DRAFT FOR PUBLIC CONSULTATION INTERCONNECTION AGREEMENT v.2.0 FOR IP KULATA/SIDIROKASTRO DEFINITIONS, BUSINESS RULES, EXCEPTIONAL EVENT

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1 RAFT FOR PUBLIC CONSULTATION INTERCONNECTION AGREEMENT v.2.0 FOR IP KULATA/SIIROKASTRO EFINITIONS, BUSINESS RULES, EXCEPTIONAL EVENT ARTICLE 1: EFINITIONS All terms of the INTERCONNECTION AGREEMENT shall have the meanng assgned to them as follows, whle the rest of the terms used shall have the meanng defned n the Regulaton (EC) 715/2009, Regulaton (EU) 2015/703 and the rectve 2009/73/EC: Border Meterng Staton (BMS) Sdrokastron: shall mean the border meterng staton, owned and operated by ESFA. Confrmed uantty shall mean the quantty of Natural Gas confrmed to be scheduled to flow on a ay at the IP, takng nto account the nomnated quanttes for that ay at both sdes of the IP and the matchng process used for comparng and algnng the Natural Gas quantty requested by the Network Users to be transported at the IP. ay shall mean a perod from 7:00 a.m. local tme of any calendar day to 7:00 a.m. local tme of the next calendar day. aly Balance Poston (BP) shall mean a quantty calculated on a daly bass, for each ay of the perod of mplementaton of the Operatonal Balancng Account (OBA) allocaton procedure. The calculaton of BP for a specfc ay s performed untl 11:00 of the ay +1, accordng to the followng formula: Where: BP = TA M M s the measured quantty, expressed n kwh (reference combuston temperature 25 o C) of the physcal flow through the IP towards the Forward Flow recton (assumng that n case of physcal flow towards the Reverse Flow recton the measured quantty s expressed as a negatve value) durng the ay ; TA s the Total aly Allocated uantty durng the ay ; Exceptonal event shall mean any unplanned event that s not reasonably controllable or preventable and that may cause, for a lmted perod, capacty reductons, affectng thereby the quantty or qualty of Natural Gas at the IP, wth possble consequences on nteractons between ESFA and BULGARTRANSGAZ as well as between ESFA and/or BULGARTRANSGAZ and Network Users. Forecast GCV shall mean the flow weghted average Gross Calorfc Value, calculated n the BMS Sdrokastron by makng use of ISO 6976, on the ay -1, mmedately precedng the ay on whch the matchng process for the ay concerned (+1) takes place. The Forecast GCV s expressed n kwh/m 3 (n) (reference combuston temperature 25 o C). Gross Calorfc Value shall mean the quantty of heat produced by the full stochometrc combuston wth ar of one (1) Normal Cubc Meter of Natural Gas under stable absolute pressure of bara when the ntal temperature of the fuel mx and the fnal temperature of the combuston products s consdered to be twenty fve (25) degrees Celsus and the water produced durng combuston s found condensed n the lqud state.

2 Identfcaton Code (IC) shall mean the EIC or a unque dentfcaton code assgned by an Operator to a regstered Network User to be used for dentfcaton n the procedures and systems admnstered by the Operator. Interconnecton Pont Kulata (BG) / Sdrokastron (GR) (IP) shall mean the physcal nterconnecton between the Natural Gas Transmsson System operated by BULGARTRANSGAZ and the Natural Gas Transmsson System operated by ESFA at the Bulgaran Greek border n the area of Kulata (BG) and Promachonas (GR). The quantty and qualty measurements of the Natural Gas delvered at the IP shall be executed (performed) at the BMS Sdrokastron. Forward Flow recton shall mean the statstcally prevalng Natural Gas flow drecton, namely Natural Gas flow drecton from Bulgara to Greece. Lmtaton range (LR) shall mean the allowed range of values of the Total Balance Poston (TBP). Month shall mean a perod from 7:00 a.m. local tme on the frst day of each calendar month to 7:00 a.m. local tme on the frst day of the next calendar month. Network User shall mean a natural or legal entty that holds transportaton capacty at the IP, on the bass of a transportaton contract concluded ether wth ESFA and/or BULGARTRANSGAZ. Each Network User s assgned a unque Identfcaton Code (IC) by the respectve Operator. NGTS shall mean ether the Greek or the Bulgaran Natural Gas Transmsson System. Normal Cubc Meter (m 3 (n)) shall mean one cubc meter of Natural Gas at normal condtons of K (= 0 C) and 101,325 kpa (= bara). Operatonal Balancng Account (OBA) s a ont account where the aly Balance Poston of both TSOs at the IP s recorded. ESFA s the TSO responsble for calculatng, on a daly bass, the aly Balance Poston and the Total Balance Poston and update the Operatonal Balancng Account accordngly. Par of Network Users shall mean the mutually served, n lne wth correspondng transportaton contracts, Network Users at both sdes of the IP. Party shall mean one of the contractual PARTIES: ESFA or BULGARTRANSGAZ. Re-nomnaton Lead Tme shall mean the tme perod between the start of a re-nomnaton cycle and the start of the hour at whch change n gas flow, as a result of the re-nomnatons taken nto account n that re-nomnaton cycle, takes effect. Representatve shall mean a person authorzed to act on behalf of ESFA, BULGARTRANSGAZ or a Network User. Reverse Flow recton shall mean the Natural Gas flow drecton opposte to the Forward Flow recton ether n pure physcal or n vrtual way. Thrd Party shall mean any entty that sells or buys Natural Gas at the IP or any Network User at the IP. Total Balance Poston (TBP) shall mean the actual accumulaton of BP over a consecutve number of ays. The calculaton of TBP for each ay of the perod of mplementaton of the OBA allocaton procedure, s performed untl 11:00 of the ay +1, as follows: 1. For the frst ay of mplementaton of the OBA allocaton procedure, the TBP s set equal to the BP calculated for ths ay. 2. For each subsequent ay and up to (and ncludng) the last ay of the perod of mplementaton of the OBA allocaton procedure, the TBP for the ay shall be

3 calculated as the algebrac sum of the TBP of ay -1 and the BP for the ay concerned. Negatve TBP ndcates that ESFA s ndebted towards the zero balance poston, wth a quantty equals to the absolute value of TBP. Postve TBP ndcates that Bulgartransgaz EA s ndebted towards the zero balance poston, wth a quantty equals to the value of TBP. Total aly Allocated uantty (TA ) shall mean a quantty defned as: TA = Al,F, Al,R, Where: Al,F, s the allocated quantty, expressed n kwh (reference combuston temperature 25 o C) for a gven par of NUs n Forward Flow recton, durng the ay ; Al,R, s the allocated quantty, expressed n kwh (reference combuston temperature 25 o C) for a gven par of NUs n Reverse Flow recton, durng the ay ;, s the par of NUs actve n the Forward Flow recton durng the ay, s the par of NUs actve n the Reverse Flow recton durng the ay ARTICLE 4: BUSINESS RULES 4.1. Capacty The Capacty s expressed n kwh/ay Calculaton of nomnated / confrmed Natural Gas quantty The nomnated / confrmed Natural Gas quanttes are expressed n kwh (reference combuston temperature 25oC) Matchng process Bulgartransgaz shall be the Intatng Transmsson System Operator (ITSO) ESFA shall be the Matchng Transmsson System Operator (MTSO) The Network Users actve at ether (or both) sde(s) of the IP are enttled to submt to the respectve TSO(s): (a) nomnatons untl local tme of the ay (-1), mmedately precedng the ay concerned (), and (b) re-nomnatons, between 17:00 local tme of the ay (-1) mmedately precedng the ay concerned (), and 04:00 local tme of the ay concerned (). A re-nomnaton cycle starts at the start of every hour, between 18:00 local tme of day -1 and 04:00 local tme of day. urng each re-nomnaton cycle, the notfcaton and matchng procedure accordng to paragraphs 4.3.4, and shall apply.

4 4.3.4 ITSO and MTSO shall calculate, ndependently of each other, the capacty whch could be nterrupted per each Network User and Natural Gas Flow drecton, by mplementng the procedure of paragraphs through below: Not later than 15 mnutes upon the nomnaton deadlne or the start of each renomnaton cycle, the Partes shall exchange nformaton on the quantty nomnated to flow through the IP, durng the ay, per each Par of Network Users and Natural Gas flow drecton, through a ELOR message, accordng to Edg@s XML format Based on the above nformaton, each Party shall calculate the prelmnary Processed uanttes per each Network User and Natural Gas flow drecton, by applyng the lesser rule on the Natural Gas quanttes nomnated (per each Par of Network Users and Natural Gas flow drecton) at ether sde of the IP. In case a Network User s part of more than one Par of Network Users, ts prelmnary Processed uantty, per each Natural Gas flow drecton, s calculated as the sum of the results of the applcaton of the "lesser rule" on the Natural Gas quanttes nomnated by the sad Network User and ts counterparty, actve at the other sde of the IP, at the specfc Natural Gas flow drecton Based on the results of paragraph above, each Party shall calculate the expected physcal Natural Gas flow through the IP (magntude, drecton) as the dfference of the prelmnary Processed uanttes of the Network Users, actve at ther sde of the IP, durng the ay, n Forward and Reverse Flow recton Each Party shall specfy the total capacty whch could be nterrupted durng the ay, by subtractng the techncal capacty of the IP (at Party s sde) at the expected physcal Natural Gas flow drecton, from the expected physcal Natural Gas flow (as t was calculated n paragraph above). In case the result s negatve or zero, no nterrupton s requred and the Processed uanttes wll be equal to the prelmnary ones. In any other case the next steps shall apply:. Each Party calculates the capacty whch could be nterrupted for each Network User, as the prelmnarly Processed uantty of the correspondng Network User mnus the frm capacty booked by the sad Network User, at the drecton of the expected physcal Natural Gas flow... In case of negatve or zero result, the capacty whch could be nterrupted for ths Network User equals to zero; otherwse the correspondng Party allocates the part of Network User s prelmnary Processed uantty, whch s n excess to the capacty booked by the sad Network User on a frm bass, to ts nterruptble capacty bookngs, startng from the one assgned the oldest tmestamp and movng to the most recent one. The Party shall calculate the capacty whch could be nterrupted per each Network User, as the sum of the Natural Gas uanttes assgned to each tmestamp, startng from the most recent one, and applyng the rule of art. 24 para 2 of EC Reg. 2013/984 (CAM NC),.e. decrease proportonally to the prelmnary Processed uanttes, whch are n excess of Network User's booked capacty on a frm bass, untl the sum of the Network Users capacty whch could be nterrupted s equal to the value of total capacty whch could be nterrupted Each Party calculates the Processed uantty per each Network User by reducng the prelmnary Processed uantty by the capacty whch could be nterrupted. In case one Network User s part of more than one Par of Network Users, each Party allocates the capacty whch could be nterrupted per each Par of Network Users the sad Network User s part of, pro rata to the prelmnary Processed uanttes, calculated as per paragraph

5 4.3.5 Not later than local tme of the ay (-1), mmedately precedng the ay concerned (), the ITSO shall send to the MTSO a ELOR message accordng to Edg@s- XML format regardng the Processed quanttes, per each Par of Network Users for the ay at the IP. The Processed quanttes are consdered to be equally dstrbuted to each hour of the ay Not later than 45 mnutes from the start of each re-nomnaton cycle, the ITSO shall send to the MTSO a ELOR message accordng to Edg@s-XML format regardng the Processed quanttes, per each Par of Network Users for the ay at the IP Per each Par of Network Users, the MTSO shall compare the Processed uantty that has been scheduled for delvery/offtake, at each sde of the IP and wthn 45 mnutes after the recept of the message under paragraph or 4.3.6, a ELRES message shall be sent to the ITSO accordng to the Edg@s-XML format. In case of dfferent Processed uanttes at ether sde of the IP, the lesser rule wll be appled (a) In case the ITSO has not sent to the MTSO, untl the expraton of the deadlne specfed n paragraph above, the Processed quanttes for a ay, these wll be consdered, by the MTSO, equal to zero (0), for the mplementaton of the matchng process. (b) In case the ITSO has not sent to the MTSO, untl the expraton of the deadlne specfed n paragraph above, the Processed quanttes for a ay, the MTSO shall consder, for the mplementaton of the matchng process, the last Processed quanttes of the ay, whch were sent by the ITSO to the MTSO (a) In case the MTSO has not sent the Confrmed quanttes for a ay to the ITSO, untl the expraton of the deadlne specfed n paragraph n relaton to paragraph above, the Confrmed quanttes shall be consdered equal to zero (0). (b) In case the MTSO has not sent the Confrmed quanttes for a ay to the ITSO, untl the expraton of the deadlne specfed n paragraph n relaton to paragraph above, the last Confrmed quanttes, shall be consdered as Confrmed quanttes for ths re-nomnaton cycle The matchng processes under paragraph 4.3.4, 4.3.5, and 4.3.7, shall be carred out usng Edg@s-XML data format and AS4 protocol. In case the above communcaton method s not avalable (.e. due to techncal problems) the data exchange shall take place va emal by usng the forms of Annex The Re-nomnaton Lead Tme s two (2) hours Network Users update The Partes shall exchange the lsts of ther Network Users IC, as soon as possble, and n any case not later than two (2) workng days before the ay a new Network User could start Natural Gas transmsson at the IP Rules for the allocaton of the transmtted gas quanttes In respect of the allocaton of gas quanttes, ESFA and BULGARTRANSGAZ establsh allocaton procedure ensurng consstency between the allocated quanttes at both sdes of the IP. Ths allocaton procedure shall be based on the Operaton Balancng Account (OBA), specfed below.

6 Under the OBA allocaton procedure the Natural Gas quantty allocated for a ay to a par of Network Users at the IP shall be equal to the Natural Gas quantty confrmed for delvery/off-take, for that ay, to the sad par of Network Users, accordng to artcle 4.3. where: Al,F, Al,R, = C,F, = C,R, and, C,F, s the confrmed quantty, for a gven Par of Network Users n the Forward Flow recton, durng the ay ; C,R, s the confrmed quantty, for a gven Par of Network Users n the Reverse Flow recton, durng the ay ; Al,F, s the quantty allocated, to a gven par of Network Users n the Forward Flow recton, durng the ay ; Al,R, s the quantty allocated, to a gven par of Network Users n the Reverse Flow recton, durng the ay ;, s the par of Network Users actve n the Forward Flow recton durng the ay ; and, s the Par of Network Users actve n the Reverse Flow recton durng the ay ; The OBA allocaton procedure shall not be appled n the event that: The condtons of paragraph () and / or () are met; The gas qualty parameters are not n accordance wth Art. 5.7 of the Agreement and the Partes are not able to perform ther daly confrmatons; The pressure s not accordng to the specfcatons n Art. 5.7 of the Agreement and the Partes are not able to perform ther daly confrmatons For each ay, when any of the condtons n paragraph s n effect, the daly measured quantty, ncreased by the Natural Gas quantty confrmed n the opposte to the gas flow drecton, s allocated to the pars of NUs proportonally to ther confrmed Natural Gas quanttes, n the gas flow drecton through the IP. The quanttes allocated to the pars of NUs n the opposte to the gas flow drecton s equal to the respectve confrmed quanttes. The OBA allocaton procedure shall be re-appled on the next ay +1 after the ay n whch all of the condtons n paragraph are no longer n effect, unless both Partes mutually agree to postpone the applcaton of the OBA for a specfc perod. Pro-rata allocated quanttes n Forward drecton shall be calculated by usng the followng formulas: Where: Subscrpts: Al, F, C, F, * Al, R, C, R, M, F nf nr 1 Al, R, 1 C, F,

7 Al : Allocated uantty C : Confrmed uantty M : Measured nf : Number of par of NUs n the recton (F) gas flow drecton nr : Number of par of NUs n the recton (R) opposte to drecton (F) The same formula apples n case the measurement occurs n the Flow recton (R). by swtchng the ndces (F) and (R). Each ay for whch the pro-rata allocaton procedure apples, the OBA s updated by calculatng the TBP, consderng BP that equals to zero (0) The ndcatve allocaton of Natural Gas quanttes shall be carred out va an ALOCAT message accordng to the Edg@s-XML format for each Par of Network Users, on a daly bass, untl a.m. local tme for the prevous ay. The excel document-based data exchange method shall be used temporarly by the Partes as a back-up soluton n case of falure of the above mentoned data exchange method The fnal allocaton of Natural Gas quanttes for each ay of the Month M, and for each Par of Network Users, based on valdated measurements, shall be carred out untl 15:00 of the thrd calendar day of the Month mmedately succeedng the Month M.The Monthly quantty allocaton protocol shall be ssued by ESFA and sgned by BULGARTRANSGAZ and shall be n accordance wth the prelmnarly approved forms as n Annex 2C. The Natural Gas quanttes, expressed n volume unts (0 and 20 C), are regstered n the allocaton protocol for reference purposes only. The quantty allocaton protocol shall be accompaned wth the respectve measurement protocols for gas quantty and qualty, where Natural Gas quanttes are also expressed n volume unts (0 and 20 C), for reference purposes only The data n the quantty allocaton protocol shall be used by ESFA and BULGARTRANSGAZ to prepare and sgn quantty allocaton protocols per each NUP actve at the IP Operatonal Balancng Account The Partes undertake to put effort so as to mantan TBP as close as possble to zero, n order to ensure that the LR specfed n paragraph s not volated The LR s specfed by ts lower lmt value (LR low), whch s set to -8,500,000 kwh and ts upper lmt value (LR up) whch s set to 8,500,000 kwh. The lower and / or upper value of the LR may be changed upon mutual agreement of ESFA and BULGARTRANSGAZ, n case of ustfed operatonal needs, ncludng but not lmted to: (a) (b) (c) (d) Exceptonal events Unplanned mantenance works Scheduled flow below the BMS Sdrokastron mnmum measurement and / or flow control lmts. Increase or decrease of the IP s techncal capacty.

8 Upon wrtten request ssued by one of the Partes, the Partes may agree to expand the lmts of the LR, pror to the executon of the ndcatve and / or the fnal allocaton of the Natural Gas quanttes for a ay or for a certan number of ays In order to carry out the ndcatve allocaton of the Natural Gas quanttes to each Par of Network Users, for a ay, the Partes shall check whether the LR, applcable for that ay, s volated. () If for the ay or TBP 1 + C,F, TBP 1 + C,F, C,R, C,R, M > LR up M < LR low the Partes shall carry out the ndcatve allocaton of Natural Gas quanttes n accordance wth the provsons of paragraph () If for the ay LR low TBP 1 + C,F, C,R, M LR up the Partes shall carry out the ndcatve allocaton of Natural Gas quanttes n accordance wth the provsons of paragraph In order to carry out the fnal allocaton of the Natural Gas quanttes to each Par of Network Users, for each ay of the Month M, the Partes shall check, based on valdated measurements, whether the LR, applcable for that ay, s volated. () If for the ay or TBP 1 + C,F, TBP 1 + C,F, C,R, C,R, M > LR up M < LR low the Partes shall carry out the fnal allocaton of Natural Gas quanttes n accordance wth the provsons of paragraph () If for the ay LR low TBP 1 + C,F, C,R, M LR up the Partes shall carry out the fnal allocaton of Natural Gas quanttes n accordance wth the provsons of paragraph Pror to the termnaton of the Interconnecton Agreement, the Partes shall endeavour to settle n knd the TBP by adustng the flow through the IP approprately. If the TBP, that wll be calculated at the last ay of mplementaton of the Interconnecton Agreement s dfferent than zero (0), then the Partes shall settle the TBP fnancally, wthn 30 days upon the ay of termnaton of the Interconnecton Agreement, usng as TBP unt prce the arthmetc average of the margnal buy and margnal sell unt prces of balancng gas,

9 wthout adustments (f such adustments are applcable), vald for the natural gas market of the credtor, for the ay of termnaton of the Interconnecton Agreement. In case there are no applcable margnal prces of the balancng gas vald for natural gas market of the credtor, then the applcable daly prce of balancng gas wthout adustments wll be used as a TBP unt prce. The daly prce of the balancng gas wll be publshed on the nternet ste of the credtor. The balancng gas unt prce, publshed and calculated by the credtor shall be n accordance wth the methodology approved by the competent Natonal Regulatory Authorty ESFA shall ssue and forward to BULGARTRANSGAZ the monthly OBA protocol untl 15:00 of the thrd calendar day of the Month mmedately succeedng the Month M The ΟΒΑ Protocol shall be n accordance wth the standard form of Annex 9 of the Interconnecton Agreement ESFA shall send daly to BULGARTRANSGAZ an Account Stuaton ocument (ACCSIT) notfcaton contanng the TBP, n accordance wth the Edg@s-XML format, not later than 11:00 local tme on the ay +1. The excel document-based data exchange method shall be used temporarly by the Partes as a back-up soluton n case of falure of the above mentoned data exchange method Exceptonal Event Should an Exceptonal event occur n the ESFA s or BULGARTRNSGAZ s Natural Gas Transmsson System whch nfluences or may nfluence the Natural Gas flow through the IP, the Party whose system s affected shall nform the other Party wthn thrty (30) mnutes and take the necessary actons to mnmze possble nfluence of such event on ts Natural Gas Transmsson System Wthn one (1) day from an Exceptonal event occurrence, the affected Party shall prepare a report ncludng as a mnmum the followng: a) escrpton of the Exceptonal event and the causes of ts occurrence; b) Hour of occurrence of the Exceptonal event and the estmated tme of ts elmnaton; c) Avalable IP capacty untl the Exceptonal event s elmnaton; and d) Operatons necessary for the restoraton of the IP capacty; The affected Party n whose system the Exceptonal event occurred shall nform the other Party of the progress of the remedal actons. Mutual remedal actons wll be agreed upon and appled, f needed Upon completon of the Exceptonal event repar works, the affected Party shall nform the other Party of the restoraton of the IP capacty.