Helis Oil & Gas Company, L .L .C. 228 ST. CHARLES AVENUE, SUITE 912

NEW ORLEANS, LA 70130 Telephone: (504) 523-1831

Facsimile: (504) 522-6486

February 21, 2017

Mr. Bryan Domangue Acting Regional Supervisor Office of Field Operations Bureau of Safety and Environmental Enforcement 1201 Elmwood Park Blvd. New Orleans, Louisiana 70123-2394

Bureou ol Sofety and Environmentol Enforcement (BSEE)

R E C E I V E D FEB 2 2 2017

Office of Fieid Operations Pipeline Section

Attn:

RE:

Angie Gobert Pipeline Section Chief

Application for Relinquishment of Right-of-Way No. OCS-G 28302 and Proposed Abandonment In Place of 4-Inch Bulk Gas Right-of-Way Pipeline Segment No. 17027, Originating at Galveston Block 350 C Platform and Terminating at Galveston Block 355 A Platform, OCS Federal Waters, Gulf of Mexico. Offshore, Texas

Ladies / Gentlemen:

In accordance with the regulations contained in Title 30 CFR 250.1019 and 250.1751, Helis Oil & Gas Company, LL.C. ("Helis") hereby requests approval to relinquish the Right-of-Way No. OCS-G 28302 and abandon in place the existing 4-inch bulk gas pipeline, Segment No. 17027. originating at Galveston Block 350 C Platform and terminating at Galveston Block 355 A Platform, Offshore, Texas.

The pipeline, which is approximately 2.22 miles in length, will be relinquished and abandoned in-place, in its entirety, as shown in the attached Pipeline Abandonment and Decommissioning Procedure. The pipeline was placed out-of-service October 18, 2016. Additionally, Helis hereby requests a departure from 30 CFR 250.1751(b) which requires pigging of the pipeline. The pipeline will be flushed with 1.5 times the pipeline volume to ensure the pipeline is clear of hydrocarbons.

Also enclosed is a PayGov receipt in the amount of $2170 to cover the processing fee. The proposed abandonment in place operations are scheduled to commence on or about April 1, 2017, dependent upon permit approvals and scheduling of contractor personnel.

Should you have any questions or require additional information, please contact Courtney Feik, J. Connor Consulting, Inc., at (281) 578-3388 or courtney.feik@jccteam.com.

Sincerely,

=5 David A. Kerstein President and Treasurer of Helis Energy, L L C. Manager of Helis Oil & Gas Company, LL.C.

DAK:cf Enclosures

Courtney Feik

From: notification@pay.gov Sent: Tuesday, February 21, 2017 8:44 AM To: Courtney Feik Subject: Pay.gov Payment Confirmation: BSEE Application to Decommission a ROW Pipeline

BU '

Your payment has been submitted to Pay.gov and the details are below. If you have any questions regarding this payment, please contact Brenda Dickerson at (703) 787-1617 or BseeFinanceAccountsReceivable@bsee.gov.

Application Name: BSEE Application to Decommission a ROW Pipeline - BU Pay.gov Tracking ID: 260PPPCR Agency Tracking ID: 75189489218 Transaction Type: Sale Transaction Date: 02/21/2017 09:44:24 AM EST

Account Holder Name: Jane C. Fiegler

Transaction Amount: $2,170.00 Card Type: AmericanExpress Card Number: ************3000

Region: Gulf of Mexico Contact: Courtney Feik 281-578-3388 Company Name/No: Helis Oil Gas Company, LLC, 01978 Pipeline Segment No: 17027 Originating Area/Block: Galveston GA, 350 Terminating Area/Block: Galveston GA, 355

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY.

HELIS OIL & GAS COMPANY. L.L .C. 228 SAINT CHARLES AV ENUE SUITE 912

NEW ORLEANS, LA 70130

Procedure for Abandonment and Decommissioning of Galveston Block 350 ^ C " - 4" Bulk Gas Pineline - Segment # 17027

Revision A

1. Objective

Helis Oil & Gas Company, L.L.C. proposes the following procedure for the abandonment and decommissioning of pipeline segment #17027 beginning at Galveston Block 350 "C" Braced Caisson and terminating at Galveston Block 355 "A" Tripod Structure.

Segment #17027 Size: 4.500"'OD x 0.337"w.t. (3.826"1D) Total Length: 11.710 fl Service: Bulk Gas Pipeline Volume: 171 bbl (7,169 gal)

GA 350 "C" Location: X = 3,312,338' Lat = 28° 43* 17.66" N (NAD 27) Y = 345,940" Long = 94° 54' 16.88" W (NAD 27)

GA 355 ' A " Location: X = 3,318,819' Lat = 28° 41' 38.91" N (NAD 27) Y = 336,188* Long = 94° 53' 07.98"' W (NAD 27)

2. Scope of Work

The scope of work for abandonment of pipeline segment #17027 shall consist of the following:

• Verify pipeline pressure is at 0 psig. if not, bleed down pipeline through water/oil handling equipment located at GA 355 "A" ensuring all hydrocarbons are captured and seawater is discharged overboard. A static sheen and oil & grease lest must be performed on sile to ensure the pipeline is suitable for abandonment per the BSEE requirements.

• Flush 4"" pipeline segment # 17027 with minimum 1.5 volumes (approximately 257 bbls or 10,773 gal) of seawater from GA 350 "C" through water/oil handling equipment located at GA 355 "A" ensuring all hydrocarbons are captured and seawater is discharged overboard. A static sheen and oil & grease test must be performed on site to ensure the pipeline is suitable for abandonment per the BSEE requirements. In the event sea conditions prohibit discharge of seawater overboard, then the fluids will be captured in the 500 bbl DOT tanks on the marine vessel, where they will be later properly disposed of.

At GA 350 "CM, cold cut pipeline approximately 20 ft downstream of tube turn and 5 ft upstream of tube turn, install plumber's plug in open end of pipeline and riser. Retrieve piping assembly with tube turn and check for NORM as required and ensure proper documentation is filled out. At GA 355 "A", cold cut pipeline approximately 20 ft upstream of tube turn and 5 ft downstream of tube turn, install plumber's plug in open end of pipeline and riser. Retrieve piping assembly with tube turn, check for NORM as required, and ensure proper documentation is filled out. At GA 350 "C" and GA 355 "A", cover fittings and pipe with sand bags to ensure there is a minimum of 3 ft cover or natural bottom, whichever is greater. Any sand bags installed above mud line must be on a 1:3 slope (rise:run).

3. Procedure

3.1. GA350"C" Platform

3.1.1. Mobilize marine vessel with Helis Representative, Helis Operations, dive crew/equipment and flushing crew/equipment to GA 350 "C".

3.1.2. Verify pipeline pressure is at 0 psig, if not, bleed down pipeline through water/oil handling equipment located at GA 355 "A" ensuring all hydrocarbons are captured and seawater is discharged overboard. A static sheen and oil & grease test must be performed on site to ensure the pipeline is suitable for abandonment per the BSEE requirements.

3.1.3. Once pipeline is bled down to 0 psig, connect low pressure/high volume pump with high pressure hose to top of 4" riser located at GA 350 "C", which will be isolated from topsides piping during cleaning operations. Cleaning operations will be completed prior to pipeline P&A mobilization.

3.1.4. Standby until crew at OA 355 "A" is ready to receive fluids for thc pipeline Qush.

3.2 GA 355 "A" Platform

3.2.1 Mobilize marine vessel with Helis Representative, Helis Operations and flushing crew/equipment to location.

3.2.2 Verify pipeline pressure is at 0 psig, if not, bleed down pipeline through water/oil handling equipment located at GA 355 "A" ensuring all hydrocarbons are captured and seawater is discharged overboard. A static sheen and oil & grease test must be performed on site to ensure the pipeline is suitable for abandonment per the BSEE requirements.

3.2.3 Once the pipeline is bled down to 0 psig, connect the high pressure hose from the top of 4" riser located at GA 355 "A" to the inlet of the water/oil handling equipment located on the marine vessel. The top of the riser will be isolated from topsides piping during cleaning operations, which will be completed prior to pipeline P&A mobilization.

3.2.4 Standby until crew at GA 350 "C" is ready to flush 4" pipeline.

3.3 Flushing Pipeline from GA 350 "C" to GA 355 "A"

3.3.1 Test communications between two locations to ensure all is working properly.

3.3.2 Ensure all flushing equipment is hooked up correctly. Both Helis Representatives to sign off on prior to starting this operation.

3.3.3 Flush 4" pipeline with minimum 1.5 volumes (approximately 257 bbls or 10,773 gal) of seawater from GA 350 "C" through pipeline segment #17027 into water/oil handling equipment on the marine vessel, ensuring all hydrocarbons are captured and seawater is discharged overboard. A static sheen and oil & grease test must be performed on site to ensure the pipeline is suitable for abandonment per the BSEE requirements. In the event sea conditions prohibit the discharge of seawater overboard, then the 2" high pressure hose will be connected to the 500 bbl DOT tanks on the marine vessel.

3.3.4 Ensure product is clean and within BSEE requirements prior to disconnecting Hushing equipment. This must be verified with a static sheen and oil & grease test as indicated above.

3.3.5 Ensure 0 psig on 4" pipeline. 3.3.6 Disconnect flushing equipment and blind off top of 4" risers at GA 350 " C and

GA 355 "A". Install tag on blind flange indicating the date at which pipeline P&A was completed.

3.4 Cut / Plug Pipelines at GA 350 "C "

3.4.1 Ensure 0 psig on 4" pipeline at GA 350 "C". 3.4.2 Jump divers and jet to expose 4" pipeline approximately 20 ft downstream from

tube turn. 3.4.3 Cold cut 4" pipeline approximately 20 ft downstream from tube turn and install

plumber's plug in open ends of pipeline. 3.4.4 Cold cut 4" pipeline approximately 5 ft upstream of tube turn and install

plumber's plug in open ends of pipeline and riser. 3.4.5 Recover and properly dispose piping assembly with tube turn attached. Check for

NORM as required and ensure proper documentation is filled out. 3.4.6 Cover all fittings and pipe with sand bags to ensure there is a minimum of 3 ft of

cover or natural bottom, whichever is greater. Any sand bags installed above mud line must be at 1:3 slope (rise:run).

3.4.7 Relocate marine vessel with personnel and equipment to GA 355 "A" once all parties are in agreement that all work is completed at GA 350 "C".

3.5 Cut / Plug Pipelines at GA 355 "A"

3.5.1 Ensure 0 psig on 4" pipeline at GA 355 "A" 3.5.2 Jump divers and expose 4" pipeline approximately 20 ft out from tube turn. 3.5.3 Cold cut 4" pipeline approximately 20 ft upstream from tube turn and install

plumber's plug in open ends of pipeline. 3.5.4 Cold cut 4" pipeline approximately 5 ft downstream of tube turn and install

plumber's plug in open ends of pipeline and riser. 3.5.5 Recover and properly dispose piping assembly with tube turn attached. Check for

NORM as required and ensure proper documentation is filled out. 3.5.6 Cover all fittings and pipe with sand bags to ensure there is a minimum of 3 ft of

cover or natural bottom, whichever is greater. Any sand bags installed above mud line must be at 1:3 slope (rise:run).

3.5.7 Demobilize marine vessel with personnel and equipment once all parties are in agreement that all work is completed at GA 355 "A". Properly dispose of any miscellaneous material.

3.6 Conclusion

3.6.1 The 4" bulk gas pipeline, segment #17027, shall be abandoned in place, left filled with seawater with plumber's plugs installed on each end, and all fittings and pipe shall be covered with sand bags to ensure there is a minimum of 3 ft ofcover or natural bottom, whichever is greater. Any sand bags installed above mud line must be at 1:3 slope (rise:run).