Submittal Overview...• Review the qualifications of the welder(s) to assure that they are properly trained and qualified in accordance with ANSI B31.3, AWS D1.1 and/or other applicable

UNITED STATES DEPARTMENT OF THE INTERIOR Created on BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT 21-OCT-2020

SUBMITTAL REPORT 13:25:34

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Submittal Overview

Operator: Fieldwood Energy LLC (03295)

Business Process: District Notices and Requests

Submittal Type: General Welding and Burning Plan

Project Name:Submittal Coordinator: Ozoral, Cemal

Submittal Status: Approved

Submittal ID: 24818811

Status Date: 21-OCT-2020

Submittal Description:Remarks:

Final Action

Decision Maker: Ozoral, Cemal Production EngineerGOMR Houma Production Operations Section

Submitted Date 13-AUG-2020Review Decision: Approved Decision Date 21-OCT-2020

The General Welding and Burning Plan, submitted on 13-AUG-2020, has been Approved on 21-OCT-2020

Decision Maker's comments:

Mitigation _

NO MITIGATIONS

Submittal Statuses

Status Creator Created Modifier Last ModifiedApproved [email protected] 21-OCT-2020 13:25:34

Remark

Status Creator Created Modifier Last ModifiedIn Review [email protected] 21-OCT-2020 13:20:43 [email protected] 21-OCT-2020 13:25:34

Remark

Status Creator Created Modifier Last ModifiedResubmitted

o-mackb 21-OCT-2020 12:55:04 [email protected] 21-OCT-2020 13:20:43

Remark

Status Creator Created Modifier Last ModifiedIn Rework o-mackb 21-OCT-2020 12:52:17 o-mackb 21-OCT-2020 12:55:04



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Status Creator Created Modifier Last ModifiedRemark Uploaded updated Welding & Burning Letter

Status Creator Created Modifier Last ModifiedReturned [email protected] 21-OCT-2020 12:38:22 o-mackb 21-OCT-2020 12:52:17

Remark Please update the information in regard to the SPN Resources being changed to Fieldwood Energy SP LLC due to the operator number not matching Operator# 02636.

Status Creator Created Modifier Last ModifiedIn Review [email protected] 14-AUG-2020 16:37:53 [email protected] 21-OCT-2020 12:38:22

Remark

Status Creator Created Modifier Last ModifiedSubmitted o-mackb 13-AUG-2020 16:20:00 [email protected] 14-AUG-2020 16:37:53

Remark

Status Creator Created Modifier Last ModifiedDraft o-mackb 13-AUG-2020 15:53:35 o-mackb 13-AUG-2020 16:20:00

Remark

Magnetic Anomalies

Area Block Shot Line #

Shot Point

Intensity (Gammas)

Duration(Feet)

Coordinates Min Avoidance Dist (ft)

Applied Mitigation

Sonar Targets

Area Block Magnetometer Association

DimensionsLxWxH (Feet)

Coordinates Min Avoidance Dist (ft)

Applied Mitigation

Variances

NO VARIANCES

MetadataDistrict Office: New Orleans, Houma, Lafayette, Lake Jackson, and Lake CharlesArea-Block(s): All associated within entities of Fieldwood Energy

Lease(s): All associated within entities of Fieldwood EnergyComplex ID Number(s): All associated within entities of Fieldwood Energy

Well API Number(s): All associated within entities of Fieldwood Energy

Contacts



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MR. Mack, Bryan Phone: (337)354-8090 - Office Email: [email protected] Type: Secondary Contact

Address: 2014 West Pinhook RoadSuite 800Lafayette, LA 70508

MS. Montalvo, Brenda Phone: (713)969-1084 - Office Email: [email protected] Type: Primary Contact

Address: 2000 Sam Houston Pkwy. SouthSuite 1200Houston, TX 77042

Verbal Authorization

NO VERBAL AUTHORIZATIONS

Payments

NO PAYMENTS

Checklist

NO CHECKLIST

Requests for Information

NO RFIS

Associated Submittals

NO Associated Submittals

Welding, Burning and Hot Work Safe Practices / Plan

Section D Chapter 15

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Safe Work Practices July 2020

Welding, Burning and Hot Work Safe Practices / Plan Purpose To establish procedures for safely conducting welding, burning, cutting and other hot work activities in accordance with BSEE regulations (30 CFR 250.109 – 113) Scope This policy establishes requirements for burning, welding, and hot work activities at all Fieldwood Energy BSEE regulated facilities Responsibilities The Person in Charge (PIC) and/or Project Supervisor is responsible for:

• Fieldwood Energy’s designated person-in-charge of welding/burning operations as required in 30 CFR 250.113 shall be the Person in Charge (PIC) or Project Supervisor

o In the case of SIMOPS, the person-in-charge of welding/burning operations shall be the person who has Ultimate Work Authority (UWA) per the Ultimate Work Authority Agreement Form for Simultaneous Operations

• Evaluating the safety aspect of these activities as an integral part of pre-planning a job, (i.e. Job Safety Analysis)

• Ensuring all employees involved in these activities are properly trained and understand the requirements of this procedure and the hazards and safeguards involved

• Issuing and following the Hot Work Permit to include:

o Inspecting the work area o Filling out the permit form o Reviewing the permit conditions with employees involved o Monitoring the work for compliance o Revoking the permit if conditions change that may create hazards o Inspecting the work area when the work is completed and closing out the permit

• A copy of the completed Hot Work Permit and associated JSA must be available at the

work site at all times and kept on file. A separate permit is required for each job and/or shift change not to exceed 12 hours

• The provisions of the permit must stay in place for the duration of the permitted time, including all breaks. (i.e. A designated fire watch must remain on post at all times including breaks for the duration of the permit when welding, burning and spark producing activities are being conducted.)



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General Requirements

• All offshore welding/burning shall be minimized by onshore fabrication when feasible

• This Welding and Burning Safe Practices and Procedures Plan will be used in performing welding/burning activities on a platform, structure, artificial island, or other installation during any drilling, well completion, well workover, production operation or other installation which contains or may be reasonably expected to contain residual flammable fluids including, but not limited to a well open to a hydrocarbon-bearing zone

• A copy of this plan and approval letter shall be available on the facility where the welding is being conducted

• A Hot Work Permit is required anytime hot work activities are going to be conducted

outside of a BSEE approved designated safe welding area. This includes the use of non-intrinsically safe equipment (i.e. cameras, radios, etc.)

Hot Work NOT Involving Welding, Burning and/or Spark Producing Activities The following provisions apply to the use of specific types of devices and tools or equipment, which, under originally intended use circumstances should not result in the emission of flames or sparks. Any activity not otherwise specified within this section are considered welding, burning, or spark-producing activities.

• Use of Portable Electronic Devices:

o Laptops or Hand Held Computers o Digital Cameras o Non-Intrinsically Safe Radios o Cellular Phones

• Use of Pneumatic (air-operated) Tools:

o Chipping or needle guns with brass needles o Rivet busters o Impact wrenches o Drilling holes where bits are lubricated to minimize heat o Sawing or cold cuts where blades are lubricated to minimize heat

General Requirements – Non Open Flame Hot Work • Completion of a Hot Work Permit

o The use of these devices and/or tools requires the completion of checklist items 1 – 5

o Checklist items 6 – 17 are not applicable when the work involved is subject to these provisions (i.e. does NOT include welding, burning or spark producing



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activities) • Continuous monitoring with a gas detector. If LEL above 10% is detected; personnel

must immediately stop work, vacate the area and inform the designated ultimate work authority

• A Fire Watch is not required during these activities, so long as the activity being performed does not hinder a worker’s ability detect atmospheric condition changes

Portable Electric Tools Use of electric tools (with cords or batteries) such as abrasive grinding or cutting tools, drills, saws, grinders, etc. must meet all requirements of open flame hot work and the hot work permit, including fire watch, shut-in of wells, production equipment, flameproof covers, or tarps, etc. as defined in this safe work practice Hot Work involving Welding, Burning and Spark Producing Activities Prior to the commencement of any welding, burning or spark producing activities, whether in designated or undesignated areas, the Person in Charge (PIC) and/or Project Supervisor shall ensure the following:

• Review the qualifications of the welder(s) to assure that they are properly trained and qualified in accordance with ANSI B31.3, AWS D1.1 and/or other applicable welding codes (i.e. B31.8 and B31.4 for pipeline weld repairs)

• Inspect the area in which the work is to be performed for potential fire and explosion hazards

• Verify that all welding and burning equipment has been inspected

o Verify welding leads are completely insulated and in good condition o Verify that oxygen and fuel gas bottles are in a secure place o Verify each welding or burning unit bottles are equipped with fittings, gauges,

regulators, flame arrestors and leak free hoses o Verify all engine-driven welding machines located on production or process

platforms are equipped with spark arrestors and drip pans o Verify all engine-driven welding machines are equipped with manual or automatic

air intake shut down devices

• Verify that all welding ground return cables have been properly mounted

o All Ground Return Cables must be mounted in locations that can be verified to have unbroken continuity between the ground clamp and the welding site

o Whenever possible, the Ground Return Cable (Ground Lead) should be run along with the Welding Cable (Welding Lead) to the worksite. The Ground Return Cable should be mounted in reasonable proximity to the worksite so it can be



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monitored during the welding operation o When the Ground Return Cable must be mounted in a location away from the

welding site, it shall be mounted on a welded structural component o Mounting surfaces must be properly prepared before installing Ground Return

Cable clamps o Ground Return Cables must not be attached to socket-mounted handrails or

other non-welded components

Welder Qualification Standards – Structural Welding: • All structural welding on Fieldwood Energy facilities shall be done by qualified welders

who have been tested and qualified in accordance with appropriate provisions of AWS Structural Welding Code, AWS D1.1. Structural Welding includes but not limited to the following:

o Structural members of the facility o Stairways o Walkways o Handrails o Grating o Deck Plating o Temporary Crane Installation o Temporary Living Quarter Installation o Structural support Installations o Boat Landings

Welder Qualification Standards – Process Pipe and Equipment Welding: • All welding on pressure piping and process equipment on Fieldwood Energy’s facilities

shall be done by qualified welders who have been tested and qualified in accordance with appropriate provisions of ANSI B31.3, Petroleum Refinery Piping Code. Any welding performed on coded process equipment shall be conducted by a qualified welder.

General Requirements for Process Piping

• Cold cutting shall be the only method of existing process piping primary cuts.

• The process piping or vessel has been either cleaned and degassed or rendered inert. Monitoring shall be conducted throughout the hot work operation to ensure 0% LEL during hot work activities on process piping.

• The following means of isolating for hot work tasks are ranked in order of precedence:

o Prior to starting hot work, positive isolation will be installed by means of rated skillet. Air gapping with installation of blind flange is also acceptable means of



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isolation from pressure source. If this cannot be accomplished due to piping configuration:

o Double block and bleed with locked open bleed point upstream and downstream may be used. P&ID will be referenced to ensure if pneumatic valves serve as isolation valves, they are designed to fail closed upon loss of pneumatic pressure and/or do not required back pressure to seal properly. If this cannot be accomplished due to piping configuration and a single isolation only is available:

o A vented plug will be installed to serve as the double block for isolation. The bleed hose for the isolation plug will be routed and located at least 35’ from the hot work activity

• In certain complex conditions such as a production header or similar circumstance of

multiple inlets, such methods as steaming, flush and fill, and/or continuous nitrogen purge in addition to vented plug installation may be acceptable so long as all other means were considered and additional safeguards employed as necessary

Process Piping Hot Work Procedures

1. Line will be traced by authorized and affected personnel involved in the job. Piping will be isolated; LOTO according to established safe work practice(s), and confirmed to be bled down

2. A "cut here" sticker, stencil, or marker will designate specific cut location and be communicated to all parties involved during walk down pre-job safety analysis and issuance of hot work permit

3. Adequate containment will be installed as applicable in the event residual fluids may be encountered during line cutting

4. Primary cut will be performed using cold-cut equipment and gas monitoring equipment will be used (if applicable) to determine if fluids contain flammable vapors so additional safeguards can be put in place

5. Hot work activities will commence in accordance with the safe work practice and permit. If any part of the work plan is altered, an "all stop" is to be initiated by the work task supervisor and all parties will agree upon safest means with JSA, work pack if applicable, and permit revision as necessary

BSEE Approved Designated Safe Welding and Burning Areas Facilities may have designated safe welding and burning areas. These areas must meet the following criteria:

o Approved by the BSEE District Supervisor with approval letter on file at the facility o Be clearly marked/identified and the facility drawing as safe welding and burning area(s)



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on the facility.

• Safe welding areas will be placed only in unclassified areas as defined by API RP 500

• All safe-welding areas will have solid decking immediately beneath them to prevent welding slag from falling into the water below the facilities or to a lower deck

• There will be no equipment containing hydrocarbons or other flammable substances

within 35 feet horizontally from the safe welding site

• Properly designed and placed welding sheds shall be kept free of flammables around all sides

Prior to the commencement of any welding or burning within an approved designated welding and burning area the Person in Charge (PIC) and/or Project Supervisor shall ensure the following:

• Verify a copy of the BSEE approved designated welding and burning plan and letter is on file

• Review the qualifications of the welder or welders to assure that they are properly

trained and qualified in accordance with ANSI B31.3, AWS D1.1 and/or other applicable welding codes

• Inspect the area in which the work is to be performed for potential fire and explosion

hazards

• Verify all welding and burning equipment has been inspected

Welding, Burning and/or Spark Producing Activities in Undesignated Areas

• If welding, burning or spark producing activities are to be conducted within 10 feet of the well bay, all producing wells in that well bay must be shut in

• If welding, burning or spark producing activities are to be conducted within 10 feet of a production area, all production equipment (i.e. vessels, pumps, tanks, panels, etc.) in that area must be shut in. Process piping is not classified as production equipment

o Welding near process piping without shut-in is allowed as long as the piping and

associated connections are verified to be properly secured, maintained and adequately shielded with fire resistant guards or curtains

• If welding, burning or spark producing activities are to be conducted between 10 and 35 feet of equipment containing hydrocarbons or other flammable substances, on the same level, above or below, the following applies:



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o Relocate equipment at least 35 feet from the welding or burning area o Relocate equipment on lower decks or upper decks at least 35 feet from the point

of impact where slag, sparks, or other burning materials could fall or fly o If moving of equipment is impractical, you must do one of the following:

� Protect equipment with flame-proofed covers � Install shielding using metal or fire resistant guards or curtains (i.e. tarps) � Render any residual flammable substances inert

• NO welding, burning or spark producing activities will be conducted while drilling,

completion, workovers, or conducting wireline operations unless:

o Fluids in the well are non-combustible, and o The entry of formation hydrocarbons into the wellbore have been precluded by

either mechanical means or by a positive overbalance toward the formation

• NO welding, burning or spark producing activities shall be done on containers, tanks, or other vessels which have contained a flammable substance unless:

o The vessel has been either cleaned and degassed or rendered inert. Monitoring shall be conducted throughout the hot work operation to maintain 0% LEL in all areas inside containers, tanks or vessels

o All vessel inlet/outlet piping has been blocked by blanks, or process piping disconnected from the vessel prior to hot work

• During all welding, burning or spark producing activities, one or more persons shall be

designated as a fire watch. The following will be adhered to:

o Persons assigned as a fire watch shall be trained and have adequate skills/knowledge to recognize potential hazards, utilize equipment and initiate emergency response

o No other duties shall be assigned to fire watch during welding or burning operations

o Fire watch shall have useable firefighting equipment available for use. o Fire watch shall maintain continuous surveillance with a portable gas detector

during welding or burning operations. o Fire watch shall remain on duty for at least 30 minutes after welding or burning

operations have ceased.

• All water discharge point sources from hydrocarbon handling vessels shall be monitored as necessary by designated qualified personnel, in order to stop operational activities in the case of flammable fluids discharged as a result of equipment upset or malfunction.

• Hot tapping operations shall only be conducted with BSEE and Fieldwood Engineering

approval

• After it has been determined that it is safe to proceed with the welding, burning or spark



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producing activities, the designated person-in-charge (PIC) and/or Project Supervisor shall issue written authorization for the work using the Welding and Burning Authorization - Hot Work Permit – see Section D, chapter 15, Part A)

Fieldwood Energy LLC • 2000 W. Sam Houston Pkwy S., Suite 1200 • Houston, Texas 77042 • (713) 969-1000

October 20, 2020

Mr. James Fletcher

U.S. Department of the Interior

Bureau of Safety and Environmental Enforcement

Gulf of Mexico OCS Region

1201 Elmwood Park Blvd.

New Orleans, LA 70123

RE: Revised Welding, Burning and Hot Work Safe Practices Plan

Mr. Fletcher,

Fieldwood hereby submits the enclosed, revised Welding, Burning & Hot Work Safe Practices Plan

for your review and approval on the following entities listed below located within the physical

boundaries and jurisdiction of all Gulf of Mexico BSEE Districts in which we operate under:

Fieldwood Energy LLC Operator # 03295

Fieldwood Energy Offshore LLC Operator # 03035

GoM Shelf LLC Operator # 02451

Fieldwood SD Offshore LLC Operator # 02865

Bandon Oil & Gas, LP Operator # 02894

Dynamic Offshore Resources NS, LLC Operator # 02630

Fieldwood Energy SP LLC Operator # 02636

The enclosed, revised plan includes the required standards, requirements, practices, and

procedures for safe welding and burning, in accordance with 30 CFR 250.109 through 113.

Your favorable consideration of the attached, revised Welding, Burning, & Hot Work Safe

Practices Plan is greatly appreciated. If you have any questions or assistance is required, please

contact our Regulatory Director by phone (713) 969-1084 or via email at

[email protected].

Sincerely,

Vice President Senior Vice President - Production

mailto:[email protected]

Documents

Submittal Overview...• Review the qualifications of the welder(s) to assure that they are properly trained and qualified in accordance with ANSI B31.3, AWS D1.1 and/or other applicable