In Reply Refer To: GE 1035A

Ms. Patty Brewer Talos Energy Offshore LLC 500 Dallas Street, Suite 2000 Houston. TX 77002

Dear Ms. Brewer:

V ^ H ^ U ^ A U J September 6. 2018

Reference is made to Talos Energy Offshore LLC's (Talos) Right-of-way (ROW) decommissioning modification application, dated November 1. 2017. and received by this office on November 3, 2017, for Pipeline Segment Number (PSN) 12017, ROW No. OCS-G29025. This application was amended with a submittal received by this office on August 6. 2018.

Specifically, Talos requests to modify previously approved decommissioning application for PSN 12017. To date, 2,190" of pipe has been removed and the remaining 9,803" of pipe will be removed using a reverse pipe lay method.

The table below describes the Pipeline Segment pertaining to the aforementioned application:

PSN Size (NPS)

Length (feet)

Service Origin Termination

12017 3 11.994 Gas/Condensate Caisson No. 1

Vermilion Area Block 87

16-Inch SSTI Vermilion Area

Block 87

Pursuant to 30 CFR 250.1000(b). your application is hereby approved.

You must complete the aforementioned decommissioning operations within 180 days of the date of this letter and a decommissioning completion report must be submitted to this office within 30 days of completing the decommissioning.

Sincerely.

(org. sgd.) J. Caraher

(for) Bryan A. Domangue Acting Regional Supervisor Regional Field Operations

be: 1502-01 Pipeline Segment Number 12017 wilh application (GE 1035A) 1502-01 ROW No. OCS-G29025 (Scanning) (GE 274E)

TAL®S E N E R G Y I L C

November 1, 2017 **Amended July 26. 2018**

U. S. Department of the Interior Bureau of Safety and Environmental Enforcement Gulf of Mexico OCS Region 1201 Elmwood Park Boulevard New Orleans, LA 70123-2394

Attention: Joan Hall GE1035A

RE: Amended Pipeline Modification Application for Segment No 12017, Associated with Relinquished ROW (OCS-G 29025), Vermilion Block 87, OCS Federal Waters, Gulf of Mexico

Dear Ms. Hall:

By letter dated November 1, 2017, Talos Energy Offshore LLC (Talos) submitted a pipeline modification application requesting approval to remove approximately 2190' of the 11,993' pipeline and decommission-in-place approximately 9803' of the 11,993' pipeline found to be buried too deep for removal.

To recap, pipeline removal operations began 8/21/2017 and continued until 9/16/2017, at which point removal operations were suspended due to deep pipeline burial, the difficulty of keeping the jet sled on the pipeline due to excessive burial depth, and working conditions in the jetted ditch becoming unsafe for divers.

By email dated 4/16/2018, BSEE requested Talos submit an amendment to the modification application with a procedure to remove the remaining portion of the pipeline due to its location in a significant sediment resource area.

Attached is proposed pipeline procedure outlining steps to complete removal of the remaining buried pipeline.

To date, Talos has flushed and filled, disconnected both ends of the pipeline and removed approximately 2190' of the 11,993' pipeline. Approximately 9803' of the pipeline remains in place. The attached Oceaneering survey report details the pipe that has been removed, end of pipe (EOP) and burial data encountered with the spud barge.

TALOS ENERGY OFFSHORE, LLC 500 Dallas Street, Suite 2000, Houston, Texas 77002-4800

Application for Pipeline Modification of VR 87 Pipeline Segment No. 12017 Amended July 26, 2018 Page Two

A brief recap of the pipeline removal is outlined below.

February 2, 2017: The pipeline was flushed and filled with sea water.

May 20 , h thru May 25 t h 2017: The dive vessel "Triton Crusader" was mobilized to the field and

disconnected the pipeline at the SSTI end (VR 87) and the platform riser end (VR 87 A Platform). The dive vessel spent considerable time to locate the pipeline at the SSTI end as it was buried 10' BML.

All drawings produced by Kinetica indicated the pipeline should have been buried at most 3' BML. Although the dive vessel successfully disconnected the pipeline at the SSTI end, the safety of the divers was a concern throughout the phase due to the unstableness of the sandy soils. The divers also successfully disconnected the pipeline from the riser at the VR 87 A platform end. The pipeline was buried 6' on the riser end.

June 13 thru June 16 l h , 2017: Shore Offshore removed the VR 87 A platform and A001 well casings as per the platform removal and site clearance verification permit approved on January 24, 2017.

August 2 1 s t thru 23 r d , 2017: The Broussard Brothers spud barge BB 90 mobilized to the field and began pipeline removal operations. The BB 90 set up at the former location of the VR 87 A platform and was unsuccessful in locating the 3" pipeline even though the coordinates of the EOP were known. The bottom soils were tightly packed sand and would not maintain an open ditch. The BB 90 then set up and located Kinetica's 36" pipeline SN 3478 in an attempt to locate the 3" crossing but were unsuccessful. The BB 90 then set up on the SSTI to locate the SSTI. The BB 90 located the 3" EOP at the location and depth that Triton left it. The BB 90 then picked up the EOP and began the removal operations. The barge removed 3 sections of pipe and then the pipe became too deep in burial and the barge could not remove any additional pipe. The barge then set up at the platform end and charged the pipeline with air in order to locate the EOP. The BB 90 picked up the EOP and began removal operations on the platform end and recovered 3 sections of pipe before the pipe became buried too deep and recovery operations could not continue.

August 24 t h thru September V 1 , 2017: Waiting on weather at ICY, LA due to Hurricane Harvey.

September 4 , h , 2017: BB 90 back on location and attempted to recover pipeline a second time setting up at the platform end and the SSTI end with very little success due to pipe being buried too deep. The BB 90 proceeded along the 3" pipeline route and at various locations set the spuds to determine if anywhere along the length the soils had changed. The soils were consistent along the entire length of the 3" pipeline.

September 5 t h thru 13 t h , 2017: Waiting on weather at ICY, LA.

TALOS ENERGY OFFSHORE, LLC 500 Dallas Street, Suite 2000, Houston, Texas 77002-4800

Application for Pipeline Modification of VR 87 Pipeline Segment No. 12017 Amended July 26, 2018 Page Three

September 14 t h thru 16 t h , 2017: Mobilized both the BB 90 and the BB 70 (Jet barge). The BB 70 set up in front of the BB 90 in an attempt to uncover the pipe with the jet sled as the BB 90 recovers pipe. The pipe was buried to 8' BML at the EOP on the platform end and quickly became deeper. The jet sled would not stay on the pipe due to the instability of the bottom conditions. The equipment then set up on the east end and the results were the same. The pipe was buried too deep and the bottom soils would not maintain a ditch. In the last attempt, the equipment was set up at midpoint of the 3" pipeline. The jet sled was set at 8' and moved 200' south of the 3" to 200' north of the 3" pipeline. The jet sled did not find the pipeline which determined the pipe was buried more the 8' at that location. Due to the deep pipeline burial depth, the soft sandy soils that result in the inability of a jet sled being capable of maintaining an open ditch and concern for diver safety, Talos respectfully requests approval for modification of the pipeline to remove portion of the pipeline (2191') and decommission the remaining 9,803' portion of the pipeline-in-place.

Attached is copy of the Pipeline Decommission and Removal report, as-built location plat, Oceaneering area map with details of pipe removed, end of pipe (EOP) and burial data encountered with the spud barge. Also included is PayGov receipt in the amount of $4,169 for the associated cost recovery fee.

If you have any questions or should need any additional information, please contact me at (713) 328-

3016 or via email at pbrewer(g)talosenerRvllc.com.

Sincerely,

Talos Energy Offshore LLC

Patty Brewer

Regulatory Specialist

Attachments

MiOS ENERGY OFFSHORE, LLC 500 Dallas Street, Suite 2000, Houston, Texas 77002-4800

T A L ® S E N C R O Y I N C

TALOS ENERGY OFFSHORE, LLC VERMILION 87 AREA

PIPELINE ABANDONMENT SEGMENT NO. 12017

PROPOSED PIPELINE ABANDONMENT

1) RESPONSIBLE PARTY

a. Pipeline Operator Name: Talos Energy Offshore, LLC

Address: 500 Dallas St. Suite 2000 Houston. TX 77002-4727

c. Contact person(s) : Title : Phone : Email ;

d. Shore Base:

2) PIPELINE INFORMATION

Patty Brewer Gene Williams

3)

Regulatory Specialist 713-328-3016 pbrewer@talosenergyllc.com

Facilities Engineering Manager 713-328-3060 gwilliams@talosenergyllc com

Fourchon. LA

a Segment Number: 12017 BSEE Status: PABN b Size (inches): 3.5" O.D. c Length (feet): 11.993 ft. d Service; Gas/Condensate e. From: Id. Name: "A" Complex ID No.: 279-1

Area/Block: Vermilion 87 OCS Lease: RUE-G-30297 Coordinates:

Latitude: 29° 13'41.705" N Longitude: 92° 23' 07.155" W X: 1,664,434 ft. Y: 205,762 ft.

f. To: Id. Name 16" SSTI (Transco S-1584) Complex ID No : .... Area/Block Vermilion 87 OCS Lease: G-15169

Coordinates: Latitude: 29° 13" 03.396" N Longitude: 92° 21'00.137" W X: 1.675.654 ft. Y: 201,791 ft.

g ROW Number: G-29025 BSEE Status: ACT

PIPELINE DESCRIPTION

a Configuration: Platform riser to subsea tie-in b. Install Date (Year): 1998 c Size: Diameter (in.): 3.5" Wall Thickness: 0.300" Length: 11,993 ft. d Volume: 99 bbls e. Water Depth (ft.): 31 ft (VR 87-A Platform). 25 ft. (VR 87 16" SSTI) f. Buried: Yes - minimum 3 ft. g Present Status: Abandoned and partially removed

4) PURPOSE

a. Description: b. Length Removed c. Length to Remain d. Reason: e. Proposed Aban. Date:

Abandon and remove pipeline To date approximately 2.190' of pipe has been removed. 9.803' remains to be removed. 0 ft Production depleted Source platform to be removed August, 2018.

Issue Date: 07/24/18 Revision Page 1 of 2

T A L ® S l N I 6 O Y I N C

TALOS ENERGY OFFSHORE, LLC VERMILION 87 AREA

PIPELINE ABANDONMENT SEGMENT NO. 12017

PROPOSED PIPELINE ABANDONMENT (Continued)

5) PROPOSED PROCEDURE

a. Brief description of the method to be used:

Pipeline segment 12017 was flushed and filled with seawater on 2/2/2017. The BSEE granted a waiver on pigging during final decommissioning. The BSEE approved the Talos request to abandon S-12Q17 at the VR 87-A platform and at the VR 87 16" subsea tie-in then remove the pipeline at a later date.

Divers completed disconnecting the S-12017 pipeline at the VR 87-A caisson and at the VR 87 16" subsea tie-in on 5/25/2017.

Pipeline removal operations began on 8/21/2017 and continued until 9/16/2017 at which point removal operations were suspended due tc deep pipeline burial, the difficulty of keeping the jet sled on the pipeline due to the excessive burial depth, and working conditions in the jetted ditch becoming unsafe for divers. Buoys were set and survey coordinates were taken on each end of the remaining pipeline.

Proposed method to complete the pipeline removal :

The remaining 3" pipeline will be removed by a "reverse pipe lay" method. A 4-pt. DSV will locate the end of the 3" pipeline, attach a cable to a winch mounted on the back deck, and recover the end of the pipeline to the surface. The vessel will pull itself under the pipeline while keeping the pipeline under tension with the winch, pulling the pipeline out of the mud. As the pipeline is pulled onto the back deck of the DSV it will be cut into sections approximately 60' long. Scrap pipe will be taker to shore for disposal.

M "

b. If using an anchored vessel, provide an anchor plat or maximum radius of anchors. Maximum 4000 ft. anchor radius for 4-pt anchor vessel in 20 to 30 ft. water depth.

6) ATTACHMENTS

Abandonment drawings Pipeline segment S-12017 - Current Status

Issue Date: 07/24/18 Revision 1 Page 2 of 2