...PB Energy Storage Services, Inc.

Transcription

1 Sulphur Drive Beaumont, Texas Website: COMMITMENT (PBESS) pipeline is committed to the protection of the public and the environment through the safe operation and maintenance of its pipeline systems. PB s qualified personnel are trained in emergency response activities and regularly participate in drills and exercises reflecting various types of response levels, emergency scenarios, topographic terrain and environmental sensitivities. PBESS has committed the necessary resources to fully prepare and implement its emergency response plans and has obtained through contract the necessary private personnel and equipment to respond, to the maximum extent practicable, to a worst case discharge or substantial threat of such a discharge. COMMUNICATIONS PBESS utilizes its 24-hour Pipeline Control Center in ( ) as a hub of communications in emergency response situations. The Control Center has a vast catalog of resources and capabilities. On-site communications are conducted using cellular telephones, portable Motorola Radios and/or landline telephone systems from Company facilities and offices. INCIDENT COMMAND SYSTEM PBESS utilizes an expandable Incident Command System. Depending upon the sizes and complexity of an incident, additional Company or contract personnel may be added as needed. Additional federal, state, or local agencies may be integrated into the Incident Command System by utilizing a Unified Command Structure. How to get additional information For more information about PBESS John Hall Pipeline Superintendent, at (409) , or Rodney A Begnaud at (409) or Chuck Fontenot, Operations Manager, at (409) EMERGENCY CONTACT: Products/dot guidebook ID#/Guide#: Natural Gas TEXAS Counties of Operation: Jefferson Orange Louisiana Parishes of Operation: Beauregard Iblerville Calcasieu Changes may occur. Contact the operator to discuss their pipeline systems and areas of operation. Texas

2 Page 29 of 377 PB Energy Storage Services, Page 28 of 377 PB Energy Procedural Storage Manual for Operations, Maintenance and Emergencies Inc... for Gas Pipelines figure 2-4: Entergy Varibus green line Section: 2 Overview figure 2-3: Entergy Varibus red line Procedural Manual for Operations, Maintenance and Emergencies for Gas Pipelines Section: 2 Overview Page 26 of 377 Procedural Manual for Operations, Maintenance and Emergencies for Gas Pipelines PB Energy Storage Services Jurisdictional Equipment figure 2-1: Texas Mainline #1 3/6/2006 Section: 2 Overview figure 2-5: Entergy Varibus willow glen line 3/6/2006 Page 30 of 377 Procedural Manual for Operations, Maintenance and Emergencies for Gas Pipelines Section: 2 Overview 3/6/2006 Page 27 of 377 Procedural Manual for Operations, Maintenance and Emergencies for Gas Pipelines figure 2-2: Texas Mainline #2 3/6/2006 Section: 2 Overview 3/6/ Texas 2016

3 PB ESS Pipeline Emergency Public Awareness February, 2015

4 Effective Date: January 2011 Supersedes: Page 2 of 66 Table of Contents CONTENTS REVISIONS...5 GENERAL INFORMATION...6 PURPOSE... 6 MANUAL DISTRIBUTION... 6 APPLIES TO... 6 TRAINING AND QUALIFICATION... 7 PB ESS FACILITIES...9 THE PB ESS SPINDLETOP GAS STORAGE FACILITY... 9 FACILITY INFORMATION FORM THE PB ESS PIPELINE SYSTEM PERSONNEL WORK SCHEDULING RECEIVING NOTIFICATION OF AN EMERGENCY EMERGENCY NOTIFICATION FLOW CHART FOR PB ESS OPERATED PIPELINES & CAVERNS IDENTIFICATION AND CLASSIFICATION OF EMERGENCIES Classifications of Emergencies COMMUNICATIONS WITH PUBLIC OFFICIALS LIAISON WITH EMERGENCY RESPONDERS AND PUBLIC OFFICIALS NOTIFYING PUBLIC OFFICIALS AND RESPONDERS OF AN EMERGENCY MAINTAINING COMMUNICATION WITH PUBLIC OFFICIALS FIELD EMERGENCY RESPONSE PROCEDURES CONTROL OF THE AFFECTED PUBLIC GENERAL GUIDELINES ERP NO. 2: HOT ZONE ASSESSMENT ERP NO. 3: HAZARD MINIMIZATION ERP NO. 4: DE-COMMISSION AND RE-COMMISSIONING A PIPELINE SYSTEM FIRE OR EXPLOSION GAS DETECTED INSIDE OR NEAR A BUILDING ACCIDENTAL RELEASE OF PRODUCT OPERATIONAL FAILURE NATURAL DISASTER Hurricane Tornado Duties of Pipeline and Site Supervisors During Natural Disasters PERSONNEL AND EQUIPMENT PP ESS EMERGENCY EQUIPMENT AND RESOURCES CONTRACTOR EMERGENCY EQUIPMENT AND RESOURCES Park Ten Place, Houston,Tx, 77084

5 Effective Date: January 2011 Supersedes: Page 3 of 66 CONTROL ROOM OPERATOR PROCEDURES DAY-TO-DAY VERIFICATION ERP NO. 8: ROW ENVIRONMENT MONITORING Severe Storms, Tornadoes Flooding Grass Fires/Forest Fires Earthquake CONTROL ROOM OPERATOR PROCEDURES EMERGENCY PROCEDURES ERP NO. 9: RECEIVING NOTIFICATION OF AN EMERGENCY ERP NO. 10: USING THE PIPELINE EMERGENCY RESPONSE TEXT MESSAGE NOTIFICATION SYSTEM SPINDELTOP STORAGE FACILITY EMERGENCY RESPONSE ACTIONS INTRODUCTION TYPES OF EMERGENCIES TYPES OF EMERGENCY RESPONSE DEVICES OBJECTIVES AND RESPONSIBILITIES COMMON TO ALL EMERGENCIES EMERGENCY RESPONSE PROCEDURES Overpressure of Equipment Office Building Fire Fire or Explosion (beyond the capacity of a 30# fire extinguisher) Compressor Building Gas Leak Detection or Fire Alarm Compressor Building Gas and Fire Detection Systems Gas Leak Detection Emergency Response Fire Detection Emergency Response Process Piping Failure or Gas Leak (no fire) Mechanical Failure (Excluding Piping) Power, I&C Failure Personnel Injury or Sickness (other than first aid) Spills and Pollution Threat (hazardous material) TEXAS MAINLINE NO.1 (9 MILE), MAINLINE NO. 2 (14 MILE) EMERGENCY SHUTDOWN PROCEDURES ADMINISTRATIVE SUPPORT PROCEDURES MEDIA GUIDELINES NOTIFICATIONS AND REPORTING INVESTIGATION OF FAILURES EMERGENCY PROCEDURE / TRAINING EVALUATION AND EFFECTIVENESS FORMS ERP-F1: EMERGENCY RESPONSE EQUIPMENT, TOOLS AND MATERIALS CHECKLIST ERP-F2: RECEIVING NOTIFICATION OF AN EMERGENCY ERP-F3: EMERGENCY RESPONSE RECORD OF EVENTS MAPS TEXAS MAINLINE # TEXAS MAINLINE # RED LINE GREEN LINE WILLOW GLEN Park Ten Place, Houston,Tx, 77084

6 Effective Date: January 2011 Supersedes: Page 4 of 66 NATURAL GAS MSDS REGULATORY CROSS REFERENCE TELEPHONE NUMBERS PB ESS TELEPHONE NUMBERS CONTROL ROOM OPERATORS PIPELINE PERSONNEL CORPORATE PERSONNEL CHART CHANGERS... ERROR! BOOKMARK NOT DEFINED. LAW ENFORCEMENT TEXAS LAW ENFORCEMENT LOUISIANA FIRE SERVICE TEXAS FIRE SERVICE LOUISIANA EMERGENCY MEDICAL SERVICES (EMS) TEXAS EMERGENCY MEDICAL SERVICES (EMS) LOUISIANA MEDICAL SERVICES TEXAS MEDICAL SERVICES LOUISIANA EMERGENCY MANAGEMENT TEXAS EMERGENCY MANAGEMENT LOUISIANA REGULATORY AGENCIES Park Ten Place, Houston,Tx, 77084

7 Effective Date: January 2011 Supersedes: Page 5 of 66 REVISIONS Revision Number Revision Date Revision Summary Review and Approval Public Officials required by PHMSA Rodney A. Begnaud Notification numbers Rodney A. Begnaud Review and update phone list Rodney A. Begnaud review Rodney A. Begnaud Review and update phone list Rodney A. Begnaud Pg18 communication with responders and phone numbers Rodney A. Begnaud

8 Effective Date: January 2011 Supersedes: Page 6 of 66 Purpose GENERAL INFORMATION The purpose of these Pipeline Emergency Response Procedures is to provide information to protect people, property and the environment in the case of an emergency involving one of PB ESS s regulated gas pipelines. Protecting people is the first priority in an emergency. These procedures are to be used in an emergency to protect PB ESS personnel, local emergency responders, other operating company and contractor personnel and the general public. All PB ESS facilities are operated and maintained in compliance with applicable federal and state pipeline safety regulations. Compliance with these regulations is under the jurisdiction of the federal Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety (DOT/PHMSA/OPS); the Texas Railroad Commission (TRRC), and the Louisiana Department of Natural Resources (LA DNR), Office of Conservation. These emergency response procedures have been developed to provide for a timely response to possible emergency situations involving PB ESS gas pipelines. These procedures are built on a sharing of personnel resources between the gas pipelines and storage facility. All PB ESS personnel who will respond to emergency situations involving PB ESS gas pipelines will be trained in these procedures. All responding personnel will be trained in the Unified Incident Command System (UICS), HAZMAT response procedures and will be qualified under the PB ESS Operator Qualification program to perform tasks that they would reasonably be expected to perform in responding to an emergency situation. Manual Distribution This manual is made available to all individuals that will have responsibility in handling an emergency. Supervisors that are responsible for emergency action will have a copy of the portions of this manual that pertain to the items for which they are responsible. Applies To These procedures are to be used anytime there is an emergency on any of the regulated gas pipelines or at the Spindletop Storage Facility. The regulated pipelines include: Texas No.1 ( 9 Mile) Texas No.2 (14 Mile) Red Line Green Line Willow Glen

9 Effective Date: January 2011 Supersedes: Page 7 of 66 Training and Qualification All employees participating in emergency response will be trained to complete the parts of this procedure that are applicable to them and in any other procedures needed to fulfill their duties in responding to the emergency. In addition to procedure training, individuals will also receive the following training: 1. Off System Employees a. Uniform Incident Command System (UICS) b. Level 3 HAZMAT Technician c. Covered Task 007; Operate Valves d. Covered Task 716; Inspect, Maintain, and Operate Valves 2. System Employees a. Uniform Incident Command System (UICS) b. Level 3 HAZMAT Technician c. PB ESS OQ Covered Tasks i. Covered Task 007; Operate Valves ii. Covered Task 401; Examination of Buried Pipelines When Exposed iii. Covered Task 404; Protection of Coating When Backfilling and From Below Ground Supports iv. Covered Task 405; Protection of Coatings From Above Ground Structures v. Covered Task 414; Inspect for Internal Corrosion Whenever Pipe is Removed vi. Covered Task 418; General and Localized Corrosion Measurement (Remedial Measures) vii. Covered Task 601; Start-up/Shut-down of Pipeline to Assure Operation Within MOP viii. Covered Task 605; Locate Line/Install Temporary Marking of Buried Pipeline ix. Covered Task 607; Damage Prevention: Observation of Excavating and Backfilling x. Covered Task 607; Hot Tap (Steel Pipe) xi. Covered Task 614; Purge Pipeline Facilities With Air or Inert Gas xii. Covered Task 701; Patrolling Pipeline and Leakage Survey without Instrument xiii. Covered Task 702; Leakage Survey with Leak Detection Device xiv. Covered Task 716; Inspect, Maintain, and Operate Valves d. Responsibilities in an Emergency e. Location and use of Emergency equipment f. Properties of Products g. Location of Maps, Records, Valve Sites, etc.

10 Effective Date: January 2011 Supersedes: Page 8 of 66 h. In an Emergency Step-by-Step Procedures i. Recordkeeping Requirements (Forms F2 and F3) j. Telephone Reports k. Control Room Contact Number l. Notification Procedures for Contacting Qualified Individual on a 24 Hour Basis.

11 Effective Date: January 2011 Supersedes: Page 9 of 66 PB ESS FACILITIES The PB ESS Spindletop Gas Storage Facility (PB ESS) operates a Natural Gas Storage facility at Spindletop. The total capacity is 11.1 Bcf. Capacity of Well #1 is 6.4 Bcf. Cavern #2 Capacity is 4.7 Bcf. The facility is capable of delivering out at a rate of 480 MM scf / day. Injection capability to the facility is 280 MM scf / day. The Spindletop Storage Facility receives and delivers natural gas by pipeline from Entergy s Gas Pipeline System & other customers. Natural gas is delivered to wells from pipeline. Compression is required for injection to the caverns. Pressure reduction is required for delivery to the pipeline system. The physical address of the Spindletop site is 6950 Sulphur Drive Beaumont, TX The logistical location is: Latitude: N30 Degrees 01 Minutes 43.6 Seconds Longitude: W94 Degrees 04 Minutes 20.2 Seconds The site and the facilities associated with it are utilized for the underground storage of natural gas. The Spindletop site consists of the following: Office/Control Room Building Maintenance Building Motor Control Center Process Area Two Underground Storage Caverns o o Well #1 Natural Gas Storage Well #2 Natural Gas Storage Facility Inlet Metering Area Compression Facilities o Unit 100 o Unit 200 o Unit 300 o Unit 400

12 Effective Date: January 2011 Supersedes: Page 10 of 66 Facility Pressure Reduction Station Facility Discharge Metering A general area map illustrating the location of the site may be found in at the in the map section of this manual. There is no facility general alarm. Employees are contacted via radio or telephone in the event of an emergency event. The IC will provide a radio to local fire or police, so that the IC can communicate directly with outside emergency assistance groups during an emergency Facility Information Form Facility Information Facility Name: Spindletop Storage Facility Location (St. Address) 6950 Sulphur Drive City, State, Zip Code Beaumont, Tx County: Jefferson Phone Numbers: Latitude N30 Degrees 01 Minutes 43.6 Seconds Longitude W94 Degrees 04 Minutes 20.2 Seconds Owner: Operator Entergy Fossil Fuels Operator Address: Katy Freeway, Suite 600 City, State, Zip Code Houston, Tx Emergency Response Coordinators: Date of Gas Storage Start-up: Current Operations Substantial Expansions Name / Title Address Phone No. Chuck Fontenot Manager of Operations John Hall Site Supervisor Rodney A. Begnaud Asisst Opr Mgr Sulphur Drive Beaumont, Tx Sulphur Drive Beaumont, Tx Sulphur Drive Beaumont, Tx

13 Effective Date: January 2011 Supersedes: Page 11 of 66 The PB ESS Pipeline System (PB ESS) operates five gas pipelines. PB ESS pipelines are intrastate in the states of Texas and Louisiana. The PB ESS corporate headquarters are in Houston, TX. The gas pipelines are controlled from the Spindletop Control Center in Beaumont, TX. Six of the PB ESS pipelines are located between Beaumont, TX and Westlake, LA. A single gas pipeline crosses the Mississippi River between West Baton Rouge Parish, LA and East Baton Rouge Parish, LA. PB ESS also operates a non-hazardous liquid pipeline (brine) between Belle Rose, LA and Taft, LA. All PB ESS gas pipelines are operated and maintained to be in compliance with applicable federal and state pipeline safety regulations. Compliance with these regulations is under the jurisdiction of the federal Department of Transportation, Pipeline and Hazardous Material Safety Administration, Office of Pipeline Safety (DOT/PHMSA/OPS); the Texas Railroad Commission (TRRC) and the Louisiana Department of Natural Resources, Office of Conservation. These emergency response procedures have been developed to provide for a timely response to possible emergency situations involving PB ESS gas pipelines. These procedures are built on a sharing of personnel resources between the gas, and brine pipelines operating units. All PB ESS personnel who will respond to emergency situations involving PB ESS gas pipelines will be trained in these procedures. All responding personnel will be trained in the Unified Incident Command System (UICS), HAZMAT response procedures and will be qualified under the PB ESS Operator Qualification program to perform tasks that they would reasonably be expected to perform in responding to an emergency situation. Personnel Work Scheduling PB ESS gas pipelines operate 24 hrs/day. The Spindletop gas pipeline control center in Beaumont, TX is manned 24 hrs/day. Maintenance activities are usually carried out during normal, weekday working hours. A list of all PB ESS pipeline personnel can be found in the Telephone Numbers section of this manual. A map showing the general and relative location of the PB ESS pipeline facilities can be found in the Maps section of this manual. The map shows the likely proximate location of PB ESS pipeline supervisors and pipeline personnel during non-working hours. Because of the nature of the layout of the pipeline and the control centers; the distances between facilities; and the location of pipeline personnel, it is important that normal maintenance activities be planned so that areas of the pipeline are not left unattended should a possible emergency situation develop. Example: When planning a maintenance activity on the Willow Glen gas pipeline that would require several pipeline operators and a pipeline supervisor. Advise the pipeline supervisor so that only maintenance activities that allow for the Louisiana end of the system to be attended during a possible emergency situation can be scheduled.

14 Effective Date: January 2011 Supersedes: Page 12 of 66 The same logic must be applied when pipeline supervisors and pipeline personnel are on days off, vacation, or other situations where they may possibly be unavailable to respond to an emergency. Pipeline supervisors are responsible for developing policies and procedures within their own operating unit for personnel to take scheduled and non-scheduled time off without jeopardizing the Company s ability to respond to a possible emergency situation on the pipeline. Pipeline Supervisors must be in regular communication with each other so that the availability of pipeline personnel is known at all times; especially during times outside of the normal work day. Because of the nature of the industries to which PB ESS delivers materials to through the pipelines it operates, PB ESS is obligated to continue the operation of pipelines during periods of severe weather and natural disaster. During periods of severe weather or natural disaster, PB ESS pipeline operating personnel must make every effort possible to secure the safety of their families and property in order to be available to assist in operating the pipeline. Pipeline Supervisors will work to adjust duty schedules during weather emergencies and natural disasters to allow pipeline personnel opportunity to secure their own personal situations. PB ESS will assist pipeline personnel who experience personal loss during such periods to whatever extent is practicable. Pipeline operating personnel from systems not affected by the severe weather or natural disaster may be asked to relieve personnel from the affected systems and may be temporarily assigned to other systems.

15 Effective Date: January 2011 Supersedes: Page 13 of 66 RECEIVING NOTIFICATION OF AN EMERGENCY Sources of notification of an emergency could be: A telephone call to the pipeline control center from a member of the affected public (someone along the ROW) to the 24 hour emergency number shown on the pipeline ROW markers. (see ERP No. 9: Receiving Notification of an Emergency) ROW Marker Emergency Telephone Number Spindletop Control Center Location Pipelines 6950 Sulphur Drive Beaumont, TX Natural Gas This telephone must be answered 24 hours per day/365 days per year. Individuals answering these phones must be trained in how to receive a call reporting a possible emergency situation or must know how to redirect the call to someone who is trained in how to receive the call. This telephone must be checked regularly to verify that the numbers are working. (see ERP No. 5: Verifying the Operation of the ROW Marker Emergency Telephone Number) Indication or alarm from the SCADA system. The SCADA system can be used to identify unusual differential in pipeline pressure between the remote transmitter locations along the pipeline. Keep in mind that not all emergencies will result in a pressure differential on the pipeline that can be determined from the SCADA system. Observation by pipeline personnel of an emergency condition. Information from ROW condition monitoring. ALL POSSIBLE EMERGENCY SITUATIONS MUST BE REPORTED TO THE PIPELINE CONTROL ROOM OPERATOR.

16 Effective Date: January 2011 Supersedes: Page 14 of 66 Emergency Notification Flow Chart For PB ESS Operated Pipelines & Caverns Outside Call or Operator detects a Leak (If required) Notifies PB ESS Emergency Notification system (ALL) 911 Notifies Facility Operation Supervisor Gas & Storage John Hall Notifies Pipeline Client and Customers (If required) Notifies Texas Railroad Commission Notifies Operation Manager Chuck Fontenot Assist. Operation Manager Rodney Begnaud Notifies Pipeline Operations and Maintenance Contractor National Response Center Louisiana Office of Conservation LA State Police Notifies Environmental / Hygiene Monitoring Contractor Notifies President of PBESS (If required) Notifies Environmental Health & Safety David Perkins (If required) Notifies Southeast Texas Alerting Networks (877-THE-STAN) Notifies Texas Commission on Environmental Quality (TCEQ)

17 Effective Date: January 2011 Supersedes: Page 15 of 66 Identification and Classification of Emergencies Classifications of Emergencies 1. Abnormal Operation; 2. Emergencies requiring GENERAL RESPONSE; 3. Emergencies requiring IMMEDIATE RESPONSE Abnormal Operation An abnormal operation is a situation in which continued operation of the pipeline without investigation or implementing some type of intervening or mitigating action may cause injury to people or cause the pipeline to operate outside of design conditions that could lead to the unintended release of material from the pipeline or result in damage to the pipeline. Examples of abnormal operations are: Unintended closure of valves or shutdowns; Increase or decrease in pressure or flow rate outside normal operating limits; Loss of communications (SCADA, telephone, radio, , text message system, etc); Operation of any safety device; Operation during or after a natural disaster; Any other malfunction of a component, deviation from normal operation, or personnel error which could cause a hazard to persons or property. Abnormal operation is a low level emergency that could escalate to a higher level. ALL ABNORMAL OPERATION MUST BE: Responded to or acknowledged; Investigated; Corrected. It is most likely that the pipeline will continue operating when and abnormal operation is encountered. DO NOT DISREGARD ABNORMAL OPERATION. IF THE ABNORMAL OPERATION CANNOT BE CORRECTED CONTACT THE PIPELINE SUPERVISOR. Abnormal operation should be recorded in the daily operating log. When abnormal operation concludes, it is the responsibility of the Pipeline Supervisor to: Determine continued integrity and safe operation of the pipeline.

18 Effective Date: January 2011 Supersedes: Page 16 of 66 Alert appropriate pipeline and control room operators to the potential for future abnormal operation and to provide guidance about how to respond, investigate and correct the abnormal operation. Determine if a written procedure must be developed for responding to a specific abnormal operation. In particular, operation during or after natural disasters. Check with the appropriate administrative personnel to determine if a Safety Related Condition report must be filed. Emergencies Requiring GENERAL RESPONSE Active or evidence of third party excavation within the ROW of a PB ESS pipeline when notice of the excavation was not received from the local One-Call Center. One-Call Center emergency locate request. Unintended power equipment contact with a PB ESS pipeline. The operation of a pressure relief device, pipeline alarm or automatic pipeline shutdown with no indication of a release of product. Any situation or condition having the potential of damaging the integrity of a PB ESS pipeline. Any situation in which the control room operator determines that an emergency general response is necessary in order to insure continued safe operation of the pipeline. An emergency situation requiring GENERAL RESPONSE will result in specific individuals being notified via the PB ESS Pipeline Emergency Response Text Message Notification System to respond to appropriate locations as quickly as possible. (See ERP No. 10: Using the Pipeline Emergency Response Text Message Notification System). Emergencies Requiring IMMEDIATE RESPONSE Emergencies that require immediate response are the ones that may pose an immediate threat to human life or health including but not limited to: A telephone call, message or any other form of notification received by PB ESS, reporting a confirmed or suspected pipeline leak or any other emergency involving a PB ESS pipeline. An unexplained and uncontrollable change in pipeline pressure. Indication by operation monitoring equipment or direct observation of a possible release of product. The unintended release of product from a PB ESS pipeline. The unintended release of product from a non-pb ESS pipeline in the buffer* zone of a PB ESS pipeline.

19 Effective Date: January 2011 Supersedes: Page 17 of 66 Fire or explosion in the buffer zone of a PB ESS pipeline. * The buffer zone is 220 yards (660 feet) on both sides of the centerline of a PB ESS pipeline. An emergency situation requiring IMMEDIATE RESPONSE will cause the simultaneous notification of ALL PB ESS pipeline personnel using the PB ESS Pipeline Emergency Response Text Message Notification System. (see ERP No. 10: Using the Pipeline Emergency Response Text Message Notification System) This will result in all available personnel immediately reporting to their assigned emergency response function.

20 Effective Date: January 2011 Supersedes: Page 18 of 66 COMMUNICATIONS WITH PUBLIC OFFICIALS Liaison with Emergency Responders and Public Officials PB ESS has prepared and follows its Public Awareness Program (the PA Program). Supplemental activities described in the PA Program will involve a detailed analysis and identification of the specific emergency response organizations and public officials along each PB ESS pipeline ROW. The goal of that supplemental activity will be to indentify individuals within those organizations to serve as points of contact during a possible emergency on a PB ESS pipeline ROW. As those individuals are identified, their contact information will be added to this emergency response procedures manual. PB ESS will communicate with emergency responders and public officials to: Learn the responsibility and resources of each governmental agency that might respond to an emergency on a PB ESS pipeline. Acquaint the officials with PB ESS s ability to handle an emergency and the response resources available. Identify the types of emergencies that should be expected and plan how emergency responders, public officials and PB ESS will engage in mutual assistance to minimize hazards to life and property. Notifying Public Officials and Responders of an Emergency Prior to requiring emergency response, PB ESS will notify fire, police and other public officials in the vicinity of their pipelines. The following information will be discussed: Location of pipelines and commodity transported in the pipelines. The response capabilities of PB ESS. Planned responses from local fire, police and public officials. Contractors PB ESS has available to help in an emergency and their roles. Methods of communication prior to and during an emergency. In the case of an emergency, PB ESS will use the telephone numbers at the end of this manual to notify public offices and emergency responders of the type of emergency and the response that will be needed. Maintaining Communication with Public Officials During an emergency, PB ESS Pipeline will use the telephone numbers at the end of this manual to establish and maintain communication with public officials using land lines and cell phones. A PB Person will stay next to the emergency responders to maintain communication.

21 Effective Date: January 2011 Supersedes: Page 19 of 66 FIELD EMERGENCY RESPONSE PROCEDURES Control of the Affected Public Do not allow anyone other than emergency responders and operator response personnel near the area of the emergency. Follow the instructions of the Incident Commander in controlling the affected public in the area of the emergency. EVACUATE THE AFFECTED PUBLIC FROM THE AREA ONLY UNDER THE DIRECTION OF THE EMERGENCY RESPONSE INCIDENT COMMANDER. General Guidelines Approach the area of the emergency from the upwind side. Assess the situation. If a true emergency exists, call 911 (if not already done). Assess the hot zone. Notify anyone potentially in the hot zone to evacuate immediately. DO NOT ENTER THE HOT ZONE. Do not allow anyone to enter the hot zone. Block traffic at all possible access points. Traffic needing to be blocked might include railroad, ship and aircraft. Eliminate all potential ignition sources. Liquid materials or gases and vapors that are heavier than air may migrate into and be carried away to areas away from the emergency location by streams and bodies of water. In urban or populated areas, leaking materials may enter into sewer systems, vaults or other underground conduits and migrate to areas away from the emergency location. Do not enter any building in the hot zone. Leave the evacuation of buildings in the hot zone to trained emergency responders. ERP No. 2: Hot Zone Assessment It is possible that a cloud of highly flammable gas or vapor will surround a sizable area around the site of a pipeline leak. When responding to the area of a pipeline leak be aware of the possible presence of the cloud. Always try to approach the area of a leak from the upwind side. When arriving at the site of a confirmed or suspected pipeline leak, use the gas detector/hazardous atmosphere indicator to determine if a gas or vapor cloud exists. MAKE SURE THE INSTRUMENT IS KEPT IN CALIBRATION ACCORDING TO THE MANUFACTURER S SPECIFICATIONS. If you are not sure about the status of the instrument s

22 Effective Date: January 2011 Supersedes: Page 20 of 66 calibration DO NOT ATTEMPT TO APPROACH THE SITE. Immediately withdraw from the area on any indication from the instrument of a hazardous atmosphere. It is possible that the pipeline involved is not a PB ESS operated pipeline and the material leaking and forming the vapor cloud is very different from the products PB ESS handles in dayto-day operations. Keep in mind, the gas detector/hazardous atmosphere indicator may not function as needed in the presence of gases and liquids other than those it may be specifically designed or programmed for. If you are not sure of the nature of the material or product leaking from a pipeline, IMMEDIATELY WITHDRAW FROM THE AREA. If there is a pool of liquid or there is evidence of a leak of a liquid material, assume the liquid to be hazardous and/or extremely flammable. Consider the hot zone to extend well beyond the edges of a pool of liquid or area of a liquid leak. IF THERE IS A POSSIBILITY THAT A GAS OR VAPOR CLOUD EXISTS: DO NOT USE ELECTRIC/ELECTRONIC EQUIPMENT, INCLUDING CELL PHONES, GPS NAVIGATION DEVICES, ETC.! WHEN YOU TURN ON A GAS DETECTOR/HAZARDOUS ATMOSPHERE INDICATOR, TURN OFF YOUR CELL PHONE! ERP No. 3: Hazard Minimization The first responders to arrive at an emergency location must survey the situation and take actions necessary to: PROTECT PEOPLE Protect Property and the Environment Do only what is absolutely necessary to protect people then property WITHOUT PUTTING YOURSELF AT RISK until additional help arrives. Join the Unified Incident Command System (UICS) as the PB Incident Commander until the Pipeline Supervisor arrives. DO NOT ATTEMPT TO RECONFIGURE THE PIPELINE SYSTEM UNLESS INSTRUCTED TO DO SO BY THE PIPELINE SUPERVISOR OR THE CONTROL ROOM OPERATOR. If no one else at the emergency location is familiar with the UICS, assume the position of Incident Commander and direct others in using the UICS. The highest ranking emergency responder or public official will be the incident commander while there is an ongoing threat to public safety. Make sure that ALL emergency responders are aware of the general and specific procedures to follow in responding to a pipeline emergency. ERP No. 4: De-commission and Re-commissioning a Pipeline System For Startup are after a Repair 1. Isolate the pipeline system or section you are wanting to De-commission

23 Effective Date: January 2011 Supersedes: Page 21 of Connect a temporary flare at the end of the section you want to de-commission and start flaring. 3. Completed depressuring to the flare. 4. Hook up a nitrogen truck at the beginning of the section you want to de-commission. 5. Purge N2 to the flare until the flare goes out with zero LEL. 6. Complete the repairs or work on the pipeline section. Also analyze up stream and down stream of the repair to determine if the integrity of the pipeline was affected after an event to protect the public 7. Re-pressure up the section with nitrogen to 300 psig. 8. Start re-pressuring the section up with product, through the small by-pass line. 9. Maintain the pressure on this section at 300psig with product until the flare re-lights. 10. Purge the line with product to the flare for 45 minutes and the take a sample to check the quality of product in the system. 11. Slowly start re-pressuring up the section of the pipeline, also checking for leaks. 12. Re-pressure the pipeline to full line pressure, open all main line block valves and put the pipeline back into service. This is a general de-commission and re-commissioning/startup procedure. All pipeline sections will have detail instructions on valve alignment, with operation of the specific pipeline sections. Fire or Explosion Leave fire fighting to trained emergency responders. Extinguish only those fires which can be extinguished with a hand-held fire extinguisher ONLY IF NECESSARY TO PROTECT LIFE. Generally, it is a better idea to let ignited leaking gas, vapors or liquid material burn so that unignited materials go not migrate unobserved, to subsequently find an ignition source. Leave that decision to trained emergency responders. In some situations, leaking gas, vapors or liquid material may be intentionally ignited to keep it from migrating. Leave that decision to trained emergency responders. In the case of an explosion, hazardous conditions may exist or may even be magnified after an explosion. An explosion may increase the flow of material from a leak. An explosion may extinguish an active fire burning leaking material. Even though flames may have dissipated, the possibility of re-ignition exists after explosion. An explosion may cause damage to other pipelines and facilities. As soon as possible after an explosion the integrity of pipeline facilities in the immediate area of an explosion must verified.

24 Effective Date: January 2011 Supersedes: Page 22 of 66 Gas Detected Inside or Near a Building A Leak Survey will be performed anytime there is a report of gas inside or near a building. If gas is detected, the building will be evacuated. PB ESS will survey their pipelines to determine if there is a leak from one causing the gas to migrate in the building. If a leak is found, it will be promptly repaired. Accidental Release of Product The accidental release of natural gas from a PB ESS pipeline should be treated as an emergency requiring IMMEDIATE RESPONSE until the Pipeline Supervisor declares the emergency to be over. Operational Failure An emergency situation resulting from an operational failure is any situation in which abnormal operation can no longer provide continued safe operation of the pipeline and the operation of the pipeline must cease. Control room operators have the authority to cease the operation of the pipeline in any situation in which in their judgment, continued operation of the pipeline could result in injury to people; could result in the unintended release of material from the pipeline; or could result in damage to pipeline facilities. Natural Disaster Pipeline Supervisors and control room operators must be aware of the threat or occurrence of a natural disaster in the area of the ROW of the pipelines they operate as well as the other pipelines operated by PB ESS. Some of the pipelines operated by PB ESS are relatively long and follow routes which are far removed from the location of the pipeline control center. Conditions at the control center or any particular location along the ROW may be radically different from conditions at other locations. Control room operators will monitor the ROW environment through USGS and NOAA websites. (see ERP No. 8: ROW Environment Monitoring). Hurricane Hurricanes on the pipeline ROW are usually preceded by advance warning. As the path and intensity of a hurricane become known PB ESS and client hurricane response procedures will be implemented. PB ESS will operate pipelines in accordance with the hurricane response plans of the client owners of the pipelines. Example: Pipelines delivering natural gas to electric generating power plants will most likely remain in operation during even the most intense hurricanes. Client owners should be encouraged to shut in and drain down pipelines that transport materials that are not essential to public health and safety. Pipeline and Site Supervisors will implement the PB ESS hurricane response procedures at their respective facilities and will coordinate PB ESS procedures with those of the client owners of the pipeline. As PB ESS and client response plans are implemented, Pipeline and Site Supervisors will develop a plan to address pipeline operating personnel needs and the availability of personnel during the event.

25 Effective Date: January 2011 Supersedes: Page 23 of 66 In no case will PB ESS jeopardize the personal safety of PB ESS personnel and contractors or the physical assets of PB ESS and the client owner in operating pipelines during hurricanes or other natural disasters. The most likely threats to the integrity of pipelines during a hurricane are: Wind damage to above ground facilities Wind with very high sustained speed is usually present over long periods of time during a hurricane. Even though the wind itself may not be a threat, air borne debris can damage above ground piping and facilities. Flooding 1. Above Ground Facilities and Buried Pipelines Flooding can be hazardous to above ground facilities by damaging or interfering with communication and operating electric and electronic systems. Floating debris can come in contact with and damage above ground facilities. Flooding can be a hazard to underground facilities by causing washout of the pipeline and facility support. Flooding can also cause normally buried piping to become exposed. Pipeline coating, particularly at soil-to-air interfaces can be damaged by flooding. Pipelines in ROW that has been flooded must be inspected as soon as possible after the water recedes to determine the integrity of the pipeline and the right-of-way. 2. Waterways Pipelines crossing navigable waterways can be susceptible to damage from flooding. Pipeline cover can be washed away, exposing the pipeline. Exposed pipelines can float up and be damaged by floating debris or ship traffic. Barges and other vessels can be broken away from moorings by floods and drag anchor lines across the pipeline or even sink on top of the pipeline. Pipelines crossing navigable and non-navigable waterways must be monitored during periods of flooding. After an unusually large flood, pipelines crossing navigable waterways should be inspected by divers. Tornado Tornadoes can include all of the hazards of the highest level hurricanes. Tornadoes are usually more localized and are not as widespread as hurricanes but are more dangerous because there is usually very, little if any, advance notice of the occurrence of a tornado. Duties of Pipeline and Site Supervisors During Natural Disasters 1. Keep emergency supplies, equipment and materials available as necessary across the pipeline ROW. 2. Monitor the entire length of the pipeline ROW for the possibility of natural disasters. 3. Communicate with other supervisors and operating personnel prior to (if advance notice is available), during and after a natural disaster to establish a priority of action.

26 Effective Date: January 2011 Supersedes: Page 24 of Establish the availability of PB ESS operating personnel, contractors and client owner personnel. 5. Inform local emergency responders; fire departments, police, public safety organizations and public officials of PB ESS pipelines that will remain in operation during the anticipated period of the event. Discuss the potential for damage to pipeline facilities and the consequences of damage to specific facilities, how PB ESS will respond and the assistance they might be expected to provide. 6. Coordinate with local police and public safety organizations for allowing PB ESS personnel and contractors to examine and inspect pipeline facilities as soon as practical after an event. DISPATCH PERSONNEL TO EXAMINE AND INSPECT FACILITIES ONLY WITH THE KNOWLEDGE AND CONSENT OF LOCAL POLICE AND PUBLIC SAFETY OFFICIALS.

27 Effective Date: January 2011 Supersedes: Page 25 of 66 PERSONNEL AND EQUIPMENT PP ESS Emergency Equipment and Resources Form ERP-F1: Emergency Response Equipment, Tools and Materials Checklist is a list of items that all PB ESS pipeline personnel should keep in their company assigned vehicles. This list should be checked each month to make sure all items are available. MAKE SURE THAT ALL INSTRUMENTS AND EQUIPMENT REQUIRING REGULAR CALIBRATION ARE KEPT CALIBRATED ACCORDING TO THE MANUFACTURER S SPECIFICATIONS. Due to the possible limited availability of line locating equipment it may not be possible to keep line locating equipment in each vehicle. If line locating equipment is not available in each vehicle, the control room operator will use the emergency notification text message system to notify an individual to report to the pipeline control center during an IMMEDIATE RESPONSE condition to pick up the line locating equipment and get it to the area of the emergency. If additional personnel, equipment and/or resources are needed, contact these contractors: All Systems: EMS Willow Glen: THI Contractors, LLC Contractor Emergency Equipment and Resources PB Energy has contracts with the following companies to provide equipment and resources to assist in an emergency: Contract Company Contract Expiration Date Available Resources Local Emergency Response EMS THI Contractors, LLC. N/A Ongoing Ongoing Fire fighting, equipment and public safety equipment (i.e. barricades) Gas monitoring, barricades, excavating equipment, HAZMAT Gas monitoring, barricades, excavating equipment, HAZMAT

28 Effective Date: January 2011 Supersedes: Page 26 of 66 CONTROL ROOM OPERATOR PROCEDURES DAY-TO-DAY VERIFICATION ERP No. 8: ROW Environment Monitoring Severe Storms, Tornadoes At the start of each shift and periodically throughout a shift, control room operators should access the NOAA Storm Reports website and check for reports of tornadoes or severe storms along the pipeline ROW. If there is evidence of tornadoes or severe storms in the area of the pipeline ROW a GENERAL RESPONSE EMERGENCY should be implemented to investigate the state of the ROW and the integrity of pipeline facilities in the area. If there is evidence of damage to the pipeline caused by a tornado or a severe storm contact the Pipeline Supervisor. Be prepared to implement an IMMEDIATE RESPONSE EMERGENCY. Flooding At the start or each shift, control room operators should access the USGS Waterway Data website to check for abnormal water levels in waterways crossed by PB ESS pipelines. If the water level in any of the waterways crossed by PB ESS pipelines is higher than normal, a GENERAL RESPONSE EMERGENCY should be implemented to determine the impact on the integrity of the pipeline and the body of water containment system. Grass Fires/Forest Fires At the start of each shift and periodically throughout a shift, control room operators should access the NOAA Fire Monitoring website and check for the evidence of grass fires along the pipeline ROW. If there is an indication of possible fire activity near the pipeline ROW a GENERAL RESPONSE EMERGENCY should be implemented to determine the severity of the possible threat to the pipeline. Earthquake The pipelines PB ESS operates are in areas that are typically not seismically active. However, minor or moderate seismic occurrences could result in hazardous or emergency situations along the pipeline ROW. At the start of each shift and periodically throughout a shift, control room operators should access the USGS Seismic Monitoring website and check for the evidence of seismic activity along the pipeline ROW. If there is evidence of seismic activity in the geographic vicinity of PB ESS pipelines, inform the Pipeline Supervisor. Major seismic activity in offshore areas of the Gulf of Mexico could result in tsunami or tidal waves that could flood inlets and other bodies of water connected to the Gulf of Mexico. If there is an indication of seismic activity in the Gulf of Mexico, access the USGS Waterway Data website to check the level of waterways which PB ESS pipelines cross. If the water level in any of the waterways crossed by PB ESS pipelines is higher than normal, a GENERAL RESPONSE

29 Effective Date: January 2011 Supersedes: Page 27 of 66 EMERGENCY should be implemented to determine the impact on the integrity of the pipeline and the body of water containment system.

30 Effective Date: January 2011 Supersedes: Page 28 of 66 CONTROL ROOM OPERATOR PROCEDURES EMERGENCY PROCEDURES ERP No. 9: Receiving Notification of an Emergency When notification of an emergency is received, it is the responsibility of the control room operator to: Determine that an emergency condition exists; Classify the emergency; Identify the area of the emergency; Notify pipeline personnel to respond to the emergency; Serve as the communication coordinator for PB ESS emergency response personnel through the duration of the emergency. Whatever the source of notification of an emergency, use form ERP-F2: Receiving Notification of an Emergency to record information to be used to help identify the area of the emergency. Form ERP-F2 is a permanent record of our response to a possible emergency situation. Fill out the form completely and accurately. A copy of the completed form will be kept at the pipeline control center and at the corporate office. 1. If a call to the ROW marker emergency number is received, immediately ask the caller for A TELEPHONE NUMBER WHERE THE CALLER CAN BE REACHED in the event the call is lost or disconnected. 2. Get as much information as possible about the location of the emergency. A street address might not be available. 3. Locate the area of the emergency on Google Earth by entering the location information in the Fly to data entry box. If possible, KEEP THE CALLER ON PHONE UNTIL THE AREA OF THE EMERGENCY IS LOCATED on Google Earth. 4. Get a description of the emergency situation. Ask if there is a pipeline leak. Advise the caller to keep a safe distance from any hazardous areas and to avoid possible ignition sources. 5. Ask if 911 has been called. Tell the caller to call 911 immediately after the call is done. If the caller cannot call 911, call 911 from the control center and ask the local 911 operator to help get emergency response personnel to the area of the emergency. 6. Right click on the location placemark frame and select Properties. The Google Earth Edit Placemark menu will appear. 7. WRITE THE LATITUDE AND LONGITUDE COORDINATES OF THE AREA OF THE EMERGENCY ON FORM ERP-F2. 8. Copy and paste the Latitude and Longitude coordinates of the area of the emergency in the emergency notification text message if the situation requires GENERAL REPSONSE or IMMEDIATE RESPONSE.

31 Effective Date: January 2011 Supersedes: Page 29 of As soon as possible and at every opportunity, record events as they occur on form ERP-F3: Emergency Response Record of Events. Use as many copies of the form as are necessary to record all of the events and activities that take place. ERP No. 10: Using the Pipeline Emergency Response Text Message Notification System When notification of a potential emergency is received, use these steps: 1. Use form ERP-F2 to record information about the location of the emergency. 2. Use Google Earth to determine the latitude and longitude coordinates of the area of the emergency. 3. Determine if the situation requires IMMEDIATE RESPONSE by all available personnel or GENERAL RESPONSE from select individuals. Call the Pipeline Supervisor if necessary to help make this determination. 4. Access the Pipeline Emergency Response Text Message Notification System. 5. IF THE AREA OF THE EMERGENCY IS THE WILLOW GLEN SYSTEM THE TEXT MESSAGE NOTIFICATION SYSTEM CANNOT BE USED. CALL THE WILLOW GLEN PIPELINE SUPERVISOR BY TELEPHONE. 6. Send out the appropriate text message with the latitude and longitude coordinates from Google Earth. Copy and past the coordinates from Google Earth to prevent mistakes. 7. Once the text message notification has been sent, initiate and moderate a conference call (see ERP No.11: Moderating a Conference Call) 8. Open the Check Text Status window and monitor the availability of responding personnel 9. Coordinate communications among the Pipeline Supervisor/Incident Commander and responding personnel until the response team is identified. 10. If necessary, Use the Pipeline Emergency Response Text Message System, arrange for pipeline locating equipment to be taken the site of the emergency, if necessary. 11. Maintain communication with the PB ESS Incident Commander in order to assist in whatever way is necessary. 12. Monitor the pipeline pressures and valve positions via SCADA. The control room operator will act as the communication coordinator for PB ESS emergency response personnel through the duration of the emergency

32 Effective Date: January 2011 Supersedes: Page 30 of 66 Spindeltop Storage Facility Emergency Response Actions Introduction The Station Emergency Response Plan is intended to provide supervisors and operators a description of the type of emergencies, emergency response devises installed at the site, objectives and responsibilities common to all emergencies, emergency response plans, incidents requiring reporting, and emergency contact numbers. Types of Emergencies 1. Overpressure (above MAWP of equipment) 2. Office building fire 3. Fire or explosion (beyond the capacity of a 30# fire extinguisher) 4. Compressor building gas leak detection or fire alarm 5. Process piping failure or gas leak (no fire) 6. Mechanical failure (excluding piping) 7. Power, I&C failure (critical equipment operation) 8. Personnel injury or sickness (other than first aid) 9. Spills & pollution threat (hazardous material) Types of Emergency Response Devices 1. Emergency Shutdown (ESD) system 2. Emergency Blowdown (EBD) system 3. Equipment start-stop switches 4. Standby Generator 5. UPS 6. Tank containment & absorbent pads 7. Process piping and pressure vessels overpressure relief valves 8. Process piping and equipment isolation valves 9. Fire extinguishing equipment 10. First aid kit in control room Objectives and Responsibilities Common to All Emergencies 1. Provide safety and protect the lives and well-being of all personnel on site. (Person who discovers the problem). 2. Attempt to minimize equipment and property damage. (Person who discovers the problem). 3. Isolate the damage or contain the spill. (Person who discovers the problem).

33 Effective Date: January 2011 Supersedes: Page 31 of Notify the appropriate Company personnel. (Person who discovers the problem) (Spindletop Emergency Contacts). 5. Notify Entergy Sabine Plant if injection or withdrawal activities are interrupted. (Operations) (409) Notify Knife River Concrete in the event of a leak or fire. (Immediately in the event of a leak or fire at Well #2) (409) AGL Golden Triangle Storage DCP Costal Caverns Air Liquide RHEACO Oil Company Knife River Concrete IBEW Hall Notify adjacent station operator, Duke Energy. (Plant Manger) (409) Notify IBEW in the event of a leak or fire. (409) *. 9. Notify the appropriate law enforcement, medical, and fire emergency response personnel. (Supervisor or his designated A Operator). 10. Notify Golden Triangle Storage (AGL) at option #9 then talk to the dispatcher. (Local & Regulatory Contacts). 11. Notify the appropriate Federal, State and Local Government regulatory personnel. (Supervisor) (Local & Regulatory Contacts). Emergency Response Procedures Overpressure of Equipment 1. First actuate the ESD valve closure at the wellheads and at the Metering and Regulating (M&R) station. Then relieve the overpressure by either shutting in the piece of equipment, bleeding down the piece of equipment or, as a last resort, actuating the EBD system. If EBD system is activated, block all roads into the Plant and stop incoming traffic. The fuel gas system must be manually blown down from a valve near PV-090 if a Plant EBD is initiated. ( A Operator) 2. If relief valves are relieving, extinguish all welding or other ignition sources on the Plant site, block all roads into the Plant, and stop incoming traffic. ( A Operator) 3. Identify, if possible, the cause of the overpressure and advise A Operator in charge. (Person who discovers the problem) 4. The A Operator will assess whether the equipment can be returned to service and will advise the Supervisor. 5. The Supervisor, if appropriate, will advise all nonessential personnel to evacuate to the Plant gate on Sulphur Drive. Randy Boudreaux, Donna Peltier, or weekend duty supervisor will conduct a head count and verify that all personnel are accounted for.

34 Effective Date: January 2011 Supersedes: Page 32 of 66 Office Building Fire 1. An audible alarm will be sounded to alert all employees. 2. The emergency shut down or the emergency blow down system will be activated if necessary. 3. The Beaumont Fire Department will be notified of the fire if containment requires in excess of one 30# fire extinguisher. 4. All competent person trained employees will respond to the fire. 5. All untrained or nonessential employees will evacuate the facility as quickly and safely as possible, and report as quickly as possible to the main Plant gate or Sulphur Drive. 6. All equipment affected by the fire will be put out of use and will remain out of use until proper post-fire testing and inspection can deem the equipment safe for operation. Fire or Explosion (beyond the capacity of a 30# fire extinguisher) 1. Actuate the ESD system immediately. DO NOT actuate the EBD system without being certain that gas will not be vented in the area of the fire. (Person who discovers the problem) 2. Evacuate all personnel from the area of the incident to the control room or auxiliary building area. ( A Operator) 3. Attempt to isolate the fire from its source using process block valves. Commence extinguishment with appropriate equipment, if necessary. (Person who discovers the problem) 4. Advise the A Operator in charge who will assess with the Supervisor whether it is necessary to evacuate the entire plant site. Call local firefighting agencies. (Person who discovers the problem) 5. The A Operator will rack out any electrical equipment in the area of the fire. Water must not be used on any fire in the high voltage area of the Plant. 6. The Supervisor, if appropriate, will advise all nonessential personnel to evacuate to the Plant gate on Sulphur Drive. If evacuation is required notify Sabine Station Number 3 Control Room that Entergy personnel will be required for monitoring of the pipeline system until PB Personnel can arrive at the Sabine No. 3 Control Room. (409) Compressor Building Gas Leak Detection or Fire Alarm One of the most critical buildings in the facility is the Compressor building containing four gas injection compressors. Compressor Building Gas and Fire Detection Systems 1. The compressor building is equipped with extensive gas and fire detection system as described in the paragraph "Safety Systems and Alarms." 2. The building is also equipped with a comprehensive ventilation system consisting of three exhaust fans located in the ridge of the compressor building roof. Automatic start of these

35 Effective Date: January 2011 Supersedes: Page 33 of 66 exhaust fans is tied to the signal from the gas detectors which enables to classify area inside the compressor building as Class I, Div. 2 instead of Div. 1 in accordance to API RP 505. The exhaust fans could also be started manually. All equipment enclosures inside the building are specified and installed suitable minimum for Class 1, Div.2 area classification. 3. Compressor building has 8 gas detector and 8 fire detector sensors. Two gas detectors are installed above each engine/compressor unit enabling to detect gas leak from any individual unit. 4. Infrared optical fire detectors are installed on the building's west and east wall columns enabling to cover 100% of the equipment and floor surface. 5. The gas and fire detectors are connected to the site SCADA systems and display the status and alarm conditions on the operator's control screen in the control room. a. Gas detectors are set to issue an alarm when they detect gas at 20% of Low Explosive Level (LEL) and initiate an automatic start of exhaust fans, if fans are not running. If the gas level continue to rise regardless of exhaust fans operation and reaches 50% of LEL an automatic building shut down signal is issued. Upon such signal, all unit intake and discharge ESD valves will close and all EBD valves open to evacuate gas trapped in the units and pipes to the vent system. b. Fire detectors signals in SCADA are programmed in such a way as to avoid nuisance trips in case of false alarm. A signal from a single fire detector issues an alarm in the operators control room. An operator is forced to check and verify what caused this signal and take preventive actions in accordance to plan. If two fire detectors sense fire, it will cause an immediate automatic shutdown of all compressor units and open EBD valves as described above, thus isolating the compressor building. c. Compressor building has also two manual ESD pushbuttons located adjacent to the north and south of west wall of the building entrance doors. The pushbuttons are intended for total facility ESD and enable operator to shut facility down on the run in case if a danger to life or serious equipment damage could happen. Gas Leak Detection Emergency Response 1. Upon receiving an alarm only signal (without auto shutdown) from compressor building gas detection system the operator on duty shall immediately go to the building to assess the conditions. 2. If gas detection signal was initiated, the operator has to make sure that the exhaust fans were started automatically. In case of automatic start failure, the operator shall attempt to start fans manually inside the building. 3. The operator has to stop any "hot" work, if performed inside or close by the compressor building and evacuate any personnel. 4. If gas alarm continues, the operator has to shut down the ESD valves on each unit and open the EBD valves to evacuate remaining in pipes and units gas. 5. The operator shall immediately notify assistant plant manager on emergency conditions arisen in the compressor building.

36 Effective Date: January 2011 Supersedes: Page 34 of 66 Fire Detection Emergency Response 1. Upon receiving an alarm only signal (without auto shutdown) from compressor building fire detection system the operator on duty shall immediately go to the building to assess the conditions. 2. If fire detection signal was initiated by a single fire detector, the operator has to make sure that there is no obvious fire in the building. If a small fire is present, the operator has immediately notify by radio second operator and use fire extinguisher to suppress fire. If not feasible to suppress fire, the operator shall initiate ESD and EBD valves operation as described above. 3. If two fire alarm signals were initiated, the operator shall make sure that an automatic compressor building shutdown is initiated. If no automatic shutdown occurred, the operator should initiate total facility ESD by manual ESD pushbutton and act as described in the paragraph 6.4 of this plan. Process Piping Failure or Gas Leak (no fire) 1. Locate, if possible, the source of process leak or failure. Cease all hot work in the immediate area of the leak and shut down any arcing or sparking operations plant wide. (Person who discovers the problem) 2. If the incident is relating to an alarm from a gas leak detected inside the compressor building, isolate the compressor building by shutting the ESD valves on the suction and discharge headers. If accessible, close all equipment/vessel isolation valves inside the building and open the EBD valves to evacuate the gas within the piping inside the compressor building. 3. Advise the A Operator and jointly determine if the situation is immediately jeopardizing personnel safety or property. (Person who discovers the problem) 4. If the problem is a threat to personnel safety or property, or if the cause of the problem is not readily apparent, the process will be shut in either with the equipment on/off switch, with isolation valves, or with the ESD system. (Person who discovers the problem) 5. Advise the A Operator on tour. (Person who discovers the problem) 6. The Supervisor, if appropriate, will advise all nonessential personnel to evacuate to the Plant gate on Sulphur Drive. Mechanical Failure (Excluding Piping) 1. Immediately shut in the piece of equipment involved. (Person who discovers the problem) 2. If electrically driven, lock and tag it out of service. (Person who discovers the problem) 3. Notify the A Operator. (Person who discovers the problem) 4. The Supervisor, if appropriate, will advise all nonessential personnel to evacuate to the Plant gate on Sulphur Drive. Power, I&C Failure 1. The facility is provided with an emergency generator and an UPS for accommodating critical loads during a power or I&C failure. The facility is designed for the generator to come on line

37 Effective Date: January 2011 Supersedes: Page 35 of 66 automatically through an auto transfer switch. The facility is also designed for UPS to come on line automatically in the event of an I&C failure. 2. Make sure the facility generator is periodically exercised and that the day tank is filled with diesel and the UPS batteries are fully charged at all times. Personnel Injury or Sickness (other than first aid) 1. Check the area to insure that it is safe before entry. 2. If possible remove the injured person to a safe location. (Person who discovers the problem) 3. Apply first aid. (Person who discovers the problem) 4. If injury or sickness merits, dial 911 for emergency medical assistance. (Person who discovers the problem) 5. Be prepared to verify Workers Compensation coverage as noted on the document on the bulletin board in the control room if injured person must be transported to a hospital. (Supervisor, Randy Boudreaux, Donna Peltier) Spills and Pollution Threat (hazardous material) 1. If threat involves a liquid storage tank inside a firewall or containment structure, close the firewall drain immediately. These drains must always remain closed except when draining rainwater. (Person who discovers the problem). 2. Be aware that all plant site drainage goes to the S.E. culvert across the rear Plant access road. Bundles of absorbent pads are available in the tool room and can be spread at the road crossing culvert to collect any spilled hydrocarbons. (Person who discovers the problem). 3. Notify the A Operator on tour. (Person who discovers the problem). 4. The Supervisor will evaluate and make appropriate regulatory agency contacts. 5. Material Safety Data Sheets (MSDS) for commodities utilized at the site may be found in the Control Room. Note: Product lists and MSDS will be given to the emergency response authorities, as required.

38 Effective Date: January 2011 Supersedes: Page 36 of 66 TEXAS MAINLINE NO.1 (9 MILE), MAINLINE NO. 2 (14 MILE) EMERGENCY SHUTDOWN PROCEDURES Identify that there is an emergency by using the Delta V System, and try to identify the area of the emergency. Unusual differential in pipeline pressure between the remote transmitters on the pipeline and each individual gas yard may help identify the problem area. If the problem area is determined to be on the #2 line, between the Spindletop Storage facility and AOV-1 located in the Texoma gas yard, cease all injection or withdrawal at the storage facility, close valve 001, storage outlet, and shut in AOV-1. Dispatch pipeline personnel to visually determine that AOV-1 is closed. If the problem area is determined to be on the #2 line between AOV-1 and AOV-8, located inside the Tejas 2 yard, cease injection or withdrawal at the storage facility and close valve 001 shut in all gas flow onto the #2 line by shutting in Texoma buy and sell sides, DCP 3, and Tejas 2 sell, then close AOV-1 and AOV-8 are closed and that all yards mentioned before are shut in. If the problem area is determined to be on the #1 line between the Houston Pipeline yard and the Midstream Isolation Valve inside the Winnie Pipeline yard, shut in all yards flowing gas upstream of the Midstream Isolation valve by shutting in Houston Pipeline, Texas Eastern, Enbridge, and Florida Gas. Then close the Midstream Isolation valve. Dispatch pipeline personnel to visually determine that the Midstream Isolation valve is closed and that all gas yards mentioned above are shut. If the problem area is determined to be located between the Midstream Isolation valve and the 150 Yard Isolation valve, contact the Entergy operator on duty and instruct him/her to close the 150 Yard Isolation valve. Shut in all gas flowing onto the system by shutting in all gas yards, cease any injection or withdrawal at Spindletop, close the midstream Isolation valve on line #1 and close AOV-8 on line #2. Dispatch pipeline personnel to visually ensure that the Midstream Isolation valve, AOV-8, and 150 Isolation valve are closed and all gas yards are shut in. In the event that any of the fore mentioned situations should arise, the operators on duty should monitor the pipeline pressures and valve positions via the Delta V System. He/She will act as the communication coordinator for PB ESS emergency response personnel through the duration of the emergency.

39 Effective Date: January 2011 Supersedes: Page 37 of 66 Media Guidelines ADMINISTRATIVE SUPPORT PROCEDURES The Operations Manager or his designee will act as the PB ESS media spokesperson during an emergency event. PB ESS pipeline personnel responding to an emergency should politely defer all questions from media representatives to the responding Pipeline Supervisor. The Pipeline Supervisor should inform media representatives that a PB ESS spokesperson will be available to provide more information and answer questions. Notifications and Reporting Procedures for the required notification of public officials and the reporting of incidents and safety related conditions involving PB ESS operated pipelines are found in PB ESS pipeline operation and maintenance (O&M) manuals. Investigation of Failures As soon as practical after the emergency, the procedures in the Operations and Maintenance (O&M) Manual for investigating the cause of failures (49 CFR ) will be initiated. This review will include a root cause analysis to determine the cause of the failure. In addition, it will be determined if an individual may have contributed to the emergency and if so action will be taking according to the Operator Qualification (OQ) Manual. Results from this investigation will be used to update this manual as needed. Emergency Procedure / Training Evaluation and Effectiveness These procedures are in continuing refinement and development. Revisions identified as necessary for the protection of people and property will be implemented immediately upon discovery. Revisions identified but not absolutely necessary for the improved safety of people and property will be implemented as expeditiously as possible. These written procedures will be reviewed at least once each calendar year and/or within 15 months of the last review or revision. After each emergency, all procedures followed will be reviewed to determine if the were effectively followed and for accuracy and places of needed improvement. These updates will be immediately incorporated into the appropriate procedure. In addition to procedure review, individuals who are trained in emergency response will have the opportunity to evaluate the training received and determine which improvements need to be made. These improvements will be incorporated into the emergency training as appropriate.

40 Effective Date: January 2011 Supersedes: Page 38 of 66 FORMS ERP-F1: Emergency Response Equipment, Tools and Materials Checklist THE FOLLOWING ITEMS WILL BE KEPT IN ALL PB ESS COMPANY VEHICLES TO BE USED BY PERSONNEL WHEN RESPONDING TO A PIPELINE EMERGENCY. Keep vehicle fuel at minimum of half tank First aid kit Company cell phone Flashlight In vehicle navigation device Bolt cutters or hacksaw PB ESS Pipeline Emergency PPE Vehicle magnetic identification signs Gas/hazardous atmosphere detector o Calibration Fire extinguisher o Inspected Line locating equipment/line marking supplies Public warning and control materials

41 Effective Date: January 2011 Supersedes: Page 39 of 66 ERP-F2: Receiving Notification of an Emergency Use this form to record information about an emergency from any source (telephone, SCADA, pipeline personnel, etc.) Telephone Number Where the Caller Can Be Reached (Including area code. Check Caller ID) Caller s Name: Caller s Location / Location of Emergency (circle one): Address or Nearest Town Nearest Intersection: Location Coordinates (Degrees Decimals Example Latitude: Longitude: ) Latitude: Longitude: Describe the Emergency: Has 911 been called? (Tell caller to keep a safe distance and call 911) Yes No Call Taken By: Date: Time: (Start Emergency Response Record of Events) Classification (circle one): IMMEDIATE RESPONSE GENERAL RESPONSE ABNORMAL OPERATION

42 Effective Date: January 2011 Supersedes: Page 40 of 66 ERP-F3: Emergency Response Record of Events RECORD ALL EVENTS (copy this sheet as many times as needed) Date: Time Event Page of

43 Effective Date: January 2011 Supersedes: Page 41 of 66 MAPS The following maps are inserted following this page: Texas Mainline #1 Texas Mainline #2 Red Line Green Line Willow Glen

44 Texas Mainline #1

45 Texas Mainline #2

46 Red Line

47 Green Line

48 Willow Glen

49 Effective Date: January 2011 Supersedes: Page 47 of 66 NATURAL GAS MSDS The MSDS for Natural Gas, dated September 2004, is inserted following this page.

50 Effective Date: January 2011 Supersedes: Page 48 of 66