TRUNKLINE GAS An ENERGY TRANSFERCompany

July 12, 2016

R E C P T ^ Mr. Bryan Domangue 1 1 ' V E J) Acting Regional Supervisor I I . . Bureau of Safety and Environmental Enforcement 1 4 2016 Gulf of Mexico OCS Region & Atlantic Activities ^ 1201 Elmwood Park Blvd. F ' e , c 'Operatiods New Orleans, LA 70123-2394 p'Pe''ne Section Attention: Mr. Frank Patton

Pipeline Section

Subject: Application for Right-of-Way Pipeline Modification of Trunkline Gas Company, L L C ROW OCS-G1693, Segment No. 1658, T-23 Valve Platform, Located in South Timbalier Area, Block 52, Gulf of Mexico, Federal Waters, Offshore Louisiana

Mr. Patton:

As an alternative plan to mitigate platform ultimate strength as documented in our previously submittal dated January 12, 2016, Trunkline Gas Company, LLC (Trunkline) herein submits an addendum to the subject application to install a cable-guying system onto the South Timbalier 52 "T-23 Valve" platform.

The retrofit cable-guying system includes steel wire rope guy cables, clamps, adjustable terminators and driven anchor piles, and serves to laterally strengthen the platform and mitigate platform strength issues as determined from recent assessment per API RP2A Section 17. The supporting API RP2A Section 17 ultimate strength analysis and Section 2 design for this application include all known cumulative damage and platform modifications. The design of the modifications was based on the latest API RP2A, 21 s t Edition guidelines and 21 NT-MET environmental criteria.

In support of this addendum, the following information for the alternative plan to mitigate platform ultimate strength is enclosed:

• Design Data and Certification • General Arrangement Plan Drawing • API Interaction Ratio and Safety Factor/Assembly Elevation Drawing • Anchor Pile Elevation Drawing • Certified Structural Modification Drawings (11x17), full set • Structural Strengthening Engineering Report • SACS Input and Output Files • Statement of Position Letter dated 21 June16

Note that Trunkline has not submitted duplicates of previous data such as location plat, soils report, original platform drawings, and inspection reports. The data submitted herein as noted above is applicable only to the modified plan for strengthening the platform.

8100 Big Lake Rd Lake Charles, LA 70605 (337) 478-9936

Trunkline Gas Company, LLC Page 2

Additionally, the following information previously requested by BSEE to support the initial application is provided:

• Drawings for the replacement boat landing • Drawings for construction preparation • A service fee pay.qov receipt for "Platform Application - Modification" in the amount of

$3,884.00.

Should you have any questions or requests for additional information, please contact Mr. Kevin Jueschke at (337) 475-4203 or via email at Kevin.Jueschke@energytransfer.com.

Sincerely,

Trunkline Gas Company, L L C

Dennis Odum Vice President - South Division

^ X D 2 J o I S

TRUNKUNE GAS An ENERGY TRANSFER Company

January 12, 2016

Mr. Bryan Domangue Acting Regional Supervisor Bureau of Safety and Environmental Enforcement Gulf of Mexico OCS Region & Atlantic Activities 1201 Elmwood Park Blvd. New Orleans, LA 70123-2394

Attention: Ms. Angle Gobert Pipeline Section (GE1035A)

Bureau ol Safety and Envircmtfld Enforcefnent (i!chE)

R E C E I V E D JAN 15 201S

Office of Field Operations Pipeline Section

RE: Application for Right-of-Way Pipeline Modification of Trunkline Gas Company, L L C ROW OCS-G1693, Segment No. 1658, T-23 Valve Platform, Located in South Timbalier Area, Block 52, Gulf of Mexico, Federal Waters, Offshore Louisiana

Dear Mr. Domangue:

Pursuant to the regulations contained in Title 30 CFR 250, Subpart J and in accordance with the provisions contained in Title 30 CFR 250.901 through CRF 250.908 as implemented by Bureau of Safety and Environmental Enforcements (BSEE), Trunkline Gas Company, LLC (Trunkline) has prepared this application in quadruplicate for the pipeline right-of-way modification for the major structural modification and strengthening of the existing accessory Platform T-23 located in South Timbalier Block 52, Complex ID 25015. Trunkline agrees that said right-of-way modification, i f approved, wi l l be subject to the terms and conditions of said regulations. Included with the application are all pertinent information and documentation covering the platform strengthening and modification.

In regards to §250.1007(b), the primary purpose of the proposed modification wil l be to replace the existing boat landings on the Row A and B sides of the ST 52 T-23 Valve platform jacket with new boat landings. Trunkline wi l l strengthen the jacket by attaching a soldier pile braced frame system to each leg at El. (-) 23'-71/2". The strengthening braces wi l l be attached to the jacket using stress grouted clamp and to the soldier piles via a grouted connection. The soldier piles wi l l be located approximately 27 feet outboard of each jacket leg. This soldier pile system wi l l ensure that the Reserve Strength Ratio from a Reserve Strength Analysis of the platform wi l l exceed 1.0 after the modifications are made.

The platform was analyzed and drawings of the strengthening system were produced and sealed by a registered professional engineer in accordance with CFR 250.901 through 250.908. A l l design data shall be kept on file at Trunkline's office.

In support of the proposed platform strengthening, enclosed is the ST 52 T-23 Structural Permit Package. The structural permit package consists of the following items:

• ST-52 T-23 Structural Permit Report

8100 Big Lake Rd Lake Charles, LA 70605 (337) 478 9936

Bureau of Safety and Environmental Enforcement Page 2

• Appendix A: ST-52 T-23 Inspection Reports • Appendix B: ST-52 T-23 Original Platform Design Drawings • Appendix C: Soils Report • Appendix D: Results of the In-place Analysis • Appendix E: Results of Global Inelastic Analysis (API 2INT-MET 50-year) • Appendix F: Complete set of Structural Strengthening Drawings • Appendix G: ST-52 T-23 Location Plat

The subject right-of-way pipeline. Segment No. 1658, Right-of-Way OCS-G1693, is owned and operated by Trunkline Gas Company, LLC. Assignment of the pipeline right-of-way OCS-G 1693 from Trunkline Gas Company, LLC to Sea Robin Pipeline Company, LLC has been submitted, but is being held until modification are received. Per discussions with Ms. Angle Gobert, the modifications to the right-of-way assignment wi l l not be submitted by Trunkline until after BSEE approval is received on this application.

This application and any amendments made hereto are made with Trunkline's ful l knowledge and concurrence with the OCS Lands Act (43 U.S.C. 1334, et Seq.), as amended. Trunkline further agrees to comply with the regulations contained in Title 30 CFR 250, Subpart J. Trunkline understands that in regards to requirements in §250.1010(c), that i f any site, structure, or object of historical or archeological significance should be discovered during the conduct of any operation within the right-of-way, we wil l immediately report such findings to the Regional Supervisor and make every reasonable effort to preserve and protect the cultural resource from damage until the Regional Supervisor has given directions as to its preservation.

Trunkline agrees that the area covered by the proposed right-of-way modification and all improvements thereon shall be kept open at all reasonable times for inspection by the Bureau of Safety and Environmental Enforcement (BSEE) and wil l make available all records relative to the design, construction, operation, maintenance and repair, and investigations on or with regard to such area.

This application and any amendments made hereto are made with Trunkline's fu l l knowledge and concurrence with the OCS Lands Act (43 U.S.C. 1334, et. Seq.), as amended. Trunkline further agrees to comply with the regulations in Title 49 CFR, Part 192, Transportation of Natural and Other Gas By Pipeline: Minimum Federal Safety Standards, and all applicable regulations contained in Title 30 CFR, Part 250, Subpart J, Pipelines and Pipeline Rights of Way on the Outer Continental Shelf.

The shore-based operations facilities for the pipeline wi l l be located in Lake Charles, Louisiana. Trunkline wil l continue to be the pipeline operator.

Per, CFR 250.125, a service fee pay.gov receipt for "Pipeline Application - Modification ROW" in the amount of $4,169.00 is attached. Should you have any questions or requests for additional information, please contact Mr. Kevin Jueschke at (337) 475-4203 or via email at Kevin.Jueschke@energytransfer.com.

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The proposed platform modification activities are expected to commence on or about April 15, 2016. Your expedited review and approval is greatly appreciated.

Sincerely, Trunkline Gas Company, L L C

Dennis Odum Vice President - South Division