Unilcd Stales Department ol the Interior 7

BURI \\ ol SAFI I'Y AND ENVIRONMENTAL ENFORCEMENT GulfofMexico OCS Recoil 1201 Elmwood I'ark Boulevard New Oi lcans. LA 70123-2394

In Repl> Refer fo: ( il 1035A

Mr. Wilton I). ( ox ExxonMobil Production Compan} \\ 1.2,\.555 P.O. Box 4358 Houston, Texas 77210-4358

Dear Mr. Cox:

April 6. 2017

Reference Is made lo ExxonMobil Production Company's (Exxon) enclosed application dated October 17. 2016 requesting for an alternative compliance for Hadrian South Pipelines to utilize internal facilit) inspection plan in lien of pipeline route inspection pursuant to JO CFR 250.1005(a) and I eller to I essee dated April I X. 1991.

The application includes luo RightS-of-wa) No. OCS-G29192 and OCS-029193 associated with Pipeline Segment Nos. (PSN) 18839 and 18840, respectively, fhe Rights-of-wa) were granted to Exxon Mobil Corporation. F.won Mobil ( orporation should have submitted the application separate!} for each of the Right-Of-wa) pipelines. The application erroneous!) came from ExxonMobil Product ion ( ompanv. on behalf of ExxonMobil Oil Corporation.

Application also includes four lease term pipeline Segment Nos. 1884 I . 18842. 1843, and 18844 operated b\ Exxon Mobil ("orporation. Exxon Mobil Corporation should have submitted the application for all of those lour lease term pipelines. The application came from ExxonMobil Production (ompanv. on behalf of ExxonMobil Oil Corporation.

Several attempts were made hv phone and emails to contact your designated POC. Mr. Dean Ericson, hut these calls and emails were not answered

If you are still interested to pursue this request, vim must submit three applications separately, one each for Segment No. 18839 and 18841) and one for PSN 18841 through 18844. All of these applications should come liom F.won Mobil Corporation.

tf you have anv questions, please contact the undersigned al 504-736-2548 or hv email at Himal.shrestha a hsee.gov .

(for)

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Sincere!).

BIMAL SHRESTHA Brv an A. Domangue Acting Regional Supervisor Regional Field Operations

Enclosures: (I) Exxon Mobil oil Corporation Application (2)1 mails to Mr. Dean I ricson

ExxonMobil Production ( ompanv W4.2A.555 P.O. Box 4358 Houston Texas 77210-4358

E^onMobil Production

October 17, 2016

Departure Request ROW Inspection Keathley Canyon Block 964 OCS-G 21451, Hadrian South Project

Sent via UPS Next Day Air: IZ V6F 140 01 9104 7728

Mr. Brian Domangue Regional Supervisor Bureau of Safety and Environmental Enforcement (BSEE) Attention: Ms. Angie Gobert MS 5232 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123

Mr. Domangue,

R E C E I V E D OCT 18 2016

Office of Field Operations Pipeline Section

ExxonMobil Production Company, on behalf of Exxon Mobil Oil Corporation, respectfully requests Alternative Compliance per 30 CFR 250 141 to utilize our intemal facility inspection plan to monitor the following Hadrian South DOI Pipelines as a substitute to pipeline route patrols as described in 30 C FR 250.1005(a) and STL-T248C2.

Segment Number

Pipeline Code

Size Pipeline Length [ft/

Max Water Depth I f t j

MAOP Production ( ode

ROW Permit Authority

18839 08-10 39145 7685 7600 HLKG G29I92 DOI

18840 08-10 39430 7685 7600 BI.KC, G29I93 DOI

18841 06 56 7660 7600 Rl.KC, DOI

18842 06 65 7660 600 BLKG DOI

18843 10 120 7660 '600 Rl.KC DOI

18844 10 no ^685 ~600 RLKC DOI

A Division of Exxon Mobil Corporation

See enclosed documents Hadrian South Flowline Route Patrol Alternative Compliance Request Addendum Document Hadrian South Pipeline Route Patrol Alternative Compliance Request PPT

Should additional information be required, please contact Dean D. Kricson at 832-625-4581 or via email at dean.d.ericson a exxonmobil.com

Sincerely,

Wilton D. Cox Attorney-in-Fact ExxonMobil Production Company

ExxonMobil Production Company W4.2A.555 P.O. Box 4358 Houston. Texas 77210-4358

E^onMobil Production

October 6 ,2016

Departure Request ROW Inspection Keathley Canyon Block 964 OCS-G 21451, Hadrian South Project

If

I of SAy end Etfyn r tol Enf. m m (B Q

R E C E I V E D OCT 11 2016

Office of Field Operations Pipeline Section

Sent via UPS Next Day Air: IZ V6F 140 01 9929 9353

Mr. Brian Domangue Regional Supervisor Bureau of Safety and Environmental Enforcement (BSEE) Attention: Ms. Angie Gobert MS 5232 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123

Mr. Domangue,

ExxonMobil Production Company, on behalf of Exxon Mobil Oil Corporation, respectfully requests Alternative Compliance per 30 CFR 250.141 to utilize our intemal facility inspection plan to monitor the applicable Hadrian South DOI Pipelines as a substitute to pipeline route patrols as described in 30 ('FR 250.1005(a) and NTL-T248C2

See enclosed documents Hadrian South Flowline Route Patrol Alternative Compliance Request Addendum Document Hadrian South Pipeline Route Patrol Alternative Compliance Request PPT

Should additional information be required, please contact Dean D. Ericson at 832-625-4581 or via email at dean.d.ericson ^ exxonmobil.com.

Sincerely,

til A 0 Wilton D. Cox Attorney-in-Fact ExxonMobil Production Company

A Division of Exxon Mobil Corporation

HADRIAN SOUTH FLOWINES ROUTE PATROL - ALTERNATIVE COMPLIANCE REQUEST

[ADDEDUM DOCUMENT]

1. The Hadrian South subsea field, for which ExxonMobil is the operator-of-record, ties back to the

Anadarko Lucius Spar and is operated on ExxonMobil's behalf by the Lucius control room operators.

The Hadrian South subsea system is operated through the common Lucius / Hadrian South subsea

Master Control Station (MCS) that interfaces directly with the Lucius topsides facility's integrated

control and safety system (ICSS), designed to provide a fully-integrated monitoring, control,

protection, and safety system. These systems provide a safe method of operating the process from

within the safety of central control room (CCR) and displaying alarm and trip information. The ICSS

will allow Operations to shut down safely, and CCR Operators are trained with all Operator interfaces

control and emergency shutdown system. ExxonMobil also requires Anadarko to comply with

minimum notification requirements, including but not limited to subsea shut-downs and subsea leaks.

2. The Lucius Spar will retain records of platform-executed activities, as prescribed by the current

regulations.

3. Hadrian South periodic Integrity / Surveillance activities descriptions

Action Name Flowline Corrosion Coupon Replacement

Water Sampling

Maintenance Pigging, Returns Analysis, and Bacteria Monitoring

Chemical Management Team

Description (Overall) 1 Complete coupon installation and removal 2 Measure coupons and analyze results a Visually evaluate coupon as-pulled b Clean, weigh and measure pit depth on coupon c. Visually evaluate corrosion of coupon (as-cleaned) d. Measure weight loss and pit depths e Evaluate general corrosion and pitting rates of coupon versus past results f Make recommendation for adjustment of appropriate corrosion control program

1 Collect water samples from identified sample points 2 Complete lab tests with appropriate laboratory Typical samples will be analyzed for iron counts, inhibitor residuals, chlorides, biocide residual, and scale inhibitor residual (as applicable) Additionally on an annual basis sample will be analyzed for all ionic species, organic acids, and alkalinity in addition to the standard requirements.

Interval* Quarterly

Monthly

1. Run pipeline maintenance pig per MS operating procedure, Subsea Manifold and Flowline Pigging 2 Collect samples for pigging return analysis and bacteria monitoring 3 Document results in a pigging report 4 Complete lab tests with appropriate laboratory to analyze the pigging return and bacteria samples, review results and provide recommendations, determine if any adjustments to operations need to be completed 1. The Chemical Vendor will issue a quarterly report covering recent chemical treatment results, corrosion monitoring results, and progress on outstanding action items regarding the program 2. The CMT will review the quarterly report, identify, and track actions to achieve chemical program goals, remedy any noted opportunities, and take advantage of upside opportunities 4. One of the quarterly meetings should include identification of potential improvements in cost, safety, health, and environment (SHE), and management processes

Meeting Members Should Include: Field Sup, Operator most closely involved with chemical program. Integrity Advisor, Materials and Corrosion Engineer Facility Engineer, Chemical Vendor, Appropriate Anadarko Personnel

Ad-Hoc

Quarterly

October 3, 2016 11Page

HADRIAN SOUTH FLOWINES ROUTE PATROL - ALTERNATIVE COMPLIANCE REQUEST

[ADDEDUM DOCUMENT] Action Name Description (Overall) Interval*

Corrosion Program Review

Review overall corrosion management system to identify gaps in the corrosion monitoring and corrosion control programs The review shall 1. Determine the cost effectiveness/adequacy of corrosion control activities for maintaining equipment integrity/reliability levels consistent with operations/equipment life cycle requirements. 2 Identify any technology issues and mitigation program/performance opportunities including equipment strategies and program procedures. 3 Recommend Corrosion Control Program improvements and budget requirements for the annual and five year plans 4. Review most recent Flow Assurance models / analysis to identify any potential changes that will have impacts on the chemical management program (chemical selection, maintenance pigging requirements for chemical management, etc )

5 Yearly

Sand/ Erosion Monitoring

1. Review/evaluate sand meter/lab test data 2. Monitoring of pressure vessels and pigging return analysis of pipelines. 3 Survey Operations for operational experience 4 Review/evaluate results of the analysis and make recommendation for adjustment

Monthly

Temperature and Pressure Review

Identify all documentation, maps, drawings, previous inspection readings, reports, and etc. needed to perform the review 1. Review available temperature and pressure monitoring data, including pressure cycling Compare to onginal pipeline design limits. 2 Compare data to integrity and flow assurance to identify any opportunity

Annual

Water Cut Measurement

- Monitor water rates reported by multiphase meters and compare against expected values determined by Reservoir Engineering - Leverage water and gas analysis completed by chemical vendor to validate multiphase meter measurements This information is used for corrosion inhibition program design/monitoring and corrosion modeling/estimation purposes

Monthly

Visual Underwater Inspection & Pipeline CP Survey

Perform the underwater inspection with a ROV by capturing video footage of the inspection for documentation and detailed review.

Conduct Underwater Pipeline Inspection in coordination with analogous subsea equipment inspection: - Identify free-spans, mechanical damage, horizontal and vertical deflections, coating damage, debris, pipe burial, condition of trench, condition of associated fixings and attachments, artificial supports, integrity of mechanical connectors and flanges, integrity of subsea protective structures. Wye and Tee connections, valves, repairs, crossings, and so forth - Confirm relative changes in location of pipeline from one survey to another

Flowline/riser CP Survey: conduct cathodic protection pipeline continuous survey - Identify areas along PL that either require further evaluation, installation of supplemental CP, of interference or remediation

5 Yearly

* Surveillance activities frequencies may be adjusted as necessary via Management of

Change

October 3, 2016 2 | P a g e

E^onMobil

September 2016

Hadrian South Pipeline Route Patrol Alternative Compliance Request

US Production / Gulf of Mexico

Energy lives here

Alternative Compliance Request

ExxonMobil requests Alternative Compliance per 30 CFR 250.141 to utilize our intemal, in-service inspection plan to monitor the structural integrity of the applicable Hadrian South DOI pipelines throughout their life as a substitute to pipeline route patrols as described in the regulation, 30 CFR 250.1005 (a) and Ntl-t248c2.

§250.1005 Inspection requirements for DOI pipelines. (a) Pipeline routes shall be inspected at time intervals and methods prescribed by the Regional Supervisor for indication of

pipeline leakage. The results of these inspections shall be retained for at least 2 years and be made available to the Regional Supervisor upon request

1991 Letter to Lessees Ntl-t248c2 6. Clarification to 250.155(a) - Each DOI pipeline route in the GOM shall be inspected at least monthly for indication of

pipeline leakage These inspections can be made by using a helicopter, marine vessel, or other approved means.

The Hadrian South DOI pipeline segments include:

Segment Originating Id Number Name

Receiving Id Name

Pipeline Size Code

Pipeline Length [ft]

Max Water Depth [ft]

MAOP [psig]

Production Code

ROW Permit

Authority

18839 FLET #3 Lucius Spar 08-10 39745 7685 7600 BLKG G29192 DOI

18840 FLET #4 Lucius Spar 08-10 39430 7685 7600 BLKG G29193 DOI

18841 SS Well #2 Manifold 06 56 7660 7600 BLKG DOI

18842 SS Well U 3 Manifold 06 65 7660 7600 BLKG DOI

18843 Manifold FLET #4 10 120 7660 7600 BLKG DOI

18844 Manifold FLET #3 10 110 7685 7600 BLKG DOI

EjgonMobil

Alternative Compliance Request

In accordance with 30 CFR 250.141, we will present to confirm how this alternative provides a level of safety and environmental protection that equals or surpasses current BSEE requirements.

(1) Site-specific application(s)

(2) Performance characteristics

(3) Safety features of the proposed procedure or equipment

E^onMobil

Site-Specific Application Site-Specific information:

• Region:

• Asset:

• DOIPSNs.

• DOI PSN ROWs.

• Originating Block

• Entered Blocks:

• Receiving Blocks:

• Tieback Distance

• Host Platform

• Water Depth

• Service:

• Authority:

• Design life:

• MAOP:

• Operating Conditions:

Gulf of Mexico, 230 miles offshore Louisiana

EM-operated Hadrian South subsea tieback

18839, 18840, 18841, 18842, 18843. 18844

18839, 18840

Keathley Canyon block 964

KC 964, 963, 919, 875

Keathley Canyon block 964. 875

7.5 miles

APC-operated Lucius Spar

7 650 ft (3200 psig hydrostatic)

Bulk Gas from 2 wells

(-315 MMSCFD, 95% Methane with low C02)

DOI

10 years (umbilical, subsea trees / manifold)

20 years (jumpers and flowlines)

7600 psi

4,200 psig subsea

» 4 to-* t j

f qu r r • | KnUur. SouUi (kmknr ft*Iff n *

E^on Mobil

Riser (2): 8.625" with 1 05' WT Riser based Jumper (2) 8.625" with 1" WT Flowline (2): 10.750" with 1.08" WT Manifold Jumper (2): 10 750" with 1.25" WT Umbilical (1): Electro/hyd-aulic

Performance Characteristics Proposed Alternative Procedures/Equipment for this Site:

• Real-time Local Safety System Triggered Shutdowns *As documented in the DWOP and the Subsea Cause and Effects Document (USHS-ED-IBICS-40-0002) • A flowline PSD immediately triggers shut in of all wells flowing into that flowline and BSDV closure within 45s

after sensor activation. • A flowline PSHL on transmitter upstream of boarding valve immediately triggers shut in of all wells flowing into

that flowline and BSDV closure within 45s after sensor activation. • PR-05: PSHL-0140 • PR-06: PSHL-0150

• A Manifold Header PSHH immediately shut in of all wells flowing into that flowline • An outboard Wellhead MVT02 LoLo will shut-in associated well upon low pressure condition

• Continuous Local and Remote Surveillance • Subsea pressures and temperatures • Boarding pressures, temperatures, MPFM produced water rates

• Periodic Integrity / Surveillance Activities

Action Name Performance Interval

Flowline Corrosion Coupon Replacement 3 Months

Water Sampling 1 Months

Maintenance Pigging, Returns Analysis, and Bacteria Monitoring Ad Hoc

• '—— Chemical Management Team

3 Months

Corrosion Program Review 5 Years

Sand/ Erosion Monitoring 1 Months

Temperature and Pressure Review 1 1 1

1 Years

Weekly Water Cut Measurement 1 Months

Visual Underwater Inspection & Pipeline CP Survey 5 Years

E^onMobil •Periodic surveillance activity frequencies may be adjusted as necessary via MOC.

Safety Features Safety Features:

• ExxonMobil propose to use an alternate integrity activities to waive Hadrian South pipeline route inspection requirement (DOI Pipeline routes inspection requirement: 30 CFR §250.1005 and Ntl-t248c2) based on ExxonMobil U S Production Facilities Integrity Management System (FIMS) program addressing the following integrity equipment degradations modes:

I. Mechanical damage (third-party marine damage, dropped objects, anchor drop, etc.) and External Corrosion: ROV inspection every 5 years with additional inspection within the first 2 years of operation: external visual inspection, free span, debris, line moves, Cathodic Protection Visual monitoring from the platform of 3rd party activities within proximity to the HS system

II. Continuous spill / leak detection: flow rate monitoring, flowline PSHL. flowline PSD, subsea manifold header PSHH

III. Internal Corrosion: Corrosion coupon monitoring, as needed corrosion inhibitor injection, erosion, and fluid monitoring, as needed maintenance pigging program

Level of Safety and Environmental Protection That Equals or Surpasses Current Regulation

• In the event of a leak, the pressure monitoring system will alert operators as well as shut down the subsea well(s)

• Continuous surveillance of other parameters in the system will also provide secondary means to identify leak(s).

Safety Features Comparison Summary

Detection Feasibility

Reaction Time

30 CFR §250.1005 / Ntl-t248c2 Alternative

Low High

Time between patrols (assuming detection possible) Real Time

E^onMobil

4/6/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd Alternate compliance request few S18839 18840

Shrestha, Bimal <bimal.shrestha@bsee.gov;

Fwd: Alternate compliance request for s18839 18840 1 message

Shrestha, Bimal <bimal.shrestha@bsee,gov> Men Mar 20 2017 at 12 04 PM To bryan I chapman@exxonmobil.com

Bryan;

FYI

Please address this issue .. These are from Dean Ericson.

Forwarded message From Shrestha, Bimal <bimal.shrestha@bsee.gov> Date Thu, Feb 2, 2017 at 2:08 PM Subject: Fwd Alternate compliance request for si8839 18840 To "Bettencourt Paul J" <paul.j.bettencourt@exxonmobil com>, wilton d cox@exxonmobil,com

Forwarded message — From: Shrestha, Bimal <bimal.shrestha@bsee,gov> Date: Thu, Jan 12, 2017 at 3:38 PM Subject: Altemate compliance request for s 18839 18840 To. "Ericson Dean D" <dean.d.ericson{a)exxonmobil.com>

Dean:

We have your request dated 10/17/2016 for alternate compliance for monthly flyover inspection for s#18839, 18840, and other lease term pipelines.

since s#l8839 and 18840 are ROW pipelines permitted to Exxon Mobil Corporation, please resend the applications for these pipelines from Exxon Mobil Corporation. The submitted application refers to Exxon Mobil Oil Corporation and is submitted by ExxonMobil production company.

please send separate application for s#18841-44 from Exxon Mobil Corporation

You may send by email attachment.

Bimal Shrestha Pipeline Section Bureau of Safety and Environment Enforcement 1201 Elmwood Parkway Blvd New Orleans, LA 70123 (504) 736-2548

Bimal Shrestha Pipeline Section Bureau of Safety and Environment Enforcement 1201 Elmwood Parkway Blvd. New Orleans, LA 70123 (504) 736-2548

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