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2 General Information

2(a) Applications and Permits

No individual or site specific applications or permits will be required for Phase II of the

development plan beyond those required by 30 CFR 250 (e.g. Surface Safety

Application, Application to Drill and Application to Modify). Per NTL 2008 G04,

coverage under the National Pollutant Discharge Elimination System (NPDES) General

Permit or Corps of Engineers (COE) permits are not described in this section.

2(b) Drilling Fluids

Phase II of the development plan includes drilling and completing at least five new wells.

Two wells are here proposed for the Cascade Unit and three wells have been proposed

under separate cover (SDOCD) for the Chinook Unit. Appendix 7-A shows the types and

amounts of drilling fluids that would be used to drill the two wells described in this

SDOCD.

2(c) Production [Proprietary]

2(d) Oils Characteristics

Table 2-2 describes the chemical and physical characteristics of the produced oil from the

Cascade and Chinook reservoirs. The analytical methodology is compatible with the

requirements of NTL 2008-G04 and the nomenclature and unit measurements reported

below are consistent with ASTM measurement standards and protocol.

The information included in Table 2-2 represents the chemical and physical

characteristics of oil that could be spilled in the largest volume spill during Phase II of the

development plan.
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Table 2-2 – Oils Characteristics

Area / Block WR Block 250 WR Block 425

BOEM Platform ID # N/A N/A

Field / Unit Cascade Unit 206 Chinook Unit 425

Sample Date (1) (2)

Sample # (1) (2)

Well # WR206#1, WR206#1bp1,

WR206#2, WR250#2ST1 WR469#1

Storage Tank ID # N/A N/A

Gravity (API) 17 - 26 22 - 29

Flash Point (C) Unknown Unknown

Pour Point (C) -16 to -24 -6 to -12

Dynamic Viscosity (Centipoise at 16C) 29 – 600 63 – 132

Dynamic Viscosity (Centipoise at 38C) 18 – 221 1 -2

Wax Content (wt %) 1.7 – 4.1 2.8 - 4.9

Asphaltene Content (wt %) 4.7 – 22.2 5.1 – 12.6

Resin Content (wt %) 20.4 – 36.1 15.3 – 25.8

Sulphur (wt %) 3.5 3.5

(1) 184 samples from April 15, 2002 to June 17, 2009 [information above is representative]

2(e) New or Unusual Technology

No new technology is proposed in this supplement however; the Conceptual Plan and the

Initial DOCD, both previously approved by the BOEM identified six components of the

phased Cascade / Chinook development plan that are considered technologies new to the

GoM. These six components were addressed extensively in the Initial DOCD as well as

the DWOP. BOEM Technical Assessment and Operations Support (TAOS) Section

reviewed and approved the safety and reliability of the technologies new to the GoM in

the approved DWOP (ref. Appendix 1a). There are no significant changes to the

information previously submitted regarding new or unusual technologies and the

information remains accurate and consistent.

The most important safety and pollution prevention features that will be used to mitigate

hazards related to technologies new to the GoM are described in Section 1(f).
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2(f) Bonding Statement

The bond requirements for the activities and facilities proposed in this DOCD are

satisfied by an area wide bond and supplemental bonding furnished and maintained in

accordance with 30 CFR Part 256, Subpart and NTL 2000 G16 “Guidelines for General

Lease Surety Bonds,” and NTL 2003 N06 “Supplemental Bond Procedures.”

2(g) Oil Spill Financial Responsibility

PAI (Operator #1207) has demonstrated oil spill financial responsibility for the facilities

proposed in this SDOCD in accordance with 30 CFR Part 253 and NTL 99 N01

“Guidelines for Oil Spill Financial Responsibility for Covered Facilities.”

2(h) Deepwater Well Control Statement

PAI (Operator #1207) has the financial capability to drill a relief well and conduct other

emergency well control operations.

2(i) Suspension of Production

In accordance with the PAI’s latest SOP, which was approved by BOEM letter dated 28

September 2011, PAI has committed to begin producing the Cascade Unit by December

2011. The SOP activity schedules are included in Appendix 1.

2(j) Blowout Scenario

Well Control during drilling and completion relies on a number of interrelated processes

and procedures. The drilling or completion fluid provide Primary Well Control during

operations with the fluid density providing hydrostatic pressure on the wellbore which

exceeds the pore pressures within the drilled or open hole formations. This overbalance

prevents fluid flow from the pore space in the formation to flow into the wellbore.

Subsea-mounted Blowout Prevention Equipment (BOPE), will provide Secondary Well

Control during drilling or completion operations. In the event that primary well control is

lost, the BOPE will contain the influx of formation fluid and then allow safe circulation

of the influx out of the wellbore. Generally speaking, the Cascade and Chinook wells are

considered Development wells and should have less unknowns and risk when compared

to Exploration wells.

Measures to Enhance the Ability to Prevent a Blowout

Well Control Training:

PAI requires certified well control training for drilling supervisors, operations

superintendents, drilling engineers, and the drilling contractor requires training for tool

pushers, drillers & assistant drillers, floor hands, and other appropriate personnel through

an operations training program with a professional organization and in accordance with

BSEE/BOEM requirements. The curriculum consists of training in blowout prevention

technology and well control. Successful completion results in participant certification.
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Well Control Monitoring and Procedures:

Automatic and manual monitoring equipment is installed to detect abnormal variation in

the mud system volumes and drilling parameters. If an influx of formation fluid into the

wellbore occurs, the BOPE will be used to immediately shut-in the well.

Each well will be drilled according to a location specific pore pressure profile and

detailed safe mud weight envelope. Too low of a mud weight could result in an underbalance in the well, and an influx of formation fluids. Conversely, too high of a mud

weight may result in lost circulation to a weak formation, which could lead to a drop in

fluid level (total hydrostatic column) resulting in an under-balanced condition. The mud

weight envelope is designed to provide the proper balance for well control for the

formation and pore pressure encountered.

In case an uncontrolled influx of formation fluid (water or hydrocarbon), or “Kick” does

occur, Secondary Well Control methods will be employed, i.e., the kick is quickly

detected, the pumps are turned off, the annulus will be shut in using the annular, the drill

pipe positioned relative to the annular, and the annulus isolated. The internal barrier in

the Drill Pipe is a downhole check valve near the bit and a surface-mounted valve. These

barriers will contain the influx and any associated build-up of surface pressure. It will

also prevent further influx of formation fluid into the wellbore.

Measures to Reduce the Likelihood of a Blowout

To kill an influx, surface pressures will be allowed to stabilize and then the SIDP (Shut In

Drill Pipe) and SICP (Shut In Casing Pressure) are measured. These pressures will

enable the calculation of the new kill-weight mud density needed to regain primary well

control. A standard well-kill procedure will be implemented to circulate the kill-weight

mud and safely remove formation fluids from the hole. Mud-gas separators and

degassers will be used to safely remove gas from the mud as it is circulated out of the

hole. After this procedure is completed, the kill effectiveness will be confirmed and the

well will be circulated around, the BOPE opened up and the fluid levels monitored.

Drilling operations will resume when the well has been brought under control and a static

condition exists.

Measures to Enhance the ability to Conduct Effective and Early Intervention in the

Event of a Blowout

Well Control drills/exercises are an integral part of the rig teams training and will be

performed on a frequent basis to ensure the human element is prepared, and the well can

be shut in quickly and properly. Certified training of Gulf of Mexico personnel will

include hands-on simulator practice at recognizing kicks, well shut-in, and circulating the

kicks out of the wellbore. Well specific shut-in procedures will be posted on the rig.

In the unlikely event of a “kick” or loss of well control event, surface intervention,

defined as the normal well control methods which include wellbore fluid control or

overbalance, diverter and BOP operations to shut-in the well from the surface will be the

primary response.
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Should surface intervention prove unsuccessful, PAI has evaluated two additional

potential scenarios to kill a blowout; seafloor intervention and a relief well. This would

involve subsea intervention in the form of; ROV control of the BOP stack via hot stabs, a

shut off device mounted on the BOP stack or LMRP, or diverting flow to a surface

vessel.

WCD and the Blowout Scenario

The Initial DOCD provided for two worst case discharge (WCD) scenarios identified for

Phase 1 of the development plan. The scenarios assumed the mechanical barriers to flow

to have failed, which would allow the well to flow uncontrolled at the sea floor. In both

cases, the ability to intervene before this occurrence is valid assuming that the subsea

wellhead connector profile remains undamaged. A blowout preventer stack or isolation

assembly could be positioned and latched on the profile and the well brought under

control. This operation would take 3-10 days, excluding the time required to mobilize the

rig.

The chances of a well bridging over in this scenario would be reasonably likely in an

exploration well, although the compressive strengths of the Wilcox group (EocenePaleocene), a prolific hydrocarbon producing sediment, make it more difficult.

The chances of a well bridging over in a completed well are very unlikely.

In light of the tragedy surrounding the Macondo incident of April 2010 and in accordance

with NTL N06, PAI has reevaluated the blowout scenario for an exploratory /

development / drilling operation in the Cascade Unit. In summary, according to the

instructions and direction of NTL N06 the PAI calculations and concurrence for the

WCD flow rates for the field result in rate of 18,135 barrels of oil per day (BOPD)

for Cascade (see Table 2-3). The main factors controlling these rates include reservoir

permeability, net pay thickness and oil viscosity. This information is described in detail

in Section 9 – Oil Spill Information. The values chosen for all the input parameters are

conservative (conservative in the sense of maximizing rate) estimates based on available

data gathered from drilling, cores, and detailed petrophysical analysis of wells drilled and

completed in these fields.
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Table 2-3 – Worst Case Discharge Scenario

In the event of a blowout, a total of 110-days may be necessary to secure a rig, mobilize

to the location, drill the relief well and kill the blowout well. Utilizing the maximum

discharge calculation from BOEM, the calculated Total Volume in barrels of a spill

lasting 110 days is:

18,135 bbls / day X 110 day = 1,994,850 total bbls.

PAI 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 the DOCD.

Category

OSRP WCDS

Drilling

DOCDWCDS

Drilling

OSRP WCDS

Production

DOCD WCDS

Production

Type of Activity Drilling Drilling

Subsea

Production

Subsea

Production

Facility Location(s)

WR 206

OCS-G 16965

WR 206

OCS-G 16965

GB Block 244

OCS-G 15860

WR 206

OCS-G 16965

Facility Designation

Subsea Well

Cascade #5

Subsea Well

Cascade #5

Subsea Well

Cottonwood #2

Subsea Well

Cascade #5

Distance to Nearest

Shoreline (Miles)

165 165 134 165

Volume (barrels) :

Storage Tanks (total) 0 0 0 0

On-facility Flowlines 0 0 0 0

Lease Term Pipelines 0 0 0 0

Uncontrolled Blowout

(volume per day) 18,135

18,135

18,000

16,281

Total Volume 18,135 18,135 18,000 16,281

Type of Oil

(e.g. Crude, Condensate,

Diesel)

Crude Crude Crude Crude

API Gravity 23 23 32 23
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PAI will work with specific partners and industry to develop rig-sharing agreements to

allow faster mobilization in the event of an emergency. In the event a relief well is

required, a deepwater rig currently located in the GOM would be contracted to drill the

relief well. As of July 2011, there are approximately 20 rigs in the GOM capable of

drilling a Cascade or Chinook relief well. The rig must be capable of drilling to a depth of

~29,000 feet in a water depth of 9,000 feet. This Rig will be a Rig of no constraints.

There are no platforms or other structures in the vicinity for drilling a relief well. PAI

expects to have a 2-rig operation by 2012, Phase II operations, with a rig operating in

each field.

2(k) Chemical Products

Per NTL 2008 G04, information regarding chemical products is not required for DOCDs

submitted of the BOEM GoM region.
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3 Geological and Geophysical (G&G) Information

3(a) Geological Description [PROPRIETARY]

3(b) Structure Maps [PROPRIETARY]

3(c) Interpreted 2-Dimensional and or 3-Dimensional Seismic Lines

[PROPRIETARY]

3(d) Geologic Structural Cross-Sections [PROPRIETARY]

3(e) Shallow Hazards Reports [PROPRIETARY]

3(f) Shallow Hazards Assessment [PROPRIETARY]

3(g) High-Resolution Seismic Lines [PROPRIETARY]

3(h) Stratigraphic Column

Per NTL 2008-G04, biostratigraphic / lithostratigraphic column information is not required for

DOCDs.

3(i) Time vs. Depth Tables

Per NTL 2008-G04, this information is required only for Exploration Plans where there is no

well control. As a result, this information is not provided in this DOCD.

3(j) Geochemical Information

Per NTL 2008-G04, geochemical information is not required for DOCDs submitted in the

BOEM GoM region.

3(k) Future G&G Activities

Per NTL 2008-G04, information related to future geological and geophysical activities is not

required to be included in DOCDs submitted to the BOEM GoM region.
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4 Hydrogen Sulfide (H2S) Information

4(a) Concentration

Samples from the Cascade and Chinook Units indicate that the estimated concentration of

H2S is approximately 0.6 parts per million by volume (ppmv). Simulations indicate a

maximum H2S concentration of 10.3 ppmv at arrival conditions. The pressure-volumetemperature analyses performed did not show any presence of H2S.

4(b) Classification [PROPRIETARY]

In accordance with Title 30 CFR 250.490(c), PAI respectfully requests that Walker Ridge

Blocks 206 and 250 be classified by the BOEM as an area where the absence of H2S has

been confirmed.

4(c) H2S Contingency Plan

A H2S contingency plan is not necessary.

4(d) Modeling Report

A H2S contingency plan is not necessary.
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5 Mineral Resource Conservation Information

5(a) Technology and Reservoir Engineering Practices / Procedures

Due to the water depth, wellbore depth, and low bubble point of the production fluids, the

hydrostatic pressure losses in the system are expected to be significant. Therefore, some

form of artificial lift is required to enhance the production flow rates.

PAI has decided to utilize subsea booster pumps during the development for

enhancement of production flow rates. Other artificial lift options either do not meet

field life boosting requirements (e.g. gas lift) or they are not sufficiently proven or

practical for high subsea flow rates. Although subsea booster pumps may not be needed

in the early stages of Phase I and Phase II of the development plan, the boosting system

will be used to test various scenarios on the boosting pump operating curve as well as to

assure that production rates remain high enough to avoid flow assurance issues (hydrate

formation / wax deposition).

PAI will be utilizing electrical submersible pumps (ESP) mounted in a frame on the

seafloor for boosting. ESP’s have a proven track record in the industry when installed in

wellbores. Installation of ESP’s on the seafloor is considered technology new to the

GoM by BOEM and the ultra deepwater industry.

Since there is indication of a large aquifer in both the Cascade and Chinook fields, the

base scenario assumes water influx as the primary recovery drive for long term reservoir

planning. During early production, the reservoir performance will be monitored to

evaluate the degree of pressure maintenance and the aquifer's strength. Depending on the

observed results, the recovery mechanism for the future phases will be selected. At this

time, PAI considers water injection (if needed) to likely be the best alternative among the

options for enhanced recovery methods for future phases of the development plan.

Recovery methods to be utilized in future phases of the development plan will be further

defined in a Supplemental DOCD.

5(b) Technology and Recovery Practices / Procedures and Reservoir

Information

Drilling and Completion

The Cascade discovery well WR Block 206 #1 spudded on January 31, 2002 and reached

total depth of 26,710 feet on April 14, 2002. The Chinook discovery well WR Block 469

#1 spudded on January 13, 2003 and reached total depth of 26,652 feet on June 19, 2003.

The Cascade and Chinook Project was sanctioned in 2006 and included Phased

development with 3-Phases. Phase I of the development plan includes the drilling and

completion of three new wells. Phase II will be full development of the drill centers &

manifolds, and Phase III will likely include new topsides, additional wells and potential

water injectors.
5. Mineral Resource Conservation Information

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Two of the wells in Phase I have already been drilled and completed: one well in the

Cascade East drill center (Walker Ridge 250, Well No. CA 003, OCS G-16970), and one

well in the Chinook Drill Center (Walker Ridge 469, Well No. CH 002, OCS G-16997).

This supplement covers the first two wells of Phase II in the Cascade Drill Center in WR

206 Wells No. 6 and 7. These two wells will be drilled and completed applying standard

GoM best practices and technologies. The objective of Phase II is to delineate the

reservoir, add production, and continue to gather sufficient information about the well

productivity to optimize future completions and development, including:

 Number and type of wells

 Completion design

 Production system capacity and type

 Subsea layout and boosting system

 Secondary recovery assessment

Figure 5-1 illustrates the casing program being utilized in Phase II of the development

program.
5. Mineral Resource Conservation Information

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Figure 5-1 – Casing Program

DEPTH (RT) HOLE SIZE CASING MW/PP/FG/FIT

FMC UWD-15K-LB 18-3/4" Wellhead top @ 8,215' MD,TVD

36" Housing @ 40° F

JET 36" X 2.0", X-60, RL-2HCX JET

36" X 1.50", X-56, RL-2HCX

36" X 1.0", X-56, RL-4F 8.6 PP

36" @ 8,5530' MD/TVD (322' BML) 42° F 8.6 FG

Cement circulated to mudline

22", 1.0" wall, X-80, RL4S RISERLESS

10 3/4" x 10 1/8" XO @ 11,300' 26" 8,215' - 11,552' MD SW / WBM

16" TOL @ 11,173' MD,TVD 22", 0.75" wall, X-60, RL4S

18" Landing Sub @ 11,506' MD,TVD 11,552' - 11,995' MD 8.6 PP

20" @ 11,995' 22" @11,992' MD/TVD (3,764' BML) 90° F 10.7 FG

18 1/8" x 19-1/2" 16", 96 ppf,

HCQ-125 H511 weight up to

9.9 ppg SBM

16" TOC @ 20,764' MD

9.7 PP

16" @ 21,764' MD, 21,510' TVD 198 °F 13.6 FG

Drill Depth 22,000' MD 13.2 FIT

TOC @ 23,250' MD for Production Tieback

13 5/8" TOC @ 23,766' MD Hold Inclination and Azimuth to 23.6° @ 162.5° Drill out with

11.2 ppg SBM

HCQ - 125 H 523 weight up to

Wireline: GR / Resistivity / Density/ Neutron / Sonic 10,200' - 24,766' MD 12.6

10 1/8" TOL @ 24,250' MD / 23,782' TVD

12.0 PP

14" x 13 5/8" @ 24,766' MD, 24254' TVD 234°F 15.4 FG

Drill Depth 24,900' MD

MWD: GR/Res/Sonic/PWD/Neu/Den

10-3/4" 79.2 ppf

TOC @ 25,174' MD for 10 1/8" Liner 12-1/4" HCQ-125 VAM HP MW

Hold Inclination and Azimuth to 23.6° @ 162.5° 8215' - 11,300' MD 14.5 -14.7 ppg

Earth Imager / 3DEX / XMAC / FLEX / SL 10-1/8" 79.2 ppf

HILD / MREX / ZDL / CN HCQ-125 VAM SLIJ-II

RCI (pressures and fluids) 11,300' - 27,211' MD 14.5 PP

Rotary SWC 10 1/8" Prod liner run and cemented @ TD

ZVSP / Checkshot 27,211' MD / 26,493' TVD 252 °F 10 3/4" x 10 1/8" Tieback run and cemented prior to completion 16.1 FG

Wireline Success Case:

MUDLOG

MUDLOG

MWD: GR/Res/PWD

MUDLOG

MWD: GR/Res/PWD

LOGS

8,218' MD,TVD

22" x 4' Hunting burst disk sub at

11,087' MD (6,092 psi burst)

16" x 4' Hunting collapse disk

subs at approximately 11,200' and

13,500' MDMD/TVD (7,000 psi

minimum back pressure, 2200 psi

collapse 16" x 22" annulus}

OH TD @12,043' MD (3,815' BML)

Start directional Rev I.2

17,259' MD, TVD BUR 1.5°/100'

Build to 23.6° inclination and 162.5°

Azimuth.

13-5/8", 88.2 ppf

14", 113 ppf

HCQ -125 H 523

8215' - 10,200' MD

MWD: GR/Res/Sonic/PWD 14-3/4"x16 1/2"

MWD: GR/Res/Sonic/PWD

Wireline: GR / Resistivity / Density/ Neutron / Sonic
5. Mineral Resource Conservation Information

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Given the challenging reservoir characteristics of low permeability (between 5-100md)

and low gravity oil (around 20° API), the completion of the wells must include reservoir

(near wellbore) stimulation techniques. The stimulation design must incorporate

hydraulic fracturing to improve conductivity and improve flow rates.

Due to uncertainties regarding the sand production potential and in order to achieve

greater levels of depletion prior to final abandonment, a fit-for-purpose Sand Control

Frac-Pack completion is the preferred choice in Phase II. To address the geological and

lithological challenges presented by the need for both stimulation and sand control, fracpacks with several stages in each well will be used to effectively stimulate the wells.

A Single-Trip Multi-Zone Frac Pack system is currently the completion design for the

lower completion of Cascade & Chinook development wells. This technology is being

developed by PAI and its vendors to reduce the complexity and cost of the completion

when compared to stack-frac completion systems. See Figure 5-2 for a conceptual

representation of a completion schematic for the downhole completion (upper and

lower).

The Cascade and Chinook reservoir depletion mechanisms and zonal contribution are not

yet fully understood. To understand this more a downhole remote flow control and

monitoring system (“intelligent completion” - IC) is being developed for the upper

completion in Phase II wells. The IC provides the ability to select or isolate intervals

producing in order establish a relative contribution from each zone. The system will also

aid in monitoring and control, isolation of water influx, minimizing cross-flow among

intervals, and managing real-time reservoir data. All intelligent completion hardware

will be installed above the sand face, providing reservoir and production management

capabilities from two “intervals”, regardless of the number of frac-pack intervals

completed in the lower completion.
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Figure 5-2 – Completion Schematic

RKB (West Sirius): 85.5'

WATER DEPTH: 8143'

ML (RKB est.): 8228.5'

WH (HP HSG) ELEVATION: 8219'

TH ELEVATION: 8211'

Prepared by: OM/ZH 05/27/2010

CASING MD (top) ID OD COMPLETION CONNECTION MAT-GRADE

8,211 ft 4.674 in n/a TBG HANGER (w/ 9 penetrations) 5-1/2" 26# Box down F6NM 80ksi

4960 psi 8,239 ft SAVER SUB ASSY 5-1/2" 26# Pin x Pin 13Cr HP1 110ksi

8,260 ft 4.548 in 6.075 in X-OVER SUB 5-1/2" 26# VamTop Box x Super 13Cr 110ksi

4-1/2" 15.1# VamTop Pin

8,267 ft 3.826 in 7.750 in ECCENTRIC BUMPER SUB (NOT SHOWN) 4-1/2" 15.1# VamTop Super 13Cr 110ksi

(T&C)

10-1/8" x 10-3/4" 79.22# HCQ-125 tieback to wellhead FLAT PACK #1 (SCSSV) - 2ea. 1/4"x.065"wt INC825

FLAT PACK #2 (DHCI and DHMS) - 2ea. 3/8"x.065"wt and 1ea. 1/4"x.049"wt (TEC) INC825

11,236 ft 3.688 in 7.560 in 4-1/2" 15Kpsi DHSV (N2 charged) w/ 3.688" ID Sealbore 4-1/2" 15.1# Box x Pin Super 13Cr 110ksi

(7.560"OD/3.688"ID)

11,254 ft 3.826 in 7.750 in ECCENTRIC BUMPER SUB (NOT SHOWN) 4-1/2" 15.1# VamTop Super 13Cr 110ksi

(T&C)

36" x 2", 1.5" & 1" wt X-56 RL-4S 8,550' MD

22" x 4' Hunting burst disk sub @ 11,117' (6,092psi) FLATPACK PROTECTION CLAMP compatible with Cast steel

16" FMC submudline hanger @ 11,243' MD (NOT SHOWN) 4-1/2 VamTop

16" x 4' Hunting collapse disk sub @ 11,307' (2,200psi)

18" FMC submudline hanger @ 11,534' MD

22" 1.00" wt 224# & .75" wt 170# X-80 RL-4S 11,993' MD

16" x 4' Hunting collapse disk sub @ 13,500' (2,200psi)

16" 95# HCQ-125 Hydril 511 20,446' MD

4-1/2" 15.1# VamTop PRODUCTION STRING 4-1/2" 15.1# VamTop 13Cr HP1 110ksi

3.826" ID (T&C)

10-3/4" x 10-1/8" X-over sub 21,949'MD/21,942'TVD

21,701 ft 3.688 in 6.287 in 4-1/2 Inj. Mandrel w/ Inj. valve for Scale Inhibitor 4-1/2" 15.1# VamTop PxP Super 13Cr 110ksi

(Complete with cplg)

21,709 ft 3.688 in 6.287 in 4-1/2 Inj. Mandrel w/ Inj. valve for Asphaltene Inhibitor 4-1/2" 15.1# VamTop PxP Super 13Cr 110ksi

(Complete with cplg)

21,718 ft 3.815 in 6.187 in 4-1/2 Dual Downhole Pressure/Temperature Mandrel 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi

13400 psi

22,241 ft 3.750 in 8.310 in 9-5/8" x 4-1/2" Retrievable Prod Packer 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi

22,259 ft 3.562 in 5.000 in 4-1/2" x 3.562 Top No-Go Seating Nipple (lock OD: 3.610") 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi

22,267 ft 3.750 in 5.880 in Baker SCT (single Cycle Tool) 4-1/2" 15.1# VamTop BxP Super 13Cr 110ksi

14.7 PPG

TOC (tie-back and 13-5/8") 22,670' MD ZnBr

15100 p[si ISOLATION STRING ASSY (Drawn in RED)

22,881 ft 6.000 in 8.420 in 10-1/8" x 6" ID SealBore Ret. Packer

22,887 ft 6.000 in 7.000 in 40ft long x 6"

4.600 in 5.985 in 6" OD Seal Nipple Assy w/ spacers - 10' minimum

22,910 ft Top of Seals are 21' into 40' seal bore assembly.

22,936 ft End of Upper Completion

10-1/8" x 13-5/8" liner hanger 23,148' MD 14.7 PPG 22,990 ft 3.870 in 8.015 in HES FS-1 Fluid Loss Control Device (Ball Valve) 5-1/2" 15.1# VamTop (w/ x-overs) Super 13Cr 110ksi

ZnBr

14" 113# HCQ-125 Hydril 523 (2000') x 23,102 ft 3.510 in 5.130 in 4-1/2" x 3.562 Bottom No-Go Seating Nipple

13-5/8" 88.2# HCQ-125 Hydril 523 23,835'MD/23,762'TVD

☼

17600 psi BJ MST Single-Trip FRAC-PACK ASSY

25,067 ft 8.420" x 6.000" ID XTR Sealbore Ret. Packer

Inner Production String: 2-7/8" PTS-8 Mechanical Tubing 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi

3.220" OD 2.371" ID

☼

25,282 ft **

Premium Screens Assy w/ 1ea. pos A22 prod MSV and

1ea. Pos 2 monitor & production MSV

(114 ft Screens) - 2 Production Sleeves at 25,313' & 25,373'

25,379 ft **

25,390 ft 2.371 in 3.750 in 30' - 3.750" Slick Joint 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi

25,397 ft 8.310" x 3.785" ID MST ISO Packer

25,496 ft **

Premium Screens Assy w/ 3ea. pos A33 prod MSVs and

1ea. Pos 2 monitor MSV

(214 ft Screens) - 3 Production Sleeves at 25,527', 25,567' & 25,646'

25,691 ft **

25,703 ft 2.371 in 3.750 in 30' - 3.750" Slick Joint 2-7/8" 6.5#/ft PTS-8 Super 13Cr 110ksi

☼

25,710 ft 8.310" x 3.785" ID MST ISO Packer

25,746 ft 1.710 in 3.668 in 3.22" x 1.71" Top No-Go Seating Nipple (Lock OD: 1.765") 2-7/8" 6.5#/ft PTS-8

25,944 ft **

☼ Premium Screens Assy w/ 2ea. pos A44 prod MSVs and

1ea. Pos 2 monitor MSV

(154 ft Screens) - 2 Production Sleeves at 25,980' & 26,040'

26,080 ft **

26,092 ft Sump Packer

26,120 ft End of MST Assembly

☼

10-1/8" 79.2# HCQ-125 production liner 27,014' MD/26,800' TVD

11.6 PPG NaBr

Walker Ridge

Cascade #4 - East Block (WALKER RIDGE 250 OCS G-16970 WELL NO. 3)

COMPLETION WELLBORE SCHEMATIC - As-Built

(FOR ILLUSTRATION PURPOSE ONLY)**

UPPER COMPLETION

14600 psi

c

15900 psi

LOWER COMPLETION (FRAC-PACK) ISO ASSEMBLY

40 ft PBR

10 ft Seal nipple

20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each

production sleeve

20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each

production sleeve

20' long 2-7/8" 6.5#/ft PTS-8 Perf Joint across each

production sleeve

Pos A22 Shifting Collet

Pos A33 Shifting Collet

Pos A44 Shifting Collet

Pos 1 Shifting Collet

(close only)

☼ RA Tags in 10-1/8" Prod Liner

- 23,985' MD

- 25,206' MD

- 25,703' MD

- 25,974' MD

- 26,336' MD

☼ RA Tags in MST Assy

- 25,084' MD

- 25,241' MD

- 25,454' MD

- 25,907' MD
5. Mineral Resource Conservation Information

Page 5-6 Petrobras America Inc.

Development Operations Coordination Document

Cascade / Chinook Development Project

Flow Assurance

The key flow assurance issues for the Cascade and Chinook Fields are driven by unique

fluid properties (low bubble point and high viscosity).

Flow assurance analysis has established that subsea equipment design, operating, and

maintenance procedures would have to include a number of mitigation measures to

maximize productivity and reserve recovery. These measures include:

 Subsea boosting of the production stream to provide a significant benefit in terms

of recoverable reserves

 Hydrate inhibition through subsea flowline insulation, chemical injection, and

operating procedures

 Dual, piggable flowlines will be utilized

 Chemical injection, both downhole and at the wellhead, will be used to mitigate

the precipitation of wax and asphaltenes

 Formation of emulsion is anticipated with increased water production in later field

life (i.e. post Phase 1); provision is planned for injecting demulsifier at the subsea

trees

 Utilize appropriate materials for erosion/corrosion management

 Provision for downhole sand control utilizing frac-pack techniques

 For planned FPSO disconnection scenarios (i.e. named storms which originate

outside of the GoM), the FSHRs and flowlines will be depressurized and

displaced with diesel for flow assurance mitigation prior to disconnection;

methanol will be injected into selected components (e.g. trees, pumps, manifolds)

to prevent hydrate formation

 For unplanned FPSO disconnection scenarios (i.e. named storms which originate

in the GoM), the FSHRs and flowlines will only be depressurized prior to

disconnection with the consequences of hydrate formation being addressed at

FPSO re-connection

Reservoir Information [PROPRIETARY]

Conservation Information Documents (CID) have been developed, submitted and

approved for the Cascade Field and for the Chinook Field. The Cascade CID was

approved by BOEM, formerly BOEMRE, on 17 November 2008 and the Chinook CID

was approved on 8 May 2009.
Petrobras America Inc. Page 6-1

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Cascade / Chinook Development Project

6 Biological, Physical, and Socioeconomic

Information

In accordance with 30 CFR 250.247, information on site-specific conditions relating to

the biological, physical, and socioeconomic conditions must accompany the DOCD and

therefore is provided herein. The biological information addresses chemosynthetic

communities, federally listed threatened and endangered species, critical habitat

designated under the ESA, marine mammals protected under the MMPA, sensitive

underwater features, marine sanctuaries, and other areas of biological concern. Physical

information addresses site-specific meteorological, physical oceanographic, geotechnical,

and archaeological conditions. Socioeconomic information addresses affected states and

human conditions of population, employment, and commercial and recreational industries

upon which they depend.

6(a) High Density Deepwater Benthic Communities Information

A primary concern in the development of any field is the avoidance by the field’s

architecture of biologically sensitive areas. In the deepwater GoM, the primary concern

is the protection of chemosynthetic organisms and fragile benthic habitats.

As required under 30 CFR 250.247(a), site-specific information regarding sensitive

underwater features, including high-density deepwater benthic communities is to be

provided in accordance with NTL 2009 G 40, effective January 27, 2010, and is provided

herein and in the associated Appendix 2a. According to the list of Known High-density

Deepwater Benthic Communities in the Gulf of Mexico, the closest known community

would be in Walker Ridge Block 269 at Lat.(N) 26o41.07’ and Long. (W) 91o, 40.28’

at water depth 1,862 m (http://www.gomr.mms.gov/homepg/regulate/environ/knowndwb

enthic.pdf). In 2006 and 2007, BOEM and NOAA funded deep submersible vehicle (the

Alvin in 2006) and remote operated vehicle (the Jason in 2007) to document the seafloor

geology and biological conditions associated with the continental slope, including Walker

Ridge lease block (Roberts et al 2008). These surveys documented an active hydrocarbon

seep site that supports a thriving chemosynthetic mussel and tubeworm community.

Cascade East Development Wells WR 206 No. 6 and 7 and associated jumper connectors

are not located within any of the areas of known communities: Alaminos Canyon, East

Breaks, Garden Banks, or Green Canyon, particularly the community identified in

Walker Ridge Block 269 which would be located over 117.7 km (73 miles) east of the

proposed project site and approximately 620m (2,034 feet) higher in elevation.

Nonetheless, PAI, in conjunction with Geoscience Earth and Marine Services, Inc.

(GEMS), designed and implemented both geophysical and geotechnical data acquisition

programs for Chinook, Cascade, and the Chinook Gas Export Routes during two studies:

Summary of Environmental Conditions for the Petrobras America Inc. Cascade and

Chinook Fields Development (2007) (see Appendix 2-B for full report) and Seafloor and
6 Biological, Physical, and Socioeconomic Information

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Development Operations Coordination Document

Cascade / Chinook Development Project

Geologic Assessment (Shallow Hazards) Report for Facilities (2007) (see Appendix 2-B

for full report). The Cascade data acquisition area includes the location for Cascade East

Development Wells WR 206 No. 6 and 7 and associated jumper connectors.

Additionally, PAI, initiated an environmental monitoring program of water, sediments,

and marine organisms within the Walker Ridge Cascade and Chinook Development Units

to provide environmental characterization after initial exploration and development wells

installation in order to evaluate results of these activities. Analytical results from

monitoring are compared to “benchmarks” developed by the U.S. Environmental

Protection Agency (EPA). These benchmarks provide interested parties a tool to evaluate

potential risks to aquatic life and humans coming into contact with impacted water and

sediments. Initial findings from an initial monitoring campaign undertaken in September

2010 indicate no exceedances of EPA acute and chronic benchmarks for any of the

petroleum hydrocarbon analytes, including polyaromatic hydrocarbons, in sediment and

water samples. This initial monitoring campaign provided a “snapshot” in time of water

and sediment conditions in Walker Ridge Cascade and Chinook Oil Production blocks in

September 2010. The absence of detectable concentrations of polyaromatic

hydrocarbons and reportable total petroleum hydrocarbons in the sediment samples

suggests that no petroleum hydrocarbon contamination was detected in the study area

bottom surface sediments during the time of the Characterization Campaign. This

information may be utilized as a benchmark and becomes especially important in light of

the ‘Macondo’ tragedy in early 2010. Summaries of the findings of these three studies

are provided below.

Environmental survey protocol included 3D seismic data and 2D High-resolution Hugin

AUV survey data and groundtruthing to identify and avoid biologically sensitive areas

defined and protected by BOEM. There is precedent to employ the use of 3D seabed

peak seismic amplitude data to infer the presence of conditions that may be conducive to

high-density deepwater benthic communities, including chemosynthetic communities and

sensitive benthic habitats (Roberts et al 2008). GEMS has reviewed the 3D seismic

coverage provide by PAI. However, GEMS defers to the available 2D High-Resolution

data.

The 2D High-Resolution geophysical data consists of multibeam bathymetry (3m bins),

side-scan sonar, and chirp sub bottom profiler data. These data provide information on

seabed reflectance character which is inferred to be seabed soil type or hardness. This is

excellent for identifying areas of potential harder substrate that may be an indication of

the presence of chemosynthetic organisms or sensitive habitat. The sub bottom profiler

provides further evidence for harder substrate, or, hydrocarbon indicators necessary as

the source for chemosynthetic communities. The multibeam bathymetry also provides

indirect evidence for hydrocarbon mounds or organic mounds from the topography of the

seafloor. Used in combination, these data provide the best geophysical means to identify

and define areas where there is potential for chemosynthetic communities to occur and

forms the basis for the assessment of the seabed and shallow conditions with respect to

the protection of these sensitive benthic communities.
6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-3

Development Operations Coordination Document

Cascade / Chinook Development Project

The Seafloor and Geologic Assessment Report of Cascade and Chinook Development

Areas (June 2007 DOCD, Appendix 2-B) provides in detail information on the geologic

structure, stratigraphy, slopes and topographic features, and potential for chemosynthetic

communities. No active faults, gas venting, or hard bottom conditions were identified

within the Cascade Development Area. There is no potential for encountering

chemosynthetic communities in the area planned for Cascade East Development Wells

WR 206 No. 6 and 7.

The initial assessment of PAI’s environmental monitoring program indicates that an

abundance and diversity of infauna in the seafloor sediments was low. The soft bottom

benthic community was dominated by polychaetes.

Discharges and Moorings Related to Drilling Cascade East Wells

NTL 2009-G40 increased the separation distance from muds and cuttings discharge

locations to 2,000 feet 9609.6m) from any high-density deepwater benthic community.

Features or areas that could support high-density chemosynthetic communities are not

located within 2,000 feet of the proposed muds and cuttings discharge locations for the

Cascade East Development Wells WR 206 No. 6 and 7 located in WR Block 206. PAI

proposes to utilize one vessel to drill and complete the Cascade wells: the “Deep Ocean

Mendocino”. The vessel, as defined by 46 USC 2101(45), is a dynamic position drilling

ship (provided in MMS Form 137 in Section 1) thus; the seafloor will not be disturbed by

an anchoring or mooring system.

Discharges related to drilling would involve drilling fluids which were identified along

with amounts per well in Section 2, Table 2-1, Section 7, and Appendix 7-A. A majority

of these fluids are recycled or reused. Relatively small amount of soft seafloor sediments

would be temporarily disturbed, put into suspension, and settled out again a short

distance from the area of disturbance by the local currents. Discharges are further

addressed in Section 19 (c) 3.

The proposed action would have localized impact on water quality from the FPSO,

shuttle vessels, drilling rig, and support vessels produced water discharges and waste

water discharges and deck drainage. However, these impacts would not be significant

because produced water and waste water are treated onboard prior to discharge according

to NPDES General Permit requirements to a sufficient quality for discharging overboard

as indicated in Section 7 and as addressed in Section 19 (c) 3, the previous Deepwater

Operations and Activities Environmental Assessment (DOI 2000), and the Proposed Use

of Floating Production, Storage, and Offloading Systems on the Gulf of Mexico Outer

Continental Shelf Final Environmental Impact Statement (DOI 2001).

Subsea Facilities

Subsea facilities associated with Cascade East Development Wells WR 206 No. 6 and 7

will involve jumpers to be installed to connect the wells to a common four slot manifold

which has already been installed. Later Phase II development will include an additional

drill center with trees, jumpers and an additional manifold tied into the existing subsea

architecture. The Cascade East seafloor wells will be tied back to the Cascade
6 Biological, Physical, and Socioeconomic Information

Page 6-4 Petrobras America Inc.

Development Operations Coordination Document

Cascade / Chinook Development Project

development via tie-back flow lines that then connected to the FPSO through floating

flow lines/production risers and umbilicals. Features or areas that could support highdensity chemosynthetic communities were not located within 2,000 feet (609.6m) of any

seafloor disturbances resulting from installation of the subsea facilities located in WR

Block 206 included in the monitoring area. In accordance with 30 CFR 250.221 (a) and

30 CFR 250.252 (a), a description of monitoring of the proposed activities is provided in

6(g) and Section 10.

6(b) Topographic Features Map

As per NTL 2009-G40, a map depicting seafloor/bathymetry conditions using highresolution seismic information at a scale of 1 inch = 1,000 feet is provided in Figure 6-1.

Analysis of seafloor conditions was undertaken and results are provided in Appendix 2-

A, confirming no high-density deepwater benthic communities or underwater sensitive

features are within 2,000 feet (609.6m) of each proposed well discharge location.

Per 30 CFR 250, subpart B and NTL 2008-G04, information requirements for EPs and

DOCDs, the information required in this section pertains to activities occurring near

protective zones and within 1,000 feet (305 meters) of a “No Activity Zone” of an

identified topographic feature. The facilities associated with Phase II, specifically

Cascade East Development Wells WR 206 No. 6 and 7, of the development plan are

located in a water depth of over 8,000 feet (2,446.5m) and are not located near a

“Protective Zone” or “No Activity Zone”. Shuttle Vessels and marine support vessels

could cross over “No Activity Zones”, however no bottom disturbances to these features

are anticipated.

Cascade Development Area consists of three geomorphic provinces: the Lower

Continental Slope, the Sigsbee Escarpment, and the Upper Continental Rise. The

Cascade East oil development facilities, including Cascade East Development Wells WR

206 No. 6 and 7 are, and will be placed on the Upper Continental Rise. The location for

the Cascade East development was found to have low gradient with furrows and flukes

caused by periodic strong seabed currents resulting in local topographic highs. There are

no indications of mounds, expulsion features, or stronger reflectance suggestive of more

granular or hard substrate. Topographic features / bathymetry within 2,000 feet (609.6m)

of the proposed well locations are shown in Figure 6-1.

6(c) Topographic Features Statement (Shunting)

Per NTL 2008 G04, this information is not required for DOCDs.

6(d) Live Bottoms (Pinnacle Trend) Map

Per NTL 2008-G04, the information required in this section pertains to activities

occurring within 200 feet (61 meters) of a Live Bottom (Pinnacle Trend). The facilities

associated with Phase II, specifically Cascade East Development Wells WR 206 No. 6

and 7 of the development plan are not located near a Live Bottom (Pinnacle Trend).
6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-5

Development Operations Coordination Document

Cascade / Chinook Development Project

6(e) Live Bottoms (Low Relief) Map

Per NTL 2008-G04, the information required in this section pertains to activities

occurring within 100 feet (30.5 meters) of a Live Bottom (Low Relief). The facilities

associated with Phase II, specifically Cascade East Development Wells WR 206 No. 6

and 7, of the development plan are not located near a Live Bottom (Low Relief).

6(f) Potentially Sensitive Biological Features

Per NTL 2008-G04, the information required in this section pertains to activities

occurring within 200 feet (61 meters) of a Sensitive Biological Feature. Sensitive

biological features include topographic features, pinnacles, live bottoms typically found

in water depths less than 984 feet (300 meters) in the Gulf of Mexico. The Cascade East

Development Area, including Cascade East Development Wells WR 206 No. 6 and 7, are

located in over 8,000 feet (2,446.5 meters) of water depth. The facilities associated with

Phase II of the development plan are not located near a Sensitive Biological Feature.

Further, Cascade East Development Area, which includes Cascade East Development

Wells WR 206 No. 6 and 7, has seafloor currents that have and continue to erode and redeposit seabed sediments. The 2010-2011 site-specific environmental monitoring found

the Area to have soft bottom sediments and confirmed the absence of chemosynthetic

communities within 2,000 feet (609.6m) of the drill center as indicated in Figure 6-1. It

is unlikely that organisms requiring hard bottom substrate would find suitable

colonization locations within the proposed project area.

6(g) Remotely Operated Vehicle (ROV) Monitoring Survey Plan

PAI is familiar with the ROV survey and the reporting provisions described in NTL

2008-G06, Remotely Operated Vehicle Surveys in Deepwater. As per NTL 2008-G06,

ROV survey plans are required for Exploration Plans. ROV monitoring was undertaken

before and after initial installation activities using guidance from NTL No 2008-G06 and

the ROV survey plan results were submitted as required on MMS Form 141 by Devon.

A ROV survey plan is not required for this supplemental DOCD.

6(h) Threatened and Endangered Species Information

Florida and Alabama are not Affected States for Phase II, including Cascade East

Development Wells WR 206 No. 6 and 7, of the development plan. As per NTL 2008-

G04, site-specific information on the presence of federally-listed threatened and

endangered species and critical habitat as designated under ESA, along with information

on marine mammals as protected under the MMPA for the Affected States of Texas,

Louisiana, and Mississippi, is provided in the Environmental Impact Analysis located in

Section 19.

6(i) Archeological Report

BOEM GOMR has not identified a potential for containing historic or prehistoric

archeological resources within the Cascade East Development Area containing the
6 Biological, Physical, and Socioeconomic Information

Page 6-6 Petrobras America Inc.

Development Operations Coordination Document

Cascade / Chinook Development Project

location of Cascade East Development Wells WR 206 No. 6 and 7. The proposed project

location is not located within specific areas defined as “Archeological Survey Blocks”.

Archeological considerations are included in the GEMS Summary of Environmental

Conditions for Cascade and Chinook and the GEMS Shallow Hazards Report for

Facilities in Appendix 2.

6(j) Air and Water Quality Information

Florida and Alabama are not Affected States for Phase II, specifically Cascade East

Development Wells WR 206 No. 6 and 7 of the development plan. As a result, the

information for Florida and Alabama is not provided per NTL 2008-G04. However, air

and water quality information for the Affected States (Texas, Louisiana, and Mississippi)

is provided in the Environmental Impact Analysis located in Section 19. See also

information in Section 8 on air emissions.

PAI initiated a water and sediment analysis study in 2010 with sampling within the

Walker Ridge Cascade and Chinook Development Units to provide an environmental

characterization after exploration and development wells installation. Sampling was

done on a grid using 37 sampling stations. Sampling points were located in water depths

ranging from 6,650-9,180 feet (2,000-2,800 meters) with water samples collected at 5

depths: surface, start and end of thermocline, mid-depth, and near-bottom depth. This

study addressed obtaining hydrographic and seawater data and among other things,

toxicity testing.

Twenty-nine water and sediment parameters were addressed in the 2010 environmental

monitoring. No petroleum hydrocarbon contamination was detected. Low

concentrations of metals on the seafloor sediments indicate lack of significant

concentrations in the water column. Water quality was found not acutely toxic to

Americamysis bahia.

6(k) Socioeconomic Information

Although the Gulf of Mexico is bounded by five coastal states, Florida and Alabama are

not Affected States for Phase II, specifically Cascade East Development Wells WR 206

No. 6 and 7 of the development plan. As a result, information is provided per NTL 2008-

G04 on socioeconomic information for the Affected States of Texas, Louisiana, and

Mississippi in the Environmental Impact Analysis located in Section 19.
6 Biological, Physical, and Socioeconomic Information

Petrobras America Inc. Page 6-7

Development Operations Coordination Document

Cascade / Chinook Development Project

Figure 6-1 Bathymetry Map
6 Biological, Physical, and Socioeconomic Information

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Petrobras America Inc. Page 7-1

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7 Waste and Discharge Information

7(a) Projected Generated Wastes

Appendix 7 indicates projected solid and liquid wastes likely to be generated per well by

drilling and completion operations during Phase II (including Cascade WR 206 Wells

No. 6 and 7) of the development plan. Appendix 7-A addresses wastes generated by the

drilling rig while Appendix 7-B addresses separately wastes generated by the FPSO.

Appendix 7-C and Appendix 7-D provide information on transportation and on shore

disposal of the wastes generated by the drilling rig and FPSO, respectively.

Waste generated by the FPSO and Drilling Rigs operations include both solid and liquid

wastes and will be covered under the NPDES General Permit.

Plans for treating, storing, and disposal of solid and liquid wastes generated by the FPSO

and Drilling Rigs will be temporarily stored onboard these respective vessels until

transported to onshore facilities by supply boats for disposal (approximately weekly).

The FPSO and Drilling Rigs will be contracted to PAI and are covered under PAI waste

management plans. Their respective solid and liquid wastes that they generate will be

transported onshore for proper disposal in authorized facilities. Support vessels (supply

and service vessels) will be used for the FPSO and Drilling Rigs. Any wastes generated

by these support vessels are the responsibility of the support vessel and covered under

their respective waste management plans. PAI anticipates that those support vessel

owners will utilize existing onshore disposal facilities (with no need for expansions) that

are consistent with those onshore disposal facilities that PAI currently utilizes. Section

15 provides information on support vessels and Section 15(d) provides further

information on the transportation of solid and liquid wastes to shore via the support

vessels. Section 16 provides information on onshore support facilities and 16(d) provides

additional information on solid and liquid waste disposal. Sanitary wastes associated with

the FPSO, and Drilling Rigs, would be treated by an approved USCG Marine Sanitation

Device and discharged overboard with no floating solids. All other wastes generated on

the FPSO and Drilling Rigs will be treated (as required) and discharged per Region 6

NPDES General Permit requirements.

7(b) Projected Ocean Discharges

Appendix 7-A indicates discharge method of various types of waste with indication of

expected ocean discharges of solid and liquid wastes associated with drilling and

completion operations for Phase II (including Cascade WR 206 Wells No. 6 and 7) of the

development plan.

Appendix 7-B indicates discharge methods by waste type generated by the FPSO with an

indication of the wastes expected for overboard ocean discharges of solid and liquid

wastes associated with FPSO production operations for Phase II of the development plan.
7 Waste and Discharge Information

Page 7-2 Petrobras America Inc.

Development Operations Coordination Document

Cascade / Chinook Development Project

Waste discharged by the FPSO and Drilling Rigs operations will be covered under the

NPDES General Permit.

7(c) Modeling Report

PAI sent to the Environmental Protection Agency (EPA) a Notice of Intent on May 03,

2009 requesting coverage under EPA Region 6 NPDES General Permit (GMG 290000)

for discharges associated with Phase II which includes Cascade WR 206 Wells No. 6 and

7 of the development plan. As a result, modeling is not required per NTL 2008-G04.

7(d) NPDES Permits

Per NTL 2008-G04, information regarding NPDES permits is not required for DOCDs

submitted in the BOEM GoM region.

7(e) Cooling Water Intakes

Per NTL 2008-G04, information regarding cooling water intake structures is not required

to accompany DOCDs submitted in the BOEM GoM region.
Petrobras America Inc. Page 8-1

Development Operations Coordination Document

Cascade / Chinook Development Project

8 Air Emissions Information

8(a) Complex and Plan Emissions

The Complex Total Emissions information includes a second drilling rig for Cascade

during Phase II of the development plan beyond the first rig that will be working at

Chinook. The Complex Total Emissions evaluation also includes the FPSO, support

vessels, shuttle vessels, and aircraft. There are no other existing facilities or activities colocated with our currently proposed activities.

Drilling rigs are not subject to the Greenhouse Gas Reporting Rule. The stationary

sources and fugitive emissions (engines, flares, pipe valves, flanges, and vents) on the

FPSO are subject to the Greenhouse Gas Reporting Rule, however, the FPSO has not yet

started production. Greenhouse gas emissions from the FPSO in 2011 must be reported

by March 21, 2012.

8(b) Screening Questions

Is any calculated Complex Total (CT) Emission amount (tons) associated with your

proposed development and production activities more than 90% of the amounts

calculated using the following formulas: CT = 34002/3 for CO, and CT = 33.3D for the

other air pollutants (where D = distance to shore in miles)?

Yes No

X

Do your emission calculations include any emission reduction measures or modified

emission factors?

X

Does or will the facility complex associated with your proposed development and

production activities process production from eight or more wells? X

Do you expect to encounter H2S at concentrations greater than 20 parts per million

(ppm)? X

Do you propose to flare or vent natural gas in excess of the criteria set forth under §

250.1105(a)(2) and (3)? X

Do you propose to burn produced hydrocarbon liquids? X

Are your proposed development and production activities located within 25 miles (40

kilometers) from shore? X

Are your proposed development and production activities located within 124 miles (200

kilometers) of the Breton Wilderness Area? X

8(c) Worksheets

Air emissions worksheets for Phase II of the development plan are in Appendix 3.
8. Air Emissions Information

Page 8-2 Petrobras America Inc.

Development Operations Coordination Document

Cascade / Chinook Development Project

8(d) Contact Information

For questions regarding calculations of the projected Plan Emissions, contact:

Gregory D. Roland

Regulatory Compliance Area Manager

Petrobras America Inc.

10350 Richmond Ave, Suite 1400

Houston, Texas 77042

Office: 713-808-2881

8(e) Emissions Reduction Measures

The Plan Emissions do include emissions reductions measures as the Plan Emissions are

below the Exemption threshold. Petrobras used different fuel use factors based on data

from actual fuel use in Phase I. Emission factors are from the original BOEM

spreadsheet, updated AP42 factors, manufacturer’s guarantee, and helicopter emission

factors from Swiss Confederate emissions data. All changes are documented in the

“Factors” noted in the spreadsheet in Appendix 3.

8(f) Verification of Non-Default Emissions Factors

The air emissions worksheets in Appendix 3 include descriptions of the rationale for

operating assumptions (i.e. fuel consumption) related to certain facilities and marine

equipment used for Phase II of the development plan in the notes of each worksheet.

8(g) Non Exempt Activities

The Plan Emissions are below the Exemption threshold.

8(h) Modeling Report

Modeling will not be required as the Plan Emissions are below the Exemption threshold.
Petrobras America Inc. Page 9-1

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9 Oil Spill Information

9(a) Oil Spill Response Planning

Regional Oil Spill Response Information

Proposed activities in this Supplemental DOCD cover drilling, completion and

production of two additional Cascade wells, WR 206 Well No. 6 and Well No. 7. The

activities are covered under PAIs (BOEM operator #1207) Regional Oil Spill Response

Plan (OSRP) filed in accordance with 30 CFR 254. PAI’s WCD planning volume is

18,135 bopd reflecting the calculations of the Resource Evaluation Section (RE) of

BOEM. PAI’s latest OSRP biennial filing was submitted on 27 July 2011 and is pending

approval.

Information provided in herein has been updated and is current to the best of PAI

knowledge at the time of this SDOCD submittal. In light of the Macondo tragedy PAI

recognizes that industry as a whole continues to experience new regulatory requirements,

challenges and changes. Many of the OSROs are bolstering resources, especially

equipment and personnel and as fast as these changes are occurring, some information in

this section could become obsolete shortly after submittal of this document. The numbers

reflected herein should be considered minimum capacities and could be much more

substantial by the time this SDOCD is approved. PAI confirms our commitment to revise

and update these capabilities and inventories as appropriate and as information is

received and confirmed by our OSROs. Changes will be reflected in any OSRP update /

modification as soon as the information becomes available or regulatory requirements

mandate changes.

Spill Response Sites

PAI is currently a member of Clean Gulf Associates (CGA) who acts as PAI’s primary

equipment provider. CGA is an industry cooperative, owning an inventory of oil spill

clean-up equipment which is located throughout the gulf coast. CGA is supported by the

Marine Spill Response Corporation (MSRC), which is responsible for storing, inspecting,

maintaining and dispatching CGA’s equipment. CGA also has access to equipment

provided by the National Response Corporation (NRC) and the Teppco Marine Services

LLC Barges. The MSRC STARS network provides the closest available personnel, as

well as an MSRC supervisor to operate the equipment.

PAI’s primary spill response equipment is provided by CGA as described in the current

OSRP. Table 9-1 indicates the locations of PAI’s primary spill response equipment and

the locations of the planned staging areas.
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Table 9-1 – Location of CGA Oil Spill Response Equipment & Staging Areas

Primary Response

Equipment Locations (CGA)

Preplanned

Staging Locations (CGA)

CGA/Galveston, TX Galveston, TX

CGA/Harvey, LA Houma, LA/Venice, LA

CGA/Houma, LA Houma, LA

CGA/Lake Charles, LA Cameron, LA

CGA/Ingleside, TX Ingleside, TX

CGA/Intracoastal City, LA Intracoastal City, LA

CGA/Pascagoula, MS Pascagoula, MS

CGA/Venice, LA Venice, LA

PAI also has access to spill response equipment provided by CCA. Table 9-2 indicates

the locations of CCA’s spill response equipment and the locations of the planned staging

areas.

Table 9-2 – Location of CCA Oil Spill Response Equipment & Staging Areas

Response Equipment Locations (MSRC GoM) Preplanned Staging Locations (MSRC GoM)

Fort Lauderdale, FL Fourchon, LA

Venice, LA

Houma, LA

OSRO Information

PAI is currently a member of Clean Gulf Associates (CGA). The de-rated (i.e. 20% of

equipment name plate per manufacturer specification) daily mechanical recovery

capabilities for each OSRO is described in Table 9-3.

Table 9-3 – OSRO Mechanical Recovery and Storage Capabilities

OSRO De-Rated Daily Recovery

Capability (barrels per day)

Storage Capacity

(bbls)

Clean Gulf Associates (CGA) 139,796 7,396

CGA Access T&T Marine Services LLC

Koseq Skimming Arms

196,119 22,000

CGA Access T&T Marine Services LLC

Aqua Guard Triton RBS Skimmers

45,560 4,000

CGA Access Enterprise Marine

Services LLC Storage Barges

-- 201,000

CGA Access K-Sea operating

Partnership Storage Barges

-- 1,478,222

TOTAL 381,475 1,712,618
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PAI will also utilize dispersants as an alternative response strategy in certain

circumstances when approved by regulatory authorities. The available dispersant

inventories are described in Table 9-4.

Table 9-4 – Dispersant Inventories

OSRO Dispersant Inventory (gallons)

Clean Gulf Associates 33,300

CGA ASI Access 49,155

TOTAL 82,455

PAI also utilizes other complimentary specialist OSROs as appropriate, including but not

limited to AMPOL, Garner Environmental Services, Industrial Cleanup, Oil Mop, and

PSC Industrial Services. See the current -OSRP for a complete listing.

Worst Case Scenario Determination

WCD Scenario for MMS Areas of Interest:

Table 9-5 provides a comparison of the Worst Case Discharge (WCD) scenarios from

PAI’s OSRP with the WCD scenario from the proposed activities covered by this

supplemental DOCD. As shown, the calculated WCD for this Supplemental DOCD is

18,135 bopd. This is explained in Appendix 6 by the fact that the calculated WCD for

these proposed wells is less than the amount calculated by BOEM RE section tusy PAI

has chosen to utilize the higher number for simplification and minimum response

planning and containment resources. BOEM RE section has authorized PAI to utilize the

greater WCD volume (18,135 bopd) calculated for Walker Ridge (206) for WCD

planning volumes in PAI’s OSRP and previous SDOCD and confirmed that it is not

necessary to make changes to the PAI calculations in Appendix 6.

Pursuant to guidance from BOEM, PAI agreement to utilize the BOEM-RE calculated

WCD volume of 18,135 bopd WCD, and in accordance with NTL 2008 G 04, PAI

provides the following compliance statement:
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Table 9-5 – Worst Case Discharge Scenario

Category

R-OSRP

WCDS

DOCD WCDS

Drilling

DOCD WCDS

Production

Type of Activity Drilling Drilling Subsea Production Produced to

FPSO

Facility Location(s)

WR 206

OCS-G 16965

WR 469

OCS-G

16997

WR Block 249

OCS-G 16969

Facility Designation

Subsea Wells

Cascade No. 6

and 7

Subsea Well

Chinook

WR425-W

FPSO

Distance to Nearest Shoreline

(Miles) 165 165 134

Volume (barrels) :

Storage Tanks (total) 0 0 6,010 (1)

On-facility Flowlines 0 0 2,000 (2)

Lease Term Pipelines 0 0 2,110

Uncontrolled Blowout

(volume per day) 18,135 15,477 (3) -

Total Volume 18,135 15,477 10,120

Type of Oil

(e.g. Crude, Condensate, Diesel) Crude Crude Crude

API Gravity 23 26 23

Notes:

(1) Includes FPSO Topsides Tanks only; does not include FPSO Cargo or Fuel Tanks; see 1(d)

for storage tank details and 9© below for additional discussion

(2) On-facility Flowlines includes Processing Piping (including Turret systems)

(3) See Appendix 6 for details

Additional notes for BOEM WCD Scenario:

 PAI is proposing to perform well testing for the Cascade Wells (WR 206 Well

No. 6 and 7) proposed by this Supplemental DOCD. PAI is proposing to

discharge the well completion fluids (which will not include EPA defined

“priority pollutants”) per NPDES requirements.

 PAI is not proposing to use oil-based drilling fluids. PAI is proposing to use

water-based and synthetic-based drilling fluids for the drilling of the proposed

Cascade wells covered by this Supplemental DOCD.

 A site –specific worst case scenario is included in PAI’s Regional OSRP for

the FPSO (which will receive production from the Cascade / Chinook subsea

well[s]) Production rates from the wells does not affect the FPSO WCD.
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9(b) Oil Spill Response Discussion – BSEE Areas of Interest

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 18,135 barrels of crude oil with an API gravity of 23°.

9(b).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 BSEE Oil Spill Risk Analysis Model (OSRAM) for

the Central and Western Gulf of Mexico available on the BSEE website. The results are

shown in Table 9-6. The BSEE OSRAM identifies a 2% probability of impact to the

shorelines of Galveston County, Texas; Cameron Parish, Louisiana; and/or Plaquemines

Parish, Louisiana within 30 days.

Table 9-6 – Trajectory by Land Segment

Galveston County includes the Gulf Beach from the west end of Galveston Island at

Texas Highway 3005 to the east coast of High Island at the Jefferson County line.

Habitats include marshes at the west end of Seawall Boulevard and on the east end of the

island and open beaches and avian feeding areas all along the coastline, including a

National Audubon Society Sanctuary. The waters of Galveston Bay are classified as an

EPA National Estuary.

Cameron Parish includes the east side of Sabine Lake, Sabine National Wildlife Refuge,

Calcasieu Lake, Lacassine National Wildlife Refuge (inland) and Grand Lake. Cameron

Parish also includes the area along the coastline from Sabine Pass to Big Constance Lake

in Rockefeller Wildlife Refuge. This region is composed of open public beaches,

Trajectory of a spill and the probability of it impacting a land segment have been projected

utilizing Petrobras America Inc.’s WCD and information in the BSEE Oil Spill Risk

Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the

BSEE 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

Drilling Operations

WR 206 165 miles

from shore

G16965 C48

Matagorda County, TX

Brazoria County, TX

Galveston County, TX

Jefferson County, TX

Cameron Parish, LA

Vermilion Parish, LA

Terrebonne Parish, LA

LaFourche Parish, LA

Plaquemines Parish,

LA

1

1

2

1

2

1

1

1

2
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marshlands and swamps. It serves as a habitat for numerous birds, finfish and other

animals, including several rare, threatened and endangered species.

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.

9(b).2 Response

Petrobras America Inc. will make every effort to respond to the Worst Case Discharge as

effectively as practicable. A description of the response equipment available to contain

and recover the Worst Case Discharge is shown in Appendix 4 with estimated response

times.

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. As shown

in Table 9-7, the results indicate 18% or approximately 3,264 barrels of crude oil would

be evaporated/dispersed within 24 hours, with approximately 14,871 barrels remaining.

Table 9-7 – Oil Spill Response Results

Spill Response WR 206 Barrels of Oil

WCD Volume 18,135

Less 18% natural evaporation/dispersion 3,264

Remaining volume 14,871

Oil addressed by aerial dispersants 7,540

Oil addressed by in-situ burning 744

Appendix 4 outlines equipment, personnel, materials and support vessels as well as

temporary storage equipment available to respond to a spill of 18,135 barrels. The list

estimates individual times needed for procurement, load out, travel time to the site and

deployment. Appendix 4 also indicates how operations will be supported.

Petrobras America Inc.’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 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 totaling 419 bbls of dispersants should disperse

approximately 7,540 barrels of oil. If the conditions are favorable for in-situ burning, the
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proper approvals have been obtained and the proper planning is in place, in-situ burning

of oil may be attempted. Using estimates based on the Deepwater Horizon spill of 2010,

up to 5% or approximately 744 barrels of the total daily Worst Case Discharge remaining

volume could be burned. Slick containment boom would be immediately called out and

on-scene as soon as possible. Offshore response strategies may include attempting to

skim utilizing the HOSS Barge and seven Fast Response Units (FRUs), with a total

derated skimming capacity of 69,390 barrels. Temporary storage associated with

skimming equipment equals 5,300 barrels. If additional storage is needed, a 20,000 barrel

storage barge and a 47,000 barrel storage barge may be mobilized and centrally located to

provide temporary storage allowing the skimmers to stay in the area of operations as

much as possible. Safety is first priority. Air monitoring will be accomplished and

operations deemed safe prior to any containment/skimming attempts.

If the spill went unabated, shoreline impact in Galveston County, Texas; Cameron Parish,

Louisiana; and/or Plaquemines Parish, Louisiana would depend upon existing

environmental conditions. Shoreline protection would include the use of CGA’s near

shore and shallow water skimmers with a totaled derated skimming capacity of 18,253

barrels. Temporary storage associated with skimming equipment equals 1,317 barrels. If

additional storage is needed, a 20,000 barrel storage barge may be mobilized and

centrally located to provide temporary storage allowing the skimmers to stay in the area

of operations as much as possible. Onshore response may include the deployment of

shoreline boom on beach areas, or protection and sorbent boom on vegetated areas.

Letters of Intent from AMPOL, Miller, Oil Mop and USES will ensure access to

approximately 263,000 feet of 18” shoreline protection boom. Appendix 4 outlines

individual times needed for procurement, load out, travel time to the site and deployment.

Strategies would be based upon surveillance and real time trajectories that depict areas of

potential impact given actual sea and weather conditions. The One-Gulf Plan (Area

Contingency Plan) and Unified Command would be consulted to ensure that

environmental and special economic resources would be correctly identified and

prioritized to ensure optimal protection. The State of Louisiana Initial Oil Spill Response

Plan for Cameron Parish/Plaquemines Parish and 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 modes 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 coastal 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 operation of equipment allowing a more effective response to sitespecific circumstances. Petrobras Americas Inc.’s contract Spill Management Team holds

copies of the State of Louisiana Initial Oil Spill Response Plan and the One-Gulf Plan.
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9(b)2.1 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

Petrobras America Inc. will take action to provide a safe, aggressive response to contain

and recover 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.

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 plan 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
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9(b)2.2 Offshore Response Actions

9(b)2.2.1 Equipment Deployment

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 remote sensing systems, aerial

photography and visual confirmation

• Continual monitoring of vessel assets using vessel monitoring systems

9(b)2.2.2 Dispersant application assets

• Put ASI on standby

• With the FOSC, conduct analysis to determine appropriateness of dispersant

application

• 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 equipment and

personnel

• Confirm dispersant availability for current and long range operations

• Start ordering dispersant stocks required for expected operations

9(b)2.2.3 Containment boom

• Call out early and expedite deployment to be on scene ASAP

• Ensure boom handling 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

9(b)2.2.4 Dedicated off-shore skimming systems

General

• Deployed to the highest concentration of oil

• Assets deployed at safe distance from aerial dispersant and in-situ burn operations

CGA
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HOSS Barge

• Use in areas with heaviest oil concentrations

• Consider for use in areas of known debris (seaweed, and other floating materials)

CGA FRUs

• To the area of the thickest oil

• Use as far off-shore as allowed

Storage Vessels

• Establish availability of CGA contracted assets

• 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 Petrobras America Inc.’s contracted resources as applicable

• Industry vessels are usually best 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 for vessel inspections

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 ignition systems

• Start ordering fire boom stocks required for expected operations

• Contact boom manufacturer to provide training if required

• Determine assets to perform on water operation

• Build operations into safety plan

• Conduct operations in accordance with an approved plan
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9(b)2.3 Near Shore Response Actions

9(b)2.3.1 Timing

• Put near shore assets on standby and deployment in accordance with planning

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 Considerations

• Water depth, vessel draft

• Shoreline gradient

• State of the oil

• Use of VOOs

• Distance of surf zone from shoreline

9(b)2.3.2 Equipment Deployment

Surveillance

• Provide trained observer to direct skimming operations

• Continual surveillance of oil movement by remote sensing systems, aerial

photography and visual confirmation

• Continual monitoring of vessel assets

9(b)2.3.3 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)

9(b)2.3.4 Vessel Deployment

Dedicated Near Shore Skimming Systems

• FRVs

• Egmopol and Marco SWS

• Operate with aerial spotter directing systems to observed oil slicks VOO

• Use Petrobras America Inc.’s contracted resources as applicable

• Industry vessel are usually best 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
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• 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

9(b)2.4 Shoreline Protection Operations

9(b)2.4.1 Response Planning Considerations

• Environmental risk assessments (ERA) to determine priorities for area protection

• Time to acquire personnel and equipment and their availability

• Previous contingency planning contained in the appropriate Area Contingency

Plan, and currently for Louisiana, The State of Louisiana Initial Oil Spill

Response Plan, Deep Water Horizon, dated 2 May 2010 (La. OSRP)

9(b)2.4.2 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 movement

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 and 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 minimize 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
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• 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 protection boom may be considered to protect

sensitive inland areas

9(b).3Decanting 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 can 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. This practice

is routinely used for oil spill recovery.

9(b).4 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 capabilities 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. Skimming equipment

listed in Table 9-8 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.

Table 9-8 – Oil Spill Response Equipment Limitations

Boom 3 foot seas, 20 knot winds

Dispersants Winds more than 25 knots

Visibility less than 3 nautical miles

Ceiling less than 1,000 feet.

FRU 8 foot seas

HOSS Barge/OSRB 8 foot seas

Koseq Arms 8 foot seas

OSRV 4 foot seas

9(b).5 Environmental Conditions in the GOM

Prevailing winds, waves and currents along the Texas coast are from the southeast and

northeast quadrants. Ten to 20 foot waves may occur during hurricanes. The combined

effect of the winds, surface currents, and waves refracting shoreward produce the

prevailing westerly longshore currents.
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Tides are semi-diurnal and diurnal, and range in height from less than 1 foot to 2.5 feet.

The direction, force, and duration of the wind has a considerable effect on the tides and

currents. Fifteen foot tides may be expected during severe hurricanes and very low tides

may accompany strong northerlies of long duration.

Surface water temperature averages slightly less than 90° F and ranges between 80 and

100° F during the late summer. During the winter the average is slightly less than 60° F

and the range is between 35 and 80° F.

Louisiana is situated between the easterly and westerly wind belts, and therefore,

experiences westerly 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 Atlantic 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.

9(c) Oil Spill Response Discussion – USCG Areas of Interest

This section is provided to assure a comprehensive NEPA review.

PAI is also capable of responding to the Worst Case Discharge, the Maximum Most

Probable Discharge, and Average Most Probable Discharge scenarios which are focused

on USCG areas of interest related to marine vessels as described in the most recent

Memorandum of Agreement between the MMS and the USCG (OCS-03) and 33 CFR

Part 155 Subpart D. PAI will utilize existing memberships in Clean Gulf Associates

(CGA) and Clean Caribbean & Americas (CCA) to demonstrate oil spill response

capability.

Although PAI is capable of responding to the various USCG defined discharge scenarios,

it should be noted that the owners of the FPSO and the Shuttle Vessels will also be

responsible for demonstrating that they have the capability to respond to the USCG

defined discharge scenarios prior to USCG approval of their vessel specific oil spill

response plans. Although each of the organizations (PAI and vessels owners) will be

capable of responding to the USCG defined discharge scenarios, it is anticipated that the

vessel owners’ will have the primary responsibility as vessel operators while PAI will

have secondary responsibility due to ownership of the produced oil. The details

regarding primary and secondary responsibility will be finalized with the USCG after
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PAI awards contracts for the provision of the FPSO and Shuttle Vessels (approximately

3Q07).

Table 9-9 describes the amounts associated with each USCG discharge scenario for the

FPSO.

Table 9-10 describes the amounts associated with each USCG discharge scenario for the

Shuttle Vessels.

PAI and the USCG have required the FPSO owner / provider to implement a vessel

specific oil spill response plan (i.e. SOPEP) which is approved by the USCG and which

will be bridged to the PAI -OSRP. PAI and the USCG also required the Shuttle Vessel

owner / provider to implement a SOPEP which is approved by the USCG and is bridged

to the PAI OSRP. Comprehensive drills will / are performed to verify readiness from all

involved parties (PAI, FPSO provider, and Shuttle Vessel provider).

Table 9-9 – FPSO Discharge Scenarios (USCG Areas of Interest)

USCG Discharge

Scenario for FPSO

Estimated Amount

(barrels) Comments

Worst Case Discharge 550,000 - 650,000

Equal to discharge of a marine vessel’s entire

cargo tanks in adverse weather conditions. See

notes (1) and (2) for additional details.

Maximum Most Probable

Discharge 2,500

Equal to 2,500 barrels of oil for vessels with a

cargo capacity equal to or greater than 25,000

barrels OR 10% of the vessels oil cargo capacity

with a capacity of less than 25,000 barrels. See

note (3) for additional details.

Average Most Probable

Discharge 50

Equal to the lessor of 50 barrels of oil or 1% of

the cargo from the vessel during cargo oil

transfer operations to or from the vessel

Notes :

(1) The USCG Worst Case Discharge would involve a total loss of the FPSO which is an extreme low

probability event given the industry proven controls that PAI has in place.

(2) The USCG has implemented a geographic (i.e. inland, nearshore, offshore, open ocean) based

cap system to identify the amount of planning volumes that must be covered by contract. For

offshore work scopes, the planning volume caps are 12,500 barrels per day for Tier 1, 25,000

barrels per day for Tier 2, and 50,000 barrels per day for Tier 3. When the required planning

volume exceeds the cap amounts, the vessel owner is only required to have OSRO contracts in

place up to the amount of the caps, but the vessel owner is required to identify sources of

additional OSRO resources to respond to the required planning volumes over and above the cap.

Regarding the USCG Worst Case Discharge planning volumes for the FPSO, PAI currently has the

capability to respond to the cap amounts of the required planning volumes for Tiers 1-3 through

CGA and CCA. PAI may be required to identify but not contract additional OSRO coverage (e.g.

MSRC, NRC) due to the required planning volumes associated with onshore recovery of oil spilled

offshore which could reach the shore, depending on the OSRO coverage that the FPSO owner has

in place.

(3) The USCG Maximum Most Probable Discharge is significantly greater than an oil spill associated

with FPSO offloading, which may be the highest exposure regarding oil spills associated with

FPSOs. As mentioned in section 1(f), PAI will utilize a number of industry proven safety and

pollution prevention measures to mitigate against oil spills during FPSO offloading. If multiple

controls mentioned in section 1(f) failed, the amount of oil spilled during FPSO offloading would

likely be an order of magnitude lower (i.e. the amount of oil in the offloading hose) than the

amount of the USCG Maximum Most Probable Discharge.
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Table 9-10 – Shuttle Vessel Discharge Scenarios (USCG Areas of Interest)

USCG Discharge

Scenario for Shuttle

Vessels

Estimated Amount

(barrels) Comments

Worst Case Discharge 185,000 - 330,000

Equal to discharge of a marine vessel’s entire

cargo tanks in adverse weather conditions. See

notes (1) and (2) for additional details.

Maximum Most Probable

Discharge 2,500

Equal to 2,500 barrels of oil for vessels with a

cargo capacity equal to or greater than 25,000

barrels OR 10% of the vessels oil cargo capacity

with a capacity of less than 25,000 barrels. See

note (3) for additional details.

Average Most Probable

Discharge 50

Equal to the lessor of 50 barrels of oil or 1% of the

cargo from the vessel during cargo oil transfer

operations to or from the vessel

Notes :

(1) The USCG Worst Case Discharge would involve a total loss of the Shuttle Vessel which is an

extreme low probability event given the industry proven controls that PAI will put in place.

(2) The USCG has implemented a geographic (i.e. inland, nearshore, offshore, open ocean) based

cap system to identify the amount of planning volumes that must be covered by contract. For

offshore work scopes, the planning volume caps are 12,500 barrels per day for Tier 1, 25,000

barrels per day for Tier 2, and 50,000 barrels per day for Tier 3. When the required planning

volume exceeds the cap amounts, the vessel owner is only required to have OSRO contracts in

place up to the amount of the caps, but the vessel owner is required to identify sources of

additional OSRO resources to respond to the required planning volumes over and above the cap.

PAI may be required to identify but not contract additional OSRO coverage (e.g. MSRC, NRC) due

to the required planning volumes associated with onshore recovery of oil spilled offshore or

nearshore which could reach the shore, depending on the OSRO coverage that the Shuttle Vessel

owner has in place.

(3) The USCG Maximum Most Probable Discharge is significantly greater than an oil spill associated

with Shuttle Vessel loading at the FPSO or Shuttle Vessel offloading at terminals, which may be

the highest exposures regarding oil spills associated with Shuttle Vessels. As described in section

1(f), PAI will utilize a number of industry proven safety and pollution prevention measures to

mitigate against oil spills during Shuttle Vessel loading at the FPSO while terminal operators will

utilize a number of industry proven safety and pollution prevention measures to mitigate against

oil spills during Shuttle Vessel offloading at terminals. If multiple controls described in section

1(f) failed, the amount of oil spilled would likely be an order of magnitude lower (i.e. the

amount of oil in the offloading hose) than the amount of the USCG Maximum Most Probable

Discharge.

9(d) Modeling Report

At PAI’s request, MMS conducted a site specific Oil Spill Risk Analysis (OSRA) in

February 2007 to estimate the risk of impacts to coastal resources resulting from oil spills

in the Walker Ridge area. A summary of the results follow. See Appendix 5 to review

the details of PAI’s Oil Spill Risk Analysis Report.

This model calculates the trajectories of oil spills from hypothetical spill locations to

various environmental resources using realistic data fields of winds and ocean currents in

the GoM. The ocean currents used are computed from an ocean circulation model of the

GoM driven by “analyzed meteorological forces,” such as near-surface winds and total

heat fluxes, and observed river inflow. The models used are versions of the Princeton
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Ocean Model (POM), which allows a realistic coastline and bottom topography to be

represented in the model. In addition, the OSRA model incorporates the Mellor-Yamada

turbulence closure model to represent the vertical mixing process in the water column.

In the trajectory simulation portion of the OSRA model, hypothetical oil spills are

initiated at regular intervals in space and time within the study area. The other portion of

the model records the number of times the simulated oil spills come into contact with the

shoreline and other environmental resources. The OSRA model periodically divides the

total number of contacts to shoreline segments by the total number of simulated oil spills

in the study area to arrive at estimated probabilities of oil-spill contact (Ji et al., 2007).

For this analysis at Walker Ridge, MMS analyzed the trajectories of a typical offshore oil

spill of 1,000 bbls or greater occurring under the activities described in this DOCD. The

simulations did not include factors such as possible cleanup operations, chemical

composition, or biological weathering of oil spills, or the spreading and splitting of oil

spills, which could affect the transport of spilled oil as well as the dimensions, volume,

and nature of the oil spills. The model takes a more environmentally conservative

approach by presuming persistence of spilled oil over the selected duration of time of the

trajectories. However, an implicit analysis of the likely weathering and cleanup of a

typical offshore oil spill of 1,000 bbl or greater occurring under the proposed action

scenarios shows that the slick would not persist on the water surface beyond 10 days

(MMS 2002).

The trajectories run for Walker Ridge were followed for at least 30 days in the model.

This allowed more hypothetical spills to reach the environmental resources and the

shoreline from more distant spill locations. With increased travel time, the complex

patterns of wind and ocean currents produce eddy-like motions of the oil spills and results

in multiple opportunities for a spill to make contact with any given environmental

resource or shoreline segment (Ji et al., 2007).

The OSRA results were that, due to the study area’s distance of 140 to 160 nautical miles

from the shoreline, there were no probabilities of contact greater than 0.5% for oil spills

persisting from 3 to 10 days and an annual average maximum probability of contact of

2%. Oil spills in transit for 30 days were more likely to come into contact with

environmental resources and the shoreline. However, it is contemplated that active

response activities and weathering factors would likely mean that oil would not persist

long enough to reach the U.S. shoreline. The study area is approximately 40 to 55

nautical miles from the limits of the Exclusive Economic Zone; therefore, the

international boundary segments included in the model have annual average contact

probabilities of up to 16% within 10 days (Ji et al., 2007).
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10 Environmental Monitoring Information

10(a) Monitoring Systems

As per CFR 250.252, PAI will utilize numerous monitoring systems to measure

environmental conditions and to identify conditions which may impact the environment

or asset integrity of the facilities. PAI, has initiated an environmental monitoring

program of water, sediments, and marine organisms within the Walker Ridge Cascade

East Development Unit to provide environmental characterization after initial exploration

and development wells installation in order to evaluate results of these activities. The

monitoring plan results are discussed in more detail in Section 6 of this Supplemental

DOCD.

The Environmental Monitoring Plan (EMP) utilized by PAI is based on environmental

understanding and an initial bio-physical-chemical parameters evaluation developed

during a field baseline study, performed in September 2010. The combination of the

baseline study and the EMP will provide PAI with a planned strategy to monitor the

marine environment within the leased blocks as a proactive measure toward regulatory

compliance and unforeseen litigation in the event of a release of oil in or near the Walker

Ridge Cascade production area (Walker Ridge Area).

The EMP will be carried out by scientific and technical crews with extensive experience

in collecting oceanographic data, including deep-sea sediments, water and biological

samples, for a thorough understanding of the deep–sea ecosystems of Walker Ridge.

The overall objectives for the EMP are: 1) to better understand the environmental

characteristics of the area; and, 2) to evaluate the evolution and trends that may result

from future exploration and production of oil in the area and nearby.

The implementation of a well designed EMP will provide many tangible benefits, such

as:

 A good understanding of the ecosystems of the area where PAI is conducting

exploration and production activities.

 Early detection of inadvertent releases of petroleum from deep-sea wellheads,

piping, the FPSO and off-loading operations and an understanding of resulting

environmental effects.

 A proactive approach for the collection and analysis of scientifically creditable

data that may be used to address regulatory or legal concerns.

 Credibility with regulatory agencies, stakeholders, and the community for taking a

socially responsible approach that always meets or exceeds mandated

requirements.
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Proper execution of this monitoring plan requires, at a minimum, the use of shipboard

methodologies, equipment, instrumentation and protocols that are standard in the industry

today. This ensures results that fulfill regulatory requirements while providing

scientifically credible data for improved ecosystem understanding for scientific,

conservation, and policy purposes. The accuracy and standardization of the data is

particularly important in that it may be extremely useful to agencies and activities

interested in developing and enhancing process models for the Gulf of Mexico.

It is anticipated that PAI representatives will actively take part in future environmental

monitoring activities in Walker Ridge. The scope of work of the EMP, for instance, will

include the collection and analysis of water, sediment, plankton, benthos and nekton

fauna in the natural structures of the Gulf of Mexico deep water ecosystem.

The Media and data for the Environmental Monitoring Plan will consist of:

 Sea water physical-chemical parameters, including conductivity, temperature and

density;

 Ocean sediment physical-chemical parameters, including drilling muds and

cutting discharges;

 Biological parameters, including any incidental takes;

 Meteorological parameters, including air emissions;

 Ocean current measurements;

 Aqueous discharges; and

 Solid waste discharges.

PAI affirms that an effective monitoring and assessment program should be adaptive and

supported by effective communication plans and response plans. As an understanding of

the local ecosystems improves over time, monitoring locations, approaches, and

methodologies may need to change to reflect this knowledge.

A list of additional important monitoring systems is included below.

 Fully outfitted Central Control Room on the FPSO providing the capability of

monitoring topsides / subsea production systems and FPSO marine systems;

 Monitoring and testing per Region 6 NPDES General Permit requirements;

 Monitoring and testing of surface and subsurface safety systems per 30 CFR 250

Subpart H ;

 Inert Gas Monitoring System to be used on FPSO;

 Air Emissions monitoring to collect and report facility, equipment, fuel usage, and

other activity information during the period January 1, 2011, to December 31,

2011 as per NTL 2010-G06 on emissions data for NAAQS criteria pollutants

carbon monoxide (CO), sulfur dioxide (SO2), nitrogen oxides (NOx), particulate
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matter-10 (PM10), particulate matter-2.5 (PM2.5), all volatile organic compounds

(VOC), including exempted compounds (40 CFR 51.100), as well as greenhouse

gases CO2, CH4, and N2O.;

 Ballast Monitoring System to be used on FPSO ;

 In-Service Inspection Plan (utilizing CCTV and ROV inspections) to be used on

the FPSO in lieu of dry-docking;

 Leak detection and recovery system for the swivel located in the FPSO turret;

 Leak testing of critical connections performed after FPSO re-connection prior to

introduction of pressurized fluids;

 CCTV to be utilized in the FPSO turret for critical connection systems;

 Life cycle management of polyester components of mooring system managed

through IMRR Plan (if polyester mooring is used);

 ROV surveys performed after installation of polyester mooring system; performed

annually thereafter (if polyester mooring is used);

 Watchkeeping performed by FPSO and Shuttle Vessel crews during offloading

operations;

 Offloading Telemetry System with OESD1 and OESD2 capabilities;

 Hawser (i.e. mooring line between FPSO and Shuttle Vessel) tension monitoring

system;

 CCTV for spill detection during offloading operations;

 Infrared leak detection system during offloading operations;

 Flexible jumpers outfitted with a leak detection system;

 FSHRs outfitted with a tension monitoring system;

 FSHRs outfitted with VIV monitoring system (if needed);

 Monitoring of turret motions in FPSO-connected and FPSO-disconnected

conditions;

 Downhole monitoring system for wells;

 Ocean current monitoring performed using ADCP arrays (during drilling and

production operations) as required by NTL 2009-G02; and

 Monitoring and reporting applicable statistics to the BOEM Gulf of Mexico OCS

Region (GOMR) regarding evacuation of personnel and curtailment of production

because of hurricanes and tropical storms as required by NTL 2011-G01.
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10(b) Flower Garden Banks National Marine Sanctuary

Phase II of the development plan is located approximately 170 miles (273.5 km) from the

Flower Garden Banks and approximately 225 miles (362.1 km) from the Stetson Banks

and will not include activities within either the protective zones of the Flower Garden

Banks or the Stetson Banks.
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11 Lease Stipulations Information

11(a) Topographic Features Stipulation

The proposed Cascade East Development WR 206 Wells No. 6 and 7 associated with

Phase II of the development plan is located in a water depth of over 8000 feet and is not

located near a “No Activity Zone”. Shuttle Vessels and marine support vessels could

cross over “No Activity Zones” but disturbances to these features are not anticipated.

11(b) Live Bottoms (Pinnacle Trend) Stipulation

Neither the drilling locations nor facilities associated with Phase II of the development

plan are located near a Live Bottom (Pinnacle Trend).

11(c) Military Warning Area Stipulation

The FPSO will be located in WR Block 249 which is approximately 15 miles south of

Military Warning Area W92. PAI has and will continue to notify the designated military

contact prior to engaging in operations which may cross the W92 Military Warning Area

(Shuttle Vessels, marine support vessels, and helicopters).
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12 Environmental Mitigation Measures

Information

Major issues associated with the FPSO and three wells have been addressed in the Initial

DOCD and the site-specific Environmental Assessment for a FPSO Facility (USDOI

2008). Impact producing factors associated with two additional wells (Cascade East

Development Wells WR 206 No. 6 and 7) in the Cascade Field and their associated

jumper connectors would include seafloor disturbances, including physical disturbances

to benthic communities from well jumper installation, ocean waste discharges during

drilling activities and from shuttle vessels, air emissions, onshore waste disposal, noise

from drilling activities, shuttle vessel operations, vessel and helicopter collisions with

coastal and marine mammals and birds, respectively and accidental blowout and oil spill.

These impact producing factors were considered in the Multiscale EIS (USDOI 2007)

and the Deepwater EA (USDOI 2000a). Therefore, site specific analysis of applicable

mitigation measures is provided below. As per 30 CFR 250.223 and CFR 250.254 and

the information requirements specified in NTL No. 2008-G04, the following applies:

a) Florida is not an Affected State. Therefore, information regarding the measures PAI

will take to avoid, minimize, and mitigate impacts to marine and coastal resources in the

state of Florida is not applicable.

b) Incidental takes are not likely with the installation of the two wells and their associated

jump connectors in the Cascade Field. No impacts to marine and coastal environments

and habitats, biota, and threatened and endangered species occurred during installation of

the initial subsea infrastructure or the initial wells. Nonetheless, mitigation measures to

avoid and minimize incidental take of threatened and endangered species listed under the

ESA and marine mammals under MMPA, as applicable to the proposed work area

associated with the two additional wells include:

1) having a good understanding of the ecosystem through site-specific

investigations;

2) having knowledge of potential hazards and project activity effects on the

ecosystem;

3) early detection through monitoring (see Section 10) of inadvertent releases

from either drilling, production, off-loading operations with an

understanding of the environmental consequences; and

4) taking a proactive approach to avoid impact.
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c) Site-Specific mitigation measures are as follows:

c1. Air Quality

Fugitive emissions from equipment/vessels are controlled at potential source using

BMPs. Other specific mitigation measures would include use of low-sulfur polluting

fuels (diesel or bunker fuel) to reduce SO2 impacts. If ozone is an issue, undertake NOx

control. Consider timing of source emissions to occur during non-peak ozone periods.

Consider use of offset or emission credits. Two additional wells in the Cascade Field

would be far removed from human population areas. Results of air emission modeling

show no significant impact to localized air quality and no mitigation measures are

required.

c2. Sea Floor Habitat

The results of recent (September 2010) baseline monitoring of the Cascade Field project

area show soft bottom in which burrowing infauna are the most abundant. The

monitoring summary confirms no impacts or exceedances of EPA thresholds. There is no

known hard-bottom in project area of the proposed wells, Cascade East Wells WR 206

No. 6 and 7 or their jumper connector locations. No high density deepwater benthic

communities, including chemosynthetic communities, were observed. Impact producing

factors to the seafloor habitat would involve drilling activities and installing jumper

connector with resuspension of the soft sediments likely. However, impacts from

installation of the wells and jumpers will not likely have significant impact due to short

duration of construction activities and small aerial footprint and natural distribution of

sediments by seafloor currents. Proposed use of a DP vessel to install the wells further

reduces the anticipated impact associated with the actions.

Rapid burial by sediment accumulation of greater than one foot (30 cm) in thickness

would be lethal to those organisms that do inhabit the proposed project area (MMS

2008). Accidental spill from a well blowout might rapidly smother infauna. Recolonization is expected however. Dispersal from strong ocean currents could have an

effect increasing an impact area should an inadvertent spill occur.

The primary concern is habitat alteration during construction/drilling activities and

inadvertent spills. Site-specific mitigation measures include:

 Conduct pre-drilling ROV surveys;

 Monitor during and post-drilling (additional ROV surveys); and

 No explosives or anchoring are part of this supplemental activity, therefore no

significant impact would occur and no mitigation measure required.

PAI completed seafloor mapping of the project area in advance of project installation,

ensuring appropriate siting to avoid and minimize potential impacts and hazards

associated with the seafloor. As per NTL 2008-G06, PAI will be conducting ROV

surveys to assist with site-specific mitigation, as required. Monitoring results conducted
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following the successful installation of initial project activities showed no impacts to the

seafloor.

c3. Ocean Currents and Movements

Installation of the two wells would have no measurable impact on ocean currents and

movements. Conversely, PAI has developed hurricane avoidance plans for the FPSO,

and for the drilling rigs. No mitigation measure would be required.

c4. Water Quality

Project: drilling, completing and producing associated with Cascade East Wells WR 206

No. 6 and 7, is located approximately 165 miles (265.5 km) offshore, GoM, in over 8,200

feet (2,446.5 meters) of water depth. Oil Spill Emergency Plans were developed for the

FPSO and for the drilling rigs including procedures such as the use of radar, watch

standing, and other communication efforts that will minimize the chance of collisions, all

of which contribute to water quality protection measures. In coastal waters, the water

quality issues identified by Gulf of Mexico Alliance are bacteria-related beach and

shellfish bed closures, estuarine hypoxia, harmful algae blooms, and seafood

contamination. Existing pollutant sources along the coast include petrochemical plants

and refineries. The National Research Council (NRC 2003) estimated that 942 metric

tons of oil per year (about 6,600 barrels/year) enter the Gulf from these plants and

refineries in Texas and Louisiana. The Mississippi River brings in and additional 525, 60

metric tons (about 3.7 million barrels /year) (NRC 2003). Water quality in the Gulf is

further affected by shipping and fishing vessels as well as recreational boaters from bilge

water, liquid and solid and leached chemicals from anti-fouling paints (USDOI 2008).

Site-specific water quality has been assessed and based on completed sampling to date,

no issues were identified.

In offshore waters, a zone of hypoxia on the Texas-Louisiana shelf is one of the largest

areas of low oxygen in the world (Murray 1998). Phosphorus is the primary source of

hypoxia and the proposed project will not contribute additional phosphorus to Gulf water.

No significant water quality impacts have been identified in conjunction with the

installation of the previous wells.

During drilling, limiting drilling fluids use, and /or use of environmentally friendly

(biodegradable, non-toxic) fluids would be site-specific mitigation measures. Minimal

resuspension of soft bottom sediments associated with drilling activities and installation

of the jumper cable should have negligible effect since 1) the existing sediments are not

contaminated as per the results of the baseline environmental monitoring report and 2)

seafloor currents naturally redistribute these sediments. Other site-specific mitigation

measures that PAI will be implementing include the following:

 During operation, PAI will undertake routine monitoring and update spill

prevention, control and countermeasures plans, including pre-staging of response

vessels and equipment, as applicable.
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 Shuttle vessels, double-hulled and compartmentalized, shall follow good

maintenance and housekeeping to avoid oil and other chemical releases offshore,

near shore and dockside.

 Adherence to USCG circular NVIC 07-02 guidelines.

c5. Hazardous Materials and Waste Management

 PAI has developed hazardous materials and waste management plans addressing

transport, use, and storage. These plans incorporate emergency response

procedures, including notification requirements.

 PAI minimizes waste with reduction procedures and pollution prevention goals.

 PAI develops and routinely trains staff on spill prevention and response plan.

 Secondary containment will be provided, as applicable.

c6. Acoustic Environment

No seismic surveys are a part of activities associated with drilling, completing and

producing additional wells in the Cascade East Field development. Therefore, no

mitigation measures are required.

c7. Marine Mammals

Potential impacts to marine mammals include noise, water quality degradation, vessel

collisions, inadvertent oil spills, spill-response activities, trash and debris. These

potential impacts would be the same for non T&E species of concern. PAI will

implement the following measures to minimize impacts to marine mammals.

 Avoid shuttle vessel strikes by adhering to guidance in NTL 2003-G10 “Vessel

Strike Avoidance and Injured/Dead Protected Species Reporting”;

 Avoid known important cetacean congregation areas, mating and/or feeding areas;

 Reduce speeds when marine mammals are present and maintain safe distance;

 Coordinate w/NMFS and USFWS and follow NMFS Regional Viewing

Guidelines; and

 Consider having at least one qualified marine mammal observer present during

construction activities.

c8. Marine and Coastal Birds

Proposed activities are located over 180 miles (290 km) offshore in the GoM. Other than

transient individuals, the project area is not expected to be in a high use area. Shuttle

vessels from the FPSO to existing ports will use existing shipping lanes. Based on the

minimal impact expected, no mitigation measures are required.
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c9. Fish Resources and Essential Fish Habitat

The description of Essential Fish Habitat (EFH) has been revised as per Generic

Amendment #3 to the Gulf of Mexico Fishery Management Plan. The habitats most

important for managed fish species are those in shallow, less than 100 fathoms of water.

The proposed project is in over 8,200 feet (2,500 meters) of water depth and is no longer

in a blanket designation of EFH. The project area does retain EFH designation for some

specific species: shark, tuna, swordfish, and sailfish. The benthic fish population within

the project site is very low in density and restricted to species that live below 8,200 feet

(2,508 meters), primarily oceanic bathypelagics. In the water column above the seafloor

of the project site, fish species may include oceanic pelagic and mesopelagics (see

Section 19(b)8). Shuttle vessels will utilize existing commercial shipping lanes in

shallower water areas. Principal impacts would be temporary disturbance during

construction /well drilling of any bottom foraging and inadvertent oil spills. To minimize

impacts to fish resources and EFH, PAI will:

 Conduct surveys and monitoring during the installation of the proposed Cascade

wells and associated jumpers; and

 Adhere to NMFS accepted EFH Conservation Recommendations including the

recent six additional recommendations.

c10. Sea Turtles

Sea turtles are found throughout the GoM. Based on the depth of water that the Cascade

East Field is located in, only sea turtles in the project area would be considered transient,

either migrating through the area, or foraging. Shuttle vessels will be using existing

shipping lanes into existing port facilities, which will minimize potential impacts in the

richer shallow water habitats of the GoM. To minimize impacts to sea turtles, PIA is

implementing the following measures:

 No facilities are located in known nesting/hatching locations;

 Shuttle vessels will use existing commercial shipping lanes near shore;

 Floating Sargassum out at sea will be avoided;

 No explosives are part of proposed project activities;

 Because spilled oil, chemical dispersants, and spill-response activities may

adversely affect sea turtles or their reproductive success, PAI will conduct visual

surveys and contain spilled oil;

 Shuttle vessels will adhere to NMFS Regional Viewing guidelines while in transit

and vessel operators will undergo training on applicable guidelines to avoid strike

impacts; and

 PAI prohibits discharging trash and other debris at sea as it could ensnare or be

consumed by sea turtles thus injuring or killing them.
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c11. Coastal Habitats

The project is located over 180 miles (290 km) from the nearest coastline, which is

Louisiana. Lengthy spill travel times and large dilution factor into the significant

dispersion of an accidental spill prior to reaching a coastline from the proposed Cascade

East wells. As required under NTL 2010 N-06, PAI has completed worst case oil spill

discharge evaluation. (see Appendix 6).

No new navigation channels would be required for this project. Primary potential

impacts to coastal habitats would be from shuttle vessel traffic and inadvertent spills

since onshore facilities are existing facilities. No onshore, or near shore, construction

activities are part of the proposed Cascade East Field drilling, completion and production,

therefore no impacts or mitigation measures are required. Based on the worst case

scenario modeling, an accidental spill could make landfall along the coastline. As

indicated in this section, PAI implements a series of mitigation measures to minimize

potential impacts to both onshore and offshore environments. In addition to field

development, discharges from shuttle vessels en route to Texas, Louisiana, and

Mississippi could also potentially impact coastal habitat. Shuttle traffic associated with

the project would not significantly increase the volume of traffic into existing ports and

anticipated impacts would be similar to existing commercial tanker and other vessel

traffic.

Sensitive coastal habitats include beaches and dunes and barrier islands. A large scale

inadvertent oil release at the well site would take 30 days to travel to beaches and islands

as per oil spill risk analysis undertaken for the FPSO (USDOI 2008). These areas of

natural resources and the protection of them are extremely important to PAI and

mitigation measures would include monitoring and installation of containment booms.

As per MMS 2008, a study in Texas showed oil spilled on sand and vegetated dunes had

little deleterious effects on existing vegetation (Webb 1988). Spilled oil beyond 0.025

gallon/ft2(1.0liter/m2) of marsh was found to cause vegetation death and therefore land

loss. Additionally, impacts from oil spill clean-up activities could result in short-term (up

to two years) adjustments to beach profiles and configurations (USDOI 2008). In light of

the tragic events surrounding the Deepwater Horizon incident, spill and clean up

activities, it is suspected that the potential long term effects will be studied for years to

come.

Coastal wetlands, particularly in Louisiana, already are greatly impacted by sediment

deficiencies, sea level rise, and subsidence and are further damaged by recent hurricanes.

Deterioration of coastal wetlands is a serious concern at local, state and federal levels.

Distance from the well site to the closest Louisiana coastal marshes is 180 miles (290

km), thus providing significant time and opportunity for response, adequate control of an

inadvertent spill, and implementation of suitable mitigation measures.

Seagrass beds, another sensitive coastal habitat are located behind barrier islands.

Therefore, likelihood of impact from an inadvertent oil spill is low. Nonetheless, as

demonstrated during the Deepwater Horizon accident, these sensitive resources are
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susceptible to impacts. Specific mitigation measures that PAI would implement include

avoidance through use of containment booms and dispersants before oil reaches shore

and any seagrass beds.

The following mitigation measures would be implemented to minimize potential impacts

from shuttle vessel traffic or inadvertent spills:

 Constant monitoring of site activities to identify a potential problem so that it can

be addressed early;

 To reduce shuttle vessel traffic effects, recommend of reduced speeds in vicinity

of barrier islands; and

 In the case of an inadvertent spill, minimize spill clean-up impacts with low

impact response technologies, i.e. low-pressure flushing, containment booms,

bioremediation, burning, open water dispersants as applicable (Mendelssohn and

Lin 2003, Hoff 1995, Proffitt 1998) and specified in PAI’s Oil Spill Response

Plan.

c12. Areas of Special Concern

Areas of Special Concern include marine protected areas. The proposed project is not

located in or near a marine protected area. However, the GoM is considered an area of

special concern. As such, a principal impacting factor would be a significant inadvertent

spill. Fate of hydrocarbons in the GoM is largely uncertain (Ramseur 2010) following

BP’s Deepwater Horizon oil spill of 200 million gallons (4.9 million barrels) of crude

oil. According to a Congressional Research study, the fate of spilled oil was as follows:

human intervention (direct recovery 17%; in-situ burning 5%; skimming 3%; chemical

dispersal 16%), natural processes (natural dispersal 13%; evaporated or dissolved 24%),

and other 22% remaining in the water column, settling to the seafloor, mixing with

sediments, ingested by microbes, or collected during shore clean-up activities. Oiled

shorelines (classified as light, moderate, or heavily oiled) were estimated to extent

approximately 700 miles in Louisiana, Mississippi, Alabama, and Florida. According to

studies following the 1979 Ixtoc oil spill, approximately 25% of that oil settled on the

bottom of the GoM. This is consistent with the preliminary information developed

following the Deepwater Horizon oil spill (Ramseur 2010). The primary mitigation

measure that PAI will implement will be avoidance of situations that could lead to

inadvertent spills. In the event that a spill does occur, PAI will use the following

industry wide recognized site-specific mitigation measures, as appropriate, to address

inadvertent spills:

 Monitoring;

 Response teams and equipment in place prior to an incident;

 Rapid response of OSROs;

 Direct recovery;

 In-situ burning;
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 Dispersants; and

 Drilling a relief well.

Based on the successful completion of other wells within the nearby Cascade and

Chinook Fields, PAI would maintain that the risk of a significant oil spill is low.

c13. Tourism and Recreation

The GoM supports diverse and valuable commercial and recreational fisheries; beaches,

wetlands and barrier island natural resources that support local and state-wide tourism

economics and recreational opportunities for the public.

Primary concern to tourism and recreation is effects from inadvertent spill that could

cause 1) change in fish distribution and abundance; 2) reduced catches of finfish and

shellfish; 3) inability to access fishing areas; 4) loss/damage to fishing equipment; 5)

reduced market value of a fishery, i.e. public perception of contamination; and 6) beach

damage (real or perceived). Mitigation would include measures indicated in c12 above

and public education program.

c14. Shipping and Transportation

No port modifications are required as part of the proposed project. PAI will be using

existing ports that currently accommodate commercial traffic and no additional facilities

or facility expansions are required for this project. Shuttle vessels would use existing

shipping lanes and no modifications to shipping would be required. Therefore, no

mitigation is required.
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13 Decomissioning Information

Per NTL 2008-G04, decommissioning information is not required for DOCDs in the

BOEM GoM region.
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14 Related Facilities and Operations Information

14(a) Related OCS Facilities and Operations

This section provides an overview of the drilling unit, topside, subsea facilities, and

pipelines. Section 2(e) describes any applicable technologies that would be used during

Phase II which are considered new or unusual to the GoM in more detail. Section 1(f)

describes the most important safety and pollution prevention features of the facilities

covered by this supplemental DOCD.

No new technology is proposed in this supplement however; the Conceptual Plan and the

Initial DOCD, both previously approved by the BOEM identified six components of the

Phase I development plan that are considered technologies new to the GoM. These six

components were addressed extensively in the Initial DOCD as well as the DWOP.

BOEM Technical Assessment and Operations Support (TAOS) Section reviewed and

approved the safety and reliability of the technologies new to the GoM in the approved

DWOP (ref. Appendix 1a). There are no significant changes to the information

previously submitted regarding new or unusual technologies and the information remains

accurate and consistent.

The most important safety and pollution prevention features that will be used to mitigate

hazards related to technologies new to the GoM are described in Section 1(f).

Drilling Rigs

Phase I included the drilling and completion of three new wells. Two of these Phase I

wells have been drilled and completed, one in the Cascade Field and one in the Chinook

Field. The second well in the Cascade Field is currently being drilled as part of Phase I.

Phase II includes drilling and completion of the remaining wells in Cascade being the

subject of this SDOCD.

Cascade WR 206 Wells No. 6 and 7 will be directionally drilled from Drill Center 1,

cased, and completed with multi-zone frac-pacs. PAI and its vendors have successfully

run a Single Trip, Multi-Zone (STMZ) Frac Pack assembly in the first two wells, and this

is also new technology in the DW GoM. Although there are some well engineering

challenges due to reservoir characteristics, the majority of the well engineering utilizes

proven practices.

Primary Rig

The “Deep Ocean Mendocino” (Mendocino) is scheduled to drill the next two Cascade

wells WR 206 Well No. 6 and 7 upon completion of Cascade Well No. 5. It is a new

build (2011) drill ship from Samsung in Korea, and is equipped with lifesaving

equipment to accommodate 200 personnel and has gas, fire, and smoke detection

systems, which are monitored on a 24-hour manned basis. The rig has fixed fire fighting

equipment including carbon dioxide foam flooding. The rig has a sump system to catch
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all deck drainage. Rig personnel will follow PAI and Mendocino (Contractor) offshore

HSE policies. Safety features include well control, pollution prevention, welding

procedures, and blowout prevention equipment as described in 30 CFR 250, including

NTL-06, as incorporated in the CFR’s. The drilling rig will comply with all BOEM,

USCG, and EPA requirements for operating in the GoM. See Figure 14-1 to see an artist

rendition of the “Mendocino”.

Figure 14-1 – Deep Ocean “Mendocino”

Optional Rig

The Vantage “Dragon Quest” (Dragon Quest) could potentially drill the Cascade WR 206

Wells No. 6 and 7, if the operations window and exact timing does not permit the

Mendocino to begin first. The Dragon Quest, which will be on site at the Chinook Field,

is a Daewoo new build (2011) drill ship, capable of operating in 12,000’ of water depth,

and up to 40,000’. PAI has made a long term commitment to the GoM projects by

contracting one the largest capacity drillships in the world. The Dragon Quest is

equipped with lifesaving equipment to accommodate up to 180 personnel and has gas,

fire and smoke detection systems, which are monitored on a 24-hour manned basis. The

rig has fixed fire fighting equipment including a CO2 foam flooding. The rig has a sump
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system to catch all deck drainage. Rig personnel will follow PAI and Vantage

(Contractor) HSE policies, and a bridging document will be written for the rig. Safety

features include well control, pollution prevention, welding procedures, and blowout

prevention equipment as described in 30 CFR 250, including NTL-06 as incorporated in

the CFR’s. The drilling rig will comply with all BOEM, USCG, and EPA requirements

for operating in the GoM. See Figure 14-2 to see the Vantage “Dragon Quest”.

Figure 14-2 – Vantage “Dragon Quest”

Subsea Facilities and Pipelines / Risers

Subsea facilities were installed during Phase I of the development plan including drill

centers at Cascade and Chinook. With the exception of the FSHRs and subsea booster

pumps, the Cascade and Chinook subsea facilities use field proven designs that have been

extensively used in deepwater projects in the GoM. The FSHRs and subsea booster

pumps are discussed in greater detail in Section 2(e) as they were considered technology

new to the GoM by BOEM. See Figure 1-2 to review a conceptual representation of the

subsea facilities and associated pipelines and risers. Figure 14-3 provides an illustration

which summarizes the subsea facilities and associated pipelines and risers. See Figure 1-

3 to review the Field Layout.
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Figure 14-3 – Illustration of Subsea Facilities Layout

Cascade consists of one drill center in Cascade East located in WR Block 249. The

Cascade drill center is in approximately 8,200 feet of water. The Chinook drill center is

in approximately 8,800 feet of water.

Production from all Cascade wells will be gathered into a 4 slot manifold and transported

via 7” flowlines and two production FSHRs. Production from Cascade is enhanced by 2

skid mounted booster pumps which are located downstream of the Cascade gathering

manifold. Each pump is capable of boosting 20,000 bpd for a total of 40,000 bpd. Dual

flowlines will allow for round trip pigging. The Cascade production flowlines are wet

insulated for flow assurance considerations. Cascade will utilize PLETs and jumpers for

subsea connectivity. Cascade will be powered and controlled by one power umbilical

and one control umbilical (with flying leads) originating from the FPSO. See Figure 14-4

Cascade Drill Center.

FPSO

Boosting Station

4-Slot Manifold

Production Well

Production FSHR

Gas Export FSHR

Approx 11.5 Mi.

Approx 2 Mi. Approx 1.3 Mi.

Gas Export Line

Cascade East DC

WR Block 206

X = 2,458,390.33’

Y = 9,712,448.4’

WD approx. 8,160’

FPSO

WR Block 249

X = 2,453,797.74’

Y = 9,695,007.17’

WD approx. 8,200’

Chinook DC

WR Block 425

X = 2,447,000.00’

Y = 9,632,800.00’

WD approx. 8,800’

Infield Flowlines
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Figure 14-4 – Cascade Drill Center
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The FPSO is double hulled with segregated cargo and ballast tanks. The FPSO has a

cargo tank capacity of 600,000 – 850,000 barrels.

The FPSO has a single point mooring (SPM) system which allows for full passive

weathervaning. The SPM has a disconnectable feature which allows her to disconnect

and motor away from named storms and hurricanes under her own power, returning for

re-connection when it is safe to do so.

The FPSO was designed to remain on station for 1.) a 100 year return winter storm with a

1 year return loop current or 2.) a 100 year return loop current with a 1 year return winter

storm. The FPSO will disconnect for named storms and hurricanes, with no hydrocarbon

release to the environment. After disconnection, the turret buoy (which is attached to the

mooring lines and FSHRs) will be left behind in a submerged condition out of harms way

of the environment conditions at the surface. See Figure 1-2 for a conceptual

representation of the FPSO connected to the seafloor facilities.

Table 14-1 describes the design capacities of that the FPSO will be able to accommodate:

Table 14-1 – FPSO Topsides Design Parameters

Capacity Minimum Maximum

Oil 3,000 bpd 80,000 bpd

Produced Water 0 bpd 16,000 bpd

Total Fluids 3,000 bpd 80,000 bpd

Gas 16 MMscfd 16 MMscfd

In accordance with 30 CFR 250 Subparts H and J and the approved DWOP, the flowline /

pipeline boarding shut down valve(s) (BSDV) will close within 45 seconds of the

activation of any sensor due to any undesirable event or emergency shut-down (ESD).

The FPSO complies with all requirements for continuous operation throughout Phase II

without the need to be dry-docked in a shipyard.

The FPSO is discussed in greater detail in the Initial DOCD and DWOP as it was

considered technology new to the GoM by BOEM at that time.

14(b) Transportation System

The development plan utilizes a 6-inch gas export pipeline to transport gas (maximum of

16 MMscfd) which is not consumed on the FPSO to the existing Discovery gas pipeline

system, Operations System 34.5/DSO, which in turn terminates onshore in Larose,

Louisiana.
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14(c) Produced Liquid Hydrocarbon Transportation Vessels

The development plan calls for utilization of dedicated Shuttle Vessels to transport

produced oil to market. Shuttle Vessels will Jones Act and OPA90 compliant tankers.

The capacity of each Shuttle Vessel is approximately 330,000 bbls.

PAI will likely utilize one Shuttle Vessel to perform one offloading every two weeks in

the first year of production operations (i.e. during production ramp-up). PAI will likely

utilize two Shuttle Vessels (on a staggered schedule) to perform one offloading every

week in subsequent years of production operations for Phase II. The frequency of

offloading will evolve over time as the frequency is driven by the size / speed / number of

the Shuttle Vessels relative to the production profile of the reservoirs. Offloading from

the FPSO to the Shuttle Vessel will take approximately 24 hours. See Table 14-2.

Table 14-2 – Shuttle Vessel Transportation Information

Transport

Method

Shuttle Vessel

Capacity (barrels)

Average Volume to be

Loaded (barrels per

offloading)

Anticipated FPSO

Offloading per Year

One Shuttle

Vessel (Year 1) 185,000 - 330,000 185,000 – 330,000 26

Two Shuttle

Vessels (Years 2

through end of

Phase II)

185,000 - 330,000 185,000 – 330,000 52

During offloading, Shuttle Vessels will be connected to the FPSO via a hawser system

(i.e. mooring line) and offloading hose between the bow of the Shuttle Vessel and the

stern of the FPSO in a tandem offloading configuration. The Shuttle Tanker will

weathervane in a similar manner as the FPSO (i.e. both vessels will react to the

environmental conditions as one “system”). A dedicated field support tug will be utilized

to support offloading.

Shuttle Vessels will transport produced oil to the terminals of choice along the GoM

coast, potentially including terminals in Texas, Louisiana, and Mississippi. PAI has not

yet determined which specific terminals will be used.

PAI is currently evaluating which terminals may be used based on the following

considerations:

 quality of produced oil relative to the processing capability of terminals (1)

 vessel size limitations (1)

 terminal capacities (2)

 commercial (2)
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Notes:

(1) assessment made by PAI during the planning phase

(2) assessment made by PAI just prior to each offloading

There will not be a need to expand or modify any terminals to accommodate

transportation of oil to market via Shuttle Vessels. Figure 14-5 provides the locations of

the terminals that PAI is considering.
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Figure 14- 5 Potential Terminals under Consideration
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15 Support Vessels and Aircraft Information

15(a) General

Table 15-1 provides an overview of the equipment that PAI anticipates using for

drilling and completion operations during Phase II of the development plan. PAI

anticipates approximately 18 months of drilling and completion operations during Phase II.

Support vessels include crew boats and service vessels.

Table 15-1 – Support Equipment (Drilling and Completions Operations)

Type

Maximum Fuel

Tank Storage

Capacity (barrels)

Maximum Number

in Area at Any Time

Trip Frequency

or Duration

Drilling Rig (DP) 34,500 1 18 months

Crew Boat / Fast Supply

Vessel (FSV)

800 2 3 round trips per week

Offshore Service Vessel

(PSV)

8,900 3 2 round trips per week

Helicopter 22 1 1 round trip per day

Table 15-2 provides an overview of the equipment that PAI anticipates using for

FPSO production operations during Phase II of the development plan. PAI anticipates 6-

8 years of production operations during Phase II.

Table 15-2 - Support Equipment (FPSO Production Operations)

Type Maximum Fuel

Tank Storage

Capacity (barrels)

Maximum Number

in Area at Any Time

Trip Frequency

or Duration

Crew Boat / Fast Supply

Vessel (2)

550 2 3 round trips/week (2)

Offshore Service Vessel (2) 8,900 3 2 round trips/week (2)

Field Service Tug (1) 8,900 1 100% in field (1)

Helicopter (3) 22 1 2 round trips per day (3)

(1) Offloading and general marine support

(2) PSV’s and FSV’s will be shared between the FPSO and drilling

(3) Helicopter will be shared between the FPSO and drilling. However, the FPSO will have 2 round trips

per day

15(b) Diesel Oil Supply Vessels

Table 15-3 provides an overview of the diesel oil supply vessels PAI anticipates using for

drilling / completion operations and FPSO production operations.
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Table 15-3 – Diesel Oil Supply Vessels

Size of Fuel

Supply Vessel

Capacity of

Fuel Supply Vessel

(barrels)

Frequency of

Fuel Transfers

Route Fuel Supply

Vessel Would Take

280’ Class Offshore

Service Vessel (1, 2, 3)

8,900 2 round trips per week Port Fourchon to

Cascade / Chinook Units

and return

280’ Class Offshore

Service Vessel (1, 2, 3)

8,900 2 round trips per week Port Fourchon to

Cascade / Chinook Units

and return

280’ Class Offshore

Service Vessel (1, 2, 3)

8,900 2 round trips per week Port Fourchon to

Cascade / Chinook Units

and return

(1) Supports Drilling and Completion operations for approximately 18 months

(2) Supports FPSO Production Operations for 6-8 years

(3) Supports diesel oil supply. Also brings other supplies to the drilling and FPSO operations area.

15(c) Drilling Fluids Transportation

Florida is not an Affected State for Phase II of the development plan. Per NTL 2008-

G04, information regarding drilling fluids transportation is not required in this DOCD.

15(d) Solid and Liquid Wastes Transportation

Appendix 7-C provides an overview of the projected generated waste types, their

composition, and transportation methods PAI anticipates will be used for anticipated

amounts of solid and liquid wastes associated with drilling and completions operations.

Applicable onshore facilities per waste type for disposal is also provided in Appendix 7-

C. PAI anticipates approximately eighteen months of drilling and completion operations

during Phase II.

Appendix 7-D provides an overview of the projected generated waste types, their

composition, and transportation methods PAI anticipates will be used to transport the

anticipated amounts of solid and liquid wastes associated with FPSO production

operations to onshore facilities for disposal. Applicable onshore disposal facilities are

also identified for FPSO wastes in Appendix 7-D. PAI anticipates approximately 6-8

years of FPSO production operations during Phase II.

15(e) Vicinity Map

Figure 15-1 shows the location of the Phase II facilities at the Cascade and Chinook

Fields, the distance of the proposed Cascade activities from the shoreline, and the

primary transportation route(s) of the support vessels and aircraft that would be used

when traveling between the primary and secondary onshore service bases and the FPSO.
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Figure 15-1 – Vicinity Map
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16 Onshore Support Facilities Information

16(a) General

PAI proposes to use onshore support facilities located in Port Fourchon, Louisiana to

support Phase II of the development plan. The name of the facilities are identified in

Table 16-1. These are existing facilities.

Table 16-1 – Onshore Support Facilities

Name Location Existing, New, or Modified

C-Port 2, Slips 5 & 6 Port Fourchon, LA Existing

ERA Port Fourchon, LA Existing

The marine shorebase is equipped with facilities related to warehouse and outside storage

spaces, material handling equipment, marine vessel dock space, fuel storage and

bunkering, water storage and bunkering, drilling fluids storage and bunkering,

communications, security, offices, and vehicle parking lot.

The aviation facilities are equipped with a helipad, office space, waiting room, and

vehicle parking lot.

PAI anticipates that secondary onshore support facilities in Texas and Louisiana may be

used on occasion due to specific conditions such as weather, market availability of

marine vessels or helicopters, security, and / or safety.

16(b) Support Base Construction or Expansion

PAI will utilize an existing onshore support base with adequate facilities to support

operational needs for Phase II of the development plan. No base construction or

expansions will be required.

16(c) Support Base Construction or Expansion Timetable

Per 16(b), no construction or expansion activities will be performed for Phase II of the

development plan.

16(d) Waste Disposal

Appendix 7-C depicts the onshore facilities that PAI anticipates using to dispose of solid

and liquid wastes associated with drilling and completion operations during Phase II of

the development plan. Appendix 7-D also depicts the onshore facilities that PAI

anticipates utilizing to dispose of solid and liquid wastes associated with FPSO

production operations during Phase II of the development plan.
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16(e) Air Emissions

Per NTL 2008-G04, information regarding air emissions generated by onshore support

facilities is not required for DOCDs submitted in the BOEM GoM region.

16(f) Unusual Solid and Liquid Wastes

Per NTL 2008-G04, information regarding unusual solid and liquid wastes generated by

onshore support facilities is not required for DOCDs submitted in the BOEM GoM

region.
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17 Sulfur Operations Information

No sulfur operations are proposed as part of the Phase II (or future phases) of the

development plan.
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18 Coastal Zone Management Act (CZMA) Information

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Louisiana Coastal Resources Program

In 1978, the Coastal Management Division (CMD) of the Louisiana Department of Natural

Resources implemented the Louisiana Coastal Resources Program (LCRP) under authority of

the State and Local Coastal Resources Management Act, as amended (Act 361, Louisiana

Revised Statute Title 49 Section 214). The law provides for the review of federally permitted

actions that could potentially impact Louisiana’s coastal resources. The intent of the LCRP

is to protect, develop, and where feasible, restore or enhance the resources of the state’s

coastal zone. The LCRP encourages multiple uses of resources and adequate economic

growth in order to reduce adverse effects of one resource upon another. Program regulations

can be found in Louisiana Administrative Code, Title 43 Part I Chapter 7.

As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes

to develop two wells, WR 206 No.6 and 7 with one jumper connector per well in the Cascade

deep water field. The Cascade Field and the associated Chinook Field developments were

previously addressed in a common DOCD submittal with an accompanying coastal

consistency certificate in June 2007. At that time, the Floating Production, Storage and

Offloading (FPSO) facility was addressed. Specific details related to the proposed offshore

development activities associated now with two additional wells and jumper connectors can

be found in Section 1. This supplemental DOCD specifically addresses project activities in

the Cascade East Development.

The project is located in the Central Planning Area of the Gulf of Mexico in Walker Ridge

Block 206 approximately 165 miles from the coast of Louisiana as shown in Figure 1-1.

Because of its location in the Central Planning Area, Louisiana is considered to be an

“affected state” and the state’s review and concurrence is required to ensure that the proposed

activities are consistent with the enforceable policies of the LCRP.

The Cascade / Chinook Development, including the drilling, completion and production of

the proposed WR 206 Wells No.6 and 7 will include the use of existing onshore support

facilities at Port Fourchon for marine vessel support and disposal of wastes (see Figure 15-8).

Port Fourchon will serve as the port of debarkation for equipment, supplies, and crews for

drilling / completion operations, development activities, and production operations. No new

construction or expansion of Port Fourchon’s facilities will be necessary. No new dredging

or changes to Louisiana’s coastal areas or shipping channels would be needed. Refer to

Section 16 for additional details. The following is a list of shore-based facilities in Louisiana

that would be used for the projected wastes associated with the Cascade East Development

WR 206 Wells No. 6 and 7:

 US Liquids of Louisiana, Newpark Services, and / or CCT located in Fourchon.

These contractors will accept environmental wastes such as cutting boxes, solid

wastes from the marine portable tanks, and tank clearing fluids.
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 Solid Waste Disposal or Galiano Waste located in Fourchon. These contractors will

accept the disposal of domestic wastes.

 L&L located in Fourchon. This contractor will accept waste oils.

As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the produced oil to

market to terminals along the coast of the GoM. After the initial production ramp-up in the

first year of operations, PAI anticipates an offloading frequency of once per week during sixeight years of production operations for Phase II of the development plan. PAI has not yet

determined which specific terminals will be used. However, PAI anticipates using several

refineries located in Louisiana (see Figure 14-8). The specific refineries to be utilized will

depend on several factors including market conditions and available terminal capacities. The

Louisiana refineries that could potentially be used are shown below. This list includes the

ranking of each refinery in Louisiana compared to all US refineries relative to their daily

crude operating capacity as of January 2008 (Energy Information Administration 2011).

Lake Charles

 Citgo Petroleum, Lake Charles (#4)

 ConocoPhillips, Westlake (#22)

 Calcasieu Refining, Lake Charles (#110)

Baton Rouge

 ExxonMobil, Baton Rouge (#2)

 Motiva Enterprises, Convent (#25)

 Placid Refining, Port Allen (#94)

Lower Mississippi River

 ConocoPhillips, Belle Chasse (#18)

 Marathon Petroleum, Garyville (#20)

 Motiva Enterprises, Norco (#27)

 Chalmette Refining, Chalmette (#34)

 Valero Refining, Norco (#35)

 Murphy Oil, Meraux (#56)

 Shell, Saint Rose (#96)

Louisiana Offshore Oil Port (LOOP)

 The LOOP eventually connects to pipelines that can transport crude oil to 35% of

the total US refining capacity.
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No new construction or expansion of these terminals will be necessary. No new dredging or

changes to Louisiana’s shipping channels will be needed.

PAI has evaluated the anticipated activities related to the proposed wells and their associated

jumper connectors to determine if there would be any reasonably foreseeable coastal effects

on the land, water uses, or natural resources of the coastal zone of Louisiana, pursuant to the

enforceable policies of the state’s LCRP. Specific policies that address the potential

environmental impacts to coastal uses, such as waste disposal, accidental spills, and

nearshore water quality, are briefly described in Table 18-1 with relevant cross references to

this supplemental DOCD where further details are provided. The analysis upon which this

effects determination has been made is provided in Section 19.

Table 18-1 – Consistency Review Summary

Policy Effects Analysis Cross References

Guidelines Applicable to All Uses

Policy 1.2 –

Conformance with

applicable air and

water quality laws

 The project site will be located at least 165 miles

from the Louisiana coast.

 The air emissions analysis shows that the project

will not exceed emission thresholds established

by BOEM. The project will not affect air

resources in Louisiana.

 No air or water quality impacts will occur

because of the use of existing support base and

refineries that are located at established ports.

Wastes will be properly contained, transported,

and disposed in designated waste facilities.

 The project will comply with all requirements

including the US Environmental Protection

Agency (EPA) National Pollutant Discharge

Elimination System (NPDES) general permit for

offshore discharges and US Coast Guard (USCG)

regulations for vessels operating in state waters.

The project would not affect water quality in

Louisiana.

 The use of a gas export pipeline at the beginning

of production would provide a positive

environmental effect because no flaring would

occur during normal production operations.

Short term flaring (several days per well) would

likely occur during the well testing phase but this

would not affect near shore resources.

Section 7, Appendix

7_A, B, C and D

Projected Generated

Discharged and

Trasported Wastes

Section 8, Air

Emissions

Appendix 3, Air

Emission

Worksheets

Sections 19(b),

Existing Resource

Conditions and 19(c),

Project Impacts
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Policy Effects Analysis Cross References

Policy 1.6 - General

factors that will be

utilized by the

permitting authority

 No state permits are required for the project.

 The FPSO will be able to disconnect from its

mooring and motor away from a hurricane or

named storm, which will prevent storm related

damages or accidents and reduce the potential

for impacts to coastal resources.

 The direct and indirect expenditures of the

project will have a minor and temporary positive

impact on the economic activities around the

support facilities at Port Fourchon, which would

provide direct private benefits.

 The project area is not located in or near nor

would have any impacts on historical or

recreational sites, or protected / sensitive areas.

 No impacts to state fisheries are likely due to the

distance from shore and the use of existing

transportation and shore based infrastructure.

Sections 1(a),

Introduction; 1(c),

Safety and Pollution

Prevention Features;

and 1(f), Additional

Safety and Pollution

Prevention Features

Section 2(e), New or

Unusual Technology

Sections 19(b),

Existing Resource

Conditions and 19(c),

Project Impacts

Policy 1.7 - Adverse

effects from land and

water uses in the

coastal areas

 All of the wastes generated from the proposed

development will be either (1) discharged

overboard in compliance with NPDES

requirements or (2) transported to shore for

disposal in permitted or licensed commercial

facilities or for recycling. All wastes brought to

shore will be properly disposed so there would be

no effects to the coastal area.

 Minor, localized impacts to federal OCS waters

near the project site will occur during the life of

the project as a result of the proposed discharges

from drilling and production activities but the

effects are expected to be minimal because the

project will comply with NPDES requirements.

There will be no effects to the coastal area.

 Insignificant impacts related to the burial of

soft-bottom benthic communities are expected

from the discharge of drill cuttings. There will

be no effects to the nearshore coastal areas.

 Short term turbidity will result from bottom

disturbances caused by placement of two wells

and two jumper connectors. There will be no

effects to land and water uses in the coastal

area.

 No impacts on chemosynthetic fauna are

expected because chemosynthetic communities

or hard-ground substrates are not present.

 No federal or state listed species are known to

occur in proximity to the proposed well sites.

 This project would have no effects on minority or

low income populations in Louisiana.

Section 6(a),

Chemosynthetic

Communities

Section 7, Projected

Wastes

Section 9(a), Oil Spill

Response Planning

Section 16(a)

Onshore Support

Facilities

Section 19(c),

Project Impacts
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Policy Effects Analysis Cross References

Policy 1.9 –

Permitting multiple

uses to avoid

conflicts

There will be no conflicts with other users because

existing shore based and transportation infrastructure

will be used.

Section 15, Support

Vessels and Aircraft

Information

Section 16(a),

Onshore Support

Facilities

Guidelines for Linear Facilities (Policies 3.1 through 3.16) – The project does not involve the

construction of linear facilities in or near the coastal zone. The gas export pipeline will tie into an

existing facility located on either Green Canyon Block 829 (Option 1) or Green Canyon Block 606

(Option 2; See Section 6(a), Chemosynthetic Communities Report).

Guidelines for Dredged Spoil Deposition (Policies 4.1 through 4.7) - This project does not involve any

expansion of facilities or new dredging (See Section 16, Onshore Support Facilities Information).

Guidelines for Surface Alterations (Policy 6.1) – The project will use only existing shore based support

and waste disposal facilities and will not involve any surface alterations (See Section 15(d), Solid and

Liquid Wastes Transportation and Section 16, Onshore Support Facilities Information).

Guidelines for Hydrologic and Sediment Transport Modifications (Policies 7.1, sediment diversions; 7.3,

deposition of sediments; and 7.9, water withdrawal) – The project will use desalination units to

generate the needed freshwater at the project site (See Section 7, Waste and Discharge Information).

Guidelines for Disposal of Waste

Policy Effects Analysis Cross References

Policy 8.1 - Location

and operation of

waste storage,

treatment, and

disposal facilities

 Solid waste generated by the development

activities will be bagged and kept onboard the

FPSO and drilling rig, then transported via supply

boat to a designated contractor in Louisiana for

proper disposal in Port Fourchon.

 Sanitary wastes on each of the vessels will be

treated by a Marine Sanitation Device and

discharged overboard in accordance with USCG

regulations.

 Other waste streams from the FPSO and drilling

rig will be discharged overboard in accordance

with the NPDES general permit.

 Trash and debris and other waste products will

be brought to a designated contractor in

Louisiana for proper disposal.

 Other wastes consisting of waste oil will be

stored in barrels, transported to shore, and then

disposed of by a designated contractor in

Louisiana.

Section 7(a),

Appendix 7- A-D

Projected Wastes

Section 15(d), Solid

and Liquid Wastes

Transportation

Section 16, Onshore

Support Facilities

Information

Policy 8.1 –

Generation,

transportation,

treatment, storage,

and disposal of

hazardous waste

Only oil field wastes would be generated as a result of

this project and these would be disposed in an

authorized waste facility.

Section 7, Appendix

7- A-D

Waste and Discharge

Information

Section 15, Support

Vessels and Aircraft

Information

Section 16(d), Waste

Disposal Facilities
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Policy Effects Analysis Cross References

Policy 8.8 - Approved

disposal sites

No unusual solid or liquid wastes will be generated or

disposed. Only existing and approved onshore waste

disposal facilities would be used. No air or water

quality impacts would occur as a result.

Section 7(a),

Appendix 7- A-D

Projected Generated

Wastes

Section 15, Support

Vessels and Aircraft

Information

Section 16, Onshore

Support Facilities

Information

Policy 8.9 –

Radioactive Wastes

Only oil field wastes will be generated as a result of

this project and these will be disposed in an

authorized waste facility.

Section 7,

Appendix 7- A-D

Waste and Discharge

Information

Section 16(d), Waste

Disposal Facilities

Guidelines for Uses that Result in the Alteration of Waters Draining into Coastal Waters (Policy 9.2) -

The project will not result in any increase in developed area runoff (See Section 16, Onshore Support

Facilities Information).

Guidelines for Oil, Gas and other Mineral Activities

Policy Effects Analysis Cross References

Policy 10.3 - Siting of

exploration,

production and

refining activities

Production or refining activities will not be located in

areas containing critical wildlife or vegetation.

Sections 19(b).4,

Coastal Environments

Policy 10.5 - Access

to site

 Access routes to production and refining sites will

not affect critical wildlife and vegetation areas.

 Based on surveys conducted, there was no

detection of chemosynthetic features or hard

substrate at the proposed well locations.

Section 14, Related

Facilities and

Operations

Information, and

Figure 14-8, Gulf

Coast Refineries

Considered for

Receipt of Crude Oil

Appendix 2b, GEMS

Shallow Hazards

Report for Facilities

Policy 10.6 - Best

practical techniques

for drilling and

production sites

The estimated volume of drilling muds and cuttings

generated will be discharged according to NPDES

permit limitations and will therefore not release

pollutants or toxic substances into the environment.

Section 2(b), Drilling

Fluids
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Guidelines Applicable to All Uses

Policy Effects Analysis Cross References

Policy 10.10 -

Guidelines for drilling

and production

equipment for

preventing adverse

environmental effects

 Placement of jumper connectors on the seafloor will

cause minor, short term turbidity and will have no

effect to coastal resources. The proposed wells

would have no effect to coastal resources.

 There is no additional oil spill risk resulting from

bringing the crude product to shore. The various

terminals will likely operate at capacity whether or

not this proposed project is approved. If the shuttle

vessels proposed for this development are not used,

it is anticipated that some other tanker, likely

carrying foreign supplied oil, will be used in its

place.

 PAI would use a dedicated field tug, which will

enhance safety and pollution response during

offloading and other operational activities.

Sections 1(a), Safety

and Pollution

Prevention Measures

and 1(f), Additional

Safety and Pollution

Prevention Measures

Section 2(e), New or

Unusual Technology

Section 9(a), Oil Spill

Response Planning

Section 19(c), Project

Impacts and

Section 1(e) Pollution

Prevention Measures

Policy 10.11 - Effective

environmental

protection and

emergency or

contingency plans

 A dedicated field tug will help prevent collisions or

accidents during offloading operations and other

operational activities.

 A hurricane avoidance plan has been developed for

the FPSO.

 Oil Spill Emergency Response Plans were developed

for the FPSO and Shuttle Vessels.

 Existing procedures such as the use of radar, watch

standing, and other communication efforts will

minimize the chance of collisions with other vessels.

 The FPSO has an emergency shutdown system that

will handle any extreme process conditions or

hazardous situations such as fire and gas cloud

formation.

 PAI is a member of Clean Gulf Associates (CGA) and

Clean Caribbean and Americas (CCA). PAI’s primary

spill response equipment is provided by CGA. PAI

also has access to secondary spill response

equipment from CCA.

 PAI will contract MWCC to provide well blowout

response equipment under a non-member well by

well basis.

Sections 1(e), Pollution

Prevention Measures

and 1(f), Additional

Safety and Pollution

Prevention Measures

Section 2(e), New or

Unusual Technology

Sections 9(a), Oil Spill

Response Planning and

9(b), Oil Spill Response

Discussion

Section 10,

Environmental

Monitoring

The activities proposed in this SDOCD are consistent with the previously approved Cascade /

Chinook Development Plan and are supported by sufficient data and information concerning

the potential impacts associated with drilling, completing and producing additional wells.

The proposed activities would be conducted in accordance with all federal and state

regulations, applicable notices to lessees (NTLs), conditions in the approved permits, and

lease stipulations. PAI has therefore determined that the proposed activities associated with

this project are consistent with the Louisiana LCRP.
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Texas Coastal Management Program

The Texas Coastal Management Program (TCMP) is a comprehensive management program

for coastal land and water activities that sets policies, standards, and regulations affecting

private and public property. These policies are administered under Texas laws. The program

protects coastal resources by preventing resource destruction, promoting the benefits of

resources, and managing activities that impact resources. The TCMP is based primarily on

the Coastal Coordination Act of 1991, as amended by House Bill 3226 in 1995. Program

policies are set forth in Texas Administrative Code Title 31 Part 16 Chapters 501 – 506.

As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes

to develop two wells: WR 206 No. 6 and 7 and their associated jumper connectors, one per

well, within the Cascade deep water field. The Cascade Field and the associated Chinook

Field developments were previously addressed in a DOCD submittal and accompanying

coastal consistency certificate in June 2007. At that time, the Floating Production, Storage

and Offloading (FPSO) facility was addressed. Specific details related to the proposed

development activities can be found in Section 1. This supplemental DOCD specifically

addresses project activities in the Cascade deep water field. The project is located in the

Central Planning Area of the Gulf of Mexico on Walker Ridge Block 206 more than 285

miles from the coast of Texas as shown in Figure 1-1.

Texas is considered to be an “affected state” because some aspects of the project may use

resources in the state. This would require the state’s review and concurrence with the project

to ensure that the proposed activities are consistent with the enforceable policies of the

TCMP.

PAI may occasionally use existing facilities at the Port of Galveston as a secondary onshore

support base for equipment and supplies due to specific conditions such as weather, market

availability of marine vessels or helicopters, security, or safety (see Figure 15-8). No new

construction or expansion of facilities at the port will be required. No new dredging or

changes to coastal areas will occur.

The following is a list of shore-based waste disposal facilities in Texas that could be used for

the projected wastes associated with the WR 206 No. 6 and 7 wells:

 US Liquids of Louisiana located in Galveston and Newpark Services located in

Winnie. These contractors will accept environmental wastes such as cutting boxes,

solid wastes from the marine portable tanks, and tank clearing fluids.

 L&L located in Houston. This contractor will accept the disposal of used oil and

filters, and oil rags.

As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the produced oil to

market to terminals along the coast of the GoM. After the initial production ramp-up in the
18 Coastal Zone Management Act (CZMA) Information

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Cascade / Chinook Development Project

first year of operations, PAI anticipates an offloading frequency of once per week during sixeight years of production operations for Phase II of the development plan. PAI has not yet

determined which specific terminals will be used. However, PAI anticipates using several

refineries located in Texas (see Figure 14-8). The specific refineries to be utilized will

depend on several factors including market conditions and available terminal capacities. The

Texas refineries that could potentially be used are shown below. This list includes the

ranking of each refinery in Texas compared to all US refineries relative to their daily crude

operating capacity as of January 2008 (Energy Information Administration 2011).

Corpus Christi

 Flint Hills Resources, Corpus Christi (#11)

 Citgo Refining, Corpus Christi (#45)

 Valero Refining, Corpus Christi (#53)

Freeport

 ConocoPhillips, Sweeny (#19)

Galveston / Houston

 ExxonMobil Refining, Baytown (#1)

 BP Products, Texas City (#3)

 Deer Park Refining, Deer Park (#8)

 Lyondell Citgo Refining, Houston (#14)

 Valero Refining, Texas City (#30)

 Pasadena Refining, Pasadena, TX

 Valero Refining, Houston (#69)

 Marathon Petroleum, Texas City (#78)

Port Arthur / Beaumont

 ExxonMobil Refining, Beaumont (#6)

 Motiva Enterprises, Port Arthur (#12)

 Premcor Refining, Port Arthur (#17)

 Total Petrochemicals, Port Arthur (#26)
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PAI has evaluated the proposed activities related to the proposed wells to determine if there

would be any reasonably foreseeable coastal effects on the land, water uses, or natural

resources of the coastal zone of Texas, pursuant to the enforceable policies of the state’s

CMP. Specific policies that address the potential environmental impacts to coastal uses from

oil and gas exploration and production activities are briefly described in Table 18-2 with

relevant cross references to this supplemental DOCD. The analysis upon which this effects

determination has been made is provided in Section 19.

Table 18-2 – Consistency Review Summary

Policies Information Required Cross References

Category 2 -

Construction,

Operation and

Maintenance of Oil

and Gas Exploration

and Production

Facilities

 The project site will be located at least 285 miles

offshore the Texas coast and will use existing

shore based facilities.

 The use of a gas export pipeline at the beginning

of production will provide a positive

environmental effect because no flaring would

occur during normal production operations. Short

term flaring (several days per well) will likely

occur during the well testing phase but this

would not affect near shore resources.

Section 8, Air

Emissions

Appendix 3, Air

Emission Worksheets

Category 3 -

Discharges of

Wastewater and

Disposal of Waste

from Oil and Gas

Exploration and

Production Activities

 No water quality impacts will occur because of

the use of existing support base and terminals

that are located at established ports. Wastes

will be properly contained, transported, and

disposed in designated waste facilities.

 The project will comply with all requirements

including the EPA NPDES general permit for

offshore discharges and USCG regulations for

vessels operating in state waters. The project

will not affect water quality in Texas.

 Solid waste trash and other waste products

generated by the FPSO and the drilling rigs will

be bagged and kept onboard until transported via

supply boat to a designated contractor

(potentially as secondary onshore support

facilities in Texas could be used occasionally) for

proper disposal.

 Sanitary wastes on each of the vessels will be

treated by a Marine Sanitation Device and

discharged overboard in accordance with USCG

regulations.

 Other waste streams from the FPSO and

construction vessels will be discharged overboard

in accordance with the NPDES general permit.

Section 7, Appendix 7

A_D Waste Discharge

Information

Section 14, Related

Facilities and

Operations

Information, and

Figure 14-8, Gulf

Coast Refineries

Considered for

Receipt of Crude Oil

Section 16, Waste

Disposal Facilities

Sections 19 (c),

Project Impacts
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Policies Information Required Cross References

Category 4 –

Construction and

Operation of Solid

Waste Treatment,

Storage, and Disposal

Facilities

The project will have no effect on the construction

and operation of solid waste treatment facilities

because only existing and approved onshore waste

disposal facilities will be used. Furthermore, no

unusual solid or liquid wastes would be generated or

disposed.

Section 16, Onshore

Support Facilities

Information

Category 5 -

Prevention, Response

and Remediation of

Oil Spills

 There is no additional oil spill risk resulting from

bringing the crude product to shore. The various

refineries will likely operate at capacity whether

or not this proposed project is approved. If the

shuttle vessels proposed for this development are

not used, it is anticipated that some other

tanker, likely carrying foreign supplied oil, would

be used in its place.

 PAI will use a dedicated field tug, which would

enhance safety and pollution response during

offloading and other operational activities.

 A hurricane avoidance plan has been developed

for the FPSO.

 Vessel Shipboard Oil Pollution Emergency Plans

have been developed for the FPSO and Shuttle

Vessels.

 Existing procedures such as the use of radar,

watch standing, and other communication efforts

will minimize the chance of collisions with other

vessels.

 The FPSO has an emergency shutdown system

that will handle any extreme process conditions

or hazardous situations such as fire and gas cloud

formation.

 PAI is a member of Clean Gulf Associates (CGA)

and Clean Caribbean and Americas (CCA). PAI’s

primary spill response equipment is provided by

CGA. PAI also has access to secondary spill

response equipment from CCA.

 PAI will contract MWCC to provide well blowout

response equipment under a non-member well by

well basis.

Sections 1(c), Safety

and Pollution

Prevention Features,

and 1(f), Additional

Safety and Pollution

Prevention Features

Section 9, Oil Spill

Information

Category 6 –

Discharge of

Municipal and

Industrial Waste

Water to Coastal

Waters

No municipal or industrial waste discharges would

occur in coastal waters. Only existing designated

wastes facilities in Texas may be used.

Section 7(a),

Appendix 7- A-D

Projected Generated

Wastes

Section 15, Support

Vessels and Aircraft

Information

Section 16, Onshore

Support Facilities

Information
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Policies Information Required Cross References

Category 7 – Non

Point Source

Pollution

The project will comply with NPDES permit limitations

and will therefore not release pollutants or toxic

substances into the environment. There should be no

impact to water quality in Texas coastal waters.

Section 2(b), Drilling

Fluids

Category 8 –

Development in

Critical Areas

No development or dredging and filling will occur in or

near state waters; therefore, there will be no impact

to critical areas.

Section 1,

Introduction and Plan

Contents

Category 9 –

Construction of

Waterfront Facilities

and Other Structures

on Submerged Lands

Only existing terminal facilities in Texas will be used

and no industrial expansion is proposed to occur.

Section 1,

Introduction and Plan

Contents

Section 14, Related

Facilities and

Operations

Information

Category 10 –

Dredging and

Dredged Material

Disposal and

Placement

The project does not involve any new development or

dredging and filling in or near state waters; therefore,

there will be no effects to coastal waters, submerged

lands, critical areas, coastal shore areas, and Gulf

beaches.

Section 1,

Introduction and Plan

Contents

Category 11 –

Construction in the

Beach / Dune System

The project does not involve any construction in

critical dune areas or on Texas beaches.

Section 1,

Introduction and Plan

Contents

Category 12 –

Development in

Coastal Hazard Areas

The project does not involve any new development in

Coastal Hazard Areas.

Section 1,

Introduction and Plan

Contents

Category 13 –

Development Within

Coastal Barrier

Resource

The project does not involve the development of new

infrastructure or major repair of existing

infrastructure within or supporting development

within or near a Coastal Barrier Resource System Unit

or any other protected area.

Section 1,

Introduction and Plan

Contents

Category 14 –

Development in State

Parks, Wildlife

Management Areas or

Preserves

The project does not in involve the use of or the

taking of any public land in Texas.

Section 1,

Introduction and Plan

Contents

Category 15-

Alteration of Coastal

Historic Areas

To ensure any shallow hazards and historic sites are

identified and avoided, a shallow hazards assessment

of the seafloor at the project site was conducted. No

coastal areas would be affected by the proposed

action.

Section 19(b).14

Section 6(i),

Archeological Report

and Appendix 2b,

Shallow Hazards

Report for Facilities

Category 16 –

Transportation

Projects

The project involves the use of existing shore based

facilities and will not require new transportation

construction within the coastal zone.

Section 1,

Introduction and Plan

Contents
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Policies Information Required Cross References

Category 17-

Emission of Air

Pollutants

 The air emissions analysis shows that the project

will not exceed emission thresholds established

by EPA/BOEM. The project would not affect air

resources in Texas.

 No increase in air quality effects are expected

because there would be no change in refinery

capacity or increase in the number of shuttle

vessels bringing crude oil to port.

Section 8, Air

Emissions Information

Section 19(b).1 and

19(c).1, Air Quality

Appendix 3, Air

Emission Worksheets

Category 18 –

Appropriations of

Water

The project does not involve the use of impoundments

or the diversion of state water.

Section 1,

Introduction and Plan

Contents

Category 19 – Levee

and Control Projects

The project does not involve drainage, reclamation,

channelization, levee construction or modification, or

flood or floodwater-control.

Section 1,

Introduction and Plan

Contents

Category 20 – Marine

Fishery Management

The project will not affect any commercial or

recreational fishing activities or management efforts.

Section 19(b).8,

Commercial and

Recreational

Fisheries

Category 21 – Policies

for Major Actions

A major action under this policy is considered to be an

activity for which an environmental impact statement

is required. BOEM has undertaken multiple EISs for

OCS lease sales in the GOM and undertook an EIS for

use of the FPSO. PAI conducted an analysis of site

specific potential impact producing factors and

determined that the proposed project falls within the

design and operational parameters that were assessed

in the programmatic FPSO EIS document and site

specific environmental impact analysis undertaken for

this SDOCD. No additional EIS is required.

Section 19,

Environmental

Impact Analysis

The activities proposed in this SDOCD are supported by sufficient data and information

concerning potential impacts associated with these proposed activities. The proposed

activities will be conducted in accordance with all federal and state regulations, applicable

NTLs, conditions in the approved permits, and lease stipulations. PAI has therefore

determined that the proposed activities associated with this project are consistent with the

Texas TCMP.

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Mississippi Coastal Program

The Mississippi Coastal Program has been in effect since 1972. The regulations, guidelines,

and procedures (Section 57-15-6 of the Mississippi Code of 1972) carry out state policy in

the Mississippi coastal area in order to protect coastal resources by preventing resource

destruction, promoting the benefits of resources, and managing activities that impact

resources.

As described more fully in this supplemental DOCD, Petrobras America Inc. (PAI) proposes

to develop two wells: WR 206 No. 6 and 7 and their associated jumper connectors, one per

well, within the Cascade deep water field. The Cascade Field and the associated Chinook

Field developments were previously addressed in a DOCD submittal and accompanying

coastal consistency certificate in June 2007. These Fields are located in the Central GoM and

do not involve any construction of facilities within the coastal zone of Mississippi. The only

action that could potentially affect the State of Mississippi is the transportation of produced

oil to market. As described in Section 14(c), PAI will charter Shuttle Vessels to deliver the

produced oil to market to terminals along the coast of the GoM. After the initial production

ramp-up in the first year of operations, PAI anticipates an offloading frequency of once per

week during six-eight years of production operations for Phase 1 of the development plan.

This SDOCD now addresses Phase II of the development plan. PAI has not yet determined

which specific terminals will be used. The specific refineries to be utilized will depend on

several factors including market conditions and available terminal capacities. PAI could

potentially utilize the Chevron USA terminal located in Pascagoula (see Figure 14-8). This

terminal ranks number 9 among all US refineries relative to daily crude operating capacity as

of January 2008 (Energy Information Administration 2011).

PAI has evaluated the proposed activities related to the proposed wells and their associated

jumper connectors to determine if there would be any reasonably foreseeable coastal effects

on the land, water uses, or natural resources of the coastal zone of Mississippi pursuant to the

enforceable policies of the state’s Coastal Zone Management Program. Specific policies that

address the potential environmental impacts to coastal uses related to oil and gas exploration

and production, are briefly described in Table 18-3 with relevant cross references to this

supplemental DOCD where further details are provided. The analysis upon which this

effects determination has been made is provided in Section 19.
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Table 18-3 – Consistency Review Summary

Policies Information Required Cross Reference

Goal 1 – To provide

for reasonable

industrial expansion

in the coastal area

and to insure the

efficient utilization

of waterfront

industrial sites

 Only existing terminal facilities in Pascagoula

may be potentially used and no industrial

expansion is proposed.

 There is no additional oil spill risk resulting from

bringing the crude product to shore. The various

refineries will likely operate at capacity whether

or not this proposed project is approved. If the

shuttle vessels proposed for this development are

not used, it is anticipated that some other

tanker, likely carrying foreign supplied oil, would

be used in its place.

Section 14, Related

Facilities and

Operations

Information

Goal 2 – To favor the

preservation of

coastal wetlands and

ecosystems

The project site is located 270 miles from Mississippi

out into the central Gulf of Mexico and would not

directly impact coastal wetlands or ecosystems in

Mississippi.

Section 1(b),

Location

Sections 19(b).4,

Coastal Environments

and 19(c), Project

Impacts

Goal 3 – To protect,

propagate, and

conserve the state’s

seafood and aquatic

life

Environmentally sensitive areas, including oyster

reefs, submerged grass beds, and other productive

shallow water areas will not be affected by project

activities.

Sections 19(b),

Existing Resource

Conditions and 19(c),

Project Impacts

Goal 4 – To conserve

the air and waters of

the state

 No air or water quality impacts would occur

because of the use of an existing refinery that is

located at an established port.

 Wastes from shuttle vessels will be properly

treated by a Marine Sanitation Device and

discharged overboard in accordance with USCG

regulations.

 PAI will use a dedicated field tug to enhance

safety and pollution response during offloading

and other operational activities, which will

minimize the chance of an oil spill affecting state

waters.

Section 8, Air

Emissions Information

and Appendix 3, Air

Emissions

Spreadsheets

Section 9, Oil Spill

Information

Goal 5 – The

beneficial use of the

state’s water

resources and to

prevent its waste.

The project does not involve the use of water

resources in Mississippi. Desalination units will be used

to generate the needed freshwater at the project site.

Section 7, Appendix

7-A-D

Waste and Discharge

Information

Goal 6 – To preserve

the state’s historical

and archeological

resources

To ensure any shallow hazards and historic sites are

identified and avoided, a shallow hazards assessment

of the seafloor was conducted at the project site.

Project activities will not affect any historical or

archeological sites in Mississippi coastal areas.

Section 19(b).14

Section 6(i),

Archeological Report

and Appendix 2-B

Shallow Hazards

Report for Facilities
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Policies Information Required Cross Reference

Goal 7 – To preserve

the natural scenic

qualities in the

coastal area

The project is located 270 miles from Mississippi and

areas with natural scenic qualities will not be

affected.

Section 1(b),

Location

Goal 8 – To assist

local governments in

the provision of

public facilities

services

The project does not involve the use of public

facilities.

Section 1,

Introduction

The activities proposed in this SDOCD are supported by sufficient data and information

concerning potential impacts associated with these proposed activities. The proposed

activities are not anticipated to result in any direct impacts to the land, water uses, or natural

resources of the coastal zone of Mississippi, pursuant to the enforceable policies of the state’s

coastal program. PAI has therefore determined that the proposed activities associated with

this project are consistent with the Mississippi Coastal Program.
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19 Environmental Impact Analysis (EIA)

Pursuant to 30 CFR 250.227 and 250.261 and NTL 2008-G04, this section provides

project-specific environmental impact analysis that assesses the potential direct and

indirect environmental impacts to offshore and onshore resources that could be affected

by the proposed activities. The Submerged Lands Act of 1953, the Outer Continental

Shelf Lands Act of 1953, and the Oil Pollution Act of 1990 provide the regulatory

framework and authority for BOEM to have oversight and management of offshore

operations. Seven other Federal laws also mandate compliance with their provisions:

 National Environmental Policy Act of 1970 requires a detailed environmental

review before any major Federal action;

 Clean Air Act of 1970, re-authorized in 1990, regulates allowable air pollutant

emissions from industrial activities;

 Clean Water Act of 1977 regulates discharges into waters of the U.S. through

issuance of National Pollutant Discharge and Elimination System permits;

 Coastal Zone Management Act of 1972, re-authorized in 1990, requires State

review of Federal action that affects the land and water uses of their coastal zones;

 Marine Mammal Protection Act of 1972 requires protection and conservation of

all marine mammals and their habitats; and

 Endangered Species Act of 1973 requires that all Federal actions not significantly

impair or jeopardize protected species or their habitats and requires a permit for

the taking of any protected species.

An EIA is undertaken herein by 1) identifying impact producing factors from the

proposed action, 2) undertaking an inventory of existing resources of concern, and 3)

conducting an analysis of potential impacts to these resources for avoidance,

minimization, or mitigation of the foreseen impacts.

The Notice to Lessees (NTL) 2008-G04, Information Requirements for Exploration

Plans and Development Operations Coordination Documents, issued on April 1, 2008,

provides guidance on preparing DOCDs required by 30 CFR 250, Subpart B regulations.

The NTL requires that the EIA identify impact-producing factors (IPF) associated with

the proposed action that could affect environmental, archeological, socioeconomic, or

other important resources in the area and provides additional guidance on information

requirements regarding compliance with the provisions of the Endangered Species Act

(ESA) and the Marine Mammals Protection Act (MMPA). This section describes

activities and potential impact producing factors associated with the proposed Cascade

Development Wells WR 206 No. 6 and 7 and their associated jumper connectors (one

jumper connector per well) that may have the potential to affect environmental,
19 Environmental Impact Analysis (EIA)

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archeological, and socioeconomic resources. Information on impact producing factors

(IPFs) is presented in Section 19(a). Existing resource conditions in or near the proposed

project area are presented in Section 19(b). Potential project impacts to these resources

are discussed in Section 19(c). Environmental hazards that may affect the project and/or

exist in the project area, i.e. the Gulf of Mexico, are addressed in Section 19(d).

Alternatives to avoid and minimize potential environmental impacts are addressed in

Section 19(e). In the unlikely event of project environmental impacts, mitigation

measures are identified in Section 19(f). Applicable consultation and coordination is

presented in Section 19(g) while a list of preparers is in Section 19(h). References are

listed in Section 19(i).

19(a) Impact Producing Factors (IPFs) from the Proposed Activities

The proposed project location is shown in Figure 1-1, which is approximately 290 miles

(467 km) southeast from the Port of Galveston, Texas and 180 miles (290 km) south from

the Port of Fourchon, Louisiana in the Gulf of Mexico, beyond the continental shelf and

continental slope in ultradeep water, approximately 8,200 feet (2,500 m). This location is

just off the Sigsbee escarpment on the edge of the Abyssal Plain. The Cascade and

Chinook Field locations are shown in Section 1, Figure 1-1 and specific well locations

are shown in Section 1(b) and are within the Walker Ridge Area.

The Gulf of Mexico is a roughly oval basin covered by a semi-enclosed marginal sea of

the Atlantic Ocean bounded by the United States, Mexico, and the island of Cuba. Entry

from the Atlantic is gained through the Straits of Florida, north of Cuba, and entry from

the Caribbean Sea is gained through the Yucatan Channel, south of Cuba. The Gulf of

Mexico has a surface area of 580,000 square miles (1.5 million sq km) and is

characterized by a very wide, gently sloping continental shelf (35%) around most of its

margin which is generally less than 656 feet (200 m) deep

(http://www.gulfbase.org/facts.phb). The only area in the Gulf where water depth

reaches 654 feet (200 meters) within (50 km) of the shore is off the Mississippi River

Delta. In contrast to the smooth gentle slope of the continental shelf, the Gulf continental

slope (40%) is steep and irregular, with canyons and knolls and reaches water depths of

between 590-9,842 feet (180-3,000 m). The remaining 25% are the abyssal depths,

mainly the Sigsbee Abyssal Plain, greater than 9,842 feet (3,000 m).

A summary of the proposed project activities within the Gulf is included in Section 1 of

this supplemental DOCD with Section 1(b) showing the location of the wells. Sections 2,

14, 15, and 16 respectively provide general information about offshore and onshore

project activities, operations, and support equipment while Sections 7, 8, and 9 provide

information on waste generation and discharges, air emissions, and potential inadvertent

oil spills associated with the proposed project and taken into consideration for

environmental impact analysis.

PAI has identified the following project-specific Impact Producing Factors (IPFs) which

could potentially impact the environment as a result of proposed development activities:
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 Air emissions;

 Noise;

 Seafloor disturbance;

 Ocean discharges;

 Onshore waste disposal;

 Accidental events such as oil spills or blowouts; and

 New or unusual technology.

19(b) Existing Resource Conditions

The Gulf of Mexico, as a relatively large semi-enclosed marginal sea off the Atlantic

Ocean and Caribbean Sea, has diverse abiotic and biotic resources. According to the

National Biodiversity Information Infrastructure and the Harte Research Institute for Gulf

of Mexico Studies, there are 15,419 known species from 40 phyla and divisions

(http://www.nbii.gov/portal/server.pt?open=512&objID=1950&mode=2&in_hi_userid=2

&cached=true). The diversity of biotic resources includes corals, jellyfish, sea anemones,

crustaceans, diatoms, dinoflagellates, marine vertebrates, birds, marine worms, mollusks,

squid, octopus, moss animals (Bryozoans), sea stars and sea urchins, shelled protists, and

sponges (Felder and Camp 2009). The following provides descriptions of applicable

existing resources to the project.

19(b).1 Air Quality

National Ambient Air Quality Standards

The Clean Air Act (CAA) of 1970 established national ambient air quality standards

(NAAQS). When measured concentrations of regulated pollutants exceed standards

established by NAAQS, then an area may be designated as non-attainment area for a

regulated pollutant. As mandated by the Clean Air Act (CAA) of 1970, EPA has

established ambient air quality standards to protect public health (primary standards) and

public welfare (secondary standards). Primary standards are based on observable human

health responses, and are set at levels that provide an adequate margin of safety for

sensitive segments of the population. Secondary standards are intended to protect nonhealth based public interests such as structures, vegetation, and livestock. The more

stringent of the primary or secondary standards are applicable to projects under EPA

jurisdiction.

The EPA Office of Air Quality Planning and Standards (OAQPS) has set National

Ambient Air Quality Standards for six principal pollutants, which are called "criteria"

pollutants. Units of measure for the standards are parts per million (ppm) by volume,

parts per billion (ppb - 1 part in 1,000,000,000) by volume, milligrams per cubic meter of

air (mg/m3), and micrograms per cubic meter of air (μg/m3).
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The criteria pollutants are: sulfur dioxide (SO2), particulate matter with aerodynamic

diameters less than 10 micrometers or microns (PM10) and 2.5 microns (PM2.5), nitrogen

dioxide (NO2), carbon monoxide (CO), photochemical oxidants as ozone (O3), and lead

(Pb). Nitrogen oxides (NOx) and Volatile Organic Compounds (VOCs) are regulated as

precursors to ozone. The PM10 National Ambient Air Quality Standards (NAAQS) was

promulgated July 1, 1987 at the federal level to replace the existing standards limiting

Total Suspended Particulates (TSP). On July 19, 1997, EPA promulgated a new Fine

Particulate (PM2.5) NAAQS.

The NAAQS have been developed for various durations of exposure. The short-term

(24-hours or less) NAAQS for SO2 and CO refer to exposure levels not to be exceeded

more than once per year. The short-term standard for PM10 may not be exceeded more

than once per year on average over 3 years. For PM2.5 the 3-year average of the 98th

percentile of 24-hour concentrations at each population-oriented monitor within an area

must not exceed 35 micrograms per cubic meter (μg/m3; effective December 17, 2006).

The 1-hour ozone standard is attained when the expected number of days per calendar

year with the maximum hourly average concentrations above 0.12 parts per million

(ppm), is less than or equal to 1. As of June 15, 2005, EPA revoked the 1-hour ozone

standard in all areas except the fourteen 8-hour ozone non-attainment areas. The 8-hour

ozone standard is attained when the 3-year average of the fourth highest daily maximum

8-hour average ozone concentrations measured at each monitor within an area over each

year does not exceed 0.08 ppm. A 1-hour NO2 standard of 100 parts per billion (ppb)

was established on January 22, 2010. This new standard is calculated as the 3-year

average of the 98th percentile of the daily 1-hour average concentration of NO2. . A 1-

hour SO2 standard of 75 parts per billion (ppb) was established o June 2, 2010. This new

standard is calculated as the 3-year average of the 99th percentile of the daily 1-hour

average concentration of SO2.

Long-term NAAQS for SO2, NO2, and Pb refer to limits that cannot be exceeded for

exposure averaged over three months (Pb) or annually (SO2 and NO2). To attain this

standard, the 3-year average of the weighted annual mean PM2.5 concentrations from

single or multiple community-oriented monitors must not exceed 15.0μg/m3. The

NAAQS are listed in Table 19-1.

Monitored ambient air quality data in coastal areas is depicted in Table 19-2, which

shows that there are no exceedances of the NAAQS with the exception of ozone. Ozone

non-attainment status occurs in the port areas of Galveston/Houston and Beaumont/Port

Arthur, Texas. Further information related to climatology and air quality can be found in

MMS (2006a).
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Table 19-1 - National Ambient Air Quality Standards

Primary Standards Secondary Standards

Pollutant Level Averaging Time Level Averaging Time

Carbon

Monoxide

9 ppm

(10 mg/m3)

8-hour (1) None

35 ppm

(40 mg/m3)

1-hour (1)

Lead 0.15 μg/m3 (2) Rolling 3-Month Average Same as Primary

Nitrogen

Dioxide

53 ppb (3) Annual

(Arithmetic Average)

Same as Primary

100 ppb 1-hour (4) None

Particulate

Matter (PM10)

150 μg/m3 24-hour (5) Same as Primary

Particulate

Matter (PM2.5)

15.0 μg/m3 Annual (6)

(Arithmetic Average)

Same as Primary

35 μg/m3 24-hour (7) Same as Primary

Ozone 0.075 ppm

(2008 std)

8-hour (8) Same as Primary

0.08 ppm

(1997 std)

8-hour (9) Same as Primary

0.12 ppm 1-hour (10) Same as Primary

Sulfur

Dioxide

0.03 ppm (11)

(1971 std)

Annual

(Arithmetic Average)

0.5 ppm 3-hour (1)

0.14 ppm (11)

(1971 std)

24-hour (1)

75 ppb (12) 1-hour None

(1) Not to be exceeded more than once per year.

(2) Final rule signed October 15, 2008. The 1978 lead standard (1.5 μg/m3 as a quarterly average)

remains in effect until one year after an area is designated for the 2008 standard, except that in areas

designated nonattainment for the 1978 standard, the 1978 standard remains in effect until

implementation plans to attain or maintain the 2008 standard are approved.

(3) The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the

purpose of clearer comparison to the 1-hour standard

(4) To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average

at each monitor within an area must not exceed 100 ppb (effective January 22, 2010).

(5) Not to be exceeded more than once per year on average over 3 years.

(6) To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from

single or multiple community-oriented monitors must not exceed 15.0 μg/m3.

(7) To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each

population-oriented monitor within an area must not exceed 35 μg/m3 (effective December 17, 2006).

(8) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone

concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm.

(effective May 27, 2008)

(9)(a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average

ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm.

(b) The 1997 standard—and the implementation rules for that standard—will remain in place for

implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone

standard to the 2008 ozone standard.

(c) EPA is in the process of reconsidering these standards (set in March 2008).

(10)(a) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing

obligations under that standard ("anti-backsliding").
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(b) The standard is attained when the expected number of days per calendar year with maximum hourly

average concentrations above 0.12 ppm is < 1.

(11) The 1971 sulfur dioxide standards remain in effect until one year after an area is designated for the

2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971

standards remain in effect until implementation plans to attain or maintain the 2010 standards are

approved.

(12) Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the

daily maximum 1-hour average at each monitor within an area must not exceed 75 ppb.
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Table 19-2 – Coastal Ambient Air Quality

Year

O3

(ppm) SO2 (ppm) NO2 (ppm) PM2.5 (μg/m3)

PM10

(μg/m3) CO (ppm)

Highest

4

th High 8-

hr

Highest

2

nd High 3-

Hr

Highest

2

nd High

24-hr

Highest

Annual

Mean

Highest

Annual

Mean

Highest

98th

Percentile

24-hour

Highest

Annual

Mean

Highest

2

nd High

24-hour

Highest

2

nd High

1-hour

Highest

2

nd High

8-hour

Baldwin County, Alabama

2008 0.072 - - - - 20.2 9.96 - - -

2006 0.081 - - - - 26.0 11.2 - - -

2005 0.074 - - - - 26.0 11.8 - - -

2004 0.080 - - - - 28.0 11.4 - - -

2003 0.078 - - - - 29.0 12.2 - - -

Mobile County, Alabama

2008 0.076 - - - - 22.4 10.3 - - -

2006 0.085 0.014 0.005 0.002 - - - - - -

2005 0.073 0.019 0.008 0.002 - 29.0 17 135 - -

2004 0.077 0.017 0.007 0.002 - 36.0 13.0 116 - -

2003 0.082 0.017 0.009 0.002 - 31.0 12.8 82 - -

Jackson County, Mississippi

2008 0.078 - 0.007 0.002 0.006 20.0 9.89 - - -

2006 0.082 0.035 0.008 0.002 0.007 28.0 13.1 40 - -

2005 0.081 0.031 0.012 0.003 0.007 28.0 11.9 40 - -

2004 0.079 0.034 0.008 0.003 0.007 32.0 12.1 51 - -

2003 0.084 0.017 0.007 0.002 - 26.0 12.0 33 - -

Breton Aerometric Monitoring Program – Offshore

2001 - 0.017 0.005 0.002 0.003 - - - - -

East Baton Rouge Parish, Louisiana

2008 0.074 - 0.017 0.003 0.013 28.4 14.3 - 2.5 1.8

2006 - - - - - - - - 4.4 3.3

Orleans Parish, Louisiana

2008 0.071 - - - - - - - - -

2005 - - - - - - - - 2.7 1.7

2004 - - - - - - - - 5.2 3.4

2003 - - - - - - - - 6.5 3.5

Jefferson County, Texas

2008 0.078 - 0.018 0.003 0.008 32.6 10.41 - 1.7 0.7

2006 0.085 0.150 0.034 0.004 0.009 27.0 11.1 - - -

2005 0.083 0.070 0.019 0.004 0.009 36.0 15.0 - - -

2004 0.091 0.149 0.032 0.004 0.010 27.0 11.6 - - -

2003 0.086 0.236 0.034 0.004 0.010 26.0 11.8 - - -

Sources EPA 2006; Sonoma Technology 2004 (actual period of data collection October 2000-November 2001) and http://www.epa.gov/air/data/geosel.html
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The closest Federal Class I area, which prohibits impairment from manmade air

pollution, is Breton National Wilderness Area (BNWA) located approximately 40 miles

offshore southeastern Louisiana and approximately 30 miles from the Mississippi coast.

The Breton Aerometric Monitoring Program measured ambient concentrations of NO2

and SO2 at BNWA that were well below the NAAQS and similar or lower than ambient

concentrations measured at shore-based monitors in Alabama, Mississippi, Texas, and

Louisiana (EPA 2006).

For any OCS plan that is located within 63 miles of BNWA, BOEM would consult with

the US Fish and Wildlife Service (USFWS), which manages the area. The Cascade

wells, WR 206 No. 6 and 7 are located over 200 miles from BNWA as shown in Figure

19-1.
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Figure 19-1 - National Park Lands
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The CAA specifies air quality jurisdictional boundaries between the EPA and the

Department of the Interior in the GoM OCS. Projects on the OCS east of 87.5o West

longitude (approximately the Eastern Planning Area boundary) are subject to EPA air

quality regulations. Projects located west of 87.5o West longitude, which includes the

Cascade / Chinook Development, are regulated by BOEM.

Air quality over federal OCS waters is unclassified because no provisions exist under the

Clean Air Act for designating such areas outside the boundaries of state waters. Only

areas within state boundaries are classified as attainment, non-attainment, or

unclassifiable (Minerals Management Service [MMS] 2002). The 1990 CAA

Amendments required that BOEM evaluate cumulative, onshore, air quality nonattainment areas, and impacts from OCS petroleum resource development. The Secretary

of Interior and the EPA Administrator have determined that no new air quality

requirements are necessary for the area under BOEM jurisdiction.

No specific air quality data exist for the Walker Ridge area. However, due to the distance

from shore based pollution sources, offshore air quality is expected to be better than the

NAAQS for all criteria pollutants (MMS 2001). The BOEM uses a two level approach to

evaluate a project’s potential impacts to onshore areas. If the proposed activities exceed

the criteria at the first (exemption) level, the proposed project must be evaluated to

determine if it exceeds the second (significance) level criteria. The influence to onshore

air quality is dependent upon meteorological conditions and air pollution emitted from

operational activities. The pertinent meteorological conditions affecting air quality are

wind speed and direction, atmospheric stability, and mixing height which govern

dispersion and transport of potential pollutants. The typical synoptic wind flow for the

Walker Ridge area is driven by the clockwise circulation around the Bermuda High

(MMS 2008). This circulation direction is conducive to transporting emissions to shore.

However, in actuality, the wind blows from all directions in the area of concern because

of smaller meso-scale wind flow patterns, such as the land/sea breeze phenomenon,

periodic tropical cyclones, and mid-latitude frontal systems. Therefore, winds are

predominately from the south-southeast across the area. Refer to Section 8 and Appendix

3, Air Emissions Worksheets, for more specific details on the projected air emissions

associated with the proposed activity.

19(b).2 Water and Sediment Quality

The continental shelf effectively isolates the deeper waters of the OCS of GoM from the

direct influences of many coastal processes. Limited information is available regarding

water quality in the deepwater environment. Water depths greater than 4,593 feet

(1,400 m) have been found to be relatively homogeneous with respect to temperature,

salinity, and oxygen (MMS 2002). In general, the site is expected to have typical ocean

salinity and oxygen levels, low levels of nutrients, and low levels of contaminants in

water and sediments (Continental Shelf Associates [CSA] and Texas Agriculture and

Mechanical [A&M] University 2001 and MMS 2002).

Measuring the quantity of dissolved oxygen (DO) in water is one method to determine

marine environment water quality and to identify water masses and their sources. DO
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values are described in Boehm et al. (2001) and Gallaway et al. (2001). Water masses,

which come into the GoM through the Yucatan Channel, have relatively high DO

concentrations and are considered to be the source of replenishment of DO to the deep

GoM waters (Jochens et al. 2005). However, there was very little data on DO levels in

waters deeper than 6,562 feet. More recently, data has been collected (JAG 2010, Garcia

et al 2010). Reduced DO below thresholds that sustain aquatic life results in a condition

called hypoxia. Hypoxia occurs when the concentration of dissolved oxygen in the water

falls to a level that impedes aquatic life. Hypoxic conditions are generally agreed to occur

when DO falls below 1.4 mL/L (also expressed as 2 mg/L) though effects levels are

species dependent. Hypoxia is regularly observed in the Northern Gulf of Mexico

adjacent to the Mississippi River on the Louisiana and Texas continental shelf

(http://www.gulfhypoxia.net/Overview/). Hypoxic conditions do not normally occur in

the deep-water layer (JAG 2010). In fact this water layer is relatively rich in DO with a

spring climatological mean of 4.8 ± 0.1 mL/L (~6.9 mg/L) at 1500 m depth (Garcia et al

2010).

Detailed information related to water and sediment quality in the GoM can be found in

MMS (2006a). Following the Deepwater Horizon accident, more recent water and

sediment data has also been collected along various shorelines as well as out into the Gulf

(http://www.nodc.noaa.gov/General/DeepwaterHorizon/deepwater_floats_gmap.html).

These data indicate that water temperatures decrease with depth from a water surface

temperature near 30° C to less than 5° C below 3,325 feet (1,000 meters). Salinity is

shown to also decrease with depth from a general surface salinity of 36.5 ppt to

approximately 35 ppt below 2,625 feet (800 meters). PAI undertook a geophysical and

geotechnical data acquisition in 2007 (Appendix 2a), an assessment of the seafloor and

shallow geology in 2007 (Appendix 2b), and water and sediment analysis study in 2010

with sampling within the Walker Ridge Cascade and Chinook Development Units to

provide an environmental characterization before and after exploration and initial

development of two wells. The 2010 water and sediment sampling was done on a grid

using 37 sampling stations. Sampling points were located in water depths ranging from

6,650-9,180 feet (2,000-2,800 meters) with water samples collected at 5 depths: surface,

start and end of thermocline, mid-depth, and near-bottom depth. This study addressed

obtaining hydrographic and seawater data and among other things, toxicity testing.

Twenty-nine water and sediment parameters were addressed in the 2010 survey.

There are likely natural hydrocarbon seeps in the vicinity, which are extensive throughout

the Central GoM. However, the area sediments are generally very soft to soft, highly

plastic, normally consolidated clays. Shallow gas or active fluid venting to the seafloor

was not present and no petroleum hydrocarbon contamination was detected (Appendix 2).

The primary factors influencing coastal and marine offshore water quality are

temperature, salinity, oxygen, nutrients, potential of hydrogen (pH), oxidation-reduction

potential, pathogens, and turbidity or suspended load. Trace constituents such as metals

and organic compounds can also affect water quality. Low concentrations of metals on

the seafloor sediments indicate lack of significant concentrations in the water column.

Water quality was found not acutely toxic to Americamysis bahia.
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19(b).3 Coastal Environments

The Submerged Lands Act of 1953 grants States rights to the natural resources of

submerged lands from the coastline to no more than 3 nautical miles (5.6 km) into the

Atlantic, Pacific, Artic Oceans, and the Gulf of Mexico with the exception of Texas and

the west coast of Florida, where state jurisdiction extends 3 marine leagues, about 9 miles

(16.2 km) into the Gulf

(http://www.boemre.gov/AboutBOEMRE/FedOffshoreLands.htm).

Pursuant to 30 CFR 250.226 and 250.260 following information is provided to support

coastal consistency determination and EIA. This section summarizes the coastal

environments of the affected states of Texas, Louisiana, and Mississippi. Coastal

environments are protected under various regulations including the Coastal Zone

Management Act, PL 92-583 (16 U.S.C. 1451-1464). There are approximately 808 total

miles of coastline along the three affected states: Texas (367 miles), Louisiana (397

miles), and Mississippi (44 miles) (CRS 2006) comprised of barrier islands, beaches,

subtidal nearshore areas, shallow water hypersaline lagoons, open water estuaries and

embayments, intertidal and supratidal marshes (wetlands), swamps, and other coastal

environments. There are four geologic subareas within the affected states that

characterize the different types of shoreline: the barrier island complex of southern Texas

(and northern Tamaulipas, Mexico); the Chenier Plain of eastern Texas and western

Louisiana; the Mississippi River Delta marsh complex of southeastern Louisiana; and the

barrier-island and Pleistocene-plain complex of Mississippi (and Alabama) (MMS

2006a). In addition to these coastal environments, various niche habitats are also present

such as sand bars, mud flats, seagrass beds, oyster reefs, and coral reefs as other sensitive

coastal resource of the nearshore environment of the Gulf of Mexico. Detailed

information on the coastal environments of each of these geologic subareas can be found

in MMS 2006a.

Coastal Barrier Islands and Beaches

The U.S. Gulf of Mexico shoreline along the affected states is characterized by a series of

sandy barrier islands, sandy beaches with low to moderate ocean-wave intensities

interrupted by the Mississippi River Delta Marsh Complex in southeast Louisiana before

returning to sandy beaches and barrier islands along the state of Mississippi. The Gulf

coast landmass is relatively low lying, forming broad flat plains with gradually sloping

topography. These broad flat plains are punctuated by drowned river mouths which

today are a series of large bay complexes where in some areas of Louisiana and Texas,

tidal influences can be seen 25 – 40 miles inland due to low flat topography. These

embayments, or estuaries, are generally protected behind a series of barrier islands.

The barrier islands along in the western Gulf of Mexico shoreline of the United States are

primarily the result of former Gulf shoreline migration processes. The barrier islands are

transgressive, meaning there is a landward movement of sediment. Transgressive barrier

islands typically have low profiles; narrow widths; low, sparsely vegetated, discontinuous

sand dunes; and closely spaced with active washover channels (MMS 2006a). Some of

the major barrier islands of the affected states of Texas, Louisiana, and Mississippi
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include Brazos Island, Padre Island, Harbor and Mustang Islands, St. Joseph Island,

Goose Island, Matagorda Island, Follets Island, and Galveston Island along the Texas

Gulf coast; Marsh Island, Round Island, Petit Bois, Ship Island, Horn Island, Cat Island,

the Chandeleur Islands chain, Grand Terre, Timbalier Island, and the Isles Dernieres

island chain along the Louisiana coast; and the Dog Keys of the Mississippi coast. These

barrier islands are characterized by sandy beaches which provide important stopover

habitats for migratory birds during spring migration, foraging areas for species such as

the endangered Piping Plover (Charadrius melodus), and nesting habitat for sea turtles,

which are discussed in section 19(b).6.

Coastal Birds

Coastal birds are composed of diverse types of shorebirds, marsh birds, colonial

waterbirds, and various other types of birds that annually migrate through the Gulf coast

between wintering grounds in south and central America and breeding grounds in central

and north America, including Canada and Alaska. There are over 300 species that

migrate through two major flyways of the central and western Gulf: the Central Flyway

along the Texas coast and the Mississippi Flyway through Mississippi

(http://www.birdnature.com/flyways.html). These species would generally utilize the

affected states of Texas, Louisiana, and Mississippi twice a year on spring and fall

migrations. The number of species and the number of individual birds migrating has

resulted in the State of Texas’ Parks and Wildlife Department to designate a Great Texas

Coastal Birding Trail along the coast supporting ecotourism through many coastal

communities with an annual international birding event called the Great Texas Birding

Classic.

Coastal birds that breed and nest along the Gulf coast include species that tend to nest

together in relatively large colonies. These species are collectively called colonial

waterbirds and include Great Blue Heron (Ardea herodias), Great Egret (Ardea alba),

Roseate Spoonbill (Platalea ajaja), and numerous other heron and egret species, such as

the endangered Reddish Egret (Egretta rufescens) and the Brown Pelican (Pelecanus

occidentalis). Colonial waterbird sites are protected by the US Fish and Wildlife Service

(USFWS). These sites, as well as each species, are counted annually by the USFWS.

Other species are more solitary and use a variety of habitat types along the coast nesting

on bare ground, shrubs, grasslands, and trees. Bare ground nesting birds include the

endangered Piping Plover (Charadrius melodus) and American oystercatcher

(Haematopus palliatus). The USFWS has designated critical habitat along the Gulf

beaches (http://www.data.gov/raw/1858). The mottled duck (Anas fulvigula) is another

Gulf coast bird species of concern in Texas and is also listed on the National Audubon

Society’s watchlist because of its very restricted range to the coastal marshes of Texas,

Louisiana, and a less extent Florida.

(http://webl.audubon.org/science/species/watchlist/profile.php?speciescode=motduc).
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Coastal Wetlands

Coastal wetlands are highly productive ecosystems, both environmentally and

economically. Together with barrier islands, coastal wetlands provide an important

buffer against storm surges. Coastal wetland types along the shores of the affected states

include fresh, intermediate, brackish, and saline marshes; mud and sand flats; and

forested wetlands including mangrove swamps, cypress-tupelo swamps, and bottomland

hardwoods. Detailed descriptions of these various wetland types, processes, functions,

and their importance can be found in Chapter 3.1.2.1 of the Multisale EIS (USDOI,

MMS, 2007), in Chapter 3.2.1.2 of the FPSO EIS (USDOI, MMS, 2001), and the Sitespecific Environmental Assessment for an FPSO Facility: Site-specific Evaluation of

Petrobras America Inc.’s Initial Development Operations Coordination Document, N9015 (MMS 2008).

Gulf coast wetlands within the affected states occur as either relatively narrow bands

around the margins of waterways or broad expanses along the lagoons and embayments,

such as the Laguna Madre of south Texas, along the bay side of barrier islands associated

with Matagorda Bay and Galveston Bay in Texas or as extensive coastal delta wetlands

that protrude out into the Gulf associated with the Mississippi River Delta complex and

within Atchafalaya Bay, and the Grand Bay Coastal Reserve in Mississippi. Due to

proximity to Gulf waters, subtle elevation changes, and freshwater inputs, coastal

wetlands support a wide range of types that include saltwort and glasswort flats, intertidal

Spartina saltwater marshes, freshwater marshes, cypress swamps, and bottomland

hardwood wetlands (MMS 2006a). The general distribution of coastal wetlands relative

to the affected states is shown on Figure 19-2.

Texas, Louisiana, and Mississippi have experienced a net loss of coastal wetlands due to

human development activities and natural processes of erosion and subsidence. Between

1955 and 1992, Texas lost approximately 329.0 square miles of coastal wetlands, with an

estimated total of 6,085.6 square miles of coastal wetlands remaining in Texas in 1992

(Moulton et al. 1997, Dahl 2010). Louisiana accounts for 25% of the vegetated wetlands

and 40% of the tidal wetlands in the contiguous US, but the Louisiana coastline is

eroding faster than any other coastal area of the world, losing up between 24 to 40 square

miles each year (USGS 1995) to the severe lack of sediment deficient due to over 100

years of Mississippi River system alterations. The loss of coastland in Louisiana east of

the Mississippi River from 2004 to 2005 was 72.9 square miles (MMS 2006b). The US

Geological Survey assessed the water-land area within two months after Hurricanes

Katrina (August 2005) and Rita (September 2005) and determined that 217 square miles

of Louisiana’s coast had been converted to open water compared to images taken in 2004

(Barras 2006) as a result of the storms. Analyses show that coastal Louisiana has

undergone a net change in land area of about -1,883 square miles (mi2) from 1932 to

2010 (Couvillion et al 2011). Mississippi contains approximately 112.5 square miles of

coastal wetlands, and while coastal wetlands in the state have been lost to human

development, Mississippi coastal wetlands are considered to be more stable than those of

Louisiana (MMS 2006a) due to their less reliance on Mississippi River sediments.
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Coastal wetlands are important nursery habitats for many commercially and

recreationally important species such as crab, shrimp, and finfish. Coastal wetlands also

provide resting and foraging habitat for the diversity of wintering waterfowl and coastal

birds including the Wood Duck (Aix sponsa), a species of concern in Texas. Due to the

location of the Texas, Louisiana, Mississippi coasts to the Central Migratory Flyway,

these wetlands provide critical migratory stopover areas, especially fallout areas during

spring migration. Louisiana’s coastal wetlands support more than two-thirds of the

wintering waterfowl population of the Mississippi Flyway, including 20-25 percent of

North America’s puddle or dabbling duck (Anas sp) population. (MMS 2008).
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Figure 19-2 – Coastal Wetlands
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Nearshore Environment

The nearshore environment is characterized by shallow waters and wave influenced

bathymetric conditions including shifting sandbars. In the northern Gulf of Mexico, there

are an estimated 11,583.1 square miles of submerged seagrass beds in exposed, shallow

coastal waters and another 640.9 square miles located in protected, natural embayments.

Seagrass beds are underwater grass meadows dominated by submerged aquatic

vegetation (SAV). The characteristic seagrass SAV species are eelgrass (Zostera

marina), turtle grass (Thalassia testudinum), shoal grass (Halodule wrightii), manatee

grass (Syringodium filiforme), and widgeon grass (Ruppia maritime). Seagrass beds

require shallow, relatively clear, protected or calm waters with predominantly sand

bottoms. Johnson’s seagrass (Halophila johnsonii) is a federally-listed threatened

species, listed since 1998.

(http://www.nbii.gov/portal/server.pt/community/gulf_of_mexico_biodiversity/1950/mari

ne_vertebrates/7249).

Seagrass beds support a high diversity of marine species and provide a food source for

wintering waterfowl. Like coastal wetlands, seagrass beds in the GoM have diminished in

recent decades (MMS 2006a).

Seagrass beds have been shown to provide at least 13 ecological functions including

primary producers, habitat for 170 invertebrate species and 100 fish species, and food

web support. The majority (98.5%) of the remaining coastal seagrass beds are located off

of Florida. The affected states of Texas, Louisiana, and Mississippi account for less than

1.5% of the coastal seagrass beds in the northern Gulf of Mexico. The most extensive

seagrass beds off of the affected states occur in the Laguna Madre, a hypersaline lagoon

of Texas.

Protected Coastal Areas

Protected coastal areas are those marine and coastal habitats protected under national,

state, tribal, or local designations and typically open to public use and managed for the

preservation of unique coastal and marine resources such as estuaries. Estuaries are

semi-enclosed bodies of water, and the surrounding coastal habitat, where saltwater from

the ocean meets and mixes with freshwater inflows from streams and rivers. Estuaries

are critically important nursery areas with more than 95% of all commercially harvested

species and 85% of all recreational species in the GoM spending a portion of their life in

estuarine waters (MMS 2006a). The National Estuary Program (NEP) was established in

1987 under the Clean Water Act (CWA) of 1977 and is administered by the EPA. The

program is intended to identify nationally important estuaries, to protect and improve

their water quality, and enhance their living resources. The Mobile Bay NEP (Alabama),

Grand Bay NEP (Mississippi), Barataria-Terrebonne NEP (Louisiana), and Galveston

Bay NEP (Texas) are examples of NEPs located along the Gulf coast.

Protected coastal areas included specific geographic areas that are designated as critical

habitat by the U.S. Fish and Wildlife Service (USFWS) under the Endangered Species

Act as essential for the conservation of a threatened or endangered species and that may
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require special management and protection such as 18 specified areas containing 139,029

acres (56,263 ha) along the Texas, 7 specified areas containing 24,964 ac (10,103 ha) in

Louisiana, and 12 designated areas containing 9,529 ac (3,857 ha) along the Mississippi

coasts for piping plover (Charadrius melodus) (http:/www.fws.gov/plover/). The

USFWS also designates protection under the Coastal Barrier Resources Act of 1982.

Relatively long, continuous coastal barriers with small ebb-tidal deltas are produced by

longshore currents along wave-dominated coasts as islands along the coast. These barrier

islands are typified along the Texas coast in Padre Island and Galveston Island which are

long, generally narrow, and cut by widely separated tidal inlets with large sand

accumulations in the back-barrier bays, and small or nonexistent seaward shoals. Similar

barrier islands are also found along parts of the Louisiana coast and Mississippi and

Alabama.

National Wildlife Management Areas and National Wildlife Refuges also protect and

preserve unique habitats located along the Gulf coast as an interrelated system with state

parks, state wildlife management areas, and local protected coastal habitats such as

Galveston Island State Park, City of Galveston’s East End Marsh Complex, and Sea Rim

State Park in Texas, Grande Isle State Park, Peveto Woods Bird and Butterfly Sanctuary

and the Creole Nature Trail in Louisiana, and the Grand Bay National Estuarine Research

Reserve in Mississippi. National Wildlife Refuges (NWR), which are managed by the

U.S. Fish and Wildlife Service to conserve fish, wildlife, and plants, are located

throughout the three affected states. Coastal NWRs of Texas, Louisiana, and Mississippi

include: Laguna Atascosa NWR, Aransas NWR, San Bernard NWR, Brazoria NWR,

Anahuac NWR, McFadden NWR, and Texas Point NWR in Texas; Sabine NWR,

Lacassine NWR, Shell Keys NWR, Bayou Teche NWR, Mandalay NWR, Delta NWR,

Breton NWR, Bayou Sauvage NWR, and Big Branch Marsh NWR in Louisiana; and

Mississippi Sandhill Crane NWR and Grand Bay NWR (both part of the Gulf Coast

Refuge Complex) in Mississippi. The coastal protected areas within the affected states

also include parts of the National Park System, specifically Gulf Islands National

Seashore (Mississippi) and Padre Island National Seashore (Texas). Some of these

protected areas of NEPs, National Parks, and NWRs on the coastlines of the affected

states are shown in Figure 19-3.
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Figure 19-3 – Protected Areas
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There are topographic features on the continental shelf that are the result of intruding salt

domes, particularly on the northwestern shelf and relict carbonate reefs on the south

Texas OCS and the pinnacles region offshore of the Mississippi/Alabama coast

(Halbouty 1967). These features also include banks offshore that are geologically group

to include mid-shelf bedrock banks and outer shelf bedrock banks with carbonate reef

caps (Merrill 1983). There are dozens of banks throughout the northern Gulf of Mexico

that support coral, though they are not considered true coral reefs (MMS 2006a). Many

of these banks, including the East and West Flower Garden Banks, Seven and One Half

Fathom Bank, Claypile Bank, Fishnet Bank, Alaminos Bank, Ewing and Diaphus Banks,

and Sackett are considered Marine Habitat Areas of Particular Concern (see Section

19(b).11) and some are shown in Figure 19-4. There are seven biotic zones at a bank

depending upon depth, salinity, substrate, turbidity, and temperature. Off the coasts of

the affected states of Texas, Louisiana, and Mississippi, there are two true coral reefs: the

East and West Flower Garden Banks which are protected along with the banks as marine

sanctuaries under the National Marine Sanctuaries Act, amended in 2000 (Title 16,

Chapter 32, Sections 1431 et seq.) and in furtherance of the purposes of the National

Marine Sanctuaries Act (16 U.S.C. 1431 et seq.), National Wildlife Refuge System

Administration Act of 1966 (16 U.S.C. 668dd-ee), National Park Service Organic Act (16

U.S.C. 1 et seq.), National Historic Preservation Act (16 U.S.C. 470 et seq.), Wilderness

Act (16 U.S.C. 1131 et seq.), Magnuson-Stevens Fishery Conservation and Management

Act (16 U.S.C. 1801 et seq.), Coastal Zone Management Act (16 U.S.C. 1451 et seq.),

Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.), Marine Mammal Protection

Act (16 U.S.C. 1362 et seq.), Clean Water Act of 1977 (33 U.S.C. 1251 et seq.), National

Environmental Policy Act, as amended (42 U.S.C. 4321 et seq.), Outer Continental Shelf

Lands Act (42 U.S.C. 1331 et seq.), and other pertinent statutes and Presidential

Executive Order 13158 of May 26, 2000 defining marine protected areas.

The East and West Flower Garden Banks coral reefs are located on the outer shelf on salt

domes, approximately 110 miles south of the Texas / Louisiana border (MMS 2006a,

TPWD 2007, NOAA 2011). These reefs support over 21 species of coral, 175 species of

fish, 250 species of macro-invertebrates, and 80 species of algae (TPWD 2007). The

East and West Flower Garden Banks as well as the nearby Stetson Bank (30 miles closer

to shore) are part of the Flower Garden National Marine Sanctuary, protected by

NOAA’s Office of National Marine Sanctuaries (TPWD 2007, NOAA 2011).

Endangered and threatened species in critical marine habitats under the jurisdiction of the

NOAA Fisheries Service Southeast Region, which spans from Texas through Florida

include the invertebrate coral species, elkhorn coral (Acropora palmate) and staghorn

coral (Acropora cervicornis). Both species were listed in 2006 as threatened.
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Figure 19-4 – Biological Resources
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Deepwater Chemosynthetic Communities

GoM chemosynthetic communities are found in water depths from several hundred

meters to more than two thousand meters, generally in association with faults,

hydrocarbon seeps, and in lava-like flows of solidified asphalt (MacDonald et al. 2002).

They can also referred to as high density benthic communities. The northern GoM has

been described as a ‘leaky’ hydrocarbon province characterized by faults that facilitate

migration, or seeps, of oil and gas from subterranean reservoirs to the sea floor

(MacDonald et al. 2002). A summary is provided below, but further details related to the

level of information known about chemosynthetic communities and the conditions where

they can be found in the GoM are provided in MMS (2006a).

The hydrocarbon seeps alter the physical properties of surface and near-surface

sediments, which can be detected using geophysical techniques. Near-surface sediments

produce distinct signatures on high-frequency echo-sounder and seismic reflection

profiles. Seeps are recognized on echo-sounder records as they cause acoustic “wipeout,”

which is the absence of subsurface reflectors. Seepage effects can be identified by

seismic reflection, in particular the 2D and 3D multi-channel seismic data, which is used

to assess seafloor conditions in the project area. Refer to the GEMS Shallow Hazards

Report for Facilities and the Summary of Environmental Conditions for Cascade /

Chinook in Appendix 2.

Macrofaunal assemblages that are characteristic of GoM chemosynthetic communities

are dominated by tubeworms, mussels and clams with adjacent bacterial mat

communities (Cordes 2006). There is a dependent symbiosis relationship with bacteria

that can utilize chemical energy as opposed to light. The settings for these

chemosynthetic communities are characterized by vents and seeps (MMS 2002). These

foundation species, which are essentially sessile (attached and not moving from place to

place), form a habitat that is utilized by numerous other species. Species commonly

associated with this foundation community include limpets, starfish, shrimp, crabs, snails,

fish, and numerous species of polychaete worms.

While chemosynthetic communities require particular geophysical and geochemical

conditions to establish, their existence also results in the development of secondary

features. For example, microbial respiration increases dissolved organic carbon

concentrations and alkalinity, which generates authigenic carbonates; notable as one of

the macroscale geologic features of seep environments (TDI-Brooks International, Inc.

2005). They are also temperature sensitive and influenced by Loop Current eddies and

transient deepwater currents.

MMS requires that a geophysical assessment of the seafloor be conducted in the project

area to indicate whether there is the potential for chemosynthetic communities to be

present. Findings of the seafloor and geologic assessment for the Cascade and Chinook

Development (GEMS 2007) are provided in the GEMS Shallow Hazards Report for

Facilities and the Summary of Environmental Conditions for Cascade / Chinook included

in Appendix 2.
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According to a list of known high-density deepwater benthic communities, the proposed

drilling, completion and production activities for the Cascade East Wells WR 206 No.6

and 7 and their associated jumper connectors would not be located within any of the areas

of known communities: Alaminos Canyon, East Breaks, Garden Banks, or Green Canyon

(http://www.gomr.mms.gov/homepg/regulate/environ/knowndwbenthic.pdf).

Site-specific seafloor conditions were found that the abundance and diversity of infauna

in the seafloor sediments was low. The soft bottom benthic community was dominated

by polychaetes. No active faults, gas venting, or hard bottom conditions were identified

within the Cascade Development Area. There is no potential for encountering

chemosynthetic communities in the area planned for Cascade Development Wells.

19(b).4 Offshore Environments

The Submerged Lands Act of 1953 and the Outer Continental Shelf Lands Act of 1953

affirms the federal claim to the lands of the Outer Continental Shelf (OCS) which have

been addressed in previous section and these Acts outline the Federal responsibility over

the submerged lands of the OCS and authorizes the Secretary of the Interior to lease those

lands for mineral development

(http://www.boemre.gov/AboutBOEMRE/FedOffshoreLands.htm).

Under a Presidential Proclamation (5030) in 1983 by Ronald Reagan, a U.S. Exclusive

Economic Zone was established extending 200 nautical miles (370 km) from the

coastline. About 15 percent of the Zone lies on the continental shelf, 10-15 percent lies

on the continental slope, and the remaining 70-75% is the Abyssal Plain in deepwater.

Sigsbee Escarpment

The project area consists of three geomorphologic provinces: the Lower Continental

Slope, the Upper Continental Rise, and the Sigsbee Escarpment (GEMS 2007). The

Sigsbee Escarpment marks the edge between the continental slope and rise of the GoM

and is the seaward limit of the northern Gulf regional salt province. This escarpment

extends for more than 370 miles and is formed by the underlying salt tectonics (Lee and

George 2004). The escarpment includes large submarine canyons, numerous small

submarine canyons and gullies, and large slumps. Relief along the escarpment can range

from a few hundred to more than 3,300 feet (Lee and George 2004). Seafloor gradients

in the Cascade / Chinook Development range from nearly 0o to approximately 70° along

the steeper portions of the Sigsbee Escarpment (GEMS 2007).

The water depth of Cascade / Chinook blocks 206, 249, 250, 425, 426, 469, and 470 is

between 8,200 and 8,800 feet (2,500 to 2,682 m). The Sigsbee Escarpment runs through

a portion of Block 205, resulting in a dramatic change in bathymetry from 8,000 feet to

5,800 feet (2,440 to 1,770 m) in less than two miles (3.22 km) (Petrobras America Inc.

2006). The locations of the proposed Cascade Wells WR 206 No. 6 and 7 are in Walker

Ridge Block 206. Details about the seabed of the project site can be found in the seafloor

and geologic assessment for the Cascade and Chinook Development (GEMS 2007) in

Appendix 2.
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Furrows

The seafloor below the Sigsbee Escarpment in the Cascade / Chinook Development area

is irregular due to seabed furrows and erosion by seafloor currents (GEMS 2007). These

mega-furrows are aligned parallel to the base of the escarpment, and some have been

reported to extend for more than 60 miles (Lee and George 2004). The erosional nature

of the furrows indicates the presence of potentially strong bottom currents along the

Sigsbee Escarpment indicating that bottom currents may occur up to 3.3 feet per second

(100 cm/sec) and higher (Bryant et al. 2004; GEMS 2007).

According to the site-specific geophysical and geotechnical data collected by PAI, in

conjunction with Geoscience Earth and Marine Services (GEMS) in 2007 (see appendix

2a), the seabed in the Cascade Development Area is comprised of furrows and flukes

resulting from seabed currents. Darker areas on the side scan data correspond with

outcrops of firmer strata exposed by erosion due to the periodic strong currents in the

area. The subbottom data confirms the side-scan revealing generally parallel and

continuous clay stratigraphy that is eroded at the seabed. The furrows are irregular

seabed undulations of unclear origin with a typical trough to crest spacing on the order of

50-300 feet (15.2-91.44 m), amplitudes on the order of 10-30 feet (3.05-9.14 m), and

slopes in the range of 5oto 20ofrom horizontal. These furrows are generally trending

northeast to southwest. Approximately 49,000 feet (14,935m) of the Cascade flowline

route is within the furrows. Dense seafloor furrows are present in the southeastern

portion of the Cascade area. The furrows are evident in the multi-beam data as linear

features trending parallel to the escarpment. In general individual furrows average about

100 feet (30.48m) wide and 30 feet (9.14m) deep and have relatively steeply dipping

walls. The furrows are tightly spaced, averaging between 75 and 100 feet (22.86 and

30.48 m) apart.

These furrows also appear to branch and merge with each other. The exact nature of the

seafloor current responsible for the varying appearance of the furrows in this area is not

well understood at this time; however, it is possible that the dominant direction and/or

intensity of the currents may vary over time. There are no hydrocarbon indicators

suggesting hydrocarbon migration or seepage near the planned field development.

Further details concerning the geomorphology of this area can be found in the seafloor

and geologic assessment for the Cascade and Chinook Development (GEMS 2007) as

described in Appendix 2.

19(b).5 Marine Mammals

At least 29 species of cetaceans are known to occur in the GoM including five species

listed as endangered and protected under the Endangered Species Act and all marine

mammals are protected under the marine Mammals Protection Act of 1972 (Mullin, et al

1991). The marine mammals in the GoM comprise seven mysticetes (baleen whales) and

21 odontocetes (toothed whales and dolphins) as identified in Table 19-3. Other marine

mammals include one introduced pinniped (California sea lion; Zalophus californianus)

and one sirenian species (West Indian manatee; Trichechus manatus) (Davis, Evans and

Wursig 2000). The West Indian manatee is divided into two subspecies: the Antillean
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manatee (T. manatus manatus), which is not known to exist in the northern GoM, and the

Florida manatee (T. manatus latirostris), which occurs mainly in Florida waters, but will

travel to the west coast of Louisiana in extreme cases (US Fish and Wildlife Service

[USFWS] 2000).

Table 19-3 – Marine Mammals in GoM

Common Name

Scientific

Name Status

Abundance

and

Distribution1

Estimated

Number of

Individuals2

Likelihood of Occurring

Near Site3

Mysticetes

Northern right

whale

Eubalaena

glacialis

E Rare and

likely of

accidental

occurrence.

Extralimital Unlikely

Blue whale Balaenoptera

musculus

E Rare and

likely of

accidental

occurrence.

Extralimital Unlikely

Fin whale Balaenoptera

physalus

E Rare and

likely of

accidental

occurrence.

Rare Unlikely

Sei whale Balaenoptera

borealis

E Rare and

likely of

accidental

occurrence.

Rare Unlikely

Bryde’s whale Balaenoptera

edeni

* Common;

sightings

occurred only

near 100-

meter (328-

foot) isobath

40 Unlikely

Minke whale Balaenoptera

acutorostrata

* Although not

coastal they

rarely

venture more

than 169 km

(105 miles)

from shore.

Rare Unlikely

Humpback whale Megaptera

novaeangliae

E Rare and

likely of

accidental

occurrence.

Rare Unlikely

Sowerby’s Beaked

whale

Mesoplodon

bidens

Rare and

likely of

accidental

occurrence.

Extralimital Unlikely
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Common Name

Scientific

Name Status

Abundance

and

Distribution1

Estimated

Number of

Individuals2

Likelihood of Occurring

Near Site3

Odontocetes

Sperm whale Physeter

macrocephalus

E Common;

occurs from

900 to 2,000

meters (2,953

to 6,562 feet)

and deeper

with possible

resident

population

near

Mississippi

River delta.

1,349 Likely

Pygmy or dwarf

sperm whale

Kogia spp. * Widely

distributed in

deep waters

of Gulf.

742 Likely

Beaked whale Ziphiid * Widely

distributed

from 1,000

meters (3,280

feet) and

beyond.

241 Likely

Pygmy killer

whale

Feresa

attenuata

* Uncommon

but widely

distributed in

Northern

Gulf.

408 Possibly

Pilot whale Globicephala

sp.

* Uncommon

on slope.

2,388 Unlikely

Risso’s dolphin Grampus

griseus

* Frequently

sighted along

between 200

and 1,000

meters (656

and 3,280

feet), but

concentrated

near

Mississippi

River delta.

2,169 Possibly

Melon-headed

whale

Peponocephala

electra

* Uncommon in

northeastern

Gulf but

possible in

deeper

waters.

3,451 Possibly
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Common Name

Scientific

Name Status

Abundance

and

Distribution1

Estimated

Number of

Individuals2

Likelihood of Occurring

Near Site3

Bottlenose

dolphin

Tursiops

truncates

* Common;

widely

distributed

between 100

and 750

meters (328

and 2,460

feet).

27,559 Likely

Rough-toothed

dolphin

Steno

bredanensis

* Common;

widely

distributed on

mid-slope.

2,223 Possibly

Striped dolphin Stenella

coeruleoalba

* Most common

cetacean;

widely

distributed on

slope.

6,505

Likely

Pantropical

spotted dolphin

Stenella

attenuata

* Common;

widely

distributed

around 1,000-

meter (3,280-

foot) isobath.

91,321 Likely

Clymene’s dolphin Stenella

clymene

* Common;

widely

distributed in

water depths

from 250 to

5,000 meters

(820 to

16,404 feet).

17,355 Likely

Atlantic spotted

dolphin

Stenella

frontalis

* Common;

widely

distributed on

slope but

rarely beyond

the shelf

edge near

100-meter

(328-foot)

isobath.

30,947 Possibly

Spinner dolphin Stenella

longirostris

* Common;

widely

distributed on

slope.

11,971 Possibly

Fraser’s dolphin Lagenodelphis

hosei

* Uncommon

but widely

distributed.

726 Possibly
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Common Name

Scientific

Name Status

Abundance

and

Distribution1

Estimated

Number of

Individuals2

Likelihood of Occurring

Near Site3

Killer whale Orcinus orca * Uncommon

but mainly

found

southwest of

the

Mississippi

River delta.

133 Unlikely

False killer whale Pseudorca

crassidens

* Uncommon

throughout

Northern

Gulf, but

mainly

southwest of

Mississippi

River delta in

pelagic

waters.

1,038 Unlikely

Source: Davis et al. 2000; MMS 2000; Baumgartner et al. 2001; University of Michigan 2003; and

Department of the Navy 2003; http://www.nefsc.noaa.gov/psb/assesspdfs.html.

Notes:

1

Accurate depth ranges could not be found in the literature but “deep” is probably 1,000 meters (3,280

feet) and deeper.

2

Extralimital: known on the basis of only a few records that probably resulted from unusual wanderings

of animals into the region (Würsig et al. 2000). Rare: present in such small numbers throughout the

region that it is seldom seen (Würsig et al. 2000).

3

The likelihood determination was based on a compilation of surveys that indicated the number of

individuals and occurrences of cetaceans close to the project site (Department of the Navy 2003), as

well as a consideration of the distribution discussed in other literature.

Key:

> = greater than.

* = Protected under the Marine Mammal Protection Act.

E = Endangered under the Endangered Species Act.

km = kilometers.

Six species of whales (northern right [Eubalaena glacialis], blue [Balaenoptera

musculus], fin [B. physalus], sei [B. borealis], humpback [Megaptera novaeangliae]), and

sperm whale [Physeter macrocephalus]), are listed as endangered. All cetaceans

occurring in the GoM, however, are protected under the MMPA of 1972, as presently

amended. Except for the sperm whale, the other endangered cetaceans are known from

only very few sightings and are considered to be rare or of accidental occurrence

(Continental Shelf Associates [CSA] 2000; Table 19-3). While there is no federally

designated critical habitat for endangered cetacean species in the Gulf, the deepwater

region provides important habitat for these and other marine mammals (CSA 2000).

Habitat preference varies with each cetacean type, but seems to be related to water

depths, bottom conditions (Table 19-3; Baumgartner et al. 2001; Davis et al. 2000) and

potential prey (Davis et al 2000). Food stocks may be locally concentrated in nutrientrich areas offshore from the Mississippi River delta, within current eddies, and along

current eddy interfaces (Davis et al 2000). On the continental shelf, the most frequently
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occurring cetaceans are the bottlenose dolphin (Tursiops truncatus), Atlantic spotted

dolphin (Stenella frontalis), and possibly the Bryde’s whale (Balaenoptera edeni; CSA

2000). The majority of cetaceans are typically found in deepwater on the continental

shelf edge and slope, but much less frequently in water depths greater than 2,000 meters

or in anticyclones (warm core rings). It appears that the deepwater cetaceans spend much

of their time resting on the surface and then foraging at great depths (University of

Michigan 2003). A marine resources report developed by the Department of the Navy

(2003) describes the marine mammals of the Eastern GoM including the area around

Warning Area W-92 located in the Central Gulf, north of the Cascade / Chinook

Development. The movements of whales and dolphins are typically associated with

feeding and breeding behavior, with some species (such as the humpback and northern

right whale) making extensive annual migrations for breeding and mating (Department of

the Navy 2003). In the GoM, oceanic cetaceans tend to aggregate around areas where the

distribution and abundance of prey is the highest such as cyclonic eddies (Department of

the Navy 2003). The high slopes and rugged topography of the Sigsbee Escarpment, as

well as the occurrence of strong currents, may provide conditions that are conducive to

nutrient upwelling. Infrequent but sometimes large groups of cetaceans have been

sighted near the project area (Department of the Navy 2003) but the surveys are limited

and there is not enough information available to determine if cetaceans regularly use the

area for feeding or other purposes.

The sperm whale is the only endangered odontocete species considered common and

perhaps a resident in certain deepwater areas. Sperm whales have been observed

throughout the GoM from the upper continental slope near the 100-meter isobath and

beyond the seaward extent of the U.S. Exclusive Economic Zone (NOAA 2002). Based

on their distribution, sperm whales show a preference for continental margins, sea

mounts, and areas of upwelling where food is abundant (MMS 2001). They are also

known to dive for two hours up to depths of 10, 498 feet (3,200 meters) or more to feed

on squid (MMS 2000). The most well-known congregations occur along the shelf edge

and slope in the vicinity of the Mississippi River Delta trough in water depths of 1,640 to

6,562 feet (500 to 2,000 meters). Data deficiencies remain, however, such as the duration

of time spent in an area, their patterns of movement and their preferred feeding areas.

The location of cyclonic features (cold core rings) in the GoM produces nutrient-enriched

waters, which appears to be an important factor in determining cetacean distribution

(MMS 2001). In general, cetaceans are found along the continental slope in areas of

cyclonic circulation and confluence zones, which are high in primary productivity. Since

cyclones in the GoM are dynamic, cetaceans will likely move in response to the

movement of prey associated with these hydrographic features. Pelagic dolphin species

(primarily bottlenose and Atlantic spotted) and possibly Bryde’s whale, appear to occur

more often in relatively shallow waters north of the influence of these cyclonic features

(Baumgartner et al. 2001; Davis et al. 2000).
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19(b).6 Sea Turtles

Five sea turtles, all federally protected under the ESA, are known to occur in the GoM.

The Kemp’s ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), and

hawksbill (Eretmochelys imbricata) are listed as endangered; the loggerhead is listed as

threatened (Davis et al. 2000). The green sea turtle (Chelonia mydas) is listed as

threatened; except for breeding populations in Florida, which are listed as endangered.

See Table 19-4.

Table 19-4 – Sea Turtles in GoM

Common

Name

Scientific

Name Status

Abundance and Distribution in

Gulf of Mexico

Likelihood of

Occurring

Near Site

Loggerhead Caretta caretta T Common; widely distributed on Eastern

Gulf shelf and slope; mostly near 328 ft

(100 m) but some in water deeper than

3,280 ft (1,000 m).

Possibly

Leatherback Dermochelys

coriacea

E Common; widely distributed on shelf and

slope.

Possibly

Kemp’s

ridley

Lepidochelys

kempii

E Occasional; occurs mainly in coastal areas. Unlikely

Hawksbill Eretmochelys

imbricata

E Occasional; occurs mostly in shallow

lagoons and coral reefs

Unlikely

Green Chelonia mydas T/E Common in coastal areas. Unlikely

Source: Davis et al., 2000.

Key:

Common = Estimated abundances above 200 individuals.

T = Threatened.

E = Endangered.

Most sea turtles, with the possible exception of the leatherback, which is the most pelagic

of the group, vary in their distributions depending on their life stage. Hatchlings actively

swim away from their nesting beaches to zones of water mass convergence and/or

floating Sargassum, which provide prey and shelter. Most then drift within prevailing

oceanic currents for a number of years. Once juveniles reach a certain age/size range,

they leave the pelagic habitat and travel to shallow waters on the continental shelf (CSA

2000).

It is not known if adult sea turtles or juveniles in floating Sargassum mats would occur in

the vicinity of the proposed project. Based on what is known about the distribution of

loggerhead and leatherback sea turtles (Table 19-4) it is possible that adults of these

species could be found in the area as transients. Refer to MMS (2006a) and NOAA

(2002) for the current status of knowledge and life history information pertaining to

marine turtles occurring in the Gulf of Mexico.

Sea turtles nest on multiple beaches along the Texas coast, though Padre Island National

Seashore is the only area in Texas where all five species that occur in the Gulf of Mexico

have been recorded nesting. Kemp’s Ridley is the most common nesting species of sea
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turtle in Texas, and the species’ nests were recorded at Bolivar Peninsula, Galveston

Island, Brazoria County – North of Surfside, Surfside Beach, Bryan Beach, Matoagorda

Peninsula, Matagorda Island, San Jose Island, Mustang Island, North Padre Island, Padre

Island National Seashore, South Padre Island, and Boca Chica Beach in 2010.

Loggerhead sea turtle and green sea turtle nests were also documented on Padre Island

National Seashore in 2010 (U.S. National Park Service 2010). No significant colonies of

nesting sea turtles have been documented in Louisiana or Mississippi (USFWS 2010).

However, sea turtles may rarely nest on beaches of these states; for example, a

loggerhead sea turtle nest was discovered on a man-made beach in Biloxi, Mississippi in

1990 (Hoggard 1991).

19(b).7 Pelagic Birds

Pelagic birds are species adapted to life within marine environments spending much time

migrating and foraging offshore at sea; often over deep ocean waters exceeding 656 feet

(200 meters) in depth. Pelagic birds include penguins (Sphenisciformes), albatross

(Albatrosses), petrels (Procellaridae), and pelicans (Pelecaniformes). All pelagic birds

are protected by the Migratory Bird Treaty Act (USFWS 2002).

Predominate species seen in offshore areas of the GoM include terns (Sterna), stormpetrels (Hydrobatidae), jaegers (Stercorarius), and laughing gulls (Larus atricilla).

Surveys have determined water depth influences the distribution of species groups and

individual species of seabirds, which vary both spatially and seasonally (MMS 1996).

They live far from land most of the year, roosting on the water surface, except at breeding

time when they return to nesting areas along coastlines. Environmental parameters, such

as sea surface productivity, also affect seabird distribution (Davis et al. 2000). The

highest species diversity of seabirds has been associated within cyclonic eddies, while the

lowest species diversity occurred on the continental shelf (Davis et al. 2000). Other

evidence shows that seabird groups tend to concentrate at fronts defined by steep

temperature gradients (Ribic et al. 1997).

Seabirds, especially migrating birds, are affected by offshore platforms in many ways.

For most species, platforms provide a suitable stopover habitat. Birds that are fatigued

from long migrations may use platforms and vessels to rest and feed. Many shorter

distance migrants that spend the winter along the Gulf coast (such as wrens and sparrows)

inadvertently overshoot the coastline during nocturnal migratory flights and end up over

GoM waters. These birds, which are evolutionarily ill equipped to deal with the rigors of

overwater migration, are among the heaviest users of platforms during certain seasons

and the availability of platforms to rest probably enabled many individuals to return to

land successfully (Russell 2005).

Populations and distributions of these birds inhabiting offshore waters (outer continental

shelf and abyssal areas) in the central GoM have not been well studied. Due to the

proposed project’s distance offshore, it is not known whether migratory or threatened or

endangered bird species occur near the project’s vicinity or would use the area during

migration. Presence of these birds appears to be a function of sea surface properties:

salinity, plankton, and other prey.
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19(b).8 Marine Fisheries

Offshore waters of the GoM support many economically and ecologically important

shellfish and finfish fisheries. Marine habitats in the GoM support a varied and abundant

fish fauna. Species found in a given area are related to variable ecological factors at the

site, including salinity, primary productivity, and bottom substrate. These factors differ

widely across the GoM. In addition, the pelagic, floating brown algae, Sargassum, has

been found to support a diverse community of marine organisms including more than 100

species of fishes, as well as more than 170 species of invertebrates and four species of sea

turtles around the world (Coston-Clements et al. 1991). Fish species associated with

Sargassum in the North Atlantic and Gulf of Mexico are listed in Table 19-5. The

primary assemblages that could occur near the proposed Cascade well sites include

commercial pelagic species and deepwater finfish. The following sections provide

general information on these resources, along with information associated with

commercial and recreational pelagic fisheries.

Table 19-5 - Fish Species Associated with Sargassum

Species Common Name

Carcharhinus falciformis Silky shark

Carcharhinus limbatus Blacktip shark

Carcharhinus longimanus Oceanic whitetip shark

Sardinella aurita Spanish sardine

Cypselurus furcatus Spotfin flyingfish

Exocoetus obtusirostris Oceanic-two-wing flyingfish*

Hemiramphus brasiliensis Ballyhoo

Hyporhamphus unifasciatus Silverstripe halfbeak

Parexocoetus brachypterus Sailfin flyingfish*

Epinephelus inermis Marbled grouper*

Rachycentron canadum Cobia*

Caranx bartholomaei Yellow jack*

Caranx crysos Blue runner*

Caranx hippos Crevalle jack*

Caranx latus Horse-eye jack*

Caranx ruber Bar jack*

Decapterus macarellus Mackerel scad*

Decapterus punctatus Round scad*

Decapterus tabl Roughear scad*

Elagatis bipinnulata Rainbow runner*

Naucrates ductor Pilotfish
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Species Common Name

Selar crumenophthalmus Bigeye scad*

Seriola dumerili Greater amberjack*

Seriola fasciata Lesser amberjack*

Seriola rivoliana Almaco jack*

Seriola zonata Banded rudderfish*

Trachurus lathami Rough scad*

Coryphaena hippurus Dolphin*

Rhomboplites hippurus Vermilion snapper*

Lobotes surinamensis Tripletail*

Mugil cephalus Striped mullet*

Mugil curema White mullet*

Sphyraena barracuda Great barracuda*

Bodianus pulchellus Spotfin hogfish*

Thalassoma bifasciatum Bluehead*

Unidentified Trichiuridae Snake mackerel*

Acanthocybium solandri Wahoo*

Euthynnus alleterattus Little tunny

Katsuwonus pelamis Skipjack tuna

Thunnus albacares Yellowfin tuna

Thunnus atlanticus Blackfin tuna

Xiphias gladius Swordfish*

Istiophorus platypterus Sailfish*

Makaira nigricans Blue marlin*

Tetrapturus albidus White marlin*

Source: Coston-Clements et al. 1991.

Note:

* = early life stage present (i.e. egg, larvae or juvenile).

Pelagic Fish

Fish species likely to be found in the offshore waters near the project site in the Walker

Ridge Protraction Area are characterized as oceanic pelagic. Oceanic pelagic species

occur mainly in deep, open ocean waters offshore from the shelf break. Oceanic pelagics

occur throughout the GoM, especially at or beyond the shelf edge. They are reportedly

associated with mesoscale hydrographic features such as fronts, eddies, and

discontinuities. Common oceanic pelagic species include: tunas and wahoo

(Scombridae), marlins and sailfish (Istiophoridae), swordfish (Xiphias gladius), dolphins
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(Coryphaenidae), and mako sharks (Isurus sp.). Refer to Benfield and Shaw (2005) for

detailed information on the presence of pelagic fish.

Deepwater Fish

In addition to the large pelagic species, predatory species such as halfbeaks, flyingfishes,

driftfishes, and lesser known pelagics such as snake mackerels (Gempylidae), ribbonfish

(Trachipteridae) and escolar (Lepidocybium flavobrunneum), occur throughout the GoM;

especially at or beyond the shelf edge (MMS 2001). Lantern fish (Myctophids) are

among the most abundant of oceanic fish. Almost all species of myctophids vertically

migrate through the water column to feed in the upper zones (492 feet (150 m)) during

the night and deeper zones (984 to 295 feet (300 to 900 m)) during the day.

Other fish exist in the mesopelagic zone (656 to 3,281 feet (200 to 1,000 m)) and migrate

in the water column, moving each night to correspond with feeding cycles. Their feeding

habitat ranges from depths of 1,312 to 2,625 feet (400 to 800 m) into epipelagic waters,

sometimes reaching the surface (CSA 2000).

Demersal fish are those having either direct contact with the substrate or hovering above

it. The most extensive surveys of demersal fish were conducted in the 1980s from two

MMS sponsored studies. The data showed a decline in diversity with depth although this

was not statistically significant (CSA 2000).

Bathypelagic fish inhabit waters greater than 3,280 feet (1,000 meters) and seldom

migrate into shallower waters. These fish have developed similar physiological

adaptations, similar to the mesopelagic fish, in order to live in the deepwater

environment. No studies to date have directly examined the bathypelagic fish in the Gulf

(CSA 2000). It is possible that important pelagic species and other deepwater fish occur

in or near the Cascade / Chinook development site particularly given the topographic

relief provided by the Sigsbee Escarpment.

19(b).9 Commercial and Recreational Fisheries

An estimated 2,000 species of fish are known in the GoM (MMS 2001) but only a small

fraction of those are commercially harvested. Commercially important pelagic fish in the

Gulf include dolphin, sharks, snake mackerels (Gempylus serpens), swordfish, tunas, and

wahoo (Acanthocybium solanderi; CSA 2000). Commercial fishing efforts resulting in

the highest economic returns for pelagic species include: (1) upper-ocean trolling for

billfish, (2) mixed-depth long-lining for yellowfin tuna, and (3) deep-bottom trawling for

royal red shrimp. However, the only type of vessel that would likely fish near the project

site is related to the commercial pelagic longline fishery (CSA 2002).

The gear associated with this fishery consists of a mainline of 700-pound or greater test

monofilament that typically ranges in length from 10 to 45 miles (16 to 72 km). At

regular intervals along the mainline, bullet-shaped floats are suspended and long sections

of the gear are marked by radio beacons. Long lines of 200 to 400-pound test

monofilament that are typically 100 to 200 feet in length are suspended from the mainline

and set with baited hooks (Waring et al. 2007).
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Longline sets targeting tunas are typically set at dawn and soak throughout the day with

recovery near dusk. Those sets targeting swordfish are generally set at night. The total

amount of time the gear remains in the water including set, soak, and haul times is

typically 10-14 hours (Waring et al. 2007).

The total number of vessels that reported fishing in the longline pelagic fishery in the

GoM in 2004 was 69. However, the total fishing effort (i.e., number of hooks set) has

increased throughout the 1990s and into this decade. The total number of hooks set in

2004 were 4.08 million, which represented 5,410 longline sets (Waring et al. 2007). The

pelagic longline fishery occurs year round, both inside and outside the Exclusive

Economic Zone, from Florida to Texas (Waring et al. 2007).

Commercial landings of oceanic pelagic species of interest for Louisiana, Texas, and

Mississippi are summarized in Table 19-6. The latest data available from NOAA

Fisheries is annual landings by species for 2010 (NOAA 2010

http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html).

In 2010, more than 2.26 million pounds of yellowfin tuna were caught from the Gulf with

439,904 pounds off Louisiana (worth $1.4 million) accounting for nearly 20% of the total

catch in the region down from 95% in 2005. According to the most recent data available

from NOAA Fisheries Service, other tunas landed in the region for 2010 included

albacore (Thunnus alalunga), little tunny (Euthynnus alletteratus), and bigeye (T. obesus)

(NOAA 2010 http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html).

Table 19-6 - Commercial Landings of Oceanic Pelagic Species

Species Pounds Value ($)

Louisiana

Shark (various species) 1,074,253 706,340

Blackfin tuna NA NA

Bluefin tuna 35,787 170,697

Yellowfin tuna 439,904 1,473,663

Swordfish 259,537 486,786

Texas

Shark (various species) 4,837 3,112

Blackfin tuna 327 504

Bluefin tuna N/A N/A

Yellowfin tuna 815 3,257

Swordfish 2,066 4,845

Mississippi

Shark (various species) 3,676 1,103

Source: NOAA 2010.

Significant fishing pressure has occurred to coastal and pelagic sharks as they are most

often part of the bycatch from longline fisheries. A comparison between 2005 and 2010

commercial landings of ocean pelagic species reported in Table 19-6 reveals a decrease

in 4 of the 5 species for Louisiana fishing, decrease in the one species reported for
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Mississippi, and a slight increase in one species, blackfin tuna in Texas fishing with a

significant decrease in another species, yellowfin tuna for Texas commercial fishing.

Yellowfin tuna commercial landings have decreased by 80% in Louisiana and over 95%

in Texas. Pelagic species range widely in the upper ocean zones and often travel over

entire ocean basins. Coastal-pelagics are intermediate; occurring both inshore and

beyond the continental shelves, but are not known to move across the oceans. Deepdwelling species of the continental slope and beyond to 1,804 feet (550 m) include most

cat sharks (Scyliorhinidae), and gulper sharks (Centrophoridae), in water depths ranging

between 328 to 3,937 feet (100 and 1,200 m). Large commercial shark fisheries have

occurred primarily off Louisiana (19.2% of 1998 landings in U.S.; Buck 2000).

Of the 42 managed species in the Gulf, fourteen are known to have at least one life

history stage occurring in deepwater (MMS 2001) which include sharks. Sharks

occurring in deepwater include blacktip (Carcharhinus limbatus), bull (Carcharhinus

leucas), dusky (Carcharhinus obscurus), silky (Carcharhinus falciformis), tiger

(Galeocerdo cuvier), Atlantic sharpnose (Rhizoprionodon terraenovae), and longfin

mako (Isurus paucus; MMS 2001). No commercial fishing is known for any deepdwelling shark species except for blacktip sharks, which also occur closer to shore. Other

managed pelagic species and their known habitat requirements and spawning areas are

provided in Table 19-7.
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Table 19-7 - Pelagic Species and their Known Habitat Requirements and Spawning

Areas

Common and

Species Names Habitat Preferences

Likelihood of

Occurring

Near Site

Atlantic swordfish

(Xiphias gladius)

Usually found in surface waters, but occasionally diving as

deep as 650 meters.

Possibly

Blue marlin (Makaira

nigricans)

Found at great distances from the continents as well as

coastal regions, near deep waters such as near the

Mississippi River.

Likely

White marlin

(Tetrapturus

albidus)

Usually found in water over 100 meters deep; often

associated with upwellings and weed lines, and regions with

benthic geographic features such as drop-offs, canyons, and

shoals.

Likely

Sailfish (Istiophorus

platypterus)

Most densely distributed in waters close to coasts and

islands but spawning and larvae are known to occur in 100

meters and deeper.

Possibly

Yellowfin tuna

(Thunnus albacares)

Have been found to dive as deep as 1,100 meters though

they generally swim at much shallower depths, averaging 75

meters.

Possibly

Skipjack tuna

(Katswonus pelamis)

Occur beyond the 200 meter contour. Possibly

Bluefin tuna

(Thunnus thynnus)

Swim at depths of 200 meters while diving to depths of

approximately 1,000 meters.

Possibly

Sources: NOAA 1999; Florida Museum of Natural History 2007; MMS 2001; Nakamura 1985; Dagorn et

al. 2006; Block et al. 2001

19(b).10 Protected Fish Species

Protected fish species within the Gulf of Mexico include the smalltooth sawfish (Pristis

pectinata), which was once common from Texas to Florida and now only found in two

critical habitats: sheltered bays north of Fort Meyers, Florida and the southern tip of

Florida (http://www.nmfs.noaa.gov/pr/species/fish/smalltoothsawfish.htm.) No federally

listed fish species are predicted to occur in proximity to the proposed Cascade well sites.

Table 19-8 lists candidate fish species currently not protected under the ESA but

concerns about their status indicate they may warrant listing in the future (NOAA 2007b).

Deepwater species are speckled hind (Epinephelus drummondhayi) and Warsaw grouper

(Epinephelus nigritus), which inhabit steep and rocky ledges on the continental slope

with depths to approximately 1,800 feet (525 meters); but are not known to occur in the

project area (Heemstra and Randall 1993; MMS 2001).
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Table 19-8 – Protected Fish and Marine Mammals Species

Candidate Species (year added) Scientific Name

Dusky shark (1997) Carcharhinus obscurus

Sand tiger shark (1997) Odontaspis taurus

Night shark (1997) Carcharhinus signatus

Speckled hind (1997) Epinephelus drummondhayi

Warsaw grouper (1997) Epinephelus nigritus

Nassau grouper (1991) Epinephelus striatus

Gulf sturgeon (1991) Acipenser oxyrinchus desotoi

Shortnose sturgeon (1967) Acipenser brevirostrum

Smalltooth sawfish (2003) Pristis pectinata

Blue whale (1970) Balaenoptera musculus

Finback whale (1970) Balaenoptera physalus

Humpback whale (1970) Megaptera novaeangliae

North Atlantic right whale (1970) Eubalaena glacialis

Sei whale (1970) Balaenoptera borealis

Sperm whale (1970) Physeter macrocephalus

Source: NOAA 2007b and 2011

19(b).11 Essential Fish Habitat

Essential Fish Habitat (EFH), defined by National Marine Fisheries Service (NMFS) as

waters and substrate necessary for fish to spawn, breed, feed, and grow to maturity, was

previously identified throughout the Gulf of Mexico. The Generic Amendment #3 to all

Gulf of Mexico Fishery Management Plans reduced the extent of EFH by removing EFH

designation from waters between 600 feet (183 meters or 100 fathoms) and the seaward

limit of the Exclusive Economic Zone (as deep as 10,499 feet (3,200 meters). Due to the

wide variation of habitat requirements for all life history stages of managed fish, essential

fish habitat (EFH) for the GoM includes all estuarine and marine waters and substrates

from the shoreline to the 100 fathom contour located along the break of the continental

shelf (GoM Fishery Management Council 2005). The Department of the Navy (2003)

contains a good description of these shelf edge features, which range in water depths

from 174 to 427 feet (53 to 130 m), but are located at least 70 miles (112.7 km) north of

the project site. The Walker Ridge block, containing the project site, no longer has a

blanket designation as EFH but does retain EFH designation for some specific species,

including many highly migratory species such as sharks, tunas, swordfish, and sailfish.

Because of the broad designations associated with EFH, Habitat Areas of Particular

Concern HAPCs) have been designated to help focus EFH conservation priorities.
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NOAA’s web site http://www.habitat.noaa.gov/protection/efh/habitatmapper.html maps

EFH for designated species including bluefish, Although generally small areas within the

EFH, HAPCs provide extremely important ecological functions and/or are considered to

be especially vulnerable to degradation (McKay et al. 2002). HAPC in the Northwestern

GoM are identified as: East and West Flower Garden Banks, Stetson Bank, Sonnier

Bank, MacNeil Bank, 29 Fathom, Rankin Bright Bank, Geyer Bank, McGrail Bank,

Bouma Bank, Rezak Sidner Bank, Alderice Bank, and Jakkula Bank (Federal Register

Notice 2005). All of these areas are greater than 100 miles (161 km) from the proposed

development.

19(b).12 Social and Economic Conditions

This section summarizes the social and economic conditions around the proposed

onshore support facilities and other ports potentially used by the Cascade development.

The project area would likely include the use of onshore support facilities in two states:

Louisiana (primary) and Texas (secondary). Port Fourchon, Louisiana would serve as the

primary onshore support base. Shuttle tankers would transport crude from the FPSO to

terminals located in Texas, Louisiana, and Mississippi, and it may be more likely that

terminals in Louisiana and Texas will be used more frequently than Mississippi because

there are more with larger capacities. Wastes would be brought to shore at several

existing facilities in Galiano, Louisiana (primary) and Texas (secondary). Refer to

Section 16 for additional details on Onshore Support Facilities Information.

Population

The population near the Gulf Coast has been increasing steadily since the 1970s. From

2000 until 2030, the region is projected to experience a doubling of the population (MMS

2006a). Increased interest in deepwater energy production will continue to influence this

trend. For every million dollars invested in offshore projects, 20 jobs are created and for

every 10 jobs created offshore, 37 jobs are created onshore (MMS 2001) therefore, every

million dollars invested creates 74 jobs onshore. The MMS estimates an average

deepwater project would require approximately 400 employees, both on and offshore.

These employees are expected to be drawn from the current labor force residing in the

GoM coastal region (MMS 2001). In addition, employment demands from outside of the

GoM coastal area may also be required, creating in-migration of skilled labor. Port

Fourchon has seen a decrease in unemployment since 1990; largely due to the boom in

the offshore energy industry during the 1990s (MMS 2001). The region’s coastal

economic zone employment projections show an across the board increase,

approximately 45%, including employment in the oil and gas industry and related

services (MMS 2006a).

In general, the FPSO vessel would be staffed with approximately 35-45 personnel during

normal production operations. Others would be employed on the shuttle vessels, drilling

rigs, and offshore construction vessels. The total number employed offshore on the

Cascade / Chinook development would not approach a level posing a significant impact

to any particular labor market.
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The population numbers and employment by industry for the affected states of Texas,

Louisiana, and Mississippi, with emphasis on counties and parishes where onshore

support facilities for the project may be located, are described below. Data for this

section was obtained from the 2010 U.S. Economic Census, which was the most recent

U.S. Economic Census completed at the time of preparing this supplemental DOCD, as

well as the most recent (December 2010) Bureau of Labor Statistics unemployment

statistics.

Texas

As of the 2010 U.S. Economic Census, approximately 24.2% of the total Texas

population (25,145,561) lived in coastal counties (6,078,043). In Texas, refineries that

are being considered for the receipt of crude oil from the project are located in Corpus

Christi (Nueces County), Freeport (Brazoria County), Houston-Galveston (Harris and

Galveston counties), and Port Arthur-Beaumont (Jefferson County). The population

numbers in these counties from the 2010 U.S. Economic Census are presented in Table

19-9.

Table 19-9 Population in Counties Where Onshore Support Facilities may be

Located

County Population

Nueces County 340,223

Brazoria County 313,166

Harris County 4,092,459

Galveston County 291,309

Jefferson County 252,273

Source: U.S. Census Bureau 2010

Based on the 2010 Bureau of Labor Statistics , the top three industries in Texas, in terms

of the number of people employed, are business administration (1,741,210 people), retail

trade (1,106,390 people) and food preparation (860,620 people) (U.S. Bureau of Labor

Statistics 2011). Construction, including mining, quarrying, and oil and gas extraction

employed 519,040 people, and manufacturing, which includes petroleum refining,

employed 623,680 people as of 2010 (U.S. Bureau of Labor Statistics 2011). The top

three industries by number of paid employees for each five analyzed Texas counties are

presented in Table 19-10.
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Table 19-10 Top Three Industries by Number of Paid Employees in Texas Counties

Where Onshore Support Facilities may be Located

County Industry

Number of Paid

Employees

Nueces County

Health care and social assistance 24,413

Retail trade 16,877

Accommodation and food services 15,167

Brazoria County

Manufacturing 13,787

Retail trade 11,791

Accommodation and food services 7,330

Harris County

Administrative and support and waste

management and remediation services 240,164

Health care and social assistance 205,171

Retail trade 183,618

Galveston County

Health care and social assistance 14,414

Accommodation and food services 12,643

Retail trade 10,790

Jefferson County

Health care and social assistance 17,840

Manufacturing 15,460

Retail trade 14,764

Source: U.S. Census Bureau 2007

The statewide unemployment in Texas was 8.0% in December of 2010. Brazoria County

(8.8%), Harris County (8.3%), Galveston County (9.2%), and Jefferson County (11.5%)

all had higher unemployment rates than the state of Texas overall. Only Nueces County

had a lower unemployment rate (7.9%) (U.S. Department of Labor 2010).

Louisiana

As of the 2010 U.S. Economic Census, approximately 19.7% of the total Louisiana

population (4,533,372) lived in coastal counties (892,397). In Louisiana, refineries that

are being considered for the receipt of crude oil from the project are located in Lake

Charles (Calcasieu Parish), Baton Rouge (West Baton Rouge Parish and East Baton

Rouge Parish), the Lower Mississippi River (St. Charles Parish), and Port Fourchon

(Lafourche Parish) which would also serve as the project’s primary onshore support base.

The population numbers in these five parishes from the 2010 U.S. Economic Census are

presented in Table 19-11.
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Table 19-11 Population Numbers in Louisiana Parishes Where Onshore Support

Facilities may be Located

Parish Population

Calcasieu Parish 192,768

West Baton Rouge Parish 23,788

East Baton Rouge Parish 440,171

St. Charles Parish 52,780

Lafourche Parish 96,318

Source: U.S. Census Bureau 2010

Based on the 2010 Bureau of Labor Statistics, the top three industries in Louisiana in

terms of the number of people employed are business administration (290,970 people),

retail trade (198,990 people) and food services (160,260) (U.S. Bureau of Labor Statistics

2011). Mining, quarrying, and oil and gas extraction employed 112,430 people, and

manufacturing, which includes petroleum refining, employed 110,730 people as of 2010

(U.S. Bureau of Labor Statistics 2011). The top three industries by number of paid

employees for each for the five analyzed parishes are presented in Table 19-12.

Table 19-12 Top Three Industries by Number of Paid Employees in Louisiana

Parishes Where Onshore Support Facilities may be Located

Parish Industry

Number of Paid

Employees

Calcasieu Parish

Retail trade 13,413

Health care and social assistance 11,022

Accommodation and food services 8,997

West Baton Rouge

Parish

Construction 2,422

Manufacturing 1,624

Retail Trade 1,421

East Baton Rouge

Parish

Retail trade 38,780

Health care and social assistance 38,732

Construction 23,193

St. Charles Parish

Manufacturing 5,859

Construction 3,782

Retail trade 2,973

Lafourche Parish

Retail trade 6,632

Manufacturing 4,926

Administrative and support and waste

management and remediation services 4,340

Source: U.S. Census Bureau 2011

The statewide unemployment in Louisiana was 7.2% in December of 2010. Calcasieu

Parish (6.7%), East Baton Rouge Parish (6.8%), St. Charles Parish (6.3%), and Lafourche
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Parish (4.9%) all had lower unemployment rates than the state of Louisiana overall. Only

West Baton Rouge Parish had a higher unemployment rate (8.1%) (U.S. Department of

Labor 2010).

Mississippi

As of the 2010 U.S. Economic Census, approximately 14.4% of the total Mississippi

population (2,967,297) lived in coastal counties (426,536). In Mississippi, only one

refinery in Pascagoula, Jackson County is being considered for the receipt of crude oil

from the project. Jackson County had a population of 139,668 people in 2010 (U.S.

Census Bureau 2007).

The top three industries in Mississippi in terms of the number of paid employees are

business administration (165,670), retail sales (113,710), and manufacturing which

includes petroleum refining (101,700 people). Mining, quarrying, and oil and gas

extraction employed 5,923 people in Mississippi as of 2007. Similarly, the top three

industries in Jackson County in terms of the number of paid employees are

manufacturing (10,000 – 24,999 people), retail trade (5,356 people), and health care and

social assistance (5,343 people) (U.S. Census Bureau 2007).

The statewide unemployment rate in Mississippi was 9.7% in December of 2010. Jackson

County had a slightly lower unemployment rate of 9.5% (U.S. Department of Labor

2010).

Minority and Lower Income Groups

There are areas of low income communities and areas of significant minority populations

within the GoM region. Coastal cultures and populations include the Hispanic enclaves

of south Texas, the Acadian “French Triangle” of south Louisiana, Amerindian peoples

such as the Houma of Louisiana, and the Vietnamese communities of coastal Texas,

Louisiana, and Mississippi. The State of Louisiana alone contains numerous cultural

groups of Native American, African, European, Asian, Latin American, and Middle

Eastern origins (MMS 2006a).

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations, mandates that federal agencies identify and

address as appropriate, disproportionately high and adverse human health or

environmental effects that the programs may have on minority and low income

populations.

Information on race, ethnicity, and income characteristics of the affected states of Texas,

Louisiana, and Mississippi, with emphasis on counties and parishes where refineries may

receive crude oil from the project, are described below. At the time of the preparation of

this supplemental DOCD to address the proposed Cascade wells the 2010 U.S. Census

data was still being processed; therefore, 2000 U.S. Census data was used where 2010

data was not yet available.
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Texas

Census data for 2010 reveals that for Texas, the majority (70.4%) of the Texas population

is white, and 37.6% of the population considers itself Hispanic or Latino, regardless of

race. Race and ethnicity data from the 2010 U.S Census for the state of Texas and the

five analyzed counties in Texas are summarized below in Table 19-13.

Table 19-13 Race and Ethnicity Characteristics of the State of Texas and Texas

Counties Where Onshore Support Facilities may be Located

Category

Nueces

C

ounty

Brazoria

C

ounty

Harris

C

ounty

Galv

eston

C

ounty

Jefferson

C

ounty

State

of

T

e

xas

Total Population 340,223 313,116 4,092,459 291,309 252,273 25,145,561

Race and Ethnicity

White 81.5% 70.1% 56.6% 72.5% 52.5% 70.4%

Black or

African

American

4% 12.1% 18.9% 13.8% 33.8% 11.8%

American

Indian

and

Alaska

Native

0.6% 0.6% 0.7% 0.6% 0.5% 0.7%

Asian 1.7% 5.5% 6.2% 3.0% 3.4% 3.8%

Native

Hawaiian

or Pacific

Islander

0.1% - 0.1% 0.1% - 0.1%

Two or

More

Races

2.4% 2.6% 3.2% 2.7% 2.0% 2.7%

Hispanic

or Latino

(of any

race)

60.6% 27.7% 40.8% 22.4% 17.0% 37.6%

Source: U.S. Census Bureau 2011

As of the 2011 U.S. Census, 17.1% of families in Texas lived below poverty level, the

median household income in Texas was $48,286, and 62.0% of the Texas population over

16 years old was in the labor force. Economic characteristics data from the 2010 U.S

Census for the state of Texas and the five analyzed Texas counties are summarized below

in Table 19-14.
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Table 19-14 Economic Characteristics of the State of Texas and Texas Counties

Where Onshore Support Facilities may be Located

Category

Nueces

C

ounty

Brazoria

C

ounty

Harris C

ounty

Galv

eston

C

ounty

Jefferson

C

ounty

State

of T

e

xas

Population

under 18

Years

26.9% 27.8% 28.9% 26.1% 24.7% 27.8%

Population

Over 65 11.6% 9.4% 8.1% 14.0% 13.0% 10.2%

Median

Household

Income in

2009

(Dollars)

41,009 66,516 50,577 55,883 41,087 48,286

Total

Family

Households

116,896 100,617 1,358,313 107,133 92,822 8,269,046

Families

Below

Poverty

Level

Income

19.9% 10.0% 17.1% 14.7% 19.1% 17.1%

Source: U.S. Census Bureau 2011 and http://quickfacts.census.gov/qfd/states/48000.html

Louisiana

Census data on race and ethnicity and economic characteristics in Louisiana from the

2010 U.S. Census was available at the time of preparing this section. The majority of the

state of Louisiana is white (62.6%), with black or African American as the next highest

racial group (32.0%). Only 4.2% of the population considers themselves Hispanic or

Latino regardless of race. West Baton Rouge and East Baton Rouge parishes have a

higher percentage of minorities than the state of Louisiana as a whole. West Baton

Rouge Parish is 60.0% white (40.0% minority) and East Baton Rouge Parish is 48.8%

white (51.2% minority). Like the state of Louisiana as a whole, the highest population

minority group in West Baton Rouge and East Baton Rouge parishes is black or African

American (37.7% West Baton Rouge Paris; 45.3% East Baton Rouge Parish). All of the

five parishes analyzed have a lower percent Hispanic or Latino population than the state

as a whole. Race and ethnicity data from the 2010 U.S Census for the state of Louisiana

and the five analyzed Louisiana parishes are summarized below in Table 19-15.
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Table 19-15 Race and Ethnicity Characteristics of the State of Louisiana and

Louisiana Parishes Where Onshore Support Facilities may be Located

Category

Calcasieu

Parish

W

est Baton

R

ouge

Parish

East Baton

R

ouge

Parish

St. Charles

Parish

Lafourche

Parish

State

of

Louisiana

Total

Population 192,768 23,788 440,171 52,780 96,318 4,533,372

Race and Ethnicity

White 70.8% 60.0% 48.8% 69.2% 79.4% 62.6%

Black or

African

American

24.8% 37.7% 45.3% 26.6% 13.2% 32.0%

American

Indian

and

Alaska

Native

0.5% 0.1% 0.2% 0.3% 2.8% 0.7%

Asian 1.1% 0.3% 2.8% 0.8% 0.7% 1.5%

Native

Hawaiian

or Pacific

Islander

- - - - - -

Two or

More

Races

1.9% 1.1% 1.3% 1.6% 1.8% 1.6%

Hispanic

or Latino

(of any

race)

2.6% 2.3% 3.7% 5.0% 3.8% 4.2%

Source: U.S. Census Bureau 2010

As of the 2010 U.S. Census, 17.6% of families in Louisiana lived below poverty level,

the median household income in Louisiana was $42,460, and 62.7% of the Louisiana

population over 16 years old and was in the labor force. Economic characteristics data

from the 2010 U.S Census for the state of Louisiana and the five analyzed Louisiana

parishes are summarized in Table 19-16.
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Table 19-16 Economic Characteristics of the State of Louisiana and Louisiana

Parishes Where Onshore Support Facilities may be Located

Category

Calcasieu

Parish

W

est Baton

R

ouge Parish

East Baton

R

ouge Parish

St. Charles

Parish

Lafourche

Parish

State

of

Louisiana

Population

under 18 25.8% 25.1% 25.3% 26.9% 24.5% 25.0%

Population

Over 65 12.7% 10.8% 14.0% 9.9% 12.3% 12.3%

Median

Household

Income in

2009

(Dollars)

43,534 45,167 34,958 56,869 47,909 42,460

Total

Families 72,603 8,698 9,790 18,180 33,670 1,644,094

Families

Below

Poverty

Level

Income

16.4% 14.4% 19.3% 12.0% 15.5% 17.6%

Source: U.S. Census Bureau 2010

Mississippi

Census data on race, ethnicity, and economic characteristics in Mississippi from the 2010

U.S. Census was available at the time of preparing this supplemental DOCD. The

majority of the state of Mississippi is white (59.1%), and black or African American

individuals account for the next highest percentage of the population (37.0%). Jackson

County is also predominantly white (72.1%), and black or African American individuals

account for 21.5% of the county’s population. Race and ethnicity data from the 2010 U.S

Census for the state of Mississippi and Jackson County are summarized in Table 19-17.