United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT

GulfofMexico OCS Region 1201 Elmwood Park Boulevard

New Orleans, Louisiana 70123-2394

In Reply Refer To: GE 1035A January 15, 2019

Ms. Sarah Lunsford Proteus Oil Pipeline Company, L L C P.O. Box 2648 Houston, TX 77252

Dear Ms. Lunsford:

Reference is made to Proteus Oil Pipeline Company, L L C (Proteus) letter dated September 24, 2018, received by this office on October 23, 2018, clarifying demarcation line of the Right-of-way associated with Pipeline Segment No. (PSN) 13633 at Platform A (Thunderhorse) in Mississippi Canyon Area 778 (MC778A). Specifically, Proteus clarified that the Right-of-way No. OCS-G23429 begins from the lower face of the flange directly above the SCR flexjoint on the riser associated with the PSN 13633.

The portion ofthe riser above the lower face ofthe flange directly above the SCR flex joint is a part ofthe platform MC778A (Thunderhorse) currently operated by BP Exploration and Production, Inc (BP). A letter dated October 9, 2018 from BP concurring with this clarification is also acknowledged. The portion above the lower face ofthe flange directly above the SCR flex joint on the riser is under the jurisdiction of BSEE, New Orleans District. BP or any subsequent operator should contact New Orleans District for permitting issues for this portion ofthe pipeline.

Proteus has designated Shell Pipeline Company LP as an operator for the PSN 13633 associated with the Right-of-way No. OCS-G23429.

This office accepts your clarification and describes the Right-of-way No. OCS-G23429 as follows:

Pipeline Right-of-way (ROW) OCS-G23429 is a 200foot wide and approximately 70.64 miles (372,942feet) long corridor associated with the 24 to 28-inch Pipeline Segment No. (PSN) 13633. The purpose of pipeline ROW OCS-G23429 is to maintain and operate Pipeline ROW accessory structures Platform E (Complex ID 1093-1), Platform E-AUX (Complex ID 1093-2), and PSN 13633 and to transport oil originating from the lower face ofthe flange directly above the SCR flex joint on the riser at Platform A (Thunderhorse) in Mississippi Canyon Area Block 778, through Mississippi Canyon Area Blocks 777, 733, 734, 690, 689, 645, 644, 643, 599, 598, 554, 553, 552, 508, 507, 463, 462, 418, 417, 416, 372, 371, 327, 326, 282, 281, 280, 279, and278, through South Pass Area Blocks 91, 90, and terminating at Platform E in Block 89.

Sincerely,

For: Bryan A. Domangue Acting Regional Supervisor Regional Field Operations

Cc: Denise McGuire Shell Pipeline Company LP P.O. Box 2648 Houston, TX 77252

Ms. Beth Atwood BP Exploration and Production, Inc 501 Westlake Park Blvd. Houston, TX 77079

New Orleans. BSEE

(3/ISti'i/A'trvr-.-on- sscr

Proteus Oil Pipeline Company, LLC PO Box 2648

Houston, TX 77252-2648

September 24, 2018

R E C E I V E H Bureau ofSafety and * * Ms MJ

Environmental Enforcement O C T 2 3 2018

Attention: Ms. Angie Gobert, GE1035A

1201 Elmwood Park Blvd. Office of Field Operations New Orleans, LA 70123 P ^ n e Section

RE: NOTIFICATION OF OPERATORSHIP DEMARCATION -24-28" PROTEUS OIL PIPELINE, ROW OCS-G23429, SEGMENT 13633 ROW HOLDER - PROTEUS OIL PIPELINE COMPANY, LLC ROW OPERATOR OF RECORD - SHELL PIPELINE COMPANY LP PRODUCING OPERATOR-BP EXPLORATION & PRODUCTION INC. THUNDERHORSE PLATFORM, MC778A, OFFSHORE LOUISIANA

Dear Ms. Gobert:

Proteus Oil Pipeline Company, LLC hereby submits supporting documentation to reflect demarcation

between the producing operator (BP Exploration & Production Inc.) and the transporting operator (Shell

Pipeline Company LP) for 24-28" Oil Pipeline, OCS-G23429, Segment 13633 at MC778A Platform.

Segment No. 13633 originates at the Thunderhorse facility (MC778A) and includes the SCR portion ofthe pipeline and a horizontal section extending along the seafloor on the ROW several miles eventually terminating at SP89E Platform. As per the Safety Flow Schematic MGT-INT-C-14-HS-DRW-0001-2 (copy attached) previously approved by BSEE on February 20, 2008, the producing operator, BP Exploration & Production Inc., is responsible forthe pipeline on the facility hull up to the SCR flexjoint. The responsibility ofthe transporting operator. Shell Pipeline Company LP, begins at the lower face ofthe flange directly above the SCR flexjoint.

By the attached letter dated October 9, 2018 BP Exploration & Production Inc. acknowledges their agreement with the aforementioned demarcation.

Ms. Angie Gobert Bureau ofSafety and Environmental Enforcement September 24, 2018

Should you have questions or need additional information, please contact:

Denise McGuire Sr. Land Agent, Offshore Shell Pipeline Company LP

P.O. Box 2648

Houston, TX 77252-2648

832-762-2487 (Office) or Denise.McGuire@Shell.com

Sincerely,

Sarah Lunsford

Vice President

Proteus Oil Pipeline Company, LLC

xc: Anthony Pizza, BSEE New Orleans District

Stephen Dessauer, BSEE Production Operations Jason Dollar, Shell Pipeline Company LP Michelle Bourgeois, Shell Pipeline Company LP Michael Mitchel, Shell Pipeline Company LP Denise McGuire, Shell Pipeline Company LP Blair Hunt, Shell Pipeline Company LP Madhav Parimi, BP Exploration & Production Tana Eckols, BP Exploration & Production Elizabeth Komiskey, BP Exploration & Production

In Reply Refer To: MS 5232

Mr. James Black Proteus O i l 501 Westlake Park Boulevard Houston, Texas 77079

Dear Mr. Black:

The Minerals Management Service has reviewed your completion report f o r the following p i p e l i n e :

Application Type: New Right-of-way Pipeline Letter Date: August 16, 2006

Segment ROW Size Length Nuinber Nuinber (inches) (feet) Service From To

13633 G23429 24-28 372,942 O i l Platform A Mississippi Canyon Block 778 OCS-G098 68

Platform E South Pass Area

Block 8 9 OCS-G01618

The t o t a l length of the " a s - b u i l t " right-of-way i s 70.63 miles.

The report i s submitted i n accordance with 30 CFR 250.1008 (b) .

The data provided i n the report establishes the assigned maximum allowable operating pressure (MAOP) f o r the p i p e l i n e :

MAOP MAOP (psig) Determination

3630 Hydrostatic Test Pressure

The high- and low-pressure sensors s h a l l be set no higher than 15 percent above and below the normal operating range, respectively. The high p i l o t , however, s h a l l not be set higher than the MAOP of the p i p e l i n e . The pressure range s h a l l be established by the use of pressure recorders.

Sincerely ,

(org. sgd^. A, Alvarado

Joe T. Gordon Regional Supervisor F i e l d Operations

bcc: 1502-01 Segment No. 13633, ROW OCS-G G23429 (MS5232) 1502-01 ROW OCS-G G23429 (Scanning) (MS 5033)

August 16,2006

Attn: Pipeime Unit (MS 5232) Regional Supervisor, Field Operations Minerals Management Service 1201 Eknwood Park Blvd New Orleans, L A 70123

Re: As-built Pipeline Report Proteus Oil Pipeline

MMS Segment 13633; ROW OCS-G 23429

Gentlemen:

Wiwrtte tk^M.t>m.sai Statics

E E C i i l V E1) SEP 1 J ZOOS

In accordance with 30 CFR 250.1008(b), please find enclosed the pkts and hydrostatic test data, in triplicate, for the foUowing pipeline segment:

Segment Number

Designation Pennitted Length,

To TD Point, ft

As-Built Length,

To TD Point, ft

Completed Date

Proposed Operation

Date

13633 24-28" Oil Pipeime fiom MC778A Platform to SP 89 E Platform

373,166 372,941.74 July 16, 2006 December 2006

Hydrotest The pipeline was hydrostatically tested to on June 23, 2006 for eight hours. The pressure ranged ftom 4556 psi to 4558 psi. Please see the attached hydrotest data.

Proteus Hydrotest Report.pdf

Plats Please find enclosed the certified as-built plats for the subject pipeime. The pipeline did not substantifllly deviate from the approved route. Also enclosed is an ASCII file of the pipeline route as requited in NTL 98-09.

061243pro_v4.pdf MP

061243pro.pdd

A copy of the plat included in the report required by this paragraph shall also be submitted to: National Ocean Service N/CS26Rm7317 1315 E-W Highway Silver Springs, MD 20910

Pipehne Crossing Diagrams Viosca Knoll Gas 12" (S-lay) - C22 WFS Gas 18" and Williams Oil 18" Q-lay) -C21

Please find enclosed drawings showing the as-built crossing arrangements for each ofthe pipelines crossed by tiae subject pipeline. The mats were laid from touchdown point to touchdown point over the Proteus Oil Pipeline at die pipeline crossings and then the edges were jetted down below the mudline.

MGT-im'-C-M-PL-DR W-0030-0.pdf

PROi44_04_0165 RevAl.pdf

Anodes Anodes were installed on the pipeline as described in the pipeline application. In summary, the following

Pipeline Section Anode-Net Weight, lbs Spacing COI 512 1 every 6 joints + 1 every joint

for first 5 joints to protect the riser and tie-in spool piece at SP 89 E

C02 512 1 every 6 joints

COS 512 1 every 6 joints

C04 512 1 every 6 joints

COS 411 1 every 6 joints + 22 additional anodes on the last 18 joints to protect the SCR

Pipeline Crossings 1

512 1 additional anode on each side of Viosca Knoll pipeline crossing. No additional anodes for the Williams crossing.

Buckle arrestors, including J-ky collars that serve as buckle arrestors, were installed as follows: • Section C02: 1224 lb, 1 every 72 joints; 1168 lb, 1 every 72 joints for WD = 130.0-3200 ft • Section C03: 1387 lb, 1 every 6 joints; 1527 lb, 1 every 72 joints • Section C04: 1423 lb, 1 every 6 joints; 1564 lb, 1 every 72 joints • Section COS: 1171 lb, 1 every 6 joints

Safety System Schematic Please find enclosed a revised safety system schematic for review and approval. Modifications to the drawing from the previously approved drawing are shown in the clouded areas. Please note that the change of operatorship has been designated on the drawing at the face of the flange above the Flexjoint.

MGT-INT-C-14-HS-D RW-00Ol-2.pdf

If you have any questions, please contact our regulatory representative, Wanda Parker, WJP Enterprises at 972-516-1177 or by e-mail at wanda.parkerfSjwjpentetprises.com.

Very truly yours,

9 Mike v andenbossche BP America Inc. c/o INTEC Engineering Inc. 15600 JFK Blvd. 3ni Floor Houston,^ 77032-2349 (281) 925-2182

Tana Eckols Regulatory Compliance Advisor Deepwater GoM SPU

BP Exploration & Produetion Inc. 501 Westlake Park Boulevard Houston, Texas 77079 Telephone. 832-472-7375 Email TanaEckols@bp.com

October9, 2018

Ms. Angie Gobert Pipeline Section Chief Bureau ofSafety and Environmental Enforcement 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123-2394

RE: Notification of Operatorship Demarcation 24-28-inch Proteus Oil Right-of-Way Pipeline Segment No. 13633, ROW G-23429 Originating in Mississippi Canyon 778, Platform A, OCS-G09868 Receiving in South Pass 89, Platform E, OCS-G01618 ROW Holder: Proteus Oil Pipeline Company, LLC (Company No: 02530)

Dear Ms. Gobert:

Proteus Oil Pipeline Company, LLC submitted the clarification notice for ROW G-23429, Segment number 13633, dated September 24, 2018. The notification identified the point of demarcation between the pipeline and the interconnect facilities on the Thunderhorse platform from which the pipeiine originates, as well as the responsibility for operations downstream of the point of demarcation (Shell Pipeline Company LP, Company No. 02289) vs. upstregm of the point of demarcation (BP Exploration & Production Inc., Company No. 02481). BP Exploration & Production Inc. submits this letter to confirm that it supports the point of demarcation and respective responsibilities indicated in Proteus' notification. BP Exploration & Production Inc. further agrees that a reference to the associated ROW (OCS-G23429 and Segment Number (13633) will be included in future submittals for the section of pipeline for which BP Exploration & Production inc. is responsible.

If you have any questions or require additional information, please contact Tana Eckols, Regulatory Advisor, at 832-472-7375 or by e-mail to tana.eckols@bD.com.

Sincerely,

Tana Eckols BP Thunder Horse Regulatory Advisor