Line Diameter Name Year Installed Seam Type Coating Type Grade Wall Thickness (inches) MAOP Test Pressure (psig) Pressure Test Factor (inches) 500-1 30 1959 DSAW X52 0.375 936 (psig) 1,179 1.26 500-2 36 1965 800-1 30 1954 Coal tar enamel DSAW / ERW Coal tar enamel X60 0.39 936 1,310 1.40 X52 0.375 EW Coal tar enamel 936 1,201 1.28 Note: EW is either a single or double submerged arc welded pipe longitudinal seam. ERW is electric resistance welded pipe longitudinal seam. DSAW is double submerged arc welded pipe longitudinal seam. 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 March 1, 2022, 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 or Class 2 to a Class 3 on the 30-inch diameter 500-1 Line, 30-inch diameter 800-1 Line, and 36-inch diameter 500-2 Line Pipelines located in Cheatham, Dickson, Hickman, and Robertson Counties, Tennessee. TGP’s special permit applies to the special permit segments and special permit inspection areas described and defined as follows, using the TGP survey station references: Special Permit Segments: This special permit applies to the special permit segments in this section and are identified using the TGP valve and survey station (SS) references. Special permit segments are divided into two (2) categories: Type A special permit segments and Type B special permit segments. PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 2 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 31) Type A special permit segment include the special permit segment as described in Table 2 – Type A Special Permit Segment. This special permit segment is where the pipe installed has been identified to have a seam type or manufacturer type that is problematic for maintaining pipeline integrity. The type A special permit segment totals approximately 0.472 miles (2,492.68 feet) of pipe. Type A special permit segment must have pressure reduced or be replaced as required by the special permit conditions. Special Outside Permit Line Diameter Length (feet) Table 2 – Type A Special Permit Segments County, State Segment Name Start Survey Station (Valve - SS) End Survey Station No. Dwellings Year Seam Installed Type (inches) (Valve - SS) Number 710 36 500-2 2,492.68 560-2 - 49.8 560-2 - 2542.48 Hickman, TN 18 1968 ERW 2) Type B special permit segments total approximately 7.539 miles (39,805.04 feet) of pipe as described in Table 3 – Type B Special Permit Segments. Type B special permit segments may continue to operate at the MAOP’s listed below with implementation of the special permit conditions by TGP. Special Outside Permit Line Diameter Length (feet) Table 3 – Type B Special Permit Segments County, State Start Survey End Survey Station Station Segment Name No. Dwellings Year Seam Installed Type (inches) (Valve - SS) (Valve - SS) Number 667 30 500-1 495.65 562-1- 5463.6 562-1 - 5959.25 Cheatham, TN 1 1959 DSAW 671 30 500-1 2,410.73 564-1 - 3941.6 564-1 - 6352.33 Robertson, TN 79 1959 DSAW 672 30 500-1 3,888.06 564-1 - 6968.23 564-1 - 10856.29 Robertson, TN 6 1959 DSAW 673 36 500-2 4,669.38 563-2-3 - 68015.73 564-2 - 4016.81 Robertson, TN 20 1965 DSAW 674 36 500-2 2,409.11 564-1 - 4016.81 564-2 - 6425.92 Robertson, TN 74 1965 DSAW 675 36 500-2 3,153.17 564-2 - 7035.82 564-2 - 10188.99 Robertson, TN 3 1965 DSAW 676 30 800-1 664.71 800-1 - 68042.49 865-1 - 68707.2 Robertson, TN 1 1954 EW 677 30 800-1 2,414.56 865-1 - 3942.59 865-1 - 6357.15 Robertson, TN 79 1954 EW 678 30 800-1 3,882.31 865-1 - 6961.01 865-1 - 10843.32 Robertson, TN 6 1954 EW 679 30 800-1 3,906.15 860-1 - 91419.55 860-1 - 95325.7 Dickson, TN 7 1954 EW 680 30 800-1 425.09 863-1 - 5525.4 863-1 - 5950.49 Cheatham, TN 1 1954 EW 707 30 500-1 3,415.68 564-1 - 176.4 564-1 - 2514.5 Robertson, TN 19 1959 DSAW 708 30 800-1 3,410.81 865-1 - 204.7 865-1 - 3615.51 Robertson, TN 20 1954 EW 709 30 800-1 2,345.02 861-1 - 66.3 861-1 - 2411.32 Dickson, TN 17 1954 EW 714 30 500-1 1,347.20 564-1 - 2594.4 564-1 - 3941.60 Robertson, TN 8 1959 DSAW 715 30 800-1 967.4 860-1 - 95478.3 860-1 - 96445.7 Dickson, TN 4 1954 EW PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 3 of 12 MAO P (psig) 936 MAOP (psig) 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 4Special 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 4 – Special Permit Inspection Areas. Table 4 – Special Permit Inspection Areas Special Special Outside Permit Permit Diameter Line Name Inspection Start Survey Station (SS) End Survey Station (SS) Length3 (miles) Area Number Segment(s) Included (inches) 1 667, 671, 672, 714 30 500-1 491.54 559-1 564-1 69928.44 75.90 2 673, 674, 675, 710 36 500-2 559-2A_LAUNCHER 419.88 564-2_RECEIVER 69872.19 75.75 3 676, 677, 678, 679, 680, 708, 709, 715 30 800-1 860-1 491.43 865-1 69836.08 75.89 Public Notice: On June 1, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR 33302) with a closing date of July 1, 2022. PHMSA has reviewed all public comments received for Docket Number PHMSA-2022-0035 through September 22, 2022. PHMSA received public comments concerning this special permit request that have been addressed in the Final Environmental Assessment and Finding of No Significant Impact (FEA and FONSI). The TGP special permit application letter, Federal Register notice, FEA, Finding of No Significant Impact, and all other pertinent documents are available for review in Docket No. PHMSA-2022-0035 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 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 3 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-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 4 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 5maintenance 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 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 segments in a class location changing to Class 4 location will be considered. • This special permit request is for 17 special permit segments where a change has occurred from a Class 1 or Class 2 location to a Class 3 location. • TGP meets this requirement. • No bare pipe will be considered. • The special permit segments are externally coated with coal tar enamel or wax. • 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 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. • TGP meets this requirement. • Records must be produced that show a hydrostatic test to at least 1.25 time the MAOP. The records should include test pressure, year of the test, test duration, and pressure test percent of MAOP for each pipeline: • TGP has communicated that all special permits segments have been tested to at least 1.25 times the MAOP. • TGP meets this requirement. • In-line inspection (ILI) must have been performed with no significant anomalies identified that indicate systemic problems such as stress corrosion cracking (SCC). PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 5 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 6• TGP ran a high-resolution magnetic flux leakage (HR-MFL) ILI for corrosion and deformation ILI for denting. • TGP meets this requirement. • 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 longer segments surrounding each special permit segment as the special permit inspection area. These segments have been extended to the entire segment length between the upstream launcher and downstream receiver on each ILI segment that contains one (1) or more special permit segments. Criteria Matrix: The data submitted by TGP for the special permit segments have been compared to the class location change special permit criteria matrix. • The following special permit segments fall in the probable acceptance column of the criteria matrix for: o Class location change (special permit segments 672, 673, 675, 676, 678, and 679), design stress, depth of pipe cover, test pressure, test failures, local geology, type of service, pressure fluctuations, safety related conditions, direct assessment, ILI type, and damage prevention program. • The following special permit segments fall in the possible acceptance column of the criteria matrix for: o Class location change (Special permit segments 667, 671, 674, 677, 680, 707, 708, 708, 710, 714, and 715) pipe manufactured in 1954, 1959, and 1965; Coating type (coal tar enamel or wax coating which may shield CP when disbonded, causing SCC. 4) • The following special permit segment fall in the required substantial justification column of the criteria matrix for: o Special permit segment 710 has 36-inch diameter ERW seam type. 4 Two (2) types of SCC are found on pipelines: High pH (9 to 11) SCC and near-neutral pH (6 to 8) SCC. Coal tar and asphalt coatings that are disbonded are more prone to have SCC. PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 6 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 7Operational 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 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 has carefully designed a comprehensive set of conditions that TGP must implement to comply with this special permit. Past Enforcement History – January 1, 2012, through January 22, 2023: During January 1, 2012, through January 22, 2023, TGP was cited in 23 enforcement actions with a total of $232,600 in assessed civil penalties. PHMSA issued two (2) Corrective Action Order, six (6) Notice of Amendments, nine (9) Notice of Probable Violations, and six (6) Warning Letters to TGP. Tables 5 and 6 below shows PHMSA’s enforcement actions and civil penalties for TGP: Table 5 - TGP Enforcement Matters from January 1, 2012, through January 22, 2023 Notice of Status Corrective Action Order Notice of Probable Amendment Safety Order Warning Letter Total Violation CLOSED 1 6 9 0 6 22 OPEN 1 0 0 0 0 1 Total 2 6 9 0 6 23 Table 6 - TGP Enforcement Civil Penalty Status January 1, 2012, through January 22, 2023 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $359,200 $232,600 $126,600 $232,600 PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 7 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 8Summary of Enforcement Findings for TGP includes: • Atmospheric Corrosion Control: General and Monitoring; Construction: Compliance with Standards; Control Room Management: Alarm Management, Fatigue Mitigation, and Roles and Responsibilities; External Corrosion Control: Protective Coating and Test Stations; Integrity Management: Continual Process Evaluation and Assessment and High Consequence Area Identification; Maintenance: Compressor Stations-Gas Detection, Compressor Stations- Storage of Combustible Materials, Leak Surveys, Permanent Field Repair of Damage, Pressure Limiting and Regulating Stations Inspection and Testing, Relief Devices, Patrolling, Record Keeping, and Valve Maintenance; OME Procedural Manual: Emergency Plans, General, and Maintenance and Normal Operations; Operations: Continual Surveillance, Emergency Plans, General, and MAOP; Operator Qualification: Qualification Program; Public Awareness: General; Reporting: Incident Reports, Construction, and Pipeline Condition Report; Welding: Limitations on Welders and Procedures. • 49 CFR 191.15, 191.22, 191.27, 192.225, 192.229, 192.303, 192.461, 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 7 below shows PHMSA’s enforcement actions and civil penalties for TGP and the specific 49 CFR Parts 191 and 192 violations: Table 7 - Summary of Enforcement Findings from TGP January 1, 2012, through January 22, 2023 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 Corrosion Control 3 Integrity Management 3 OME Procedural Manual 5 Operation and/or Maintenance 3 Operator Qualification 2 Public Awareness 1 Reporting 1 Welding of Steel in Pipelines 1 Notice of Probable Violation Total: 20 Warning Letter OME Procedural Manual 3 Operation and/or Maintenance 9 Operator Qualification 1 Reporting 1 Warning Letter Total: 14 Grand Total: 45 PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 8 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 9Summary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG, NGPL, SNG, Tejas, and TGP: From January 1, 2012, through January 22, 2023, Kinder Morgan, the operator of TGP, was cited in 64 enforcement actions with a total of $979,900 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 seven (7) Corrective Action Orders, 15 Notice of Amendments, 20 Notices of Probable Violations, and 22 Warning Letters to Kinder Morgan. Tables 8 and 9 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 8 - Kinder Morgan Enforcement Matters from January 1, 2012, through January 22, 2023 Notice of Status Corrective Action Order Notice of Safety Warning Probable Total Amendment Order Letter Violation CLOSED 3 15 20 0 22 60 OPEN 4 0 0 0 0 4 Total 7 15 20 0 22 64 Table 9 - Kinder Morgan Enforcement Civil Penalty Status January 1, 2012, through January 22, 2023 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $1,363,600 $0 $979,900 $383,700 $979,900 The type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline systems from January 1, 2012, through January 22, 2023, were as follows: Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and TGP includes: • Atmospheric Corrosion Control: General and Monitoring; Construction: Compliance with Standards; Control Room Management: Alarm Management and Fatigue Mitigation; Design: Supports and Anchors; External Corrosion Control: Cathodic Protection, Examination of Buried Pipe, Monitoring, and Test Stations; Gas Transportation: Conversion of Service and Underground Natural Gas Storage; Internal Corrosion Control: Inspection Internal Surface; Integrity PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 9 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 10Management: Addressing Integrity Issues, Continual IM Baseline Assessment, Continual Process of Evaluation and Assessment, High Consequence Area (HCA) Identification, HCAs – Integrity Actions, Preventative and Mitigative Measures, and Threat Identification; Maintenance: Compressor Stations-Gas Detection, Compressor Stations-Inspection and Testing of Relief Devices, Compressor Stations-Storage of Combustible Materials, Line Markers, Leak Surveys, Pressure Limiting and Regulating Stations Inspection and Testing, Relief Devices, Patrolling, Record Keeping, and Valve Maintenance; OME Procedural Manual: General and Maintenance and Normal Operations; Operations and Maintenance: Overpressure safety devices and overfill protection systems and Valve Maintenance; Operations: Change in Class Location, Continual Surveillance, Emergency Plans, General, MAOP, and Odorization of Gas; Operator Qualification: Qualification Program and Recordkeeping; Public Awareness: Develop and Implement Public Awareness, Documentation available for Review, Follow API RP 1162, Justification for not following API RP 1162, Language Used, and Specifics addressing the Public; Reporting: Filing SRCR, Incident Reports, Immediate Reporting Incident, National Registry of Pipeline and LNG Operators, Offshore Pipeline Condition Report; Welding: Limitations on Welders and Procedures. • 49 CFR 191.3, 191.5, 191.15, 191.22, 191.23, 191.25, 191.27, 192.3, 192.12, 192.14, 192.161, 192.201, 192.225, 192.227, 192.229, 192.303, 192.459, 192.461, 192.463, 192.465, 192.469, 192.475, 192.479, 192.481, 192.603, 192.605, 192.611, 192.613, 192.615, 192.616, 192.619, 192.625, 192.631, 192.705, 192.706, 192.707, 192.709, 192.713, 192.731, 192.735, 192.736, 192.739, 192.743, 192.745, 192.805, 192.807, 192.905, 192.917, 192.921, 192.933, 192.935, and 192.937. Table 10 below gives a complete summary of the findings and the specific 49 CFR Parts 191 and 192 violations: Table 10 - Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and TGP January 1, 2012, through January 22, 2023 Notice of Amendment Construction 1 Control Room Management 4 Integrity Management 2 OME Procedural Manual 6 Operation and/or Maintenance 2 Operator Qualification 3 Public Awareness 8 Reporting 3 Transportation of Gas 5 Welding of Steel in Pipelines 1 Notice of Amendment Total: 35 PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 10 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 11Table 10 - Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and TGP January 1, 2012, through January 22, 2023 Notice of Probable Violation Corrosion Control 6 Integrity Management 9 OME Procedural Manual 11 Operation and/or Maintenance 14 Operator Qualification 8 Public Awareness 2 Reporting 4 Welding of Steel in Pipelines 2 Notice of Probable Violation Total: 56 Warning Letter Corrosion Control 13 Design 1 Integrity Management 1 OME Procedural Manual 13 Operation and/or Maintenance Public Awareness 4 Reporting 43 Warning Letter Total: Operator Qualification 4 4 Transportation of Gas 1 84 Grand Total: 167 Findings: 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 that requires TGP to operate the 17 special permit segments on the 30-inch diameter 500-1 Line, 30-inch diameter 800-1 Line, and 36-inch diameter 500-2 Line Pipelines located in Cheatham, Robertson, Dickson, and Hickman Counties, Tennessee, at either their current MAOP for a Class 1 to Class 3 location change segment 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 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(a) and (d) and 192.619(a) 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 integrity management of the special permit segments and the special permit inspection areas. TGP will be required to PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 11 of 12#

2022-0035 - TGP - Class 1 to 3 SP - SPAF, page 12implement 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 24, 2023 Prepared by: PHMSA - Engineering and Research Division PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – Tennessee Page 12 of 12#

2022-0035 - TGP - Class 1 to 3 LOD, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 July 24, 2023 Kenneth W. Grubb Chief Operating Officer Kinder Morgan Natural Gas Division 1001 Louisiana Street, Suite 1000 Houston, Texas 77002 Re: Docket No. PHMSA-2022-0035 Special Permit from July 24, 2023, to July 24, 2033 Dear Mr. Grubb: On March 1, 2022, 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 17 pipeline segments for approximately 8.011 miles of 30-inch diameter and 36-inch diameter gas transmission pipelines (Pipelines) located in Cheatham, Dickson, Hickman, and Robertson Counties, Tennessee. 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 June 1, 2022, PHMSA published a Federal Register notice (87 FR 33302) 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-2022-0035 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 regulations for the Pipelines and requires TGP to comply with conditions and limitations designed to maintain 1 Tennessee Gas Pipeline Company, LLC is owned by Kinder Morgan, Inc. 2 https://www.regulations.gov/docket?D=PHMSA-2022-0035.#

2022-0035 - TGP - Class 1 to 3 LOD, page 2pipeline 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 pipeline 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 is available to discuss this special permit or any other regulatory matter with you. Mary McDaniel, Acting Director of PHMSA Engineering and Research Division, may be contacted at 713-272-2847, 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-2022-0035 Special Permit: PHMSA-2022-0035 – Tennessee Gas Pipeline Company, LLC Letter of Decision – Class 1 to 3 Location – Tennessee Page 2 of 2#