UNITED STATES GOVERNMENT MEMORANDUM

To: Public Information (MS 5030)

Plans Section, Office of Field Operations (MS 5231)

Public Information copy of Exploration Plan

Control # - N-09849

Type - Initial Exploration Plan

Lease(s) - OCS-G35431 Block - 198 Atwater Valley Area

Operator - Freeport-McMoRan Oil & Gas LLC

Subsea wells A, B, C, D, E (AT198)

Not Found

Attached is a copy of the subject plan for public comments on issues that
should be addressed in an Environmental Assessment.

It has been deemed submitted as of this date and is under review for approval.

Tommy Hoke

Plan Coordinator Description -

Rig Type - Subject: From: December 30, 2014

### PUBLIC COPY
December 4

, 2014



## INITIAL
EXPLORATION PLAN

Atwater Valley Block 198
OCS

- G 35431 Prospect Name : Sun
Affected State s: Louisiana and Mississippi

Estimated Startup Date: February 26

, 2018

SUBMITTED BY : Freeport

- McMoRan Oil & Gas LLC
400 E . Kaliste Saloom, Suite 1100 Lafayette, Louisiana 70508

Paul Landry
Office: 337

- 354

- 5065, Cell: 337

- 349

- 7781

paul_landry@fmi.com

AUTHORIZED REPRES ENTATIVE:

Callie Hutchinson J. Connor Consulting, Inc.
16225 Par k Ten Place, Suite 700 Houston, Texas 77084 (281) 698

- 8545 callie.hutchinson@jccteam.comTOC Pg 1 of 3 TABLE OF CONTENTS

SECTION 1 PLAN CONTENTS

................................ ................................ ................................ . 1

1.1 PLAN INFORMATION

................................ ................................ ................................ ...... 1

1.2 LOCATION

................................ ................................ ................................ ....................... 1

1.3 SAFETY AND POLLUTION PREVENTION FEATURES

................................ .................. 1

1.4 STORAGE TANKS AND PRODUCTION VESSELS

................................ ......................... 1

1.5 POLLUTION PREVENTION MEASURES

................................ ................................ ........ 2

1.6 ADDITIONAL MEASURES

................................ ................................ ............................... 2

1.7 COST RECOVERY FEE

................................ ................................ ................................ ... 2

SECTION 2 GENERAL INFORMATION

................................ ................................ .................... 3

2.1 APPLICATIONS AND PE RMITS

................................ ................................ ...................... 3

2.2 DRILLING FLUIDS

................................ ................................ ................................ ........... 3

2.3 NEW OR UNUSUAL TECHNOLOGY

................................ ................................ ............... 3

2.4 BONDING STATEMENT

................................ ................................ ................................ .. 3

2.5 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR)

................................ .......................... 3

2.6 DEEPWATER WELL CONTROL STATEMENT

................................ ................................ 3

2.7 BLOWOUT SCENARIO AND WORST CASE DISCHARGE CALCULATIONS

................. 4

SECTION 3 GEOLOGICAL AND GEOPHYSICAL INFORMATION

................................ .......... 7

3.1 GEOLOGICAL DESCRIPTION

................................ ................................ ......................... 7

3.2 STRUCTURE CONTOUR MAPS

................................ ................................ ...................... 7

3.3 INTERPRETED SEISMIC LINES

................................ ................................ ..................... 7

3.4 GEOLOGICAL STRUCTURE CROSS

- SECTIONS

................................ .......................... 7

3.5 SHALLOW HAZARDS REPORT

................................ ................................ ...................... 7

3.6 SHALLOW HAZARDS ASSESSMENT

................................ ................................ ............. 7

3.7 HIGH

- RESOLUTION SEISMIC LINES

................................ ................................ ............. 7

3.8 STRATIGRAPHIC COLUMN

................................ ................................ ............................ 7

3.9 TIME VERSUS DEPTH TABLES

................................ ................................ ...................... 7

SECTION 4 HYDROGEN SULFIDE INFORMATION

................................ ................................ 8

4.1 CONCENTRATION

................................ ................................ ................................ .......... 8

4.2 CLASSIFICATION

................................ ................................ ................................ ............ 8

SECTION 5 BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION

................... 9TOC Pg 2 of 3

5.1 DEEPWATER BENTHIC COMMUNITIES

................................ ................................ ........ 9

5.2 TOPOGRAPHIC FEA TURES (BANKS)

................................ ................................ ............ 9

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING)

................................ ............... 9

5.4 LIVE BOTTOMS (PINNACLE TREND FEATURES)

................................ ......................... 9

5.5 LIVE BOTTOMS (LOW RELIEF)

................................ ................................ ...................... 9

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP

................................ ........... 9

5.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS

................................ .................... 9

5.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND MARINE

MAMMAL INFORMATION

................................ ................................ .............................. 10

5.9 ARCHAEOLOGICAL REPORT

................................ ................................ ........................ 11

5.10 AIR AND WATER QUALITY INFORMATION

................................ ................................ 11

SECTION 6 WASTES AND DISCHARGES INFORMATION

................................ ................... 12

6.1 PROJECTED GENERATED WASTES

................................ ................................ ............ 12

6.2 MODELING REPORT

................................ ................................ ................................ ...... 12

SECTION 7 AIR EMISSIONS INFORMATION

................................ ................................ ........ 13

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS

................................ ...... 13

7.2 SUMMARY INFORMATION

................................ ................................ ............................ 13

SECTION 8 OI L SPILL INFORMATION

................................ ................................ .................. 14

8.1 OIL SPILL RESPONSE PLANNING

................................ ................................ ................ 14

8.2 SPILL RESPONSE SITES

................................ ................................ ............................... 14

8.3 OSRO INFORMATION

................................ ................................ ................................ .... 14

8.4 WORST CASE SCENARIO DETERMINATION

................................ ............................... 14

8.5 OIL SPILL RESPONSE DISCUSSION

................................ ................................ ............ 15

8.6 MODELING REPORT

................................ ................................ ................................ ...... 15

SECTION 9 ENVIRONMENTAL MONITORI NG INFORMATION

................................ ............ 16

9.1 MONITORING SYSTEMS

................................ ................................ ............................... 16

9.2 INCIDENTAL TAKES

................................ ................................ ................................ ....... 16

9.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY

................................ .... 16

SEC TION 10 LEASE STIPULATIONS INFORMATION

................................ .......................... 17

10.1 MARINE PROTECTED SPECIES

................................ ................................ ................. 17

SECTION 11 ENVIRONMENTAL MITIGATION MEASURES INFORMATION

....................... 19

11.1 MEASURES TAKEN TO AVOID, MINIMIZE, AND MITIGATE IMPACTS

...................... 19

11.2 INCIDENTAL TAKES

................................ ................................ ................................ ..... 19TOC Pg 3 of 3

SECTION 12 SUPPORT VESSELS AND AIRCRAFT INFORMATION

................................ ... 20

12.1 GENERAL

................................ ................................ ................................ ..................... 20

2.2 DIESEL OIL SUPPLY VESSELS

................................ ................................ ..................... 20

12.3 DRILLING FLUID TRA NSPORTATION

................................ ................................ ......... 20

12.4 SOLID AND LIQUID WASTE TRANSPORTATION

................................ ....................... 20

12.5 VICINITY MAP

................................ ................................ ................................ ............... 20

SECTION 13 ONSHORE SUPPORT FACILITIES INFORMATION

................................ ......... 21

13. 1 GENERAL

................................ ................................ ................................ ..................... 21

13.2 SUPPORT BASE CONSTRUCTION OR EXPANSION

................................ ................. 21

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE

............................. 21

13.4 WASTE DISPOSAL

................................ ................................ ................................ ....... 21

SECTION 14 COASTAL ZONE MANAGEME NT ACT (CZMA) INFORMATION

..................... 22

SECTION 15 ENVIRONMENTAL IMPACT ANALYSIS

................................ ........................... 25

SECTION 16 ADMINISTRATIVE INFORMATION

................................ ................................ ... 26

16.1 EXEMPTED INFORMATION DESCRIPTION

................................ ................................ 26

16.2 BIBLIOGRAP HY

................................ ................................ ................................ ............ 26Attachments Pg 1 of 1 SECTION ATTACHMENTS

Section 1 Plan Contents

1

- A OCS Plan Information Form

1

- B Well Location Plat

1

- C Bathymetry Map

1

- D Pay.gov Receipt
Section 3 Geological, Geophysical Information

3

- A Shallow Hazard Assessment
Section 5 Biological, Physical and Socioeconomic Information

5

- A Biologically Sensitive Underwater Features and Areas Map
Section 6 Wastes and Discharges Information

6

- A Wastes You Will Generate, Treat and Downhole Dispose or Discharge to

the GOM
Section 7 Air Emissions Information

7

- A Emissions Worksheets
Section 8 Oil Spill Information

8

- A Oil Spill Response Discussion
Section 12 Support Vessels and Aircraft Information

12

- A Waste You Will Transport and/or Dispose Onshore

12

- B Vicinity Map
Section 14 Coastal Zone Management Act Information

14

- A Coastal Zone Consistency Certifications , Louisiana

14

- B Coastal Zone Consistency Certifications , Mississippi
Section 15 Environmental Impact Analysis (EIA)

15

- A Environmental Impact Analysis (EIA)Freeport

- McMoRan Oil & Gas LLC Section 1

– Pg. 1 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 1

PLAN CONTENTS

1.1 PLAN INFORMATION Under this Exploration Plan, Freeport

- McMoRan Oil & Gas LLC ( FM O&G ) proposes to drill, complete, test, flare and install subsea trees on five wells. T he wells will be drilled with a dynamically positioned drillship MODU similar to the Transocean Deepwater Champion , and are located in approximately 4,855 feet of water.

The OCS Plan Information Form BOEM

- 137 is i ncluded as Attachment 1

- A

.

1.2 LOCATION

A Well Location Plat depicting the proposed surface and bottom hole locations of the proposed

wells

, measured depth/t rue vertical depth and water depth for each location is included as

Attachment 1

- B

.

A Bathymetry Map depicting the proposed surface locations and water depth of each proposed

well is included as Attachment 1

- C

.

No anchors are associated with the proposed activities in this plan.

1.3 SAFETY AND POLLUTION PREVENTION FEATURES

FM O&G proposes to drill the wells with a dynamically positioned drillship which is equipped

with a Subsea BOP

. Once a rig is determined , BOP information and schematics will be included as a part of the Application for Permit to Drill.

The rig will be equipped with safety and fire

- f ighting equipment required to comply with United States Coast Guard (USCG) regulations. Appropriate life saving equipment such as life rafts, life jackets, ring buoys, etc. as prescribed by the USCG, will be maintained on the rig at all times.

Safety feat ures on the drilling unit will include well control, pollution prevention, and blowout prevention equipment as described in BSEE regulations 30 CFR 250 C, D, E, O, Q and S; and as further clarified by BSEE Notices to Lessees, and current policy making invo ked by the BSEE, Environmental Protection Agency and the U.S. Coast Guard (USCG)

.

Pollution prevention measures include installation of curbs, gutters, drip pans, and drains on drilling deck areas to collect all contaminants and debris. Compliance will b e maintained with the EPA NPDES Permit. The rig will be monitored daily and any waste or fuel resulting in pollution of the Gulf waters will be reported to the representative in charge for immediate isolation and correction of the problem. Any spill will b e reported to the appropriate governmental agencies.

1.4 STORAGE TANKS AND PRODUCTION VESSELS
The table below provides storage tanks with capacity of 25 barrels or more that will store fuels

, oil and lubricants.Freeport

- McMoRan Oil & Gas LLC Section 1

– Pg. 2 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) Type of Storage Tank Type of Facility Tank

Capacit y (bbl ) Number

of Tanks Total

Capacity ( bbl ) Fluid

Gravity (API)

Fuel Oil DPDS 4,135.6 2 8,271.2 33 ̊

Fuel Oil DPDS 9,340.4 2 18,680.8 33 ̊

Fuel Oil DPDS 9,048.5 1 9,048.5 33 ̊

Fuel Oil DPDS 9,043.5 1 9,043.5 33 ̊

Fuel Oil DPDS 445.3 2 830.6 33 ̊

Fuel Oil DPDS 320.2 2 640.3 33 ̊

Fuel Oil DPDS 359.8 1 359.8 33 ̊

Fuel Oil DPDS 435.3 1 435.3 33 ̊

Fuel Oil DPDS 59.8 1 59.8 33 ̊

Base Oil DPDS 3,683.9 1 3,683.9 31 ̊

Base Oil DPDS 3,687.1 1 3,687.1 31 ̊

Lube Oil DPDS 429.6 1 429.6 22.3o

Waste Oil DPDS 132.1 1 132.1 20o

Waste Oil DPDS 44 1 44 20o

Waste Oil DPDS 143.4 1 143.4 20o

Waste Oil DPDS 1,366.2 1 1,366.2 6.5o



### 1.5 POLLUTION PREVENTION MEASURES These operations do not propose activities for which the State of Florida is an affected state.

1.6 ADDITIONAL MEASURES

FM O&G does not propose any additional safety, pollution prevention, or early spill detection measures beyond those required by 30 CFR 250.

1.7 COST RECOVERY FE E Documentation of the $ 1 8

, 365 .00 cost recovery fee payment is included as Attachment 1

- D

.U.S. Department of the Interior Bureau of Ocean Energy Management

Have you previously provided information to verify the calculations and assumptions for your WCD? Yes X No

If so, provide the Control Number of the EP or DOCD with which this information was provided

Do you propose to use new or unusual technology to conduct your activities? Yes X No

Do you propose to use a vessel with anchors to install or modify a structure? Yes X No

Do you propose any facility that will serve as a host facility for deepwater subsea development? Yes X No

Description of Proposed Activities and Tentative Schedule (Mark all that apply)

Proposed Activity Start Date End Date No. of Days

Drill, complete, test, flare Well Location A, install subsea trees 02/26/2018 08/12/2018 167

Drill, complete, test, flare Well Location B, install subsea trees 08/13/2018 01/29/2019 169

Drill, complete, test, flare Well Location C, install subsea trees 01/30/2019 07/13/2019 166

Drill, complete, test, flare Well Location D, install subsea trees 07/14/2019 12/31/2019 170

Drill, complete, test, flare Well Location E, install subsea trees 01/01/2020 06/19/2020 170

Description of Drilling Rig Description of Structure

Jackup X Drillship Caisson Tension leg platform

Gorilla Jackup Platform rig Fixed platform Compliant tower

Semisubmersible Submersible Spar Guyed tower

DP Semisubmersible Other (Attach description) Floating production
system Other (Attach description) Drilling Rig Name (If known): Similar to Transocean Deepwater Champion
Description of Lease Term Pipelines

From (Facility/Area/Block) To (Facility/Area/Block) Diameter (Inches) Length (Feet)

Form BOEM- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 1 of 4 General Information

Type of OCS Plan: X Exploration Plan (EP) Development Operations Coordination Document (DOCD)

Company Name: Freeport

- McMoRan Oil & Gas LLC BOEM Operator Number: 03280

Address: 400 E. Kaliste Saloom, Suite 1100

Lafayette, LA 70508 Contact Person: Paul Landry

Phone Number: (Office) 337

- 354

- 5065, (mobile) 337

- 349

- 7781

E

- Mail Address: paul_landry@fmi.com

If a service fee is required under 30 CFR 550.125(a), provide the Amount paid $18,365.00 Receipt No. 25INIVIU
Project and Worst Case Discharge (WCD) Information

Lease : OCS

- G 35431 Area: Atwater Valley Block : 198 Project Name (If Applicable): Sun

Objective(s) x Oil Gas Sulphur Salt Onshore Support Base(s): Fourchon , LA; Houma, LA

Platform / Well Name: E Total Volume of WCD: 196,060 bbl API Gravity: 27.1 °

Distance to Closest Land (Miles): 87.0 miles Volume from uncontrolled blowout: 25,487,800 bbl 

### OCS PLAN INFORMATION FORM OMB Control Number: 1010

- 0151 OMB Approval Expires: 12/31/14OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): A Previously reviewed under an approved EP or DOCD? Yes X No

Is this an existing well or

structure? Yes X No If this is an existing well or structure, list the Complex ID

or API No. N / A

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? X Yes No

WCD Info For wells, volume of uncontrolled

blowout (Bbls/Day): 196,060 For structures, volume of all storage and pipelines (Bbls ) : N / A API Gravity of fluid 27.1 °

Surface Location Bottom

- Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

- G

- 35431 OCS

OCS

Area Name Atwater Valley

Block No. 198

Blockline Departures (in feet) N/S Departure 3,262' FNL N/S Departure N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 3,578' FWL E/W Departure E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X

- Y
coordinates X: 1,033,178.00' X: X:

X:

X:

Y: 10,086,818.00' Y: Y:

Y:

Y:

Latitude/ Longitude Latitude : 27°47’00.745”N Latitude: Latitude

Latitude

Latitude

Longitude : 88°52’42.516”W Longitude : Longitude Longitude Longitude

Water Depth (Feet): 4,806’ MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: N/A

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

N/A X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM

- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 2 of 4OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): B Previously reviewed under an approved EP or DOCD? Yes X No

Is this an existing well or

structure? Yes X No If this is an existing well or structure, list the Complex ID

or API No. N/A

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? X Yes No

WCD Info For wells, volume of uncontrolled

blowout (Bbls/Day): 196,060 For structures, volume of all storage and pipelines (Bbls ): N/A API Gravity of fluid 27.1 °

Surface Location Bottom

- Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

- G

- 35431 OCS

OCS

Area Name Atwater Valley

Block No. 198

Blockline Departures (in feet) N/S Departure 7,007' FNL N/S Departure N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 6,964' FWL E/W Departure E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X

- Y

coordinates X: 1,036,564.00' X: X:

X:

X:

Y: 10,083,073.00' Y: Y:

Y:

Y:

Latitude/ Longitude Latitude: 27° 46’24.177”N Latitude: Latitude

Latitude

Latitude

Longitude : 88°52’04.191”W Longitude : Longitude Longitude Longitude

Water Depth (Feet): 4,870’ MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: N/A

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

N/A X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM

- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 2 of 4OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): C Previously reviewed under an approved EP or DOCD? Yes X No

Is this an existing well or

structure? Yes X No If this is an existing well or structure, list the Complex ID

or API No. N/A

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? X Yes No

WCD Info For wells, volume of uncontrolled

blowout (Bbls/Day): 196,060 For structures, volume of all storage and pipelines (Bbls ): N/A API Gravity of fluid 27.1 °

Surface Location Bottom

- Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

- G

- 35431 OCS

OCS

Area Name Atwater Valley

Block No. 198

Blockline Departures (in feet) N/S Departure 5,711' FSL N/S Departure N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departur e 6,676' FWL E/W Departure E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X

- Y

coordinates X: 1,036,276.00' X: X:

X:

X:

Y: 10,079,951.00' Y: Y:

Y:

Y:

Latitude/ Longitude Latitude: 27°45’53.223”N Latitude: Latitude

Latitude

Latitude

Longitude : 88°52’06.868”W Longitude : Longitude Longitude Longitude

Water Depth (Feet): 4,906’ MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: N/A

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

N/A X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM

- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 2 of 4OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): D Previously reviewed under an approved EP or DOCD? Yes X No

Is this an existing well or

structure? Yes X No If this is an existing well or structure, list the Complex ID

or API No. N/A

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? X Yes No

WCD Info For wells, volume of uncontrolled

blowout (Bbls/Day): 196,060 For structures, volume of all storage and pipelines (Bbls ): N/A API Gravity of fluid 27.1 °

Surface Location Bottom

- Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

- G

- 35431 OCS

OCS

Area Name Atwater Valley

Block No. 198

Blockline Departures (in feet) N/S Departure 4,958' FNL N/S Departure N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 5,058' FWL E/W Departure E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X

- Y

coordinates X: 1,034,658.00' X: X:

X:

X:

Y: 10,085,122.00' Y: Y:

Y:

Y:

Latitude/ Longitude Latitude: 27°46’44.177”N Latitude: Latitude

Latitude

Latitude

Longitude : 88°52’25.753”W Longitude : Longitude Longitude Longitude

Water Depth (Feet): 4,835’ MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: N/A

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

N/A X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM

- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 2 of 4

OCS PLAN INFORMATION FORM (CONTINUED)Include one copy of this page for each proposed well/structure

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): E Previously reviewed under an approved EP or DOCD? Yes X No

Is this an existing well or

structure? Yes X No If this is an existing well or structure, list the Complex ID

or API No. N/A

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? X Yes No

WCD Info For wells, volume of uncontrolled

blowout (Bbls/Day): 196,060 For structures, volume of all storage and pipelines (Bbls ): N/A API Gravity of fluid 27.1 °

Surface Location Bottom

- Hole Location (For Wells) Completion (For multiple completions, enter separate lines)

Lease No. OCS

- G

- 35431 OCS

OCS

Area Name Atwater Valley

Block No. 198

Blockline Departures (in feet) N/S Departure 5,423' FNL N/S Departure N/S Departure F __ L N/S Departure F __ L N/S Departure F __ L

E/W Departure 7,310' FWL E/W Departure E/W Departure F __ L E/W Departure F __ L E/W Departure F __ L

Lambert X

- Y

coordinates X: 1,036,910.00' X: X:

X:

X:

Y: 10,084,657.00' Y: Y:

Y:

Y:

Latitude/ Longitude Latitude: 27°46’39.912”N Latitude: Latitude

Latitude

Latitude

Longitude : 88°52’00.607”W Longitude : Longitude Longitude Longitude

Water Depth (Feet): 4,860’ MD (Feet): TVD (Feet): MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet): Anchor Radius (if applicable) in feet: N/A

Anchor Locations for Drilling Rig or Construction Barge (If anchor radius supplied above, not necessary)

Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

N/A X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

X: Y:

Form BOEM

- 0137 (December 2011

– Supersedes all previous editions of this form which may not be used.) Page 2 of 4OCS-G-35431FM O&GAT242 

### AT197AT198



### AT199AT154SHEET 1 of 1INITIAL EXPLORATION PLANOCS-G-35431BLOCK 198, ATWATER VALLEY AREAPROPOSED SURFACE LOCATIONSBLOCK WELLCALLSX COORDINATE Y COORDINATELATITUDELONGITUDEAT198 "A"3,262' FNL 3,578' FWL1,033,178.00' 10,086,818.00'
1
:DATE:REVISED:JOB No:FILENAME:140712Oct. 24, 2014PREPAREDBY:730 E. KALISTE SALOOM RD.LAFAYETTE, LA 70508(337) 210-0000LA Reg. No. 330020002000SCALE IN US SURVEY FEETWell "A"OCS-G-35431NAD27ZONE 16 NORTHUTM GRID NORTHWATERDEPTH4,806'OCS-G-35431FM O&GAT242 

### AT197AT198



### AT199AT154SHEET 1 of 1INITIAL EXPLORATION PLANOCS-G-35431BLOCK 198, ATWATER VALLEY AREAPROPOSED SURFACE LOCATIONSBLOCKWELLCALLSX COORDINATEY COORDINATELATITUDELONGITUDEAT198"B"7,007' FNL6,964' FWL1,036,564.00'10,083,073.00'
1
:DATE:REVISED:JOB No:FILENAME:140712Oct. 24, 2014PREPAREDBY:730 E. KALISTE SALOOM RD.LAFAYETTE, LA 70508(337) 210-0000LA Reg. No. 330020002000SCALE IN US SURVEY FEETWell "B"OCS-G-35431NAD27ZONE 16 NORTHUTM GRID NORTHWATERDEPTH4,870'OCS-G-35431FM O&GAT242 

### AT197AT198



### AT199AT154SHEET 1 of 1INITIAL EXPLORATION PLANOCS-G-35431BLOCK 198, ATWATER VALLEY AREAPROPOSED SURFACE LOCATIONSBLOCKWELLCALLSX COORDINATEY COORDINATELATITUDELONGITUDEAT198"C"5,711' FSL6,676' FWL1,036,276.00'10,079,951.00'
1
:DATE:REVISED:JOB No:FILENAME:140712Oct. 24, 2014PREPAREDBY:730 E. KALISTE SALOOM RD.LAFAYETTE, LA 70508(337) 210-0000LA Reg. No. 330020002000SCALE IN US SURVEY FEETWell "C"OCS-G-35431NAD27ZONE 16 NORTHUTM GRID NORTHWATERDEPTH4,906'OCS-G-35431FM O&GAT242 

### AT197AT198



### AT199AT154SHEET 1 of 1INITIAL EXPLORATION PLANOCS-G-35431BLOCK 198, ATWATER VALLEY AREAPROPOSED SURFACE LOCATIONSBLOCKWELLCALLSX COORDINATEY COORDINATELATITUDELONGITUDEAT198"D"4,958' FNL5,058' FWL1,034,658.00'10,085,122.00'
1
:DATE:REVISED:JOB No:FILENAME:140712Oct. 24, 2014PREPAREDBY:730 E. KALISTE SALOOM RD.LAFAYETTE, LA 70508(337) 210-0000LA Reg. No. 330020002000SCALE IN US SURVEY FEETWell "D"OCS-G-35431NAD27ZONE 16 NORTHUTM GRID NORTHWATERDEPTH4,835'OCS-G-35431FM O&GAT242 

### AT197AT198



### AT199AT154SHEET 1 of 1INITIAL EXPLORATION PLANOCS-G-35431BLOCK 198, ATWATER VALLEY AREAPROPOSED SURFACE LOCATIONSBLOCKWELLCALLSX COORDINATEY COORDINATELATITUDELONGITUDEAT198"E"5,423' FNL7,310' FWL1,036,910.00'10,084,657.00'
1
:DATE:REVISED:JOB No:FILENAME:140712Nov. 18, 2014PREPAREDBY:730 E. KALISTE SALOOM RD.LAFAYETTE, LA 70508(337) 210-0000LA Reg. No. 330020002000SCALE IN US SURVEY FEETNAD27ZONE 16 NORTHUTM GRID NORTHWATERDEPTH4,860'Well "E"OCS-G-35431

# AT198

OCS-G-35431

FM O&G X= 1,033,178.00' Y= 10,086,818.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "A" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence 1. Water column velocity corrections applied 2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2 3. Bin size= 3 meters (9.84 feet) 4. Median filter applied 5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G X= 1,036,564.00'

Y= 10,083,073.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "B" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G

X= 1,036,276.00'

Y= 10,079,951.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "C" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G X= 1,034,658.00'

Y= 10,085,122.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "D" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G X= 1,036,910.00'

Y= 10,084,657.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "E" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)1 

### Favaloro, Katharine

From: pay.gov.clev@clev.frb.org

Sent: Wednesday, December 03, 2014 3:44 PM

To: Favaloro, Katharine Subject: Pay.gov Payment Confirmation: BOEM Exploration Plan - BF

Y our 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 by email at BseeAccountsReceivable@bsee.gov

.

Application Name: BOEM Exploration Plan - BF Pay.gov Tracking ID: 25INIVIU Agency Tracking ID: 74716976793 Transaction Type: Sale Transaction Date: 12/03/2014 04:43:55 PM EST

Account Holder Name: Douglas Begley

Transaction Amount: $18,365.00
Billing Address: 700 Milam, Suite 3100 Billing Address 2:
City: Houston State/Province: TX Zip/Postal Code: 77002
Country: USA Card Type: MasterCard

Card Number: ************7057

Region: Gulf of Mexico Contact: Paul Landry 337-354-5065 Company Name/No: Freeport-McMoRan Oil Gas LLC, 03280 Lease Number(s): 35431, , , , Area-Block: Atwater Valley AT, 198: , : , : , : ,

Surface Locations: 5

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY.Freeport

- McMoRan Oil & Gas LLC Section 2

– Pg. 3 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) 

## SECTION 2

GENERAL INFORMATION

2.1 APPLICATIONS AND PERMITS

The t able below provides all additional applications to be filed covering operations proposed in

this EP

.

Application/Permit Issuing Agency Status Application s for Permit to Drill BSEE To Be Submitted Application s for Permit to Modify BSEE To Be Submitted Emergency Evacuation Plan s USCG To Be Submitted

2.2 DRILLING FLUIDS

The table below provide s t he types and estimated volumes of the drilling fluids FM O&G plan s
to use to drill the proposed wells

.

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be Used per Well (bbl )

Water

- based (seawater, freshwater, barite) 60,000
Oil

- based (diesel, mineral oil ) 0 Synthetic

- based (internal olefin, ester) 20,000

2.3 NEW OR UNUSUAL TECHNOLOGY [PROPRIETARY]

2.4 BONDING STATEMENT The bond requirements for the activities and facilities proposed in this EP are satisfied by a an

area

- wide bond, furnished and maintained according to 30 CFR 5 56, S ubpart I; NTL No. 2000

- G16, "Guidelines for General Lease Surety Bonds;" and a current BOEM

- approved deferment from providing additional security under 30 CFR 5 56.53(d) and National NTL No. 2008

- N07, “Supplemental Bond Procedures .” If at any point Freeport

- McMoRan Oil & Gas LLC no longer qualifies for a supplemental bonding deferment, Freeport

- McMoRan Oil & Gas LLC will either provide the required additional security or a third party guarantee within 60 days after such disqualification.

2.5 OIL SPILL FINANCIAL RESPONSIB ILITY (OSFR)
Freeport

- McMoRan Oil & Gas LLC (Company N o. 03280 ) will demonstrate oil spill financial responsibility for the facilities proposed in this EP according to 30 CFR 5 53; and NTL No. 2008

- N05, "Guidelines for Oil Spill Financial Responsibility for Covered Facilities" prior to conducting operations covered in this EP.

2.6 DEEPWATER WELL CONTROL STATEMENT
Freeport

- McMoRan Oil & Gas LLC (Company No. 03280 ) has the financial capability to drill a relief well and conduct other emergency well control op erations.Freeport

- McMoRan Oil & Gas LLC Section 2

– Pg. 4 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) 2.7 BLOWOUT SCENARIO AND WORST CASE DISCHARGE CALCULATIONS The Worst Case Discharge is defined as an uncontrolled blowout through the drilling string during drilling operations.

Estimated initial flow rate: The calculated Worst Case Discharge es timate for Atwater Valley

Block 198 W ell Location E is 196,060 bbl of crude.

Maximum duration/total volume that could occur if the Atwater Valley Block 198 Well

Location E sustained a blowout :

Scenario Maximum Discharge

Rate (bbl/day) Discharge Duration (days ) Total Volume

Condensate (bbl)

Relief w ell 196,060 130 25,487,800

Potential of wellbore to bridge over during a blowout: While the sands anticipated to be encountered by the wells listed in this EP are expected to be

somewhat consolidated

, FM O& G does NOT assume that the proposed wells would bridge over in a blowout scenario. This assumption is based on work in association with Society of Petroleum Engineers ( SPE ) Paper # 163438 on the analysis of potential bridging scenarios during blowout events in the deep water GoM. FM O&G agrees with the conclusions of this SPE paper that the only instances in which a deep water well could potentially bridge over is a complete loss of the marin e riser hydrostatic column resulting in a sharp pressure reduction downhole leading to wellbore collapse before a blowout can fully develop. This bridging would occur quickly before large volumes of hydrocarbons could escape. As FM O&G does not

consider this bridging event to cover all blowout scenarios. The Worst Case Discharge calculations for this proposed well will be based upon a well flowing until a relief well can be completed.

Likelihood for surface intervention to stop blowout:

Location “ E ” will be drilled in the Atwater Valley Block 198 as a subsea well in ~4,8 60 f ee t of water with the wellhead and BOP equipment located on the seabed. Surface intervention would be the preferred method in an uncontrolled blowout; however, the technique used is con tingent upon the rig condition, marine riser system and BOP equipment. Surface intervention is quicker than a relief well but actual well control operations would be determined based on site

‐ specific

conditions.

Prior to surface intervention operations, a team of specialists would be mobilized immediately to assess the situation and determine a course of action. Well control specialists would assess the

on

- site conditions either by helicopter and/or surface vessel. FM O&G has Master Service Agreements with both Wild Well Control (a Superior Energy Services company) and Boots and Coots (a Halliburton company). Additionally a ROV capable of manipulating the rig’s BOP

hot

‐ stab functions would be mobilized to location and, if appropriate, an attempt would be ma de to shut in the well by closing the blind shear rams, if not done previously. These actions would
take place within 24

‐ 48 hours of the incident. Initial assessment activities are projected to take

3

– 5 days. During this period, the well control team w ould analyze the blowout situation, devise an intervention strategy and mobilize service company specialists, supplies and equipment. FMFreeport

- McMoRan Oil & Gas LLC Section 2

– Pg. 5 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) O&G would establish a field support base and secondary command center in the comp any shore base facility in Fourchon, LA. Communications would be established with the support

base and command center.

Rel ief Well Rig type capable of drilling relief well at water depth and to TD: There are more than 10 drilling rigs currently working or slated to begin wor k in the Gulf of

M exico that are capable of drilling a relief well at these locations.

The rig chosen to drill the relief well must be:

 Rated and equipped for water depths > 5,000 ft due to Atwater Valley Block locations.

 Dynamically

‐ positioned to eliminate anchoring issues due to nearby subsea

infrastructure.

 Have a BOP package acceptable and certified under current BSEE regulations.

Time to acquired rig, move onsite and drill relief well:

Activity Duration (days) Assess the situation and obtain the optimum
MODU 5

Secure the well at current location of MODU 14
Mobilization time to relief well location 3
Drill the relief well 80

Well bore intersection (of blown out well) 21 Dynamic kill operations 7 Total anticipated time 130

Statement whether possibility of using nea rby platform was considered: There are no platforms located within proximity of th i s block with the capacity to support drilling operations.

Other measures to enhance ability to prevent a blowout:

 FM O&G will verify with the contractor that all BOPs have been certified, maintained and are capable of operating in the anticipated conditions required for operations.

 FM O&G representatives will review and witness the installation, testing, function testing and operation of the diverter system and diverter outl ets.

 Key personnel on the rig will have a valid well control certificate.

 Wiper trips will be performed as hole conditions dictate in order to quantify the stability of the wellbore and to determine whether sufficient mud weights are being utilized.

 Connec tions will be simulated as needed while drilling into pressure transition areas in order to properly assess the current wellbore conditions.Freeport

- McMoRan Oil & Gas LLC Section 2

– Pg. 6 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) Measures to reduce the likelihood of a blowout:

 A liner top packer or equivalent expandable will be run on all liner laps as an additional barrier for well safety.

 Lost circulation material will be added to the mud system in order to assist the mud system’s ability to prevent lost circulation. Sweeps and concentrated pills will be used to prevent uncontrolled mud l osses.

 Every effort will be made to review all offset and seismic data in order to prepare a mud weight schedule that will allow for safe drilling margin without putting excess hydrostatics pressures on known zones previously encountered.

 Mudloggers may be utilized during critical drilling operations to monitor gas content of mud returns, formation characteristics and abnormalities of cuttings and to estimate paleo aging of cuttings.

 Logging While Drilling (LWD) tools will be utilized as much as possible to evaluate formations, formation pressures and fluid content in the critical sections of the well.

 Log data will be continuously reviewed by FM O&G’s drilling and geological
departments

.

Measures to enhance ability to conduct effective and early interventio n in event of a

blowout: FM O&G is a member of the Helix Well Containment Group (HWCG) and has full access to a subsea capping stack and a complete suite of oil recovery equipment as required. This subsea capping stack has been deployed successfully to a well location with oversight from

BSEE.

Arrangements for drilling relief wells: FM O&G has Master Service Agreements with both Wild Well Control (a Superior Energy Services company) and Boots and Coots (a Halliburton company) who would assist in detailed r elief well planning including the identification of required equipment and services.

Any other measures: NoFreeport

- McMoRan Oil & Gas LLC Section 3

– Pg. 7 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 3

GEOLOGICAL AND GEOPHYSICAL INFORMATION

3.1 GEOLOGICAL DESCRIPTION [PROPRIETARY]

3.2 STRUCTURE CONTOUR MA P S [PROPRIETARY]

3.3 INTERPRETED SEISMIC LINE S
[ PROPRIETARY]

3.4 GEOLOGICAL STRUCTURE CROSS

- SECTION S [PROPRIETARY]

3.5 SHALLOW HAZARDS REPORT A shallow hazards survey was conducted over Atwater Valley Block 198

.

In accordance with NTL No. 2008

- G05, “Shallow Hazards Program” (Extended by NTL NTL No.

2014

- G05 , “Extension of Prior Notices to Lessees” ), a s hallow hazards survey evaluating seafloor and subsurface geological and manmade features and conditions that may adversely affect drilling operations, was conducted by C & C Technologies Survey Services . The shallow hazards report is provided with this pl an.

3.6 SHALLOW HAZARDS ASSESSMENT

In accordance with NTL No. 2008

- G05, “ Shallow Hazards Program

, ” (Extended by NTL No.

2014

- G05 , “Extension of Prior Notices to Lessees” ), a shallow hazards assessment has been prepared for each p roposed surface locati on evaluating seafloor and subsurface geological and manmade features and conditions that may adversely affect drilling operations. The shallow hazards survey and archaeological assessment is included as Attachment 3

- A

.

3.7 HIGH

- RESOLUTION SEISMIC LINES
[PR OPRIETARY]

3.8 STRATIGRAPHIC COLUMN [PROPRIETARY ]

3.9 TIME V ERSUS DEPTH TABLES
[ PROPRIETARY]C&C Project No. 140712



### 1

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### October 21, 2014

Freeport-McMoRan Oil & Gas 717 Texas Avenue, Suite 2100 Houston, TX 77002

Attn: Mr. Terry Arcuri

Site Clearance Letter Proposed Well “A” Block 198 (OCS-G-35431) Atwater Valley Area Dear Mr. Arcuri,

INTRODUCTION Freeport-McMoRan Oil & Gas (FMOG) contracted C & C Technologies, Inc. (C&C) to prepare

a wellsite clearance letter for the proposed Well “ A” location in Block 198 (OCS-G-35431), Atwater Valley (AT) Area. The data used for the site clearance letter is based on the interpretation of an exploration-quality 3D seismic volume and a high-resolution geophysical dataset collected with C&C’s Autonomous Underwater Vehicle (AUV) C-Surveyor VI TM. C&C completed the geohazard assessment titled “ 3D Shallow Hazard Report, Sun Prospect, Block s 154 (OCS-G-35019), 197 (OCS-G-35430), 198 (OCS-G-35431), and Vicinity, Atwater Valley

Area ” in October, 2014. This site clearance letter is based on the findings provided within that
report.

This letter provides a top-hole drilling prognosis and addresses seafloor conditions within a 2,000-foot radius of the proposed surface location. The depth limit of investigation is approximately 2.0 seconds of two-way traveltime (~5,000 feet) below the mud line (BML). The reporting and mapping presented in this letter comply with the BOEM/BSEE guidelines provided in NTL No. 2008-G05 (Shallow Hazards Program) and No. 2009-G40 (Deepwater Benthic Communities).

METHODS AUV Survey Data

C&C’s C-Surveyor VI TM AUV provided multibeam bathymetric mapping, high-resolution side scan sonar imagery, and subbottom profiles. The AUV remote-sensing instruments include a Kongsberg EM 2040 Swath Multibeam Sonar (200, 300, and 400 kHz), an EdgeTech 2200-M Side Scan Sonar (410 and 120 kHz ), and a custom EdgeTech Chirp DW106 Subbottom Profiler (1 - 6 kHz). All the raw digital data were logged utilizing proprietary software developed by C&C. The multibeam system delivered a 3-meter gridded dataset with relative vertical

accuracies within 20 centimeters.

The AUV survey grid in the study area consists of one-hundred sixty-seven (167) tracklines, including one-hundred fifty-five (155 ) primary lines (Line Nos. 101-155) running east-west at200-meter (656-foot) line spacing and twelve (12) tie lines (Line Nos. 201-212) running northso uth at 900-meter (2,953-foot) line spacing. Navigation fixes (event marks) were annotated atC&C Project No. 140712



### 2

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### 125

- meter (410

- foot) intervals along all survey lines. The survey grid was designed to provide a representative sampling with the subbottom profiler system and o verlapping coverage with side scan sonar and multibeam echosounder systems.

3D Seismic Data The 3D seismic data used for this assessment was provided in SEG

- Y format. The data were loaded into IHS’ Kingdom Suite 2d/3dPAK for interpretation. The 3D dat a were acquired by

CGGVeritas aboard the Symphony , and reprocessed with Pos t

- Stack Time Migration (PSTM)

. The 3D data were provided at a four

- millisecond sample rate and extend to the full data range of

7.0 seconds

. The inlines of the data run east

- west and are spaced at 20

- meter (65.62

- foot) intervals, while the crosslines run north

- south and are spaced at 12.5

- meter (41.01

- foot)

intervals. Spectral whitening was applied to the 3D seismic dataset to amplify the higher frequencies. After applying the sp ectral whitening, a power spectrum generated at a few selected locations indicated the seismic data volume contains sufficiently high frequency content for a

shallow hazards assessment (Figure 1)

.

The 3D seismic data are zero phase, and the seafloor refl ector is represented by a strong, positive amplitude peak flanked by troughs with absolute amplitude values of less than one

- half of the peak value. The seismic data provided adequate screening of the regional seafloor and shallow geologic conditions, and large scale geohazards (faults, salt, high acoustic impedance, stratigraphic horizons, etc.).

WELL LOCATION The coordinates and calls for the proposed Well “A” surface location are tabulated below:

Table 1. Proposed Well “A”

Well Easting

(feet) Northing

(feet) Latitude Longitude Calls From Block 198
, Atwater Valley Area

“A” 1,033,178 ’ 10,086,818 ’ 27  47’ 00.745 ” N 88  52’ 4 2.516 ” W 3,578’ FW L 3,262 ’ FN L



### A 2,000

- foot clearance radius is required for assessing deepwater benthic co mmunities in proximity to the proposed Well “A”

.

The geodetic datum used for this project is the North American Datum 1927 (NAD27) with the Clarke 1866 Ellipsoid. The datum is projected using the Universal Tr ansverse Mercator (UTM), Zone 16 North (16 N) with a central meridian at 87 ° 00′W, a false easting of 1,640,416.67 feet at the central meridian, and a false northing of 0.00 feet at 00° 00′N. Mapping and reporting units are in U.S. Survey Feet.

REGIONAL GEOLOGY

The Gulf of Mexico is a semi

- enclosed basin that has been rece iving sediment influx dominated by the Mississippi River since the Late Jurassic. Mesozoic and Cenozoic sediments have attained a thickness in excess of 9 miles (Coleman et al., 1991). The prograded shelf sequence consists of intercalated coastal plain, delta, estuarine, and marine sediments. Sediment deposition along the northern rim of the Gulf of Mexico resulted in particularly thick TertiaryC&C Project No. 140712



### 3

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### and Quaternary sections. These rapidly deposited sediments have prograded the Cretaceous

shelf

- edge up to 185 miles basinward. The exceptionally high rate of shelf

- edge progradation is on the order of 3.0 to 3.7 miles per 1,000 years.

The near surface geology across the Gulf Coast region is the product of fluctuating sea levels

associated with climatic variati ons over the past 20,000 years. During this time, low sea levels left the continental shelf exposed to subaerial weathering and other erosional processes. Streams and rivers meandered and cut into the exposed landmass, depositing bedloads along the moder n

day shelf break. Fan systems were formed, and mass movement events were common as deltaic sediments were deposited on the steep upper continental slope. As the climate warmed, seas transgressed, and marine sedimen ts were deposited on the shelf.

BATHYM ETRY AND SEAFLOOR GR ADIENTS

The wat er depth at the proposed Well “A” location is 4

, 806 feet below mean sea level (M SL). Within the 2,000

- foot radius area centered at the proposed Well “A” location, the seafloor depth ranges from 4,784 fe et in the north wes t to 4

, 833 feet in the south east (Sheet 1, Color Shaded Bathymetry Map)

.

The proposed Well “A” location is situated on a very smooth sloping seafloor located in the

northeastern corner of AT198 (Figure 2)

. The seafloor in the area surrounding the propose d well

location s lopes south east at a gradient of less than 1 ° (Sheet 2, Seafloor Gradient Map)

.

SEAFLOOR HAZARDS Low to moderate sonar reflectivity occurs around the proposed wellsite indicating mostly fine

grained sediments (Figure 3 ).

T he 3D se afloor amplitude image displays a range of low to moderate acoustic amplitudes within the 2,000

- foot radius area (Sheet 3, Seafloor Amplitude Map)

. These low to moderate seafloor amplitudes indicate finely textured seafloor sediments that are likely comprised of hemipelagic clay.

No sonar contacts are found within 2,000 feet of the proposed well location.

There were no seafloor features or potential hazards identified at or in proximity to the proposed

well location (Sheet 4, Seafloor and Subsurface Hazards M ap)

.

POTENTIAL DEEPWATER BENTHIC COMMUNITIES High or low

- amplitude seismic seafloor anomalies are potential indicators of carbonates, benthic community habitats, and gas/fluid seepages. The se afloor at the proposed Well “A ” and surrounding 2,000

- foot rad ius contains no high or low positive seafloor amplitude anomalies associated with fluid expulsion or mounded carbonates representing potential b enthic

communities. The s ide scan sonar a nd multibeam backscatter agree with the seafloor amplitude image, and show no evidence of outcrops or fluid expulsion.C&C Project No. 140712



### 4

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### SUBSURF ACE GEOHAZARDS AND S TRATIGRAPHY

The AUV subbottom profiler data exhibit continuous, sharp bottom echoes with parallel to divergent, continuous reflect ors throughout the wellsite area

. The uppermost shallow sediments consist of a 20 to 25 foot thick acoustically semi

- transparent hemipelagic clay drape. Sediments below this drape are characterized by parallel, low to moderate amp litude reflectors that represent cyclic deposition of hemipelagic clay an d silty clays (Figure 4)

.

Five s edimentary units (Units A to E ), each consisting of one or more distinctive sequences, were interpreted within the study area from the 3D seismic data to approximately 2 seconds of

two

- way traveltime (~5,000 feet) below the seafloor, the lower limit of investigation. Six horizons mark the upper and/or lower contacts of each of the successive units (Figures 5 and 6)

.

C&C was provided with a series of time

- depth pairs for the sediment column. The following polynomial equat ion was derived from Total Vertical Depth (TVD) (feet) and the corresponding

two

- way traveltime (seconds) using the time

- depth values to calculate depths below the seafloor:

D = 426.02 T 2 

### + 1,524.4 T

where D = depth below seafloor in feet and T = time below seafloor in seconds.

A detailed description of the sequence units, beginning at the se afloor, can be found in the 2014 Geohazard Report. The To p

- Hole Prognosis Chart (Figure 7 ) summarizes the stratigraphy.

Unit A (Seafloor to Horizon 1)

Unit A consists of mostly low amplitude, parallel, semi

- continuous reflectors and measures 1,280 feet thick at the proposed well location. The reflection patterns suggest the unit is comprised mostly of hemipelagic clay with interbedded fine

- grained mass transport depos its. No high amplitu de anomalies occur within Unit A near the proposed well location

.

Unit B (Horizon 1 to Horizon 2) Unit B consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 1,891 feet thick at the proposed we ll location . Unit B is interpreted as fine

- grained mass transport deposits atop an interbedded channel fill zone. No high amplitu de anomalies occur within Unit B near the proposed well location

.

Unit C (Horizon 2 to Horizon 3)

Unit C consists of low to moderate amplitude, semi

- continuous to sub

- parallel reflectors and

measures 738 feet. This relatively thin u nit is interpreted as mass transport deposits with a few

interbedded channel fills. No high amplitu de anomalies occur within Unit C near the prop osed

well location

.

Unit D (Horizon 3 to Horizon 4)

Unit D consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 2,111 feet thick at the proposed well location

. T he sediments in Unit D are interpreted

as a coarser

- grained channel fill between two finer

- grained m ass transport deposits. No highC&C Project No. 140712



### 5

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### amplitu de anomalies occur within Unit D near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Unit E (Horizon 4 to Horizon 5 )

Unit E consists of low to moderate amplitude, semi

- continuous to subparallel reflectors and

measures 1,415 feet thick at the proposed well location

. T he sediments in Unit E are interpreted

as mostly chann el fill sitting atop an interbedded mass transport deposit zone

. No high amplitu de anomalies occur within Unit E near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potent ial.

Horizon 5 represents the salt/sediment interface at the proposed well location.

SHALLOW GAS Anomalies of very high amplitude, commonly termed bright spots, are interpreted as potential regions of fluid saturation usually associated with porous sands . Seismic amplitude anomalies are mapped on a unit

- by

- unit basis to assess the potential risk of gas. Seismic amplitude

anomalies are exhibited on the Seafloor & Subsurface Features Map

.

The risk of gas refers to the risk of encountering shallow gas. The risk of gas is interpreted based on amplitude levels. Stratigraphic and structural settings may also be taken into account. The four risk levels of gas are:

 Negligible

— No amplitude anomalies or other gas indicator present.

 Low risk of gas

— Generally indicated by increased amplitude (2

– 3× background level) and phase reversal. This may also include diffuse areas of gas blanking.

 Moderate risk of gas

— Generally indicated by high amplitude (3

– 4× background level) and phase reversal.

 High risk of gas

— Gener ally indicated by the highest amplitudes (in excess of 4× background level), phase reversal, and a combination of other attributes indicative of the presence of gas, particularly velocity pull

- down and masking of underlying sediments.

There were no ampl itude anomalies identified wit hin 2,000 feet of the proposed W ell “A” location. All units are interpreted as having a low risk of gas.

SHALLOW WATER FLOW Several factors may contribute to shallow water flows. These include: high porosity and permeabilit y, sand

- prone aquifer, mechanism to pressurize, and seal. Additional details are

described below:

 Water depth and burial depth. Significant water depths (> 500 feet below the seafloor) are required for the overpressure to occur. The seal must be deeply buried (> 500 feet below the seafloor) to become sufficiently strong.

 High deposition rates. Sedimentation rate needs to be greater than 1,500 feet/myr to effectively seal in sands. Sedimentation rates are expected to be high within a salt

withdrawal ba sin. Rapid burial leads to pressure disequilibrium. In addition, if theseC&C Project No. 140712



### 6

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### sediment ‘packets’ were formed through a sequence of turbidites or gravity flow, there is an increased likelihood of water saturation and overpressure (pore pressure rapidly increa sed and sealed by an impervious layer).

 Suitably porous sediments. The sediment packets comprising the risk of shallow water flow are believed to contain clastic material and are thus porous.

 Impermeable seal. The overlying sediments are comprised of a clay facies.

All of these factors occur within the study area. Since there is presently no method for quantifying the risk of shallow water flow, caution is recommended when drilling through units with shallow water flow potential. Sands with SWF poten tial often occur in unconsolidated, overpressured sands that lie below a seal. This seal prevents dewatering and compaction after deposition. The pressure rises with overburden causing a potentially disastrous hazard for drilling operations.

The neare st repo rted shallow water flow was in AT194 , approximately 10 miles west o f the survey area, according to information listed on the BOEM and BSEE website. This SWF event

is listed as occurring 2,132 feet below mudline and was categorized as a moderate sev erity flow

.

The assessment of seismic profiles suggests that Units A and C exhibit a low risk of SWF , while

the coarser

- grained channel fills within Units B, D

, and E exhibit a low to moderate risk . Due to the unpredictable nature of SWF, it is advised that caution be executed for any drilling operations through these sediments.

GAS HYDRATES Gas hydrates are an ice crystalline form of gas hydrocarbons in deepwater marine environments where the conditions of pressure and temperature are favorable. The hydrate stability zone is the depth interval between the seafloor and the point where the hydrate is no longer stable in form. The thermal gradient of the seabed soils determines the depth of the hydrate stability zone base. The acoustic impedance contra st caused between the hydrate and free gas trapped at the base of the hydrate stability zone forms a Bottom Simulating Reflector (BSR) on seismic profiles. This BSR reflector cross cuts the normal seismic stratigraphy, much like a bottom multiple.

The ar eas where seafloor gas hydrates accumulate in the near

- surface sediments of the Gulf of Mexico are generally unfavorable sites for drilling operations. Irregular seafloor topography, gas seeps, gas chimneys, seafloor hydrates and deepwater benthic communi ties may all be found in

close association. No indication of BSRs was found in the vicinity of the proposed well.

CONCLUSIONS The proposed Well “A” location is situated on a very smooth sloping seafloor at a water depth of 4, 806 feet MSL . The seabed slo pes gently to the southeast at a gradient of less than 1 °

.

There were no potential hazardous features identified near the proposed Well “A” location.

No sonar contacts exist within 2,000 feet of the proposed Well “A” location.C&C Project No. 140712



### 7

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70 508 

### No high or low seafloor amplitudes anomalies that may indicate the occurrence of hardgrounds, carbonates, benthic communities or potential expulsions are found within 2,000 feet of the proposed Well “A” location.

Five ( 5 ) subsurface units interpreted from the 3D seismic data wer e assessed to approximately 5,000 feet BSF at the proposed Well “A” location (Units A to E )

. Unit A is comprised mostly of low amplitude, parallel to semi

- continuous ref lectors and consists of hemipelagic clays and mass transport deposits. Unit B is char acterized by low to moderate amplitude, semi

- continuous to

chaotic reflectors and consists of fine

- grained mass transport deposits atop an interbedded channel fill zone. Unit C is comprised of low to moderate amplitude, semi

- continuous reflectors

and is i nterpreted as mostly mass transport deposits with a few interbedded channel fills. Units D and E consist of low to moderate, semi

- continuous to chaotic reflectors and consists of alternating layers of fine

- grained mass transport deposits and coarser

- grain ed channel fill zones.

There were no amplitude anomalies indicative of shallow gas identified within any of the unit s at the proposed Well “A” location. All units are therefore assessed as having a low risk of gas. No indication of gas hydrates was found within the study area.

Un its A a nd C are assessed as having a low risk of SWF. The coarser

- grained channel fills

within Units B, D

, and E are assessed as having a low to moderate risk of SWF.

Thank you for this opportunity to be of service. Plea se contact us if you have any questions concerning this assessment.

Sincerely,

___________________________ 

### Christopher Baker

Senior Geologist

E NCLOSURES Figure 1. Extracted wavelet and power spectrum at the proposed Well “A”

. Figure 2. AUV seafloor bathymetry surrounding the proposed Well “A”

. Figure 3

. Side scan s onar mosaic at the proposed Well “ A ”

. Figure 4. Subbottom profiler Line 133 near the proposed Well “A ”

. Figure 5

. 3D seismic Inline 1675 through the proposed Well “A”

. Figure 6

. 3D seismic Crossline 10208 through the proposed Well “A”

. Figure 7

. Top

- Hole Prognosis Chart for the proposed Well “A”

.

Sheet 1

. Color Shaded Bathymetry Map , Proposed Well “A” Location 1”=1,000’

Sheet 2. Seafloor Gradient Map, Proposed Well “A” Location 1”=1,000’

S heet 3. Seafloor Amplitude Map, Proposed Well “A” Location 1”=1,000’

Sheet 4. Seafloor & Subsurface Hazard Map, Proposed Well “A” Location 1”=1,000’C&C Project No. 140712



### 1

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### October 21 , 201 4

Freeport

- McMoRan Oil & Gas 717 Texas Avenue, Suite 2100 Houston, TX 77002

Attn: Mr. Terry Arcuri

Site Clearance Letter Proposed Well “B”

Block 198 ( OCS

- G

- 35431 ) Atwater Valley Area

Dear Mr. Arcuri

,

INTRODUCTION Freeport

- McMoRa n Oil & Gas (FMOG) contrac ted C & C Technologies, Inc. (C& C) to prepare

a well site clearance letter for the propose d Well “B” location in Block 198 ( OCS

- G

- 35431 ), Atwater Valley (AT ) Area. The data used for the site clearance letter is based on the interp retation of an exploration

- quality 3D seismic volume and a high

- resolution geophysical dataset collected with C&C’s Autonomous Underwater Vehicle (AUV) C

- Surveyor V I TM. C&C

com pleted the geohazard assessment titled “ 3D Shallow Hazard Report, Sun Prospect

, Block s 154 (OCS

- G

- 35019 )

, 197 (OCS

- G

- 35430 ), 198 (OCS

- G

- 35431), and Vicinity

, Atwater Valley

Area ” in October

, 2014 . This site clearance letter is based on the findings provi ded within that
report

.

This letter provides a top

- hole drilling prognosis and a ddresses seafloor conditions within a 2

, 000

- foot radius of the proposed surface location. The depth limit of investigation is approximately 2 .0 seconds of two

- way traveltime (~5 ,000 feet) below the mud line (BML) . The reporting and mapping presented in t his letter comply with the BOEM/BSEE guidelines provided

in NTL No. 2008

- G05 (Shallow Hazards Program ) and No. 2009

- G40 (D eepwater Benthic Communities).

METHODS AUV Survey Data

C&C’s C

- Surveyor V

I TM AUV provided multibeam bathymetric mapping, high

- resoluti on side scan sonar imagery, and subbottom profiles. The AUV remote

- sensing instruments include a Kongsberg EM 204 0 Swath Multibeam Sonar (200, 300, and 400 kHz), an EdgeTech 2200

- M Side Scan Sonar ( 410 and 120 kHz ), and a custom EdgeTech Chi rp DW106 Subbo ttom Profiler (1

- 6 kHz). All the raw digital data were logged utilizing proprietary software developed by C&C. The multibeam system delivered a 3

- meter gridded dataset with relative vertical

accuracies within 20 centimeters.

The AUV survey grid in the study area consists of one

- hundred sixty

- seven (167 ) tracklines, including one

- hundred fifty

- five (155 ) primary lines (Line Nos. 101

- 155 ) running east

- west at
200

- meter (656

- foot) line spacing and twelve (12) tie lines (Line Nos. 201

- 212 ) running north

so uth at 900

- meter (2,953

- foot) line spacing. Navigation fixes (event marks) were annotated atC&C Project No. 140712



### 2

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### 125

- meter (410

- foot) intervals along all survey lines. The survey grid was designed to provide a representative sampling with the subbottom profiler system and o verlapping coverage with side scan sonar and multibeam echosounder systems.

3D Seismic Data The 3D seismic data used for this assessment was provided in SEG

- Y format. The data were loaded into IHS’ Kingdom Suite 2d/3dPAK for interpretation. The 3D dat a were acquired by

CGGVeritas aboard the Symphony , and reprocessed with Pos t

- Stack Time Migration (PSTM)

. The 3D data were provided at a four

- millisecond sample rate and extend to the full data range of

7.0 seconds

. The inlines of the data run east

- west and are spaced at 20

- meter (65.62

- foot) intervals, while the crosslines run north

- south and are spaced at 12.5

- meter (41.01

- foot)

intervals. Spectral whitening was applied to the 3D seismic dataset to amplify the higher frequencies. After applying the sp ectral whitening, a power spectrum generated at a few selected locations indicated the seismic data volume contains sufficiently high frequency content for a

shallow hazards assessment (Figure 1)

.

The 3D seismic data are zero phase, and the seafloor refl ector is represented by a strong, positive amplitude peak flanked by troughs with absolute amplitude values of less than one

- half of the peak value. The seismic data provided adequate screening of the regional seafloor and shallow geologic conditions, and large scale geohazards (faults, salt, high acoustic impedance, stratigraphic horizons, etc.).

WELL LOCATION The coordinates and calls for the proposed Well “B” surface location are tabulated below:

Table 1. Proposed Well “B”

Well Easting

(feet) Northing

(feet) Latitude Longitude Calls From Block 198
, Atwater Valley Area

“B” 1,036,564 ’ 10,083,073 ’ 27  46’ 24.177 ” N 88  52’ 04.191 ” W 6,964 ’ FW L 7,007 ’ FN L



### A 2,000

- foot clearance radius is required for assessing deepwater benthic co mmunities in proximity to the proposed Well “B”

.

The geodetic datum used for this project is the North American Datum 1927 (NAD27) with the Clarke 1866 Ellipsoid. The datum is projected using the Universal Tr ansverse Mercator (UTM), Zone 16 North (16 N) with a central meridian at 87 ° 00′W, a false easting of 1,640,416.67 feet at the central meridian, and a false northing of 0.00 feet at 00° 00′N. Mapping and reporting units are in U.S. Survey Feet.

REGIONAL GEOLOGY

The Gulf of Mexico is a semi

- enclosed basin that has been rece iving sediment influx dominated by the Mississippi River since the Late Jurassic. Mesozoic and Cenozoic sediments have attained a thickness in excess of 9 miles (Coleman et al., 1991). The prograded shelf sequence consists of intercalated coastal plain, delta, estuarine, and marine sediments. Sediment deposition along the northern rim of the Gulf of Mexico resulted in particularly thick TertiaryC&C Project No. 140712



### 3

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### and Quaternary sections. These rapidly deposited sediments have prograded the Cretaceous

shelf

- edge up to 185 miles basinward. The exceptionally high rate of shelf

- edge progradation is on the order of 3.0 to 3.7 miles per 1,000 years.

The near surface geology across the Gulf Coast region is the product of fluctuating sea levels

associated with climatic variati ons over the past 20,000 years. During this time, low sea levels left the continental shelf exposed to subaerial weathering and other erosional processes. Streams and rivers meandered and cut into the exposed landmass, depositing bedloads along the moder n

day shelf break. Fan systems were formed, and mass movement events were common as deltaic sediments were deposited on the steep upper continental slope. As the climate warmed, seas transgressed, and marine sedimen ts were deposited on the shelf.

BATHYM ETRY AND SEAFLOOR GR ADIENTS

The wat er depth at the proposed Well “B” location is 4

, 8 70 feet below mean sea level (M SL). Within the 2,000

- foot radius area centered at the proposed Well “B” location, the seafloor depth ranges from 4,844 fe et in the north wes t to 4

, 900 feet in the south east (Sheet 1, Color Shaded Bathymetry Map)

.

The proposed Well “B” location is situated on a very smooth sloping seafloor located in the

northeastern corner of AT198 (Figure 2)

. The seafloor in the area surrounding the propose d well

location s lopes south east at a gradient of less than 1 ° (Sheet 2, Seafloor Gradient Map)

.

SEAFLOOR HAZARDS Low to moderate sonar reflectivity occurs around the proposed wellsite indicating mostly fine

grained sediments (Figure 3 ).

T he 3D se afloor amplitude image displays a range of low to moderate acoustic amplitudes within the 2,000

- foot radius area (Sheet 3, Seafloor Amplitude Map)

. These low to moderate seafloor amplitudes indicate finely textured seafloor sediments that are likely comprised of hemipelagic clay.

No sonar contacts are found within 2,000 feet of the proposed well location.

There were no seafloor features or potential hazards identified at or in proximity to the proposed

well location (Sheet 4, Seafloor and Subsurface Hazards M ap)

.

POTENTIAL DEEPWATER BENTHIC COMMUNITIES High or low

- amplitude seismic seafloor anomalies are potential indicators of carbonates, benthic community habitats, and gas/fluid seepages. The se afloor at the proposed Well “B” and surrounding 2,000

- foot rad ius contains no high or low positive seafloor amplitude anomalies associated with fluid expulsion or mounded carbonates representing potential b enthic

communities. The s ide scan sonar a nd multibeam backscatter agree with the seafloor amplitude image, and show no evidence of outcrops or fluid expulsion.C&C Project No. 140712



### 4

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### SUBSURF ACE GEOHAZARDS AND S TRATIGRAPHY

The AUV subbottom profiler data exhibit continuous, sharp bottom echoes with parallel to divergent, continuous reflect ors throughout the wellsite area

. The uppermost shallow sediments consist of a 20 to 25 foot thick acoustically semi

- transparent hemipelagic clay drape. Sediments below this drape are characterized by parallel, low to moderate amp litude reflectors that represent cyclic deposition of hemipelagic clay an d silty clays (Figure 4)

.

Five s edimentary units (Units A to E ), each consisting of one or more distinctive sequences, were interpreted within the study area from the 3D seismic data to approximately 2 seconds of

two

- way traveltime (~5,000 feet) below the seafloor, the lower limit of investigation. Six horizons mark the upper and/or lower contacts of each of the successive units (Figures 5 and 6)

.

C&C was provided with a series of time

- depth pairs for the sediment column. The following polynomial equat ion was derived from Total Vertical Depth (TVD) (feet) and the corresponding

two

- way traveltime (seconds) using the time

- depth values to calculate depths below the seafloor:

D = 426.02 T 2 

### + 1,524.4 T

where D = depth below seafloor in feet and T = time below seafloor in seconds.

A detailed description of the sequence units, beginning at the se afloor, can be found in the 2014 Geohazard Report. The To p

- Hole Prognosis Chart (Figure 7 ) summarizes the stratigraphy.

Unit A (Seafloor to Horizon 1)

Unit A consists of mostly low amplitude, parallel, semi

- continuous reflectors and measures 1,2 14 feet thick at the proposed well location. The reflection patterns suggest the unit is comprised mostly of hemipelagic clay with interbedded fine

- grained mass transport depos its. No high amplitu de anomalies occur within Unit A near the proposed well location

.

Unit B (Horizon 1 to Horizon 2) Unit B consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 1,810 feet thick at the proposed we ll location . Unit B is interpreted as fine

- grained mass transport deposits atop an interbedded channel fill zone. No high amplitu de anomalies occur within Unit B near the proposed well location

.

Unit C (Horizon 2 to Horizon 3)

Unit C consists of low to moderate amplitude, semi

- continuous to sub

- parallel reflectors and

measures 625 feet. This relatively thin u nit is interpreted as mass transport deposits with a few

interbedded channel fills. No high amplitu de anomalies occur within Unit C near the prop osed

well location

.

Unit D (Horizon 3 to Horizon 4)

Unit D consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 2, 093 feet thick at the proposed well location

. T he sediments in Unit D are interpreted

as a coarser

- grained channel fill between two finer

- grained m ass transport deposits. No highC&C Project No. 140712



### 5

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### amplitu de anomalies occur within Unit D near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Unit E (Horizon 4 to Horizon 5 )

Unit E consists of low to moderate amplitude, semi

- continuous to subparallel reflectors and

measures 1, 323 feet thick at the proposed well location

. T he sediments in Unit E are interpreted

as mostly chann el fill sitting atop an interbedded mass transport deposit zone

. No high amplitu de anomalies occur within Unit E near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potent ial.

Horizon 5 represents the salt/sediment interface at the proposed well location.

SHALLOW GAS Anomalies of very high amplitude, commonly termed bright spots, are interpreted as potential regions of fluid saturation usually associated with porous sands . Seismic amplitude anomalies are mapped on a unit

- by

- unit basis to assess the potential risk of gas. Seismic amplitude

anomalies are exhibited on the Seafloor & Subsurface Features Map

.

The risk of gas refers to the risk of encountering shallow gas. The risk of gas is interpreted based on amplitude levels. Stratigraphic and structural settings may also be taken into account. The four risk levels of gas are:

 Negligible

— No amplitude anomalies or other gas indicator present.

 Low risk of gas

— Generally indicated by increased amplitude (2

– 3× background level) and phase reversal. This may also include diffuse areas of gas blanking.

 Moderate risk of gas

— Generally indicated by high amplitude (3

– 4× background level) and phase reversal.

 High risk of gas

— Gener ally indicated by the highest amplitudes (in excess of 4× background level), phase reversal, and a combination of other attributes indicative of the presence of gas, particularly velocity pull

- down and masking of underlying sediments.

There were no ampl itude anomalies identified wit hin 2,000 feet of the proposed W ell “B” location. All units are interpreted as having a low risk of gas.

SHALLOW WATER FLOW Several factors may contribute to shallow water flows. These include: high porosity and permeabilit y, sand

- prone aquifer, mechanism to pressurize, and seal. Additional details are

described below:

 Water depth and burial depth. Significant water depths (> 500 feet below the seafloor) are required for the overpressure to occur. The seal must be deeply buried (> 500 feet below the seafloor) to become sufficiently strong.

 High deposition rates. Sedimentation rate needs to be greater than 1,500 feet/myr to effectively seal in sands. Sedimentation rates are expected to be high within a salt

withdrawal ba sin. Rapid burial leads to pressure disequilibrium. In addition, if theseC&C Project No. 140712



### 6

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### sediment ‘packets’ were formed through a sequence of turbidites or gravity flow, there is an increased likelihood of water saturation and overpressure (pore pressure rapidly increa sed and sealed by an impervious layer).

 Suitably porous sediments. The sediment packets comprising the risk of shallow water flow are believed to contain clastic material and are thus porous.

 Impermeable seal. The overlying sediments are comprised of a clay facies.

All of these factors occur within the study area. Since there is presently no method for quantifying the risk of shallow water flow, caution is recommended when drilling through units with shallow water flow potential. Sands with SWF poten tial often occur in unconsolidated, overpressured sands that lie below a seal. This seal prevents dewatering and compaction after deposition. The pressure rises with overburden causing a potentially disastrous hazard for drilling operations.

The neare st repo rted shallow water flow was in AT194 , approximately 10 miles west o f the survey area, according to information listed on the BOEM and BSEE website. This SWF event

is listed as occurring 2,132 feet below mudline and was categorized as a moderate sev erity flow

.

The assessment of seismic profiles suggests that Units A and C exhibit a low risk of SWF , while

the coarser

- grained channel fills within Units B, D

, and E exhibit a low to moderate risk . Due to the unpredictable nature of SWF, it is advised that caution be executed for any drilling operations through these sediments.

GAS HYDRATES Gas hydrates are an ice crystalline form of gas hydrocarbons in deepwater marine environments where the conditions of pressure and temperature are favorable. The hydrate stability zone is the depth interval between the seafloor and the point where the hydrate is no longer stable in form. The thermal gradient of the seabed soils determines the depth of the hydrate stability zone base. The acoustic impedance contra st caused between the hydrate and free gas trapped at the base of the hydrate stability zone forms a Bottom Simulating Reflector (BSR) on seismic profiles. This BSR reflector cross cuts the normal seismic stratigraphy, much like a bottom multiple.

The ar eas where seafloor gas hydrates accumulate in the near

- surface sediments of the Gulf of Mexico are generally unfavorable sites for drilling operations. Irregular seafloor topography, gas seeps, gas chimneys, seafloor hydrates and deepwater benthic communi ties may all be found in

close association. No indication of BSRs was found in the vicinity of the proposed well.

CONCLUSIONS The proposed Well “B” location is situated on a very smooth sloping seafloor at a water depth of 4, 8 70 feet MSL . The seabed slo pes gently to the southeast at a gradient of less than 1 °

.

There were no potential hazardous features identified near the proposed Well “B” location.

No sonar contacts exist within 2,000 feet of the proposed Well “B” location.C&C Project No. 140712



### 7

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### No high or low seafloor amplitudes anomalies that may indicate the occurrence of hardgrounds, carbonates, benthic communities or potential expulsions are found within 2,000 feet of the proposed Well “B” location.

Five ( 5 ) subsurface units interpreted from the 3D seismic data wer e assessed to approximately 5,000 feet BSF at the proposed Well “B” location (Units A to E )

. Unit A is comprised mostly of low amplitude, parallel to semi

- continuous ref lectors and consists of hemipelagic clays and mass transport deposits. Unit B is char acterized by low to moderate amplitude, semi

- continuous to

chaotic reflectors and consists of fine

- grained mass transport deposits atop an interbedded channel fill zone. Unit C is comprised of low to moderate amplitude, semi

- continuous reflectors

and is i nterpreted as mostly mass transport deposits with a few interbedded channel fills. Units D and E consist of low to moderate, semi

- continuous to chaotic reflectors and consists of alternating layers of fine

- grained mass transport deposits and coarser

- grain ed channel fill zones.

There were no amplitude anomalies indicative of shallow gas identified within any of the unit s at the proposed Well “B” location. All units are therefore assessed as having a low risk of gas. No indication of gas hydrates was found within the study area.

Un its A a nd C are assessed as having a low risk of SWF. The coarser

- grained channel fills

within Units B, D

, and E are assessed as having a low to moderate risk of SWF.

Thank you for this opportunity to be of service. Plea se contact us if you have any questions concerning this assessment.

Sincerely,

___________________________ 

### Christopher Baker

Senior Geologist

E NCLOSURES Figure 1. Extracted wavelet and power spectrum at the proposed Well “B”

. Figure 2. AUV seafloor bathymetry surrounding the proposed Well “B”

. Figure 3

. Side scan s onar mosaic at the proposed Well “B”

. Figure 4. Subbottom profiler Line 139 near the proposed Well “B”

. Figure 5

. 3D seismic Inline 1618 through the proposed Well “B”

. Figure 6

. 3D seismic Crossline 10290 through the proposed Well “B”

. Figure 7

. Top

- Hole Prognosis Chart for the proposed Well “B”

.

Sheet 1

. Color Shaded Bathymetry Map , Proposed Well “B” Location 1”=1,000’

Sheet 2. Seafloor Gradient Map, Proposed Well “B” Location 1”=1,000’

S heet 3. Seafloor Amplitude Map, Proposed Well “B” Location 1”=1,000’

Sheet 4. Seafloor & Subsurface Hazard Map, Proposed Well “B” Location 1”=1,000’C&C Project No. 140712



### 1

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### October 21 , 201 4

Freeport

- McMoRan Oil & Gas 717 Texas Avenue, Suite 2100 Houston, TX 77002

Attn: Mr. Terry Arcuri

Site Clearance Letter Proposed Well “C”

Block 198 ( OCS

- G

- 35431 ) Atwater Valley Area

Dear Mr. Arcuri

,

INTRODUCTION Freeport

- McMoRa n Oil & Gas (FMOG) contrac ted C & C Technologies, Inc. (C& C) to prepare

a well site clearance letter for the propose d Well “C” location in Block 198 ( OCS

- G

- 35431 ), Atwater Valley (AT ) Area. The data used for the site clearance letter is based on the interp retation of an exploration

- quality 3D seismic volume and a high

- resolution geophysical dataset collected with C&C’s Autonomous Underwater Vehicle (AUV) C

- Surveyor V I TM. C&C

com pleted the geohazard assessment titled “ 3D Shallow Hazard Report, Sun Prospect

, Block s 154 (OCS

- G

- 35019 )

, 197 (OCS

- G

- 35430 ), 198 (OCS

- G

- 35431), and Vicinity

, Atwater Valley

Area ” in October

, 2014 . This site clearance letter is based on the findings provi ded within that
report

.

This letter provides a top

- hole drilling prognosis and a ddresses seafloor conditions within a 2

, 000

- foot radius of the proposed surface location. The depth limit of investigation is approximately 2 .0 seconds of two

- way traveltime (~5 ,000 feet) below the mud line (BML) . The reporting and mapping presented in t his letter comply with the BOEM/BSEE guidelines provided

in NTL No. 2008

- G05 (Shallow Hazards Program ) and No. 2009

- G40 (D eepwater Benthic Communities).

METHODS AUV Survey Data

C&C’s C

- Surveyor V

I TM AUV provided multibeam bathymetric mapping, high

- resoluti on side scan sonar imagery, and subbottom profiles. The AUV remote

- sensing instruments include a Kongsberg EM 204 0 Swath Multibeam Sonar (200, 300, and 400 kHz), an EdgeTech 2200

- M Side Scan Sonar ( 410 and 120 kHz ), and a custom EdgeTech Chi rp DW106 Subbo ttom Profiler (1

- 6 kHz). All the raw digital data were logged utilizing proprietary software developed by C&C. The multibeam system delivered a 3

- meter gridded dataset with relative vertical

accuracies within 20 centimeters.

The AUV survey grid in the study area consists of one

- hundred sixty

- seven (167 ) tracklines, including one

- hundred fifty

- five (155 ) primary lines (Line Nos. 101

- 155 ) running east

- west at
200

- meter (656

- foot) line spacing and twelve (12) tie lines (Line Nos. 201

- 212 ) running north

so uth at 900

- meter (2,953

- foot) line spacing. Navigation fixes (event marks) were annotated atC&C Project No. 140712



### 2

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### 125

- meter (410

- foot) intervals along all survey lines. The survey grid was designed to provide a representative sampling with the subbottom profiler system and o verlapping coverage with side scan sonar and multibeam echosounder systems.

3D Seismic Data The 3D seismic data used for this assessment was provided in SEG

- Y format. The data were loaded into IHS’ Kingdom Suite 2d/3dPAK for interpretation. The 3D dat a were acquired by

CGGVeritas aboard the Symphony , and reprocessed with Pos t

- Stack Time Migration (PSTM)

. The 3D data were provided at a four

- millisecond sample rate and extend to the full data range of

7.0 seconds

. The inlines of the data run east

- west and are spaced at 20

- meter (65.62

- foot) intervals, while the crosslines run north

- south and are spaced at 12.5

- meter (41.01

- foot)

intervals. Spectral whitening was applied to the 3D seismic dataset to amplify the higher frequencies. After applying the sp ectral whitening, a power spectrum generated at a few selected locations indicated the seismic data volume contains sufficiently high frequency content for a

shallow hazards assessment (Figure 1)

.

The 3D seismic data are zero phase, and the seafloor refl ector is represented by a strong, positive amplitude peak flanked by troughs with absolute amplitude values of less than one

- half of the peak value. The seismic data provided adequate screening of the regional seafloor and shallow geologic conditions, and large scale geohazards (faults, salt, high acoustic impedance, stratigraphic horizons, etc.).

WELL LOCATION The coordinates and calls for the proposed Well “C” surface location are tabulated below:

Table 1. Proposed Well “C”

Well Easting

(feet) Northing

(feet) Latitude Longitude Calls From Block 198
, Atwater Valley Area

“C” 1,036, 276 ’ 10,079

, 951 ’ 27  4 5 ’ 53

. 223 ” N 88  52’ 06

. 868 ” W 6, 676 ’ FW L 5

, 711 ’ FS L



### A 2,000

- foot clearance radius is required for assessing deepwater benthic co mmunities in proximity to the proposed Well “C”

.

The geodetic datum used for this project is the North American Datum 1927 (NAD27) with the Clarke 1866 Ellipsoid. The datum is projected using the Universal Tr ansverse Mercator (UTM), Zone 16 North (16 N) with a central meridian at 87 ° 00′W, a false easting of 1,640,416.67 feet at the central meridian, and a false northing of 0.00 feet at 00° 00′N. Mapping and reporting units are in U.S. Survey Feet.

REGIONAL GEOLOGY

The Gulf of Mexico is a semi

- enclosed basin that has been rece iving sediment influx dominated by the Mississippi River since the Late Jurassic. Mesozoic and Cenozoic sediments have attained a thickness in excess of 9 miles (Coleman et al., 1991). The prograded shelf sequence consists of intercalated coastal plain, delta, estuarine, and marine sediments. Sediment deposition along the northern rim of the Gulf of Mexico resulted in particularly thick TertiaryC&C Project No. 140712



### 3

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### and Quaternary sections. These rapidly deposited sediments have prograded the Cretaceous

shelf

- edge up to 185 miles basinward. The exceptionally high rate of shelf

- edge progradation is on the order of 3.0 to 3.7 miles per 1,000 years.

The near surface geology across the Gulf Coast region is the product of fluctuating sea levels

associated with climatic variati ons over the past 20,000 years. During this time, low sea levels left the continental shelf exposed to subaerial weathering and other erosional processes. Streams and rivers meandered and cut into the exposed landmass, depositing bedloads along the moder n

day shelf break. Fan systems were formed, and mass movement events were common as deltaic sediments were deposited on the steep upper continental slope. As the climate warmed, seas transgressed, and marine sedimen ts were deposited on the shelf.

BATHYM ETRY AND SEAFLOOR GR ADIENTS

The wat er depth at the proposed Well “C” location is 4

, 906 feet below mean sea level (M SL). Within the 2,000

- foot radius area centered at the proposed Well “C” location, the seafloor depth ranges from 4, 875 fe et in the north wes t to 4

, 934 feet in the south east (Sheet 1, Color Shaded Bathymetry Map)

.

The proposed Well “C” location is situated on a very smooth sloping seafloor located in the

northeastern corner of AT198 (Figure 2)

. The seafloor in the area surrounding the propose d well

location s lopes south east at a gradient of less than 1 ° (Sheet 2, Seafloor Gradient Map)

.

SEAFLOOR HAZARDS Low to moderate sonar reflectivity occurs around the proposed wellsite indicating mostly fine

grained sediments (Figure 3 ).

T he 3D se afloor amplitude image displays a range of low to moderate acoustic amplitudes within the 2,000

- foot radius area (Sheet 3, Seafloor Amplitude Map)

. These low to moderate seafloor amplitudes indicate finely textured seafloor sediments that are likely comprised of hemipelagic clay.

No sonar contacts are found within 2,000 feet of the proposed well location.

There were no seafloor features or potential hazards identified at or in proximity to the proposed

well location (Sheet 4, Seafloor and Subsurface Hazards M ap)

.

POTENTIAL DEEPWATER BENTHIC COMMUNITIES High or low

- amplitude seismic seafloor anomalies are potential indicators of carbonates, benthic community habitats, and gas/fluid seepages. The se afloor at the proposed Well “C” and surrounding 2,000

- foot rad ius contains no high or low positive seafloor amplitude anomalies associated with fluid expulsion or mounded carbonates representing potential b enthic

communities. The s ide scan sonar a nd multibeam backscatter agree with the seafloor amplitude image, and show no evidence of outcrops or fluid expulsion.C&C Project No. 140712



### 4

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### SUBSURF ACE GEOHAZARDS AND S TRATIGRAPHY

The AUV subbottom profiler data exhibit continuous, sharp bottom echoes with parallel to divergent, continuous reflect ors throughout the wellsite area

. The uppermost shallow sediments consist of a 20 to 25 foot thick acoustically semi

- transparent hemipelagic clay drape. Sediments below this drape are characterized by parallel, low to moderate amp litude reflectors that represent cyclic deposition of hemipelagic clay an d silty clays (Figure 4)

.

Five s edimentary units (Units A to E ), each consisting of one or more distinctive sequences, were interpreted within the study area from the 3D seismic data to approximately 2 seconds of

two

- way traveltime (~5,000 feet) below the seafloor, the lower limit of investigation. Six horizons mark the upper and/or lower contacts of each of the successive units (Figures 5 and 6)

.

C&C was provided with a series of time

- depth pairs for the sediment column. The following polynomial equat ion was derived from Total Vertical Depth (TVD) (feet) and the corresponding

two

- way traveltime (seconds) using the time

- depth values to calculate depths below the seafloor:

D = 426.02 T 2 

### + 1,524.4 T

where D = depth below seafloor in feet and T = time below seafloor in seconds.

A detailed description of the sequence units, beginning at the se afloor, can be found in the 2014 Geohazard Report. The To p

- Hole Prognosis Chart (Figure 7 ) summarizes the stratigraphy.

Unit A (Seafloor to Horizon 1)

Unit A consists of mostly low amplitude, parallel, semi

- continuous reflectors and measures 1,2 90 feet thick at the proposed well location. The reflection patterns suggest the unit is comprised mostly of hemipelagic clay with interbedded fine

- grained mass transport depos its. No high amplitu de anomalies occur within Unit A near the proposed well location

.

Unit B (Horizon 1 to Horizon 2) Unit B consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 1, 592 feet thick at the proposed we ll location . Unit B is interpreted as fine

- grained mass transport deposits atop an interbedded channel fill zone. No high amplitu de anomalies occur within Unit B near the proposed well location

.

Unit C (Horizon 2 to Horizon 3)

Unit C consists of low to moderate amplitude, semi

- continuous to sub

- parallel reflectors and

measures 6 34 feet. This relatively thin u nit is interpreted as mass transport deposits with a few

interbedded channel fills. No high amplitu de anomalies occur within Unit C near the prop osed

well location

.

Unit D (Horizon 3 to Horizon 4)

Unit D consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 2, 080 feet thick at the proposed well location

. T he sediments in Unit D are interpreted

as a coarser

- grained channel fill between two finer

- grained m ass transport deposits. No highC&C Project No. 140712



### 5

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### amplitu de anomalies occur within Unit D near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Unit E (Horizon 4 to Horizon 5 )

Unit E consists of low to moderate amplitude, semi

- continuous to subparallel reflectors and

measures 1, 196 feet thick at the proposed well location

. T he sediments in Unit E are interpreted

as mostly chann el fill sitting atop an interbedded mass transport deposit zone

. No high amplitu de anomalies occur within Unit E near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potent ial.

Horizon 5 represents the salt/sediment interface at the proposed well location.

SHALLOW GAS Anomalies of very high amplitude, commonly termed bright spots, are interpreted as potential regions of fluid saturation usually associated with porous sands . Seismic amplitude anomalies are mapped on a unit

- by

- unit basis to assess the potential risk of gas. Seismic amplitude

anomalies are exhibited on the Seafloor & Subsurface Features Map

.

The risk of gas refers to the risk of encountering shallow gas. The risk of gas is interpreted based on amplitude levels. Stratigraphic and structural settings may also be taken into account. The four risk levels of gas are:

 Negligible

— No amplitude anomalies or other gas indicator present.

 Low risk of gas

— Generally indicated by increased amplitude (2

– 3× background level) and phase reversal. This may also include diffuse areas of gas blanking.

 Moderate risk of gas

— Generally indicated by high amplitude (3

– 4× background level) and phase reversal.

 High risk of gas

— Gener ally indicated by the highest amplitudes (in excess of 4× background level), phase reversal, and a combination of other attributes indicative of the presence of gas, particularly velocity pull

- down and masking of underlying sediments.

There were no ampl itude anomalies identified wit hin 2,000 feet of the proposed W ell “C” location. All units are interpreted as having a low risk of gas.

SHALLOW WATER FLOW Several factors may contribute to shallow water flows. These include: high porosity and permeabilit y, sand

- prone aquifer, mechanism to pressurize, and seal. Additional details are

described below:

 Water depth and burial depth. Significant water depths (> 500 feet below the seafloor) are required for the overpressure to occur. The seal must be deeply buried (> 500 feet below the seafloor) to become sufficiently strong.

 High deposition rates. Sedimentation rate needs to be greater than 1,500 feet/myr to effectively seal in sands. Sedimentation rates are expected to be high within a salt

withdrawal ba sin. Rapid burial leads to pressure disequilibrium. In addition, if theseC&C Project No. 140712



### 6

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### sediment ‘packets’ were formed through a sequence of turbidites or gravity flow, there is an increased likelihood of water saturation and overpressure (pore pressure rapidly increa sed and sealed by an impervious layer).

 Suitably porous sediments. The sediment packets comprising the risk of shallow water flow are believed to contain clastic material and are thus porous.

 Impermeable seal. The overlying sediments are comprised of a clay facies.

All of these factors occur within the study area. Since there is presently no method for quantifying the risk of shallow water flow, caution is recommended when drilling through units with shallow water flow potential. Sands with SWF poten tial often occur in unconsolidated, overpressured sands that lie below a seal. This seal prevents dewatering and compaction after deposition. The pressure rises with overburden causing a potentially disastrous hazard for drilling operations.

The neare st repo rted shallow water flow was in AT194 , approximately 10 miles west o f the survey area, according to information listed on the BOEM and BSEE website. This SWF event

is listed as occurring 2,132 feet below mudline and was categorized as a moderate sev erity flow

.

The assessment of seismic profiles suggests that Units A and C exhibit a low risk of SWF , while

the coarser

- grained channel fills within Units B, D

, and E exhibit a low to moderate risk . Due to the unpredictable nature of SWF, it is advised that caution be executed for any drilling operations through these sediments.

GAS HYDRATES Gas hydrates are an ice crystalline form of gas hydrocarbons in deepwater marine environments where the conditions of pressure and temperature are favorable. The hydrate stability zone is the depth interval between the seafloor and the point where the hydrate is no longer stable in form. The thermal gradient of the seabed soils determines the depth of the hydrate stability zone base. The acoustic impedance contra st caused between the hydrate and free gas trapped at the base of the hydrate stability zone forms a Bottom Simulating Reflector (BSR) on seismic profiles. This BSR reflector cross cuts the normal seismic stratigraphy, much like a bottom multiple.

The ar eas where seafloor gas hydrates accumulate in the near

- surface sediments of the Gulf of Mexico are generally unfavorable sites for drilling operations. Irregular seafloor topography, gas seeps, gas chimneys, seafloor hydrates and deepwater benthic communi ties may all be found in

close association. No indication of BSRs was found in the vicinity of the proposed well.

CONCLUSIONS The proposed Well “C” location is situated on a very smooth sloping seafloor at a water depth of 4, 906 feet MSL . The seabed slo pes gently to the southeast at a gradient of less than 1 °

.

There were no potential hazardous features identified near the proposed Well “C” location.

No sonar contacts exist within 2,000 feet of the proposed Well “C” location.C&C Project No. 140712



### 7

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 705 08 

### No high or low seafloor amplitudes anomalies that may indicate the occurrence of hardgrounds, carbonates, benthic communities or potential expulsions are found within 2,000 feet of the proposed Well “C” location.

Five ( 5 ) subsurface units interpreted from the 3D seismic data wer e assessed to approximately 5,000 feet BSF at the proposed Well “C” location (Units A to E )

. Unit A is comprised mostly of low amplitude, parallel to semi

- continuous ref lectors and consists of hemipelagic clays and mass transport deposits. Unit B is char acterized by low to moderate amplitude, semi

- continuous to

chaotic reflectors and consists of fine

- grained mass transport deposits atop an interbedded channel fill zone. Unit C is comprised of low to moderate amplitude, semi

- continuous reflectors

and is i nterpreted as mostly mass transport deposits with a few interbedded channel fills. Units D and E consist of low to moderate, semi

- continuous to chaotic reflectors and consists of alternating layers of fine

- grained mass transport deposits and coarser

- grain ed channel fill zones.

There were no amplitude anomalies indicative of shallow gas identified within any of the unit s at the proposed Well “C” location. All units are therefore assessed as having a low risk of gas. No indication of gas hydrates was found within the study area.

Un its A a nd C are assessed as having a low risk of SWF. The coarser

- grained channel fills

within Units B, D

, and E are assessed as having a low to moderate risk of SWF.

Thank you for this opportunity to be of service. Plea se contact us if you have any questions concerning this assessment.

Sincerely,

___________________________ 

### Christopher Baker

Senior Geologist

E NCLOSURES Figure 1. Extracted wavelet and power spectrum at the proposed Well “C”

. Figure 2. AUV seafloor bathymetry surrounding the proposed Well “C”

. Figure 3

. Side scan s onar mosaic at the proposed Well “C”

. Figure 4. Subbottom profiler Line 143 near the proposed Well “C”

. Figure 5

. 3D seismic Inline 1571 through the proposed Well “C”

. Figure 6

. 3D seismic Crossline 102 83 through the proposed Well “C”

. Figure 7

. Top

- Hole Prognosis Chart for the proposed Well “C”

.

Sheet 1

. Color Shaded Bathymetry Map , Proposed Well “C” Location 1”=1,000’

Sheet 2. Seafloor Gradient Map, Proposed Well “C” Location 1”=1,000’

S heet 3. Seafloor Amplitude Map, Proposed Well “C” Location 1”=1,000’

Sheet 4. Seafloor & Subsurface Hazard Map, Proposed Well “C” Location 1”=1,000’C&C Project No. 140712



### 1

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### October 21 , 201 4

Freeport

- McMoRan Oil & Gas 717 Texas Avenue, Suite 2100 Houston, TX 77002

Attn: Mr. Terry Arcuri

Site Clearance Letter Proposed Well “D”

Block 198 ( OCS

- G

- 35431 ) Atwater Valley Area

Dear Mr. Arcuri

,

INTRODUCTION Freeport

- McMoRa n Oil & Gas (FMOG) contrac ted C & C Technologies, Inc. (C& C) to prepare

a well site clearance letter for the propose d Well “D” location in Block 198 ( OCS

- G

- 35431 ), Atwater Valley (AT ) Area. The data used for the site clearance letter is based on the interp retation of an exploration

- quality 3D seismic volume and a high

- resolution geophysical dataset collected with C&C’s Autonomous Underwater Vehicle (AUV) C

- Surveyor V I TM. C&C

com pleted the geohazard assessment titled “ 3D Shallow Hazard Report, Sun Prospect

, Block s 154 (OCS

- G

- 35019 )

, 197 (OCS

- G

- 35430 ), 198 (OCS

- G

- 35431), and Vicinity

, Atwater Valley

Area ” in October

, 2014 . This site clearance letter is based on the findings provi ded within that
report

.

This letter provides a top

- hole drilling prognosis and a ddresses seafloor conditions within a 2

, 000

- foot radius of the proposed surface location. The depth limit of investigation is approximately 2 .0 seconds of two

- way traveltime (~5 ,000 feet) below the mud line (BML) . The reporting and mapping presented in t his letter comply with the BOEM/BSEE guidelines provided

in NTL No. 2008

- G05 (Shallow Hazards Program ) and No. 2009

- G40 (D eepwater Benthic Communities).

METHODS AUV Survey Data

C&C’s C

- Surveyor V

I TM AUV provided multibeam bathymetric mapping, high

- resoluti on side scan sonar imagery, and subbottom profiles. The AUV remote

- sensing instruments include a Kongsberg EM 204 0 Swath Multibeam Sonar (200, 300, and 400 kHz), an EdgeTech 2200

- M Side Scan Sonar ( 410 and 120 kHz ), and a custom EdgeTech Chi rp DW106 Subbo ttom Profiler (1

- 6 kHz). All the raw digital data were logged utilizing proprietary software developed by C&C. The multibeam system delivered a 3

- meter gridded dataset with relative vertical

accuracies within 20 centimeters.

The AUV survey grid in the study area consists of one

- hundred sixty

- seven (167 ) tracklines, including one

- hundred fifty

- five (155 ) primary lines (Line Nos. 101

- 155 ) running east

- west at
200

- meter (656

- foot) line spacing and twelve (12) tie lines (Line Nos. 201

- 212 ) running north

so uth at 900

- meter (2,953

- foot) line spacing. Navigation fixes (event marks) were annotated atC&C Project No. 140712



### 2

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### 125

- meter (410

- foot) intervals along all survey lines. The survey grid was designed to provide a representative sampling with the subbottom profiler system and o verlapping coverage with side scan sonar and multibeam echosounder systems.

3D Seismic Data The 3D seismic data used for this assessment was provided in SEG

- Y format. The data were loaded into IHS’ Kingdom Suite 2d/3dPAK for interpretation. The 3D dat a were acquired by

CGGVeritas aboard the Symphony , and reprocessed with Pos t

- Stack Time Migration (PSTM)

. The 3D data were provided at a four

- millisecond sample rate and extend to the full data range of

7.0 seconds

. The inlines of the data run east

- west and are spaced at 20

- meter (65.62

- foot) intervals, while the crosslines run north

- south and are spaced at 12.5

- meter (41.01

- foot)

intervals. Spectral whitening was applied to the 3D seismic dataset to amplify the higher frequencies. After applying the sp ectral whitening, a power spectrum generated at a few selected locations indicated the seismic data volume contains sufficiently high frequency content for a

shallow hazards assessment (Figure 1)

.

The 3D seismic data are zero phase, and the seafloor refl ector is represented by a strong, positive amplitude peak flanked by troughs with absolute amplitude values of less than one

- half of the peak value. The seismic data provided adequate screening of the regional seafloor and shallow geologic conditions, and large scale geohazards (faults, salt, high acoustic impedance, stratigraphic horizons, etc.).

WELL LOCATION The coordinates and calls for the proposed Well “D” surface location are tabulated below:

Table 1. Proposed Well “D”

Well Easting

(feet) Northing

(feet) Latitude Longitude Calls From Block 198
, Atwater Valley Area

“D” 1,03 4

, 658 ’ 10,0 85

, 122 ’ 27  4 6 ’ 44

. 177 ” N 88  52’ 25

. 753 ” W 5

, 058 ’ FW L 4

, 958 ’ F N L



### A 2,000

- foot clearance radius is required for assessing deepwater benthic co mmunities in proximity to the proposed Well “D”

.

The geodetic datum used for this project is the North American Datum 1927 (NAD27) with the Clarke 1866 Ellipsoid. The datum is projected using the Universal Tr ansverse Mercator (UTM), Zone 16 North (16 N) with a central meridian at 87 ° 00′W, a false easting of 1,640,416.67 feet at the central meridian, and a false northing of 0.00 feet at 00° 00′N. Mapping and reporting units are in U.S. Survey Feet.

REGIONAL GEOLOGY

The Gulf of Mexico is a semi

- enclosed basin that has been rece iving sediment influx dominated by the Mississippi River since the Late Jurassic. Mesozoic and Cenozoic sediments have attained a thickness in excess of 9 miles (Coleman et al., 1991). The prograded shelf sequence consists of intercalated coastal plain, delta, estuarine, and marine sediments. Sediment deposition along the northern rim of the Gulf of Mexico resulted in particularly thick TertiaryC&C Project No. 140712



### 3

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### and Quaternary sections. These rapidly deposited sediments have prograded the Cretaceous

shelf

- edge up to 185 miles basinward. The exceptionally high rate of shelf

- edge progradation is on the order of 3.0 to 3.7 miles per 1,000 years.

The near surface geology across the Gulf Coast region is the product of fluctuating sea levels

associated with climatic variati ons over the past 20,000 years. During this time, low sea levels left the continental shelf exposed to subaerial weathering and other erosional processes. Streams and rivers meandered and cut into the exposed landmass, depositing bedloads along the moder n

day shelf break. Fan systems were formed, and mass movement events were common as deltaic sediments were deposited on the steep upper continental slope. As the climate warmed, seas transgressed, and marine sedimen ts were deposited on the shelf.

BATHYM ETRY AND SEAFLOOR GR ADIENTS

The wat er depth at the proposed Well “D” location is 4

, 835 feet below mean sea level (M SL). Within the 2,000

- foot radius area centered at the proposed Well “D” location, the seafloor depth ranges from 4, 8 09 fe et in the north wes t to 4

, 860 feet in the south east (Sheet 1, Color Shaded Bathymetry Map)

.

The proposed Well “D” location is situated on a very smooth sloping seafloor located in the

northeastern corner of AT198 (Figure 2)

. The seafloor in the area surrounding the propose d well

location s lopes south east at a gradient of less than 1 ° (Sheet 2, Seafloor Gradient Map)

.

SEAFLOOR HAZARDS Low to moderate sonar reflectivity occurs around the proposed wellsite indicating mostly fine

grained sediments (Figure 3 ).

T he 3D se afloor amplitude image displays a range of low to moderate acoustic amplitudes within the 2,000

- foot radius area (Sheet 3, Seafloor Amplitude Map)

. These low to moderate seafloor amplitudes indicate finely textured seafloor sediments that are likely comprised of hemipelagic clay.

One sonar contact was found within 2,000 feet of the proposed well location. Sonar Contact No. 7 was found 930 feet southeast of the proposed location and measures 13.3 feet long, 3.1 feet wide, and has no measurable height.

There w ere no seafloor features or potential hazards identified at or in proximity to the proposed

well location (Sheet 4, Seafloor and Subsurface Hazards Map)

.

POTENTIAL DEEPWATER BENTHIC COMMUNITIES High or low

- amplitude seismic seafloor anomalies are potentia l indicators of carbonates, benthic community habitats, and gas/fluid seepages. The se afloor at the proposed Well “D” and surrounding 2,000

- foot radius contains no high or low positive seafloor amplitude anomalies associated with fluid expulsion or mounde d carbonates representing potential b enthic

communities. The s ide scan sonar a nd multibeam backscatter agree with the seafloor amplitude image, and show no evidence of outcrops or fluid expulsion.C&C Project No. 140712



### 4

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### SUBSURF ACE GEOHAZARDS AND S TRATIGRAPHY

The AUV subbottom p rofiler data exhibit continuous, sharp bottom echoes with parallel to divergent, continuous reflect ors throughout the wellsite area

. The uppermost shallow sediments consist of a 20 to 25 foot thick acoustically semi

- transparent hemipelagic clay drape. Se diments below this drape are characterized by parallel, low to moderate amp litude reflectors that represent cyclic deposition of hemipelagic clay and silty clays (Figure 4)

.

Five s edimentary units (Units A to E ), each consisting of one or more distinctive sequences, were interpreted within the study area from the 3D seismic data to approximately 2 seconds of

two

- way traveltime (~5,000 feet) below the seafloor, the lower limit of investigation. Six horizons mark the upper and/or lower contacts of each of t he successive units (Figures 5 and 6)

.

C&C was provided with a series of time

- depth pairs for the sediment column. The following polynomial equation was derived from Total Vertical Depth (TVD) (feet) and the corresponding

two

- way traveltime (seconds) us ing the time

- depth values to calculate depths below the seafloor:

D = 426.02 T 2 

### + 1,524.4 T

where D = depth below seafloor in feet and T = time below seafloor in seconds.

A detailed description of the sequence units, beginning at the se afloor, can be found in the 2014 Geohazard Report. The To p

- Hole Prognosis Chart (Figure 7 ) summarizes the stratigraphy.

Unit A (Seafloor to Horizon 1)

Unit A consists of mostly low amplitude, parallel, semi

- continuous reflectors and measures 1,2 52 feet thick at the proposed well location. The reflection patterns suggest the unit is comprised mostly of hemipelagic clay with interbedded fine

- grained mass transport deposits. No high amplitu de anomalies occur within Unit A near the proposed well location

.

Unit B (Horizon 1 to Horizon 2) Unit B consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 1, 818 feet thick at the proposed well location . Unit B is interpreted as fine

- grained mass transport deposits atop an interbedded channel fill zone. No high amplitu de anomalies occur within Unit B near the proposed well location

.

Unit C (Horizon 2 to Horizon 3) Unit C consists of low to moderate amplitude, semi

- continuous to sub

- parallel reflectors and

measures 6 90 feet. This relatively thin u nit is interpreted as mass transport deposits with a few

interbedded channel fills. No high amplitu de anomalies occur within Unit C near the proposed

well location

.

Unit D (Horizon 3 to Horizon 4)

Unit D consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 2, 127 feet thick at the proposed well location

. T he sediments in Unit D are interpreted

as a coarser

- grained channel fill between two finer

- grained m ass transport deposits. No highC&C Project No. 140712



### 5

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### amplitu de anomalies occur w ithin Unit D near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Unit E (Horizon 4 to Horizon 5 )

Unit E consists of low to moderate amplitude, semi

- contin uous to subparallel reflectors and

measures 1, 367 feet thick at the proposed well location

. T he sediments in Unit E are interpreted

as mostly channel fill sitting atop an interbedded mass transport deposit zone

. No high amplitu de anomalies occur within U nit E near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Horizon 5 represents the salt/sediment interface at the proposed well location.

SHALLOW GAS

Anomalies of very high amplitude, commonly termed bright spots, are interpreted as potential regions of fluid saturation usually associated with porous sands. Seismic amplitude anomalies are mapped on a unit

- by

- unit basis to assess the potential risk of gas. Seis mic amplitude

anomalies are exhibited on the Seafloor & Subsurface Features Map

.

The risk of gas refers to the risk of encountering shallow gas. The risk of gas is interpreted based on amplitude levels. Stratigraphic and structural settings may also be taken into account. The four risk levels of gas are:

 Negligible

— No amplitude anomalies or other gas indicator present.

 Low risk of gas

— Generally indicated by increased amplitude (2

– 3× background level) and phase reversal. This may also include diffuse areas of gas blanking.

 Moderate risk of gas

— Generally indicated by high amplitude (3

– 4× background level) and phase reversal.

 High risk of gas

— Generally indicated by the highest amplitudes (in excess of 4× background level), phase reversal, and a combinati on of other attributes indicative of the presence of gas, particularly velocity pull

- down and masking of underlying sediments.

There were no amplitude anomalies identified wit hin 2,000 feet of the proposed W ell “D” location. All units are interpreted a s having a low risk of gas.

SHALLOW WATER FLOW Several factors may contribute to shallow water flows. These include: high porosity and permeability, sand

- prone aquifer, mechanism to pressurize, and seal. Additional details are

described below:

 Water de pth and burial depth. Significant water depths (> 500 feet below the seafloor) are required for the overpressure to occur. The seal must be deeply buried (> 500 feet below the seafloor) to become sufficiently strong.

 High deposition rates. Sedimentation rate needs to be greater than 1,500 feet/myr to effectively seal in sands. Sedimentation rates are expected to be high within a salt withdrawal basin. Rapid burial leads to pressure disequilibrium. In addition, if theseC&C Project No. 140712



### 6

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### sediment ‘packets’ were formed t hrough a sequence of turbidites or gravity flow, there is an increased likelihood of water saturation and overpressure (pore pressure rapidly increased and sealed by an impervious layer).

 Suitably porous sediments. The sediment packets comprising the ri sk of shallow water flow are believed to contain clastic material and are thus porous.

 Impermeable seal. The overlying sediments are comprised of a clay facies.

All of these factors occur within the study area. Since there is presently no method for

qua ntifying the risk of shallow water flow, caution is recommended when drilling through units with shallow water flow potential. Sands with SWF potential often occur in unconsolidated, overpressured sands that lie below a seal. This seal prevents dewaterin g and compaction after deposition. The pressure rises with overburden causing a potentially disastrous hazard for drilling operations.

The nearest repo rted shallow water flow was in AT194 , approximately 10 miles west o f the survey area, according to in formation listed on the BOEM and BSEE website. This SWF event

is listed as occurring 2,132 feet below mudline and was categorized as a moderate severity flow

.

The assessment of seismic profiles suggests that Units A and C exhibit a low risk of SWF , whi le

the coarser

- grained channel fills within Units B, D

, and E exhibit a low to moderate risk . Due to the unpredictable nature of SWF, it is advised that caution be executed for any drilling operations through these sediments.

GAS HYDRATES Gas hydrates ar e an ice crystalline form of gas hydrocarbons in deepwater marine environments where the conditions of pressure and temperature are favorable. The hydrate stability zone is the depth interval between the seafloor and the point where the hydrate is no long er stable in form. The thermal gradient of the seabed soils determines the depth of the hydrate stability zone base. The acoustic impedance contrast caused between the hydrate and free gas trapped at the base of the hydrate stability zone forms a Bottom Simulating Reflector (BSR) on seismic profiles. This BSR reflector cross cuts the normal seismic stratigraphy, much like a bottom multiple.

The areas where seafloor gas hydrates accumulate in the near

- surface sediments of the Gulf of Mexico are generally unfavorable sites for drilling operations. Irregular seafloor topography, gas seeps, gas chimneys, seafloor hydrates and deepwater benthic communities may all be found in

close association. No indication of BSRs was found in the vicinity of the proposed well.

CONCLUSIONS The proposed Well “D” location is situated on a very smooth sloping seafloor at a water depth of 4, 835 feet MSL . The seabed slopes gently to the southeast at a gradient of less than 1 °

.

There were no potential hazardous features iden tified near the proposed Well “D” location.C&C Project No. 140712



### 7

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### One sonar contact was found within 2,000 feet of the proposed well location. Sonar Contact No. 7 was found 930 feet southeast of the proposed location and measures 13.3 feet long, 3.1 feet wide, and has no meas urable height.

No high or low seafloor amplitudes anomalies that may indicate the occurrence of hardgrounds, carbonates, benthic communities or potential expulsions are found within 2,000 feet of the proposed Well “D” location.

Five ( 5 ) subsurface units interpreted from the 3D seismic data were assessed to approximately 5,000 feet BSF at the proposed Well “D” location (Units A to E )

. Unit A is comprised mostly of low amplitude, parallel to semi

- continuous ref lectors and consists of hemipelagic clays and mass transport deposits. Unit B is characterized by low to moderate amplitude, semi

- continuous to

chaotic reflectors and consists of fine

- grained mass transport deposits atop an interbedded channel fill zone. Unit C is comprised of low to moderate ampli tude, semi

- continuous reflectors and is interpreted as mostly mass transport deposits with a few interbedded channel fills. Units D and E consist of low to moderate, semi

- continuous to chaotic reflectors and consists of alternating layers of fine

- grained mass transport deposits and coarser

- grained channel fill zones.

There were no amplitude anomalies indicative of shallow gas identified within any of the unit s at the proposed Well “D” location. All units are therefore assessed as having a low risk o f gas. No indication of gas hydrates was found within the study area.

Un its A a nd C are assessed as having a low risk of SWF. The coarser

- grained channel fills

within Units B, D

, and E are assessed as having a low to moderate risk of SWF.

Thank you fo r this opportunity to be of service. Please contact us if you have any questions concerning this assessment.

Sincerely,

___________________________ 

### Christopher Baker

Senior GeologistC&C Project No. 140712



### 8

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### E NCLOSURES Figure 1. Extracted wavelet and power spectru m at the proposed Well “D”

. Figure 2. AUV seafloor bathymetry surrounding the proposed Well “D”

. Figure 3

. Side scan s onar mosaic at the proposed Well “D”

. Figure 4. Subbottom profiler Line 136 near the proposed Well “D”

. Figure 5

. 3D seismic Inline 1649 t hrough the proposed Well “D”

. Figure 6

. 3D seismic Crossline 102 44 through the proposed Well “D”

. Figure 7

. Top

- Hole Prognosis Chart for the proposed Well “D”

.

Sheet 1

. Color Shaded Bathymetry Map , Proposed Well “D” Location 1”=1,000’

Sheet 2. Seafloor Gr adient Map, Proposed Well “D” Location 1”=1,000’

Sheet 3. Seafloor Amplitude Map, Proposed Well “D” Location 1”=1,000’

Sheet 4. Seafloor & Subsurface Hazard Map, Proposed Well “D” Location 1”=1,000’C&C Project No. 140712



### 1

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### October 21 , 201 4

Freeport

- McMoRan Oil & Gas 717 Texas Avenue, Suite 2100 Houston, TX 77002

Attn: Mr. Terry Arcuri

Site Clearance Letter Proposed Well “E”

Block 198 ( OCS

- G

- 35431 ) Atwater Valley Area

Dear Mr. Arcuri

,

INTRODUCTION Freeport

- McMoRa n Oil & Gas (FMOG) contrac ted C & C Technologies, Inc. (C& C) to prepare

a well site clearance letter for the propose d Well “E” location in Block 198 ( OCS

- G

- 35431 ), Atwater Valley (AT ) Area. The data used for the site clearance letter is based on the interp retation of an exploration

- quality 3D seismic volume and a high

- resolution geophysical dataset collected with C&C’s Autonomous Underwater Vehicle (AUV) C

- Surveyor V I TM. C&C

com pleted the geohazard assessment titled “ 3D Shallow Hazard Report, Sun Prospect

, Block s 154 (OCS

- G

- 35019 )

, 197 (OCS

- G

- 35430 ), 198 (OCS

- G

- 35431), and Vicinity

, Atwater Valley

Area ” in October

, 2014 . This site clearance letter is based on the findings provi ded within that
report

.

This letter provides a top

- hole drilling prognosis and a ddresses seafloor conditions within a 2

, 000

- foot radius of the proposed surface location. The depth limit of investigation is approximately 2 .0 seconds of two

- way traveltime (~5 ,000 feet) below the mud line (BML) . The reporting and mapping presented in t his letter comply with the BOEM/BSEE guidelines provided

in NTL No. 2008

- G05 (Shallow Hazards Program ) and No. 2009

- G40 (D eepwater Benthic Communities).

METHODS AUV Survey Data

C&C’s C

- Surveyor V

I TM AUV provided multibeam bathymetric mapping, high

- resoluti on side scan sonar imagery, and subbottom profiles. The AUV remote

- sensing instruments include a Kongsberg EM 204 0 Swath Multibeam Sonar (200, 300, and 400 kHz), an EdgeTech 2200

- M Side Scan Sonar ( 410 and 120 kHz ), and a custom EdgeTech Chi rp DW106 Subbo ttom Profiler (1

- 6 kHz). All the raw digital data were logged utilizing proprietary software developed by C&C. The multibeam system delivered a 3

- meter gridded dataset with relative vertical

accuracies within 20 centimeters.

The AUV survey grid in the study area consists of one

- hundred sixty

- seven (167 ) tracklines, including one

- hundred fifty

- five (155 ) primary lines (Line Nos. 101

- 155 ) running east

- west at
200

- meter (656

- foot) line spacing and twelve (12) tie lines (Line Nos. 201

- 212 ) running north

so uth at 900

- meter (2,953

- foot) line spacing. Navigation fixes (event marks) were annotated atC&C Project No. 140712



### 2

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### 125

- meter (410

- foot) intervals along all survey lines. The survey grid was designed to provide a representative sampling with the subbottom profiler system and o verlapping coverage with side scan sonar and multibeam echosounder systems.

3D Seismic Data The 3D seismic data used for this assessment was provided in SEG

- Y format. The data were loaded into IHS’ Kingdom Suite 2d/3dPAK for interpretation. The 3D dat a were acquired by

CGGVeritas aboard the Symphony , and reprocessed with Pos t

- Stack Time Migration (PSTM)

. The 3D data were provided at a four

- millisecond sample rate and extend to the full data range of

7.0 seconds

. The inlines of the data run east

- west and are spaced at 20

- meter (65.62

- foot) intervals, while the crosslines run north

- south and are spaced at 12.5

- meter (41.01

- foot)

intervals. Spectral whitening was applied to the 3D seismic dataset to amplify the higher frequencies. After applying the sp ectral whitening, a power spectrum generated at a few selected locations indicated the seismic data volume contains sufficiently high frequency content for a

shallow hazards assessment (Figure 1)

.

The 3D seismic data are zero phase, and the seafloor refl ector is represented by a strong, positive amplitude peak flanked by troughs with absolute amplitude values of less than one

- half of the peak value. The seismic data provided adequate screening of the regional seafloor and shallow geologic conditions, and large scale geohazards (faults, salt, high acoustic impedance, stratigraphic horizons, etc.).

WELL LOCATION The coordinates and calls for the proposed Well “E” surface location are tabulated below:

Table 1. Proposed Well “E”

Well Easting

(feet) Northing

(feet) Latitude Longitude Calls From Block 198
, Atwater Valley Area

“E” 1,03 6

, 910 ’ 10,0 84

, 657 ’ 27  4 6 ’ 39

. 912 ” N 88  52’ 00

. 607 ” W 7

, 310 ’ FW L 5

, 423 ’ F N L



### A 2,000

- foot clearance radius is required for assessing deepwater benthic co mmunities in proximity to the proposed Well “E”

.

The geodetic datum used for this project is the North American Datum 1927 (NAD27) with the Clarke 1866 Ellipsoid. The datum is projected using the Universal Tr ansverse Mercator (UTM), Zone 16 North (16 N) with a central meridian at 87 ° 00′W, a false easting of 1,640,416.67 feet at the central meridian, and a false northing of 0.00 feet at 00° 00′N. Mapping and reporting units are in U.S. Survey Feet.

REGIONAL GEOLOGY

The Gulf of Mexico is a semi

- enclosed basin that has been rece iving sediment influx dominated by the Mississippi River since the Late Jurassic. Mesozoic and Cenozoic sediments have attained a thickness in excess of 9 miles (Coleman et al., 1991). The prograded shelf sequence consists of intercalated coastal plain, delta, estuarine, and marine sediments. Sediment deposition along the northern rim of the Gulf of Mexico resulted in particularly thick TertiaryC&C Project No. 140712



### 3

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### and Quaternary sections. These rapidly deposited sediments have prograded the Cretaceous

shelf

- edge up to 185 miles basinward. The exceptionally high rate of shelf

- edge progradation is on the order of 3.0 to 3.7 miles per 1,000 years.

The near surface geology across the Gulf Coast region is the product of fluctuating sea levels

associated with climatic variati ons over the past 20,000 years. During this time, low sea levels left the continental shelf exposed to subaerial weathering and other erosional processes. Streams and rivers meandered and cut into the exposed landmass, depositing bedloads along the moder n

day shelf break. Fan systems were formed, and mass movement events were common as deltaic sediments were deposited on the steep upper continental slope. As the climate warmed, seas transgressed, and marine sedimen ts were deposited on the shelf.

BATHYM ETRY AND SEAFLOOR GR ADIENTS

The wat er depth at the proposed Well “E” location is 4

, 860 feet below mean sea level (M SL). Within the 2,000

- foot radius area centered at the proposed Well “E” location, the seafloor depth ranges from 4, 8 32 fe et in the north wes t to 4

, 89 0 feet in the south east (Sheet 1, Color Shaded Bathymetry Map)

.

The proposed Well “E” location is situated on a very smooth sloping seafloor located in the

northeastern corner of AT198 (Figure 2)

. The seafloor in the area surrounding the propose d well

location s lopes south east at a gradient of less than 1 ° (Sheet 2, Seafloor Gradient Map)

.

SEAFLOOR HAZARDS Low to moderate sonar reflectivity occurs around the proposed wellsite indicating mostly fine

grained sediments (Figure 3 ).

T he 3D se afloor amplitude image displays a range of low to moderate acoustic amplitudes within the 2,000

- foot radius area (Sheet 3, Seafloor Amplitude Map)

. These low to moderate seafloor amplitudes indicate finely textured seafloor sediments that are likely comprised of hemipelagic clay.

One sonar contact was found within 2,000 feet of the proposed well location. Sonar Contact No.

7 was found 1,382 feet west of the proposed location and measures 13.3 feet long, 3.1 feet wide, and has no measurable height.

There were no seafloor features or potential hazards identified at or in proximity to the proposed

well location (Sheet 4, Seafloor and Subsurface Hazards Map)

.

POTENTIAL DEEPWATER BENTHIC COMMUNITIES High or low

- amplitude seismic seafloor anomalies are potential i ndicators of carbonates, benthic community habitats, and gas/fluid seepages. The se afloor at the proposed Well “E” and surrounding 2,000

- foot radius contains no high or low positive seafloor amplitude anomalies associated with fluid expulsion or mounded c arbonates representing potential b enthic

communities. The s ide scan sonar a nd multibeam backscatter agree with the seafloor amplitude image, and show no evidence of outcrops or fluid expulsion.C&C Project No. 140712



### 4

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### SUBSURF ACE GEOHAZARDS AND S TRATIGRAPHY

The AUV subbottom prof iler data exhibit continuous, sharp bottom echoes with parallel to divergent, continuous reflect ors throughout the wellsite area

. The uppermost shallow sediments consist of a 20 to 25 foot thick acoustically semi

- transparent hemipelagic clay drape. Sedim ents below this drape are characterized by parallel, low to moderate amp litude reflectors that represent cyclic deposition of hemipelagic clay and silty clays (Figure 4)

.

Five s edimentary units (Units A to E ), each consisting of one or more distinctive se quences, were interpreted within the study area from the 3D seismic data to approximately 2 seconds of

two

- way traveltime (~5,000 feet) below the seafloor, the lower limit of investigation. Six horizons mark the upper and/or lower contacts of each of the successive units (Figures 5 and 6)

.

C&C was provided with a series of time

- depth pairs for the sediment column. The following polynomial equation was derived from Total Vertical Depth (TVD) (feet) and the corresponding

two

- way traveltime (seconds) using the time

- depth values to calculate depths below the seafloor:

D = 426.02 T 2 

### + 1,524.4 T

where D = depth below seafloor in feet and T = time below seafloor in seconds.

A detailed description of the sequence units, beginning at the se afloor, can be found in the 2014 Geohazard Report. The To p

- Hole Prognosis Chart (Figure 7 ) summarizes the stratigraphy.

Unit A (Seafloor to Horizon 1)

Unit A consists of mostly low amplitude, parallel, semi

- continuous reflectors and measures 1,161 feet thick at the proposed we ll location. The reflection patterns suggest the unit is comprised mostly of hemipelagic clay with interbedded fine

- grained mass transport deposits. No high amplitu de anomalies occur within Unit A near the proposed well location

.

Unit B (Horizon 1 t o Horizon 2) Unit B consists of low to moderate amplitude, semi

- continuous to chaotic reflectors and

measures 1, 874 feet thick at the proposed well location . Unit B is interpreted as fine

- grained mass transport deposits atop an interbedded channel fill zo ne. No high amplitu de anomalies occur within Unit B near the proposed well location

.

Unit C (Horizon 2 to Horizon 3) Unit C consists of low to moderate amplitude, semi

- continuous to sub

- parallel reflectors and

measures 6 49 feet. This relatively thin u n it is interpreted as mass transport deposits with a few

interbedded channel fills. No high amplitu de anomalies occur within Unit C near the proposed

well location

.

Unit D (Horizon 3 to Horizon 4)

Unit D consists of low to moderate amplitude, semi

- con tinuous to chaotic reflectors and

measures 2, 096 feet thick at the proposed well location

. T he sediments in Unit D are interpreted

as a coarser

- grained channel fill between two finer

- grained m ass transport deposits. No highC&C Project No. 140712



### 5

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### amplitu de anomalies occur with in Unit D near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Unit E (Horizon 4 to Horizon 5 )

Unit E consists of low to moderate amplitude, semi

- continuou s to subparallel reflectors and

measures 1, 406 feet thick at the proposed well location

. T he sediments in Unit E are interpreted

as mostly channel fill sitting atop an interbedded mass transport deposit zone

. No high amplitu de anomalies occur within Unit E near the proposed well location

. The coarser sediments found in the channel fill zone may represent low to moderate shallow water flow potential.

Horizon 5 represents the salt/sediment interface at the proposed well location.

SHALLOW GAS

Anomalies of very high amplitude, commonly termed bright spots, are interpreted as potential regions of fluid saturation usually associated with porous sands. Seismic amplitude anomalies are mapped on a unit

- by

- unit basis to assess the potential risk of gas. Seismic amplitude

anomalies are exhibited on the Seafloor & Subsurface Features Map

.

The risk of gas refers to the risk of encountering shallow gas. The risk of gas is interpreted based on amplitude levels. Stratigraphic and structural settings may also be ta ken into account. The four risk levels of gas are:

 Negligible

— No amplitude anomalies or other gas indicator present.

 Low risk of gas

— Generally indicated by increased amplitude (2

– 3× background level) and phase reversal. This may also include diffuse are as of gas blanking.

 Moderate risk of gas

— Generally indicated by high amplitude (3

– 4× background level) and phase reversal.

 High risk of gas

— Generally indicated by the highest amplitudes (in excess of 4× background level), phase reversal, and a combination of other attributes indicative of the presence of gas, particularly velocity pull

- down and masking of underlying sediments.

There were no amplitude anomalies identified wit hin 2,000 feet of the proposed W ell “E” location. All units are interpreted as h aving a low risk of gas.

SHALLOW WATER FLOW Several factors may contribute to shallow water flows. These include: high porosity and permeability, sand

- prone aquifer, mechanism to pressurize, and seal. Additional details are

described below:

 Water depth and burial depth. Significant water depths (> 500 feet below the seafloor) are required for the overpressure to occur. The seal must be deeply buried (> 500 feet below the seafloor) to become sufficiently strong.

 High deposition rates. Sedimentation ra te needs to be greater than 1,500 feet/myr to effectively seal in sands. Sedimentation rates are expected to be high within a salt withdrawal basin. Rapid burial leads to pressure disequilibrium. In addition, if theseC&C Project No. 140712



### 6

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### sediment ‘packets’ were formed thro ugh a sequence of turbidites or gravity flow, there is an increased likelihood of water saturation and overpressure (pore pressure rapidly increased and sealed by an impervious layer).

 Suitably porous sediments. The sediment packets comprising the risk of shallow water flow are believed to contain clastic material and are thus porous.

 Impermeable seal. The overlying sediments are comprised of a clay facies.

All of these factors occur within the study area. Since there is presently no method for quanti fying the risk of shallow water flow, caution is recommended when drilling through units with shallow water flow potential. Sands with SWF potential often occur in unconsolidated, overpressured sands that lie below a seal. This seal prevents dewatering a nd compaction after deposition. The pressure rises with overburden causing a potentially disastrous hazard for drilling operations.

The nearest repo rted shallow water flow was in AT194 , approximately 10 miles west o f the survey area, according to infor mation listed on the BOEM and BSEE website. This SWF event

is listed as occurring 2,132 feet below mudline and was categorized as a moderate severity flow

.

The assessment of seismic profiles suggests that Units A and C exhibit a low risk of SWF , while

the coarser

- grained channel fills within Units B, D

, and E exhibit a low to moderate risk . Due to the unpredictable nature of SWF, it is advised that caution be executed for any drilling operations through these sediments.

GAS HYDRATES Gas hydrates are a n ice crystalline form of gas hydrocarbons in deepwater marine environments where the conditions of pressure and temperature are favorable. The hydrate stability zone is the depth interval between the seafloor and the point where the hydrate is no longer stable in form. The thermal gradient of the seabed soils determines the depth of the hydrate stability zone base. The acoustic impedance contrast caused between the hydrate and free gas trapped at the base of the hydrate stability zone forms a Bottom Sim ulating Reflector (BSR) on seismic profiles. This BSR reflector cross cuts the normal seismic stratigraphy, much like a bottom multiple.

The areas where seafloor gas hydrates accumulate in the near

- surface sediments of the Gulf of Mexico are generally un favorable sites for drilling operations. Irregular seafloor topography, gas seeps, gas chimneys, seafloor hydrates and deepwater benthic communities may all be found in

close association. No indication of BSRs was found in the vicinity of the proposed we ll.

CONCLUSIONS The proposed Well “E” location is situated on a very smooth sloping seafloor at a water depth of 4, 860 feet MSL . The seabed slopes gently to the southeast at a gradient of less than 1 °

.

There were no potential hazardous features identif ied near the proposed Well “E” location.C&C Project No. 140712



### 7

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### One sonar contact was found within 2,000 feet of the proposed well location. Sonar Contact No. 7 was found 1,382 feet west of the proposed location and measures 13.3 feet long, 3.1 feet wide,

and has no measurable height.

No high or low seafloor amplitudes anomalies that may indicate the occurrence of hardgrounds, carbonates, benthic communities or potential expulsions are found within 2,000 feet of the proposed Well “E” location.

Five ( 5 ) subsurface units interp reted from the 3D seismic data were assessed to approximately 5,000 feet BSF at the proposed Well “E” location (Units A to E )

. Unit A is comprised mostly of low amplitude, parallel to semi

- continuous ref lectors and consists of hemipelagic clays and mass

t ransport deposits. Unit B is characterized by low to moderate amplitude, semi

- continuous to

chaotic reflectors and consists of fine

- grained mass transport deposits atop an interbedded channel fill zone. Unit C is comprised of low to moderate amplitude, s emi

- continuous reflectors and is interpreted as mostly mass transport deposits with a few interbedded channel fills. Units D and E consist of low to moderate, semi

- continuous to chaotic reflectors and consists of alternating layers of fine

- grained mass tr ansport deposits and coarser

- grained channel fill zones.

There were no amplitude anomalies indicative of shallow gas identified within any of the unit s at the proposed Well “E” location. All units are therefore assessed as having a low risk of gas. No indication of gas hydrates was found within the study area.

Un its A a nd C are assessed as having a low risk of SWF. The coarser

- grained channel fills

within Units B, D

, and E are assessed as having a low to moderate risk of SWF.

Thank you for this opportunity to be of service. Please contact us if you have any questions concerning this assessment.

Sincerely,

___________________________ 

### Christopher Baker

Senior GeologistC&C Project No. 140712



### 8

730 EAST KALISTE SALOOM ROAD, LAFAYETTE, LA 70508 

### E NCLOSURES Figure 1. Extracted wavelet and power spectrum at th e proposed Well “E”

. Figure 2. AUV seafloor bathymetry surrounding the proposed Well “E”

. Figure 3

. Side scan s onar mosaic at the proposed Well “E”

. Figure 4. Subbottom profiler Line 136 near the proposed Well “E”

. Figure 5

. 3D seismic Inline 1 642 through the proposed Well “E”

. Figure 6

. 3D seismic Crossline 102 99 through the proposed Well “E”

. Figure 7

. Top

- Hole Prognosis Chart for the proposed Well “E”

.

Sheet 1

. Color Shaded Bathymetry Map , Proposed Well “E” Location 1”=1,000’

Sheet 2. Seafloor Gradient Map, Proposed Well “E” Location 1”=1,000’

Sheet 3. Seafloor Amplitude Map, Proposed Well “E” Location 1”=1,000’

Sheet 4. Seafloor & Subsurface Hazard Map, Proposed Well “E” Location 1”=1,000’Freeport

- McMoRan Oil & Gas LLC Section 4

– Pg. 8 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 4

HYDROGEN SULFIDE INFORMATION

4.1 CONCENTRATION

FM O&G anticipates encountering 0 ppm H 2 S during the proposed operations.

4.2 CLASSIFICATION

In accordance with Title 30 CFR 250.490(c)

, FM O&G requests that the area of proposed operations be classified by the BOEM as H 2 S absent

.Freeport

- McMoRan Oil & Gas LLC Section 5

– Pg. 9 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 5
BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION

5.1 DEEPWATER BENTHIC COMMUNITIES The seafloor disturbing activities proposed in this plan are in water depths greater than 300 meters (984’). C & C Technologies Survey Services was contracted to provide an assessment of the shallow conditions at the proposed surface locations. The purpose of the assessment was to address seafloor conditions that may impact exploratory drilling operations within 2,000 feet of the proposed well si tes. FM O&G will avoid all high

- density deepwater benthic communities by 2,000 feet from each proposed mud and cuttings discharge location and 250

feet from the location of all other seafloor disturbances. A s per NTL No. 2009

- G40, “Deepwater

Benthic Commun ities,” a map showing the 2,000 foot radius around the well site is included as

Attachment 5

- A

.

5.2 TOPOGRAPHIC FEATURES ( BANKS) Activities proposed in this EP do not fall within 305 meters (1000 feet) of a topographic “N o Activity Z one ; ” therefore, no ma p is required per NTL No. 2009

- G39, “Biologically Sensitive

Underwater Features and Areas.”

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) All activities proposed under this EP will be conducted outside all Topog raphic Feature
Protective Zones; therefore sh unting of drill cuttings and drilling fluids is not required per NTL

No. 2009

- G39, “Biologically Sensitive Underwater Features and Areas.”

5.4 LIVE BOTTOM S (PINNACLE TREND FEATURES) Atwater Valley Block 198 is not located within 61 meters (200 feet) of any pinnacle trend
feature; therefore

, a separate bathymetric map is not required per NTL No. 2009

- G39, “Biologically Sensitive Underwater Features and Areas.”

5.5 LIVE BOTTOM S (LOW RELIEF) Atwater Valley Block 198 is not located within 30 meters (100 feet) of any live bottom (low relief) feature with vertical relief equal to or greater than 8 feet; therefore, live bottom (low relief) maps are not required per NTL No. 2009

- G39, “Biologically Sensitive Underwater Features and

Areas.”

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP Atwater Valley Block 198 is not located within 30 meters (100 feet) of potentially sensitive biological features; therefore, biologically sensitive area maps are not required.

5.7 REMO TELY OPERATED VEHICLE (ROV) SURVEYS BOEM has determined there is enough data gathered in Grid Area 16 ; therefore, FM O&G will not be conducting any ROV surveys either pre

- spud or post

- drill operations per NTL No. 2008

- G06, “Remotely Operated Vehicle Surve ys in Deepwater” (Extended by NTL No. 2014

- N01, “Elimination of Expiration Dates on Certain Notices to Lessees and Operators Pending Review and Reissuance”).Freeport

- McMoRan Oil & Gas LLC Section 5

– Pg. 10 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 5.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND MARINE

MAMMAL INFORMATION The federally listed endangered and threatened species potentially occurring in the lease area and along the Gulf Coast are provided in the table below.

Species Scientific Name Status Potential
Presence Critical Habitat Designated

in the Gulf of Mexico

Lease
Area Coastal

Marine Mammals Manatee, West
Indian Trichechus manatus latirostris E

-- X Florida (p eninsular)

Whale, Blue Balaenoptera masculus E X a

-- None

Whale , Finback Balaenoptera physalus E X a

-- None

Whale

, Humpback Megaptera novaeangliae E X a

-- None

Whale , North Atlantic Right Eubalaena glacialis E X a

-- None

Whale , Sei Balaenopiera borealis E X a

-- None Whale, Sperm Physeter catodon

(= macrocephalus

) E X

-- None

Terrestrial Mammals Mouse, Beach (Alabama, Choctawatchee, Perdido Key, St. Andrew) Peromyscus polionotus E

- X Alabama, Florida (p anhandle) beaches

Birds Plover, Piping Charadrius melodus T

- X Coastal Texas, Louisiana, Mississippi, Alabama and
Florida (p anhandle) Crane, Whooping Grus Americana E

- X Coastal Texas Reptiles Sea Turtle,
Green Chelonia mydas T,E b X X None

Sea Turtle,
Hawksbill Eretmochelys imbricata E X X None

Sea Turtle, Kemp’s Ridley Lepidochelys kempli E X X None

Sea Turtle,
Leatherback Dermochelys coriacea E X X None

Sea Turtle, Loggerhead Carett a caretta T X X Texas, Louisiana, Mississippi, Alabama,
Florida
Fish Sturgeon, Gulf Acipenser oxyrinchus

(=oxyrhynchus) desotoi T X X Coastal Louisiana,
Mis sissippi, Alabama and Florida (p anhandle)
Coral s Coral, Elkhorn Acopora palmate T

- X Florida Keys and Dry Tortugas
Coral, Staghorn Acopora cervicornis T

- X Florida

Abbreviations: E = Endangered; T = Threatened

a The Blue Fin, Humpback, North Atlantic Right, and Sei Whales are r are or extralimital in the Gulf of Mexico and are unlikely to be present in the lease area.

b Green Sea turtle is threatened, except for the Florida breeding population, which is listed as endangered.Freeport

- McMoRan Oil & Gas LLC Section 5

– Pg. 11 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 5.9 ARCHAEOLOGICAL REPORT Atwater Valley Block 198 has been determined to be located in an archaeological area wher e historic shipwrecks may exist. In accordance with NTL No. 2005

- G07 “Archaeological Surveys and Reports,” and NTL No. 2011

- JOINT

- G01, “Revisions to the List of OCS Lease Blocks Requiring Archaeological Resourc e Surveys and Reports,” a n Archaeological Survey Report is provided with this plan

.

5.10 AIR AND WATER QUALITY INFORMATION Air and water quality information is not required to be included in this plan per NTL No. 2008

- G04, “Information requirements for Exp loration Plans and Development Operations Coordination Documents” (Extended by NTL No. BOEM 2014

- G05 , “Extension of Prior Notices

to Lessees” ).

5.11 SOCIOECONOMIC INFORMATION Socioeconomic Information is not required to be included in this plan per NTL No

. 2008

- G04, “Information Requirements for Exploration P lans and Development Operations Coordination

Documents ” (Extended by NTL No. BOEM 2014

- G05, “Extension of Prior Notices to Lessees”).

# AT198

OCS-G-35431

FM O&G X= 1,033,178.00' Y= 10,086,818.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "A" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence 1. Water column velocity corrections applied 2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2 3. Bin size= 3 meters (9.84 feet) 4. Median filter applied 5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)-158'



# AT198

OCS-G-35431

FM O&G 7 X= 1,033,178.00'

Y= 10,086,818.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET AUV navigation trackline with name, direction run, fix, and fix number (Job No. 130826)

Inline number for 3D seismic data spacing = 20 meters (65.62 feet)

Crossline number for 3D seismic data spacin g = 12.5 meters (41.01 feet)

Sonar contact & reference number 7

Fault scarp with seafloor displacement (Hachures on downthrown side)

Normal fault with depth of burial (Hachures on downthrown side) -158'

Amplitude anomaly within Unit E (2.896 - 4.705 seconds BSL) 3,255 - 11,620 feet BML 

### SONAR CONTACT

NUM. DESCRIPTION X COORDINATE Y COORDINATE

7 13.3'x3.1'x0.0' 1,035,538' 10,084,822'



## PROPOSED WELL "A" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area

# AT198

OCS-G-35431

FM O&G X= 1,036,564.00'

Y= 10,083,073.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "B" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G 7 X= 1,036,564.00'

Y= 10,083,073.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET AUV navigation trackline with name, direction run, fix, and fix number (Job No. 130826)

Inline number for 3D seismic data spacing = 20 meters (65.62 feet)

Crossline number for 3D seismic data spacin g = 12.5 meters (41.01 feet)

Sonar contact & reference number 7 

### SONAR CONTACT

NUM. DESCRIPTION X COORDINATE Y COORDINATE

7 13.3'x3.1'x0.0' 1,035,538' 10,084,822'



## PROPOSED WELL "B" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area

# AT198

OCS-G-35431

FM O&G

X= 1,036,276.00'

Y= 10,079,951.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "C" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)-5200'

-5010' -4800' 

# AT198

OCS-G-35431

FM O&G

9 X= 1,036,276.00'

Y= 10,079,951.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET AUV navigation trackline with name, direction run, fix, and fix number (Job No. 130826)

Inline number for 3D seismic data spacing = 20 meters (65.62 feet)

Crossline number for 3D seismic data spacin g = 12.5 meters (41.01 feet)

Sonar contact & reference number 9

Normal fault with depth of burial (Hachures on downthrown side) -5010'



## PROPOSED WELL "C" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area 9 12.7'x5.8'x0.0' 1,038,552' 10,077,776' 

### SONAR CONTACT

NUM. DESCRIPTION X COORDINATE Y COORDINATE

# AT198

OCS-G-35431

FM O&G X= 1,034,658.00'

Y= 10,085,122.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "D" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G 7 X= 1,034,658.00'

Y= 10,085,122.00'

1

:

DATE: REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET AUV navigation trackline with name, direction run, fix, and fix number (Job No. 130826)

Inline number for 3D seismic data spacing = 20 meters (65.62 feet)

Crossline number for 3D seismic data spacin g = 12.5 meters (41.01 feet)

Sonar contact & reference number 7 

### SONAR CONTACT

NUM. DESCRIPTION X COORDINATE Y COORDINATE

7 13.3'x3.1'x0.0' 1,035,538' 10,084,822'



## PROPOSED WELL "D" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area

# AT198

OCS-G-35431

FM O&G X= 1,036,910.00'

Y= 10,084,657.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET



## PROPOSED WELL "E" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Contour interval = 10 feet

Zero datum = Mean Sea Level

Color shaded image

6XQD]LPXWK 

6XQHOHYDWLRQ  Multibeam processing sequence

1. Water column velocity corrections applied

2. Tide corrections applied using Goddard Ocean Tide Model GOT99.2

3. Bin size= 3 meters (9.84 feet)

4. Median filter applied

5. Produced gridded-binned dataset using weighted-neighbor algorithm; search radius = 9 meters (29.53 feet)

# AT198

OCS-G-35431

FM O&G 7 X= 1,036,910.00'

Y= 10,084,657.00'

1

:

DATE:

REVISED: JOB No:

FILENAME: 140712 Oct. 20, 2014 0' 1,000' 1,000'

SCALE IN US SURVEY FEET AUV navigation trackline with name, direction run, fix, and fix number (Job No. 130826)

Inline number for 3D seismic data spacing = 20 meters (65.62 feet)

Crossline number for 3D seismic data spacin g = 12.5 meters (41.01 feet)

Sonar contact & reference number 7 

### SONAR CONTACT

NUM. DESCRIPTION X COORDINATE Y COORDINATE

7 13.3'x3.1'x0.0' 1,035,538' 10,084,822'



## PROPOSED WELL "E" LOCATION

lock 198 (OCS-G-35431) Atwater Valley Area Amplitude anomaly within Unit D (2.499 - 3.702 seconds BSL) 1,734 - 6,947 feet BMLFreeport

- McMoRan Oil & Gas LLC Section 6

– Pg. 12 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 6

WASTES AND DISCHARGES INFORMATION

6.1 PROJECTED GENERATED WASTES
“Wastes You Will Generate, Treat and Downhole Dispose or Discharge to the Gulf of Mexico” is

included as Attachment 6

- A

.

6.2 MODELING REPORT

Mod eling reports are not required for the activities proposed in this plan.Attachment 6-A. WASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE OR DISCHARGE TO THE GOM

Projected
Downhole Disposal Projected generated waste Projected ocean discharges

Type of Waste Composition Projected Amount Discharge Rate Discharge Method

Cuttings wetted with water-based fluid Cuttings coated while drilling with WBM 2,700 BBLS/WELL 386 BBLS/DAY/WELL Discharged to mudline prior to riser installation. Based on seven total
days of drilling with WBM. No Answer yes or no

Will drilling occur? If yes, you should list muds and cuttings

Water-based drilling fluid Water, NaCI (salt), PHPA polymer and Barium
Sulfate (Barite) 60,000 BBLS/WELL 8,571 BBLS/DAY/WELL Discharge at the mudline prior to the riser installation.
Nominal amount of unused fluid may be discharged at the
surface. Based on seven days of drilling with WBM. No

Will humans be there? If yes, expect conventional waste

26,860 BBLS/WELL 158 BBLS/DAY/WELL USCG approved MSD with chlorination Cuttings wetted with synthetic-based fluid Cuttings coated with synthetic drilling fluids,
including drilled out cement 6,300 BBLS/WELL 73 BBLS/DAY/WELL Discharged to surface. Treated cutting will be discharged
overboard during drilling of the SBM intervals. Discharge rate is based

upon 8 6 days of drilling. Cuttings will
be processed through a cuttings dryer, substantially reducing
the ROC percentage. No

Domestic waste

Sanitary

All liquids are expressed in barrels and solids expressed in pounds. All volumes were calculated on a total per well basis, unless otherwise noted.

All discharged wastes will be treated to comply with the requirements of the NPDES permit. Gray water from living quarters 58,820 BBLS/WELL 346 BBLS/DAY/WELL Chlorinate and discharge overboard No

Sanitary waste from living quarters, control
rooms and change rooms.

Will you conduct well treatment, completion, or workover?

Miscellaneous discharges. If yes, only fill in those associated with your activity.

Will you produce hydrocarbons? If yes fill in for produced water.

N/A N/A N/A N/A N/A Is there a deck? If yes, there will be Deck Drainage

Deck Drainage Deck drainage from drilling floor 850 BBLS/WELL 5 BBLS/DAY/WELL No drill floor drainage routed to sea. All retained on board and
processed to <15ppm or sent to shore for disposal No No

KCl/acid/xylene

N/A

Will you be covered by an individual or general NPDES permit? General NPDES Permit # GMG290534 Well treatment fluids

Well completion fluids

Workover fluids

Desalinization unit discharge

Blowout prevent fluid

Ballast water

Bilge water

Excess cement at seafloor

Fire water
Cooling water Sea Water with no additional chemicals 100,699,330 BBLS/WELL 592,349 BBLS/DAY/WELL Hull discharge overboard No N/A

N/A

N/A

Rejected water from the watermaker. 256,700 BBLS/WELL 1,510 BBLS/DAY/WELL Hull discharge overboard No N/A

N/A

N/A N/A

N/A

N/A ZnBr2/CaBr2/CaCl2/KCL

ZnBr2/CaBr2/CaCl2/KCL N/A

N/A

N/A

Sea Water with no additional chemicals 340 BBLS/WELL 2 BBLS/DAY/WELL Hull discharge overboard No Cement Slurry 530 BBLS/WELL 530 BBLS/DAY/WELL Discharge at seafloor during riserless operations. Discharge rate based
upon 1 day (22" cement returns) No N/A N/A N/A N/A N/A Potable Water with
4% Stack-Magic ECO-Fv2 1,200 BBLS/WELL 7 BBLS/DAY/WELL Discharge at the seafloor or with deck drainage when tested

at surface No

Uncontaminated seawater used to maintain
proper draft 27,000 BBLS/WELL 159 BBLS/DAY/WELL Hull discharge overboard. Based upon 5 major ballast operations, with
rig at operating draft minimal ballast change is required NoFreeport

- McMoRan Oil & Gas LLC Section 7

– Pg. 13 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 7

AIR EMISSIONS INFORMATION

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS
Screen Questions for EP’s Yes No Is any calculated Complex Total (CT) Emission amount (tons) associated with your proposed exploration activities more than 90% of the amounts calculated using the following formulas: CT = 3400D 2/3 for CO, and CT = 33.3D for the other air pollutants (where D = distance to shore in miles)? X

Do your emission calculations include any emission reduction measures or
modified emission factors? X

Are your proposed exploration activities located east of 87.5° W longitude? X Do you expect to encounter H 2 S at concentrations greater than 20 parts p er million (ppm)? X

Do you propose to flare or vent natural gas for more than 48 continuous hours from any proposed well? X

Do you propose to burn produced hydrocarbon liquids? X

7.2 SUMMARY INFORMATION

Included as Attachment 7

- A are Air Emission Worksheets which show the emissions calculations. There are no existing facilities or activities co

- located with the proposed activities; therefore, the Plan Emissions are the same as the Complex Total Emissions.

This information was calculated by: Callie Hutchinson

281

- 69 8

- 8545 callie.hutchinson@jccteam.comEXPLORATION PLAN (EP)

AIR QUALITY SCREENING CHECKLIST OMB Control No. 1010-0151 OMB Approval Expires: 12/31/2011

COMPANY Freeport-McMoRan Oil & Gas LLC

AREA Atwater Valley

BLOCK 198

LEASE OCS-G 35431

PLATFORM NA

WELL Locations A, B, C, D, E

COMPANY CONTACT Callie Hutchinson

TELEPHONE NO. 281-578-3388

REMARKS Drill, complete, test, flare and install subsea trees. FM O&G will use a drillship similar to the Deepwater Champion. Total horsepower is calculated at 82% of actual horsepower of Deepwater Champion (Total horsepower = 60,348 hp). Actual fuel usage calculated at highest monthly average in 6 month fuel usage data for Deepwater Champion.



### MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 1 of 8EMISSIONS FACTORS

Fuel Usage Conversion Factors Natural Gas Turbines Natural Gas Engines Diesel Recip. Engine REF. DATE SCF/hp-hr 9.524 SCF/hp-hr 7.143 GAL/hp-hr 0.0483 AP42 3.2-1 4/76 & 8/84

Equipment/Emission Factors units PM SOx NOx VOC CO REF. DATE

NG Turbines gms/hp-hr 0.00247 1.3 0.01 0.83 AP42 3.2-1& 3.1-1 10/96 NG 2-cycle lean gms/hp-hr 0.00185 10.9 0.43 1.5 AP42 3.2-1 10/96 NG 4-cycle lean gms/hp-hr 0.00185 11.8 0.72 1.6 AP42 3.2-1 10/96 NG 4-cycle rich gms/hp-hr 0.00185 10 0.14 8.6 AP42 3.2-1 10/96

Diesel Recip. < 600 hp. gms/hp-hr 1 1.468 14 1.12 3.03 AP42 3.3-1 10/96 Diesel Recip. > 600 hp. gms/hp-hr 0.32 1.468 11 0.33 2.4 AP42 3.4-1 10/96

Diesel Boiler lbs/bbl 0.084 2.42 0.84 0.008 0.21 AP42 1.3-12,14 9/98

NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84 AP42 1.4-1, 14-2, & 14-3 7/98

NG Flares lbs/mmscf 0.593 71.4 60.3 388.5 AP42 11.5-1 9/91 Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21 AP42 1.3-1 & 1.3-3 9/98 Tank Vapors lbs/bbl 0.03 E&P Forum 1/93 Fugitives lbs/hr/comp. 0.0005 API Study 12/93 Glycol Dehydrator Vent lbs/mmscf 6.6 La. DEQ 1991 Gas Venting lbs/scf 0.0034

Sulphur Content Source Value Units

Fuel Gas 3.33 ppm
Diesel Fuel 0.4 % weight Produced Gas( Flares) 3.33 ppm Produced Oil (Liquid Flaring) 1 % weight



### MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 2 of 8EMISSIONS CALCULATIONS 1ST YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

Freeport-McMoRan Oil & Gas LLC Atwater Valley 198 OCS-G 35431 NA Locations A, B, C, D, E Callie Hutchinson 281-578-3388

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONS Diesel Engines HP GAL/HR GAL/D Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CO

DRILLING PRIME MOVER>600hp diesel 49486 2390.1738 14179.00 24 307 34.88 160.01 1199.00 35.97 261.60 31.76 145.71 1091.80 32.75 238.21 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

BURNER diesel 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AUXILIARY EQUIP<600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 2065 99.7395 2393.75 6 132 1.46 6.68 50.03 1.50 10.92 0.57 2.64 19.75 0.59 4.31 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 132 3.10 14.23 106.61 3.20 23.26 2.04 9.36 70.13 2.10 15.30 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 132 3.10 14.23 106.61 3.20 23.26 2.04 9.36 70.13 2.10 15.30 VESSELS>600hp diesel(tugs) 0 0 0.00 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

FACILITY DERRICK BARGE diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

INSTALLATION MATERIAL TUG diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(supply) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MISC. BPD SCF/HR COUNT

TANK- 0 0 0 0.00 0.00

DRILLING OIL BURN 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

WELL TEST GAS FLARE 208333.33 24 2 0.12 14.87 12.56 80.94 0.00 0.36 0.30 1.94

2018 YEAR TOTAL 42.54 195.27 1477.12 56.43 399.97 36.42 167.06 1252.17 37.86 275.07

EXEMPTION CALCULATION DISTANCE FROM LAND IN

MILES 2897.10 2897.10 2897.10 2897.10 66756.22

87.0

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 3 of 8EMISSIONS CALCULATIONS 2ND YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

Freeport-McMoRan Oil & Gas LLC Atwater Valley 198 OCS-G 35431 NA Locations A, B, C, D, E Callie Hutchinson 281-578-3388

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONS Diesel Engines HP GAL/HR GAL/D Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CO

DRILLING PRIME MOVER>600hp diesel 49486 2390.1738 14179.00 24 365 34.88 160.01 1199.00 35.97 261.60 37.76 173.23 1298.07 38.94 283.22 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

BURNER diesel 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AUXILIARY EQUIP<600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 2065 99.7395 2393.75 6 156 1.46 6.68 50.03 1.50 10.92 0.68 3.13 23.48 0.70 5.12 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 156 3.10 14.23 106.61 3.20 23.26 2.43 11.13 83.38 2.50 18.19 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 156 3.10 14.23 106.61 3.20 23.26 2.43 11.13 83.38 2.50 18.19 VESSELS>600hp diesel(tugs) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

FACILITY DERRICK BARGE diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

INSTALLATION MATERIAL TUG diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(supply) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MISC. BPD SCF/HR COUNT

TANK- 0 0 0 0.00 0.00

DRILLING OIL BURN 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

WELL TEST GAS FLARE 208333.33 24 2 0.12 14.87 12.56 80.94 0.00 0.36 0.30 1.94

2019 YEAR TOTAL 42.54 195.27 1477.12 56.43 399.97 43.30 198.63 1488.67 44.95 326.67

EXEMPTION CALCULATION DISTANCE FROM LAND IN

MILES 2897.10 2897.10 2897.10 2897.10 66756.22

87.0

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 4 of 8EMISSIONS CALCULATIONS 3RD YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

Freeport-McMoRan Oil & Gas LLC Atwater Valley 198 OCS-G 35431 NA Locations A, B, C, D, E Callie Hutchinson 281-578-3388

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONS Diesel Engines HP GAL/HR GAL/D Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CO

DRILLING PRIME MOVER>600hp diesel 49486 2390.1738 14179.00 24 170 34.88 160.01 1199.00 35.97 261.60 17.59 80.68 604.58 18.14 131.91 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME MOVER>600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

BURNER diesel 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AUXILIARY EQUIP<600hp diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 2065 99.7395 2393.75 6 73 1.46 6.68 50.03 1.50 10.92 0.32 1.46 10.94 0.33 2.39 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 73 3.10 14.23 106.61 3.20 23.26 1.13 5.18 38.84 1.17 8.47 VESSELS>600hp diesel(supply) 4400 212.52 5100.48 10 73 3.10 14.23 106.61 3.20 23.26 1.13 5.18 38.84 1.17 8.47 VESSELS>600hp diesel(tugs) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

FACILITY DERRICK BARGE diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

INSTALLATION MATERIAL TUG diesel 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(crew) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 VESSELS>600hp diesel(supply) 0 0 0.00 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MISC. BPD SCF/HR COUNT

TANK- 0 0 0 0.00 0.00

DRILLING OIL BURN 0 0 0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

WELL TEST GAS FLARE 208333.33 24 2 0.12 14.87 12.56 80.94 0.00 0.36 0.30 1.94

2020 YEAR TOTAL 42.54 195.27 1477.12 56.43 399.97 20.17 92.51 693.54 21.10 153.18

EXEMPTION CALCULATION DISTANCE FROM LAND IN

MILES 2897.10 2897.10 2897.10 2897.10 66756.22

87.0

MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 5 of 8SUMMARY

COMPANY AREA BLOCK LEASE PLATFORM WELL

Freeport-McMoRan Oil & Gas LLC Atwater Valley 198 OCS-G 35431 NA Locations A, B, C, D, E

Emitted Substance

Year

PM SOx NOx VOC CO

2018 36.42 167.06 1252.17 37.86 275.07

2019 43.30 198.63 1488.67 44.95 326.67

2020 20.17 92.51 693.54 21.10 153.18

Allowable 2897.10 2897.10 2897.10 2897.10 66756.22



### MMS FORM MMS-138 (December 2008 - Supersedes all previous versions of form MMS-138 which may not be used). Page 8 of 8Freeport

- McMoRan Oil & Gas LLC Section 8

– Pg. 14 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 8

OIL SPILL INFORMATION

8.1 OIL SPILL RESPONSE PLANNING
All the proposed activities and facilities in this EP will be covered by the Oil Spill Response Plan (OSRP) filed by Freeport

- McMoRan Oil & Gas LLC ( Company N o. 03280 ) dated January 10,

2014 , revised on January 31, 2014 and last approved on February 4

, 2014 (OSRP Control N o.
O

- 713).

8.2 SPILL RESPONSE SITES
Primary Response Equipment Location Preplanned Staging Location

Houma, LA Harvey, LA Venice, LA Houma, LA Harvey, LA Venice, LA

8.3 OSRO INFORMATION FM O&G’s primary equipment providers are Clean Gulf Associates (CGA) and Marine Spill Response Corporation (MSRC), and National Response Corporation (NRCC). Clean Gulf
Associates Services, LLC (CGAS) will provide closest available personnel, as well as a CGAS
supervisor to operate the equipment. MSRC personnel are responsible for operating MSRC response equipment. Through its Independent Contractor Network (ICN), NRCC will also provide clos est available personnel, as well as an NRCC ICN supervisor to operate the equipment.

8.4 WORST CASE SCENARIO DETERMINATION

Category Regional OSRP
WCD

- Drilling EP
WCD

- Drilling Type of a ctivity Exploratory Drilling Exploratory Drilling Facility l o cation (area/b lock) GC 393 AT 198 Facility d esignation Well Location B Well Location E

Distance to nearest s horeline (miles) 96.5 Miles 87.0 Miles Storage t anks (bbl) 0 0

Uncontrolled b lowout (bbl) 400,000 196,060

Total v olume (bbl) 400,000 196,060 Type of o il(s) (crude, condensate, diesel) Crude Crude

API g ravity 25° 2 7.1 °

The Regional OSRP Drilling WCD calculations were accepted under Plan Control No. N

- 9739 approved March 31

, 2014

.

FM O&G has determined that the worst

- case scenario from the activities proposed in this EP does not supersede the worst

- case scenario from our approved Regional OSRP.

Since Freeport

- McMoRan Oil & Gas LLC has the capability to respond to the worst

- case spill

scen ario included in our Regional OSRP approved on February 4, 2014 , and since the worst

-Freeport

- McMoRan Oil & Gas LLC Section 8

– Pg. 15 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) case scenario determined for our EP does not replace the worst

- case scenario in our Regional
OSRP, Freeport

- McMoRan Oil & Gas LLC hereby certifies that Freeport

- McMoRan Oi l & Gas

LLC has the capability to respond, to the maximum extent practicable, to a worst

- case discharge, or a substantial threat of such a discharge, resulting from the activities proposed in

this EP

.

8.5 OIL SPILL RESPONSE DISCUSSION The Oil Spill Response Discussion is included as Attachment 8

- A.

8.6 MODELING REPORT Modeling reports are not required for the activities proposed in this plan.

### SPILL RESPONSE DISCUSSION

For the purpose of NEPA and Coastal Zone Management Act analysis, the largest spill volume originating from the proposed activity would be a well blowout during drilling operations

, estimated to be 196,060 barrels of crude oil wi th an API gravity of 27.1°.

Land Segment and Resource Identification

Trajectories of a spill and the probability of it impacting a land segment have been projected utilizing information in the BOEM Oil Spill Risk Analysis Model (OSRAM) for the Central and

Western Gulf of Mexico available on the BOEM website. The results are shown in Fi gure 1.

The BOEM OSRAM identifies a 6% probability of impact to the shorelines of Plaquemines Parish, Louisiana within 30 days. Plaquemines Parish includes Barataria Bay, the Mississippi River Delta, Breton Sound and the affiliated islands and bays. This region is an extremely sensitive habitat and serves as a migratory, breeding, feeding and nursery habitat for numerous species of wildlife. Beaches in this area vary in grain particle size and can be classified as fine sand, shell or perched shell beaches. Sandy and muddy tidal flats are also abundant.

Response

FM O&G will make every effort to respond to the Worst Case Discharge as effectively as practicable. A description of the response equipment under contract to contain and recover the Worst Case Discharge is shown in Figure 2.

Using the estimated chemical and physical characteristics of crude oil, an ADIOS weathering model was run on a similar product from the ADIOS oil database. The results indicate 11 % or approximately 21,567 barrels of crude oil would be evaporated/dispersed within 24 hours, with approximately 174,493 barrels remaining.

Spill Response AT 198, Well Location E Barrels of Oil

WCD Volume 196,060

Less 11 % natural evaporation/dispersion 21,567

Remaining volume 174,493



### Figure 2 outlines equipment, personnel, materials and support vessels as well as temporary storage equipment available to respond to the worst case discharge. The volume accounts for the amount remaining after evaporation/dispersion at 24 hours. The list estimates individual times needed for procurement, load out, travel time to the site and deployment. Figure 2 also indicates how operations will be supported.

FM O&G ’s Oil Spill Response Plan includes alternative response technologies such as dispersants and in-situ burn. Strategies will be decided by Unified Command based on an operations safety analysis, the size of the spill, weather and potential impacts. If aerial dispersants are utilized, 8 sorties (9,600 gallons) from two of the DC-3 aircrafts and 4 sorties

### (8,000 gallons) from the Basler aircraft would provide a daily dispersant capability of 7,540

barrels . If the conditions are favorable for in

- situ burning, the proper ap provals have been obtained and the proper planning is in place, in

- situ burning of oil may be attempted. S lick containment boom would be immediately called out and on

- scene as soon as possible. Offshore response strategies may include attempting to skim ut ilizing CGA’s, MSRC’s, and NRCC’s spill response equipment, with a total derated skimming capacity of 1,0 22 ,754 barrels. Temporary storage associated with skimming equipment equals 296,795 barrels

. If additional storage is needed, various tank barges with a total of 1.4 million+ barrels of storage capacity may be

mobilized and centrally located to provide temporary storage and minimize off

- loading time

. Safety is first priority. Air monitoring will be accomplished and operations deemed safe prior to any co ntainment/skimming attempts.

If the spill went unabated, shoreline impact in Plaquemines Parish, Louisiana would depend upon existing environmental conditions. Shoreline protection would include the use of CGA’s
and NRCC’s near shore and shallow water s kimmers with a totaled derated skimming capacity of 147,605 barrels. Temporary storage associated with skimming equipment equals 2,393 barrels. If additional storage is needed, a 47,000 barrel storage barge, a 25,000 barrel storage barge, three 20,000 barr el storage barges, and three 23,000 barrel storage barges may be mobilized and centrally located to provide temporary storage and minimize off

- loading time . Onshore response may include the deployment of shoreline boom on beach areas, or protection and sor bent boom on vegetated areas. Letter s of Intent from AMPOL and OMI Environmental will ensure access to 147,000 feet of 18” shoreline protection boom. Figure 2 outlines individual times needed for procurement, load out, travel time to the site and deploymen t. Strategies would be based upon surveillance and real time trajectories that depict areas of potential impact given actual sea and weather conditions. The State of Louisiana Initial Oil Spill Response Plan , applicable Area Contingency and Geographical R esponse Plans a nd Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. Shoreline protection strategies depict the protection response mode s applicable for oil spill clean

- up operations. The State of Louisiana Initial Oil Spill Response Plan provides detailed shoreline protection strategies for this area, and it describes necessary action to keep the oil spill from entering Louisiana’s coasta l wetlands, based on the assumption that removal of the released oil will be much easier and less damaging to fragile coastal ecosystems if done in the open waters of the Gulf of Mexico. Supervisory personnel have the option to modify the deployment and op eration of equipment allowing a more effective response to site

- specific circumstances. FM O&G ’s contract Spill Management Team holds a copy of the State of Louisiana Initial Oil Spill Response Plan.

Based on the anticipated worst case discharge scenario, FM O&G can be onsite with contracted oil spill recovery equipment with adequate response capacity to contain and recover surface hydrocarbons, and prevent land impact, to the maximum extent practicable , within an estimated

78 hours (based on the equipment ’s Effective Daily Recovery Capacity (EDRC)).

### Initial Response Considerations

Actual actions taken during an oil spill response will be based on many factors to include but not

be limited to:

 Weather

 Equipment and materials availability

 Ocean currents and tides

 Location of the spill

 Product spilled

 Amount spilled

 Environmental risk assessments

 Trajectory and product analysis

 Well status, i.e., shut in or continual release

FM O&G will take action to provide a safe, aggressive response to contain and rec over as much of the spilled oil as quickly as it is safe to do so. In an effort to protect the environment, response actions will be designed to provide an “in

- depth” protection strategy meant to recover as much oil as possible as far from environmentally sensitive areas as possible. Safety will take precedence over all other considerations during these operations.

Coordination of response assets will be supervised by the designation of a SIMOPS group as necessary for close quarter vessel response activit ies. Most often, this group will be used during source control events that require a significant number of large vessels operating independently, but in coordination to complete a common objective, in a small area and in close coordination and support of e ach other. This group must also monitor the subsurface activities of each vessel (ROV, dispersant application, well control support, etc.). The SIMOPS group leader reports to

the Source Control Section Chief.

In addition, these activities will be monitore d by the spill management team (SMT) and Unified Command via a structured Common Operating Picture (COP) established to track resource and

slick movement in real time.

Upon notification of a spill, the following actions will be taken:

 Information will be confirmed

 An assessment will be made and initial objectives set

 OSROs and appropriate agencies will be notified

 ICS 201, Initial Report Form completed

 Initial Safety plan will be written and published

 Unified Command will be established

o Overall safety p lan developed to reflect the operational situation and coordinated objectives

o Areas of responsibility established for Source Control and each surface operational

site

o On

- site command and control established

### Offshore Response Actions

Equipment Deploymen t
Surveillance

 Surveillance Aircraft: within two hours of QI notification, or at first light

 Provide trained observer to provide on site status reports

 Provide command and control platform at the site if needed

 Continual surveillance of oil movement by rem ote sensing systems, aerial photography

and visual confirmation

 Continual monitoring of vessel assets using vessel monitoring systems

Dispersant application assets

 Put aerial dispersant providers on standby

 With the FOSC, conduct analysis to determine a ppropriateness of dispersant application (refer to Section 18)

 Gain FOSC approval for use of dispersants on the surface

 Deploy aircraft in accordance with a plan developed for the actual situation

 Coordinate movement of dispersants, aircraft, and support e quipment and personnel

 Confirm dispersant availability for current and long range operations

 Start ordering dispersant stocks required for expected operations

Containment boom

 Call out early and expedite deployment to be on scene ASAP

 Ensure boom handli ng and mooring equipment is deployed with boom

 Provide continuing reports to vessels to expedite their arrival at sites that will provide for

their most effective containment

 Use Vessels of Opportunity (VOO) to deploy and maintain boom

Dedicated off

- sho re skimming systems

General

 Deployed to the highest concentration of oil

 Assets deployed at safe distance from aerial dispersant and in

- situ burn operations

CGA HOSS Barge

 Use in areas with heaviest oil concentrations

 Consider for use in areas of known de bris (seaweed, and other floating materials)

CGA 95’ Fast Response Vessels (FRVs)

 Designed to be a first vessel on scene

 Capable of maintaining the initial Command and Control function for on water recovery operations

 24 hour oil spill detection capabilit y

###  Highly mobile and efficient skimming capability

 Use as far off

- shore as safely possible

CGA FRUs

 To the area of the thickest oil

 Use as far off

- shore as allowed

T&T Koseq Skimming Systems

 To the area of the thickest oil

 Use as far off

- shore as allowed

MSRC PSV

- VOO Skimming Systems

 To the area of the thickest oil

 Use as near

- shore as allowed by draft of vessel

 Use as far off

- shore as needed

 Expected 24

- hour mobilization

 Expected length of 200 foot or greater

 PSV

- VOO with deck space of 150’ x 40’ to prov ide space for skimmer, marine storage

tanks and boom

 PSV

- VOO with 2,000

- 20,000 bbl below deck storage supplemented with 2 or more 500 bbl marine portable tanks, if necessary, depending on below deck storage

MSRC Oil Spill Response Vessels (OSRV)

 Use in ar eas with heaviest oil concentrations

 Use as near

- shore as allowed by draft of vessel

 Consider for use in areas of known debris (seaweed, and other floating materials)

 Use as far off

- shore as needed

MSRC Fast Response Vessels (FRV)

 Use in areas with heavi est oil concentrations

 Use as far off

- shore as allowed

MSRC Responders

 Use in areas with heaviest oil concentrations

 Consider for use in areas of known debris (seaweed, and other floating materials)

NRCC Oil Spill Response Barge (OSRB)

 Use in areas with heaviest oil concentrations

NRCC Oil Spill Response Vessel (OSRV)

 To the area of the thickest oil

 Use as far off

- shore as allowed

### NRCC Vessel of Opportunity Skimming System (VOSS)

 To the area of the thickest oil

 Use as far off

- shore as allowed

 VOOs minim um 110’ in length

 VOOs with minimum of 8x15 of optimum deck space

 VOOs with 200

- 400 ft of boom

 Storage tanks of 100 bbls or more

Storage Vessels

 Establish availability of contracted assets (See Appendix E)

 Early call out (to allow for tug boat acquisition and deployment speeds)

 Phase mobilization to allow storage vessels to arrive at the same time as skimming
systems

 Position as closely as possible to skimming assets to minimize offloading time

Vessels of Opportunity (VOO)

 Use FM O&G ’s contracted resource s as applicable

 Industry vessels are ideal for deployment of Vessel of Opportunity Skimming Systems (VOSS)

 Acquire additional resources as needed

 Consider use of local assets, i.e. fishing and pleasure craft

 Expect mission specific and safety training to be required

 Plan with the US Coast Guard/ABS for vessel inspections

 

### Place VOOs in Division or Groups as needed

 

### Use organic on

- board storage if appropriate

 

### Maximize non

- organic storage appropriate to vessel limitations

 

### Decant as appropriate after approval t o do so has been granted

 

### Assign bulk storage barges to each Division/Group

 

### Position bulk storage barges as close to skimming units as possible

 

### Utilize large skimming vessel (e.g. barges) storage for smaller vessel offloading

 

### Maximize skimming area (swath) to the optimum width given sea conditions and available equipment

 

### Maximize use of oleophilic skimmers in all operations, but especially offshore

 

### Nearshore, use shallow water barges and shuttle to skimming units to minimize offloading time

 

### Plan and equip t o use all offloading capabilities of the storage vessel to minimize offloading time

In

- situ Burn assets

 Determine appropriateness of in

- situ burn operation in coordination with the FOSC and

affected SOSC

 Determine availability of fire boom and selected i gnition systems

 Start ordering fire boom stocks required for expected operations

 Ensure VOO crew members are trained prior to operations

###  Determine assets to perform on water operation

 Build operations into safety plan

 Conduct operations in accordance with an approved plan

 Initial test burn to ensure effectiveness

Adverse Weather Operations: In adverse weather, when seas are > 3 feet, the use of larger recovery and storage vessels, oleophilic skimmers, and large offshore boom will be maximized. Safety wil l be the overriding factor in all operations and will cease at the order of the Unified Command, vessel captain, or in an emergency, ”stop work” may be directed by any crew member.

Surface Oil Recovery Considerations and Tactics (Offshore and Near

- shore Operations)

Maximization of skimmer

- oil encounter rate

 Place barges in skimming task forces, groups, etc., to reduce recovered oil offloading

time

 Place barges alongside skimming systems for immediate offloading of recovered oil when practicable

 Use two vessels, each with heavy sea boom, in an open

- ended “V” configuration to funnel surface oil into a trailing skimming unit’s organic, V

- shaped boom and skimmer (see page 7, CGA Equipment Guide Book and Tactic Manual (CGATM)

 Use secondary vessels and heavy s ea boom to widen boom swath beyond normal skimming system limits (see page 15, CGATM)

 Consider night

- time operations, first considering safety issues

 Utilize all available advanced technology systems ( IR, X

- Band Radar, etc.) to determine the location of, and move to, recoverable oil

 Confirm the presence of recoverable oil prior to moving to a new location

Maximize skimmer system efficiency

 Place weir skimming systems in areas of calm seas and thick oil

 Maximize the use of oleophilic skimming systems in h eavier seas

 Place less mobile, high EDRC skimming systems (e.g. HOSS Barge) in the largest pockets of the heaviest oil

 Maximize onboard recovered oil storage for vessels.

 Obtain authorization for decanting of recovered water as soon as possible

 Use smal ler, more agile skimming systems to recover streamers of oil normally found farther from the source. Place recovered oil barges nearby

Recovered Oil Storage

 Smaller barges in larger quantities will increase flexibility for multi

- location skimming operatio ns

###  Place barges in skimming task forces, groups, etc., to reduce recovered oil offloading

time

 Procure and deploy the maximum number of portable tanks to support Vessel of Opportunity Skimming Systems if onboard storage is not available

 Maximize use of the organic recovered oil storage capacity of the skimming vessel

Command, Control, and Communications (C 3 

### )

 Publish, implement, and fully test an appropriate communications plan

 Design an operational scheme, maintaining a manageable span of control

 Designate and mark C 3 

### vessels for easy aerial identification

 Designate and employ C 3 

### aircraft for task forces, groups, etc.

 Use reconnaissance air craft and Rapid Response Teams (RAT) to confirm the presence

of recoverable oil

On Water Recovery Group

When the firs t skimming vessel arrives on scene, a complete site assessment will be conducted before recovery operations begin. Once it is confirmed that the air monitoring readings for O2, LEL, H2S, CO, VOC, and Benzene are all within the permissible limits, oil reco very operations may begin.

As skimming vessels arrive, they will be organized to work in areas that allow for the most efficient vessel operation and free vessel movement in the recovery of oil. Vessel groups will vary in structure as determined by the O perations Section of the Unified Command, but will generally consist, at a minimum, of the following dedicated assets:

 3 to 5

– Offshore skimming vessels (recovery)

 1

– Tank barge (temporary storage)

 1

– Air asset (tactical direction)

 2

– Support vessels (crew/utility for supply)

 6 to 10

– Boom vessels (enhanced booming )

Example (

Note: Actual organization of TFs will be dependent on several factors including, asset availability, weather, spilled oil migration, currents, etc.)

The 95’ FRV Breton Island out of Venice arrives on scene and conducts an initial site assessment. Air monitoring levels are acceptable and no other visual threats have been observed. The area is cleared for safe skimming operations. The Breton Island assumes command and

control (CoC) of on

- water recovery operations until a dedicated non

- skimming vessel arrives to

relieve it of those duties.

A second 95’ FRV arrives and begins recovery operations alongside the Breton Island. Several more vessels begin to arrive, including a thi rd 95’ FRV out of Galveston, the HOSS Barge (High Volume Open Sea Skimming System) out of Harvey, a boom barge (CGA 300) with 25,000’ of

### 42” auto boom out of Leeville, and 9 Fast Response Units (FRUs) from the load

- out location at

C

- Port in Port Fourchon.

As these vessels set up and begin skimming, they are grouped into task forces (TFs) as directed by the Operations Section of the Unified Command located at the command post.

Initial set

- up and potential actions:

 A 1,000 meter safety zone has been es tablished around the incident location for vessels

involved in Source Control

 The HOSS Barge is positioned facing the incident location just outside of this safety zone or at the point where the freshest oil is reaching the surface

 The HOSS Barge engage s its Oil Spill Detection (OSD) system to locate the heaviest oil and maintains that ability for 24

- hour operations

 The HOSS Barge deploys 1,320’ of 67” Sea Sentry boom on each side, creating a swath
width of 800’

 The Breton Island and H.I. Rich skim ne arby, utilizing the same OSD systems as the HOSS Barge to locate and recover oil

 Two FRUs join this group and it becomes TF1

 The remaining 7 FRUs are split into a 2 and 3 vessel task force numbered TF2 and TF3

 A 95’ FRV is placed in each TF

 The boom barge (CGA 300) is positioned nearby and begins deploying auto boom in sections between two utility vessels (1,000’ to 3,000’ of boom, depending on conditions)

with chain

- link gates in the middle to funnel oil to the skimmers

 The initial boom support vessels po sition in front of TF2 and TF3

 A 100,000+ barrel offshore tank barge is placed with each task force as necessary to facilitate the immediate offload of skimming vessels

The initial task forces (36 hours in) may be structured as follows:

TF 1

 1

– 95’ FRV

 1

– HOSS Barge with 3 tugs

 2

– FRUs

 1

– 100,000+ barrel tank barge and associated tug(s)

 1

– Dedicated air asset for tactical direction

 8

– 500’ sections of auto boom with gates

 8

– Boom

- towing vessels

 2

– Support vessels (crew/utility)

TF 2

 1

– 95’ FR V

 4

– FRUs

 1

– 100,000+ barrel tank barge and associated tug(s)

###  1

– Dedicated air asset for tactical direction

 10

– 500’ sections of auto boom with gates

 10

– Boom

- towing vessels

 2

– Support vessels (crew/utility)

TF 3

 1

– 95’ FRV

 3

– FRUs

 1

– 100,000+ barrel tank barge and associated tug(s)

 1

– Dedicated air asset for tactical direction

 8

– 500’ sections of auto boom with gates

 8

– Boom

- towing vessels

 2

– Support vessels (crew/utility)

Offshore skimming equipment continues to arrive in accordance with the ETA data listed in figure H.3a; this equipment includes 2 AquaGuard skimmers and 11 sets of Koseq Rigid Skimming Arms. These high volume heavy weather capable systems will be divided into functional groups and assigned to specific areas by the Operat ions Section of the Unified

Command.

At this point of the response, the additional TFs may assume the following configurations:

TF 4

 2

– Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1

– AquaGuard Skimmer

 1

– 100,000+ barrel tank barge an d associated tug(s)

 1

– Dedicated air asset for tactical direction

 2

– Support vessels (crew/utility)

 6

– 500’ sections of auto boom with gates

 6

– Boom

- towing vessels

TF 5

 3

– Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1

– AquaGuard Sk immer

 1

– 100,000+ barrel tank barge and associated tug(s)

 1

– Dedicated air asset for tactical direction

 2

– Support vessels (crew/utility)

 8

– 500’ sections of auto boom with gates

 8

– Boom

- towing vessels

TF 6

 3

– Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1

– 100,000+ barrel tank barge and associated tug(s)

###  1

– Dedicated air asset for tactical direction

 2

– Support vessels (crew/utility)

 6

– 500’ sections of auto boom with gates

 6

– Boom

- towing vessels

TF 7

 3

– Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1

– 100,000+ barrel tank barge and associated tug(s)

 1

– Dedicated air asset for tactical direction

 2

– Support vessels (crew/utility)

 6

– 500’ sections of auto boom with gates

 6

– Boom

- towing vessels

CGA Minimum Ac ceptable Capabilities for Vessels of Opportunity (VOO) Minimum acceptable capabilities of Petroleum Industry Designed Vessels (PIDV) for conducting Vessel of Opportunity (VOO) skimming operations are shown in the table below. PIDVs are “purpose

- built” to p rovide normal support to offshore oil and gas operators. They include but are not limited to utility boats, offshore supply vessels, etc. They become VOOs when tasked with oil spill response duties.

Capability FRU KOSEQ AquaGuard

Type of Vessel Utility Boat Offshore Supply

Vessel Utility Boat

Operating parameters

Sea State 3

- 5 ft max 9.8 ft max 3

- 5 ft max
Skimming speed ≤1 kt ≤3 kts ≤1 kt

Vessel size
Minimum Length 100 ft 200 ft 100 ft Deck space for:

 

### Tank(s)

 

### Crane(s)

 

### Boom Reels

 

### Hydraulic Power Units

 

### Equipment Boxes 18x32 ft 100x40 ft 18x32 ft

Communication Assets Marine Band

Radio Marine Band Radio Marine Band

Rad io

Tactical use of Vessels of Opportunity (VOO): FM O&G will take all possible measures to

maximize the oil

- to

- skimmer encounter rate of all skimming systems, to include VOOs, as discussed in this section. VOOs will normally be placed within an On

- water recovery unit as shown in figures below.

### Skimming Operations: PIDVs are the preferred VOO skimming platform. OSROs are more

versed in operating on these platforms and the vessels are generally large enough with crews more likely versed in spill response operations. They also have a greater possibility of having

on

- board storage capacity and the most likely vessels to be under contract, and therefore more readily available to the operator. These vessels would normally be assigned to an on

- water

recovery group/division (see figure below) and outfitted with a VOSS suited for their size and capabilities. Specific tactics used for skimming operations would be dependent upon many parameters which include, but are not limited to, safety concerns, weather, typ e VOSS on board, product being recovered, and area of oil coverage. Planners would deploy these assets with the objective of safely maximizing oil

- to

- skimmer encounter rate by taking actions to minimize

non

- skimming time and maximizing boom swath. Speci fic tactical configurations are shown in figures below.

The Fast Response Unit (FRU) : A self

- contained, skid based, skimming system that is deployed from the right side of a vessel of opportunity (VOO). An outrigger holds a 75’ long

section of air inflata ble boom in place that directs oil to an apex for recovery via a Foilex 250 weir skimmer. The outrigger creates roughly a 40’ swath width dependent on the VOO beam. The lip of the collection bowl on the skimmer is placed as close to the oil and water int erface as possible to maximize oil recovery and minimize water retention. The skimmer then pumps all fluids recovered to the storage tank where it is allowed to settle, and with the approval of the Coast Guard, the water is decanted from the bottom of the tank back into the water ahead of the containment boom to be recycled through the system. Once the tank is full of as much pure recovered oil as possible it is offloaded to a storage barge for disposal in accordance with an approved disposal plan. A sec ond 100 barrel storage tank can be added if the appropriate amount of deck space is available to use as secondary storage.

Tactical Overview

Mechanical Recovery

– The FRU is designed to provide fast response skimming capability in the

offshore and nearsh ore environment in a stationary or advancing mode. It provides a rated daily recovery capacity of 4,100 barrels. An additional boom reel with 440’ of offshore boom can be deployed along with the FRU, and a second support vessel for boom towing, to extend the swath width when attached to the end of the fixed boom. The range and sustainability offshore is dependent on the VOO that the unit is placed on, but generally these can stay offshore for extended periods. The FRU works well independently or assigne d with other on

- water recovery assets in a task force. In either case, it is most effective when a designated aircraft is assigned to provide tactical direction to ensure the best placement in recoverable oil.

Maximum Sea Conditions

– Under most circums tances the FRU can maintain standard oil spill recovery operations in 2’ to 4’ seas. Ultimately, the Coast Guard licensed Captain in charge of the VOO (with input from the CGAS Supervisor assigned) will be responsible to determine when

the sea conditions h ave surpassed the vessel’s safe operating capabilities.

Possible Task Force Configuration (Multiple VOOs can be deployed in a task force)

1

– VOO (100’ to 165’ Utility or Supply Vessel)

1

– Boom reel w/support vessel for towing

### 1

– Tank barge (offshore) for temporary storage

1

– Utility/Crewboat (supply)

1

– Designated spotter aircraft

The VOSS (yellow) is being deployed and connected to an out

- rigged arm. This is suitable for collection in both large pockets of oil and for recovery of streaming oil.

The oil

- to

- skimmer encounter rate is limited by the length of the arm. Skimming pace is < 1 knot.

Through the use of an additional VOO, and using extended sea boom, the swath of the VOSS is increased therefore maximizing the oil

- to

- skimmer encounter rate. Skimming pace is < 1 knot.

The Koseq Rigid Sweeping Arm: A skimming system deployed on a vessel of opportunity. It requires a large Offshore or Platform Supply Vessel (OSV/PSV), greater than 200’ with at least 100’ x 50’ of free deck space. On eac h side of the vessel, a 50’ long rigid framed Arm is deployed that consists of pontoon chambers to provide buoyancy, a smooth nylon face, and a hydraulically adjustable mounted weir skimmer. The Arm floats independently of the vessel and is attached by a tow bridle and a lead line. The movement of the vessel forward draws the rubber end seal of the arm against the hull to create a collection point for free oil directed to the weir by the Arm face. The collection weir is adjusted to keep the lip as close to the oil water interface as possible to maximize oil recovery while attempting to minimize excess water collection. A transfer pump (combination of positive displacement, screw type and centrifuge suited for highly viscous oils) pump the recovered liquid to portable tanks and/or dedicated fixed storage tanks onboard the vessel. After being allowed to sit and separate, with approval from the Coast Guard, the water can be decanted (pumped off) in front of the collection arm to be reprocessed through the sy stem. Once full with as much pure recovered oil as possible, the oil is transferred to a

### temporary storage barge where it can be disposed of in accordance with an approved disposal

plan.

Tactical Overview

Mechanical Recovery

– Deployed on large vessels of opportunity (VOO) the Koseq Rigid Sweeping Arms are high volume surge capacity deployed to increase recovery capacity at the source of a large oil spill in the offshore and outer nearshore environment of the Gulf of Mexico. They are highly mobile and sustainable in rougher sea conditions than normal skimming vessels (9.8’ seas). The large Offshore Supply Vessels (OSV) required to deploy the Arms are able to remain on scene for extended periods, even when sea conditions pick up. Temporary storage on

d eck in portable tanks usually provides between 1,000 and 3,000 bbls. In most cases, the OSV will be able to pump 20% of its deadweight into the liquid mud tanks in accordance with the vessels Certificate of Inspection (COI). All storage can be offloaded utilizing the vessels liquid transfer system.

Maximum Sea Conditions

- Under most circumstances the larger OSVs are capable of remaining on scene well past the Skimming Arms maximum sea state of 9.8’. Ultimately it will be the decision of the VOO Captain , with input from the T&T Supervisor onboard, to determine when the sea conditions have exceeded the safe operating conditions of the vessel.

Command and Control

– The large OSVs in many cases have state of the art communication and electronic systems, a s well as the accommodations to support the function of directing all skimming operations offshore and reporting back to the command post. Possible Task Force Configuration (Multiple Koseq VOOs can be deployed in a task force)

1

– > 200’ Offshore Supply V essels (OSV) with set of Koseq Arms 2 to 4 portable storage tanks (500 bbl)

1

– Modular Crane Pedestal System set (MCPS) or 30 cherry picker (crane) for deployment

1

– Tank barge (offshore) for temporary storage

1

– Utility/Crewboat (supply)

1

– Designate d spotter aircraft

4

– Personnel (4 T&T OSRO)

### Scattered oil is “caught” by two VOO and collected at the apex of the towed sea

boom. The oil moves thought a “gate” at that apex, forming a larger stream of oil which moves into the boom of the skimming ve ssel. Operations are paced at >1. A recovered oil barge stationed nearby to minimize time taken to offload recovered

oil.

This is a depiction of the same operation as above but using KOSEQ Arms. In this configuration, the collecting boom speed di ctates the operational pace at > 1 knot to

minimize entrainment of the oil.

Clean Gulf Associates (CGA) Procedure for Accessing Member

- Contracted and other Vessels of Opportunity (VOOs) for Spill Response

 

### CGA has procedures in place for CGA member compan ies to acquire vessels of opportunity (VOOs) from an existing CGA member’s contracted fleet or other sources for the deployment of CGA portable skimming equipment including Koseq Arms, Fast Response Units (FRUs) and any other portable skimming system(s) de emed appropriate for the response for a potential or actual oil spill, WCD oil spill or a Spill of National Significance (SONS).

 

### CGA uses Port Vision, a web

- based vessel and terminal interface that empowers CGA to track vessels through Automatic Identif ication System ( AIS) and terminal activities using a Geographic Information System (GIS). It provides live AIS/GIS views of waterways showing current vessel positions, terminals, created vessel fleets, and points

- of

- interest. Through this system, CGA has the ability to get instant snapshots of the location and status of all vessels contracted to CGA members, day or night, from any web

- enabled PC.

### Near Shore Response Actions

Timing

 Put near shore assets on standby and deployment in accordance with planni ng based on the actual situation, actual trajectories and oil budgets

 VOO identification and training in advance of spill nearing shoreline if possible

 Outfitting of VOOs for specific missions

 Deployment of assets based on actual movement of oil

Consider ations

 Water depth, vessel draft

 Shoreline gradient

 State of the oil

 Use of VOOs

 Distance of surf zone from shoreline

Equipment Deployment

Surveillance

 Provide trained observer to direct skimming operations

 Continual surveillance of oil movement by remo te sensing systems, aerial photography

and visual confirmation

 Continual monitoring of vessel assets

Dispersant Use

 Generally will not be approved within 3 miles of shore or with less than 10 meters of water depth

 Approval would be at Regional Response Team level (Region 6)

Dedicated Near Shore skimming systems

 FRVs

 Egmopol and Marco SWS

 Operate with aerial spotter directing systems to observed oil slicks

VOO

 Use FM O&G ’s contracted resources as applicable

 Industry vessel are usually best for deplo yment of Vessel of Opportunity Skimming Systems (VOSS)

 Acquire additional resources as needed

 Consider use of local assets, i.e. fishing and pleasure craft

 Expect mission specific and safety training to be required

 Plan with the US Coast Guard for vessel inspections

 Operate with aerial spotter directing systems to oil patches

### Shoreline Protection Operations

Response Planning Considerations

 Environmental risk assessments (ERA) to determine priorities for area protection

 Time to acquire personnel and equi pment and their availability

 Previous contingency planning contained in the appropriate ACP, and currently for Louisiana, The State of Louisiana Initial Oil Spill Response Plan, Deep Water Horizon, dated 2 May 2010

Actions

Placement of boom

 Position boom in accordance with the ERA based on the actual situation or the appropriate ACP

 Assess timing of booming operations to ensure it is where it needs to be at time of impact. Consider:

o Trajectories

o Weather forecast

o Oil Impact forecast

o Verified spill moveme nt

o Boom, manpower and vessel (shallow draft) availability

o Near shore boom and support material, (stakes, anchors, line)

Beach Preparation

Considerations and Actions

 Use of a 10 mile go/no go line to determine timing of beach cleaning

 Shoreline Cleanup an d Assessment Team Reports and recommendations

 Determination of Archeological sites and gaining authority to enter

 Monitoring of tide tables and weather to determine extent of high tides

 Pre cleaning of beaches by moving waste above high time lines to mini mize waste

 Staging of equipment and housing of response personnel as close to the job site as possible to maximize on

- site work time

 Boom tending, repair, replacement and security (use of local assets may be advantageous)

 Constant awareness of weather and oil movement for resource redeployment as necessary

 In

- situ burn may be considered when marshes have been impacted

 Passive clean up of marshes should considered and appropriate stocks of sorbent boom and/or sweep obtained

 Earthen berms and shoreline pro tection boom may be considered to protect sensitive

inland areas

### Decanting Strategy

Recovered oil and water mixtures will typically separate into distinct phases when left in a quiescent state. When separation occurs, the relatively clean water phase c an be siphoned or decanted back to the recovery point with minimal, if any, impact. Decanting therefore increases

the effective on

- site oil storage capacity and equipment operating time. FOSC/SOSC approval will be requested prior to decanting operations. T his practice is routinely used for oil spill

recovery.

CGA Equipment Limitations The capability for any spill response equipment, whether a dedicated or portable system, to operate in differing weather conditions will be directly in relation to the capabi lities of the vessel the system in placed on. Most importantly, however, the decision to operate will be based on the judgment of the Unified Command and/or the Captain of the vessel, who will ultimately have the final say in terminating operations. Skimm ing equipment listed below may have operational limits which exceed those safety thresholds. As was seen in the Deepwater Horizon (DWH) oil spill response, vessel skimming operations ceased when seas reached 5

- 6 feet and vessels were often recalled to port when those conditions were exceeded. Systems below are some of the
most up

- to

- date systems available and were employed during the DWH spill.

Boom 3 foot seas, 20 knot winds Dispersants Winds more than 25 knots

Visibility less than 3 nautical miles

Cei ling less than 1,000 feet.

FRU 8 foot seas HOSS Barge/OSRB 8 foot seas Koseq Arms 8 foot seas

OSRV 4 foot seas

### Environmental Conditions in the GOM

Louisiana is situated between the easterly and westerly wind belts, and therefore, experiences

wester ly winds during the winter and easterly winds in the summer. Average wind speed is generally 14

- 15 mph along the coast. Wave heights average 4 and 5 feet. However, during hurricane season, Louisiana has recorded wave heights ranging from 40 to 50 feet high and winds reaching speeds of 100 mph. Because much of southern Louisiana lies below sea level, flooding is prominent.

Surface water temperature ranges between 70 and 80  ̊ F during the summer months. During the winter, the average temperature will range from 50 and 60  ̊ F.

The Atlantic and Gulf of Mexico hurricane season is officially from 1 June to 30 November. 97% of all tropical activity occurs within this window. The At lantic basin shows a very peaked season from August through October, with 78% of the tropical storm days, 87% of the minor (Saffir

- Simpson Scale categories 1 and 2) hurricane days, and 96% of the major (Saffir

- Simpson categories 3, 4 and 5) hurricane days occurring then. Maximum activity is in early to mid September. Once in a few years there may be a hurricane occurring "out of season"

- primarily in May or December. Globally, September is the most active month and May is the least active

month.

### FIGURE 1

TRAJECTORY BY LAND SEGMENT

Trajectory of a spill and the probability of it impacting a land segment have been projected utilizing FM O&G ’s WCD and information in the BOEM Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico a vailable on the BOEM website using 30 day impact. The results are tabulated below.

Area/Block OCS

- G Launch

Area Land Segment and/or

Resource Conditional

Probability (%)

within 30 days

Drill, test, complete,

flare & install subsea

trees for Well

Locatio ns A

- E

AT 198,

Well Location E

87 miles from shore G35431 C61 Cameron, LA Vermilion, LA Terrebonne, LA Lafourche, LA Plaquemines, LA St. Bernard, LA 1

1

2

1

6

1

### WCD Scenario

– BASED ON WELL BLOWOUT DURING DRILLING OPERATIONS ( 87 miles from shore)

174,493 bbls of crude oil (Volume considering natural weathering)

API Gravity 27.1 °

FIGURE 2

– Equipment Response Time to AT 198, Well Location E

Dispersants/Surveillance

Dispersant/Surveillance Dispersant Capacity (gal) Persons

Req. From Hrs to

Procure Hrs to

Loadout Travel to site Total Hrs

ASI

Basler 67T 2000 2 Houma, LA 2 2 0.8 4.8

DC 3 1200 2 Houma, LA 2 2 1.1 5.1

DC 3 1200 2 Houma, LA 2 2 1.1 5.1

Aero Commander NA 2 Houma, LA 2 2 0.8 4.8

MSRC

C

- 130 Spray AC 3,250 2 Kiln, MS 3 0.2 0.5 3.7

Kin g Air BE90 Spray AC 250 2 Kiln, MS 3 0.3 0.9 4.2

Offshore Response
Offshore Equipment

Pre

- Determined Staging EDRC Storage Capacity VOO Persons Required From Hrs to

Procure Hrs to

Loadout Hrs to GOM Travel to Spill Site Hrs to

Deploy Total

Hrs

CGA

95’ FRV 12342 249 NA 4 Venice, LA 2 0 2 4 0 8

95’ FRV 12342 249 NA 4 Leeville, LA 2 0 2 6 0 10

95’ FRV 12342 249 NA 4 Galveston, TX 2 0 1 18.5 0 21.5

HOSS Barge 43000 4000 3 Tugs 8 Harvey, LA 7 0 5 10 1 23
Boom Barge (CGA

- 300) 42” Auto Boom (25000’) NA NA 1 Tug

50 Crew 4 (Barge)

2 (Per Crew) Leeville, LA 4 0 6 17 1.5 28.5Recovered Oil Storage Pre

Determined Staging EDRC Storage Capacity VOO Persons Required From Hrs to

Procure Hrs to

Loadout Hrs to

GOM Travel to

Spill Site Hrs to

Deploy Total

Hrs

Ki rby Offshore (available through contract with CGA)
RO Barge NA 80000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 80000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 80000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 80000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 100000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 100000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 100000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 100000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 110000+ 1 Tu g 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 130000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 140000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

RO Barge NA 150000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60
RO Barge NA 150000+ 1 Tug 6 Venice , LA 48 0 2 10 0 60

Offs hore Equipment

Pre

- determined Staging EDRC Storage Capacity VOO Persons Req From Hrs to

Procure Hrs to

Loadout Hrs to

GOM Travel to

Spill Site Hrs to

Deploy Total

Hrs

NRCC OSRV Energy

Vikoma Sea 50 1509 300 NA 4

- 6 Grand Isle, LA 2 2 1 14 1 20

OSRV Admi ral

Marco Class XI AB 8 Band Rope Mop 24000

2283 300 NA 4

- 6 Galveston, TX 2 2 1 41 1 47

OSRB Defender

Marco Class XI AB

Vikoma Cascade 24000

5520 16500 2 Tugs 4

- 6 Bayou La Batre, AL 4 2 3 30 1 40

OSRB Valor N/A 19000 2 Tugs 4

- 6 Tampa, FL 4 2 7 64 1 78Offshore Equipment

Pre

- determined Staging EDRC Storage Capacity VOO Persons Required From Hrs to

Procure Hrs to

Loadout Hrs to

GOM Travel to

Spill Site Hrs to

Deploy Total

Hrs

MSRC

Louisiana Responder

Transrec 350 + OSRV
2,640’ 67” Curtain Pressure Boom 10567 4000 NA 14 Fort Jackson, LA 2 0 4.5 11 1 18.5

MSRC 452 Offshore Barge

1 Crucial Disk 88/30

1 Desmi Ocean
2,640‘ 67” Curtain Pressure Boom 11122

3017 45000 3 Tugs 6 Fort Jackson, LA 2.5 0 6 20 1 29.5

Mississippi Responder

Transrec 350 + OSRV

2 ,640’ 67” Curtain Pressure Boom 10567 4000 NA 14 Pascagoula, MS 2 0 2 14 1 18

MSRC 402 Offshore Barge

2 Crucial Disk 88/30
2,640‘ 67” Curtain Pressure Boom 22244 40300 3 Tugs 6 Pascagoula, MS 2.5 0 3 25 1 31.5

Deep Blue Responder

LFF 100 Brush + OSRV
2, 640’ 67” Curtain Pressure Boom 18086 4000 NA 14 Fourchon, LA 2 0 1 10 1 14

Gulf Coast Responder

Transrec 350 + OSRV
2,640’ 67” Curtain Pressure Boom 10567 4000 NA 14 Lake Charles, LA 2 0 4 23 1 30

Texas Responder

Transrec 350 + OSRV
2,640’ 67” Curtain Pressure Boom 10567 4000 NA 14 Galveston, TX 2 0 1 29 1 33

MSRC 570 Offshore Barge

2 Crucial Disk 88/30
2,640’ 67” Curtain Pressure Boom 22244 56900 3 Tugs 6 Galveston, TX 2.5 0 2 53 1 58.5

Southern Responder

Transrec 350 + OSRV
2,640’ 67” Curtain Press ure Boom 10567 4000 NA 14 Ingleside, TX 2 0 1 38 1 42

MSRC 403 Offshore Barge

1 Crucial Disk 88/30
2,640’ 67” Curtain Pressure Boom 11122 40300 3 Tugs 6 Ingleside, TX 2.5 0 2 70 1 75.5Staging Area: Venice

Offshore Equipment

Preferred Staging EDRC Stora ge Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs T&T Marine (available through direct contract with CGA)
Aqua Guard Triton RBS (2) 45560 4000 2 Utility 12 Galveston, TX 4 12 13 7 2 38
Koseq Skimming Arms (6) 106974 12000 6 Utility 36 Galveston, TX 24 24 13 7 2 70
Koseq Skimming Arms (3) 53487 6000 3 Utility 18 Galliano, LA 24 24 1 7 2 58
Koseq Skimming Arms (2) 35658 4000 2 Utility 12 Harvey, LA 24 24 2 7 2 59

CGA

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Morgan City, LA 2 2 5 7 1 17

FRU (1) + 100 bbl Tank (1) 4251 100 1 Utility 6 Harvey, LA 2 2 2 7 1 14

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Galveston, TX 2 2 13 7 1 25

FRU (1) + 100 bbl Tank (2) 4251 200 1 Util ity 6 Aransas Pass, TX 2 2 18 7 1 30

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Lake Charles, LA 2 2 8 7 1 20

FRU (2) + 100 bbl Tank (4) 8502 400 2 Utility 12 Leeville, LA 2 2 5 7 1 17

FRU (2) + 100 bbl Tank (4) 8502 400 2 Utility 12 Venice, LA 2 2 0 7 1 12

Offshore Equipment Preferred

Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs

MSRC

WP 1 Skimmer (1) 3017 400 1 Utility 6 Ingleside, TX 1 2 18 7 1 29

S tress I Skimmer (1) 15840 400 1 Utility 6 Ingleside, TX 1 2 18 7 1 29

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Ingleside, TX 1 2 18 7 1 29

Foilex 250 Skimmer (1) 3977 400 1 Utility 6 Ingleside, TX 1 2 18 7 1 29

Crucial Disk 56/30 Skimmer (1) 56 71 400 1 Utility 6 Ingleside, TX 1 2 18 7 1 29

GT

- 185 Skimmer w Adaptor (2) 2742 400 2 Utility 12 Galveston, TX 1 2 13 7 1 24
Walosep 4 Skimmer (1) 3017 400 1 Utility 6 Galveston, TX 1 2 13 7 1 24

Queensboro Skimmer (1) 905 400 1 Utility 6 Galveston, TX 1 2 13 7 1 24

Foilex 250 Skimmer (1) 3977 400 1 Utility 6 Galveston, TX 1 2 13 7 1 24

Stress I Skimmer (1) 15840 400 1 Utility 6 Galveston, TX 1 2 13 7 1 24

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Port Arthur, TX 1 2 10 7 1 21

Queensboro Ski mmer (5) 4525 400 5 Utility 30 Lake Charles, LA 1 2 8 7 1 19

Desmi Skimmer (1) 3017 400 1 Utility 6 Lake Charles, LA 1 2 8 7 1 19

Foilex 250 Skimmer (1) 3977 400 1 Utility 6 Lake Charles, LA 1 2 8 7 1 19Offshore Equipment Preferred Staging EDRC Stora ge Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs

MSRC

Stress I Skimmer (1) 15840 400 1 Utility 6 Lake Charles, LA 1 2 8 7 1 19

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Lak e Charles, LA 1 2 8 7 1 19

AardVac Skimmer (1) 3840 400 1 Utility 6 Lake Charles, LA 1 2 8 7 1 19

Transrec 350 Skimmer (1) 10567 400 1 Utility 6 Lake Charles, LA 1 2 8 7 1 19

Crucial Disk 88/30 Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 11122 400 1 PS V 14 Lake Charles, LA 1 2 8 7 1 19

Crucial Disk 88/30 Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 11122 400 1 PSV 14 Lake Charles, LA 1 2 8 7 1 19

Transrec 350 Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 11122 400 1 PSV 14 Lake Charles, LA 1 2 8 7 1 19

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Baton Rouge, LA 1 2 5 7 1 16

Transrec 350 Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 10567 400 1 PSV 14 Houma, LA 1 2 4 7 1 15

Stress I Skimmer (1) 15840 400 1 Utility 6 Port Fourchon, LA 1 2 5 7 1 16

LFF 100 Brush Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 18086 400 1 PSV 14 Port Fourchon, LA 1 2 5 7 1 16

LFF 100 Brush Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 18086 400 1 PSV 14 Port Fourchon, LA 1 2 5 7 1 16

LFF 100 Brush Skimmer (1) 1,320‘ 6 7” Curtain Pressure Boom 18086 400 1 PSV 14 Port Fourchon, LA 1 2 5 7 1 16

LFF 100 Brush Skimmer (1) 1,320‘ 67” Curtain Pressure Boom 18086 400 1 PSV 14 Port Fourchon, LA 1 2 5 7 1 16

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13
Walosep W4 Skimmer (1) 3017 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Foilex 250 Skimmer (1) 3977 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Stress I Skimmer (1) 15840 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Queensboro Skimmer (1 ) 905 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Foilex 200 Skimmer (1) 1989 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Crucial Disk 56/30 Skimmer (1) 5671 400 1 Utility 6 Belle Chasse, LA 1 2 2 7 1 13

Stress I Skimmer (1) 15840 400 1 Utility 6 Pa scagoula, MS 1 2 6 7 1 17

GT

- 185 Skimmer (1) 1371 400 1 Utility 6 Pascagoula, MS 1 2 6 7 1 17

AardVac Skimmer (1) 3840 400 1 Utility 6 Pascagoula, MS 1 2 6 7 1 17

WP 1 Skimmer (1) 3017 400 1 Utility 6 Pascagoula, MS 1 2 6 7 1 17

Queensboro Skimmer (1) 905 400 1 Utility 6 Pascagoula, MS 1 2 6 7 1 17Offshore Equipment Preferred Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs

MSRC

Stress II Skimmer (1) 3017 400 1 Utility 6 Pascagoula, MS 1 2 6 7 1 17

Stress I Skimmer (1) 15840 400 1 Utility 6 Tampa, FL 1 2 21 7 1 32

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Tampa, FL 1 2 21 7 1 32

WP 1 Skimmer (1) 3017 400 1 Utility 6 Tampa, FL 1 2 21 7 1 32

Crucial Disk 56/30 Skimmer (1) 5671 400 1 Utility 6 Tampa, FL 1 2 21 7 1 32

GT

- 185 Skimmer w Adaptor (1) 1371 400 1 Utility 6 Miami, FL 1 2 27 7 1 38

Stress I Skimmer (1) 15840 400 1 Utility 6 Miami, FL 1 2 27 7 1 38
Walosep W4 Skimmer (1) 3017 400 1 Utility 6 Miami, FL 1 2 27 7 1 38

AardVac Skimmer (2) 7680 400 2 Utility 12 Miami, FL 1 2 27 7 1 38

WP 1 Skimmer (1) 3017 400 1 Utility 6 Miami, FL 1 2 27 7 1 38

Desmi Skimmer (1) 3017 400 1 Utility 6 Miami, FL 1 2 27 7 1 38

Offshore Equipment Preferred

Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs

NRCC

Marco Class XI AB 24000 100 1 Offshore

Vessel 4

- 8 Ft. Lauderdale, FL 4 4 26 17 1 52

Marco Class XI AB 24000 100 1 O ffshore

Vessel 4

- 8 Belle Chasse, LA 4 4 2 17 1 28

Marco Class XI AB 24000 100 1 Offshore

Vessel 4

- 8 New Iberia, LA 4 4 6 17 1 32

Action 48 Skimmer 2414 100 1 Offshore

Vessel 4

- 8 Key West, FL 4 4 31 17 1 57

Hoyle Disc Skimmer 1632 100 1 Offshore

Vessel 4

- 8 Tampa, FL 4 4 21 17 1 47

4

- Band Rope Mop Skimmer 1509 100 1 Offshore

Vessel 4

- 8 Ft. Lauderdale, FL 4 4 26 17 1 52

4

- Band Rope Mop Skimmer 1509 100 1 Offshore

Vessel 4

- 8 Mobile, AL 4 4 7 17 1 33

4

- Band Rope Mop Skimmer (2) 3018 200 1 Offshore

Vessel 8

- 16 New Iberia, LA 4 4 6 17 1 32

4

- Band Rope Mop Skimmer (2) 3018 200 1 Offshore

Vessel 8

- 16 Corpus Christi, TX 4 4 18 17 1 44

Vikoma Cascade Skimmer 5520 100 1 Offshore

Vessel 4

- 8 Baytown, TX 4 4 12 17 1 38

Vikoma Cascade Skimmer 5520 100 1 Offshore

Ve ssel 4

- 8 Sulphur, LA 4 4 9 17 1 35

VTU w/weir head skimmer 6857 24 1 Offshore

Vessel 4

- 8 Port Arthur, TX 4 4 10 17 1 36

VTU w/weir head skimmer 6857 24 1 Offshore

Vessel 4

- 8 La Porte, TX 4 4 12 17 1 38Offshore Equipment Preferred Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Site Hrs to

Deploy Total

Hrs

CGA

1000’ Hydro

- Fire Boom NA NA 8 Utility 40 Harvey, LA 1 4 2.1 7 6 20

MSRC

67” Curtain Pressure Boom (18480’) NA NA 14* 7 Lake Char les , LA 1 2 8 7 1 19

67” Curtain Pressure Boom (8895’) NA NA 12* 6 Pascagoula , MS 1 2 5.5 7 1 16

2000’ Hydro Fire Boom NA NA 8* 8 Lake Charles , LA 1 4 8 7 6 19

NRCC

42” Boom (1000’) NA NA 1 Offshore

Vessel 4

- 8 Bayou La Batre, AL 4 4 6 7 1 22

42” Boom (3300’) NA NA 2 Offshore

Vessels 8

- 16 Tampa, FL 4 4 21 7 1 37

42” Boom (2000’) NA NA 1 Offshore

Vessel 4

- 8 Baytown, TX 4 4 12 7 1 28

42” Boom (1000’) NA NA 1 Offshore

Vessel 4

- 8 Port Arthur, TX 4 4 10 7 1 26

42” Boom (4000’) NA NA 2 Offshore

Vessels 8

- 1 6 Corpus Christi, TX 4 4 18 7 1 34

1000’ Hydro

- Fire Boom NA NA 6 Utility 20 New Iberia, LA 4 4 6 7 1 22

* Utility Boats, Crew Boats, Supply Boats, or Fishing VesselsNearshore Response

Nearshore Equipment

Pre

- determined Staging EDRC Storage Capacity VOO Persons Required From Hrs to

Procure Hrs to

Loadout Hrs to

GOM Travel to

Spill Site Hrs to

Deploy Total

Hrs

CGA
Trinity SWS 21500 249 NA 4 Galveston , TX 2 6 N/A 48 1 57
Trinity SWS 21500 249 NA 4 Morgan City , LA 2 6 N/A 48 1 57
Trinity SWS 21500 2 49 NA 4 Leeville , LA 2 6 N/A 48 1 57
Trinity SWS 21500 249 NA 4 Venice , LA 2 6 N/A 48 1 57

46’ FRV 5000 65 NA 4 Aransas Pass , TX 2 0 2 25 0 29

46’ FRV 5000 65 NA 4 Morgan City , LA 2 0 2 6 0 10

46’ FRV 5000 65 NA 4 Lake Charles , LA 2 0 1 12 0 15

46’ FR V 5000 65 NA 4 Venice , LA 2 0 1 3 0 6
Enterprise Marine Services LLC (Available through contract with CGA)

CTCo 2603 NA 25000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2604 NA 20000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2605 NA 20000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2606 NA 20000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2607 NA 23000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2608 NA 23000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 2609 NA 23000 1 Tug 6 Amelia , LA 4 12 4 15 1 36

CTCo 5001 NA 47000 1 Tug 6 Amelia , LA 4 12 4 15 1 36Staging Area: Venice

Nearshore Equipment With Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Load Out Travel to

Staging Travel to

Deployment Hrs to

Deploy Total

Hrs

CGA
SWS Egmopol 3000 100 NA 3 Galveston , TX 2 2 12.7 2 0 18.7
SWS Egmopol 3000 100 NA 3 Morgan City , LA 2 2 4.9 2 0 10.9

SWS Marco 3588 20 NA 3 Lake Charles , LA 2 2 8 2 0 14

SWS Marco 3588 34 NA 3 Leeville , LA 2 2 4.4 2 0 10.4

SWS Marco 3588 34 NA 3 Venice , LA 2 2 0 2 0 6

Rope Mop 77 2 0 3 Harvey , LA 2 2 2.1 2 0 8.1

Foilex Skim Package (TDS 150) 891 45 NA 3 Lake Charles , LA 2 2 8 2 0 14

Foilex Skim Package (TDS 150) 891 45 NA 3 Galveston , TX 2 2 12.7 2 0 18.7

Foilex Skim Package (TDS 150) 891 45 NA 3 Harvey , LA 2 2 2.1 2 0 8.1

4 Drum Skimmer (Magnum 100) 686 100 1 Crew 3 Lake Charles , LA 2 2 8 2 0 14

4 Drum Skimmer (Magnum 100) 686 100 1 Crew 3 Harvey , LA 2 2 2.1 2 0 8.1

2 Drum Skimmer (TDS 118) 240 100 1 Crew 3 Lake Charles , LA 2 2 8 2 0 14

2 Drum Skimmer (TDS 118) 240 100 1 Crew 3 Harvey , LA 2 2 2.1 2 0 8.1Nearshore Equipment With

Staging EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Load Out Travel to

Staging Travel to

Deployment Hrs to

Deploy Total

Hrs

NRCC

Action 24 Skimmer 823 24 1 Nearshore

V essel 4

- 8 Baytown, TX 4 4 12 2 1 23

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Tampa, FL 4 4 21 2 1 32

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Ft. Lauderdale, FL 4 4 26 2 1 37

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 N ew Iberia, LA 4 4 6 2 1 17

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Corpus Christi, TX 4 4 19 2 1 30

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Pasadena , TX 4 4 12 2 1 23

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Port Ar thur, TX 4 4 10 2 1 21

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Cocoa, FL 4 4 22 2 1 33

NRC Weir Disk Skimmer 1371 24 1 Nearshore

Vessel 4

- 8 Pensacola, FL 4 4 8 2 1 19

Vikoma Fasflo Skimmer 2112 24 1 Nearshore

Vessel 4

- 8 Belle Chasse, LA 4 4 2 2 1 13

Vikoma Fasflo Skimmer 2112 24 1 Nearshore

Vessel 4

- 8 New Iberia, LA 4 4 6 2 1 17

Vikoma Fasflo Skimmer 2112 24 1 Nearshore

Vessel 4

- 8 Sulphur, LA 4 4 8 2 1 19

Vikoma Fasflo Skimmer 2112 24 1 Nearshore

Vessel 4

- 8 Atlantic Beach, FL 4 4 18 2 1 2 9Shoreline Protection

Staging Area: Venice

Shoreline Protection

Boom VOO Persons Req. Storage/Warehouse

Location Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Deployment Site Hrs to Deploy Total Hrs

AMPOL (available through Letter of Inte nt)

42,000’ 18” Boom 16 Crew 40 New Iberia, LA 2 2 6 2 12 24

20,000’ 18” Boom 8 Crew 20 New Orleans, LA 2 2 2.2 2 6 14.2

OMI Environmental (available through Letter of Intent)

10,000’ 18” Boom 4 Crew 10 New Iberia, LA 1 1 6 2 3 13

10,000’ 18” Boom 4 C rew 10 Houston, TX 1 1 12.1 2 3 19.1

10,000’ 18” Boom 4 Crew 10 Port Arthur, TX 1 1 9.7 2 3 16.7

20,000’ 18” Boom 8 Crew 20 Belle Chasse, LA 1 1 1.9 2 6 11.9

10,000’ 18” Boom 4 Crew 10 Port Allen, LA 1 1 4.5 2 3 11.5

10,000’ 18” Boom 4 Crew 10 Houma, L A 1 1 3.8 2 3 10.8

15,000’ 18” Boom 6 Crew 14 Gretna, LA (Warehouse) 2 2 2.1 2 4 12.1

Wildlife Response EDRC Storage Capacity VOO Persons Req. From Hrs to

Procure Hrs to

Loadout Travel to

Staging Travel to

Deployment Hrs to

Deploy Total Hrs

CGA

Wildl ife Support Trailer NA NA NA 2 Harvey , LA 2 2 2.1 1 2 9.1

Bird Scare Guns (48) NA NA NA 2 Harvey , LA 2 2 2.1 1 2 9.1

Bird Scare Guns (12) NA NA NA 2 Galveston , TX 2 2 12.7 1 2 19.7

Bird Scare Guns (12) NA NA NA 2 Aransas Pass , TX 2 2 17.7 1 2 24.7

Bird Scare Guns (24) NA NA NA 2 Lake Charles , LA 2 2 8 1 2 15

Bird Scare Guns (24) NA NA NA 2 Leeville , LA 2 2 4.4 1 2 11.4

Response Asset Total

Offshore EDRC 1,0 22 ,754

Offshore Recovered Oil Capacity 1,696

, 795 +

Nearshore / Shallow Water EDRC 147,605

Nearshore / Shallow Water Recovered Oil Capacity 203,393Freeport

- McMoRan Oil & Gas LLC Section 9

– Pg. 16 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 9

ENVIRONMENTAL MONITORING INFORMATION

9.1 MONITORING SYSTEMS FM O&G will monitor loop currents per the requirements as set forth in NTL No. 2009

- G02, “Ocean Current Monitoring” (Extended by NTL No. 2014

- G05, “Extension of Prior Notices to Lessees”). FM O&G subscribes to Wilkens Weather Technologies for weather forecasts and monitoring. Horizon Marine, Inc. provides Gulf of Mexico loop and eddy current forecasts.

9.2 INCID ENTAL TAKES There is no reason to believe that any of the endangered species or marine mammals as listed

in the ESA will be “taken ” as a result of the operations proposed under this plan.

It has been documented that the use of explos ives and or seismic devices can affect marine life. Operations proposed in this plan will not be utilizing either of these devices.

FM O&G will adhere to the requirements as set forth in the following documents, as applicable, to avoid or minimize impacts to any of the species listed in the Endangered Species Act (ESA) as a result of the operations conducted herein:

 NTL No. 2012

- BSEE

- G01, “Marine Trash and Debris Awareness and Elimination”

 NTL No. 2012

- JOINT

- G01, “Vessel Strike Avoidance and Injured/Dead P rotected Species Reporting”

 NTL No. 2012

- JOINT

- G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program”

9.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY Atwater Valley Block 198 is not located in the Flower Garden Banks National Marine Sanctuary;
therefore, relevant information is not required in this EP.Freeport

- McMoRan Oil & Gas LLC Section 10

– Pg. 17 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) 

## SECTION 10

LEASE STIPULATIONS INFORMATION

10. 1 MARINE PROTECTED SPECIES

In accordance with t he Federal Endangered Species Act and the Marine Mammal Protection

Act

, FM O&G will:

(a) C ollect and remove flotsam resulting from activities related to exploration, development, and production of this lease;

(b) P ost signs in prominent places on all vessels and platforms used as a result of activities related to exploration, development, and production of this lease detailing the reasons (legal and ecological) why release of debris must be eliminated;

(c) O bserve for marine mammals and sea turtles while on vessels, reduce vessel speed to 10 knots or less when assemblages of cetaceans are obse rved, and maintain a distance of 90 meters or greater from whales, and a distance of 45 meters or greater from small cetaceans and
sea turtles;

(d) E mploy mitigation measures prescribed by BOEM/BSEE or the National Marine Fisheries Service (NMFS) for all seismic surveys, including the use of an “exclusion zone” based upon the appropriate water depth, ramp

- up and shutdown procedures, visual monitoring, and reporting;

(e) Id entify important habitats, including designated critical habitat, used by listed spe cies (e.g., sea turtle nesting beaches, piping plover critical habitat), in oil spill contingency planning and require the strategic placement of spill cleanup equipment to be used only by personnel trained

in less

- intrusive cleanup techniques on beaches a nd bay shores; and

(f) I mmediately report all sightings and locations of injured or dead protected species (e.g., marine mammals and sea turtles) to the appropriate stranding network. If oil and gas industry activity is responsible for the injured or dead animal (e.g., because of a vessel strike), the responsible parties should remain available to assist the stranding network. If the injury or death was caused by a collision with the lessee’s vessel, the lessee must notify BOEM within 24 hours

of the strik e.

BOEM and BSEE issue Notices to Lessees (NTLs), which more fully describe measures implemented in support of the above

- mentioned implementing statutes and regulations, as well as measures identified by the U.S. Fish and Wildlife Service and NMFS arising from, among others, conservation recommendations, rulemakings pursuant to the MMPA, or consultation. The lessee and its operators, personnel, and subcontractors, while undertaking activities authorized under this lease, must implement and comply with the specific mitigation measures

outlined in NTL No. 2012

- JOINT

- G01, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting;” NTL No. 2012

- JOINT

- G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program;” and NTL No. 2012

- BSEE

- G01, “Marine Trash and Debris Awareness and Elimination.” At the lessee’s option, the lessee, its operators,Freeport

- McMoRan Oil & Gas LLC Section 10

– Pg. 18 of 26

Initial E P December, 2014
Atwater Valley 198 (OCS

- G 35431) personnel, and contractors may comply with the most current measures to protect species in place at the time an activity is undertaken under this lease, including but not limited to new or updated versions of the NTLs identified in this paragraph. The lessee and its operators, personnel, and subcontractors will be required to comply with the mitigation measures, identified

in t he above referenced NTLs, and additional measures in the conditions of approvals for their plans or permits.Freeport

- McMoRan Oil & Gas LLC Section 11

– Pg. 19 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 11

ENVIRONMENTAL MITIGATION MEASURES INFORMATION

11.1 MEASURES TAKEN TO AVOID, MINIMIZE, AND MITIGATE IMPACTS
Atwater Valley Block 198 is not located within Florida; therefore, mitigation information is not requi red for the activities proposed in this plan

.

11.2 INCIDENTAL TAKES

FM O&G will adhere to the requirements as set forth in the following documents, as applicable, to avoid or minimize impacts to any of the species listed in the Endangered Species Act ( ESA) as a result of the operations conducted herein:

 NTL No. 2012

- BSEE

- G01, “Marine Trash and Debris Awareness and Elimination”

 NTL No. 2012

- JOINT

- G01, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”

 NTL No. 2012

- JOINT

- G02, “Implemen tation of Seismic Survey Mitigation Measures and Protected Species Observer Program”Freeport

- McMoRan Oil & Gas LLC Section 12

– Pg. 20 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 12

SUPPORT VESSELS AND AIRCRAFT INFORMATION

12.1 GENERAL The most practical, direct route from the shorebase as permitted by weather and traffic

conditions will be utilized. Information regarding the vessels and aircraft to be used to support the proposed activities is provided in the table below.

Type Maximum Fuel

Tank Capacit y Maximum Number in Area at Any
Time Trip Frequency or

Duration

Crew boat 1 ,8 00 bbl 1 3/Week Supply boat 9,000 bbl 1 3/Week Supply boat 5 ,8 00 bbl 1 3/Week
Helicopter 950 gal 1 2/Day

2.2 DIESEL OIL SUPPLY VESSELS Information regarding vessels to be used to supply diesel oil for fuel and other purposes is provided in the table below.

Size of Fuel Supply
Vessel (ft) Capacity of Fuel

Supply Vessel Frequency of Fuel
Transfers Route Fuel Supply

Vessel Will Take

245 9,000 bbl Bi

- weekly Shortest route from Fourchon, LA to Atwater Valley 198

312 5,800 bbl Bi

- weekly Shortest route from Fourchon, LA to Atwater Valley 198

12.3 DRILLING FLUID TRANSPORTATION Drilling fluid transportation information is not required to be submitted with this plan.

12.4 SOLID AND LIQUID WASTE TRANSPORTATION
A table, “ Wastes You Will Transport and/or Dispose of Onshore

, ” is included as Attachment 12

- A.

12.5 VICINITY MAP

A vicinity map showing the location of the activities proposed herein relative to the shoreline with the distance of the proposed activities from the sh oreline and the primary routes of the support vessels and aircraft that will be used when traveling betwe en the onshore support

facilities and the drilling unit is included as Attachment 12

- B.OBM/ZnBr2/CaBr2 & KCl/ZnBr2/CaBr2 Vessel to truck or MPT tanks Newpark Environmental Services

Fourchon, LA 500 bbl All will go to a disposal

well

Recycled or Incinerated

N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A Wash water
Chemical product wastes N/A

N/A N/A

Cuttings wetted with oil-based fluids

Will you produce hydrocarbons? If yes fill in produced sand. Cuttings wetted with Synthetic-based

fluid N/A N/A N/A N/A

N/A

N/A N/A

N/A

N/A

Well completion fluids

Produced sand
Will you have additional wastes that are not permitted for discharge? If yes, fill in the appropriate rows.

Trash and debris

Used oil N/A N/A

No production is proposed under this Initial Exploration Plan

Refuse generated during operations:
paper, cardboard, metal, and glass Compactor bags in storage bins on Supply/Crew Boat Gulf Offshore Logistics

Fourchon, LA 310,000 lbs/Well Recycled if possible,
transported to landfill

otherwise

Used Engine Oil Proper DOT containers on supply boat Univar

Carencro, LA 100 bbl/Well Will drilling occur? If yes, fill in the muds and cuttings. Composition 

### Projected Generated

Wastes

Oil-based drilling fluid or mud N/A N/A N/A N/A

Synthetic-based drilling fluid

Cuttings wetted with Water-based fluid Recycled

N/A N/A

SBM Cuttings Boxes on Supply Boat Newpark Environmental Services
Fourchon, LA 1,500 BBLS/Well 

## Attachment 12-A. WASTE YOU WILL TRANSPORT AND/OR DISPOSE OF ONSHORE

Transport Method Name/Location of
Facility Amount Disposal

Method 

### Solid and Liquid

Wastes
Transportation Waste Disposal! ! ! ! ! !

! ! ! ! ! !

! !

! !

! ! ! !

! ! ! !

! ! ! ! ! !

! ! ! ! ! !

! ! ! ! ! !

! !

Atwater Valley Mississippi Canyon

Green Canyon Main Pass Mobile

South Timbalier West Delta

Grand Isle

Ewing Bank Viosca Knoll Main Pass South & East

South Timbalier South Breton Sound Chandeleur

West Delta South South Pelto **Houma**

**Dulac Biloxi** 

**Venice Meraux**  **Gretna Harvey**  **Lutcher**

**Lafitte Hopedale**  **Gulfport**

**Fourchon Galliano**  **St. Rose**

**Cocodrie Garyville**  **Pascagoula**

**Grand Isle River Ridge**  **New Orleans**

**Fort Jackson**

**Belle Chasse Pascagoula**  **Gulfport**

#   10

#   12 

#   59



#   110 De Soto NF 

# Freeport-McMoran Oil & Gas LLC Vicinity Map

Atwater 198

AT198 ~ 1 6 2 M i l e s t o H o u m a

, L A A i r c r a f t S h o r e b a s e ~ 1 1 6 M i l e s t o F o u r c h o n

, L A V e s s l e S h o r e b a s e ~ 8 7 M

i l e s t o L A S h o r e

~
1 7 7

. 9 M

i l e s

t o M S S h o

r eFreeport

- McMoRan Oil & Gas LLC Section 13

– Pg. 21 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 13

ONSHORE SUPPORT FACILITIES INFORMATION

13.1 GENERAL

T he onshore facilities that will be used to provide supply and service supp ort for the proposed activities is provided in the table below.

Name Location Existing/New/Modified Freeport

- McMoRan Oil &
Gas LLC Shorebase Fourchon, Louisiana Existing

MI

- Swaco Mud Plants Fourchon, Louisiana Existing

13.2 SUPPORT BASE CONSTRUCTION OR EXPANSION There will be no new construction of an onshore support base, nor will we expand the existing

shorebase as a result of the operations pro posed in this EP

.

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE

A support base construction or expansion timeta ble is not required for the activities proposed in this plan

.

13.4 WASTE DISPOSAL
The Table, “ Wastes You Will Transport and/or Dispose of Onshore

, “is included as Attachment

12

- A

.Freeport

- McMoRan Oil & Gas LLC Section 14

– Pg. 22 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 14

COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION

Under direction of the Coastal Z one Management Act (CZMA), the s tates of Louisia na and Mississippi developed a Coastal Zone Management Programs (CZMP) to allow for the supervision of significant land and water use activities that take place within or that could significantly affect their respective coastal zones.

Proposed activities are 87 miles from t he Louisiana shore

, and 177.9 miles from the Mississippi

shore. Measures will be taken t o avoid or mitigate the probable impacts. FM O&G will opera te in compliance with existing federal and s tate laws, regulations, and resultant enforceable program policie s in Louisiana ’s and Mississippi’s Coastal Zone Management Programs

.

The OCS related oil and gas exploratory and development activities having potential impact on

the Louisiana and Mississipp i Coastal Zones are based on the location of the proposed facilities, access to those sites, best practical techniques for drilling locations, drilling equipment guidelines for the prevention of adverse environmental effects, effective environmental protection, emergency plans and contingency plans.

Relevant en forceable policies were considered in certifying consistency for Louisiana. A

c ertificate of Coastal Zone Management Consistency for the state of Louisiana is in cluded as
Attachment 14

- A

.Freeport

- McMoRan Oil & Gas LLC Section 14

– Pg. 23 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) Th e policies and corresponding sections within this Exploration Plan identified by the State of Mississippi Coastal Program (MCP) as being related to OCS Plans are provided in the table

below.

Enforceable Program Policies of the Mississippi Coastal Program (MCP)

Goal 1 : To provide for reasonable industrial expansion i n the coastal area and to ensure

the efficient utilization of waterfront industrial sites so that suitable sites are conserved

for water dependent industry.

Go al 1 is addressed in Section 13 . The proposed activities provide no industrial expansion in

the c oastal area of Mississippi; therefore, Mississippi coastal areas will be conserved for water dependent industry.

Goal 2 : To favor the preservation of the coastal wetlands and ecosystems, except where a specific alteration of specific coastal wetlands would serve a higher public interest in compliance with the public purposes of the public trust in which the coastal wetlands are

held.

G oal 2 is addressed in Section 15. All proposed activities shall avoid to the maximum extent practicable significant impact to Mississippi’s coastal wetlands and ecosystems.

Goal 3 : To protect, propagate and conserve the state’s seafood and aquatic life in connection with the revitalization of the seafood industry of the State of Mississippi.

Goal 3 is addressed in Section 15. All proposed activities shall avoid to the maximum extent practicable significant impact to Mississippi’s seafood industry.

Goal 4 : To conserve the air and waters of the state, and to protect, maintain and improve the quality thereof for public use, for t he propagation of wildlife, fish and aquatic life, and for domestic, agricultural, industrial, recreational and other legitimate beneficial uses.

Goal 4 is addressed in Section s 2, 7 and 15. All proposed activities shall avoid to the maximum extent practic able significant impact to Mississippi’s seafood industry.

Goal 5 : To put to beneficial use to the fullest extent of which they are capable the water resources of the state, and to prevent the waste, unreasonable use, or unreasonable

method of use of water

.

The proposed activities are supported by a shorebase located in Louisiana and shall avoid to the maximum extent practicable significant impact to Mississippi’s water resources.

Goal 6 : To preserve the state’s historical and archaeological resources, to prevent their destruction, and to enhance these resources wherever possible.

Goal 6 is addressed in Section s 2 and 15. All proposed activities shall avoid to the maximum extent practicable significant impact to Mississippi’s historical and archaeological r esources.Freeport

- McMoRan Oil & Gas LLC Section 14

– Pg. 24 of 26

Initial E P December, 2014 Atwater Valley 198 (OCS

- G 35431) Goal 7 : To encourage the preservation of natural scenic qualities in the coastal area.

Goal 7 is addressed in Section s 6

, 7, 8 and 15. All proposed activities shall avoid to the maximum extent practicable significant impact to Mississippi’s natural scenic qualities in the

coastal area.

Goal 8 : To assist local governments in the provision of public facilities services in a manner consistent with the coastal program.

All proposed activities are supported by a shorebase in Louisiana and shall avoid to the maximum extent practicable significant impact to Mississippi’s local governments.

A certificate of Coastal Zone Management Consistency for the state of Mississippi is included as

Attachment 14

- B

.Freeport

- McMoRan Oil & Gas LLC Section 15

– Pg. 25 of 26

Initial EP December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 15

ENVIRONMENTAL IMPACT ANALYSIS

The Environmental Impact Analysis is included as Attachment 15

- A.

# Freeport-McMoRan Oil & Gas, LLC (FM O&G)

Initial Exploration Plan Atwater Valley Block 198

OCS- G 35431

(A) IMPACT PRODUCING FACTORS

ENVIRONMENTAL IMPACT ANALYSIS WORKSHEET

Environment

Resources Impact Producing Factors (IPFs) Categories and Examples Refer to recent GOM OCS Lease Sale EIS for a more complete list of IPFs

Emissions (air, noise, light, etc.) Effluents

(muds, cutting, other discharges to

the water

column or seafloor) Physical

disturbances to the seafloor (rig or

anchor emplacements, etc.) Wastes sent

to shore for

treatment or disposal Accidents

(e.g., oil spills,

chemical spills, H 2 S releases) Discarded

Trash &

Debris

Site

- specific at Offshore

Location

Designated topographic features (1) (1) (1)

Pinnacle Trend area live bottoms (2) (2) (2)

Eastern Gulf live bottoms (3) (3) (3)

Benthic communities (4)

Water quality X X

Fisheries X X

Marine Mammals X(8) X X(8) X

Sea Turtles X(8) X X(8) X

Air quality X(9)

Shipwreck sites (known or potential) (7)

Prehistoric archaeological sites (7)

Vicinity of Offshore Location

Essential fish habitat X X(6)

Marine and pelagic birds X X

Public health and safety (5)

Coastal and Onshore

Beaches X(6) X

Wetlands X (6)

Shore birds and coastal nesting

birds X 6)

Coastal wildlife refuges

Wilderness areasFootnotes for Environmental Impact Analysis Matrix

1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well or platform site or any anchors will be on the seafloor within the:

o 4

- mile zone of the Flower Garden Banks, or the 3

- mile zone of Stetson Bank ;

o 1000

- m, 1

- mile or 3

- mile zone of any topographic feature (submarine bank) protected by the Topographic Features Stipulation attached to an OCS lease;

o Essential Fish Habitat (EFH) criteria of 500 ft. from any no

- activity zone; or

o Proximity of any submarin e bank (500 ft. buffer zone) with relief greater than 2 meters that is not protected by the Topographic Features Stipulation attached to an OCS lease.

2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinna cle Trend) Stipulation attached to an OCS lease. 3) Activities within any Eastern Gulf OCS block where seafloor habitats are protected by the Live Bottom (Low

Relief) Stipulation attached to an OCS lease. 4) Activities on blocks designated by the BOEM as being i n water depths 300 meters or greater. 5) Exploration or production activities where H2S concentrations greater than 500 ppm might be encountered. 6) All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you

d etermine would impact these environmental resources. If the proposed action is located a sufficient distance from a resource that no impact would occur, the EIA can note that in a sentence or two. 7) All activities that involve seafloor disturbances, includin g anchor emplacements, in any OCS block designated by the BOEM as having high

- probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are adjacent to the lease block in which your planned activity will occur. If the proposed activities are located a sufficient distance from a shipwreck or a prehistoric site that no impact would occur, the EIA can note that in a sentence or two. 8) All activities that you determine might have an adverse effect on enda ngered or threatened marine mammals or

sea turtles or their critical habitats. 9) Production activities that involve transportation of produced fluids to shore using shuttle tankers or barges.

## ( B ) Analysis

Site

- Specific at Atwater Valley Block 198

Proposed operations consist of the drilling, testing, completion, flaring, and installation of subsea

trees for Well Locations A

- E. The operations will be conducted with a dynamically

- positioned drillship

.

1. Designated T opographic F eatures

Potential IPFs on topographic features include effluents, and accidents.

Effluents: Atwater Valley Block 198 is 72 mil es from the closest designated T opographic

F eature s Stipulation Block ( Sackett Bank ); therefore

, no adverse impacts are expected.

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the proposed activities (refer to statistics in Item 5 , Water Q uality). Oil spills cause damage to benthic organisms only if the oil contacts the organisms. Oil fro m a surface spill can be driven into the water column; measurable amounts have been d ocumented down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of magnitude lower than the

amount shown to have an effect on corals. Because the crests of topographic features in the Northern Gulf of Mexico are found below 10 m, no oil from a surface spill co uld reach their

sessile biota. Oil from a subsurface spill is not applicable due to the distance of these blocks from a topograph ic area. The activities proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in Section 8 ).

There are no other IPFs (including emissions , physical disturbances to the seafloor and wastes sent to shore for disposal) from the proposed activities, which could impact topographic features.

2. Pinnacle T rend A rea L ive B ottoms

Potential IPFs on pinnacle trend area live bottoms include effluents and accidents.

Effluents: Atwater Va lley Block 198 is 102 miles from the closest live b ottom (pinnacle trend)

area; therefore

, no adverse impacts are expected.

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the proposed activities (refer to stat istics in Item 5 , Water Q uality). Oil spills have the potential to

foul benthic communities and cause lethal and sublethal eff ects on live bottom organisms. Oil from a surface spill can be driven into the water column; measurable amounts have been

document ed down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of magnitude lower than the amount shown to have an effect on marine organisms. Oil from a subsurface spill is not applicable due to the distance of these block s from a live bottom

### (pinnacle trend) area. The activities proposed in this plan will be covered by FM O&G’s

Regional OSRP (refer to information submitted in Section 8 ).

There are no other IPFs (including emissions , physical disturbances to the seafloor and wastes sent to shore for disposal) from the proposed activities which could impact a live bottom (pinnacle trend) area.

3. Eastern Gulf Live B ottoms

Potential IPFs on Eastern Gulf live bottoms include effluents and accidents.

Effluents: Atwater Va lley Block 198 is not located in an area characterized by the existence of live bottoms; therefore, no adverse impacts are expected.

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the proposed activities (refer to statistics in Item 5

, Water Q uality). Oil spills cause damage to live bottom organisms only if the oil contacts the organisms. Oil from a surface spill can be driven into the water column; measurable amounts have been documented down to a 10 m depth. At this depth, the oil is found only at concentrations several orders of magnitude lower than the amount shown to have an effect on marine invertebrates. Oil from a subsurface spill is not applicable due to the distance of these blocks from a live bottom a rea. The activities proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in

Section 8 ).

There are no other IPFs (including emissions , physical disturbances to the seafloor and wastes sent to shore for disposal) from the proposed activities which could impact an Eastern Gulf live

bottom area.

4. Benthic C ommunities
There are no IPFs (including emissions, physical disturbances to the seafloor, wastes sent to shore for disposal, or accidents) from the proposed ac tivities that could cause impacts to benthic

communities.

A dynamically

- positioned drillship is being used for the proposed activities ; therefore

, only an insignificant amount of seafloor will be disturbed. Because physical disturbances to the seafloor will be minimized by the use of a dynamically

- positioned drillship

, FM O&G’s proposed operations in Atwater Valley Block 198 would not cause impacts to benthic communities.

5. Water Q uality

IPFs that could result in water quality degradation from the proposed operations in Atwater Valley Block 198 include effluents and accidents.

### Effluents: Levels of contaminants in drillin g muds and cuttings and produced water discharges,

discharge

- rate restrictions and monitoring and toxicity testing are regulated by the EPA NPDES permit, thereby eliminating many significant biological or ecological effects. Operational discharges are not expected to cause significant adverse impacts to water quality.

Accidents: Oil spills have the potential to alter offshore water quality; however, it is unlikely that an accidental surface or subsurface spill would occur from the proposed activities. Be tween 1980 and 2000, OCS operations produced 4.7 billion barrels of oil and spilled only 0.001 percent of this oil, or 1 bbl for every 81,000 bbl produced. The spill risk related to a diesel spill from drilling operations is even less. Between 1976 and 19 85, (years for which data were collected), there were 80 reported diesel spills greater than one barrel associated with drilling activities. Considering that there were 11,944 wells drilled, this is a 0.7 percent probability of an

occurrence. If a spill w ere to occur, the water quality of marine waters would be temporarily affected by the dissolved comp onents and small oil droplets. Dispersion by currents and microbial degradation would remove the oil from the water column and dilute the cons tituents to

ba ckground levels. Historically, changes in offshore water quality from oil spills have only been detected during the life of the spill and up to several months afterwards. Most of the components

of oil are insoluble in water and therefore float. The activi ties proposed in this plan will be covered by FM O&G’s Regional Oil Spill Response Plan (refer to information submitted in

Section 8 ).

There are no other IPFs (including emissions, physical disturbances to the seafloor, and wastes sent to shore for dispos al) from the proposed activities which could cause impacts to water quality.

6. Fisheries

IPFs that could cause impacts to fisheries as a result of the proposed operations in Atwater Valley Block 198 include effluents and accidents.

Effluents: Effluent s such as drilling fluids and cuttings discharges contain components and properties which are detrimental to fishery resources. Moderate petroleum and metal

contamination of sediments and the water column can occur out to several hundred meters down

curren t from the discharge point. Offshore discharges are expected to disperse and dilute to very near background levels in the water column or on the seafloor within 3,000 m of the discharge point, and are expected to have negligible effect on fisheries.

Acci dents: An accidental oil spill has the potential to cause some detrimen tal effects on fisheries; however, it i s unlikely that such an event would occur from the proposed activities (refer to Item 5 , Water Q uality). The effects of oil on mobile adult finfish or shellfish would likely be sublethal and the extent of damage would be reduced to the c apacity of adult fish and

shell fish to avoid the spill, to metabolize hydrocarbons, and to excrete both met abolites and parent compounds. The activities propos ed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in Section 8 ).

### There are no IPFs from emissions, physical disturbances to the seafloor or wastes sent to shore

for disposal from the proposed activities which could cause impacts to fisheries.

7. Marine M ammals

GulfCet II studies revealed that cetaceans of the continental shelf and shelf

- edge were almost exclusively bottlenose dolphin and Atlantic spo tted dolphin. Squid eaters, including dwarf and pygmy killer whale , Risso’s dolphin, rough

- toothed dolphin, and Cuvier’s beaked whale, occurred most frequently along the upper slope in areas outside of anticyclones. IPFs that could cause impacts to marine mammals as a result of the proposed operations in Atwater Valley Block

198 include emissions, effluents, discarded trash and debris, and accidents.

Emissions : Noises from drilling activities, support vessels and helicopters may elicit a startle

reaction from marine mammals. This reaction may lead to disruption of ma rine mammals’ normal activities. Stress may make them more vulnerable to parasites, disease, environmental contaminants, and/or predati on (Majors and Myrick, 1990). There is little conclusive evidence for long

- term displacements and population trends for marine mammals relative to noise.

Effluents: Drilling fluids and cuttings discharges contain components which may be detrimental

to marine mammals. Most operational discharges are dilut ed and dispersed upon release. Any potential impact from drilling flu ids would be indirect, either as a result of impacts on prey items or possibly through ingestion in the food chain (API, 1989).

Discarded trash and debris: Both en tanglement in, and ingestion of debris have caused the death or serious injury of marine mammals (Laist, 1997; MMC, 1999). The limited amount of marine debris, if any, resulting from the proposed activities is not expected to substantially harm marine mammals. Operators are prohibited f rom deliberately discharging debris as mandated by

MARPOL

- Annex V and the Marine Plastic Pollution Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA).

FM O&G will operate in accordance with the regulations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent ac cidental loss of solid waste. Special caution will be exercised when handling and disposing of small items and packaging materials, particularly those made of non

- biodegradable, environmentally persistent mater ials such as plastic or glass.

Inf ormational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint

### presentation)

, “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris trai ning video annually. Offshore personnel will also receive an explanation from FM O&G management or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

Accidents: Collisions between support vessels and cetaceans would be unusual events, however should one occur, death or injury to marine mammals is possible. Contract vessel operators can avoid marine mammals and reduce potential deaths by maintaining a vigilant w atch for marine mammals and maintaining a safe d istance when they are sighted. Vessel crews should use a reference guide to help identify the twenty

- eight species of whales and dolphins, and the single species of manatee that may be encountered in the Gulf of Mexico OCS. Vessel crews must report sightings of any injured or dead protected marine mammal species immediately, regardless of whether the injury or death is caused by their vessel, to the Marine Mammal and Sea Turtle Stranding Hotline at (888) 404

- 3922, the NMFS Southeast Regional Office at (727)

824

- 5312, or the Marine Mammal Stranding Network at (305) 862

- 2850. In addition, if the injury or death was caused by a collision with a contract vessel, the BOEM must be notified

within 24 hours of the st rike by email to protectedspecies@bsee.gov . If the vessel is the responsible party, it is required to remain available to assist the respective salvage and stranding

network as needed.

Oil spills have the p otential to cause sublethal oil

- related injuries and spill

- related deaths to marine mammals. However, it is unlikely that an accidental oil spill would occur from the proposed activities (ref

er to Item 5 , Water Q uality). Oil spill response activities may increase vessel traffic in the area, which could add to changes in cetacean behavior and/or distribution, thereby causing additional stress to the animals. The effect of oil dispersants on cetaceans is not known. The acute toxicity of oil dispersant chem icals included in FM O&G’s OSRP is considered to be low when compared with the constituents and fractions of crude oils and diesel products. The activities proposed in this plan will be covered by FM O&G’s OSRP (refer to

information submitted in accordanc e with Section 8 ).

There are no other IPFs (including physical disturbances to the seafloor) from the proposed activities which could impact marine mammals.

8. Sea T urtles

IPFs that could cause impacts to sea turtles as a result of the proposed operation s include emissions, effluents, discarded trash and debris, and accidents. GulfCet II studies sighted most loggerhead, Kemp’s ridley and leatherback sea turtles over shelf waters. Historically these species have been sighted up to the shelf’s edge. They appear to be more abundant east of the Mississippi River than they are west of the river (Fritts et al., 1 983b; Lohoefener et al., 1990). Deep waters may be used by all species as a transitory habitat.

### Emissions: Noise from drilling activities, support v essels, and helicopters may elicit a startle

reaction from sea turtles, but th is is a temporary disturbance.

Effluents: Drilling fluids and cuttings discharges are not know n to be lethal to sea turtles. Most operational discharges are diluted and dispersed upon release. Any potential impact from drilling fluids would be indirect, either as a result of impacts on prey items or possibly through ingestion in the food chain (API, 1989).

Discarded trash and debris: Both entanglement in, and ingestion of, debris have caused the death or serious injury of sea turtles (Balazs, 1985). The limited amount of marine debris, if any, resulting from the proposed activities is not expected to s ubstantially harm sea tu rtles. Operators are prohibited from deliberately discharging debris as mandated by MARPOL

- Annex V and the Marine Plastic Pollution Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). FM O&G will operate in accordance with the regulations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such a s covering outside trash bins to prevent ac cidental loss of

solid waste. Special caution will be exercised when handling and disposing of small items and packaging materials, particularly those made of non

- biodegradable, environmentally persistent

mater ial s such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation)

, “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from FM O&G management or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 201 2

- G01

.

Accidents: Collisions between support vessels and sea turtles would be unusual events, however should one occur, death or inju ry to sea turtles is possible. Contract vessel operators can avoid sea turtles and reduce potential deaths by maintaining a vigilant watch for sea turtles and maintaining a safe distance when they are sighted. Vessel crews should use a reference guide to help identify the five species of sea turtles that may be encounte red in the Gulf of Mexico OCS. Vessel crews must report sightings of any injured or dead protected sea turtle species immediately, regardless of whether the injury or death is caused by their vessel, to the Marine Mammal and Sea Turtle Stranding Hotline at (888) 404

- 3922, the NMFS Southeast Regional

Office at (727) 824

- 5312, or the Marine Mammal Stranding Network at (305) 862

- 2850. In addition, if the injury or death was caused by a collision with a contract vessel, the BOEM must be notified within 24 hours of the strike by email to protectedspecies@b se e.gov

. If the vessel is the responsible party, it is required to remain available to assist the respective salvage and stranding network as needed.

### All sea turtle species and their life stages are vulnerable to t he harmful effects of oil through

direct contact or by fouling of their food. Exposure to oil can be fatal, particularly to juveniles and hatchlings. However, it is unlikely that an accidental oil spill would occur from the proposed activities (refer to Item 5 , Water Q uality). Oil spill response activities may increase vessel traffic in the area, which could add to the possibility of collisions with sea turtles. The activities proposed in this plan will be covered by FM O&G’s Regional Oil Spill Response P lan (refer to

information submitted in accordance with Section 8 ).

There are no other IPFs (including physical disturbances to the seafloor) from the proposed activities which could impact sea turtles.

9. Air Quality

Atwater Valley Block 198 is located 118 miles from the Breton Wilderness Area and 87 miles from shore. Applicable emissions data is included in Section 7 of the Plan.

There would be a limited degree of air quality degradation in the immediate vicinity of the proposed activities. Plan Emi ssions for the proposed activities do not exceed the annual exemption levels as set forth by BOEM . Accidents and blowouts can release hydrocarbons or chemicals, which could cause the emission of air pollutants. However, these releases would not impact ons hore air quality because of the prevailing atmospheric conditions, emission height, emission rates, and the distance of Atwater Valley Block 198 from the coastline. There are no other IPFs (including effluents, physical disturbances to the seafloor, waste s sent to shore for treatment or disposal) from the proposed activities which would impact air quality.

10. Shipwreck Sites (known or potential)

Potential IPFs that could impact known or unknown shipwreck sites as a result of the proposed operations in At water Valley Block 198 include disturbances to the seafloor.

Physical disturbances to the seafloor: A dynamically

- positioned drillship is being used for the proposed activities; therefore, only an insignificant amount of seafloor will be disturbed.

Beca use physical disturbances to the seafloor will be minimized by the use of a dynamically

positioned drillship

, FM O&G’s proposed operations in Atwater Valley Block 198 would not cause impacts to shipwreck sites.

Additionally, Atwater Valley Block 198 is no t located in or adjacent to an OCS block designated by BOEM as having a high probability for occurrence of shipwrecks, therefore, no adverse impacts are expected.

FM O&G will perform an AUV/ ROV survey imaging 100% of the seafloor with sector scanning

sona r within a minimum 500’ radius of the proposed well location(s) prior to or upon

### commencement of operations. These locations will be certified by an authorized marine

archaeologist and by FM O&G to be clear of seafloor archaeological resources, including historic shipwrecks. Copies of the certifications and a circle radius plat of the survey area will be submitted to the BOEM. Should a resource be encountered, FM O&G will contact the BOEM immediately and make every reasonable effort to preserve and prote ct that cultural resource.

There are no other IPFs (including emissions, effluents, wastes sent to shore for treatment or disposal, or accidents) from the proposed activities that could cause impacts to shipwreck sites.

11. Prehistoric Archaeological Sit es Potential IPFs that could cause impacts to prehistoric archaeological sites as a result of the proposed operations in Atwater Valley Block 198 include disturbances to the seafloor.

Physical disturbances to the seafloor: A dynamically

- positioned drillship is being used for the proposed activities; therefore, only an insignificant amount of seafloor will be disturbed. Because physical disturbances to the seafloor will be minimized by the use of a dynamically

positioned drillship

, FM O&G’s proposed operations in Atwater Valley Block 198 would not cause impacts to prehistoric archaeological sites.

FM O&G will perform an AUV/ ROV survey imaging 100% of the seafloor with sector scanning sonar within a minimum 500’ radius of the proposed well location(s ) prior to or upon commencement of operations. These locations will be certified by an authorized marine archaeologist and by FM O&G to be clear of seafloor archaeological resources. Copies of the certifications and a circle radius plat of the survey are a will be submitted to the BOEM. Should a resource be encountered, FM O&G will contact the BOEM immediately and make every reasonable effort to preserve and protect that cultural resource.

Additionally, Atwater Valley Block 198 is located outside the Archaeological Prehistoric high probability line, therefore, no adverse impacts are expected.

There are no other IPFs (including emissions, effluents, wastes sent to shore for treatment or disposal, or accidents) from the proposed activities which could impact prehistoric archeological

sites.

Vicinity of Offshore Location

1. Essential F ish H abitat (EFH)

IPFs that could cause impacts to EFH as a result of the proposed operations in Atwater Valley

Block 198 include effluents and acc idents. EFH includes all estuarine and marine waters and

substrates in the Gulf of Mexico.

### Effluents: The Live Bottom Low Relief Stipulation, the Live Bottom (Pinnacle Trend)

Stipulation, and the Eastern Gulf Pinnacle Trend Stipulation would prevent mo st of the potential impacts on live

- bottom communities and EFH from operational waste discharges. Levels of contaminants in drilling muds and cuttings and produced

- water discharges, discharge

- rate restrictions, and monitoring and toxicity testing are regul ated by the EPA NPDES permit, thereby eliminating many significant biological or ecological effects. Operational discharges are not expected to cause significant adverse impacts to EFH.

Accidents: An accidental oil spill has the potential to cause some d etrimental effects on EFH. Oil spills that contact coastal bays and estuaries, as well as OCS waters when pelagic eggs and larvae are present, have the greatest potential to affect fisheries. However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5 , Water Q uality). The activities proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information

submitted in Section 8 ).

There are no other IPFs (including emissions, physical disturbances to the seaflo or and wastes sent to shore for treatment or disposal) from the proposed activities which could impact essential

fish habitat.

2. Marine and P elagic B irds

IPFs that could impact marine birds as a result of the proposed activities include air emissi ons, accidental oil spills, and discarded trash and debris fr om vessels and the facilities.

Emissions: Emissions of pollutants into the atmosphere from these activities are far below

concentrations which could harm coastal and marine birds.

Accidents: An oil spill would cause localized, low

- level petroleum hydrocarbon contamination. However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5

, Water Q uality). Marine and pelagic birds feeding at the spill location may experience chronic, nonfatal, physiological stress. It is expected that few, if any, coastal and marine birds would actually be affected to that extent. The activities proposed in this plan will be covered by FM
O&G’s Regional OSRP (refer to informat ion submitted in Section 8 ).

Discarded trash and debris : Marine and pelagic birds could become entangled and snared in discarded trash and debris, or ingest small plastic debris, which can cause permanent injuries and death. Operators are prohibited fro m deliberately discharging debris as mandated by MARPOL

Annex V and the Marine Plastic Pollution Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (E PA). FM O&G will operate in accordance with the regulations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to pr event

ac cidental loss of solid waste. Special caution will be exercised when handling and disposing of

### small items and packaging materials, particularly those made of non

- biodegradable,

environmentally persistent materials such as plastic or glass. Inform ational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore personnel, including contractors and other support services

- related personnel (e.g. helicopter pilots, vessel captains and boat cre ws) will be indoctrinated on waste procedures, and will v iew

the video (or Microsoft PowerPoint presentation)

, “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from FM O&G management or the designated lease operator management that emphasizes their commitment to waste management in accordance with NTL No. 2012

- G01

. Debris, if any, from these p roposed

activities will seldom interact wit h marine and pelagic birds; therefore, the effects will be negligible.

There are no other IPFs (including effluents, physical disturbances to the seafloor, or wastes sent to shore for treatment or disposal) from the proposed activities which could impact marine and pelagic birds.

3. Public H ealth and S afety D ue to A ccidents.

There are no IPFs (emissions, effluents, physical disturbances to the seafloor, wastes sent to

sho re for treatment or disposal or accidents, incl uding an accidental H 2 

### S release ) from the proposed activities which could cause impacts to public health and safety. In accordance with

NTL No.’s 2008

- G04

, 2009

- G27, and 2009

- G31, sufficient information is included in Section 4 to justify our request that our proposed activities be classified by BSEE as H 2 

### S absent.

Coastal and Onshore

1. Beaches

IPFs from the proposed activities that could cause impacts to beaches include accidents (oil spills) and discarded trash and debris.

Accidents: Oil spi lls contacting beaches would have impacts on the use of recreational beaches and associated resources. Due to the distance from shore ( 87 miles) and the response capabilities that would be implemented, no significant adverse impacts are expected. The act ivities proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in

Section 8 ).

Discarded trash and debris: Trash on the beach is recognized as a major threat to the enjoyment and use of beaches. There will only b e a limited amount of marine debris, if any, resulting from the proposed activities. Operators are prohibited from deliberately discharging debris as mandated by MARPOL

- Annex V and the Marine Plastic Pollution Research and Control Act, and regulations imp osed by various agencies including the United States Coast Guard (USCG) and the Environm ental Protection Agency (EPA). FM O&G will operate in

### accordance with the regulations and also avoid accidental loss of solid waste items by

maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent ac cidental loss of solid waste. Special caution will be exercised when handling and disposing of small items and packaging mater ials, particularly those made of non

- biodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore person nel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation)

, “Think About It” ( pr eviously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from FM O&G management or the designated lease
operator manag ement that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes sent to shore for treatment or disposal) from the proposed acti vities which could impact beaches.

2. Wetlands

IPFs from the proposed activities that could cause impacts to wetlands include accidents (oil spills) and discarded trash and debris.

Accidents: It is unlikely that an oil spill would occur from the propos ed activities (refer to Item

5 , Water Quality). Due to the distance from shore ( 87 miles) and the response capabilities that would be implemented, no impacts are expected. The activities proposed in this plan will be covered by FM O&G’s Regional OSRP (refe r to information submitted in Section 8 ).

Discarded trash and debris: There will only be a limited amount of marine debris, if any, resulting from the proposed activities. Operators are prohibited from deliberately discharging debris as mandated by MAR POL

- Annex V and the Marine Plastic Pollution Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). FM O&G will operate in accordance with the regu lations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special

caution will be exercised when handling and disposing of small items and packaging materials, particularly those made of non

- biodegradable, environmentally persistent materials such as plastic or glass.

### Informational placards will be posted on all vessels and facilities having sleeping or food

preparation capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also rec eive an explanation from FM O&G management or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes sent to shore for treatment or disposal) from the proposed activities which could impact

wetlands.

3. Shore B irds and C oastal N esting B irds

Accidents: Oil spills could cause impacts to shore birds and coastal nesting birds. However, i t is unlikely that an oil spill would occur from the proposed activities (refer to Item 5 , Water Quality). Given the distance from shore ( 87 miles) and the response capabilities that would be implemented, no impacts are expected. The activities proposed in this plan will be covered by

FM O&G’s Regional OSRP (refer to information submitted in Section 8 ).

Discarded trash and debris: Coasta l and marine birds are highly susceptible to entanglement in floating, submerged, and beached marine debris: specifically plastics. Operators are prohibited from deliberately discharging debris as mandated by MARPOL

- Annex V and the Marine Plastic

Pollution Research and Control Act, and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). FM O&G will operate in accordance with the regulations and also avoid accidental loss of s olid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when handling and disp osing of small items and packaging materials, particularly those made of non

- biodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on vessels and every facility that has sleeping or food

prepa ration capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Microsoft Power Point presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from FM O&G manageme nt or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

### There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes

sent to shore for trea tment or disposal) from the proposed activities that could cause impacts to shore birds and coastal nesting birds.

4. Coastal Wildlife Refuges

Accidents: An accidental oil spill from the proposed activities could cause impacts to coastal wildlife refuges . However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5, Water Quality). Due to the distance from shore ( 87 miles) and the response capabilities that would be implemented, no impacts are expected. The activi ties proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in Section

8 ).

Discarded trash and debris: Operators are prohibited from deliberately discharging debris as mandated by MARPOL

- Annex V, the Marine Plasti c Pollution Research and Control Act and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). FM O&G will operate in accordance with the regulations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special caution will be exercised when

handlin g and disposing of small items and packaging materials, particularly those made of non

biodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on vessels and every facility that has sleeping or food preparation capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view the video (or Micro soft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also receive an explanation from FM O& G management or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes

sent to shor e for treatment or disposal) from the proposed activities that could cause impacts to coastal wildlife refuges.

5. Wilderness Areas

Accidents: An accidental oil spill from the proposed activities could cause impacts to wilderness areas. However, it is unl ikely that an oil spill would occur from the proposed activities (refer to

Item 5 , Water Quality). Due to the distance from the nearest designated Wilderness Area ( 118 miles) and the response capabilities that would be implemented, no significant adverse i mpacts are expected. The activities proposed in this plan will be covered by FM O&G’s Regional OSRP (refer to information submitted in Section 8 ).

### Discarded trash and debris: Operators are prohibited from deliberately discharging debris as

mandated by M ARPOL

- Annex V, the Marine Plastic Pollution Research and Control Act and regulations imposed by various agencies including the United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). FM O&G will operate in accordance with the regul ations and also avoid accidental loss of solid waste items by maintaining waste management plans, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Special cautio n will be exercised when handling and disposing of small items and packaging materials, particularly those made of non

biodegradable, environmentally persistent materials such as plastic or glass.

Informational placards will be posted on vessels and ever y facility that has sleeping or food preparation capabilities. All offshore personnel, including contractors and other support

services

- related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, a nd will view the video (or Microsoft PowerPoint presentation), “Think About It” ( previously “All Washed Up: The Beach Litter Problem” ). Thereafter, all personnel will view the marine trash and debris training video annually. Offshore personnel will also r eceive an explanation from FM O&G management or the designated lease operator management that emphasizes their commitment to waste management in accordance

with NTL No. 2012

- G01

.

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes sent to shore for treatment or disposal) from the proposed activities that could cause impacts to

wilderness areas.

6. Other Envi ronmental Resources Identified
There are no other environmental resources identified for this impact asses sment.

(C) IMPAC TS ON PROPOSED ACTIV ITIES

The site

– specific environmental conditions have been taken into account for the proposed activities. No impacts are expected on the proposed activities from site

- specific environmental

conditions.

(D) ENVIRONMENTAL HAZARD S
During the hurricane season, June through November, the Gulf of Mexico is impacted by an average of ten tropical storms (39

- 73 mph winds), of which six become hurricanes ( > 74 mph winds) . Due to its location in the gulf, Atwater Vall ey Block 198 may experience hurricane and tropical storm force winds, and related sea currents. These factors can adversely impact the integrity of the operations covered by this plan. A significant storm may present physical hazards to operators and vesse ls, damage exploration or production equipment, or result in the release of hazardous materials (including hydrocarbons). Additionally, the displacement of equipment may disrupt the local benthic habitat and pose a threat to local species.

### The following p reventative measures included in this plan may be implemented to mitigate these

impacts:

1. Drilling & completion

a. Secure well

b. Secure rig / platform

c. Evacuate personnel

Drilling activities will be conducted in accordance with NTL No.’s 2008

- G09, 2009

- G10 , and

2010

- N10

.

2. Structure Installation Operator will not conduct structure installation operations during Tropical Storm or

Hurricane threat.

( E ) ALTERNATIVES

No alternatives to the proposed activities were considered to reduce environmental impacts.

( F ) MITIGATION M EASURES

No mitigation measures other than those required by regulation will be employed to avoid, diminish, or eliminate potential impacts on environmental resources.

( G ) CONSULTATION

No agencies or persons were consulted regarding potential impacts associated with the proposed activities. Therefore, a list of such entities has not been provided.

(H) PREPARER(S)

Evan Connolly J. Connor Consulting, Inc. 16225 Park Ten Place, Suite 700 Houston, TX 77084 (281) 578

- 3388 evan.connolly @jccteam.com

( I ) REFERENCES

Authors:

American Pe troleum Institute (API). 1989. Eff ects of offshore petroleum operations on cold

water marine mammals: a literature review. Washington, DC: American Petroleum Institute. 385 pp.

### Balazs, G.H. 1985. Impact of ocean debris on ma rine turtles: entanglement and ingestion. In:

Shomur a, R.S. and H.O. Yoshida, eds. Proceedin gs, Workshop on the Fate and Impact of Marine Debris, 26

- 29 November 1 984, Honolulu, HI. U.S. Dept. of C ommerce. NOAA

Tech. Memo. NOAA

- TM

- NMFS

- SWFC

- 54. Pp 387

- 429.

Bu rke, C.J. and J.A. Veil. 1995. Potential benefits from regulatory consideration of synthetic drilling muds. Environmental Assessment Division, Argonne National Laboratory,

ANL/EAD/TM

- 43

.

Daly, J.M. 1997. Controlling the dis charge of synthetic

- based drilling fluid contaminated cuttings in waters of the United States. U.S. Environmental Prote ction Agency, Office of

Water. Work Plan, June 24, 1997.

Hansen, D.J. 198l. The relative sensitivity of seabird populations in Alaska to oil pollution. U.S. Dept. of the Interior, Bureau of Land Management, Alaska OCS Region, Anchorage. BLM

YK

- ES

- 81

- 006

- 1792.

Laist, D.W. 1997. Impacts of marine debris: entanglement of marine life in marine debris including a comprehensive lis t of species with entanglement and ingestion records. In: Coe,

J.M. and D.B . Rogers, eds. Marine debris: sources, impacts, and solutions. New York, NY : Springer

- Verlag. Pp. 99

- 139

.

Majors, A.P. and A.C. Myrick, Jr. 1990. Effects of noise on animals: im plications for dolphins exposed to seal bombs in the eastern tropical Pacific purse

- seine fishery

– an annotated bibliography. NOAA Administrative Report LJ

- 90

- 06.

Marine Mammal Commission. 1999. Annual report to Congress

– 1998

.

Piatt, J.F., C.J. Lensink , W. Butler, M. Kendziore k, and D.R. Nysewander. 1990. Immediate impact of the Exxon Valdez oil spill on marine birds. The Auk. 107 (2): 387

- 397

Vauk , G., E. Hartwig, B. Reineking, and E. Vauk

- Hentzelt. 1989. Losses of seabirds by oil pollution at the German North Sea coast. Topics in Marine Biology. Ros, J.D, ed. Scient. Mar. 53 (2

- 3): 749

- 754

.

Vermeer, K. and R. Vermeer, 1975 Oil threat to birds on the Canadian west coast. The Canadian

Field

- Naturalist. 89:278

- 298.

Although not cited, the followin g were utilized in preparing this EIA:

 Hazard Surveys

 BOEM EIS’s:

o GOM Deepwater Operations and Activities. Environmental Assessment. BOEM 2000

- 001

o GOM Central and Western Planning Areas Sales 166 and 168 Final Environmental Impact Statement. BOEM 96

- 0058

.Freeport

- McMoRan Oil & Gas LLC Section 16

– Pg. 26 of 26

Initial EP December, 2014 Atwater Valley 198 (OCS

- G 35431) 

## SECTION 16

ADMINISTRATIVE INFORMATION

16.1 EXEMPTED INFORMATION DESCRIPTION
The proposed bottom hole locations of the planned well s have been removed from the Public

I nformation copy of this EP as well as any discussions of the target objectives, geologic or geophysical data, and any interpreted geology

.

16.2 BIBLIOGRAPHY

1. C & C Technologies Survey Se rvices. 3D/AUV Seismic Shallow Geohazard Report: “Sun” Prospect Block 154 (OCS

- G

- 35019), 197 (OCS

- G

- 35430) and 198 (OCS

- G

35431) Atwater Valley Area October, 2014, C & C Project: #140712.

2. C & C Technologies Survey Services. Archaeological Assessment Repo rt: Blocks 154 (OCS

- G

- 35019), 197 (OCS

- G

- 35430) and 198 (OCS

- G

- 35431) Atwater Valley Area September, 2014, C & C Project: #140712.

3. C & C Technologies Survey Services. Well Site Clearance Proposed Well Locations “A,” “B,” “C,” “D,” and “E” Block 198 (OCS

- G

- 35431) Atwater Valley Area October, 2014, C & C Project: #140712.

4. Regional Oil Spill Response Plan, Freeport

- McMoRan Oil & Gas LLC (Control Number
O

- 713).