EcoElectrica, L.P. — Pipeline Special Permit

2023-0114 - EcoElectrica_-_LOD, page 1Official PDF1200 New Jersey Avenue, S.E. Washington, D.C. 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration April 3, 2026 Mr. Carlos Reyes President & General Manager EcoEléctrica LNG Terminal 641 Road 337 k.m. 3.7 Bo. Tallaboa Poniente Peñuelas, PR 00624-9804 Re: Docket No. PHMSA-2023-0114 – EcoEléctrica, L.P. – Tallaboa Poniente, Peñuelas, Puerto Rico Dear Mr. Reyes: On September 8, 2023, 1 EcoEléctrica, L.P. (EcoEléctrica) filed an application with the Pipeline and Hazardous Materials Safety Administration (PHMSA) for a special permit. The application asked PHMSA to waive compliance with Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) §§ 193.2167 and 193.2173 for its LNG Supply Pipeline Project (or Project). The Project transfers liquefied natural gas (LNG) from the existing LNG import terminal, located in Peñuelas, Puerto Rico (EcoEléctrica LNG Terminal), to the LNG Truck Loading Facility (TLF) owned by Crowley Puerto Rico. Part 193 regulations prohibit a covered impounding and water removal system. PHMSA grants this special permit based on the findings set forth in the “Special Permit Analysis and Findings,” “Final Environmental Assessment,” and “Finding of No Significant Impact” documents. These documents can be read in their entirety in Docket No. PHMSA- 2023-0114 in the Federal Docket Management System located at www.regulations.gov. This special permit waives EcoEléctrica’s obligation to comply with the requirements in 49 CFR §§ 193.2167 and 193.2173, subject to certain terms, conditions, and limitations. The special permit includes conditions pertaining to operation and maintenance procedures, management of change, reporting of repairs, quality assurance and quality control plan, and documentation. EcoEléctrica must have and implement procedures for monitoring and ensuring a safe working environment at all EcoEléctrica LNG Terminal facilities exposed to the atmosphere. 1 EcoEléctrica submitted supplemental information for its application on May 31 and October 31, 2024, and January 2 and January 27, 2025. PHMSA-2023-0114 – EcoEléctrica LNG Terminal LLC – Letter of Decision Page 1 of 2#

2023-0114 - EcoElectrica_-_LOD, page 2Should you have any technical questions regarding this special permit, please contact Max Kieba, Director, Office of Pipeline Safety, Engineering and Research Division, at 202-420-9169. For any questions related to operational matters, please contact Bryan Lethcoe, Director, Office of Pipeline Safety, Southwest Region, at 713-773-7215. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures: • Final Conditions – EcoEléctrica (Final Conditions-2023-0114-EcoElectrica) • Final Environmental Assessment – EcoEléctrica (FEA-2023-0114-EcoElectrica) • Finding of No Significant Impact – EcoEléctrica (FONSI-2023-0114-EcoElectrica) • Special Permit Analysis and Findings – EcoEléctrica (SPAF-2023-0114-EcoElectrica) PHMSA-2023-0114 – EcoEléctrica LNG Terminal LLC – Letter of Decision Page 2 of 2#

2023-0114 - EcoElectrica_-_SPAF, page 1Official PDFU.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT ANALYSIS AND FINDINGS LNG Vacuum Jacketed (VJ) Piping System EcoEléctrica LNG Terminal Peñuelas, Puerto Rico Special Permit Information: Docket Number: PHMSA-2023-0114 Requested By: EcoEléctrica, L.P. Operator ID#: 32561 Original Date Requested: September 8, 2023 Original Issuance Date: April 3, 2026 Code Section(s): 49 CFR §§ 193.2167 and 193.2173 Purpose: The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), 1 prepared this document to provide information related to the special permit application submitted by EcoEléctrica, L.P. (EcoEléctrica). The document discusses the relevant public comments received with respect to the application; presents the engineering and safety analysis of the special permit application; and makes findings regarding whether the requested special permit should be granted and, if so, under what conditions. Liquefied Natural Gas (LNG) Facility Affected: This special permit waives compliance with certain regulations in 49 Code of Federal Regulations (CFR) Part 193, subpart C – Design, for EcoEléctrica’s Liquefied Natural Gas (LNG) Terminal located in Peñuelas, Puerto Rico. The special permit waives the regulations in 49 CFR §§ 193.2167 and 193.2173, which prohibit a covered impounding system and require impounding areas to be constructed to prevent water collection. 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. Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 1 of 6#

2023-0114 - EcoElectrica_-_SPAF, page 2The LNG Supply Pipeline Project (or Project) is located entirely within the EcoEléctrica LNG Terminal property on the south coast of Puerto Rico, in the Municipality of Peñuelas. Appendix A depicts the location of the EcoEléctrica LNG Terminal, LNG Truck Loading Facility (TLF), and Project route for the special permit segments (shown as red lines). On February 13, 2022, EcoEléctrica placed into service the Project, which transfers LNG from the EcoEléctrica LNG Terminal to the TLF owned by Crowley Puerto Rico. The Project uses pipe-in-pipe (PIP) technology, which includes an inner pipe that handles the process fluid (i.e., LNG) and an outer pipe serving as the impounding system. The outer pipe covers the inner pipe entirely to contain any LNG leakage from the inner pipe. The EcoEléctrica special permit segments include: • LNG transfer line: Approximately 3,600 feet (0.7 miles) of PIP segment with a six-inch diameter outer pipe and a four-inch diameter inner pipe, used to transfer LNG from the EcoEléctrica LNG Terminal to the Crowley TLF. • LNG recirculation line: Approximately 3,600 feet (0.7 miles) of PIP segment with a four-inch diameter outer pipe and a 1.5-inch diameter inner pipe, used to recirculate LNG from the Crowley TLF to the EcoEléctrica LNG Terminal. The LNG transfer line and LNG recirculation line do not comply with 49 CFR §§ 193.2167 and 193.2173 because the outer pipe of the PIP technology covers the inner pipe completely, resulting in a covered impounding system. Special Permit Request: EcoEléctrica submitted an application to PHMSA on September 8, 2023, and provided supplemental information on May 31 and October 31, 2024, and January 2 and 27, 2025, for a special permit seeking relief from the Federal pipeline safety regulations in 49 CFR §§ 193.2167 and 193.2173 for the EcoEléctrica LNG Terminal. Public Notice: On September 3, 2025, PHMSA posted a notice of this special permit request in the Federal Register with a closing date of October 3, 2025. The EcoEléctrica special permit application letter, Federal Register notice, Final Environmental Assessment (FEA), Finding of No Significant Impact, and all other pertinent documents are available for review in Docket No. PHMSA-2023-0114 in the Federal Docket Management System at www.regulations.gov. Summary of Public Comments and PHMSA Response: PHMSA reviewed all public comments received for Docket Number PHMSA-2023-0114 through October 3, 2025. PHMSA received two public comments concerning this special permit request. The comments raised concerns regarding EcoEléctrica’s compliance with pipeline safety regulations, the adequacy of safety measures in the proposed special permit, and potential risks associated with the PIP system. Public Comment: A commenter expressed concerns with the PIP design and requested PHMSA impose enforcement, as well as appropriate conditions to ensure public safety. Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 2 of 6#

2023-0114 - EcoElectrica_-_SPAF, page 3PHMSA Response: EcoEléctrica selected the PIP design because a conventional piping system would require construction of impoundment sumps and trenches along the truck transfer piping to contain any LNG spill. A conventional trench and impoundment system was not feasible due to the complexity of the 3,600-foot-long route, the narrow two-foot-wide corridor in some areas, multiple orientation changes, grade elevation differences, and the proximity of the EcoEléctrica Natural Gas Power Plant and other equipment. Even though PIP design presents a covered impoundment and potential confined methane vapor cloud if LNG leaks from the inner pipe, it does not result in a flammable mixture because of the vacuum condition in the annular space. The monitoring system in the annular space would detect the vapor cloud quickly. Section 7.2.4 of the FEA discusses the leak monitoring system. In addition, the PHMSA inspection program will verify that EcoEléctrica maintenance personnel monitor the vacuum conditions and conduct leak monitoring activities in accordance with the maintenance procedures. Section 7.2.2 of the FEA describes the PIP design, including the inner and outer pipe materials, pipe spacers, and design and testing requirements. The annular space is monitored in accordance with the procedures and operations and maintenance (O&M) manuals submitted to PHMSA, which include systems to detect temperature, pressure, and leaks, and to isolate segments if needed. EcoEléctrica must provide PHMSA, upon request, all records of construction, maintenance, and inspections, and any remedial actions for the special permit segments. The PHMSA inspection program includes verifying records to ensure EcoEléctrica’s compliance with the special permit conditions. EcoEléctrica installed valves to isolate the special permit segments according to section 8.2.1 of National Fire Protection Association (NFPA) 59A-2001. PHMSA staff confirmed these isolation valves in the design drawings and during field verification as part of the PHMSA design review and construction inspection compliance program. During the design review and construction inspection in 2021, PHMSA also identified the non- compliance issue with the PIP design. EcoEléctrica initially did not consider the outer pipe of the PIP system as an impounding system and, therefore, believed the project to be in compliance with 49 CFR Part 193. Under 49 CFR § 190.341(a), an LNG operator may obtain a special permit to waive compliance with one or more Federal pipeline safety regulations. PHMSA exercised its discretion and did not pursue enforcement on the PIP design when EcoEléctrica submitted a special permit request as soon as PHMSA staff identified a non-compliance issue. The special permit includes specific conditions to ensure the integrity and safety of the PIP system, including following procedures and management of change, repairs, quality assurance and quality control practices, and documentation. These conditions, together with the reporting requirements under 49 CFR § 193.2011, ensure that PHMSA is notified promptly of any adverse conditions identified through facility monitoring systems. Public Comment: A commenter expressed concerns that covered impoundment systems would pose a risk of confined vapor explosions involving methane and air mixtures. The commenter also expressed concerns with the environmental and safety risks to the public. PHMSA Response: The explosive limit for methane is between 5 and 15 percent in the air. Section 7.2.1 in the FEA addresses the risk for vapor cloud explosion. Any LNG leaks from the inner pipe would be captured within the outer pipe and would not be released directly into the Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 3 of 6#

2023-0114 - EcoElectrica_-_SPAF, page 4atmosphere. For the PIP technology used at the EcoEléctrica LNG Terminal, the annular space between the inner and outer piping is under a vacuum condition. The vacuum condition in the annular space prevents the formation of a flammable mixture, which alleviates the risk of an explosion. EcoEléctrica ensures a vacuum condition (i.e., no oxygen entering the annular space) by continuously monitoring the pressure in the annular space. The LNG transfer line and LNG recirculation line include 302 vacuum connection ports for monitoring purposes. This special permit includes conditions to ensure integrity of PIP through operation and maintenance, management of change, and quality control. The PHMSA inspection program includes verifying records to ensure EcoEléctrica’s compliance with the special permit conditions. Based on PHMSA’s expertise, consideration of the public comments, and technical information provided by EcoEléctrica, PHMSA is granting the special permit with conditions to ensure an equivalent level of safety. Analysis: Due to the complexity of the piping route between the LNG storage tank and the truck loading area, EcoEléctrica used PIP technology for the LNG truck transfer and recirculation lines, with an inner pipe carrying LNG and an outer pipe serving as spill containment. The outer pipe completely covers the inner pipe, which is prohibited by the covered systems regulations in 49 CFR § 193.2167. Covered impoundment systems present the potential for vapor cloud explosion if ignited. However, the annular space between the inner pipe and outer pipe is under vacuum condition and will not allow a flammable mixture of methane and air in the event of LNG leakage from the inner pipe. Under normal operating conditions, the annular space between the inner and outer pipes will not collect water, so a separate water removal system is not necessary. EcoEléctrica designed and constructed the PIP segments in accordance with the applicable sections in the 2019 edition of NFPA’s “Standard for the Production, Storage, and Handling of Liquefied Natural Gas” (NFPA 59A-2019). PHMSA staff reviewed engineering design drawings, testing records, and thermal shock analysis to verify compliance with NFPA 59A-2019. PHMSA carefully designed a comprehensive set of conditions that EcoEléctrica must follow to maintain compliance with the special permit, including: 1) Procedures: EcoEléctrica must update its O&M manual(s) and procedure(s) in accordance with these special permit conditions and 49 CFR Part 193 for the special permit segments. EcoEléctrica must submit the O&M manual(s) and procedure(s) for the vacuum jacketed (VJ) piping systems to PHMSA upon request. 2) Management of change: Justification for any future change in the design, operating parameters, and operation and maintenance procedures for the special permit segments must be provided by EcoEléctrica to PHMSA. EcoEléctrica must receive a letter of “no objection” from PHMSA prior to implementing a proposed change. Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 4 of 6#

2023-0114 - EcoElectrica_-_SPAF, page 53) Reporting of repairs: EcoEléctrica must notify PHMSA of any repair conditions resulting in isolation of the special permit segments no later than two business days after a condition is discovered. 4) Quality assurance and quality control plan: No later than 180 days following issuance of the special permit for the PIP system, EcoEléctrica must submit a quality assurance and quality control plan for all remedial and repair activities for the special permit segments to PHMSA for review. The plan must include protocols for document control, equipment receiving inspection, material compatibility verification, conformance review, and training requirements. 5) Documentation: EcoEléctrica must maintain all documentation of compliance with the conditions of this special permit and provide such documentation to PHMSA upon request, including documentation showing that EcoEléctrica complied with 49 CFR §§ 193.2301, 193.2303, and 193.2304 in subpart D, as well as additional requirements for VJ piping in section 10.13 of NFPA 59A (2019 edition). Based upon the review of the submitted information and discussions with EcoEléctrica, PHMSA grants the special permit with the requirement that EcoEléctrica meets the special permit conditions to ensure safety of the EcoEléctrica Terminal. PHMSA is imposing the special permit conditions to ensure that granting this special permit is not inconsistent with safety for LNG facilities used in the transportation of gas by pipeline. Findings: Based on the information submitted by EcoEléctrica and PHMSA’s analysis of the technical and safety issues, and, given the special permit conditions that will be implemented, PHMSA finds that granting this special permit to EcoEléctrica to waive 49 CFR §§ 193.2167 and 193.2173 is not inconsistent with LNG facility safety. Completed in Washington, D.C., on: April 3, 2026 Prepared by: PHMSA – Engineering and Research Division Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 5 of 6#

2023-0114 - EcoElectrica_-_SPAF, page 6Appendix A – EcoEléctrica LNG Terminal Location Map Docket Number: PHMSA-2023-0114 – EcoEléctrica LNG Terminal, L.P. Special Permit Analysis and Findings Page 6 of 6#

2023-0114 - EcoElectrica_-_Final Conditions, page 1Official PDFU.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT LNG Vacuum Jacketed (VJ) Piping System EcoEléctrica LNG Terminal Peñuelas, Puerto Rico Special Permit Information: Docket Number: PHMSA-2023-0114 Requested by: EcoEléctrica, L.P. Operator ID#: 32561 Original Date Requested: September 8, 2023 Issuance Date: April 3, 2026 Code Sections: 49 CFR §§ 193.2167 and 193.2173 Grant of Special Permit Conditions By this order, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS) grants this special permit to EcoEléctrica, L.P. (EcoEléctrica), the owner and operator of a liquefied natural gas (LNG) terminal in Peñuelas, Puerto Rico (EcoEléctrica LNG Terminal or Terminal). The order waives EcoEléctrica’s obligation to comply with the requirements in 49 CFR § 193.2167, which apply to covered impoundment systems, and 49 CFR § 193.2173, which apply to the removal of water from impoundment areas, subject to the terms and conditions set forth below. The waiver allows EcoEléctrica to use vacuum jacketed (VJ), pipe-in-pipe (PIP) technology for the special permit segments consisting of approximately 3,600 feet of LNG truck transfer piping and 3,600 feet of LNG recirculation piping. I. Purpose and Need EcoEléctrica sought this special permit to waive requirements of 49 CFR §§ 193.2167 and 193.2173 for the LNG Supply Pipeline Project at the EcoEléctrica LNG Terminal. The regulations prohibit the use of covered impoundment systems and require impoundment areas be constructed to drain completely to prevent water collection. PHMSA-2023-0114: EcoEléctrica, L.P. EcoEléctrica LNG Import Terminal – Special Permit for Pipe-in-Pipe Page 1 of 4#

2023-0114 - EcoElectrica_-_Final Conditions, page 2EcoEléctrica uses the outer pipe of the PIP technology for spill containment, which results in a covered impoundment system. The facility’s layout, complex piping route, and limited space make compliance with the regulatory requirements of 49 CFR § 193.2167 not feasible. Furthermore, EcoEléctrica has demonstrated that alternative measures used at the facility achieve the same level of safety. On the condition that EcoEléctrica complies with the terms and conditions set forth below, the special permit waives compliance with 49 CFR §§ 193.2167 and 193.2173 for the LNG Supply Pipeline Project. The request submitted by EcoEléctrica and supporting documents can be found at Docket No. PHMSA-2023-0114 in the Federal Docket Management System located at www.regulations.gov. II. Conditions PHMSA grants this special permit subject to EcoEléctrica subject to the following conditions. The special permit segments must comply with these conditions and the requirements in 49 CFR Part 193, except for 49 CFR §§ 193.2167 and 193.2173. In the event of a conflict between these conditions and the requirements in 49 CFR Part 193, the special permit conditions prevail. All notifications and submittals required by the conditions below shall be submitted as detailed in Appendix A. 1) Procedures: EcoEléctrica must update its operation and maintenance (O&M) manual(s) and procedure(s) in accordance with these special permit conditions and 49 CFR Part 193 for the special permit segments. EcoEléctrica must submit the O&M manual(s) and procedure(s) for the VJ piping systems to PHMSA upon request. 2) Management of Change: EcoEléctrica must provide justification for any future change in the design, operating parameters, and operation and maintenance procedures for the special permit segments to PHMSA. EcoEléctrica must receive a letter of “no objection” from PHMSA prior to implementing a proposed change. 3) Reporting of Repairs: EcoEléctrica must notify PHMSA of any repair conditions resulting in isolation of the special permit segments no later than two business days after a condition is discovered. 4) Quality Assurance and Quality Control Plan: No later than 180 days following issuance of the special permit for the PIP system, EcoEléctrica must submit a quality assurance and quality control plan for all remedial and repair activities for the special permit segments to PHMSA for review. The plan must include protocols for document control, equipment receiving inspection, material compatibility verification, conformance review, and training requirements. 5) Documentation: EcoEléctrica must maintain all documentation of compliance with the conditions of this special permit and provide such documentation to PHMSA upon request, including documentation showing that EcoEléctrica complied with 49 CFR PHMSA-2023-0114: EcoEléctrica, L.P. EcoEléctrica LNG Import Terminal – Special Permit for Pipe-in-Pipe Page 2 of 4#

2023-0114 - EcoElectrica_-_Final Conditions, page 3§§ 193.2301, 193.2303, and 193.2304 in subpart D, as well as additional requirements for VJ piping in section 10.13 of NFPA 59A (2019 edition). III. Limitations This special permit is subject to the limitations set forth in 49 CFR § 190.341 as well as the following limitations: 1) PHMSA has the sole authority to make all determinations on whether EcoEléctrica has complied with the specified conditions of this special permit for the PIP system at the EcoEléctrica LNG Terminal. 2) Any work plans and associated schedules for the PIP system associated with this special permit are incorporated automatically into this special permit and are enforceable in the same manner. 3) As provided in 49 CFR § 190.341, PHMSA may issue an enforcement action for failure to comply with this special permit for the PIP system at the EcoEléctrica LNG Terminal. The terms and conditions of any corrective action order, compliance order, or other order applicable to a pipeline facility covered by this special permit will take precedence over the terms of this special permit. 4) If EcoEléctrica sells, merges, transfers, or otherwise disposes of all or part of the assets known as the EcoEléctrica LNG Terminal, EcoEléctrica must provide PHMSA with written notice of the change within 30 days of the consummation date as detailed in Appendix A. 5) For purposes of 49 CFR § 190.341(j)(ii), a “material change in conditions or circumstances” shall include only conditions or circumstances arising after the issuance of this special permit that directly implicate the national security interests of the United States or that are the direct result of an emergency as declared by the President of the United States 6) This special permit is effective for the operational life of the facility, subject to the conditions and limitations set forth herein and in 49 CFR § 190.341. AUTHORITY: 49 United States Code 60118 and 49 CFR § 1.97. Issued in Washington, D.C., on April 3, 2026. Linda Daugherty Acting Associate Administrator for Pipeline Safety PHMSA-2023-0114: EcoEléctrica, L.P. EcoEléctrica LNG Import Terminal – Special Permit for Pipe-in-Pipe Page 3 of 4#

2023-0114 - EcoElectrica_-_Final Conditions, page 4Appendix A – Notifications and Submittals Notifications and submittals to PHMSA must include the special permit docket number and follow the requirements described below. Condition/ Limitation # Type Include in Notification Recipient Submittal Timing PHMSA Approval Condition 1 Procedures • O&M manual(s) and procedure(s) for the VJ piping systems Region Director Upon request No Condition 2 Management of Change • Justification for any future change in the design, operating parameters, and operation and maintenance procedures associated with the special permit segments Region Director Prior to implementing a change Yes (letter of “no objection” required) Condition 3 Repair Notification • Notification of any repair conditions resulting in isolation of the special permit segments Region Director Within two business days after the condition is discovered No Condition 4 QA/QC Plan • A quality assurance and quality control plan for all remedial and repair activities associated with the special permit segments Region Director No later than 180 days following issuance of the special permit No Condition 5 Documentation • Documentation of compliance with 49 CFR Part 193 Subpart D, NFPA 59A (2019) Section 10.13, and all special permit conditions Region Director Upon request No Limitation 4 Asset Transfer • Written notice of sale, merger, transfer, or disposal of assets known as the EcoEléctrica LNG Terminal Associate Administrator – Copies to Region Director and Engineering Director Within 30 days of the consummation date Revoke, suspend, or modify the special permit Recipient contact details: Region Director – Southwest Region – Bryan Lethcoe, Bryan.Lethcoe@dot.gov Engineering Director – Max Kieba, pipelinespecialpermits@dot.gov Acting Associate Administrator – Linda Daugherty, Linda.Daugherty@dot.gov PHMSA-2023-0114: EcoEléctrica, L.P. EcoEléctrica LNG Import Terminal – Special Permit for Pipe-in-Pipe Page 4 of 4#