4-4-11 Tres Palacios Presentation Corrected

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FERC Environmental Training:

FERC Environmental Training

Operations:

Operations Three solution-mined salt caverns located in the Markham Salt Dome ½ - ¾ mile below ground surface 54 billion cubic feet of natural gas storage Connecting to 12 intra- and interstate pipelines

Gas Handling Facility & Storage Caverns:

Gas Handling Facility & Storage Caverns Gas Handling Facility located on a 20-acre parcel that is located approximately 2,000 feet northeast of Cavern No. 3 Service corridors will provide access to the GHF and cavern well sites Temporary Fabrication Area – 30 acres adjacent to GHF

Pipeline System:

Pipeline System 24-inch-diameter, 31-mile North Pipeline and 10.75-mile South Pipeline

Environmental Inspectors:

Environmental Inspectors Verify contractor compliance with Project environmental requirements “Stop-task” authority and “Stop-work” recommendations Direct corrective actions All workers must give the Environmental Inspectors their full cooperation

Overall Project Regulatory Authority:

Overall Project Regulatory Authority Federal Energy Regulatory Commission (FERC) Primary Regulatory Authority for Facility Construction and Operation

Environmental Requirements:

Environmental Requirements FERC Certificate, Plans & Procedures Project Permits Stormwater Pollution Prevention Plan (SWPPP) Spill Prevention Control & Countermeasures Plan (SPCC) Landowner requirements

Approved Work Areas:

Approved Work Areas All construction activities must remain in approved areas Parking or storage of equipment and material outside of approved areas is prohibited

Wetlands:

Wetlands Install sediment barriers immediately after initial disturbance of wetlands or adjacent uplands and across entire construction ROW at wetland boundaries Install sediment barriers as necessary where wetlands are adjacent to ROW and along the edge of the construction ROW in wetlands

Wetlands:

Wetlands Do not work in wetlands unless absolutely necessary Plan all work in wetlands with EI’s input Do not store hazardous materials, fuels, lubricants, or concrete coating within 100 feet of wetlands Do not refuel within 100 feet of a wetland or inside a wetland

Stormwater/Erosion Controls:

Stormwater/Erosion Controls Erosion controls minimize sediment runoff Erosion control devices Containment berms or trenches Silt fences Hay bales Stone overflow structures Combination of the above

Stormwater/Erosion Controls:

Stormwater/Erosion Controls Silt Fencing Geotextile material supported by stakes

Stormwater/Erosion Controls:

Stormwater/Erosion Controls Silt Fencing Required Around well pads (new pads only) On sideslope and downslope construction boundaries On the downhill side of access road and work area to protect adjacent wetlands, waterbodies or drainage channels

Stormwater/Erosion Controls:

Stormwater/Erosion Controls Evaluated by EI for repairs Replace within 24 hours of notice from EI, by end of day, and prior to storm events

Dewatering:

Dewatering Remove only if necessary Conditions for removal Free of sheen or chemical residue Discharge through dewatering structure or filter bag Make sure you have plenty of materials available and ready

Slide 32:

Keep heavily silt-laden water out of streams and wetlands Dewater in a manner that does not cause erosion Use secondary containment for stationary pumps, fuel containers, generators, etc. Use caution when refueling dewatering pumps Dewatering

Equipment Fueling/Maintenance:

Equipment Fueling/Maintenance Employees handling fuel must be properly trained Equipment must be in good operating condition and inspected regularly Fueled or parked equipment more than 100 feet from waterbodies Hazardous materials not within 100 feet of waterbody

Equipment Fueling/Maintenance:

Equipment Fueling/Maintenance Conduct regular equipment inspections Dispose of all maintenance wastes at approved disposal facility All portable equipment with fuel tanks must be stored and operated in secondary containment (wading pool or steel tank)

Spill Reporting:

Spill Reporting All spills must be reported to EI EI will provide subsequent notifications EI will oversee contractor cleanup operations

Waste Management:

Waste Management Wastes must be collected, stored and disposed of properly Drilling muds must be disposed at permitted facilities approved by Tres Palacios Drilling contractor must maintain disposal records for all shipments of drilling muds, hazardous wastes, and liquid wastes

Unanticipated Discoveries:

Unanticipated Discoveries Cultural Resources Remain alert for possible items of historic significance (e.g, Indian arrowheads, tools, etc.) If item is uncovered Stop work or isolate area Protect find Report all items uncovered to EI

Training Requirements:

Training Requirements All contractor personnel must receive FERC training Complete and sign attendance roster Receive a list of required work practices Acknowledge by signature – received and understand work practices

What is Compliance/noncompliance?:

What is Compliance/noncompliance? Environmental Laws and Regulations Letter of the Law Spirit of the Law

What Does TPGS Have to Comply With?:

What Does TPGS Have to Comply With? Federal Energy Regulatory Commission (FERC) U.S. Fish and Wildlife Service (USFWS) U.S. Environmental Protection Agency (EPA) U.S. Army Corps of Engineers (USACE) Texas Commission on Environmental Quality (TCEQ) Texas Railroad Commission (TRC)

Noncompliance:

Noncompliance If contractor does not take corrective action, the EI will issue a “Stop-work” order and will require immediate action and/or remove contractor from project

General Compliance Penalties:

General Compliance Penalties Work Stoppage/Construction Delays (Director OEP) Costs Associated with Consent Orders Higher Level of Agency Scrutiny Fines Jail Terms for Corporate Officers

Slide 49:

Thank You