January 22, 2023

Mr. Terry Turpin

Director, Office of Energy Projects
Federal Energy Regulatory Commission (FERC)
Department of Energy

RE: Request to Cool Down Loop 1 LNG Transfer Piping and Reinstate BOG Management;
OEP/DLNG/LNG 2, Freeport LNG Development, L.P., Docket Nos. CP03-75-000, CP03-75-
002, CP03-75-003, CP03-75-004, CP05-361-000, CP05-361-001, CP12-509-000 and CP12-29-
000

Dear Director Turpin,

Pursuant to your letter dated June 30, 2022, Freeport LNG Development, L.P. (“Freeport”) must obtain
written approval from FERC before restarting any non-emergency operations in existing facilities,
constructing new or modified facilities, and commissioning and placing any facilities back into service.
As further described herein, Freeport has completed repairs to the Export Facility on Quintana Island,
Texas, performed safety reviews, revised various procedures, implemented new safety systems and
performed necessary training in order to safely begin to resume initial operations at its Export Facility.
As such, Freeport respectfully requests authorization from FERC to commence cool down of its Loop 1
transfer piping and reinstate the facility’s boil off gas (BOG) management compressors and associated
piping.

Cool down of the Loop 1 LNG transfer piping includes the slow and deliberate introduction of LNG into
the piping system to allow the piping to cool down to cryogenic temperatures necessary for circulation of
LNG within the Loop 1 piping system and to transfer LNG to Dock 1 of the Export Facility. An
overview of the piping associated with the Loop 1 cool down and reinstatement of BOG management is
attached hereto. (Please note that this attached drawing is being filed Privileged and Confidential.) The
cool down will be done slowly and methodically over a period of approximately 11 days to ensure that the
temperature rate change does not exceed thermal shock tolerances. During this time, Freeport will closely
monitor the cool down progress, including temperature changes, pipe movement, pipe support
performance, flange integrity, etc. Daily reports will be developed and filed with FERC (as Privileged
and Confidential) to provide continuous updates on the progress of the cool down. As a result of the
cooldown of Loop 1, boil off gas (BOG) production within the facility will increase as the movement of
cold vapor and subsequently, LNG increases. As opposed to directing this increased BOG production to
the facility flare, the BOG can be routed to the facility BOG management compressors and transported
via pipeline to the upstream Pretreatment Facility for use as fuel gas.

As FERC is aware, Freeport has performed repairs to the Export Facility in accordance with the approved
damage assessments and remedial work plans filed with FERC. Freeport has also implemented numerous
improvements at the Export Facility in the wake of the June 8th incident and the findings and
recommendations of IFO Group in their Loss of Primary Containment Incident Investigation Report. For
example, Freeport has developed and implemented a new pressure safety valve (PSV) testing standard
and new car seal procedure and audit program and provided training on both, as applicable, to Freeport
employees and third-party service technicians. As part of the PSV testing standard, all PSVs at the

Freeport LNG Development, L.P.

333 Clay Street, Suite 5050 • Houston, Texas 77002-4173
Phone: 713-980-2888•Fax: 713-980-2903
Export Facility have been functional tested and their car seal alignment verified. Freeport has also
revised its operating procedures to avoid the potential for isolation of LNG in piping during normal
operations. As a safeguard to any inadvertent block-in of LNG (or block-in due to activation of
emergency systems), Freeport has developed control system logic changes that will alarm and alert
Freeport operators to blocked-in LNG conditions so that such conditions can be promptly resolved.

Additionally, to prepare for its return to operations, Freeport has conducted refresher training with board
operators, as well as held training on recognizing and reacting to abnormal operating conditions so that
conditions similar to those observed leading up to the June 8th incident can be timely identified and
properly assessed. Freeport has also recently conducted a briefing with local first responders on the June
8th incident with lessons learned and discussed the return to service plan for the Export Facility. To
further ensure a safe return to operations, a Hazard and Operability Study (HAZOP) has been conducted
for portions of the Export Facility and recommendations identified and implemented, and a thorough Pre-
Startup Safety Review (PSSR) has been performed for the LNG transfer unit with action items identified
and addressed to confirm the safety and integrity of the unit.

Having completed the foregoing, Freeport hereby respectfully requests authorization to cool down the
Loop 1 LNG transfer piping and reinstate BOG management as its initial step to resuming normal
operations at the Export Facility. We note that any authorization pursuant to this request will be limited
to the cool down of this piping and reenergization of the BOG management system, and subsequent
approvals will be necessary to commence Loop 1 LNG circulation and ship loading to Dock 1, as well as
begin to return the liquefaction trains to operation. Given the close coordination that Freeport, PHMSA
and FERC have maintained over the last seven months as Freeport has repaired the Export Facility and
implemented the improvements and changes summarized above, Freeport would greatly appreciate
FERC’s response to this request by January 24, 2023.

Respectfully,

Mark W. Mallett
Mark W. Mallett, P.E.
Chief Operating Officer
Freeport LNG Development, L.P.

Enclosure (1) – PFD of Loop 1 LNG Transfer Piping (CUI-PRIV)

cc: via email

Bryan Lethcoe
Director, PHMSA Southwest Region
Bryan.Lethcoe@dot.gov

Andrew Kohout
Director, Division of LNG Facility Reviews & Inspections
Andrew.Kohout@ferc.gov

Freeport LNG Development, L.P.

333 Clay Street, Suite 5050 • Houston, Texas 77002-4173
Phone: 713-980-2888•Fax: 713-980-2903