Colorado Interstate Gas Company, LLC — Pipeline Special Permit

2022-0038 - Colorado Interstate Gas 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-2022-0038 Requested By: Colorado Interstate Gas Company, LLC Operator ID#: 2564 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 Colorado Interstate Gas Company, LLC (CIG)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. CIG 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 CIG requests a waiver from the class location change requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 1.40 miles of the 24-inch diameter 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 CIG is a wholly owned subsidiary of Kinder Morgan, Inc. PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 1 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 2Denver-Rock Springs Loop Pipeline located in Adams County, Colorado. 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 Name Diameter Year Installed Seam Type Coating Type Grade Wall Thickness (inches) MAOP Test Pressure (psig) Pressure Test Factor (inches) Denver-Rock Springs Loop 24 1978 ERW-HF Tape X60 0.25 850 (psig) 1,112 1.31 Without this special permit, 49 CFR 192.611(a) would require CIG to replace the special permit segment with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change. Special Permit Request: On March 1, 2022, CIG 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 segment, where a class location change occurred from the original Class 1 to a Class 3 on the 24-inch diameter Denver-Rock Springs Loop Pipeline located in Adams County, Colorado. CIG’s special permit applies to the special permit segment and special permit inspection area described and defined as follows, using the CIG survey station references: Special Permit Segment: This special permit applies to the special permit segment in Table 2 – Special Permit Segment and are identified using the CIG mile post (MP) and survey station (SS) references. Table 2 – Special Permit Segment Special Outside Permit Diameter Line Name Length (feet) Start Survey Station End Survey Station County, State No. Year Seam MAOP Segment Number Dwellings Installed Type (psig) (inches) (MP - SS) (MP -SS) 650 24 Denver-Rock Springs Loop 7,387 004 - 3085 005 - 5192 Adams, CO 9 1978 ERW- HF 850 PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 2 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 3Special Permit Inspection Areas: The special permit inspection area is defined as the area that extends 220 yards on each side of the centerline as listed in Table 3 – Special Permit Inspection Area. Table 3 – Special Permit Inspection Area Special Special Outside Permit Permit Diameter Line Name Inspection Start Survey Station (MP - SS) End Survey Station (MP - SS) Length3 (miles) Area Number Segment(s) Included (inches) 1 650 24 Denver-Rock Springs Loop 004 - 2161.73 085 - 3469 81 Public Notice: On May 27, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR 32235) with a closing date of June 27, 2022. PHMSA received no public comments concerning this special permit request through June 27, 2022. The CIG 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-2022-0034 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 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 provide a level of safety greater than or equal to a pipe replacement or 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-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 3 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 4pressure 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 CIG special permit request. • No pipeline segment in a class location changing to Class 4 location will be considered. • This special permit request is for one (1) special permit segment where a change has occurred from a Class 1 location to a Class 3 location. • CIG meets this requirement. • No bare pipe will be considered. • The special permit segment is externally coated with polyethylene tape. • CIG meets this requirement. • No pipe containing wrinkle bends will be considered. • There are no reported wrinkle bends in the special permit segment. • CIG 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 segment operates at or below 72% SMYS. • CIG 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: • CIG has communicated that the special permits segment has been tested to at least 1.25 times the MAOP. • CIG 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). • CIG ran a high-resolution magnetic flux leakage (HR-MFL) ILI for corrosion and deformation ILI for denting. • CIG meets this requirement. PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 4 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 5• 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). • CIG has identified longer segment surrounding each special permit segment as the special permit inspection area. This segment has been extended to the entire segment length between the upstream launcher and downstream receiver for the ILI segment that contains the special permit segment. Criteria Matrix: The data submitted by CIG for the special permit segment have been compared to the class location change special permit criteria matrix. • The following special permit segment fall in the probable acceptance column of the criteria matrix for: o 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 segment fall in the possible acceptance column of the criteria matrix for: o Pipe manufactured in 1978, class location change, coating type (polyethylene tape coating may shield CP when disbanded and lead to SCC4) 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 segment 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 4 Two (2) types of SCC are found on pipelines: high pH (9 to 11) SCC and near-neutral pH (6 to 8) SCC. Polyethylene tape coatings that are disbonded are more prone to have SCC. PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 5 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 6remediate 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 CIG 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, CIG was cited in five (5) enforcement actions with a total of $154,800 in assessed civil penalties. PHMSA issued one (1) Notice of Amendment, one (1) Notice of Probable Violation, and three (3) Warning Letters to CIG. Tables 4 and 5 below shows PHMSA’s enforcement actions and civil penalties for CIG: Table 4 - CIG 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 0 1 1 0 3 5 OPEN 0 0 0 0 0 0 Total 0 1 1 0 3 5 Table 5 - CIG Enforcement Civil Penalty Status January 1, 2012, through January 22, 2023 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $198,000 $154,800 $43,200 $154,800 Summary of Enforcement Findings for CIG includes: • Corrosion Control: Records; Integrity Management: High Consequence Area – Integrity Actions and Preventative and Mitigative Measures; OME Procedural Manual: General and Maintenance and Normal Operations; Operations and Maintenance: Overpressure safety devices and overfill protection systems, Valve Maintenance, and General; Reporting: Immediate Reporting Incident; Transportation of Gas: Conversion to Service. • 49 CFR 191.5, 191.14, 192.461, 192.475, 192.491, 192.603, 192.605, 192.745, and 192.935. PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 6 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 7Table 6 below shows PHMSA’s enforcement actions and civil penalties for CIG and the specific 49 CFR Parts 191 and 192 violations: Table 6 - Summary of Enforcement Findings from CIG January 1, 2012, through January 22, 2023 Notice of Amendment OME Procedural Manual 1 Reporting 1 Transportation of Gas 1 Notice of Amendment Total: 3 Notice of Probable Violation Integrity Management 3 Operation and/or Maintenance 2 Notice of Probable Violation Total: 5 Warning Letter Corrosion Control 1 Integrity Management 1 OME Procedural Manual 1 Operation and/or Maintenance 1 Warning Letter Total: 4 Grand Total: 12 Summary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG, NGPL, SNG, Tejas, and CIG: From January 1, 2012, through January 22, 2023, Kinder Morgan, the operator of CIG, 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 (CIG) 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 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 CIG - with operator identification numbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160. Table 7 - Kinder Morgan Enforcement Matters from January 1, 2012, through January 22, 2023 Notice of Status Corrective Action Order Notice of Safety Probable Amendment Order Warning Letter Total Violation CLOSED 3 15 20 0 22 60 OPEN 4 0 0 0 0 4 Total 7 15 20 0 22 64 PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 7 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 8Table 8 - 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 CIG 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 Management: 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, PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 8 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 9192.201, 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 6 below gives a complete summary of the findings and the specific 49 CFR Parts 191 and 192 violations: Table 9 - Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and CIG 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 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 CIG and PHMSA’s analysis of the technical, operational, and safety issues, PHMSA finds that granting this special permit with conditions that requires CIG to operate the special permit segment on 24-inch diameter Denver-Rock Springs Loop Pipeline located in Adams County, Colorado at its current MAOP for a Class 1 to Class 3 location change would not be inconsistent with pipeline safety. PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 9 of 10#

2022-0038 - Colorado Interstate Gas SPAF, page 10PHMSA has designed the special permit conditions to effectively assess and remediate threats to the special permit segment 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 CIG properly implements the special permit conditions, CIG 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 CIG to implement the special permit conditions that include safety requirements on the operations, maintenance, and integrity management of the special permit segment and the special permit inspection area. CIG will be required to implement the special permit conditions along the special permit segment and special permit inspection area 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-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado Page 10 of 10#

2022-0038 - Colorado Interstate Gas 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-2022-0038 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, Colorado Interstate Gas Company, LLC (CIG)1 applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for a special permit. CIG 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 one (1) pipeline segment for approximately 1.40 miles of 24-inch diameter gas transmission pipeline (Pipeline) located in Adams County, Colorado. 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 May 27, 2022, PHMSA published a Federal Register notice (87 FR 32235) 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-2022-0038 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 CIG 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 Pipeline and requires CIG 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), 1 Colorado Interstate Gas Company, LLC is owned by Kinder Morgan, Inc. 2 https://www.regulations.gov/docket?D=PHMSA-2022-0038.#

2022-0038 - Colorado Interstate Gas LOD, page 2PHMSA 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 CIG elects not to implement the special permit conditions, CIG must notify PHMSA within 60 days and comply with 49 CFR § 192.611 within 18 months of the date of this letter. My staff 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-2022-0038 Special Permit: PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Letter of Decision – Class 1 to 3 Location – Colorado Page 2 of 2#