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Crimson Gulf, LLC a division of Crimson Midstream. I I.C

April 15, 2019

Bureau of Safety and Environmental Erforcement Ms. Angie Gobert - Pipeline Unit Secticn Chief 1202 Elmwood Parkway Boulevard New Orleans, LA. 70123

BMOU oi Sofety ond Eimrormentol Enioramenl (BSEE)

R E C E I V E D APR 1 6 2019

Office of Field Operations Pipeline Section

Re. Amended Repair Not i f icat ion and Appl icat ion to Modi fy Existing 8" Oil Right-of-Way Pipeline Segment 806 (ROW OCS-G 1462A) Originating at VR 265 A Platform and Terminating at SM 69 B Platform, Offshore, Louisiana, Offshore Waters, Gulf of Mexico

Dear Ms. Gobert:

Refence is made to Crimson Gulf, LLC's (Crimson) April 2, 2019, application to repair and modify the subject pipeline and subsequent emails; and telephone communication with Angie Gobert and Dave Trocquet, Jr. requesting that Crimsor amend said application. The pipeline MAOP has been decreased to i252 psi per BSEE's request. Additionally, the PSH2 on pipeline Segment 806 has been set to a pressure not to exceed 15% above the normal operating range and the PSV has been set at no higher than the 1252 psi MAOP per BSEE's request.

Crimson hereby submits the aforementiDned amended application in triplicate (3 copies plus 1 CD) to repair the riser for Pipeline Segment 806 by replacing approximately 80 feet of the riser. In accordance with 30 CFR 250.1003(b)(1), Crimson respectfully requests a departure from hydrotesting the pipeline. Crimson proposes to conduct a 1-hour stand up test and the system will be returned to service with 2140 psi. All prefabricated piping and fittings will be hydrotested to 2675 psi prior to mobilization.

In support of this request, the following are enclosed:

1. Pay.gov receipt in the amount of $4169 to modify the pipeline (reduce MAOP) 2. Pay.gov receipt in the amount of $388 to repair the pipeline (install composite wrap) 3. Proposed procedure 4. General information and calculations 5. Pipeline riser schematic 6. Riser NDE results

Crimson respectfully requests your expeditious review and approval as we would like to commence the work on or about April 29, 2019. Should you have questions or require additional information, please contact Suzy Younger at SLizv(a)suzvvounqer.req or 713-208-5588 or Eric Lyons at elvons(a)crimsonpl.com or 985-855-1187.

Repair procedures are hereby accepted. Sincerely, Departure is hereby approved pursuant lo 30 CFR

Donald R. Smith Director of Gulf Operations Crimson Gulf. LLC

250.141.

Date: \Xf\&f\<\

263 Trinity Lane Gray, I A 7035$

Visit our w^b site at www.C'i im.su11Midstream.com

Bryan A. Domangue Acting Regional Supervisor Bureau of Safety and Environmental Hnforcement

^ I f tvf off ice ackt^eJtjc-s -Hvs> V^piop ^

A Crimson ^ Cult.LLC

i n( (rim nan MMxlmMn, i H'

SOUTH MARSH ISLAM) CATHKRING SYSTKM (SMIGS) SEG# 806 V R-265 (OCS#GOI955) A K ) SM-69 B (OCS#G01201)

PIPELINE REPAIR PROCEDURE

Pipeline Description:

Segmenl Ut Service:

Diameter:

Lengtll ol 8" Scu-806:

MOP:

Se8-806 Origin:

Seg-806 I crmination:

Configuration:

Current Riser Nominal Wall Thickness:

Current Riser Pipe Grade:

806 Oil

8M

130.000 ft

2,140 psi

VR-265 A (OCS#G01955)

SM-69 B(OCS#G01201)

Riser x Riser

0.593"

Gr. B

Permit Requested: Crimson (iulf, LLC (Crimson) requests approval to repair the existing Scg-806 departing riser located at l icklwood f nergy LLC's VR-265 "A" platform. All pressure sources shall be isolated, oil in the riser will be displaced with water, and approximately SO feet of the existing riser piping will be replaced in full locaied above the water line. Once the new riser piping is installed, a standup test will be conducted, and the riser vvill be returned io serv ice at original MOP.

Background: Crimson recently performed a rope-access NDL inspection of its departing oil riser from VR-265 A, segments 806. At the conclusion of this inspection, one particular area of eoncem, just downstream ofthe pig launcher, was evaluated and found to be rated for 1.252 psi rather than the current MOP of 2.140 psi. The pipeline has subsequently been de-rated to 1,252 psi until a permanent repair can be completed.

Work Plan Summary: All piping and fittings shall be hydrotested prior to mobili/ation. Mobilize crews to location, shut-in all producers, and displace oil in riser with a pig. Once the oil is displaced, the pipeline will be isolated and approximately SO feet ofthe current riser will be removed and replaced with new riser piping. X-ray crew shall test 100" o of all field welds. A standup test w ill then be perfomied. and the system w ill be retumed to service al an MOP of 2.140 psi.

Pipeline Riser Repair Procedure for 8" Seg-806

4. 5. 6.

7.

De-rate the pipeline to 1,252 psi. Notify BSEE at least 24 hours prior lo mobili/ation. All prefabricated piping and fittings shall be hydrotested to 2.675 psi for 4-hours prior to mobilization. Mobe pumping and construction crew via utility boat to the VR-265 " A " facility. General procedure: .ISA and safety meetings shall be conducted at even. 12-hour shift change. Shut-in producers on the SMIGS pipeline and perform LOTO procedures as necessary to achieve isolation at the work area. Pumping crew load pig into launcher for Seg-806 and pump approximately 15 bbls of water lo displace oil 200 feel past the end ofthe work area.

Page l .>! 2

C V i T T I S O n SOUTH MARSH ISLAND OATHKRING SYSTKM (SMIGS) ' C P U T T P S E G # 8 0 6 V R " 2 6 5 (OCS#G01955) A TO SM-69 B (OCS#G01201)

PIPELINE REPAIR PROCEDURE .liusmnoK rifflmn \Iut-lrr.>ri. I.I.C

8. Once oil is displaced pumping crew will bleed related piping and perform LOTO at VR-265A and SM-69B as required.

9. Construction crew shall provide adequate rigging and lifting aids to adequately support the removal and replacement ofthe riser.

10. Construction crew shall setup containment around work area and cutting/disconnection points. 1 1. Cutting boxes shall be used to con ain all pipeline lluids. 12. Verify pressure has been removed from the work area prior to cutting or disconnecting existing

riser. 13. The construction crew shall cut the riser into safe and manageable sections until removal is

complete. 14. New piping shall be lifted via the platform crane and carted or carried to the work area as required. 15. The construction crew shall use rigging and lifting aids to lift ncw pipe sections into place. 16. All flanges shall bc torqued in accordance with Crimson Torque Specifications. 17. All field welds shall be performed according to Crimson Weld Procedures. 18. X-ray crew shall test 100% of all field welds. 19. Once the riser replacement is completed, a 1-hour standup test with water will bc perfonned at a

pressure of 2.140 psi. 20. Thc pipeline shall then be painted in accordance with Crimson Paint Specifications. A three-coat

paint system shall be used. 21. LOTO measures shall be removed and valves shall be returned to their normal operating condition. 22. Production shall then be permitted to resume at a pressure of 1,252 psi. 23. Notification to BSEE that repair is complete. 24. Return pipeline to MOP of 2,140 psi, upon approval by BSHE. 25. Submit completion records to BSEE.

Rc\ 114 10 2019, Rev()3 Page 2 of 2

C V l TTI S O n SOUTH MARSH ISLAND GATHLRING SYSTEM (SMIGS) Cy r ] n \ r S E G * 8 0 6 VR_265(OCS#G()i955) \ roSM-69 B(OCS#GOI201)

PIPELINE REPAIR PROCEDURE •luM.in.ii«riDMrni Uidmnum l ie

General Information and Calculations:

1. The proposed riser repair will replace a portion ofthe current departing riser on Crimson's South Marsh Island Gathering System (SMIGS) X" Seg-XOft, locatcd on Fieldwood's VR-265 "A" platform.

2. Maximum source pressure to the pipeline will be limited to 2,140 psi by the facility's safety system.

3. All piping and fittings will be shop hydrotested prior to mobili/ation. These components will be hydrotest at 2,675 psig for 4 hours.

4. Connection to the existing 8.625" Riser Piping Segment #806: Hanged connections will be used to connect the new riser to the existing flange of Seg-806, above thc water line.

5. The description ofthe pipe and coatings arc as follows: a. Topside New Riser Pipe: 8.625" O.D. x .593" W.T. API-5L X42. Field welds

shall be cleaned and prepared for coating, pipe shall be coated with 3 coat offshore paint system, I2-I5_mils.

6. Intemal Coating: Intemal Coating is not required. The analysis of transported products shall he monitored, and preventative measures will be employed as necessary.

7. The proposed new riser piping is approximately 80 feet in length. The pipeline will transport oil. The pipeline design working pressure is 2,140 psig.

8. The pipeline shall be de-rated to 1,252 psig until a permanent repair is completed. Once the permanent repair is completed the pipeline w ill be retumed to serv ice at the original MOP of 2,140 psig.

Re% 04 io 2019, Rev03 Pane I of 6

/ r i \ C V l TTI S O n SOUTH MARSH ISLAND GATHERING SYSTEM (SMIGS) ' C ' Gl i l f LLC S E C ' # 8 0 6 V R " 2 6 5 ( O C 8 ^ 0 1 9 5 5 ) A T O SM-69 B (OCS#G01201)

iliv si.nioK -mwni Midstrram, l.l.c PIPELINE REPAIR PROCEDURE

General Information and Calcuiations:

1. RISER PIPING SUMMARY

a. New Riser Pipc Specifications:

O.D W.T Material Spec. Length

8.625" 0.593" API 5L X42 Seamless -80 Ft.

2. Name of Product: Crude Oil

Original MOP

2140 psig

3. Safe Operating Pressure Calculations

In determining a safe operating pressure, we used the Modified B31G Level 1 calculation for the measured anomaly located on the riser. We found the deepest metal loss to be 0.465". General metal loss was found around the anomaly and measured an overall length of 13.00". The existing pipe material is 8" 0.593 W.T. API 5L Grade B. The calculated safe operating pressure is 1252 psig.

Modified B31G Calculations:

z — Dt

Where, L = length of metal loss, in D = specified outside diameter of the pipe, in t = pipe wall thickness, in

For z < 50

M = (1 + 0.6275z - 0.00337Sz2)^2

Where, M = bulging stress magnification factor, unitless z = calculation above, unitless

Where, 5 ^ = l . l x SMYS

Snow = flow stress, psi SMYS = specified minimum yield strength, psi

Kev: 04/10/2019, Rev03 Page 2 of 6

Crimson ^ CkilfJ.LC

• i i i t M n n I I I ( ' I I I I I I I I M u l U r i M i n I . U "

SOUTH MARSH ISLAM) (JA I HLRING SYS I LM (SMIGS) SKG# 806 V R-265 (OCS#G01955) A IO SM-69 B (()( S#(;0120I)

PIPELINE REPAIR PROCEDURE

General Information and Calculations:

Sr = S flow

-0.85(1)

1 -0,85 ( f )

Where, M

SH = estimated failure siress level, psi Sfim = flow stress, psi d = depth of the metal loss, in t = pipe wall thickness, in M = bulging stress magnification faclor, unitless

PJ)

Where, SF It

SH = Hoop stress al operating pressure, psi Po = operating pressure, psi D = diameter, in t = wall thickness, in SF = Safety Factor (1.67), unitless

Rev 04 Iii Z"!1*. Rcv03 Page Jof<

a Crimson Gulf, LLC

•l i \ 'M.>nni( -iniMin M M I . I I l l

SOUTH MARSH ISLAND GATHERING SYSTEM (SMIGS) SKi.U 806 VR-265 (OCS#G01955) A TO SM-69 B (OC S#GOI20I)

PIPELINE REPAIR PROCEDURE

(icneral Information and Calculations:

Begin by calculating the z value

13.00' z = 8.625x0.593

z = 33.04

Calculate bulging stress magnification factor

M = (1 + C.6275(33.04) - 0.003375(33.04)2)1/2

M = 4.27

Calculate flow stress

Sriow = \ Ax (35.000)

Sfiow - 38,500 psi

Calculate the estimated failure stress

SF=S flow

-aas (I)

1 M

5 F = 38,500 . - 0 . 8 5 ( M | | )

i Q-85 (ulll) 4.27

SF = 15,213 psi

Kc\ I M lo 2019, RevOJ PafC 4 ot 6

© C V i TTI S O T ! SOUTH M ARSH ISLAND GATHERING SVSTEM (SMIGS)

P t f t i p 806 VR-265 (OCS#G019S5) A TO SVl-69 H (OCS#G01201) PIPELINE REPAIR PROCEDURE

• IIIVMIIII-H < rtnimn Mimtmun, HA'-

(•eneral information and Calculations:

Calculate safe intemal pressure 15,213 (^)(8.625)

1.67 2(0.593)

P0 = USI psi

4. Pipe Wall Thickness Calculations

The design ofthe proposed pipeline is in accordance with API RP 14C, API RP 14E, ASMK B3L4, 49 CFR Chapter 1 Part 195, 30 CFR Part 250 Subpart J and ANSI B16.5. Each was applied within the scope ofthe intended code or regulation.

tn > t + / I

2(5)(t) P=—5—x{F){E){T)

Where. tn = minimum required nominal wall thickness satisfying requirements for pressure and allowances A= sum of allowances for threading, grooving, corrosion, and erosion P = Intemal design pressure in pounds per square inch (psi) S = Specified mininuim yield strength, in psi D = Nominal oulside diameter of pipe, in inches t = Nominal wall thickness, in inches F = Constmction design factor of 0.60 for the riser component E= Joint Factor T = Temperature derating factor Corrosion allowance = 0.05" Mill Tolerance = 12.5%

For X42 8.625" O.D. pipe less than 250 0F

t = 2(5)(F)(E)(r)

(8.62S)(2,14()) t " 2(42,000)(().6)(1)(1) " 0 ' 3 6 6

Rn (M tO 2019. RcwOJ Page 5 oft

/ s ^ i C V i TTI S O T ! SOUTH MARSH ISLAM) OATHKRING SYSTEM (SMIGS) • C / r If I i p S t : ( ' # 8 0 6 N R - 2 6 5 (OCS#GOI955) A TO SM-69 B (OC$#GOI201)

I J U I I , L L L PIPELINE REPAIR PROC EDURE i.Nv MNi o f l rrn.s.!.! Mi.UTf.-,.in I . U '

General Information and Calculations:

Apply jorrosion allowance (A- 0.05")

tn > t + A > 0.366 + .05 = 0.416"

Apply Mill Tolerance of 12.5%

1 tn > 0.416 x = 0.475"

1 - .125 t n > 0.475"for 8.625" X42 Pipe

Wall thickness calculations sh m- that the selected 0.593 W. T. tor thc S.625 " O.D. pipe is adenuate.

Calculations Prepared by Scott Schcxnayder, PE Chapman Consulting, Inc.

Rc\ (M 10 201'). Rc\03 Pigeiofi

From: To: Subject: Date:

notificatlQnCaipay.qQV Sum Hardy Pay.gov Payment Confirmation: BSEE Pipeline Repair Notification - BX Thursday, March 28, 2019 3:24:45 PM

Q An official email of the United States government

Pay.gov logo

Your payment has been submitted to Pay.gov and the details are below. Ifyou have any questions regarding this payment, please contact Brenda Dickerson at (703) 787-1617 or BseeFinanceAccountsReceivable@bsee.gov.

Application Name: BSEE Pipeline Repair Notification - BX Pay.gov Tracking ID: 26GDS102 Agency Tracking ID: 75713547449 Transaction Type: Sale Transaction Date: 03/28/2019 04:24:40 PM EDT Account Holder Name: Crimson Gulf AP Transaction Amount: $388.00 Card Type: Visa Card Number: — — 8 3 3 7

Region: Gulf of Mexico Contact: Eric Lyons 985-872-3100 Company Name/No : Crimson Gulf, LLC, 03218 Pipeline Segment No: 806 Lease Number(s): Originating Area/Block: Vermilion VR, 255 Terminating Area/Block: South Marsh Island SM, 69

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From: To:

Subject: Oate:

notification(a>pav.Qov Suni Hardv

Pay.gov Payment Confirmation: BSEE Pipeline ROW Modification Application - BY Thursday, March 28, 2019 3:Z9:12 PM

Q An official email of the United States govemment

Pay.gov logo

Your payment has been submitted to Pay.gov and the details are below. Ifyou have any questions regarding this payment, please contact Brenda Dickerson at (703) 787-1617 or BseeFinanceAccountsReceivable(a)bsee.gov.

Application Name: BSEE Pipeline ROW Modification Application - BY Pay.gov Tracking ID: 26GDS1P9 Agency Tracking ID: 75713558778 Transaction Type: Sale Transaction Date: 03/28/2019 04:29:05 PM EDT Account Holder Name: Crimson Gulf AP Transaction Amount: $4,169.00 Card Type: Visa Card Number: ************8337

Region : Gulf of Mexico Contact: Eric Lyons 985-B72-3100 Company Name/No: Crimson Gulf, LLC, 03218 Pipeline Segment No.: 806

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Pay.gov is a program ofthe U.S. Department ofthe Treasury, Bureau ofthe Fiscal Service