UNITED STATES GOVERNMENT MEMORANDUM

To: Public Information (MS 5030)
Plans Section, Office of Field Operations (MS 5231)

Public Information copy of Exploration Plan

Control # - N-09670

Type - Initial Exploration Plan

Lease(s) - OCS-G33170 Block - 720 Mississippi Canyon Area OCS-G33171 Block - 721 Mississippi Canyon Area OCS-G33172 Block - 722 Mississippi Canyon Area

Operator - Shell Offshore Inc.

Drill & TA Wells A thru H

DP SEMISUBMERSIBLE

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

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

Ronald O'Connor
Plan Coordinator Description -

Rig Type - Subject: From: November 28, 2012Shell Offshore Inc

. P. O. Box 61933 New Orleans, LA 70161

- 1933
United States of America
Tel +1 504 425 7215
Fax +1 504 425 6747
Email Sylvia.bellone @shell.com

Public Information Copy

November 1, 2012

Ms. Liz Peuler, Section Chief
Bu reau of Ocean Energy Management 1201 Elmwood Park Boulevard New Orleans, LA 70123-2394

Attn: Plans Group GM 1053C

SUBJECT: Initial Exploration Plan OCS-G 33170, 33171 & 33172

Mississippi Canyon Blocks 720, 721 & 722 Offshore Louisiana

Dear Ms. Peuler:

In compliance with 30 CFR 550.211 and NTLs 2008- G04

, 2009-G27 and 2010-N06, giving Exploration Plan guidelines, Shell Offshore Inc. (S hell) requests your approval of this Initial Exploration Plan to drill Well Locations A, B, C, D

, E
, F
, G & H. Operations are targeted to commence in April 2013.

This plan consists of a series of attachments describing our intended operations. The attachments we desire to be exempted from disclosure under the Freedom of Information Act are marked “ Proprietary ” and excluded from the Public Information Copies of this submittal. The cost recovery fee receipt of $2 7,536 .00 is attached to the Proprietary copy of the Plan.

We are also providing a copy of the Shallow Hazards Report, prepared by Gems, Inc. (Project No. 0909-1691b) of the shallow drilling hazards “ Geologic and Stratigraphic Assessment of Blocks 720 (OCS-G 33170), 721 (OCS-G 33171) and 722 (OCS-G 33172) Mississippi Canyon Area, Gulf of Mexico ” dated February 4, 2010 and the Archaeological Report prepared by C&C Technologies, dated December 2009; Project No. 097403-097494 covering Mississippi Canyon Blocks 676-678, 720-722 & 764-766.

Should you require additional information, please contact Tracy Albert at 504.425.4652 or tracy.albert@shell.com

.

Sincerely,

Sylvia A. Bellone

## SHELL OFFSHORE INC.

INITIAL EXPLORATION PLAN

for

OCS- G 33170 , Mississippi Canyon Block 7 20 OCS- G 33171 , Mississippi Canyon Block 721 OCS- G 33172 , Mississippi Canyon Block 722



# PUBLIC INFORMATION COPY

NOVEMBER 1, 2012

PREPARED BY:



## Tracy W. Albert Regulatory Specialist

504.425 .4652

tracy.albert@shell.com

### REVISIONS TABLE:

Date of Request Plan Section What was Corrected Date ResubmittedINITIAL EXPLORATION PLAN OCS- G 33170 , Mississippi Canyon Block 720 OCS- G 33171 , Mississippi Canyon Block 721 OCS- G 33172 , Mississippi Canyon Block 722

OFFSHORE LOUISIANA

TABLE OF CONTENTS

SECTION 1 PLAN CONTENTS SECTION 2 GENERAL INFORMATION SECTION 3 GEOLOGICAL AND GEOPHYSICAL INFORMATION SECTION 4 HYDROGEN SULFIDE

- H 2 S INFORMATION SECTION 5 MINERAL RESOURCE CONSERVATION INFORMATION SECTION 6 BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION SECTION 7 WASTE AND DISCHARGE INFORMATION SECTION 8 AIR EMISSIONS INFORMATION SECTION 9 OIL SPILLS INFORMATION SECTION 10 ENVIRONMENTAL MONITORING INFORMATION SECTION 11 LEASE STIPULATIONS INFORMATION SECTION 12 ENVIRONMENTAL MITIGATION MEASURES INFORMATION SECTION 13 RELATED FACILITIES AND OPERATIONS INFORMATION SECTION 14 SUPPORT VESSELS AND AIRCRAFT INFORMATION SECTION 15 ONSHORE SUPPORT FACILITIES INFORMATION SECTION 16 SULPHUR OPERATIONS INFORMATION SECTION 17 COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION SECTION 18 ENVIRONMENTAL IMPACT ANALYSIS (EIA) SECTION 19 ADMINISTRATIVE INFORMATION

# Acronyms and Abbreviations

DIOS Automated Data Inquiry for Oil Spills APD Application for Permit to Drill
bbl barrel BOEM Bureau of Ocean Energy Management BOEMRE Bureau of Ocean Energy Management,

Regulation and Enforcement BOP blowout preventer

BO PD barrels of oil per day (bbl/day) BSEE Bureau of Safety and Environmental

Enforcement CFR Code of Federal Regulations

CH 4 methane

CO carbon monoxide

CO 2 carbon dioxide DPS distinct population segment

EA Environmental Assessment
EFH Essential Fish Habitat EIA Environmental Impact Analysis EIS Environmental Impact Statement

EP Exploration Plan ESA Endangered Species Act

FAD fish-attracting device g C m -2 grams of carbon per square meter GEMS Geoscience Earth and Marine Services, Inc. GMFMC Gulf of Mexico Fishery Management Council

H 2 S hydrogen sulfide
HAPC Habitat Area of Particular Concern

IPF impact-producing factor
MARPOL International Convention for the Prevention

of Pollution from Ships

MC Mississippi Canyon

MMC Marine Mammal Commission

MMPA Marine Mammal Protection Act

MMS Minerals Management Service MWCC Marine Well Containment Company

NA Natural Area NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act
NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric

Administration

NO 2 nitrogen dioxide

NO x nitrogen oxides NPDES National Pollutant Discharge Elimination

System NRC National Research Council NTL Notice to Lessees and Operators NWR National Wildlife Refuge
OCS Outer Continental Shelf
OCSLA Outer Continental Shelf Lands Act OSAT Operational Science Advisory Team OSRA Oil Spill Risk Analysis OSRP Oil Spill Response Plan PAH polycyclic aromatic hydrocarbon

PM particulate matter PSD Prevention of Significant Deterioration ROV remotely operated vehicle

SBM synthetic-based mud SEA Site-Specific Environmental Assessment
Shell Shell Offshore Inc.

SO 2 sulfur dioxide

SO x sulfur oxides

SP State Park SWIM Service Water and Impoundment

Monitoring SWSS Sperm Whale Seismic Study
U.S.C. United States Code
USCG U.S. Coast Guard USDOI U.S. Department of the Interior USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service VOC volatile organic compound WCD worst case discharge WMA Wildlife Management AreaSECTION 1: PLAN CONTENTS

A. DESCRIPTION, OBJECTIVES & SCHEDULE

Shell Offshore Inc. (Shell) is submitting an initial exploration plan ( EP /plan) for Mississippi Canyon (MC) Blocks 720, 721 and 722, OCS- G 33170, 33171 and 33172 respectively. This plan includes eight proposed exploration wells: A

, B, C, D, E, F, G & H. The wells will be drilled and temporarily abandoned with cement plugs and corrosion caps in accordance with 30 CFR 250.1721 until the wells are completed and developed under future plans. If the wells are unsuccessful, they will be permanently plugged and abandoned in accordance with the Bureau of Safety and Environmental Enforcement (BSEE) regulations.

The drilling activities are planned to commence on or about April 2013 and last approximately 1 65 days per well. The timeframe to complete the initial drilling activities is an estimate based on the best available information regarding downhole conditions likely to be encountered while drilling each well and are not intended to be a limitation.

The lease area is 49 statute miles from the nearest shoreline, 1 08 statute miles from the onshore support base at Port Fourchon, Louisiana and 74 statute miles from the helicopter base at Boothville, Louisiana. Water depths at the well sites range from 3,125 ’ to 3, 747’ (Attachment 1 A)

.
The proposed rig is a dynamically positioned (DP) semi-submersible; a self-contained drilling vessel with accommodations for a crew which include quarters, galley and sanitation facilities. The rig will comply with the requirements in the Interim Final Rules. The drilling activities will be supported by the support vessels and aircraft as well as onshore support facilities as listed in Sections 14 and 15 of the EP. Shell has employed or contracted with trained personnel to carry out its exploration activities. Shell is committed to local hire, local contracting and local purchasing to the maximum extent possible. Shell personnel and contractors are experienced at operating in the Gulf of Mexico and are well versed in all Federal and State laws regulating operations. Shell’s employees and contractors share Shell’s deep commitment to operating in a safe and environmentally responsible manner.

Shell, through its parent and affiliate corporations, has extensive experience safely exploring for oil and gas in the Gulf of Mexico. Shell will draw upon this experience in organizing and carrying out its planned MC 720/721/722 drilling program. Shell believes that the best way to manage blowouts is to prevent them from happening. Significant effor t goes into the design and execution of wells and into building and maintaining staff competence. In the unlikely event of a spill, Shell’s Regional Oil Spill Response Plan (OSRP) is designed to contain and respond to a spill that meets or exceeds the worst case discharge (WCD) as detailed in Section 9 of this EP. The WCD does not take into account potential flow mitigating factors such as well bridging, obstructions in wellbore, reservoir barriers, or early intervention. We continue to invest in research and development to improve safety and reliability of our well systems. All operations will be conducted in accordance with applicable federal and state laws, regulations and lease and permit requirements. Shell will have trained personnel and monitoring programs in place to ensure such compliance.

B. LOCATION

See attached location plat (Attachments 1A ) and BOEM forms (Attachments 1B through 1J).

C. RIG SAFETY AND POLLUTION FEATURES

The rig (Noble Jim Day or similar) will comply with all of the regulations of the American Bureau of Shipping (ABS), International Maritime Organization (IMO) and the United States Coast Guard (USCG). All drilling operations will be conducted under the provisions of 30 CFR, Part 250, Subpart D and other applicable regulations and notices, including those regarding the avoidance of potential drilling hazards and safety and pollution prevention control. Such measures as inflow detection and well control, monitoring for loss of circulation and seepage loss and casingdesign will be our primary safety measures. Primary pollution prevention measures are contaminated and noncontaminated drain system, mud drain system and oily water processing.

DRAIN SYSTEM POLLUTION FEATURES Drains are provided on the rig in all spaces and on all decks where water or oil can accumulate. The drains are divided into two categories, non-contaminated and contaminated. All deck drains are fitted with a removable strainer plate to prevent debris from entering the system.Deck drainage from rainfall, rig washing, deck washing and runoff from curbs and gutters, including drip pans and

work areas, are discharged depending on if it comes in contact with the contaminated or non-contaminated areas of the Rig.

1) Non-contaminated Dra ins

Non-contaminated drains are designated as drains that under normal circumstances do not contain hydrocarbons and can be discharged directly overboard. These are mostly located around the main deck and outboard in places where it is unlikely that hydrocarbons will be found.

Drains within 50 feet of a designated chemical storage area which uses the weather deck as a primary containment means shall be designated “normally plugged.” An adequate number of drains around the rig shall be designated as “normally open” to allow run -off of rain water. Normally open drains shall have a plug located in a conspicuous area near the drain which can be easily installed in the event of a spill.

The rig’s drain plug program consists at a minimum of a weekly check of all deck drains leading to the sea to verify that their status is as designated. If normally open they shall verify that the drain is open and that the plug is available in the area. If normally closed they shall verify that the plug is securely installed in the drain.

In the event a leak or spill is observed, the event shall be contained (drain plug installation and / or spill kit deployment as appropriate) and reported immediately.

Rig personnel shall ensure that the perimeter kick-plates on weather decks are maintained and drain plugs are in place as needed to ensure a proper seal.

2) Contaminated Drains

Contaminated drains are designated as drains that contain hydrocarbons and cannot be discharged overboard. When oil-based mud is used for drilling it will have to be collected in portable tanks and sent to shore for processing.

3) Mud Drain System

None

4) Oily Water Processing

Oily water is collected in an oily water tank. It must be separated and not pumped overboard until oil content is <
15 ppm. The separated oil is pumped to a dirty oil tank and has to be sent ashore for disposal. On board the MODU an oil record log has to be kept according to instructions included in the log. Any and all pollution pans are subjected to a sheen test before being pumped out. If the water passes the sheen test then it is pumped overboard. If it does not pass the sheen test then the water/oil mixture is pumped to a dirty oil tank and sent to shore for disposal. All waste oil that is sent in to be disposed of is recorded in the MODU’s oil log book.

All discharges will be in accordance with applicable NPDES permits. See Section 18, EIA.

5) Lower Hull Bilge System

 The main bilge system is designed to drain the pontoons. There are Goulds electrically driven, self priming centrifugal pumps - one for each main pump room. The aux pumps can be pump out with the bilge pump but has to be lined up manually from the main pump room.

 Bilge water is pumped overboard after a sheen test has been completed.

 The pontoon bilge pumps are operable from the Bridge and have audible and visual bilge alarms set for high and low levels.

 Portable submersible pumps are carried onboard the rig to service all column void spaces and are also used for emergency bilge pumps in the event of the main pump room flooding.

 Alternate means of pumping the bilges in each pontoon pump room include the use of:

– The ballast system emergency bilge valve which is operated from the control panel.– Portable submersible pumps

– Emergency bilge suction line connected directly to the ballast manifold. (Main Pump rooms only)

The Bilge pumps are manual/automatic type pumps. They are equipped with sensors that give a high and a high high alarm. They are set to a point at which the water gets to a certain point they will automatically turn on to pump water out in order to keep flooding under control. The pumps are also capable of being put in manual mode in which they can be turned on by hand.

6) Emergency Bilge System

Main ballast pumps may also be used for emergency bilge pumping directly from the pump rooms via remotely actuated direct bilge suction valves on the ballast system. These valves will operate in a fully flooded compartment. The ballast pumps can be supplied from the emergency switchboard.

7) Oily Water Drain/Separation System

Oily water/engine room bilge water is collected in an oily water tank. It must be separated and not pumped overboard until oil content is < 15 ppm. The separated oil is pumped to a dirty oil tank and has to be sent ashore for disposal. On board all drilling Units, an oil record log has to be kept according to instructions included in the log. The rig floor has two skimmer tanks and each is subjected to a sheen test before pumping overboard to ensure environmental safety. All three anchor winch windlasses have skimmer tanks and are subjected to sheen tests before discharge as well.

8) Drain, Effluent and Waste Systems

 The r ig’s drainage system is desig ned in line with our environmental and single point discharge policies. Drains are either hazardous, i.e. from a hazardous area as depicted on the Area Classification drawings, or non-hazardous drains from nonhazardous areas.

 To prevent migration of hazardous materials and flammable gas from hazardous to non-hazardous areas, the drainage systems are segregated.

 The rig drainage systems tie into oily water separators that take out elements in the drainage that could harm the environment. This is part o f Noble’s initiative to be good stewards of the environment

.

9) Rig Floor Drainage

The Rig floor has been outfitted with a Facet International MAS 34-3 separator. The separator has coalescent plates that remove the solids from the drainage and the remaining drainage goes to a skimmer tank. From the skimmer tank it is drained to one of the column dirty oil tank systems where it is then sent through 2 separators and cleaned further to reduce oil content to less than 15 ppm.

10) Columns #3 & 4

The drains on the decks and machinery spaces are separated at mid ship and directed to either the #3 or #4 columns. The separators in these columns go through three cycles of circulation and remove oil to less than 15ppm, then discharge the clean product to sea.

11) Main Engine Rooms

The engine rooms have their own drainage and handling system. The engine rooms are outfitted with a dirty oil tank and the drainage in the tank is processed through the separator, the waste from the separator goes back to the dirty oil tank and the clean water (less than 15ppm) goes overboard.

The locations and models of the separators are as follows:

– Column #3

–

Westfalia WSD- 18

– Column #4

–

Westfalia WSD- 18

– Drill Floor

–

Facet International MAS 34-312) Helideck Drains

The helideck has a dedicated drainage system around its perimeter to drain heli-fuel from a helicopter incident. The fuel can be diverted to the designated heli fuel recovery tank which is located under the Helideck structure.

Operating configurations are as follow s:

– The overboard piping valves and hydrocarbons take on valves are closed and locked. To unlock overboard or take on valves a permit has to be filled out.

– The oily water collection tank overflow valve is closed.

– The drill floor drains are lined-up to the drill floor skimmer tank. The Skimmer tanks have a high alarm which sounds by means of an air horn. Before tanks are pumped out a sheen test is performed. Water is pump ed out the skimmer tanks down the shunt line. Oil containment side is pumped out into 550 gal tote tanks.

– The BOP test area drains are normally lined-up to drain overboard.

– The oily water separator continuously circulates the oily water collection tank. Waste oil is discharged into the waste oil tank and oily water is re-circulated back into the oily water collection tank. Clean water is pumped overboard, which is controlled/monitored by the oil content detector, set at 15 ppm.

– The solids control system is capable of being isolated for cuttings collection.

– The bilge system is normally pumped directly overboard after a sheen test has been performed.

– The engine dirty oil sump can be drained down in Port column oily water separator which discharges water overboard from the water side and oil being pumped out into a 550 gal tote tank oil containment side. There is a high audible alarm on the ballast control panel.

D. Storage Tanks

–

Noble Jim Day or similar:

Type of Storage Tank Type of Facility Tank

Capacity (bbls) Number of

Tanks Total

Capacity (bbls) Fluid

Gravity ( Specific )

Diesel Tank in stbd 1 80% fill in all hull tanks Drilling Rig 3597 1 Marine Diesel (0.91 SG)

Diesel Tank in stbd 2 Drilling Rig 2713 1 Marine Diesel (0.91 SG)
Diesel Tank in stbd 3 Drilling Rig 3456 1 Marine Diesel (0.91 SG)
Diesel Tank in stbd 4 Drilling Rig 653 1 Marine Diesel (0.91 SG) Diesel Tank in port 1 Drilling Rig 2090 1 Marine Diesel (0.91 SG) Diesel Tank in port 2 Drilling Rig 1366 1 Marine Diesel (0.91 SG) Diesel Tank in port 3 Drilling Rig 4787 1 Marine Diesel (0.91 SG)
Diesel Tank in port 4 Drilling Rig 3456 1 Marine Diesel (0.91 SG)
Total sto r age in hull tanks Drilling Rig 22118 Marine Diesel (0.91 SG)

Diesel Settling Tanks Drilling Rig 129 1 Marine Diesel (0.91 SG) Diesel Settling Tanks Drilling Rig 129 1 Marine Diesel (0.91 SG) Diesel Settling Tanks Drilling Rig 139 1 Marine Diesel (0.91 SG) Diesel Settling Tanks Drilling Rig 129 1 Marine Diesel (0.91 SG) Diesel Day Tank Drilling Rig 100 1 Marine Diesel (0.91 SG) Diesel Day Tank Drilling Rig 115 1 Marine Diesel (0.91 SG) Diesel Day Tank Drilling Rig 114 1 Marine Diesel (0.91 SG) Diesel Day Tank Drilling Rig 115 1 Marine Diesel (0.91 SG) Total engine room diesel Drilling Rig 970 Marine Diesel (0.91 SG)
Lube Oil Tank Drilling Rig 86.25 4 345 Lube Oil (0.91 SG)E. Pollution Prevention Measures

Pursuant to NTL 2008-G04 the proposed operations covered by this EP do not require Shell to specifically address the discharges of oils and greases from the rig during rainfall or routine operations. Nevertheless, Shell has provided this information as part of its response to 1(c) above.

F. Additional Measures

 HSE (health safety and environment) are the primary topics in pre-tour and pre-job safety meetings. The discussion around no harm to people or environment is a key mindset. All personnel are reminded daily to inspect work areas for safety issues as well as potential pollution issues.

 All tools that come to and from the rig have their pollution pans inspected, cleaned and confirmation of plugs installed prior to leaving dock and prior to loading on the boat.

 Preventive Maintenance of rig equipment includes visual inspection of hydraulic lines and reservoirs on routine scheduled basis.

 All pollution pans on rig are inspected daily.

 Containment dikes are installed around all oil containment, drum storage areas, fuel vents and fuel storage tanks.

 All used oil and fuel is collected and sent in for recycling.

 Every drain on the rig is assigned a number on a checklist. The checklist is used daily to verify drain plugs are installed.

 All trash containers are checked and emptied daily. The trash containers are kept covered. Trash is disposed of in a compactor and shipped in via boat.

 The rig is involved in a recycling program for cardboard, plastic, paper, glass and aluminum.

 Fuel hoses and SBM are changed on annual basis.

 TODO spill prevention fittings are installed on all liquid take on hoses.

 Waste paint thinner is recycled on board with a solvent still to reduce hazard of shipping and storage.

 All equipment on board utilizes Envirorite hydraulic fluid as opposed to hydraulic oil.

 Shell has obtained ISO14001 certification.

 Shell uses low sulfur fuel.

G. Description of Previously Approved Lease Activities

Shell has no previously approved well locations in Mississippi Canyon 720, 721 and 722.Attachment 1A Bathymetry and Surface LocationsAttachment 1B

U. S. Department of the Interior OMB Control Number: 1010-0151 Bureau of Ocean Energy Management OMB Approval Expires: 12/31 /2014
OCS PLAN INFORMATION FORM



### Genera l Information

Type of OCS Plan: X Exploration Plan (EP) DOCD

Company Name: Shell Offshore Inc. BOEM Operator Number: 0689

Address: P. O. Box 61933 Contact Person: Tracy Albert

New Orleans, LA 70161

- 1933 Phone Number: (504) 728

- 4652

E

- Mail Address: tracy.albert@shell.com

Lease(s): G 33170, 33171, 33172 Area: MC Block(s): 720, 721,

722 Project Name (If Applicable): Queen

Objective(s): X Oil Gas Sulphur Salt Onshore Base: Fouchon Distance to Closest Land (Miles): 49


### Description of Proposed Activities (Mark all that apply)

X Exploration drilling Development drilling

Well completion Installation of production platform

Well test flaring (for more than 48 hours) Installation of production facilities

Installation of caisson or platform as well protection structure Installation of satellite structure

Installation of subsea wellheads and/or manifolds Commence production

Installation of lease term pipelines Other (Specify and describe) Pipeline appurtenance

Have you submitted or do you plan to submit a Conservation Information Document to accompany this plan? Yes X No

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

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

Do you propose any activities that may disturb an BOEM

- designated high

- probability archaeological area? X Yes No

Have all of the surface locations of your proposed activities been previously reviewed and approved by BOEM ? Yes X No 

### Tentative Schedule of Proposed Activities

Proposed Activity Start Date End Date No. of Days

Drill and suspend Well A 4/1/2013 9 / 13 /2013 165

Drill and suspend Well B 4/1/2014 9/13/201 4 165
Drill and suspend Well C 4/1/2015 9/13/201 5 165

Drill and suspend Well D 4/1/2016 9/13/201 6 165

Drill and suspend Well E 4/1/2017 9/13/201 7 165

Drill and suspend Well F 4/1/2018 9/13/201 8 165

Drill and suspend Well G 4/1/2019 9/13/201 9 165

Drill and suspend Well H 4/1/2020 9/13/20 20 165



### Description of Drilling Rig Description of Production Platform

Jackup Drillship Caisson Tension leg platform

Gorilla Jackup Platform rig Well protector Compliant tower

Semisubmersible Submersible Fixed platform Guyed tower

X DP Semisubmersible Other (Attach Description) Subsea manifold Floating production system

Drilling Rig Name (If Known): Noble Jim Day or similar Spar Other (Attach Description)



### Description of Lease Term Pipelines
From (Facility/Area/Block) To (Facility/Area/Block) Diameter (Inches) Length (Feet)
N/A

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1C OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): A Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33171

Area Name Mississippi Canyon

Block No. 721

Blockline Departures (in feet) N/S Departure: 4

, 024 FSL

E/W Departure: 5,957 FEL

Lambert X

- Y
coordinates X: 960

, 283

Y: 10

, 252

, 504

Latitude/ Longitude Latitude 28.23588 769

Longitude

- 89.11273 115

TVD (Feet): MD (Feet): Water Depth (Feet): 3

, 747’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1D OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): B Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33171

Area Name Mississippi Canyon

Block No. 721

Blockline Departures (in feet) N/S Departure: 2,120’ FSL

E/W Departure: 4,840’ FEL

Lambert X

- Y
coordinates X: 961,400

Y: 10,250,600

Latitude/ Longitude Latitude 28.23070670

Longitude

- 89.10916125

TVD (Feet): MD (Feet): Water Depth (Feet): 3, 691’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1E OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): C Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33171

Area Name Mississippi Canyon

Block No. 721

Blockline Departures (in feet) N/S Departure: 1,072 FSL

E/W Departure: 7,746 FEL

Lambert X

- Y
coordinates X: 958

, 494

Y: 10

, 249

, 552

Latitude/ Longitude Latitude 28.22768556

Longitude

- 89.11812591

TVD (Feet): MD (Feet): Water Depth (Feet): 3, 713’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1F OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name ): D Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33171

Area Name Mississippi Canyon

Block No. 721

Blockline Departures (in feet) N/S Departure: 1,865 FSL

E/W Departure: 8,873 FEL

Lambert X

- Y
coordinates X: 957

, 367

Y: 10

, 250

, 345

Latitude/ Longitude Latitude 28.22981 070

Longitude

- 89.12166 40

TVD (Feet): MD (Feet): Water Depth (Feet): 3,688’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1G OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): E Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33170

Area Name Mississippi Canyon

Block No. 720

Blockline Departures (in feet) N/S Departure: 7,020’ FSL

E/W Departure: 3,540’ FWL

Lambert X

- Y
coordinates X: 938,100

Y: 10,255,500

Latitude/ Longitude Latitude 28.24304421

Longitude

- 89.18176764

TVD (Feet): MD (Feet): Water Depth (Feet): 3,2 5 5 ’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1H OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): F Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For We ll s)

Lease No. OCS

- G 33170

Area Name Mississippi Canyon

Block No. 720

Blockline Departures (in feet) N/S Departure: 2,420’ FSL

E/W Departure: 3,140’ FWL

Lambert X

- Y
coordinates X: 937,700

Y: 10,250,900

Latitude/ Longitude Latitude 28.2303765 2

Longitude

- 89.18275197

TVD (Feet): MD (Feet): Water Depth (Feet): 3, 190’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1I OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): G Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33170

Area Name Mississippi Canyon

Block No. 720

Blockline Departures (in feet) N/S Departure: 4,960’ FNL

E/W Departure: 1,500’ FWL

Lambert X

- Y
coordinates X: 936,060

Y: 10,259,360

Latitude/ Longitude Latitude 28.25355608

Longitude

- 89.18831792

TVD (Feet): MD (Feet): Water Depth (Feet): 3,12 5 ’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)Attachment 1J OCS PLAN INFORMATION FORM (CONTINUED) Include one copy of this page for each proposed well/structure



### Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): H Subsea Completion

Anchor Radius (if applicable) in feet: NA Yes X No

Surface Location Bottom

- Hole Location (For Wells)

Lease No. OCS

- G 33172

Area Name Mississippi Canyon

Block No. 722

Blockline Departures (in feet) N/S Departure: 317’ FSL

E/W Departure: 1,380’ FWL

Lambert X

- Y
coordinates X: 967

, 620

Y: 10

, 248

, 797

Latitude/ Longitude Latitude 28.22604 445

Longitude 89.08975 587

TVD (Feet): MD (Feet): Water Depth (Feet): 3,734 ’



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

Anchor Name

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

Paperwork Reduction Act of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. 2501 et seq.) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document sub mitted for BOEM approval. We use the i nformation to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collectio n of information unless it displays a currently valid Office of Management and Budget Control Number. Responses are mandatory ( 43 U.S.C. 1334). The public reporting burden for this form is included in the burden for preparing Exploration Plans and Developm ent Operations Coordination Documents. We estimate that burden to average 600 hours with an accompanying EP, or 700 hours with an accompanying DPP or DOC D, including the time for reviewing instructions, gathering and maintaining data, and completing and re viewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance Off icer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

Form BOEM- 0137 (December 2011-Supercedes all previous editions of form BOEM-0137 which may not be used.)SECTION 2: GENERAL INFORMATION

A. Application and Permits

There are no individual or site-specific permits other than general NPDES permit and rig move notification that need to be obtained. Prior to beginning exploration operations, an Application for Permit to Drill will be submitted and approved by the Bureau of Safety and Environmental Enforcement (BSEE).

B. Drilling Fluids

See Section 7, Table 7A for a list of drilling fluids to be used.

C. Production

Information regarding production is not included in this EP as such information is only necessary in the case of DOCDs.

D. Oil Characteristics

Information regarding oil characteristics is not included in this EP as such information is only necessary in the case of DOCDs.

E. New Or Unusual Technology

Shell is not proposing to use new or unusual technology as defined in 30 CFR 250.200 to carry out the proposed activities in this EP.

F. Bonding

The bond requirement for the activities proposed in this EP are satisfied by an area-wide bond furnished and maintained according to 30 CFR Part 256, Subpart I-Bonding ; NTL No. 2000-G16, “ Guideline for General Lease Surety Bonds” and National NTL No. 2008- N0 7 , “Supplemental Bond Proc ed ures.”

G. Oil Spill Financial Responsibility (OSFR)

Shell Offshore Inc.

, BOEM Operator Number 0689, has demonstrated oil spill financial responsibility for the activities proposed in th is EP according to 30 CFR Parts 250 and 253 and NTL No. 2008- N0 5 , “Guidelines for Oil Spill Financial Responsibility for Covered Facilities.”

H. Deepwater well control statement

Shell Offshore Inc.

, BOEM Operator Number 0689, has the financial capability to drill a relief well and conduct other emergency well control operations if required.

I. Suspension of Production

Information regarding Suspension of Production is not included in this EP as such information is only necessary in the case of DOCDs.J. Blowout scenario

Summary This Section 2J was prepared by Shell pursuant to the guidance provided in the BOEM’s NTL 2010 -N06 with respect to blowout and worst case discharge (WCD) scenario descriptions. Shell intends to comply with all applicable laws, regulations, rules and Notices to Lessees.

Shell focuses on an integrated, three-pronged approach to a blowout, including prevention, intervention

, containment, and recovery.

1. Shell believes that the best way to manage blowouts is to prevent them from happening. Significant effort goes into design and execution of wells and into building and maintaining staff competence. Shell continues to invest independently in research and development (R&D) to improve safety and reliability of our well systems.
2. Shell is a founding member of the MWCC, which provides robust well containment (shut-in and controlled flow) capabilities. Additionally, Shell is investing in R&D to improve containment systems.
3. As outlined in Shell’s OSRP, and detailed in EP Section 9a (ii), Shell has contracts with OSROs to provide the resources necessary to respond to this WCD scenario. The capabilities for on-water recovery, aerial and subsea dispersant application, in-situ burning, and nighttime monitoring and tracking have been significantl y increased.

The WCD blowout scenario for this plan is calculated for the MC 721 Well D location penetration of the target interval and is based on the guidelines outlined in NTL 2010-N06 along with subsequent Frequently Asked Questions (FAQ). Shell’s Reg ional OSRP (updated in July 2012) is based on MC-391 Well D (Well #1) as the WCD well. In the unlikely event of a spill, Shell’s Regional OSRP is designed to contain and respond to a spill that exceeds this WCD. This WCD does not take into account potential flow mitigating factors such as well bridging, obstructions in wellbore, reservoir barriers, and early intervention including containment capabilities.

Uncontrolled blowout (volume first day) 392,000 bbl
Uncontrolled blowout rate (first 30

- days average daily rate) 355,000 bopd Duration of flow (days) based on relief well 157 days
Total volume of spill (bbls) for 157 days 5 2 MMBO

Table 2.1. Queen Worst Case Discharge Summary

The exploration prospect is located approximately 49 statute miles south-southeast of the nearest Louisiana shoreline in the Gulf of Mexico, in water depths of 3, 125 -3,7 47 ’ across the prospect. The structural component of the prospect is defined by an embayment culmination against base salt. The objective interval for the proposed well with flow potential is in The Miocene section, and the MC 721 D well is expected to have the highest flow rates. The alternate well locations (A, B, C, E, F, G, and H) were also evaluated; however, their flow rates are lower than the WCD calculated for the MC 721 D well.

1) Purpose Pursuant to 30 CFR 250.213(g), 250.219, 250.250, and NTL 2010-N06, this document provides a blowout scenario description, further information regarding any potential oil spill, the assumptions and calculations used to determine the WCD and the measures taken to 1) enhance the ability to prevent a blowout and 2) respond and manage a blowout scenario if it were to occur. These calculations are based on best technical estimates of subsurface parameters that are derived from the regional formation of offset well data and seismic data. These parameters are better than or consistent with the estimates used by Shell to justify the investment. Therefore, these assumed parameters were used to calculate the WCD. They do not reflect probabilistic estimates.

2) Background This attachment has been developed to document the additional information requirements for EPs as requested by NTL No. 2010-N06 in response to the explosion and sinking of the MODU Deepwater Horizon and the resulting subsea well blowout and recovery operations of the exploration well at the MC-252 Macondo location.3) Information Requirements

a) Blowout scenario

All well locations addressed in this EP were assessed for WCD. The MC 721 well from the D location represents the highest flow potential. The D well penetrates the Miocene objective interval as outlined in the Geological and Geophysical Information Section of the EP using a subsea wellhead system, conductor, surface and intermediate casing program, and using a DP MODU with a marine riser and subsea blowout preventer (BOP). A hydrocarbon influx and a well control event are modeled to occur from reservoirs in the objective interval. The modeled blowout results in unrestricted flow from the well at the seafloor, which represents the WCD (no restrictions in wellbore, failure/loss of the subsea BOP, and a blowout to the seabed).

b) Estimated flow rate of the potential blowout

Category EP Type of Activity Drilling Facility Location (area/block) MC

- 721 Facility Designation MODU Distance to Nearest Shoreline (Statute miles) 49 Uncontrolled blowout (volume first day) 392,000 bbl Uncontrolled blowout rate (first 30

- days average daily rate) 355,000 bopd Table 2.2 Estimated Flow Rates of a Potential Blowout

c) Total volume and maximum duration of the potential blowout

Duration of flow (days) 157 days total duration to drill re lief well (14 days rig demob ilization , 3 days rig mob ilization , 78 days spud to TD, 30 days ranging, 32 days contingency). Total volume of spill (bbls) 5 2 MMBO based on 157 days flowing. Note: From GAP/Prosper/MBAL model
Table 2.3 Estimated Duration and Volume of a Potential Blowout

There is usually a decline in the discharge rate as time proceeds, which is illustrated by the differences between the first 24-hour volume and 30-day average rate. The total volume calculated until a well is killed in a potential blowout further demonstrates this decline. At very short times, e.g. during the first 24 hours, the pressure profile in the reservoir changes from the moment when a well first starts flowing to a pseudo-steady state pressure profile with time, and as a result the rate declines. At somewhat longer time scales, effects such as reservoir voidage and the impact of boundaries can cause the rate to drop continuously with production. Simulation and material balance models can include these effects and form the basis of the NTL 2010-N06 calculations for 24-hour and 30-day rates as well as maximum duration volumes.

d) Assumptions and calculations used in determining the worst case discharge (Proprietary)

e) Potential for the well to bridge over

Mechanical failure/collapse of the borehole in a blowout scenario is influenced by several factors including in-situ stress, rock strength and fluid velocities at the sandface. Based on the nodal analysis and reservoir simulation models outlined above, a seabed blowout would create a high drawdown at the sand face. Given the substantial fluid velocities inherent in the worst case discharge, and the scenario as defined where the formation is not supported by a cased and cemented wellbore, it is possible that the borehole may fail/collapse/bridge over within the span of a few days, significantly reducing the outflow rates. However, this WCD scenario does not include any bridging.f) Likelihood for intervention to stop the blowout.

Safety of operations is our top priority. Maintaining well control at all times to prevent a blowout is the key focus of our operations. Our safe drilling record is based on our robust standards, conservative well design, prudent operations practices, competency of personnel, and strong HSE focus. Collectively, these constitute a robust system making blowouts extremely rare events.

Intervention Devices: Notwithstanding these facts, the main scenario for recovery from a blowout event is via intervention with the BOP attached to the well. There are built in redundancies in the BOP system to allow activation of selected components with the intent to seal off the well bore. As a minimum, the Shell contracted rig fleet in the GOM will have redundancies meeting the Interim Final Drilling Safety Rule with respect to Remotely Operated Vehicle (ROV) hot stab capabilities, a deadman system, and an autoshear system.

Additionally the Noble Jim Day (dynamically positioned semisubmersible) has a gas handler system at the top of the riser consisting of two annular preventers that can be closed in to allow hydrocarbons in the riser to be contained or circulated thru the rig’s well control system. The rig has two shearing rams in the BOP for added redundancy. Also, the Noble Jim Day is equipped with a deadman system and an auto shear system.

Containment: The experience of gaining control over the Macondo well has resulted in a better understanding of the necessary equipment and systems for well containment. As a result, industry and government are better equipped and prepared today to contain an oil well blowout in deepwater. Shell is further analyzing these advances and incorporating them into its comprehensive approach to help prevent and, if needed, control another deepwater control incident.

Pursuant to NTL 2010-N10 Shell will provide additional information regarding our containment capabilities in a subsequent filing.

g) Availability of a rig to drill a relief well and rig package constraints

Blowout intervention can be conducted from an ROV equipped vessel, the existing drilling rig or from another drilling rig. Shell has an active portfolio of well operations in the GOM which will be supported by a total of four to six MODU rigs in 2012

–

2015 timeframe. The dynamically positioned rigs under contract, the Noble Danny Adkins, Noble Globetrotter I, and the Noble Bully I will be the preferred rigs for blowout intervention work. However, moored rigs, like the Transocean Deepwater Nautilus, can also be used in some scenarios. Additionally, in the event of a blowout, there is the distinct possibility that other non-contracted rigs in the GOM could be utilized whether for increased expediency or better suitability. All efforts will be made at the tim e to secure the appropriate rig. Shell’s current contracted rigs capable of operating at Queen water depths and reservoir depths without constraints are in the following table:

Rig Name Rig Type

Noble Danny Adkins Dynamically positioned semisubmersible Noble Globetrotter I Dynamically positioned drillship Noble Bully I Dynamically positioned drillship Transocean Deepwater Nautilus Moored semisubmersible

Table 2.4 Shell contracted rigs capable at Queen

Future modifications may change the rig’s capability. Rig capabilities need to be assessed on a work scope specific basis. h) Time taken to contract a rig, move it onsite, and drill a relief well

Relief well operations will immediately take priority and displace any activity from Shell’s contracted rig fleet. Table 2.4 lists the Shell contracted rigs capable of operating at Queen. It is expected to take an average of 14 days to safely secure the well that the rig is working on up to the point the rig departs location, and an additional 3 days transit to mobilize to the relief well site depending on distance to the site. The relief well will take approximately 78 days to drill down to the last casing string above the blowout zone, plus approximately 30 days for precision rangingactivity to intersect the blowout well bore. Additionally, 32 extra days of contingency are added. The total time to

mobilize and drill a relief well would be 157 days for the Queen wells.

If a moored rig is chosen to conduct the relief well operations, anchor handlers would be prioritized to prepare mooring on the relief well site while the rig is being mobilized. This mooring activity is not expected to delay initiation of relief well drilling operations. Shell has three deepwater anchor handlers, the Laney, Dino, and Ross Chouest, on long term contract to support its moored rigs.

It is not possible to drill relief wells from any existing platforms due to the distance to reach the sub-surface.

i) Measures proposed to enhance ability to prevent blowout and to reduce likelihood of a blowout.

Shell believes that the best way to manage blowouts is to prevent them from happening. Detailed below are the measures employed by Shell with the goal of no harm to people or the environment. The Macondo incident has highlighted the importance of these practices. The lessons learned from the investigation are, and will continue to be, incorporated into our operations.

Standards: Shell’s well design and operations adhere to internal corporate standards, the Code of Federal Regulations, and industry standards. A robust management of change process is in place to handle un-defined or exception situations. Ingrained in the Shell standards for well control is the philosophy of multiple barriers in the well design and operations on the well.

Risk Management: Shell believes that prevention of major incidents is best managed through the systematic identification and mitigation process (Safety Case). All Shell contracted rigs in the GOM have been operating with a Safety Case and will continue to do so. A Safety Case requires both the owner and contractors to systematically identify the risks in drilling operations and align plans to mitigate those risks; an alignment which is critical before drilling begins.

Well Design Workflow: The Well Delivery Process (WDP) is a rigorous internal assurance process with defined decision gates. The WDP leverages functional experts (internal and external) to examine the well design at the conceptual and detailed design stages for robustness before making a recommendation to the management review board. Shell’s involvement in global deepwater drilling, starting in the GOM in the mid

- 1980’s, provides a significant depth and breadth of internal drilling and operational expertise. Third party vendors and rig contractors are involved in all stages of the planning, providing their specific expertise. A Drill the Well On Paper (DWOP) exercise is conducted with rig personnel and vendors involved in execution of the well. This forum communicates the well plan, and solicits input as to the safety of the plan and procedures proposed.

Well and rig equipment qualification, certification, and quality assurance: All rigs will meet all applicable rules, regulations, and Notice to Lessees. Shell works closely with rig contractors to ensure proper upkeep of all rig equipment, which meets or exceeds the strictest of Shell, industry, or regulatory requirements. Well tangibles are governed by our internal quality assurance/control standards and industry standards.

MWD/LWD/PWD Tools: Shell intends to use these tools at Queen. The MWD/LWD/PWD tools are run on the drill string so that data on subsurface zones can be collected as the well advances in real time instead of waiting until the drill string is pulled to run wireline logs. Data from the tools are monitored and interpreted real time against prognosis to provide early warning of abnormal pressures to allow measures to be taken to progress the well safely.

Mud Logger: Mud-logging personnel continually monitor returning drilling fluids for indications of hydrocarbons, utilizing both a hot wire and a gas chromatograph. An abrupt increase in gas or oil carried in the returning fluid can be an indication of an impending kick. The mud logger also monitors drill cuttings returned to the surface in the drilling fluid for changes in lithology that can be an indicator that the well has penetrated or is about to penetrate a hydrocarbon-bearing interval. Mud logging instruments also monitor penetration rate to provide an early indication of drilling breaks that show the bit penetrating a zone that could contain hydrocarbons. The mud logging personnel are in close communication with both the offshore drilling foremen and onshore Shell representative(s) to report any observed anomalies so appropriate action can be taken.Remote Monitoring: The Real Time Operating Center has been used by Shell to complement and support

traditional rig-site monitoring since 2003. Well site operations are monitored 24/7 virtually by onshore teams consisting of geoscientists, petrophysicists, well engineers, and monitoring specialists. The same real time well control indicators monitored by the rig personnel are watched by the monitoring specialist for an added layer of redundancy.

Competency and Behavior: A structured training program for Well Engineers and Foremen is practiced, which includes internal professional examinations to verify competency. Other industry training in well control, such as by International Association of Drilling Contractors (IADC) and International Well Control Forum (IWCF) are also mandated. Progressions have elements of competency and Shell continues to have comprehensive internal training programs. The best systems and processes can be defeated by lack of knowledge and/or improper values. We believe that a combination of HSE tools (e.g. stop work, pre-job analysis, behavior based safety, DWOPs, audits), management HSE involvement and enforcement (e.g. compliance to life saving rules) have created a strong safety culture in our operations.

j) Measures to conduct effective and early intervention in the event of a blowout.

The response to a blowout is contained in our Well Control Contingency Plan (WCCP) which is a specific requirement of our internal well control standards. The WCCP in turn is part of the wider emergency response framework within Shell that addresses the overall organization response to an emergency situation. Resources are dedicated to these systems and drills are run frequently to test preparedness (security, medical, oil spill, and hurricane). This same framework is activated and tested during hurricane evacuations, thereby maintaining a fresh and responsive team. The WCCP specifically addresses implementing actions at the emergency site that will ensure personnel safety, organizing personnel and their roles in the response, defining information requirements, establishing protocols to mobilize specialists, pre-selecting sources, and developing mobilization plans for personnel, material and services for well control procedures. The plan references individual activity checklists, a roster of equipment and services, initial information gathering forms, a generic description of relief well drilling, strategy and guidelines, intervention techniques and equipment, site safety management, exclusion zones, and re-boarding.

As set forth in 3f of this document, Shell is currently analyzing recent advances in containment technology and equipment and will incorporate them as they become available.

k) Arrangements for drilling a relief well

The size of the Shell contracted rig fleet in the GOM from 2012-2015 ensures that there is adequate well equipment (e.g. casing and wellhead) available for relief wells. Rigs and personnel will also be readily available within Shell, diverted from their active roles elsewhere. Resources from other operators can also be leveraged should the need arise. Generally, relief well plans will mirror the blowout well, incorporating any learning on well design based on root cause analysis of the blowout. A generic relief well description is outlined in the WCCP.

l) Assumptions and calculations used in approved or proposed Regional OSRP

All proposed Queen locations were evaluated and Location D was determined to have the greatest WCD volume. Shell has designed a response program (Regional OSRP) based upon a regional capability of responding to a range of spill volumes, from small operational spills up to and including the WCD from a well blowout. Shell’s program is developed to fully satisfy federal oil spill planning regulations. The Regional OSRP presents specific information on the response program that includes a description of personnel and equipment mobilization, the incident management team organization and the strategies and tactics used to implement effective and sustained spill containment and recovery operations.SECTION 3: GEOLOGICAL AND GEOPHYSICAL INFORMATION

A. Geological description Proprietary data

B. Structure Contour Map(s) Proprietary data

C. Interpreted 2D and/or 3D Seismic line(s) Proprietary data

D. Geological Structure Cross-section(s) Proprietary data

E. Stratigraphic Column with Time vs Depth Table Proprietary data

F. Shallow Hazards Report

The following report was used for our analysis:

The Shallow Hazards Report, prepared by Gems, Inc. (Project No. 0909-1691b) of the shallow drilling hazards “ Geologic and Stratigraphic Assessment of Blocks 720 (OCS-G 33170), 721 (OCS-G 33171) and 722 (OCS-G 33172) Mississippi Canyon Area, Gulf of Mexico ” dated February 4, 2010.

The Archaeological Report prepared by C&C Technologies, dated December 2009; Project No. 097403- 097494 covering Mississippi Canyon Blocks 676-678, 720-722 & 764-766.

G. Shallow Hazards Assessment See Section 6A of this plan for detailed site assessment.

H. Geochemical Information

This information is not required for plans submitted in the GOM Region.

I

. Future G&G Activities

This information is not required for plans submitted in the GOM Region.SECTION 4: HYDROGEN SULFIDE (H 2 S)

 Concentration

0 ppm

 Classification

Based on 30 CFR 550.215, Shell requests that the Regional Supervisor, Field Operations, classify the area in the proposed drilling operations as an area where the absence of H 2 S is confirmed.

 H 2 S Contingency Plan

Shell is not required to provide an H 2 S Contingency Plan with the Application for Permit to Drill before conducting the proposed exploration activities.

 Modeling Report

We do not anticipate to encounter or handle H 2 S at concentrations greater than 500 parts per million (ppm) and therefore have not included modeling for H 2 S.SECTION 5: MINERAL RESOURCE CONSERVATION INFORMATION

Information regarding Mineral Resource Conservation is not included in this EP as such information is only necessary in the case of DOCDs.SECTION 6: BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION

A. Chemosynthetic Communities Report

Shallow Hazards Reports and Data:

Geoscience Earth and Marine Services, Inc, Geologic and Stratigraphic Assessment of Blocks 720 (OCS- G 33170), 721 (OCS-G 33171), and 722 (OCS-G 33172), Mississippi Canyon Area, Gulf of Mexico, Project # 0609-1691b, dated February 4, 2010. AUV side-scan sonar and sub-bottom profiler, and Reprocessed 3- D seismic data.

Locations are Mississippi Canyon Blocks 720, Proposed Locations E, F and G, Mississippi Canyon 721, Proposed Locations A, B, C and D, and Mississippi Canyon 722, Proposed Location H. Proposed Locations A, C, D and H surface locations have been revised from the shallow hazards report.

Archaeological Reports:

C& C Technologies, Archaeological Assessment Report, Blocks 676-678, 720-722, 765-766, and Vicinity, Mississippi Canyon Area, Project No. 097403 -097494, December, 2009. AUV side-scan sonar and sub-bottom profiler data.

C&C Technologies, Archaeological and Hazard Report, Blocks 808, 809, 852, 853 and Vicinity, Mississippi Canyon Area, Project No. 083986-084109, February, 2009. AUV side-scan sonar and sub-bottom profiler data.

C&C Technologies, Archaeological Assessment Report, Block 854 and Vicinity (Blocks 809-811, 853, 855, 897-899), Mississippi Canyon Area, Project No. 072879-072915, August 2007. AUV side-scan sonar and subbottom profiler data.

Proposed Locations and Coordinates:

Proposed Location / Block X coordinate Y coordinate FNL/FSL FEL/FWL Water Depth Prop Loc A / MC 721 960,283 10,252,504 4024’ FSL 5957’ FEL 3747’ Prop Loc B / MC 721 961,400 10,250,600 2120’ FSL 4840’ FEL 3691’ Prop Loc C / MC 721 958,494 10,249,552 1072’ FSL 7746’ FEL 3713' Prop Loc D / MC 721 957,367 10,250,345 1865’ FSL 8872 ’ F E L 3688’ Prop Loc E / MC 720 938,100 10,255,500 7020’ FSL 3540’ FWL 3255’ Prop Loc F / MC 720 937,700 10,250,900 2420’ FSL 3140’ FWL 3190’ Prop Loc G / MC 720 936,060 10,259,360 4960’ FNL 1500’ FWL 3125’ Prop Loc H / MC 722 967,620 10,248,797 317’ FSL 1380’ FWL 3734’ Coordinates are in UTM 316, NAD27

See Attachments 6A through 6H for Enhanced Seafloor Rendering Maps.

Site Assessment MC 721, Proposed Location A:

Mississippi Canyon 721, Proposed Location A is located in a water depth of approximately 3,747 feet. A major seafloor fault is identified over 1000 ’ east southeast of proposed location, associated with a seafloor graben area. Hummocky topography is identified 500 ’ north of proposed location.The stratigraphy at the site of MC 721, Proposed Location A consists of:

• Unit 1 (Seafloor

– 662’ BML) – 15 ’ of drape over chaotic mass-transport deposits (MTDs), 647 ’ of alternating intervals of bedded clays and chaotic mass-transport deposits (MTDs).

• Unit 2 (662’ –

1, 387’ BML) – 227 ’

of bedded hemipelagic muds and chaotic mud-rich MTDs, 203 ’ of mud-rich MTDs, 295 ’ of MTD’s with sand seams and pockets. A fault will be penetrated 1

, 335’
BML.

• Unit 3

–

Blue Unit (1, 387’ –

2, 566’ BML) – 1,179 ’

of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors. A fault will be penetrated 1,855 ’ below the mud line.

• Unit 4 (2566’ – 3456’ BML) – 890 ’ of mud-rich turbidites and MTDs.

• Unit 5 (3456’ – 4504’ BML) – 259 ’ of mud-rich turbidites, 335 ’of moderate amplitude, leveeoverbank thin sands, and 454 ’ of mud-rich MTDs. A fault will be penetrated 4,499 ’ below the mud line.

Faults will be penetrated 1,335 ’ , 1,855 ’ and 4,499 ’

below the mud line. The casing program is designed for fault penetration.

Shallow Water Flow Potential: Negligible Potential - Seafloor to 889’ BML Low Potential

– 889’ to 1

, 387’ BML High Potential

– 1, 387’ to 2

, 566’ BML Low Potential

– 2, 566’ to 3

, 715’ BML Moderate Potential

– 3, 715’ to 4

, 050’ BML Low Potential

– 4, 050’ to 4

, 504’ BML

Shallow Gas Potential Negligible Potential

– Seafloor to 1, 092’ BML Low Potential

– 1, 092’ to 4

, 504’ BML

High amplitudes are identified 500’ north northwest and 500’ south southeast in Unit 3 (1

, 442’ – 2, 618’ BML) and this proposed location will not penetrate any high amplitudes.

Benthic/Anchor Assessment, MC 721, Proposed Location A (no anchors

– DP Vessel)

Mississippi Canyon 721, Proposed Location A is located in a water depth of approximately 3,747 ’

. Hummocky topography is identified 500 feet north of Proposed Location A.

A major seafloor fault is identified over 1,000 ’ east southeast of location, associated with a seafloor graben area. There is no other evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2, 000’ of location. This location will not disturb any high-density areas of benthic
communities.

There are no marine avoidance areas identified within 2, 000’ of this location, and there are no existing surface locations or flowlines within 2, 000’ of this area.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3- D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 721, Proposed Location A appears suitable for the planned activity.Site Assessment, MC 721, Proposed Location B:

Mississippi Canyon 721, Proposed Location B is located in a water depth of approximately 3 ,691 ’ . One major seafloor fault is identified 375 ’ west and another is 3, 000’ east of proposed location; both are associated with a seafloor graben area. A narrow seafloor furrow is identified 1,800 ’ east of location.

The stratigraphy at the site of MC 721, Proposed Location B consists of:

 Unit 1 (Seafloor - 614' BML)

– 21 ’ of drape over 593 ’

of alternating intervals of bedded clays and chaotic mass transport deposits (MTDs).

 Unit 2 (614'

–

1,442' BML)

–

197 ’ of bedded hemipelagic muds and chaotic mud-rich MTDs, and 631 ’ of discontinuous to chaotic MTDs with mud-rich, thin sands near the base.

 Unit 3 - Blue Unit (1,442'

– 2,618' BML)

– 1,176 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 4 (2,618'

–

3,318' BML)

–

700 ’ of mud-rich turbidites and MTDs with possible thin sand seams.

 Unit 5 (3,318'

–

3,896' BML)

–

578 ’ of mud-rich turbidites, moderate amplitudes, levee over-bank deposits with thin and sand mud-rich MTDs. A fault will be penetrated 3,462 ’ below the mud line.

A fault will be penetrated 3, 462 ’ below the mud line. The casing program is designed for fault penetration.

Shallow Water Flow Potential: Negligible Potential - Seafloor to 811' BML Low Potential - 811' to 1,442' BML High Potential

– 1,442' to 2,618' BML Low Potential - 2618' to 3,896' BML

Shallow Gas Potential: Negligible Potential - Seafloor to 1,442' BML Moderate Potential

– 1,442 to 1,964' BML Low Potential

– 1,964' to 3,896' BML

High amplitudes are identified 400 ’ southeast of Proposed Location B, in Unit 3 and will not penetrate any high amplitudes or amplitude anomalies.

Benthic/Anchor Assessment, MC 721, Proposed Location B (no anchors

– DP Vessel)

Mississippi Canyon 72 1, Proposed Location B is located in a water depth of approximately 3,691 ’ . A narrow seafloor furrow is identified 1,800 ’ east of proposed location.

One major seafloor fault is identified 375 ’ west and another is 3, 000’ east of this location; both are associated with a seafloor graben area. There is no other evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2, 000’ of location and this location will not disturb any highdensity areas of benthic communities.

There are no marine avoidance areas identified within 2, 000’ of this location and there are no existing surface locations or flowlines within 2, 000’ of this area.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3- D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 721, Proposed Location B appears suitable for the planned activity.Site Assessment, MC 721, Proposed Location C:

Mississippi Canyon 721, Proposed Location C is located in a water depth of approximately 3 ,713 ’ . Hummocky topography is identified 400 ’ west of proposed location. A major seafloor fault is identified over 1,400 ’ southeast of this location, associated with a seafloor graben area.

The stratigraphy at the site of MC 721, Proposed Location C consists of:

• Unit 1 (Seafloor - 602' BML)

– 26 ’ of drape over chaotic mass-transport deposits (MTD's), over 576 ’ of alternating intervals of bedded clays and chaotic MTDs.

• Unit 2 (602'

–

1,444' BML)

–

842 ’ of bedded hemipelagic muds and chaotic mud-rich MTDs.

• Unit 3 - Blue Unit (1,444'

– 2,427' BML)

–

983 ’ of sand-rich interval of channel and overbank deposits.

• Unit 4 (2,427'

–

3,207' BML)

– 780 ’

of mud-rich turbidites and MTDs with possible thin sand

seams.

• Unit 5 (3,207'

–

4,706' BML)

–

1499 ’ of mud-rich turbidites. A fault will be penetrated 3,818 ’
BML.

A fault will be penetrated 3, 818 ’ below the mud line. The casing program is designed for fault penetration.

Shallow Water Flow Potential: Negligible Potential - Seafloor to 602' BML Low Potential - 602' to 1,444' BML High Potential

– 1,444' to 2,427' BML Low Potential

– 2,427' to 4,706' BML

Shallow Gas Potential: Negligible Potential - Seafloor to 1,444' BML Low Potential

– 1,444' to 4,706' BML

High amplitude reflectors are identified 400’ northwest of this location in Unit 3 (1, 444’ – 2, 427’ BML) and 300 feet southeast of this area in Unit 5 (3, 207’ – 4, 706’ BML) and this location will not penetrate any amplitude anomalies.

Benthic/Anchor Assessment, MC 721, Proposed Location C (no anchors

– DP Vessel)

Mississippi Canyon 721, Proposed Location C is located in a water depth of approximately 3 ,713 ’

. Hummocky topography is identified 400 ’ west of this location.

A major seafloor fault is identified over 1,400 ’ southeast of this location, associated with a seafloor graben area. There is no other evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2000’ of proposed location. This location will not disturb any high-density areas of benthic
communities.

There are no marine avoidances areas identified within 2, 000’ of this location

.

Currently, there are no existing surface locations or flowlines within 2, 000’ of this location.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3-D Seismic, Enhanced Surface Render ings (ESR’s) and ESR’s with amplitudes applied, MC 721, Proposed Location C appears suitable for the planned activity.Site Assessment, MC 721, Proposed Location D:

Mississippi Canyon 721, Proposed Location D is located in a water depth of approximately 3,688 ’ . Hummocky topography is identified 250 ’ south of proposed location, and a seafloor gully is identified 1,700 ’ east of location D.

The stratigraphy at the site of MC 721, Proposed Location D consists of:

• Unit 1 (Seafloor - 614' BML ) - 22 feet of drape over 592 feet of alternating intervals of bedded clays and chaotic mass-transport deposits (MTDs).

• Unit 2 (614'

–

1,510' BML) - 457 feet of bedded hemipelagic muds and chaotic mud-rich MTDs and 439 feet of MTDs with sand seams and pockets.

• Unit 3 - Blue Unit (1,510'

– 2,517' BML)

–

1,007 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

• Unit 4 (2,517'

–

3,375' BML) - 858 feet of mud-rich turbidites and MTDs.

• Unit 5 (3,375'

–

4,779' BML)

–

1,403 ’ of mud-rich turbidites. A fault will be penetrated 4,441 ’
BML.

A fault will be penetrated 4, 441 ’ below the mud line. The casing program is designed for fault penetration.

Shallow Water Flow Potential Negligible Potential - Seafloor to 1,071' B ML Low Potential

– 1,071' to 1,510' BML High Potential

– 1,510' to 2,517' BML Low Potential

– 2,517 to 4,779' BML

Shallow Gas Potential Negligible Potential - Seafloor to 1,510' BML Low Potential

– 1,510' to 4,779' BML

High amplitude reflectors are identified 500 ’ southwest and 500 ’

southeast of location in Unit 3 (1,510 ’ to 2,517' BML) and this location will not penetrate any high amplitudes.

Benthic/Anchor Assessment, MC 721, Proposed Location D (no anchors

– DP Vessel)

Mississippi Canyon 721, Proposed Location D is located in a water depth of approximately 3,688 ’ . Hummocky topography is identified 250 ’ south of proposed location. A seafloor gully is identified 1,700 ’ east of location.

There is no evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2, 000’ of proposed location. This location will not disturb any high-density areas of benthic
communities.

There are no marine avoidances areas identified within 2, 000’ of this location

.

Currently, there are no existing surface locations or flowlines within 2, 000’ of this location.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3-D Seismic, Enhanced S urface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 721, Proposed Location D appears suitable for the planned activity.Site Assessment, MC 720, Proposed Location E:

Mississippi Canyon 720, Proposed Location E is located in a water depth ap proximately 3,255 ’

.

The stratigraphy at the site of MC 720, Proposed Location E consists of:

 Unit 1 (Seafloor

– 527’ BML) – 22 ’ of drape over chaotic mass-transport deposits (MTDs), 342 ’ of alternating intervals of bedded clays and chaotic MTDs, and 163 ’ of chaotic MTDs with possible thin sand seams and pockets.

 Unit 2 (527’ –

2, 006’ BML) –

242 ’ of mud-rich MTDs, 455 ’ of bedded mud-rich turbidites, and 945 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 3 Blue Unit (2, 006’ – 3, 018’ BML) – 1012 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 4 (3,018

–

3, 778’ BML) –

760 ’ of mud-rich turbidities and MTDs, with possible thin sand seams.

 Unit 5 (3, 778’ –

5, 969’ BML) –

1,297 ’ of discontinuous mud-rich turbidites with possible thin sand

seams.

Shallow Water Flow Potential Negligible Potential

– Seafloor to 364’ BML Low Potential

– 364’ to 527’ BML Negligible Potential

– 527’ to 1

, 224’ BML Moderate Potential

– 1, 224’ to 2

, 006’ BML High Potential

– 2, 006’ to 3

, 018’ BML Low Potential

– 3, 018’ to 5

, 969’ BML

Shallow Gas Potential Negligible Potential

– Seafloor to 1, 224’ BML Low Potential

– 1, 224’ to 5

, 969’ BML

There are no high amplitude reflectors identified within 500 feet of Proposed Location E.

Benthic/Anchor Assessment, MC 720, Proposed Location E (no anchors

– DP Vessel)

Mississippi Canyon 720, Proposed Location E i s located in a water depth approximately 3,255 feet.

There is no evidence of surface or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2000’ of this location. The location will not disturb any high-density area of benthic communities.

There are no marine avoidances identified within 2, 000’ of location.

Shell’s 18” oil flowline is identified 1

, 420’ east of this location . This flowline and the 500’ avoidance area associated with the flowline are within 2, 000’ of this location. Currently, there are no other wells or flowlines identified within 2, 000’ of location.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3-D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 720, Proposed Location E appears suitable for the planned activity.Site Assessment, MC 720, Proposed Location F:

Mississippi Canyon 720, Proposed Location F is located in a water depth of approximately 3,190 ’ and will be positioned 840 ’

upslope of the thalwag of an easterly trending valley.

The stratigraphy at the site of MC 720, Proposed Location E consists of:

 Unit 1 (Seafloor

– 575’ BML) – 15 ’ of drape over 325 ’

of alternating intervals of bedded silty clays and
235 ’ of chaotic MTDs with possible thin sand seams and pockets.

 Unit 2 (575’ –

2, 217’ BML) –

665 ’ of bedded mud-rich MTDs, 339 ’ of discontinuous overbank deposits with mud-rich sand seams and pockets, and 638’ of levee overbank and canyon fill sediments that are mud-rich sediments with scattered sand seams and pockets

 Unit 3 Blue Unit (2, 217’ – 2, 814’ BML) –

597 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 4 (2, 814’ –

3, 548’ BML) –

734 ’ of mud-rich turbidites and MTDs with possible thin sand seams.

 Unit 5 (3, 548’ –

5, 231’ BML) –

801 ’ of discontinuous mud-rich MTDs and 882 ’ of mud-rich turbidites.

Shallow Water Flow Potential Negligible Potential

– Se afloor to 340’ BML Low Potential

– 340’ to 575’ BML Negligible Potential

– 575’ to 1

, 240’ BML Low Potential

– 1, 240’ to 1

, 579’ BML Moderate Potential

– 1, 579’ – 2, 217’ BML High Potential

– 2, 217’ to 2

, 814’ BML Low Potential

– 2, 814’ to 5

, 231’ BML

Shallow Gas Potential Negligible Potential

– Seafloor

–

1, 579’ BML Low Potential

– 1, 579’ to 5

, 231’ BML

There are no high amplitude reflectors identified within 500 ’ of proposed location.

Benthic/Anchor Assessment, MC 720, Proposed Location F (no anchors

– DP Vessel)

Mississippi Canyon 720, Proposed Location F is located in a water depth of approximately 3 ,190 ’ and will be positioned 840 ’

upslope of the thalwag of an easterly trending valley.

There is no evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2, 000’ of this location. This location will not disturb any high-density areas of benthic communities.

Three marine avoidances are identified within 2,000 ’ of Proposed Location F:

Avoidance Zone Number Avoidance Size X Coordinate Y Coordinate Distance from Prop. Loc F Direction from

Prop Loc F
2

, 839 100’ 936

, 869 10

, 250

, 377 982’ West southwest
2

, 841 100 ’ 937

, 722 10

, 249

, 573 1

, 327’ South
5
, 620 50’ 935

, 997 10

, 250

, 360 1

, 786 West

Currently, there are no existing surface locations or flowlines within 2, 000’ of proposed location.Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub -Bottom profiler, Frequency Enhanced 3- D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 720, Proposed Location F appears suitable for the planned activity.

Site Assessment, MC 720, Proposed Location G:

Mississippi Canyon 720, Proposed Location G is located in a water depth of approximately 3,125 ’

.

The stratigraphy at the site of MC 720, Proposed Location G consists of:

 Unit 1 (Seafloor

– 615’ BML) – 18 ’ of drape over 417 ’

of alternating intervals of bedded clays and chaotic mass-transport deposits (MTDs), and 180 ’ of mud-rich MTDs.

 Unit 2 (615’ –

2, 072’ BML) –

305 ’ of mud-rich MTDs, 280 ’ of bedded mud-rich MTDs, 554 ’ of mud-rich overbank deposits and 318 ’ of mud-rich discontinuous channel/levee and overbank deposits with thin sand seams and pockets.

 Unit 3 Blue Unit (2, 072’ – 3, 108’ BML) – 1036 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 4 (3, 108’ –

3, 869’ BML) –

761 ’ of mud-rich turbidites and MTDs with possible thin sand seams.

 Unit 5 (3, 869’ –

6, 091’ BML) –

629 ’ of discontinuous mud-rich MTDs with possible thin sand seams and layers, and 1,593 ’

of mud-rich turbidites.

Shallow Water Flow Potential Negligible Potential

– Seafloor to 615’ BML Low Potential

– 615’ to 1

, 754’ BML Moderate Potential

– 1, 754’ to 2

, 072’ BML High Potential

– 2, 072’ to 3

, 108’ BML Low Potential

– 3, 108’ to 3

, 869’ BML Moderate Potential

– 3, 869’ to 4

, 498’ BML Low Potential

– 4, 498’ to 6

, 091’ BML

Shallow Gas Potential Negligible Potential

– Seafloor to 1, 754’ BML Low Potential

– 1, 754’ to 6

, 091’ BML

A high amplitude reflector is identified 500 feet east of this location in Unit 2 (615’ – 2, 072’ BML). This location will not penetrate any high amplitude reflectors.

Benthic/Anchor Assessment, MC 720, Proposed Location G (no anchors

– DP Vessel)

Mississippi Canyon 720, Proposed Location G is located in a water depth of approximately 3 ,125 ’

.

There is no evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsions within 2, 000’ of this location. This location will not disturb any areas of high-density benthic communities.

There are no marine avoidance areas identified within 2, 000’ of location. Sonar target 62 is located 2, 085 ’ east of location with a 100’ avoidance area. This 100’ avoidance area does appear within the 2

, 000’ clearance area for location.

Shell’s 18” oil flowline is identified 2 ,200 ’ east of location. Although this flowline is not within 2, 000’ of location , the 500’ avoidance for the flowline is.

Currently, there are no existing surface locations within 2, 000’ of location.Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3- D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 720, Proposed Location G appears suitable for the planned activity.

Site Assessment, MC 722, Proposed Location H:

Mississippi Canyon 7 22, Proposed Location H is located in a water depth of approximately 3,734 ’

.

The stratigraphy at the site of MC 722, Proposed Location H consists of:

 Unit 1 (Seafloor

– 570’ BML) – 19 ’ of drape over 451 ’

of alternating intervals of bedded clays and cha otic mass-transport deposits (MTDs), and 100 ’ of chaotic MTDs with possible thin sand seams and pockets.

 Unit 2 (570’ –

1, 443’ BML) –

962 ’ of alternating bedded mud-rich turbidites, muddy MTDs.

 Unit 3 Blue Unit (1, 443’ – 2, 528’ BML) –

1,095 ’ of basin floor fan that is sand-rich with discontinuous moderate to high amplitude reflectors.

 Unit 4 (2, 528’ –

3, 039’ BML) –

511 ’ of mud-rich turbidites and MTDs with possible thin sand seams.

 Unit 5 (3, 039’ –

4, 271’ BML) –

1,232 ’ of discontinuous mud-rich turbidities and chaotic MTDs with possible thin sand pockets and layers.

Shallow Water Flow Potential Negligible Potential

– Seafloor to 470’ BML Low Potential

– 470’ to 570’ BML Negligible Potential

– 570’ to 1

, 443’ BML Hig h Potential

–

1, 443’ to 2

, 528’ BML Low Potential

– 2, 528’ to 4

, 271’ BML

Shallow Gas Potential Negligible Potential

– Seafloor to 1, 443’ BML Low Potential

– 1, 443’ to 4

, 271’ BML

There are no high-amplitude reflectors identified within 500 feet of Proposed Location H.

Benthic/Anchor Assessment, MC 722, Proposed Location H (no anchors

– DP Vessel)

Mississippi Canyon 722, Proposed Location H is located in a water depth of approximately 3 ,734 ’

.

There is no evidence of seafloor or near-surface faulting, slumping, amplitudes or fluid expulsion features within 2, 000’ of proposed location. This location will not disturb any high-density areas of benthic
communities.

There are no marine avoidances identified within 2, 000’ of proposed location

.

Currently, there are no existing surface locations or flowlines within 2, 000’ of proposed location.

Conclusion:

Based on a high-resolution geophysical survey consisting of AUV Side Scan Sonar and Sub-Bottom profiler, Frequency Enhanced 3-D Seismic, Enhanced Surface Renderings (ESR’s) and ESR’s with amplitudes applied, MC 722, Proposed Location H appears suitable for the planned activity.B. Topographic Features Map

The proposed activities are not within 1,000 ' of a no-activity zone or within the 3-mile radi us zone of an identified topographic feature. Therefore, no map is required per NTL No. 2008-G04.

C. Topographic Features Statement (Shunting)

Shell does not plan to drill more than two wells from the same surface location within the Protective Zone of an identified topographic feature. Therefore, the topographic features statement required by NTL No. 2008- G04 is not applicable.

D. Live Bottoms (Pinnacle Trend) Map

The activities proposed in this plan are not within 200' of any pinnacle trend feature with vertical relief equal to or greater than 8'. Therefore, no map is required per NTL No. 2008-G04.

E. Live Bottoms (Low Relief) Map

The activities proposed in this plan are not within 100' of any live bottom low relief features. Therefore, no map is required per NTL No. 2008-G04.

F. Potentially Sensitive Biological Features

The activities proposed in this plan are not within 200' of any potentially sensitive biological features. Therefore, no map is required per NTL No. 2008-G04.

G. Remotely Operated Vehicle (ROV) Monitoring Plan

In accordance with the provisions of NTL 2008-G06, Remotely Operated Vehicle Surveys in Deepwater

, Mississippi Canyon Block s 720, 721 & 722 are located in Grid 13. Grid 13 is an area that does have adequate ROV survey coverage; therefore we are not required to run the pre- and post-ROV survey in accordance with NTL 2008- G0 6.

H. Threatened and Endangered Species Information

Under Section 7 of the Endangered Species Act (ESA) all federal agencies must ensure that any actions they authorize, fund, or carry out are not likely to jeopardize the continued existence of a listed species, or destroy or adversely modify its designated critical habitat.

In accordance with the 30 CFR 250, Subpart B, effective May 14, 2007 and further outlined in Notice to Lessees (NTL) 2008-G04, lessees/operators are required to address site-specific information on the presence of federally listed threatened or endangered species and critical habitat designated under the ESA and marine mammals protected under the Marine Mammal Protection Act (MMPA) in the area of proposes activities under this plan.

Currently there are no designated critical habitats for the listed species in the Gulf of Mexico Outer Continental Shelf; however, it is possible that one or more of these species could be seen in the area of our operations. The following table reflects the Federally-listed endangered and threatened species in the lease area and along the northern Gulf coast:Common Name S cientific Name T/E Status

Hawksbill Turtle Eretmochelys imbricata E
Green Turtle Chelonia mydas T /E Kemp's Ridley Turtle Lepidochelys kempii E
Leatherback Turtle Dermochelys coriacea E Loggerhead Turtle Caretta caretta T

Table 6. 6

– Threatened and Endangered Sea Turtles

The green sea turtle is threatened, except for the Florida breeding population, which is listed as endangered.

There are 29 species of marine mammals that may be found in the Gulf of Mexico (see Table 6. 7 below). Of the species listed as Endangered, only the Sperm whale is commonly found in the project area. No critical habitat for these species has been designated in the Gulf of Mexico.

Common Name Scientific Name T/E Status Atlantic Spotted Dolphin Stenella frontalis
Blainville's Beaked Whale Mesoplodon densirostris

Blue Whale Balaenoptera musculus E Bottlenose Dolphin Tursiops truncatus Bryde's Whale Balaenoptera edeni Clymene Dolphin Stenella clymene

Cuvier's Beaked Whale Ziphius cavirostris Dwarf Sperm Whale Kogia simus
False Killer Whale Pseudorca crassidens
Fin Whale Balaenoptera physalus E Fraser's Dolphin Lagenodelphis hosei

Gervais' Beaked Whale Mesoplodon europaeus Humpback Whale Megaptera novaeangliae E
Killer Whale Orcinus orca Melon

- headed Whale Peponocephala electra

Minke Whale Balaenoptera acutorostrata

North Atlantic Right Whale Eubalaena glacialis E Pantropical Spotted Dolphin Stenella attenuata Pygmy Killer Whale Feresa attenuata Pygmy Sperm Whale Kogia breviceps Risso's Dolphin Grampus griseus Rough

- toothed Dolphin Steno bredanensis

Sei Whale Balaenoptera borealis E
Short

- finned Pilot Whale Globicephala macrorhynchus Sowerby's Beaked Whale Mesoplodon bidens Sperm Whale Physeter macrocephalus E Spinner Dolphin (Long

- snouted) Stenella longirostris Striped Dolphin Stenella coeruleoalba

Florida manatee Trichechus manatus E

Table 6. 7

– Threatened and Endangered Marine MammalsThe blue, fin, humpback, North Atlantic right and sei whales are rare or extralimital in the Gulf of Mexico and

are unlikely to be present in the lease area. The Environmental Impact Analysis found in Section 18 discusses potential impacts and mitigation measures related to threatened and endangered species

.

I. Archaeological Report

The following reports were used in this analysis:

C&C Technologies, Archaeological Assessment Report, Blocks 676-678, 720-722, 765-766, and Vicinity, Mississippi Canyon Area, Project No. 097403 -097494, December, 2009. AUV side-scan sonar and sub-bottom profiler data.

C&C Technologies, Archaeological and Hazard Report, Blocks 808, 809, 852, 853 and Vicinity, Mississippi Canyon Area, Project No. 083986-084109, February, 2009. AUV side-scan sonar and sub-bottom profiler data.

C&C Technologies, Archaeological Assessment Report, Block 854 and Vicinity (Blocks 809-811, 853, 855, 897-899), Mississippi Canyon Area, Project No. 072879-072915, August 2007. AUV side-scan sonar and subbottom profiler data.

Archaeological Analysis

Dec 2009 Report:

Assessment of 2006, 2008, and 2009 survey data from Blocks 675-679, 719-723 and 763-767, Mississippi Canyon Area revealed 302 unidentified sonar contacts. These contacts appear to be mostly the result of lease development activity, or dumped barrels of industrial waste. They may represent hazards to lease development, but no areas are recommended for investigation or avoidance on the basis of archaeological potential, except the unidentified target located in Block 765, Mississippi Canyon Area that BOEM has established a 1,000 ’

avoidance zone around.

Shipwreck remains possibly could exist undetected or unidentified within the survey area. If wood beams, planking, ceramics, or other possibly cultural materials are encountered during lease development, the BSEE archaeologists should be contacted within 48 hours for an assessment of antiquities. In this event, no activities should be conducted near the area of discovery until advised by the appropriate BOEM personnel (See NTL No. 2005- G07, Archaeological Resource Surveys and Reports, Sections “Authority” through “Required Notification of the Discovery of Shipwrecks on the Seafloor”).

Feb 2009 Report:

Assessment of the 2006, 2007, and 2008 survey data from Blocks 764-766, 807-810, 851-854, and 895-898, Mississippi Canyon Area revealed 1,334 unidentified sonar contacts. None of the sonar contacts are suggestive of significant submerged cultural resources. These contacts appear to be mostly the result of lease activity, or dumped barrels of industrial waste. They may represent hazards to lease development, but no areas are recommended for investigation or avoidance of the basis of archaeological potential.

Shipwreck remains possibly could exist undetected or unidentified within the survey area. If wood beams, planking, ceramics, or other possibly cultural materials are encountered during lease development, the BSEE archaeologists should be contacted within 48 hours for an assessment of any antiquities. In this event, no activities should be conducted near the area of discovery until advised by the appropriate BOEM personnel (See NTL No. 2005- G07, Archaeological Resource Surveys and Reports, Sections “Authority” through “Required Notification of the Discovery of Shipwrecks on the Seafloor”).Aug 2007 Report:

The assessment of the survey data in Block 854, and vicinity, Mississippi Canyon Area revealed at least two hundred eighty-eight (288) unidentified sonar contacts within the survey area. These contacts are likely modern debris resulting from lease activity, other shipping activity, or dumped barrels of industrial waste. If the contacts are barrels of industrial waste, they may represent a potential biological hazard. None of these contacts are suggestive of significant submerged cultural resources and none are recommended for avoidance because of archaeological concerns.

A possibility exists that shipwreck remains could be undetected or unidentified within the survey area. If wood beams, planking, ceramics or other possibly cultural materials are encountered during lease development, the BSEE archaeologists must be contacted within 48 hours for an assessment of any antiquities. In this event, no activities should be conducted near the area of discovery until advised by the appropriate BOEM personnel.

Shell will comply with all conditions of NTL 2008-G 20

.

J. Air and Water Quality Information

Mississippi Canyon Block 720 is located 39 miles from the nearest shoreline. Drilling/completion operations will produce air pollutant emissions, but as provided in the Air Emissions Spreadsheet (see Section 8 of this Plan), these operations are below the exemption levels.

These drilling operations will result in the discharge of authorized effluents under the EPA Region VI General permit. Impacts of these discharges are expected to be minimal on water quality in the area.

For specific information relating to air and water quality information please refer to Section 18.

K. Socioeconomic Information

1) Shell will utilize its existing shorebase located in Fourchon, Louisiana which is fully staffed and operational and does not expect to employ persons from within the State of Florida.

2) Shell does not expect to purchase major supplies, services, energy, water or other resources from within the State of Florida for these operations.

3) Shell does not expect to hire contractors or vendors from within the State of Florida.

For specific information relating to socioeconomic information please refer to Section 18 in this Plan

.

# OLYMPUS Host – MARS “B” Development

MISSISSIPPI CANYON BLOCK 807



# Waste Barrel Avoidance and Release Response in the Mississippi Canyon

Area

Project OLYMPUS Host – MARS “B” Development

Document Title Waste Barrel Avoidance and Release Response in the Mississippi Canyon Area

Document Number MRB-100-HX-0505-0000002-000

Document Revision REV 2

Version Code Not Applicable

Document Status Issued for Review

EIS Discipline / Document Type Hazard Analysis Report

Originator / Author Robert Kuehn

Classification Restricted

ECCN EAR 99

Issue Date 10/20/10

Revision History is shown on next pageDocument Number -Rev Page 2 of 8
RESTRICTED 

### REVISION HISTORY
Rev # Date of
Issue Issue Description Originator Reviewer Approver

2 10/20/10 Formalized existing
document into Document Mgmt

program RB Kuehn RB Kuehn Nilesh Popat

SummaryDocument Number -Rev Page 3 of 8
RESTRICTED 

### Contents

PURPOSE ....................................................................................................................... ..... 4

REVISION HISTORY ....................................................................................................... 4

BACKGROUND ................................................................................................................. 4

N ORMAL 

### O PERATIONS 

### ....................................................................................................... 5
D ECONTAMINATION OF 

### E QUIPMENT 

### ................................................................................... 6

### Waste Barrel Avoidance and Release Re sponse in the Mississippi Canyon Area
10/20/10 REV 2

4 of 8 

# Purpose

This document provides expectations and guida nce for avoiding, and responding to a release of the contents of, a seafloor waste barrel. The pr ocedures below describes Shell’s expectations for routine barrel avoidance, data management, and response to inadvertent release of barrel

contents.



# Applicability

This document applies to all ROV, anchor and other operations which could cause a seafloor barrel rupture.

Changes to this procedure must be approved by BOEMRE. 1



# Revision History

Date Person Revision 12/16/08 RBKuehn Incorporated comments from MMS 2 and issued as final. 8/16/10 RBKuehn Incorporated comment from BOEMRE 3 to include New Orleans District manager in the notification of Step 2 of the section Barrel Impact Reporting.

Also revised all relevant references to MMS as BOEMRE
10/20/10 RBKuehn 3⁄4 In Background, added in summary of suspected materials disposed at the site, based on research of the site in public records. 3⁄4 In section on Equipment Decontamination- Decon Procedure:

o clarified what types of detergents are preferred/allowed, using the NPDES Vessel General Permit as a guide.

o Expanded on appropriate PPE and other personnel precautions

o Noted a need for secondary containment as appropriate

Significant changes to the text are shown in yellow shade. 3⁄4 Added page numbers and cleaned up format.

3⁄4 Issued as REV 2



# Background Various projects will be carried out in an area of the Miss issippi Canyon known to contain
barrels of chemical waste.

1 Per MMS approval of West Bor eas Supplemental Ex ploration Plan, MS 5231 December 16, 2008 Control No. S-07273, Lease(s) OCS-G07957, Block 762, Mississippi Canyon Area OCS-G07962, Block 806, Mississippi Canyon Area
2 Per MMS approval of West Bor eas Supplemental Ex ploration Plan, MS 5231 December 16, 2008 Control No. S-07273, Lease(s) OCS-G07957, Block 762, Mississippi Canyon Area OCS-G07962, Block 806, Mississippi Canyon Area

3 Per BOEM approval of the Supplement to the Conceptual DWOP for Mars B project, 8/12/10, MS 5220

### Waste Barrel Avoidance and Release Re sponse in the Mississippi Canyon Area
10/20/10 REV 2

5 of 8 • The barrels were discharged in this ar ea in the 1970’s under government approved permits.

• The content, and its toxicity, of each indivi dual barrel is not known. However, there are records of a wide range of i ndustrial waste materials that we re disposed in the barrels including chlorinated hydrocarbons and liquid metal salts. Below is a summary of the
barrel contents based on available records.

1. Metallic sodium and calcium; calcium oxide, sodium oxide, and inert salts. 4



### 2. 80-90% dichlorobutene, 20% organic high-boilers, and 1% quaternary ammonium salts. “Other wastes produ ced from the manufacture of fungicides
and herbicides”. 5



### • Within the area there are/could be many hundred s of waste barrels. Ma ny of the barrels may have released their contents over time. However, an unknown numb er of barrels still look intact, and they may or may not still contai n their original conten t. Also, as some of
the barrels contained metal based solid wast e, some of the barrels that no longer look intact may still contain some waste.

• Extensive sonar surveys of the area exist and are available for planning purposes.



# Potential Hazards

Although there are no records of any issues rega rding the barrels during the many years of Oil and Gas operations in the Mississippi Canyon area, the following potential hazards exist:

• Personnel exposure or equipment damage due to adherence of waste chemicals to recovered subsea equipment

• Equipment damage from sodium exposur e to water (very vigorous reaction).



# Normal Operations

For normal operations, all contractors and Shell employees must meet the following expectations:

1. Shell’s over-arching policy is to avoid barrel contact.

2. Press releases making any reference to the ch emical waste or barre ls, or any incidents involving any chemical waste or barrels, will require the ex press written permission from

4 EPA Permit Application No. 730D009E from Ethyl Co rp, March 1, 1977, Public Notice April 20, 1977,

5 Chapter 5 “Ocean Discharge” in the book Assessing Potentia l Ocean Pollutants, A Report of the Study Panel on Assessing Potential Ocean Pollutants. National Academy of Sciences, Wash ington DC, 438 pp. This document details DuPont’s application to dispose of the following at the ocean disposal site

### Waste Barrel Avoidance and Release Re sponse in the Mississippi Canyon Area
10/20/10 REV 2

6 of 8 Shell.

3. All recorded video material is confidential and the property of Shell (standard contract provision).

If during normal ROV operations there is a discovery of any potential archaeological resource (i.e., cannot be definitiv ely identified as waste barrel/b arrel remnant, modern debris, or refuse), any seafloor-disturb ing activities in its proximity, must be stopped, the discovery must be reported to Dr. Chris Horrell at 504-736-2796, and further in structions must be obtained before proceeding.

4. Equipment Placement/Stand-off Distance
4.1. A safe stand-off distance from the waste barr els is considered 10m (33ft). Care must be taken that flexible components (e.g. ROV te ther, anchor lines, seismic cables) are controlled as well (e.g. don’t drag through a barrel field).
4.2. If a seafloor action will genera te cuttings or debris, increa se the stand-off distance as
needed to avoid debris c ontact with nearby barrels.
4.3. Do not investigate any barrels or remainders of barrels. Remain the minimum stand-off of 10m (33ft) at all times.
4.4. Survey the anchor/pile/export locations with an ROV to ensure barrel avoidance.
4.5. Record the (approximate) location of any chem ical waste barrel seen, if feasible, without getting closer than the 10m (33ft) stand-off distance.

5. Contact the Shell EP Company Environmental Du ty Phone for any questions or concerns. 1-
504-390-1330

6. Decontamination of Equipment: In the event of contact with a barrel contents decontaminate equipment per Decontamination of Equipment below.

7. Make reports of barre l contact/rup ture per Barrel Release Reporting below.



# Decontamination of Equipment

1. General In the unlikely case that contact is suspected or has been made with any wastes from a barrel, appropriate action needs to be taken to guarantee the topside safety of personnel handling the equipment (e.g. ROV, anchor lines, etc). 

## It is left solely to the judgment of the Person-in-Charge of the equipment/vessel to determine if it is necessary to abandon all or part of the equipment on the sea floor.

2. Decon Procedure

### Waste Barrel Avoidance and Release Re sponse in the Mississippi Canyon Area
10/20/10 REV 2

7 of 8 Based on various factors 6 

### , Shell recommends the following:

2.1. Use the ocean to “wash” the equipment (e.g. fl y an ROV for at least an hour at depth high enough above sea floor to prevent umbili cal dragging or other disturbance of the sea floor). For other equipment, provide any movement through the water column that’s possible, again avoi ding seafloor dragging.

2.2. Retrieve the equipment to the surface, but do not bring onboard if feasible.

2.3. Hose the equipment off befo re retrieving onto the vessel . Use as high a water flow as
is available/safe. CAUTION - detergent/soap may be used BUT in as low a quantity as practicable to minimize foam. Only non-toxic and phosphate free cleaners and detergents may be used. Furthermore, cleaner s and detergents should not be caustic or only minimally caustic and should be biodegradable 7



### .

2.4. Avoid physical contact with the equipment, and keep the equipment off the vessel at this point..

2.5. Dunk the equipment back in the sea and “w ash” the equipment for approximately 15
minutes.

2.6. Retrieve the equipment to the surface. Before recovering, visually inspect the equipment, umbilical, cable surfaces with binoculars for signs of corrosion, discoloration, air reac tion such as fuming/smoking, or any other signs of chemical contact. Rewash and dunk the equipment as needed.

2.7. Retrieve the equipment onto the back d eck. Monitor the equipment and surrounding storage area for indications of chemical contamination (corrosion, discoloration, air reaction such as fuming/smoking, etc). Estab lish secondary containment as necessary to collect any potentially contaminated drips.

2.8. Only essential personnel should be allowed near the equipment, once retrieved on the
back deck.

2.9. While performing cleaning operations on th e equipment, involving contact with potentially contaminated surfaces, persona l protective equipment must be worn including, but not limited to: safety eye goggl es, safety clothing su ch as coverall and

6 Shell assumes, for purposes of this decontamination guidance, that:

• The most toxic material identified in the disposal area’s permit s and other available documents is involved . However Shell ca nnot guarantee there are not other toxic materials present than t hose identified in the permits and other documents.

• It is assumed that the materials do not chemically interact with the materials of the ROV, its tools and equipment.

7 The NPDES General Permit for Discharges Incidental to the Normal Operation of a Vessel provides insight into managing any washing. Also, EPA provides the following definitions: “Non-toxic” soaps, cleaners, and detergents means these materials which do not exhibit potentially harmful characteristics as defined by the Consumer Product Safety Commission regulati ons found at 16 CFR Chapter II, Subchapter C, Part 1500. “Phosphate Free” soaps, cleaners, and detergents m eans these materials which contain, by weight, 0.5% or less of phosphates or derivatives of phosphates.

### Waste Barrel Avoidance and Release Re sponse in the Mississippi Canyon Area
10/20/10 REV 2

8 of 8 aprons, Nitrile type chemi cal resistant industrial-safe ty gloves, and PVC boots.

2.10. Wash hands thoroughly and take a shower after performing cl eaning operations on the equipment.

2.11. Avoid drinking liquids or eating food in the work area.

2.12. If contamination is still suspected, consult with the Shell representatives/management for further actions including additiona l washing, abandonment on the seafloor, segregated storage on the boat, wrapping the equipment partially or fully in plastic sheeting, etc.

2.13. Document all actions an d results in a log.



# Barrel Impact Reporting

1. Initial reporting:

1.1. Equipment operator is to inform the Shell onsite representative and the Shell operations supervisor on duty.

1.2. The Shell onsite representative or the Shell operations supervisor will call the SEPCO Environmental Duty Engineer at 1-504-390-1330. As a back-up, call 337- 281-0783 (Rob Kuehn).

• The call should be made at the earliest convenience.

• Be prepared to report the lat/long of the ruptured barrel (not the surface location) and water depth.

2. The SEPCO Environmental Duty Engineer will call

• the regulatory Affairs Duty Phone 504-782-7823,

• Mr. Broussard of the BOEMRE (504-736-3245) and

• BOEMRE New Orleans District Manager

to report the event. The call should include the lat/long and any circ umstances of note.

3. Follow-up Reporting The SEPCO Environmental Duty Engineer or Rob Kuehn follows up with an email to
Mr. Broussard of BOEMRE.

The BOEMRE have requested submission of a copy of whatever relevant video is available for the event period. No dedicated video survey is required for a barrel rupture (i.e. just be prepared to submit whatever video was obtained as normal part of the activities). BOEM has agreed we can submit any video after the project is completed.Attachment 6A

– Enhanced Seafloor Rendering MapAttachment 6B

– Enhanced Seafloor Rendering MapAttachment 6C

– Enhanced Seafloor Rendering MapAttachment 6D

– Enhanced Seafloor Rendering MapAttachment 6E

– Enhanced Seafloor Rendering MapAttachment 6F

– Enhanced Seafloor Rendering MapAttachment 6G

– Enhanced Seafloor Rendering MapAttachment 6H

– Enhanced Seafloor Rendering MapSECTION 7: WASTE AND DISCHARGE INFORMATION

A. Projected Ocean DischargesB. Projected Generated Wastes

C. Modeling Report

The proposed activities under this plan do not meet the U.S. Environmental Protection Agency requirements for an individual NPDES permit. Therefore, modeling report requirements per NTL No. 2008-G04 is not applicable to this EP.SECTION 8: AIR EMISSIONS INFORMATION

A. Emissions Worksheet and Screening Questions

Screening Questions for EP’s Yes No

Is any calculated Complex Total (CT) Emission amount (in tons) associated with your proposed exploration activities more than 90% of the amounts calculated using the following formulas: CT = 3400D 2/3 for CO and CT 33.3D for the other air pollutants (wher e D distance to shore in miles)? x

Do your emission calculations include any emission reduction measures or modified emission factors? x
Are your proposed exploration activities located east of 87.5° W longitude? x Do you expect to encounter H 2 S at concentrations greater than 20 parts per million (ppm)? x
Do you propose to flare or vent natural gas for more than 48 continuous hours From any proposed well? x
Do you propose to burn produced hydrocarbon liquids? x *Section 4 of this plan discusses H 2 S as “unknown” although H 2 S may be encountered.

If you answer no to all of the above screening questions from the appropriate table, provide:

(1) Summary information regarding the peak year emissions for both Plan Emissions and Complex Total Emissions, if applicable. This information is compiled on the summary form of the two sets of worksheets. You can submit either these summary forms or use the format below. You
do not need to include the entire set of worksheets.

Air Pollutant Plan Emission
Amounts (tons) Calculated

Exemption
Amounts (tons) Calculated

Complex Total
Emission
Amounts (tons)

PM
SO x NOx
VOC
CO

(2) Contact: Tracy Albert, 504.425.4652

, tracy.albert@shell.com

B. Worksheets

See Attachment 8A.Attachment 8A

– Air Quality Report

COMPANY Shell Offshore Inc.

AREA MC

BLOCK 720, 721, 722

LEASE 33170, 33171, 33172

PLATFORM MODU

WELL A

- H

COMPANY
CONTACT Jeff McMenis

TELEPHONE NO. 504

- 728

- 6021

REMARKS SEPCO Env File Name

- Queen_AQR_EP_NJD_091912.xlsxFuel Usage Conversion

Factors Natural Gas Turbines Natural Gas Engines Diesel Recip. Engine REF. DATE

SCF/hp

- hr 9.524 SCF/hp

hr 7.143 GAL/hp

hr 0.0483 AP42 3.2

- 1 4/76 & 8/84

Equipment/Emission Factors units PM SOx NOx VOC CO REF. DATE

NG Turbines gms/hp

- hr 0.00247 1.3 0.01 0.83 AP42 3.2

- 1& 3.1

- 1 10/96
NG 2

- cycle lean gms/hp

- hr 0.00185 10.9 0.43 1.5 AP42 3.2

- 1 10/96
NG 4

- cycle lean gms/hp

- hr 0.00185 11.8 0.72 1.6 AP42 3.2

- 1 10/96
NG 4

- cycle rich gms/hp

- hr 0.00185 10 0.14 8.6 AP42 3.2

- 1 10/96

Diesel Recip. < 600 hp. gms/hp

- hr 1 0.1835 14 1.12 3.03 AP42 3.3

- 1 10/96
Diesel Recip. > 600 hp. gms/hp

- hr 0.32 0.1835 11 0.33 2.4 AP42 3.4

- 1 10/96
Diesel Boiler lbs/bbl 0.084 0.3025 0.84 0.008 0.21 AP42 1.3

- 12,14 9/98

NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84 AP42 1.4

- 1, 14

- 2, & 14

- 3 7/98

NG Flares lbs/mmscf 0.593 71.4 60.3 388.5 AP42 11.5

- 1 9/91 Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21 AP42 1.3

- 1 & 1.3

- 3 9/98 Tank Vapors lbs/bbl 0.03 E&P Forum 1/93 Fugitives lbs/hr/comp. 0.0005 API Study 12/93 Glycol Dehydrator Vent lbs/mmscf 6.6 La. DEQ 1991 Gas Venting lbs/scf 0.0034

Sulphur Content Source Value Units

Fuel Gas 3.33 ppm

Diesel Fuel 0.05 % weight Per 40 CFR 80.510(a)(1), Locomotive and Marine (LM) diesel fuels are limited to 500 ppm maximum sulfur, effective June 1, 2007. Produced Gas( Flares) 3.33 ppm Produced Oil (Liquid Flaring) 1 % weightCOMPANY AREA BLOCK LEASE PLATFORM WELL

Shell Offshore Inc. MC 720, 721, 722 33170, 33171, 33172 MODU A

- H

Emitted Substance

Year

PM SOx NOx VOC CO

2013

- 2020 46.68 26.72 1602.09 48.15 349.54

Allowable 1631.70 1631.70 1631.70 1631.70 45527.76SECTION 9: OIL SPILL INFORMATION

A. Oil Spill Response Planning

All the proposed activities and facilities in this EP will be covered by the Regional OSRP filed by Shell Offshore Inc. (0689) in accordance with 30 CFR 250. An update to the Regional OSRP was filed with the BSEE October 26, 2010, March 15, 2011, May 31, 2011, July 6, 2011 and August 1, 2011, January, February and March 2012 and July 2012, and is pending approval. An updated OSRP Certification in accordance with 30 CFR 254.2 was accepted by the BSEE i n July 2012.

Spill Response sites are as follows:

Primary Response Equipment Locations Preplanned Staging Location(s) Venice, LA; Ft Jackcon, LA; Harvey, LA; Stennis,

MS; Pascagoula, MS Venice, LA; Pacagouls, MS ; Mobile, AL

Table 9.1

–

Response Equipment and Staging Areas

The names of the OSRO’s under contract include Clean Gulf Associates (CGA), Marine Spill Response Company (MSRC), Clean Caribbean America (CCA) and OSRL/EARL.

Category Sub

- Regional OSRP EP Type of Activity 1 Subsea Drilling Exploratory Drilling Facility Location (area/block) MC 391 MC 721 Facility Designation 2 Subsea well 1 ◊ Subsea well D Distance to Nearest Shoreline (miles) 70 49

Volume 3 Storage tanks (total) Flowlines (on facility) Pipelines Uncontrolled blowout (volume per day)
Total Volume N/A N/A N/A 416,414* BOPD 416,414 Bbls N/A N/A N/A

3 92 ,000** BOPD

3 55 ,000 Bbls Type of Oil(s)

- (crude oil, condensate, diesel) Crude oil Crude oil

API Gravity(s) 4 26o 28 o

Table 9.2 - Worst Case Scenario Determination

*24 hour rate ( 391 ,808 BOPD 30 day average) **24 hour rate ( 330 ,000 BOPD 30 day average)

◊ This well was reviewed and accepted by BOEM on July 10, 2012 during the drilling of the well. The 30-day average was updated in update to the OSRP July 2012

Since Shell Offshore Inc. has the capability to respond to the appropriate worst-case spill scenario included in its regional OSRP, filed with the BSEE October 26, 2010 and updated March 15, 2011, May 31, 2011, July 6, 2011 and August 1, 2011

, January, February, March and July 2012 and is pending approval, and since the worst-case scenario determined for our Plan does not replace the appropriate worst-case scenario in our regional OSRP, I hereby certify that Shell Offshore Inc. 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 our EP

.

Modeling:

Shell did not model a potential oil or hazardous substance spill for operations proposed in this plan.B. Oil Spill Response Discussion

1. Volume of the Worst Case Discharge

Please refer to Section 2J and 9D of this EP.

2. Trajectory Analysis

Trajectories of a spill and the probability of it impacting a land segment have been projected utilizing information in the BOEMRE Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the BOEMRE website using 30 day impact. Offshore areas along the trajectory between the source and land segment contact could be impacted. The land segment contact probabilities are shown in Table 9.C.1.

Area/Block OCS

- G Launch
Area Land Segment Contact %

Exploratory
MC721 33171 57 Galveston, TX 1 Jefferson, TX 1 Cameron, LA 3 Vermillion, LA 2 Iberia, LA 1 Terrebonne, LA 3 LaFourche, LA 3 Jefferson, LA 1 Plaquemines, LA 8 St. Bernard, LA 1 Okaloosa, FL 1

Table 9.C.1 Probability of Land Segment Impact C. Resource Identification

The locations identified in Table 9.C.1 are the highest probable land segments to be impacted using the BOEM Oil Spill Risk Analysis Model (OSRAM). The environmental sensitivities are identified using the appropriate National Oceanic and Atmospheric Administration (NOAA) Environmental Sensitivity Index (ESI) maps for the given land segment. ESI maps provide a concise summary of coastal resources that are at risk if an oil spill occurs nearby. Examples of at-risk resources include biological resources (such as birds and shellfish beds), sensitive shorelines (such as marshes and tidal flats), and human-use resources (such as public beaches and parks).

In the event an oil spill occurs, ESI maps can help responders meet one of the main response objectives: reducing the environmental consequences of the spill and the cleanup efforts. Additionally, ESI maps can be used by planners to identify vulnerable locations, establish protection priorities, and identify cleanup strategies.

The following is a list of resources of special economic or environmental importance that potentially could be impacted by the Mississippi Canyon 721 WCD scenario.

Onshore/Nearshore: Plaquemines Parish has been identified as the most probable impacted Parish within the Gulf of Mexico for the Greater than 10 Mile Worst Case Discharge and the Exploratory Worst Case Discharge. Plaquemines Parish has a total area of 2,429 square miles of which, 845 square miles of it is land and 1,584 square miles is water. Plaquemines Parish includes two National Wildlife Refuges: Breton National Wildlife Refuge and Delta National Wildlife Refuge. This area is also a nesting ground for the brown pelican, an endangered species. Examples of Environmental Sensitivity maps for Plaquemines Parish are detailed in the following pages. Key ESI maps for Plaquemines Parish and the legend are shown in Figures 9.C.1through 9.C.5.Offshore: An offshore spill may require an Essential Fishing Habitat (EFH) Assessment. This

assessment would include a description of the spill, analysis of the potential adverse effects on EFH and the managed species; conclusions regarding the effects on the EFH; and proposed mitigation, if applicable.

Significant pre-planning of joint response efforts was undertaken in response to provisions of the National Contingency Plan (NCP). Area Contingency Plans (ACPs) were developed to provide a well coordinated response to oil discharges and other hazardous releases. The One Gulf Plan is specific to the Gulf of Mexico to advance the unity of policy and effort in each of the Gulf Coast ACPs. Strategies used for the response to an oil spill regarding protection of identified resources are detailed in the One Gulf Plan and relevant Gulf Coast ACP.

D. Worst Case Discharge Response

Shell will make every effort to respond to the MC 721 Worst Case Discharge as effectively as possible. Below is a table outlining the applicable evaporation and surface dispersion quantity:

Mississippi Canyon Block 721 Calculations (BBLS)



### i. TOTAL WCD (based on 30 day average (per day)) ~352,000



### ii. Loss of volume of oil to natural surface dispersion and evaporation base (approximate bbls

per day)* (6% Natural surface evaporation and dispersion in 24 hrs) - 21,100

TOTAL REMAINING ~330,900

Table 9.D.1 Oil Remaining After Surface Dispersion

* As this scenario involves a surface blowout onboard the platform, an ADIOS 2 Model was ran to account for surface dispersion and evaporation.

Shell has contracted OSROs to provide equipment, personnel, materials and support vessels as well as temporary storage equipment to be considered in order to cope with a WCD spill. Under adverse weather conditions, major response vessels and Transrec skimmers are still effective and safe in sea states of 6-8 ft. If sea conditions prohibit safe mechanical recovery efforts, then natural dispersion and airborne chemical dispersant application (visibility & wind conditions permitting) may be the only safe and viable recovery option.

MSRC OSRV 8 foot seas VOSS System 4 foot seas Expandi Boom 6 foot seas, 20 knot winds Dispersants Winds more than 25 knots, Visibility less than 3 nautical miles, or Ceiling less than 1,000 feet.

Table 9.D.2 Operational Limitations of Response Equipment

Upon notification of the spill, Shell would request a partial or full mobilization of contracted resources, including, but not limited to, skimming vessels, oil storage vessels, dispersant aircraft, subsea dispersant, shoreline protection, wildlife protection, and containment equipment. Following is a list of the contracted resources including de-rated recovery capacity, personnel, and estimated response times (procurement, load out, travel time to the site, and deployment). The IncidentCommander or designee may contact other service companies if the Unified Command deems such

services necessary to the response efforts.

Based on the anticipated worst case discharge scenario, Shell can be onsite with dedicated, contracted on water oil spill recovery equipment with adequate response capacity to contain and recover surface oil, and prevent land impact, within 23 hours (based on the equipment’s Estimated Daily Response Capacity (EDRC)). Shell will continue to ramp up additional on-water mechanical recovery resources as well as apply dispersants and in-situ burning as needed and as approved under the supervision of the USCG Captain of the Port (COTP) and the Regional Response Team (RRT).

Subsea Control and Containment: Shell, as a founding member of the MWCC, will have access to the IRCS that can be rapidly deployed through the MWCC. The IRCS is designed to contain oil flow in the unlikely event of an underwater well blowout, and is designed, constructed, tested, and available for rapid response. Shell’s specific containment response for MC 721 will be addressed in Shell’s NTL 2010-N10 submission at the time the APD is submitte d.

Table 9.D.9 Control, Containment, and Subsea Dispersant Package Activation List

Mechanical Recovery (skimming): Response strategies include skimming utilizing available OSROs Oil Spill Response Vessels (OSRVs), Oil Spill Response Barges (OSRBs), ID Boats, and Quick Strike OSRVs. There is a combined de-rated recovery rate capability of approximately 853,000 barrels/day. Temporary storage associated with the identified skimming and temporary storage equipment equals approximately 1,038,000 barrels.

De

- rated Recovery Rate (bopd) Storage (bbls) Offshore Recovery and Storage 714,920 1,031,526 Nearshore Recovery and Storage 138,180 7,470

Total 853,421 1,038,996

Table 9.D.3 Mechanical Recovery Combined De-Rated Capability

Table 9.D.4 Offshore On -Water Recovery and Storage Activation List Table 9.D.5 Nearshore On-Water Recovery and Storage 5ctivation List

Oil Storage: The strategy for transferring, storing and disposing of oil collected in these recovery zones is to utilize two 150,000-160,000 ton (dead weight) tankers mobilized by Shell (or any other tanker immediately available). The recovered oil would be transferre d to Motiva’s Norco, LA storage and refining facility, or would be stored at Delta Commodities, Inc. Harvey, LA facility.

Aerial Surveillance: Aircraft can be mobilized to detect, monitor, and target response to oil spills. Aircraft and spotters can be mobilized within hours of an event.

Table 9.D.6 Aerial Surveillance Activation List

Aerial Dispersant: Depending on proximity to shore and water depth, dispersants may be a viable response option. If appropriate and approved, 4 to 5 sorties from three DC

- 3’s can be made within the first 12 hour operating day of the response. These aerial systems could disperse approximately 7,704 to 9,630 barrels of oil per day. Additionally, 3 to 4 sorties from the BE90 King Air and 3 to 4 sorties from the Hercules C-130A within the first 12 hour operating day of the response could disperse 4,600 to 6,100 barrels of oil per day. For continuing dispersant operations, the CCA’s Aerial Dispersant Delivery System (ADDS) would be mobilized. The ADDS has a dispersant spray capability of 5,000 gallons per sortie.Table 9.D.7 Offshore Aerial Dispersant Activation List

Vessel Dispersant: Vessel dispersant application is another available response option. If appropriate, vessel spray systems can be installed on offshore vessels of opportunity using inductor nozzles (installed on fire-water monitors), skid mounted systems, or purpose-built boom arm spray systems. Vessels can apply dispersant within the first 12-24 hours of the response and continually as directed.

Table 9.D.8 Offshore Boat Spray Dispersant Activation List

Subsea Dispersant: Shell has contracted with Wild Well Control for a subsea dispersant package. Subsea dispersant application has been found to be highly effective at reducing the amount of oil reaching the surface. Additional data collection, laboratory tests and field tests will help in facilitating the optimal application rate and effectiveness numbers. For planning purposes, the system has the potential to disperse approximately 24,500 to 34,000 barrels of oil per day.

Table 9.D.9 Control, Containment, and Subsea Dispersant Package Activation List

In -Situ Burning: Open-water in-situ burning (ISB) also may be used as a response strategy, depending on the circumstances of the release. ISB services may be provided by the primary OSRO contractors. If appropriate conditions exist and approvals are granted, one or multiple ISB task forces could be deployed offshore. Task forces typically consist of two to four fire teams, each withtwo vessels capable of towing fire boom, guide boom or tow line with either a handheld or aeriallydeployed oil ignition system. At least one support/safety boat would be present during active burning operations to provide logistics, safety and monitoring support. Depending upon a number of factors, up to 4 burns per 12-hour day could be completed per ISB fire team. Most fire boom systems can be used for approximately 8-12 burns before being replaced. Fire intensity and weather will be the main determining factors for actual burns per system. Although the actual amount of oil that will be removed per burn is dependent on many factors, recent data suggests that a typical burn might eliminate approximately 750 barrels. For planning purposes and based on the above assumptions, a single task force of four fire teams with the appropriate weather and safety conditions could complete four burns per day and remove up to ~12,000 bbls/day. In-situ burning nearshore and along shorelines may be a possible option based on several conditions and with appropriate approvals, as outlined in Section 19, In-situ Burn Plan (OSRP). In-situ burning along certain types of shorelines may be used to minimize physical damage where access is limited or if it is determined that mechanical/manual removal may cause a substantial negative impact on the environment. All safety considerations will be evaluated. In addition, Shell will assess the situation and can make notification within 48 hours of the initial spill to begin ramping up fire boom production through contracted OSRO(s). There are potential limitations that need to be assessed prior to ISB operations. Some limitations include atmospheric and sea conditions; oil weathering; air quality impacts; safety of response workers; and risk of secondary fires.

Table 9.D.10 In -Situ Burn Equipment Activation List

Shoreline Protection: If the spill went unabated, shoreline impact in Plaquemines Parish, LA would depend upon existing environmental conditions. Nearshore response may include the deployment of shoreline boom on beach areas, or protection and sorbent boom on vegetated areas. Strategies would be based upon surveillance and real time trajectories provided by The Response Group that depict areas of potential impact given actual sea and weather conditions. Strategies from the New Orleans, Louisiana Area Contingency Plan, Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. Shell has access to shoreline response guides that depict the protection response modes applicable for oil spill clean-up operations. Each response mode is schematically represented to show optimum deployment and operation of the equipment in areas of environmental concern. Supervisory personnel have the option to modify the deployment and operation of equipment allowing a more effective response to site-specific circumstances.Table 9.D.11 Shoreline Protection and Wildlife Support List

Wildlife Protection: If wildlife is threaten ed due to a spill, the contracted OSRO’s have resources available to Shell, which can be utilized to protect and/or rehabilitate wildlife. The resources under contract for the protection and rehabilitation of affected wildlife are in Table 9.D.11.

New or unusual technology in regards to spill, prevention, control and clean-up: Shell will use our normal well design and construction processes with multiple barrier approach as well as new stipulations mandated by NTL 2008-N05. Response techniques will utilize new learnings from Macondo response to include in-situ burning and subsea dispersant application. Mechanical recovery advancements are continuing to be made to incorporate utilization of Koseq arms outfitted on barges, conversion of Platform Support Vessels for Oil Spill Response, and inclusion of nighttime spill detection radar to improve tracking capabilities (X-Band radar, Infrared sensing, etc.). In addition, new response technologies/techniques are continuing to be considered by Shell and the appropriate government organizations for incorporation into our planned response. Any additional response technologies/techniques presented at the time of response will be used at the discretion of the Unified Command and USCG.Figure 9.C.2 South Pass ESI MapFigure 9.C.3 Garden Island Pass ESI MapFigure 9.C.4 Pass a Loutre West ESI MapFigure 9.C.5 Main Pass ESI MapTable 9.D.4 Offshore On-Water Recovery Storage Activation ListTable 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.4 Offshore On-Water Recovery Storage Activation List (continued)Table 9.D.6 Nearshore On -Water Recovery Activation ListTable 9.D.6 Nearshore On-Water Recovery Activation List (continued)Table 9.D.7 Aerial Surveillance Activation ListTable 9.D.8 Offshore Aerial Dispersant Activation ListTable 9.D.8 Offshore Aerial Dispersant Activation List (cont.)

Table 9.D.9 Offshore Boat Spray Dispersant Activation ListTable 9.D.10 Subsea Dispersant Package Activation ListTable 9.D.11 In-Situ Burn Equipment Activation ListTable 9.D.11 In-Situ Burn Equipment Activation List (continued)Table 9.D.11 In-Situ Burn Equipment Activation List (continued)Table 9.D.11 In-Situ Burn Equipment Activation List (continued)Table 9.D.11 In-Situ Burn Equipment Activation List (continued)Table 9.D.12 Shoreline Protection and Wildlife Support ListSECTION 10 : ENVIRONMENTAL MONITORING INFORMATION

A. Monitoring Systems

A rig based Acoustic Doppler Current Profiler (ADCP) is used to continuously monitor the current beneath the rig. Metocean conditions such as sea states, wind speed, ocean currents, etc. will also be continuously monitored. Shell will comply with NTL 2009-G02.

B. Incidental Takes

No incidental takes are anticipated. Although marine mammals may be seen in the area, Shell does not believe that its operations proposed under this EP will result Shell implements the mitigation measures and monitors for incidental takes of protected species according to the following notices to lessees and operators from the BOEM/BSEE:

NTL 2012-BSEE-G01 “Marine Trash and Debris Awareness and Elimination” NTL 2012-Joint-G01 “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”
NTL 2012-Joint-G02 “ Implementation of Seismic Survey Mitigation Measures & Protected Species Observer Program ”

C. Flower Garden Banks National Marine Sanctuary

The operations proposed in this EP will not be conducted within the Protective Zones of the Flower Garden Banks and Stetson Bank.SECTION 11: LEASE STIPULATIONS INFORMATION

Mississippi Ca nyon Block 720, 721 & 722:

Lease OCS-G 33170, 33171 and 33172 were acquired in Lease Sale #208 held on March 18, 2009 and has an expected expiration date of May 31, 2019.

These leases are not part of a biological sensitive area, known chemosynthetic area, or shipping fairway. See Section 6 of this plan for site specific archeological information. The following stipulations are associated with this lease:

Stipulation No. 8

–

Protected Species This Stipulation is addressed in the following sections of this plan: Section 6, Threatened or endangered species, critical habitat and marine mammal information Section 10, Environmental Monitoring Information, Incidental takes Section 12, Environmental Mitigation Measures Information, Incidental takes Section 18, Environmental Impact AssessmentSECTION 12 : ENVIRONMENTAL MITIGATION MEASURE INFORMATION

A. Impacts to Marine and coastal environments

The proposed action will implement mitigation measures required by laws and regulations, including all applicable Federal & State requirements concerning air emissions, discharges to water and solid waste disposal, as well as any additional permit requirements and Shell policies. Project activities will be conducted in accordance with the Regional OSRP. Section 18 of this plan discusses impacts and mitigation measures

, including Coastal Habitats and Protected Areas.

B. Incidental Takes

We do not anticipate any incidental takes related to the proposed operations. Shell implements the mitigation measures and monitors for incidental takes of protected species according to the following notices to lessees and operators from the BOEM/BSEE:

NTL 2012-BSEE- G0 1 “Marine Trash and Debris Awareness and Elimination”
NTL 2012-Joint-G01 “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”
NTL 2012-Joint-G02 “ NTL 2012

- Joint

- G02 “Implementation of Seismic Survey Mitigation Measures & Protected Species Observer Program”SECTION 13 : RELATED FACILITIES AND OPERATIONS INFORMATION

Information regarding Related Facilities and Operations Information, transportation systems & produced liquid hydrocarbon transportation vessels are not included in this EP as such information is only necessary in the case of DOCDs.SECTION 14: SUPPORT VESSELS AND AIRCRAFT INFORMATION

A. General

Type Maximum Fuel Tank

Storage Capacity (Gals) Maximum No. In Area at Any Time Trip Frequency or Duration

Crew Boats 8,000 1 Twice per week Offshore Support Vessels 120,000 2 Twice per week Helicopter 76 0 1 Once per day

B. Diesel Oil Supply Vessels

Size of Fuel Supply Vessel Capacity of Fuel Supply Vessel Frequency of Fuel Transfers Route Fuel Supply Vessel Will Take

280 foot length 100,000 gals. 1 week 6 miles from Port Fourchon to the mouth of Bayou Lafourche, then to MC 721

C. Drilling Fluids Transportation

According to NTL 2008-G04, this information in only required when activities are proposed in the State of Florida.

D. Solid and Liquid Wastes Transportation

See Section 7, Table 7B.

E. Vicinity Map

See Attachment 14A for Vicinity Map.Attachment 14A

– Vicinity MapSECTION 15 : ONSHORE SUPPORT FACILITIES INFORMATION

A. General

Name Location Existing/New/Modified

Fourchon Port Fourchon, LA Existing

Boothville Heliport Boothville, LA Existing

The onshore support bases for water and air transportation will be the existing terminals in Boothville and Fourchon, Louisiana. The Fourchon boat facility is operated by Shell and is located on Bayou Lafourche, south of Leeville, LA approximately 3 miles from the Gulf of Mexico. The existing onshore air support base in Boothville, LA is located at 38963 Hwy. 23, Boothville, LA 70041.

B. Support Base Construction or Expansion

This does not apply to this EP as Shell does not plan to construct a new onshore support base or expand an existing one to accommodate the activities proposed in this EP.

C. Support Base Construction or Expansion Timetable

Since no onshore support base construction or expansion is planned for these activities, a timetable for land acquisition and construction or expansion is not applicable.

D. Waste Disposal

See Section 7, Tables 7A and 7B.

E. Air emissions

Not required by BOEM GOM.

F. Unusual solid and liquid wastes

Not required by BOEM GOM.

SECTION 16 : SULPHUR OPERATIONS INFORMATION

Information regarding Sulphur Operations is not included in this EP as we are not proposing to conduct sulphur operations.SECTION 17: COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION

LOUISIANA COASTAL ZONE MANAGEMENT CONSISTENCY CERTIFICATION

EXPLORATION PLAN Type of Plan

MISSISSIPPI CANYON BLOCKS 720, 721 & 722

Area and Blocks

OCS- G 33170, 33171 & 33172

Lease Number

The proposed activities described in detail in this Plan will comply with Louisiana's State and Local Coastal Resources Management Act of 1978, Coastal Resources Program and Coastal Area Management Enforceable Policies.

We have considered all of Louisiana's Enforceable Policies in making this certification of consistency.

SHELL OFFSHORE INC.

Operator

____________________________________________

Sylvia Bellone Certifying Official

11/01/2012
DateSECTION 18: ENVIRONMENTAL IMPACT ANALYSIS (EIA)



## INITIAL EXPLORATION PLAN Mississippi Canyon Block 720 (OCS- G 33170) Mississippi Canyon Block 721 (OCS- G 33171) Mississippi Canyon Block 722 (OCS-G 33172)

Offshore Louisiana

November 2012

Prepared for:

Shell Offshore Inc.
P.O. Box 61933 New Orleans, Louisiana 70161 Telephone: (504) 425-6021

Prepared by:

CSA International, Inc. 8502 SW Kansas Avenue Stuart, Florida 34997 Telephone: (772) 219-3000

# Introduction

Project Summary

Shell Offshore Inc. (Shell) is submitting an Initial Exploration Plan (EP) for Mississippi Canyon Blocks 720, 721, and 722 ( MC 720, 721, and 722) for eight exploration wells to be drilled using a dynamically positioned semisubmersible rig. This Initial EP is for proposed well locations A, B, C, and D in MC 721; E, F, and G in MC 720; and H in MC 722.

The lease area is 49 miles ( 79 km) from the nearest shoreline, 108 miles (1 74 km) from the onshore support base at Port Fourchon, Louisiana, and 74 miles (1 19 km) from the helicopter base at Boothville, Louisiana. All miles in this Environmental Impact Analysis (EIA) are statute miles. Water depths at the wellsites range from approximately 3,125 to 3,747 ft (9 53 to 1,142 m).

The Noble Jim Day , a dynamically positioned semisubmersible rig, or an equivalent rig will be used for drilling. Drilling of the wells is expected to commence during the second quarter of 2013. The average time to drill a well will be approximately 165 days.



## Purpose of the EIA

This EIA was prepared pursuant to the requirements of the Outer Continental Shelf Lands Act (OCSLA), 43 United States Code (U.S.C.) §§ 1331-1356, as well as regulations including 30 Code of Federal Regulations (CFR) 550.212(o) and 550.227. The EIA is a project- and site-specific analysis of Shell’s planned activities under this EP . On October 1, 2011

, the Bureau of Ocea n Energy Management, Regulation and Enforcement (BOEMRE) reorganized into two separate agencies: Bureau of Ocean Energy Management (BOEM) and Bureau of Safety and Environmental Enforcement (BSEE). Shell understands that the BOEM will review this EIA and prepare a S it e-Specific Environmental Assessment (SEA) for the project. This EIA complies with guidance provided in existing Notice to Lessees and Operators (NTLs) issued by the former Minerals Management Service (MMS) and BOEMRE, including NTL 2008-G04. Throughout this
EIA, w hen existing guidance and general agency activities are referred to, “BOEM” is meant to subsume the former agencies and to represent the continuous regulatory entity now called BOEM. The former agency names (MMS and BOEMRE) are used when referring to particular historical documents published under those names. In addition, until NTLs are reissued under BOEM and/or BSEE, the EIA will refer to the former BOEMRE as BOEM when addressing NTLs issued by BOEMRE or MMS.

The EIA presents data, analyses, and conclusions to support BOEM reviews as required by the National Environmental Policy Act (NEPA) and other relevant federal laws, including the Endangered Species Act (ESA) and Marine Mammal Protection Act (MMPA). It also identifies some of the mitigation measures Shell will implement in connection with the planned activities.

The EIA is a project-specific analysis that focuses on the impacts of a specific plan. This EIA addresses the impact-producing factors (IPFs), resources, and impacts associated with the

ac tivities proposed in this EP . The EIA also analyzes the potential environmental impacts of the revised blowout scenario and worst case discharge (WCD) information included in the Initial EP.

### The BOEM has performed numerous environmental evaluations of oil and gas activities on the

Gulf of Mexico Outer Continental Shelf (OCS). Potential impacts were analyzed at a broader level in the Programmatic Environmental Impact Statement (EIS) for the OCS Oil and Gas Leasing Program (MMS, 2007a; BOEM 2012a) and in multi-lease-sale EISs for the Western, Central, and Eastern Gulf of Mexico Planning Areas (MMS, 2001, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b).

These studies generated critical data and advanced the large body of existing knowledge on the Gulf of Mexico OCS. They analyze potential impacts on the natural environment, the socioeconomic effects of exploration and development activities, and other regional resources. Numerous technical studies address the likely trajectory of spilled oil, the effects of underwater noise on threatened and endangered species, and other IPFs. The studies inform agency decision-making on lease offerings, mitigation measures and lease stipulations, operational requirements, and permit restrictions. This substantial body of work, which in part, forms the basis for the evaluation presented here, will allow the BOEM and other regulatory agencies to evaluate Shell’s EP and ensure that oil and gas exploration and development activities are performed in an environmentally sound manner, with minimal impacts on the environment. Shell has incorporated these comprehensive environmental analyses by reference and built on them with project- and site-specific analyses.



## OCS Regulatory Framework

The regulatory framework for OCS activities in the Gulf of Mexico was summarized by

MMS (2010). Under the OCSLA, the U.S. Department of the Interior (USDOI) is responsible for the administration of mineral exploration and development of the OCS. Within the USDOI, the BOEM and BSEE are charged with the responsibility of managing and regulating the development of OCS oil and gas resources in accordance with the provisions of the OCSLA. The BSEE offshore regulations are in 30 CFR Parts 250, 251, 252, 254, 256, 270, and 282. The BOEM offshore regulations are in 30 CFR Parts 550, 551, 552, 556, 559, 560, 570, 580, 581, 582,
and 585.

In implementing its responsibilities under the OCSLA and NEPA, the BOEM consults numerous federal departments and agencies that have authority to govern and maintain ocean resources pursuant to other federal laws. Among these are the U.S. Coast Guard (USCG), U.S. Environmental Protection Agency (USEPA), U.S. Fish and Wildlife Service (USFWS), and the National Oceanic and Atmospheric Administration (NOAA) through the National Marine Fisheries Service (NMFS). Federal regulations establish consultation and coordination processes with federal, state, and local agencies (e.g., the ESA, MMPA, Coastal Zone Management Act of 1972, and the Magnuson-Stevens Fishery Conservation and Management Act).

NTLs are formal documents issued by the BOEM and BSEE that provide clarification, description, or interpretation of a regulation or standard. Table 1 lists and summarizes the NTLs applicable

to this EIA.

### Table 1. Notices to Lessees and Operators (NTLs) that are applicable to this Environmental Impact Analysis (EIA).

NTL Title Summary

2012

- N06 Guidance to Owners and

Operators of Offshore Facilities Seaward of the Coast Line Concerning Regional Oil Spill Response Plans Provides clarification, guidance, and information for preparation of regional Oil Spill Response Plans. Recommends description of response strategy for worst case discharge (WCD) scenarios to ensure capability to respond to oil discharges is both eff icient and effective.

2012

- JOINT

- G01 Vessel Strike Avoidance and

Injured/Dead Protected Species Reporting Recommends protected species identification training; recommends that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species; and requires operators to report sightings of any injured or dead protected species.

2012

- BSEE

- G01 Marine Trash and Debris

Awareness and Elimination Instructs operators to exercise caution in the handling and disposal of small items and packaging materials; requires the posting of placards at prominent locations on offshore vessels and structures; and mandates a yearly marine trash and debris awareness training and certification process.

2011

- JOINT

- G01 Revisions to the List of OCS Blocks

Requiring Archaeological Resource Surveys and Reports Provides new information on which Outer Continental Shelf (OCS) blocks require archaeological surveys and reports and line spacing required in each block. This NTL augments
NTL 2005

- G07.

2010

- N10 Statement of Compliance with

Applicable Regulations and Evaluation of Information Demonstrating Adequate Spill Response and Well Containment Resources Informs operators using subsea blowout preventers (BOPs) or surface BOPs on floating facilities that applications for well permits must include a statement signed by an authorized company official stating that the operator will condu ct all activities in compliance with all applicable regulations, including the increased safety measures regulations (75 FR 63346). Informs operators that the BOEM will be evaluating whether each operator has submitted adequate information demonstrating t hat it has access to and can deploy containment resources to promptly respond to a blowout or other loss of well control.

2010

- N06 Information Requirements for

Exploration Plans, Development and Production Plans, and Development Operations Coordination Do cuments on the OCS Rescinds the limitations set forth in NTL 2008

- G04 regarding a blowout scenario and WCD scenario, and provides guidance regarding the information required in blowout scenario and WCD scenario descriptions.

2009

- G40 Deepwater Benthic Communities Guidance for avoiding and protecting high

- density deepwater benthic communities (including chemosynthetic and deepwater coral communities) from damage caused by OCS oil and gas activities in water depths greater than 984 ft (300 m). Prescribes separation distances of 2,000 ft (610 m) from each mud and cuttings discharge location and 250 ft (76 m) from all other seafloor disturbances.

2009

- G39 Biologically Sensitive Underwater

Features and Areas Guidance for avoiding and protecting biologically sensitive features and areas (i.e., topographic features, pinnacles, low

- relief live bottom areas, and other potentially sensitive biological features) when conducting OCS operations in water depths less than 984 ft (300 m) in the Gulf of Mexico.

2008

- G0 4 Information Requirements for

Exploration Plans and Development Operations Coordination Documents Guidance on the information requirements for OCS plans, including EIA requirements and information regarding compliance with the provisions of the Endangered Species Act and Marine Mammal Protection Act.

2005

- G07 Archaeological Resource Surveys

and Reports Provides guidance on regulations regarding archaeological discoveries, specifies requirements for archaeological resource surveys and reports, and outlines options for protecting archaeological resources.

## Oil Spill Prevention and Contingency Planning

Shell submitted an update to the Gulf of Mexico Regional Oil Spill Response Plan (OSRP) to the

BSEE as a fundamental component of the planned drilling program that certifies Shell’s capability to respond to the maximum extent practicable to a WCD (30 CFR 254.2) (see EP Section 9 ). The OSRP demonstrates Shell’s capabilities to rapidly and effectively ma nage oil spills that may result from drilling operations. Despite the extremely low likelihood of a large oil spill occurring during the project, Shell has designed its response program based upon a regional capability of responding to a range of spill volumes that increase from small operational spills to a WCD from a well blowout. Shell’s program meets the response planning requirements of the relevant coastal states and federal oil spill planning regulations. The OSRP includes information regarding Shell’s regional oil spill organization and dedicated response assets, potential spill risks, and local environmental sensitivities. The OSRP presents specific information on the response program that includes a description of personnel and equipment mobilization, the incident management team organization, and the strategies and tactics used to implement effective and sustained spill containment and recovery operations.



## EIA Organization

The EIA is organized into Sections A through I corresponding to the information required by NTL 2008-G04, which provides guidance regarding information required by 30 CFR Part 550 for

EP s. The main impact-related discussions are in Section A (Impact-Producing Factors) and

Section C (Impact Analysis).

# A. Impact-Producing Factors

Table 2 is a matrix of IPFs and potentially affected environmental resources adapted from

Form MMS- 142. An “X” indicates that an IPF could reasonably be expected to affect a certain resource, and a dash (

-- ) indicates no impact or negligible impact. Where there may be an effect, an analysis is provided in Section C . Potential IPFs for the proposed activity are listed below and briefly discussed in the following subsections:

1. Drilling rig presence (including noise and lights);

2. Physical disturbance to the seafloor;

3. Air pollutant emissions;

4. Effluent discharges;

5. Water intake;

6. Onshore waste disposal;

7. Marine debris;

8. Support vessel and helicopter traffic; and

9. Accidents.



## A.1 Drilling Rig Presence (including noise and lights)

The wells will be drilled using the Noble Jim Day or a similar dynamically positioned semisubmersible rig. The rig will be on site for an estimated 165 days per well. Offshore support vessels will be used during the drilling program and there will likely be at least one vessel in the field at all times. The physical presence of a drilling rig in the ocean can attract pelagic fishes and other marine life, as discussed in Section C.5.1

.
A semisubmersible rig maintains buoyancy using ballasted, watertight pontoons located below the sea surface. The operating deck is located above the tops of passing waves. Structural columns connect the pontoons and operating deck. When the rig moves its location, the pontoons are de-ballasted so that the rig can float on the sea surface. The Noble Jim Day uses thrusters to hold or adjust its position.

Drilling operations produce noise that includes strong tonal components at low frequencies, including infrasonic frequencies in at least some cases (MMS, 2000). Drilling noise from semisubmersibles is not particularly intense and is strongest at low frequencies, averaging

10 to 500 Hz (Richardson et al., 1995). From a semisubmersible, sound and vibration are transmitted to the water either through the air or the risers (MMS, 2000). Drilling rigs also maintain exterior lighting for navigational and aviation safety in accordance with federal regulations.

### Table 2. Matrix of impact-producing factors and affected environmental resources. X = potential impact; dash (

-- ) = no impact or negligible impact.

Environmental Resources Impact

- producing Factors
Drilling Rig Presence (incl. noise & lights) Physical

Disturbance to Seafloor Air Pollutant

Emissions Effluent

Discharges Water Intake Onshore Waste Disposal Marine Debris Support Vessel/Helo Traffic Accidents

Small Fuel Spill Large Oil Spill

Physical/Chemical Environment Air quality

-- -- X

-- -- -- -- -- X (6) X (6) Water quality

-- -- -- X

-- -- -- -- X (6) X (6)
Seafloor Habitats and Biota
Soft bottom benthic communities

-- X

-- X

-- -- -- -- -- X (6) High

- density deepwater benthic communities

-- -- (4)

-- -- (4)

-- -- -- -- -- X (6) Designated topographic features

-- -- (1)

-- -- (1)

-- -- -- -- -- -- Pinnacle trend area live bottoms

-- -- (2)

-- -- (2)

-- -- -- -- -- -- Eastern Gulf live bottoms

-- -- (3)

-- -- (3)

-- -- -- -- -- -- Threatened, Endangered, and Protected Species and Critical Habitat Sperm whale (endangered) X (8)

-- -- -- -- -- -- X (8) X (6,8) X (6,8) Florida manatee (endangered)

-- -- -- -- -- -- -- X (8)

-- X (6,8) Endangered mysticete whales

-- -- -- -- -- -- -- -- -- -- Non

- endangered marine mammals (protected) X

-- -- -- -- -- -- X X (6) X (6) Sea turtles (endangered/threatened) X (8)

-- -- -- -- -- -- X (8) X (6,8) X (6,8) Piping Plover (threatened)

-- -- -- -- -- -- -- -- -- X (6)
Whooping Crane (endangered)

-- -- -- -- -- -- -- -- -- X (6)
Gulf sturgeon (threatened)

-- -- -- -- -- -- -- -- -- X (6) Beach mice (endangered)

-- -- -- -- -- -- -- -- -- X (6)
Coastal and Marine Birds Marine and pelagic birds X

-- -- -- -- -- -- X X (6) X (6) Shorebirds and coastal nesting birds

-- -- -- -- -- -- -- X

-- X (6)
Fisheries Resources Pelagic communities and ichthyoplankton X

-- -- X X

-- -- -- X (6) X (6)
Essential Fish Habitat X

-- -- X X

-- -- -- X (6) X (6) Archaeological Resources Shipwreck sites

-- -- (7)

-- -- -- -- -- -- - - X (6) Prehistoric archaeological sites

-- -- (7)

-- -- -- -- -- -- -- X (6)
Coastal Habitats and Protected Areas
Beaches

-- -- -- -- -- -- -- -- -- X (6) Wetlands and seagrass beds

-- -- -- -- -- -- -- X

-- X (6) Coastal wildlife refuges and wilderness areas

-- -- -- -- -- -- -- -- -- X (6)
Socioeconomic and Other Resources Recreational and commercial fishing X

-- -- -- -- -- -- -- X (6) X (6) Public health and safety

-- -- -- -- -- -- -- -- X (6) X (6) Employment and infrastructure

-- -- -- -- -- -- -- - - X (6) X (6)
Recreation and tourism

-- -- -- -- -- -- -- -- X (6) X (6)
Land use

-- -- -- -- -- -- -- -- -- X (6)
Other marine uses

-- -- -- -- -- -- -- -- -- X (6)Table 2 Footnotes and Applicability:

(1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well, platform site, or any anchors will be on the seafloor within the following: (a) 4-mi zone of the Flower Garden Banks, or the 3-mi zone of Stetson Bank; (b) 1,000-m, 1-mi, or 3-mi zone of any topographic feature (submarine bank) protected by the Topographic Features Stipulation attached to an Outer Continental Shelf (OCS) lease; (c) Essential Fish Habitat (EFH) criteria of 500 ft from any no-activity zone; or (d) Proximity of any submarine bank (500-ft buffer zone) with relief greater than 2 m that is not protected by the Topographic Features Stipulation attached to an OCS lease.

 Not applicable. The lease is not within the given ranges (buffer zone) of any marine sanctuary, topographic feature, or no-activity zone. There are no submarine banks in the block.

(2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinnacle Trend) Stipulation attached to an OCS lease.

 The Live Bottom (Pinnacle Trend) Stipulation is not applicable to the lease area.

(3) Activities within any Eastern Gulf OCS block where seafloor habitats are protected by the Live Bottom (Low-Relief) Stipulation attached to an OCS lease.

 The Live Bottom (Low-Relief) Stipulation is not applicable to the lease area.

(4) Activities on blocks designated by the BOEM as being in water depths 300 m or greater.

 No impacts on high-density deepwater benthic communities are anticipated because no features indicative of high-density chemosynthetic communities or coral communities are located within 2,000 ft (610 m) of mud or cuttings discharge locations. A dynamically positioned semisubmersible rig will be used; therefore, no seafloor disturbances due to anchoring will occur.

(5) Exploration or production activities where H 2 S concentrations greater than 500 ppm might be encountered.

 EP Section 4 contains Shell’s request for classification as an area absent of H 2 S.
(6) All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you determine would impact these environmental resources. If the proposed action is located a sufficient distance from a resource that no impact would occur, the EIA can note that in a sentence or two.

 Accidental hydrocarbon spills could affect the resources marked (X) in the matrix, and impacts are analyzed in Section C

. (7) All activities that involve seafloor disturbances, including anchor emplacements, in any OCS block designated by the BOEM as having high-probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are adjacent to the lease block in which your planned activity will occur. If the proposed activities are located a sufficient distance from a shipwreck or prehistoric site that no impact would occur, the EIA can note that in a sentence or two.

 No impacts on archaeological resources are expected. The lease area is on the list of archaeology survey blocks (BOEM, 2012c). The archaeological survey detected 302 unidentified sonar contacts within the survey area. The distribution patterns and acoustic characteristics of these sonar targets indicate that they are modern debris primarily associated with industrial waste dumping or field development activities. The lease is beyond the 60-m depth contour, so prehistoric archaeological sites are not likely. A dynamically positioned semisubmersible rig will be used; therefore, no seafloor disturbances due to anchoring will occur.

(8) All activities that you determine might have an adverse effect on endangered or threatened marine mammals
or sea turtles or their critical habitats.

 IPFs that may affect marine mammals, sea turtles, or their critical habitats include drilling rig presence and emissions, support vessel and helicopter traffic, and accidents. See Section C

. (9) Production activities that involve transportation of produced fluids to shore using shuttle tankers or barges.

 Not applicable.

## A.2 Physical Disturbance to the Seafloor

Semisubmersible rigs like the Noble Jim Day do not use anchors for holding or stabilization during drilling operations. There will be minimal disturbance to the seafloor and soft bottom communities during positioning of the wellbore and blowout preventers. Physical disturbance of the seafloor will be limited to the proximal area where the wellbore penetrates the substrate, where mud and drill cuttings will be deposited.



## A.3 Air Pollutant Emissions

Estimates of air pollutant emissions are provided in EP Section 8 . Offshore air pollutant emissions will result from operations of the drilling rig, as well as service vessels and helicopters. These emissions occur mainly from combustion of diesel fuel. The combustion of fuels occurs on diesel-powered generators, pumps, or motors and from lighter fuel motors. Primary air pollutants typically associated with OCS activities are suspended particulate matter (PM), sulfur oxides (SO
x 

### ), nitrogen oxides (NO
x 

### ), volatile organic compounds (VOCs), and carbon monoxide (CO).

The Air Quality Emissions Report (see EP Section 8 ) prepared in accordance with BOEM requirements shows that the projected emissions from emission sources associated with the proposed activities meet the BOEM exemption criteria and are therefore exempt from further air quality review pursuant to 30 CFR 550.303(d).



## A.4 Effluent Discharges

Effluent discharges are summarized in EP Section 7 . Support vessel discharges will be in accordance with USCG regulations and, as applicable, the National Pollutant Discharge Elimination System (NPDES) Vessel General Permit, and therefore are not expected to cause significant impacts on water quality. Discharges from the semisubmersible rig will be in compliance with and monitored as required by the NPDES permit (GMG290000). A synthetic-based mud (SBM) system will be used for drilling activities after the marine riser is installed that allows recirculation of the SBM fluids and cuttings. Unused or residual SBM will be collected and transported to Port Fourchon, Louisiana, for recycling. SBM cuttings will be discharged overboard via a downpipe below the water surface, after treatment that complies with the NPDES permit limitations for SBM fluid retained on cuttings. The estimated volume of SBM cuttings to be discharged is provided in EP Section 7

.
Other effluent discharges in accordance with the NPDES permit may include excess cement, non-contact cooling water, treated sanitary and domestic wastes, deck drainage, desalination unit brine, uncontaminated fire water, and ballast water.



## A.5 Water Intake

Se awater will be drawn from several meters below the ocean surface for various services

, including firewater and once-through non-contact cooling of machinery on the drilling rig ( EP Table 7a ).

Section 316(b) of the Clean Water Act requires NPDES permits to ensure that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available to minimize adverse environmental impact from impingement and entrainment of

### aquatic organisms. The current general NPDES Permit No. GMG290000 specifies requirements

for new facilities for which construction commenced after July 17, 2006, with a cooling water intake structure having a design intake capacity of greater than 2 million gallons of water per day, of which at least 25% is used for cooling purposes. The drilling rig do es not trigger the cooling water intake permit requirements of the NPDES permit because it was constructed prior to the July 17, 2006, applicability date.



## A.6 Onshore Waste Disposal

Wastes generated during exploration activities are tabulated in EP Section 7 . Non-hazardous trash and debris and non-recyclable waste will be transported to the Republic/BFI landfill

, Sorrento, Louisiana, or the parish landfill, Avondale, Louisiana. Recyclable trash and debris will be recycled at Omega Waste Management, Patterson, Louisiana, or at ARC of New Iberia, Louisiana. Hazardous waste such as paints, solvents, and unused chemicals will be disposed of at Safety Kleen Systems, Inc., Denton, Texas, while used oil will be sent to Omega Waste Management for recycling. Universal waste including batteries, lamps, glass, and mercury-contaminated waste will be recycled at Lamp Environmental Industries, Hammond

, Louisiana. At the onshore facilities, wastes will be recycled or disposed of according to applicable regulations.



## A.7 Marine Debris

Trash and debris released into the marine environment can harm marine animals through entanglement and ingestion. Shell will adhere to the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) Annex V requirements, USEPA and USCG regulations, and BSEE regulations and NTLs regarding solid wastes. BSEE regulations at

30 CFR 250.300(a) and (b)(6) prohibit operators from deliberately discharging containers and other similar materials (e.g., trash and debris) into the marine environment, and

30 CFR 250.300(c) requires durable identification markings on equipment, tools and containers (especially drums), and other material. USCG and USEPA regulations require operators to become proactive in avoiding accidental loss of solid waste items by developing waste management plans, posting informational placards, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. Shell complies with NTL 2012-BSEE-G01, which instructs operators to exercise caution in the handling and disposal of small items and packaging materials, requires the posting of placards at prominent locations on offshore vessels and structures, and mandates a yearly marine trash and debris awareness training and certification process. Shell’s compliance with applicable laws, regulations, and NTL 2012-BSEE-G01 will avoid significant impacts on the environment.



## A.8 Support Vessel and Helicopter Traffic

Shell will use existing shorebased facilities at Port Fourchon and Boothville, Louisiana, for onshore support for water and air transportation, respectively. No terminal expansion or construction is planned at either location.

The supply base at Port Fourchon is operated by Shell and located on Bayou Lafourche, approximately 3 miles (5 km) from the Gulf of Mexico. There will likely be at least one support vessel in the field at all times during drilling activities. The supply vessels will normally move to the project area via the most direct route from the shorebase. Helicopters transporting

### personnel and small supplies will normally take the most direct route of travel between the

helicopter base and the lease area when air traffic and weather conditions permit. Helicopters typically maintain a minimum altitude of 700 ft (213 m) while in transit offshore, 1,000 ft (305 m) over unpopulated areas or across coastlines, and 2,000 ft (610 m) over populated areas and sensitive habitats such as wildlife refuges and park properties. Additional guidelines and regulations specify that helicopters maintain an altitude of 1,000 ft (305 m ) within 300 ft (91 m) of marine mammals (BOEM, 2012a).



## A.9 Accidents

A.9.1 Types of Accidents Evaluated

The analysis in this EIA focuses on two types of potential accidents:

10. a small fuel spill, which is the most likely type of spill during OCS development activities; and

11. an oil spill resulting from an uncontrolled blowout. A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures detailed in EP Section 2j

.
The following subsections summarize assumptions about the sizes and fates of these spills as well as Shell’s spill response plans. Impacts are analyzed in Section C

.
The lease sale EIS (MMS, 2007b) analyzes three other types of accidents: chemical spills, vessel collisions, and loss of well control. These accidents are discussed briefly in Section A.9.4

.


### A.9.2 Small Fuel Spill

Spill Size . According to the analysis in BOEM (2012b), the most likely type of small spill (<1,000 barrels [bbl]) as a result of OCS activities is a minor diesel fuel spill. Historically, most diesel spills have been <1 bbl, and this size is predicted to be the most common in ongoing and future OCS activities in the Western and Central Gulf of Mexico Planning Areas (BOEM, 2012b). The median size for spills <1 bbl is <0.0 24 bbl, and the median size for spills of 1 to 10 bbl is 3 bbl (BOEM, 2012b ). For this analysis, a small diesel fuel spill of 3 bbl is assumed. Operational experience suggests that the most likely cause of such a spill would be a hose rupture resulting in the loss of the contents of a fuel transfer hose, which is less than 3 bbl.

Spill Fate . The fate of a small fuel spill in the lease area would depend on meteorological and oceanographic conditions at the time, as well as the effectiveness of spill response activities. However, given the open ocean location of the lease area, the duration of a small spill and the opportunity for impacts to occur would be very brief.

The water-soluble fractions of diesel are dominated by two- and three-ringed polycyclic aromatic hydrocarbons (PAHs), which are moderately volatile (National Research Council [NRC], 2003). The constituents of these oils are light to intermediate in molecular weight and can be readily degraded by aerobic microbial oxidation. Diesel’s density is such that it will not sink to the seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this generally occurs only in coastal areas with high-suspended solids loads (NRC, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes (NOAA, 2006).

### The fate of a small diesel fuel spill was estimated using NOAA’s Automa ted Data Inquiry for Oil

Spills 2 (ADIOS2 ) model. This model uses the physical properties of oils in its database to predict the rate of evaporation and dispersion over time, as well as changes in the density, viscosity, and water content of the product spilled. It is estimated that over 90% of a small diesel spill would be evaporated or naturally dispersed within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha) depending on sea state and weather
conditions.

The ADIOS2 results, coupled with spill trajectory information discussed below for a large spill,

in dicate that a small fuel spill would not affect coastal or shoreline resources. The lease area (MC 720, 721, and 722) is approximately 49 miles ( 79 km) from the nearest coastline (Louisiana). Modeling results discussed below indicate that a spill in the lease area would have no shoreline contact within 3 days and a 4% probability of contacting the nearest Louisiana shoreline (Plaquemines Parish) within 10 days after a spill. Slicks from spills are expected to persist for relatively short periods of time ranging from minutes (<1 bbl) to hours (<10 bbl) to a few days (10 to 1,000 bbl) and rapidly spread out, evaporate, and disperse into the water column Because of the distance of these potential spills on the OCS and the lack of persistence, it is unlikely that they would make landfall prior to dissipation (BOEM, 2012b).

Spill Response . In the unlikely event of a fuel spill, response equipment and trained personnel would be available to ensure that spill effects are localized and would result only in short-term, localized environmental consequences. EP Section 9b provides a detailed discussion of Shell’s response to a spill.



### A.9.3 Large Oil Spill

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an
event will b e minimized by Shell’s well control and blowout prevention measures detailed in

EP Section 2j . Blowouts are rare events and most do not result in oil spills (BOEM, 2012a)

.
Spill Size . Shell has calculated a WCD for this EP using the requirements prescribed by
NTL 2010-N06. The WCD is 3 92 9,000 bbl for the first day with a 30-day average of

35 5,000 barrels of oil per day (BOPD). The detailed analysis of this calculation can be found in

EP Section 2J . The WCD scenario for this EP, in terms of both initial and the sustained rates, has a low probability of being realized. Some of the factors that are likely to reduce rates and volumes, which are not included in the WCD calculation, include, but are not limited to, obstructions or equipment in the wellbore, well bridging, and early intervention such as

containment.

Shell has a robust system in place to prevent blowouts. Included in EP Sections 2J and 9b is Shell’s response to NTL 2010-N06, which includes descriptions of measures to prevent a blowout, reduce the likelihood of a blowout, and conduct effective and early intervention in the event of a blowout. Shell will also comply with NTL 2010-N10 and the Final Drilling Safety Rule, which specify additional safety measures for OCS activities.

Spill Trajectory . The fate of a large oil spill in the lease area would depend on meteorological and oceanographic conditions at the time. The Oil Spill Risk Analysis (OSRA) model is a computer simulation of oil spill transport that uses realistic data for winds and currents to predict spill fate. The OSRA report by Ji et al. (2004) provides conditional contact probabilities for shoreline segments. The results for Launch Area 58 (the launch area nearest to the lease

### area) are presented in Table 3 . The OSRA results presented in Table 3 include only shoreline

segments with contact probabilities greater than 0.5% within 30 days; other coastal areas could be affected at lower contact probabilities within 30 days, or from a spill persisting for more than

30 days

. Th e model predicts no shoreline contact within 3 days. After 10 days, three Louisiana parishes may be contacted. After 30 days, 11 counties and parishes, including 2 Texas counties, 8 Louisiana parishes, and 1 Florida county may be contacted. Plaquemines Parish, Louisiana, has the greatest probability of shoreline contact, with a 4% and 8% chance within 10 and 30 days, respectively.

Table 3. Conditional probabilities of a spill in the lease area contacting shoreline segments (From: Ji et al., 2004). Values are conditional probabilities that a hypothetical spill in the lease area (represented by OSRA Launch Area 58 ) could contact shoreline segments within 3, 10, or 30 days.

Shoreline Segment County or Parish

, State Conditional Probabil ity of Contact a (%) 3 Days 10 Days 30 Days
C10 Galveston, T exas

-- -- 1
C12 Jefferson, T exas

-- -- 1
C13 Cameron, L ouisiana

-- -- 3
C14 Vermilion, L ouisiana

-- -- 2
C15 Iberia, L ouisiana

-- -- 1
C17 Terrebonne, L ouisiana

-- 1 3
C18 Lafourche, Louisiana

-- 2 3
C19 Jefferson, Louisiana

-- -- 1
C20 Plaquemines, L ouisiana

-- 4 8
C21 St. Bernard, Louisiana

-- -- 1 C28 Okaloosa, Florida

-- -- 1

a Conditional probability refers to the probability of contact within the stated time period, assuming that a spill has occurred (

-- indicates less than 0.5%).



### The OSRA model does not evaluate the fate of a spill over time periods longer than 30 days, nor does it predict the fate of a release that continues over a period of weeks or months. Also as noted by Ji et al. (2004), the OSRA model does not take into account the chemical composition or biological weathering of oil spills, the spreading and splitting of oil spills, or spill response activities. The model does not assume a particular spill size but has generally been used by BOEM to evaluate contact probabilities for spills greater than 1,000 bbl.

Weathering . Following an oil spill, several physical, chemical, and biological processes, collectively called weathering, interact to change the physical and chemical properties of the oil, and thereby influence its harmful effects on marine organisms and ecosystems. The most important weathering processes include spreading, evaporation, dissolution, dispersion into the water column, formation of water- in -oil emulsions, photochemical oxidation, microbial degradation, adsorption to suspended PM, and stranding on shore or sedimentation to the seafloor (NRC, 2003).

Weathering decreases the concentration of oil and produces changes in its chemical composition, physical properties, and toxicity. The more toxic, light aromatic and aliphatic hydrocarbons are lost rapidly by evaporation and dissolution from the slick on the water surface. Evaporated hydrocarbons are degraded rapidly by sunlight. Biodegradation of oil on the water surface and in the water column by marine bacteria removes first the n-alkanes and

### then the light aromatics from the oil. Other petroleum components are biodegraded more

slowly. Photooxidation attacks mainly the medium and high molecular weight PAHs in the oil on
the water surface.

Spill Response . Shell is a founding member of the Marine Well Containment Company (MWCC) and has access to an integrated subsea well control and containment system that can be rapidly deployed through the MWC C. The MWCC is a non-profit organization that assists with the subsea containment system during a response. The near-term containment response capability will be specifically addressed in Shell’s NTL 2010-N10 submission at the time an Application for Permit to Drill (APD) is submitted and will include equipment and services available to Shell through MWCC’s development of near -term capability and other industry sources. Shell is a member of Clean Caribbean & Americas, Marine Spill Response Corporation, Clean Gulf Associates, and Oil Spill Response Limited, organizations that are committed to providing the resources necessary to respond to a spill as outlined in Shell’s OSRP.

Mechanical recovery capabilities are addressed in the OSRP. The mechanical recovery response equipment that could be mobilized to the spill location in normal and adverse weather conditions is included in the Offshore On-Water Recovery Activation List in the OSRP.

Chemical dispersion capabilities are also readily available from resources identified in the OSRP. Available equipment for surface and subsea application of dispersants, response times, and support resources are identified in the OSRP.

Open-water in situ burning may also be used as a response strategy, depending on the circumstances of the release. If appropriate conditions exist and approval from the Unified Command is received, one or multiple in situ burning task forces could be deployed offshore.

See EP Section 9b for a detailed description of spill response measures.



### A. 9.4 Other Accidents Not Analyzed in Detail

The lease sale EIS (MMS, 2007b) discusses three other types of accidents: chemical spills, vessel collisions, and loss of well control. These accidents are discussed briefly below. No hydrogen sulfide (H 2 

### S) is expected at this site, and no other site-specific issues have been identified for this

EP . The analysis in the lease sale EIS for these topics is incorporated by reference.

Chemical Spill . Chemicals are used in drilling and producing operations to achieve technical goals in the drilling process, improve the efficiency and safety of drilling, and protect associated equipment. Chemicals used during drilling include surfactants, bentonite clays, olefins, inorganic salts, glycols, polymers, barite, and calcium carbonate. Supplies are renewed on a regular basis by transfer in containers from supply boats (Boehm et al., 2001). In addition to chemicals used in drilling fluids, the following chemicals are likely to be used on the rig: ethylene glycol (blowout prevention control fluid, used in closed cooling loops for crane and main engines and brake coolers), cement (used to cement casing in place), solvents (used in painting operations), hydraulic fluids (used in cranes and other hydraulic rig equipment), lubricating oil and grease (used in reciprocating and electrical equipment), and sodium hypochlorite (dilute, used as laundry bleach and disinfectant).

A study of environmental risks of chemical products used in OCS activities determined that only two chemicals could potentially affect the marine environment in the concentrations typically

### used: zinc bromide and ammonium chloride (Boehm et al., 2001). The project addressed by this

EP does not anticipate the use of either zinc bromide or ammonium chloride. Most other chemicals are either nontoxic or used in small quantities (BOEM, 2012b). No significant impacts are expected from chemical spills.

Vessel Collisions . As summarized in MMS (2007b) and BOEM (2012b), vessel collisions occasionally occur during routine operations. Most collision mishaps are the result of service vessels colliding with platforms or vessel collisions with pipeline risers. About 10% of these collisions have caused spills of diesel fuel or chemicals (BOEM, 2012b). Shell will comply with USCG and BOEM-mandated safety requirements to minimize the potential for vessel collisions.

Loss of Well Control . A loss of well control is the uncontrolled flow of a reservoir fluid that may result in the release of gas, condensate, oil, drilling fluids, sand, or water. Loss of well control is a broad term that includes minor to serious well control incidents, while blowouts are considered to be a subset of more serious incidents with greater risk of oil spill or human injury (MMS, 2007b). Loss of well control may result in the release of oil. Shell has a robust system in place to prevent loss of well control. Included in this EP is Shell’s response to NTL 2010-N06, which includes descriptions of measures to prevent a blowout, reduce the likelihood of a blowout, and conduct effective and early intervention in the event of a blowout. Shell will also comply with NTL 2010-N10 and the Final Drilling Safety Rule, which specify additional safety
measures for OCS activities. See EP Sections 2j and 9b for further information.

H 2 

### S Release

. EP Section 4 contains Shell’s request for classification as an area absent of H 2 

### S.



# B. Affected Environment

The lease area is on the continental slope in the northwestern Gulf of Mexico, 49 miles ( 79 km) from the nearest shoreline, 108 miles (1 74 km) from the onshore support base at Port Fourchon, Louisiana, and 74 miles (1 19 km) from the helicopter base at Boothville,

Louisiana.

The wellsites in MC 720, 721, and 722 are at a water depth of approximately 3, 125 to 3,747 ft (9 53 to 1,1 42 m) ( Figure 1b of EP ). There is seafloor faulting within 2,000 ft (610 m) of well locations A, B, and C, but no high-density areas of chemosynthetic communities will be disturbed. The archaeological assessment and seafloor surveys (C&C Technologies, Inc., 2009; Geoscience Earth and Marine Services, Inc. [GEMS], 2010) reported three marine avoidance zones within 2,000 ft (610 m) of well location F. Other sonar contacts were identified as simple debris or possibly barrels and are not archaeologically significant. Shell’s procedure “Waste Barrel Avoidance and Release Response in the Mississippi Canyon Area,” which has been previously approved by MMS and BOEM, applies to operations that could cause a disturbance of
a seafloor barrel. Shell’s over‐arching policy is to avoid barrel contact. In the unlikely case that contact is suspected or has been made with any wastes from a barrel, the plan specifies actions to be taken for the topside safety of personnel handling the equipment. The plan also outlines barrel impact reporting procedures. According to the survey results, the proposed wellsite locations appear suitable for the planned activity.

### A detailed description of the regional affected environment is provided in recent EISs

( MMS 2007b; BOEM, 2012b), including meteorology, oceanography, geology, air and water quality, benthic communities, threatened and endangered species, biologically sensitive resources, archaeological resources, socioeconomic conditions, and other marine uses. These regional descriptions are based on extensive literature reviews and are incorporated by reference. General background information is presented below, and brief descriptions of each potentially affected resource are presented in Section C , including site-specific and/or new
information if available.

The local environment in the lease area is not known to be unique with respect to physical/chemical, biological, or socioeconomic conditions. Baseline environmental conditions in the lease area are expected to be consistent with the regional description of continental slope locations evaluated in recent lease sale EISs (MMS, 2001, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b,d ).



# C. Impact Analysis

This section analyzes the potential direct and indirect impacts of routine activities and accidents; cumulative impacts are discussed in Section C.9

.
Impacts have been analyzed extensively in multi-lease-sale EISs for the Western, Central, and Eastern Gulf of Mexico Planning Areas (MMS, 2001, 2007b, 2008) as well as the final EIS for the Western and Central Gulf of Mexico Planning Areas (BOEM, 2012b). Site-specific issues are addressed in this section as appropriate.



## C.1 Physical/Chemical Environment

C.1.1 Air Quality

Due to the distance from shorebased pollution sources, offshore air quality is expected to be good. The attainment status of federal OCS waters is unclassified because there is no provision in the Clean Air Act for classification of areas outside state waters (MMS, 2007b).

In general, ambient air quality on coastal counties along the Gulf of Mexico is relatively good (BOEM, 2012a). As of July 20, 2012, Louisiana, Mississippi, Alabama, and Florida coastal counties and parishes are in attainment of the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants (USEPA, 2012). One coastal metropolitan area in Texas (Houston-Galveston-Brazoria) is a nonattainment area for 8-hour ozone.

Winds in the region are driven by the clockwise circulation around the Bermuda High (MMS, 2007b). The Gulf of Mexico is located to the southwest of this center of circulation, resulting in a prevailing southeasterly to southerly flow, which is conducive to transporting emissions toward shore. However, circulation is also affected by tropical cyclones (hurricanes) during summer and fall and by extratropical cyclones (cold fronts) during winter.

IPFs potentially affecting air quality are air pollutant emissions and two types of accidents: a small fuel spill and a large oil spill.

### Impacts of Air Pollutant Emissions

Air pollutant emissions are the only routine IPF likely to affect air quality. Offshore air pollutant emissions will result from the operation of the drilling rig as well as helicopters and service vessels. These emissions occur mainly from combustion or burning of diesel fuel. Primary air pollutants typically associated with OCS activities are suspended PM, SO
x 

### , NO
x 

### , VOCs, and CO.

Due to the distance from shore, routine operations in the project area are not expected to impact air quality along the coast. As noted in the lease sale EISs (MMS, 20 07b; BOEM, 2012b), emissions of air pollutants from routine activities in the Gulf of Mexico Central Planning Area are projected to have minimal impacts on onshore air quality because of the prevailing atmospheric conditions, emission heights, emission rates, and the distance of these emissions from the
coastline.

The Air Quality Emissions Report (see EP Section 8 ) prepared in accordance with BOEM requirements shows that the projected emissions from emission sources associated with the proposed activities meet the BOEM exemption criteria. This EPis therefore exempt from further air quality review pursuant to 30 CFR 550.303(d).

The Breton Wilderness Area, which is part of the Breton National Wildlife Refuge (NWR), is designated under the Clean Air Act as a Prevention of Significant Deterioration (PSD) Class I air quality area. The BOEM coordinates with the National Park Service and the USFWS if emissions from proposed projects may affect the Breton Class I area. The lease area is approximately

84 miles (135 km) from the Breton Wilderness Area. Shell does not anticipate impact on the Class I area but will comply with emissions requirements as directed by the BOEM.



### Impacts of a Small Fuel Spill

Potential impacts of a small spill on air quality are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b). The probability of a small spill would be minimized by Shell’s preventative measures during routine operations, including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the extent and duration of air quality impacts from a small spill would not be significant.

A small fuel spill would likely affect air quality near the spill site by introducing VOCs through evaporation. The ADIOS2 model (see Section A.9.2 ) indicates that more than 90% of a small diesel spill would be evaporated or dispersed within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha) depending on sea state and weather
conditions.

A small fuel spill would not affect coastal air quality because the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill

Potential impacts of a large oil spill on air quality are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b).

### A large oil spill would likely affect air quality by introducing VOCs through evaporation from the

slick. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Additional air quality impacts could occur if response measures included in situ burning of the floating oil. Burning would generate a plume of black smoke and result in emissions of NO
x 

### , SO
x 

### , CO, and PM, as well as greenhouse gases.

Due to the lease area location ( 49 miles [ 79 km] from the nearest shoreline), most air quality impacts would occur in offshore waters. Depending on the spill trajectory and the effectiveness of spill response measures, coastal air quality could also be affected. Based on the OSRA modeling predictions ( Table 3 ), Plaquemines Parish, Louisiana, is the coastal area most likely to
be affected.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout pr evention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on air quality are expected.



### C.1.2 Water Quality

Deepwater areas in the Gulf of Mexico are relatively homogeneous with respect to temperature, salinity, and oxygen (MMS, 2007b). IPFs potentially affecting water quality are effluent discharges and two types of accidents: a small fuel spill and a large oil spill.



### Impacts of Effluent Discharges

Discharges of treated SBM cuttings will produce temporary, localized increases in suspended solids in the water column around the drilling rig. In general, turbid water can be expected to extend between a few hundred meters and several kilometers down current from the discharge point (NRC, 1983; Neff, 1987). NPDES permit limitations and requirements will be met. After discharge, SBM retained on cuttings would be expected to adhere tightly to the cuttings particles and, consequently, would not produce much turbidity as the cuttings sink through the water column (Neff et al., 2000). There will be no persistent impacts on water quality in the lease area, according to analyses in the most recent Final EIS (BOEM, 2012b).

Treated sanitary and domestic wastes may have a slight transient effect on water quality in the immediate vicinity of these discharges. NPDES permit limitations and requirements will be met and little or no impact on water quality is anticipated. Support vessel discharges will comply with USCG regulations and, as applicable, the NPDES Vessel General Permit, and therefore are not expected to cause significant impacts on water quality.

Deck drainage includes effluents resulting from rain, deck washings, and runoff from curbs, gutters, and drains, including drip pans in work areas. Rainwater that falls on uncontaminated areas of the drilling rig will flow overboard without treatment. However, rainwater that falls on the drilling rig deck and other areas such as chemical storage areas and places where equipment is exposed will be collected and oil and water separated to meet NPDES permit requirements. Negligible impact on water quality is anticipated.

### Other discharges such as desalination unit brine and uncontaminated cooling water, fire water,

and ballast water are expected to be diluted rapidly and have little or no impact on water quality.



### Impacts of a Small Fuel Spill

Potential impacts of a small spill on water quality are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b). The probability of a small spill would be minimized by Shell’s preventative measures during routine operations, including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the extent and duration of water quality impacts from a small spill would not be significant.

A small fuel spill in offshore waters would increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. However, it is estimated that more than 90% of a small diesel spill would be evaporated or dispersed within 24 hours (see Section A.9.2 ). The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha) depending on sea state
and weather conditions.

The water-soluble fractions of diesel are dominated by two- and three-ringed PAHs, which are moderately volatile (NRC, 2003). The constituents of these oils are light to intermediate in molecular weight and can be readily degraded by aerobic microbial oxidat ion. Diesel’s density is such that it will not sink and pool on the seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this generally occurs only in coastal areas with high-suspended solid loads (NRC, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes (NOAA, 2006).

A small fuel spill would not affect coastal water quality because the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill

Potential impacts of a large oil spill on water quality are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b). A large spill would likely affect water quality by producing a slick on the water surface and increasing the concentrations of petroleum hydrocarbons and their degradation products. The

exte nt and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Most of the oil would be expected to form a slick at the surface, although observations following the Macondo spill indicate that plumes of submerged oil droplets can be produced when subsea dispersants are applied at the wellhead (Camilli et al., 2010; Hazen et al., 2010; Joint Analysis Group, 2010a,b,c). A report by Kujawinski et al. (2011) indicates that chemical components of subsea dispersants used during the Macondo spill persisted for up to two months and were detectable up to 186 miles (300 km) from the wellsite at a water depth of 3,280 to 3,937 ft (1,000 to 1,200 m). While dispersants were detectable in 353 of the 4,114 total water samples, concentrations in the samples were significantly below the chronic screening level for dispersant (BOEM, 2012d).

### Once oil enters the ocean, a variety of physical, chemical, and biological processes act to

di sperse the oil slick. These processes include spreading, evaporation of the more volatile constituents, dissolution into the water column, emulsification of small droplets, agglomeration sinking, microbial modification, photochemical modification, and biological ingestion and excretion (NRC, 2003). Marine water quality would be temporarily affected by the dissolved components and small oil droplets that do not rise to the surface or are mixed down by surface turbulence. Dispersion by currents and microbial degradation removes the oil from the water column or dilutes the constituents to background levels.

A large oil spill could result in a release of gaseous hydrocarbons that could affect water quality. During the Macondo spill, large volumes of methane (CH 4 

### ) were released, causing localized oxygen depletion as methanotrophic bacteria rapidly metabolized the hydrocarbons (Joye et al., 2011; Kessler et al., 2011). However, a broader study of the deepwater Gulf of Mexico found that although some stations showed slight depression of dissolved oxygen concentrations relative to climatological background values, the findings were not indicative of hypoxia (<2.0 mg/L) (Operational Science Advisory Team [OSAT], 2010). Stations revisited around the Macondo wellhead in October 2010 showed no measurable oxygen depressions (OSAT, 2010).

Due to the lease area location ( 49 miles [ 79 km] from the nearest shoreline), most water quality impacts would occur in offshore waters. Depending on the spill trajectory and the effectiveness of spill response measures, coastal water quality could be affected. Based on the OSRA modeling predictions ( Table 3 ), nearshore waters and embayments of Plaquemines Parish, Louisiana, are the most likely coastal areas to be affected.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on water quality are expected.



## C.2 Seafloor Habitats and Biota

Water depths at the proposed well surface locations range from approximately 3, 125 to 3,747 ft (9 53 to 1,1 42 m). See EP Section 6a for further information.

According to the BOEM (2011), existing information for the deepwater Gulf of Mexico indicates that the seafloor is composed primarily of soft sediments; hard bottom communities are rare.

MC 720, 721, and 722 are within deepwater Grid 13 where remotely operated vehicle (ROV) coverage of the seafloor is considered adequate to characterize the area (BOEM, 2011).



### C.2.1 Soft Bottom Benthic Communities

Data from the Northern Gulf of Mexico Continental Slope Habitats and Benthic Ecology study (Wei, 2006; Rowe and Kennicutt, 2009) can be used to describe typical benthic communities in
the area. Table 4 summarizes data from two nearby stations in similar water depths. Sediments at these two stations were predominantly clay (46% to 54%) and silt (43% to 45%).

### Table 4. Benthic community data from stations near the lease area and in similar water depths sampled during the Northern Gulf of Mexico Continental Slope Habitats and Benthic Ecology Study (From: Wei, 2006; Rowe and Kennicutt, 2009).

Station Location

Relative to Lease Area Water

Depth (m) Abundance

Meiofauna (individuals/m 2 ) Macroinfauna

(individuals/m 2 ) Megafauna

(individuals/ha)

MT

- 3 20 mi NW 990 885,995 4,924 1,034

MT

- 4 29 mi S 1,401 246,058 3,262 1,548

Meiofaunal and megafaunal abundance from Rowe and Kennicutt (2009); macroinfaunal abundance from Wei (2006).



### Meiofauna (animals passing through a 0.5-mm sieve but retained on a 0.062-mm sieve) densities in water depths representative of the lease area typically range from about

22 0,000 to 890,000 individuals/m 2 

### (Rowe and Kennicutt, 2009). Nematodes, nauplii, and harpacticoid copepods were the three dominant groups in the meiofauna, accounting for about
90% of total abundance.

The benthic macroinfauna is characterized by small mean individual sizes and low densities, both of which are a reflection of the meager primary production in Gulf of Mexico surface waters (Wei, 2006). Densities decrease exponentially with water depth. Based on an equation presented by Wei (2006), macroinfaunal densities in the water depth of the wellsites are expected to be about 3,000 individuals/m 2 

### , lower than the values in Table 4

.
Polychaetes are typically the most abundant macroinfaunal group on the northern Gulf of Mexico continental slope, followed by amphipods, tanaids, bivalves, and isopods. Wei (2006) recognized four depth-dependent faunal zones (1 through 4), two of which are divided horizontally. The lease area is in Zone 2E, which consists of stations on the mid Texas-Louisiana Slope ranging in depth from 2,050 to 5,997 ft (625 to 1,828 m). The five most abundant species

in Zone 2E are the polychaetes Litocorsa antennata

, Aricidea suecica

, Tharyx marioni , and Paralacydonia paradoxa and the bivalve Heterodonta sp. Megafaunal density from nearby stations MT-3 and MT-4 was 1,034 and 1,548 individuals/ha, respectively ( Table 4 ). Densities of 200 to 3,000 individuals/ha were reported from other stations in a similar depth range. Common megafauna included motile groups such as decapods, ophiuroids, holothurians, and demersal fishes, as well as sessile groups such as sponges and anemones.

Bacteria are the foundation of deep-sea chemosynthetic communities (Ross et al., 2012) and are an important component in terms of biomass and cycling of organic carbon (Cruz-Kaegi, 1998). Bacterial biomass at the depth range of the lease area typically is about 1 to 2 grams of carbon per square meter (g C m

− 2 

### ) in the top 6 in. (15 cm) of sediments (Rowe and Kennicutt, 2009).

IPFs potentially affecting benthic communities are physical disturbance, effluent discharges (drilling mud and cuttings), and a large oil spill resulting from a well blowout at the seafloor. A small fuel spill would not affect benthic communities because the diesel fuel would float and dissipate on the sea surface.



### Impacts of Physical Disturbance to the Seafloor

In water depths such as those that are encountered in the lease area, dynamically positioned semisubmersibles disturb the seafloor only around the wellbore (surface hole location) where

### the bottom template and blowout preventer are located. Depending upon the specific well

configuration, this area is generally about 0.62 ac (0.25 ha) (BOEM, 2012b).

The areal extent of these impacts from a dynamically positioned drilling rig will be small compared to the lease area itself. Soft bottom communities are ubiquitous along the northern Gulf of Mexico continental slope (Gallaway et al., 2003; Rowe and Kennicutt, 2009). Physical disturbance to the seafloor during this project will have no significant impact on soft bottom benthic communities on a regional basis.



### Impacts of Effluent Discharges

Drilling mud and cuttings are the only effluents likely to affect benthic communities. During initial well interval(s) before the marine riser is set, cuttings and seawater- based “spud mud” will be released at the seafloor. Excess cement slurry will also be released at the seafloor during casing installation for the riserless portion of the drilling operations. Cement slurry components
ty pically include cement mix and some of the same chemicals used in water-based drilling mud (Boehm et al., 2001). The main impacts will be burial and smothering of benthic organisms
within several meters to tens of meters around the wellbore. Soft bottom sediments disturbed by cuttings, drilling mud, and cement slurry will eventually be recolonized through larval settlement and migration from adjacent areas. Because some deep-sea biota grow and reproduce slowly, recovery may require several years.

Discharges of treated SBM cuttings from the rig may affect benthic communities, primarily within several hundred meters of the wellsites. The fate and effects of SBM cuttings have been reviewed by Neff et al. (2000), and monitoring studies have been conducted in the Gulf of Mexico by Continental Shelf Associates, Inc. (2004, 2006). In general, cuttings with adhering SBM tend to clump together and form thick cuttings piles close to the drillsite. Areas of SBM cuttings deposition may develop elevated organic carbon concentrations and anoxic conditions (Continental Shelf Associates, Inc., 2006). Where SBM cuttings accumulate and concentrations exceed approximately 1,000 mg/kg, benthic infaunal communities may be adversely affected due to both the toxicity of the base fluid and organic enrichment (with resulting anoxia) (Neff et al., 2000). Infaunal numbers may increase and diversity may decrease as opportunistic species that tolerate low oxygen and high H 2 

### S predominate (Continental Shelf Associates, Inc., 2006). As the base synthetic fluid is decomposed by microbes, the area will gradually return to pre-drilling conditions. Disturbed sediments will be recolonized through larval settlement and migration from adjacent areas.

The areal extent of impacts from drilling discharges will be small; the typical effect radius is 1,640 ft (500 m) around each wellsite. For the eight surface locations in this exploration drilling program, the total impact area would be 1,553 ac (628 ha). Soft bottom communities are ubiquitous along the northern Gulf of Mexico continental slope (Gallaway, 1988; Gallaway et al., 2003; Rowe and Kennicutt, 2009). Impacts from drilling discharges during this project will have no significant impact on soft bottom benthic communities on a regional basis.



### Impacts of a Large Oil Spill

The most likely effects of a subsea blowout on benthic communities would be within a few hundred meters of the wellsites. The MMS (2007b) estimates that a severe subsurface blowout could resuspend and disperse sediments within a 984-ft (300-m) radius. While coarse sediments (sands) would probably settle at a rapid rate within 1,312 ft (400 m) from the blowout site, fine

### sediments (silts and clays) could be resuspended for more than 30 days and dispersed over a

much wider area. Previous studies characterized surface sediments in the vicinity of the site as about 50% clay and 45% silt (Rowe and Kennicutt, 2009).

Previous analyses (MMS, 2007a, 2008) concluded that oil spills would be unlikely to affect benthic communities beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface plumes were reported at a water depth of about 3,600 ft (1,100 m), extending at least 22 miles (35 km) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). Chemical components of subsea dispersants used during the Macondo spill persisted for up to two months and were detected up to 186 miles (300 km) from the wellsite at a water depth of 3,280 to 3,937 ft (1,000 to 1,200 m) (Kujawinski et al., 2011). However, estimated dispersan t concentrations in the subsea plume were below levels known to be toxic to marine life. While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could contact the seafloor and affect benthic communities beyond the 984- ft (300-m) radius estimated by MMS (2007a, 2008), depending on its extent, trajectory, and persistence. This contact could result in smothering and/or toxicity to benthic organisms. The affected area would be recolonized by benthic organisms over a period of months to years (NRC, 2003).

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlike ly event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on soft bottom communities are expected.



### C.2.2 High-Density Deepwater Benthic Communities

As defined by NTL 2009-G40, high-density deepwater benthic communities are features or areas that could support high-density chemosynthetic communities, high-density deepwater corals, or other associated high-density hard bottom communities. Chemosynthetic communities were discovered in the central Gulf of Mexico in 1984 and have been studied extensively (MacDonald, 2002). Deepwater coral communities are also known from numerous locations in the Gulf of Mexico (Brooke and Schroeder, 2007; CSA International, Inc., 2007). These communities occur almost exclusively on authigenic carbonates created by chemosynthetic communities, and on shipwrecks. The nearest known chemosynthetic community site is located approximately 49 miles ( 79 km) west southwest of the lease area in MC 969 (Brooks et al., 2009).

The chemosynthetic community assessment by C&C Technologies (2009) and GEMS (2010) did not identify features that could support high-density deepwater benthic communities within 2,000 f t ( 610 m) of the proposed drilling mud/cuttings discharge locations.

IPFs potentially affecting high-density deepwater benthic communities are effluent discharges (drilling mud and cuttings), and a large oil spill from a well blowout at the seafloor. A sm all fuel spill would not affect benthic communities because the diesel fuel would float and dissipate on
the sea surface.

### Impacts of Effluent Discharges

The chemosynthetic community assessment included in this EP, based on the reports by C&C Technologies (2009) and GEMS (2010), did not identify features that could support high-density deepwater benthic communities within 2,000 ft (610 m) of the proposed drilling mud/cuttings discharge locations. Monitoring programs on the Gulf of Mexico continental slope have shown that benthic impacts from drilling discharges typically are concentrated within about 1,640 ft (500 m) of the wellsites, although detectable deposits may extend beyond this distance (Continental Shelf Associates, Inc., 2004, 2006; Neff et al., 2005). If high-density deepwater communities are associated with the more distant expulsion features and mud volcanoes identified in the hazards survey, significant impacts on these communities will be avoided because of the distance from the discharge location.



### Impacts of a Large Oil Spill

Previous analyses (MMS, 2007a, 2008b) concluded that oil spills would be unlikely to affect benthic communities beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface plumes were reported at a water depth of about 3,600 ft (1,100 m), extending at least 22 miles (35 km) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). Chemical components of subsea dispersants used during the Macondo spill persisted for up to tw o months and were detectable up to 186 miles (300 km) from the wellsite at a water depth of 3,280 to 3,937 ft (1,000 to 1,200 m) (Kujawinski et al., 2011). However, estimated dispersant concentrations in the subsea plume were below levels known to be toxic to marine life. While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could have the potential to contact high-density deepwater benthic communities beyond the 984-ft (300-m) radius estimated by MMS (2007a, 2008), depending on its extent, trajectory, and persistence. Potential impacts on sensitive resources would be an integral part of the decision and approval process for the use of dispersants. The chemosynthetic community assessment by C&C Technologies (2009) and GEMS (2010) did not identify high-density deepwater benthic

communities wi thin 2,000 ft (610 m) of the proposed drilling mud/cuttings discharge locations. Potential impacts of oil on high-density deepwater benthic communities are discussed in

MMS (2007b) and BOEM (2012b).

Although chemosynthetic communities live among hydrocarbon seeps, natural seepage occurs at a relatively constant low rate compared with the potential rates of oil release from a blowout. In addition, seep organisms require unrestricted access to oxygenated water at the same time as exposure to hydrocarbon energy sources (MacDonald, 2002). Oil droplets or oiled sediment particles could come into contact with chemosynthetic organisms or deepwater corals. As discussed by MMS (2007b), impacts could include loss of habitat, biodiversity, and live coral coverage; destruction of hard substrate; change in sediment characteristics; and reduction or loss of one or more commercial and recreational fishery habitats. Sublethal effects could be long lasting and affect the resilience of coral colonies to natural disturbances (e.g., elevated water temperature and diseases) (BOEM 2012d).

The potential for a spill to affect deepwater corals was observed during an October 2010 survey of deepwater coral habitats in water depths of 4,600 ft (1,400 m) approximately 7 miles (11 km)

### southwest of the Macondo wellhead. Much of the soft coral observed in a location measuring

about 50 by 130 ft (15 by 40 m) was covered by a brown flocculent material (BOEMRE, 2010 ) with signs of stress, including varying degrees of tissue loss and excess mucous production (White et al., 2012). Researchers concluded, based on hopanoid petroleum biomarker analysis of the flocculent material, that it contained oil from the Macondo spill. The injured and dead corals were in an area where a subsea plume of oil had been documented during the spill in

June 2010. The deepwater coral at this location showed signs of tissue damage that was not observed elsewhere during these surveys or in previous deepwater coral studies in the Gulf of

Mexico. The team of researchers concluded that the observed coral injuries likely resulted from exposure to the subsurface oil plume (White et al., 2012). The study location is about 51 miles (83 km) northeast of the activities discussed in this EIA. There would not likely be cumulative impacts to those corals even in the unlikely event of a large spill associated with the activities
discussed in this EIA

.
A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Potential impacts on sensitive resources would be an integral part of the decision and approval process for the use of dispersants. Therefore, no significant spill impacts on deepwater benthic communities are expected.



### C.2.3 Designated Topographic Features

The blocks are not within or near a designated topographic feature or a no-activity zone as identified in NTL 2009-G39. The nearest designated topographic feature stipulation block is West Delta Area, South Addition 147, located 34 miles ( 55 km) northwest of the lease area.

There are no IPFs associated with either routine operations or accidents that could cause impacts to designated topographic features due to the distance from the lease area.



### C.2.4 Pinnacle Trend Area Live Bottoms

The lease area is not covered by the Live Bottom (Pinnacle Trend) Stipulation. As defined by NTL 2009-G39, the nearest pinnacle trend blocks are located about 81 miles (131 km) north-northeast of the lease area, along the shelf edge south of Alabama.

There are no IPFs associated with either routine operations or accidents that could cause impacts to pinnacle trend area live bottoms due to the distance from the lease area.



### C.2.5 Eastern Gulf Live Bottoms

The lease area is not covered by the Live Bottom (Low-Relief) Stipulation, which applies to Eastern Gulf of Mexico Planning Area leases in water depths of 328 ft (100 m) or less. The nearest blocks covered by the live bottom stipulation, as defined by NTL 2009-G39, are about

1 17 miles (188 km) northeast of the project area.

There are no IPFs associated with either routine operations or accidents that could cause impacts to eastern Gulf live bottom areas due to the distance from the lease area.

## C.3 Threatened, Endangered, and Protected Species and Critical Habitat

This section discusses species listed as endangered or threatened under the ESA. In addition, it includes all marine mammal species in the region, which are protected under the MMPA.

Endangered or threatened species that may occur in the project area and/or along the northern
Gulf Coast are listed in Table 5 . The table also indicates the location of designated critical habitat in the Gulf of Mexico. Critical habitat is defined as (1) specific areas within the geographical area occupied by the species at the time of listing, if they contain physical or biological features essential to conservation, and those features may require special management considerations or protection; and (2) specific areas outside the geographical area occupied by the species if the agency determines that the area itself is essential for conservation. The NMFS has jurisdiction over ESA-listed cetaceans and fishes in the Gulf of Mexico. The USFWS has jurisdiction over ESA- lis ted birds and the Florida manatee. These two agencies share federal jurisdiction over sea turtles, with NMFS having lead responsibility at sea and USFWS on nesting beaches.

The sperm whale and five species of sea turtles are the only endangered or threatened species likely to occur at or near the lease area. No critical habitat has been designated for these species in the Gulf of Mexico.

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right whale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

Coastal endangered or threatened species include the Florida manatee, Piping Plover, Whooping Crane, Gulf sturgeon, and four subspecies of beach mouse. Critical habitat has been designated for all of these species as indicated in Table 5 and discussed in individual sections.

Table 5. Federally listed endangered and threatened species in the lease area and along the
northern Gulf Coast.

Species Scientific Name Status Potential
Presence Critical Habitat

Designated in Gulf of Mexico Lease Area Coastal

Marine Mammals Sperm whale Physeter macrocephalus E X

-- None

Florida manatee Trichechus manatus latirostris E

-- X Florida (Peninsular) Blue whale Balaenoptera musculus E X a

-- None Fin whale Balaenoptera physalus E X a

-- None Humpback whale Megaptera novaeangliae E X a

-- None North Atlantic right whale Eubalaena glacialis E X a

-- None Sei whale Balaenoptera borealis E X a

-- None Sea Turtles Loggerhead turtle Caretta caretta T, E b X X None Green turtle Chelonia mydas T, E c X X None Leatherback turtle Dermochelys coriacea E X X None Hawksbill turtle Eretmochelys imbricata E X X None Kemp’s ridley turtle Lepidochelys kempii E X X NoneSpecies Scientific Name Status Potential
Presence Critical Habitat

Designated in Gulf of Mexico Lease
Area Coastal

Birds

Piping Plover Charadrius melodus T

-- X Coastal Texas, Louisiana, Mississippi, Alabama, and Florida (Panhandle)

Whooping Crane Grus americana E

-- X Coastal Texas (Aransas National Wildlife Refuge) Fishes

Gulf sturgeon Acipenser oxyrinchus desotoi T

-- X Coastal Louisiana, Mississippi, Alabama, and Florida (Panhandle) Terrestrial Mammals Beach mouse (A labama, Choctawhatchee, Perdido Key, St. Andrew) Peromyscus polionotus E

-- X Alabama and Florida (Panhandle) beaches

Abbreviations: E = Endangered; T = Threatened.

a The blue, fin, humpback, North Atlantic right, and sei whales are rare or extralimital in the Gulf of Mexico and are unlikely to be present in the lease area.

b The loggerhead turtle is composed of nine distinct population segments (DPS) that are considered “species.” The only DPS that may occur in the project area (Northwest Atlantic DPS) is listed as threatened ( 76 FR 58868; September 22, 2011).

c The green sea turtle is threatened, except for the Florida breeding population, which is listed as endangered.



### Two other coastal species (Bald Eagle and Brown Pelican) discussed by MMS (2007b) and BOEM (2012b) are no longer listed as endangered or threatened; these species are discussed in

Section C.4.2

, Shorebirds and Coastal Nesting Birds

.
There are no other endangered animals or plants in the Gulf of Mexico that are reasonably likely to be affected by either routine or accidental events. Other species occurring at certain locations in the Gulf of Mexico such as the smalltooth sawfish ( Pristis pectinata ), elkhorn coral ( Acropora palmata ), staghorn coral ( Acropora cervicornis ), and Florida salt marsh vole ( Microtus pennsylvanicus dukecampbelli ) are remote from the lease area and highly unlikely to
be affected.



### C.3.1 Sperm Whale (Endangered)

The only endangered marine mammal likely to be present at or near the project area is the sperm whale ( Physeter macrocephalus ). Resident populations of sperm whales occur within the Gulf of Mexico. A species description is presented in a recent lease sale EIS (MMS, 2007b). Gulf of Mexico sperm whales are classified as an endangered species and a “strategic stock” (defined as a stock that may have unsustainable human-caused impacts) by NMFS (Waring et al., 2012). No critical habitat for the sperm whale has been designated in the Gulf of Mexico.

The distribution of sperm whales in the Gulf of Mexico is correlated with mesoscale physical features such as eddies associated with the Loop Current (Jochens et al., 2008). Sperm whale populations in the north-central Gulf of Mexico are present there throughout the year

### (Davis et al., 2000). Results of a multi-year tracking study show female sperm whales typically

concentrated along the upper continental slope between the 656- and 3,280- ft (200- and 1,000-m) depth contours (Jochens et al., 2008). Male sperm whales were more variable in their movements and were documented in water depths greater than 9,843 ft (3,000 m). Generally, groups of sperm whales sighted in the Gulf of Mexico during the MMS-funded Sperm Whale Seismic Study (SWSS) consisted of mixed-sex groups comprising adult females and immatures, and groups of bachelor males. Typical group size for mixed groups was 10 individuals (Jochens et al., 2008). SWSS results show that sperm whales transit through the vicinity of the lease area. Movements of satellite-tracked individuals suggest that this area of the Gulf continental slope is within the home range of the Gulf of Mexico population (within the 95% utilization distribution) (Jochens et al., 2008).

IP Fs potentially affecting sperm whales include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents

– a small fuel spill and a large oil spill. Effluent discharges are likely to have negligible impacts on sperm whales due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of these marine mammals. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on sperm whales.



### Impacts of Drilling Rig Presence, Noise, and Lights

Noise from routine drilling activities has the potential to disturb sperm whales. Sperm whales appear to have good low-frequency hearing, but the available data do not indicate a consistent response to anthropogenic noise (Jochens et al., 2008). Noise associated with drilling is relatively weak in intensity, and an individual animal’s noise exposure would be transient. There are other OCS facilities and activities near the lease area, and the region as a whole has a large number of similar sources. Due to the limited scope, timing, and geographic location of drilling activities, this project would represent a small temporary contribution to the overall noise regime.

NMFS analyzed the potential for impacts of drilling-related noise on sperm whales in its Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico (NMFS, 2007). The analysis noted that drilling rigs sho w low sound source levels and concluded that drilling is not expected to produce amplitudes sufficient to cause hearing or behavioral effects in sperm whales; therefore, these effects are insignificant (NMFS, 2007).

Although offshore lighting and presence of drilling rigs and OCS vessels were considered potential factors affecting sperm whales, NMFS’s 2007 Biological Opinion and recent lease sale EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b) did not identify these as IPFs for sperm whales. Therefore, no significant impacts are expected.



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sperm whales. There is also a risk of vessel strikes, which are identified as a threat in the recovery plan for this species (NMFS, 2010a). Data concerning the frequency of vessel strikes are presented in the lease sale EIS (MMS, 2007b).

To reduce the potential for vessel strikes, the BOEM has issued NTL 2012-JOINT-G01, which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid

### striking protected species, and requires operators to report sightings of any injured or dead

protected species. When whales are sighted, vessel operators and crews are required to attempt to maintain a distance of 300 ft (91 m) or greater whenever possible. Vessel operators are required to reduce vessel speed to 10 knots or less, when safety permits, when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sperm whales.

NMFS (2007) analyzed the potential for vessel strikes and harassment of sperm whales in its Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico (NMFS, 2007). With implementation of the mitigation measures in NTL 2012-JOINT-G01, NMFS concluded that the likelihood of collisions between vessels and sperm whales would be reduced to insignificant levels. NMFS concluded that the observed avoidance of passing vessels by sperm whales is an advantageous response to avoid a potential threat and is not expected to result in any significant effect on migration, breathing, nursing, breeding, feeding, or sheltering to individuals, or have any consequences at the level of the population. With implementation of the vessel strike avoidance measures requirement to maintain a distance of 295 ft (90 m) from sperm whales, NMFS concluded that the potential for harassment of sperm whales would be reduced to discountable levels.

Helicopter traffic also has the potential to disturb sperm whales. Smultea et al. (2008) documented responses of sperm whales offshore Hawaii to fixed wing aircraft flying at an altitude of 800 ft (245 m). A reaction to the initial pass of the aircraft was observed during three (12%) of 24 sightings. All three reactions consisted of a hasty dive and occurred at less than 1,180 ft (360 m) lateral distance from the aircraft. Additional reactions were seen when aircraft
circled certain whales to make further observations. Based on other studies of cetacean responses to sound, the authors concluded that the observed reactions to brief overflights by the aircraft were short-term and probably of no long-term biological significance.

Helicopters maintain altitudes above 700 ft (213 m) during transit to and from the offshore working area. In the event that a whale is seen during transit, the helicopter will not approach or circle the animal(s). In addition, guidelines and regulations specify that helicopters maintain an altitude of 1,000 ft (305 m) within 300 ft (91 m) of marine mammals (BOEM, 2012a,b). Although whales may respond to helicopters (Smultea et al., 2008), NMFS (2007) and BOEM (2012a) concluded that this altitude would minimize the potential for disturbing sperm whales. Therefore, no significant impacts are expected.



### Impacts of a Small Fuel Spill

Potential spill impacts on marine mammals including sperm whales are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b) and the Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico (NMFS, 2007). Oil impacts on marine mammals are discussed by Geraci and St. Aubin (1990).
For thi s EP there are no unique site-specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by Shell’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of
Shell’s OSRP will mitigate and reduce the potential for impacts on sperm whales. EP Section 9b

### provides detail on spill response measures. Given the open ocean location of the lease area, the

duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (Marine Mammal Commission [MMC], 2011). However, due to the limited areal extent and short duration of water quality impacts from a small fuel spill, as well as the mobility of sperm whales, no significant impacts would be expected.



### Impacts of a Large Oil Spill

Potential spill impacts on marine mammals including sperm whales are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012a,b) and by the NMFS (2007). Oil impacts on marine mammals are discussed by Geraci and St. Aubin (1990). For this EP , there are no unique site-specific issues with respect to spill impacts on these animals.

Impacts of oil spills on sperm whales can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2011). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat, disruption of social structure, changing prey availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 2011 ).

Studies have shown that the cetacean epidermis functions as an effective barrier to noxious substances found in petroleum (Geraci and St. Aubin, 1985). Unlike other mammals, penetration of such substances in cetacean skin is impeded by tight intercellular bridges, the vitality of the superficial cells, the thickness of the epidermis, and the lack of sweat glands and hair follicles. In addition, cetacean skin is free from hair or fur, which in other marine mammals not found in the Gulf of Mexico (e.g., pinnipeds and otters) tend to collect oil and/or tar.

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb sperm whales and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012-JOINT-G01 to reduce the potential for striking or disturbing these animals.

### A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an

event will be minimized by She ll’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, n o significant spill impacts on sperm whales are expected.



### C.3.2 Florida Manatee (Endangered)

Most of the Gulf of Mexico manatee population is located in peninsular Florida (USFWS, 2001). Manatees regularly migrate farther west of Florida in the warmer months (Wilson, 2003) into Alabama and Louisiana coastal environs, with some individuals traveling as far west as Texas (Fertl et al., 2005). A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the recovery plan for this species (USFWS, 2001).

IPFs potentially affecting manatees include support vessel and helicopter traffic and a large oil spill. A small fuel spill in the lease area would be unlikely to affect manatees, as the lease area is approximately 49 miles ( 79 km) from the nearest shoreline (Louisiana). As explained in

Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on manatees. Consistent with the analysis in BOEM (2012a), impacts of routine project-related activities on the manatee would be negligible.



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb manatees, and there is also a risk of vessel strikes, which are identified as a threat in the recovery plan for this species (USFWS, 2001).

To reduce the potential for vessel strikes, the BOEM has issued NTL 2012-JOINT-G01, which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. Compliance with NTL 2012-JOINT-G01 will minimize the likelihood of vessel strikes, and no significant impacts on manatees are expected.

Helicopter traffic, if present, also has the potential to disturb manatees. Rathbun (1988) reported that manatees were disturbed more by helicopters than by fixed-wing aircraft; however, the helicopter was flown at relatively low altitudes of 66 to 525 ft (20 to 160 m). Helicopters used in support operations maintain a minimum altitude of 700 ft (213 m) while in transit offshore, 1,000 ft (305 m) over unpopulated areas or across coastlines, and 2,000 ft (610 m) over populated areas and sensitive habitats such as wildlife refuges and park properties. In addition, guidelines and regulations specify that helicopters maintain an altitude of 1,000 ft (305 m) within 300 ft (91 m) of marine mammals (BOEM, 2012a,b). This mitigation measure will minimize the potential for disturbing manatees, and no significant impacts are expected.



### Impacts of a Large Oil Spill

The OSRA results summarized in Table 3 predict that some Texas, Louisiana, and Florida shorelines could be contacted by a spill within 10 to 30 days. There is no critical habitat designated in these areas, and the number of manatees potentially present is a small fraction of the population in peninsular Florida.

### In the event that manatees were exposed to oil, effects could include direct impacts from oil

exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2011). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat, disruption of social structure, changing prey availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 2011 ).

In the event that a large spill reached coastal waters where manatees were present, the level of vessel and aircraft activity associated with spill response could disturb manatees and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012-JOINT-G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on manatees are expected.



### C.3.3 Endangered Mysticete Whales

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right
wh ale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

Due to the rare occurrence of these whales in the Gulf of Mexico, it is unlikely that any endangered mysticete would come into contact with any project activities, either routine operations or accidents.

Mysticete whales were not included as affected species in the Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico (NMFS, 2007). Potential impacts analyzed in recent lease sale EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012a,b,d) are incorporated by reference. If any of these whales were present in the area, potential impacts would be the same as those discussed below in

Section C.3.4

. 

### C.3.4 Non-Endangered Marine Mammals (Protected)

In addition to the seven endangered species that have been cited previously, 22 additional species of marine mammals may be found in the Gulf of Mexico, including 2 species of mysticete whales, the dwarf and pygmy sperm whales, 4 species of beaked whales, and 14 species of delphinids (see EP Section 6h ). All marine mammals are protected species under the MMPA. The most common non-endangered cetaceans in the deepwater environment are odontocetes

### such as the pantropical spotted dolphin, spinner dolphin, and Clymene dolphin. A brief

summary is presented below, and additional information on these groups is presented in a recent lease sale EIS (MMS, 2007b).

Mysticete whales . Two species of non-endangered mysticete whales are known from the Gulf
of Mexico: Bryde’s whale ( Balaenoptera edeni ) and minke whale ( Balaenoptera acutorostrata ). Bryde’s whale ( Balaenoptera edeni ) has been sighted most frequently along the 328-ft (100-m) isobath (Davis and Fargion, 1996; Davis et al., 2000). Most sightings have been made in the DeSoto Canyon region and off western Florida, although there have been some in the west-central portion of the northeastern Gulf. The minke whale is considered rare in the Gulf of Mexico, with the only confirmed records coming from strandings (Würsig et al., 2000). Based on
the available dat a, it is possible that Bryde’s whales could occur in the lease area.

Dwarf and pygmy sperm whales . At sea, it is difficult to differentiate dwarf sperm whales ( Kogia sima ) from pygmy sperm whales ( Kogia breviceps ), and sightings are often grouped together as “ Kogia spp.” Both species have a worldwide distribution in temperate to tropical waters. In the Gulf of Mexico, both species occur primarily along the continental shelf edge and in deeper waters off the continental shelf (Mullin et al., 1991; Mullin, 2007; Waring et al., 2012). Either species could occur in the lease area.

Beaked whales . Four species of beaked whales are known from the Gulf of Mexico. They are Blainville’s beaked whale ( Mesoplodon densirostris ), Cuvier’s beaked whale ( Ziphius cavirostris ), Sowerby’s beaked whale ( Mesoplodon bidens ), and Gervais’ beaked whale ( Mesoplodon

europaeus ). Stranding records in the Gulf of Mexico suggest that Gervais’ beaked whale is the most common and Sowerby’s beaked whale is extralimital. Due to the di fficulties of at-sea identification, beaked whales in the Gulf of Mexico are identified either as Cuvier’s beaked whales or are grouped into an undifferentiated complex ( Mesoplodon spp. and Ziphius spp.).

In the northern Gulf of Mexico, they are broadly distributed in waters greater than 3,281 ft (1,000 m) over lower slope and abyssal landscapes (Davis et al., 2000). Any of these species could occur in the lease area (Waring et al., 2012).

Delphinids . Fourteen species of delphinids are known from the Gulf of Mexico, including Atlantic spotted dolphin ( Stenella frontalis ), bottlenose dolphin ( Tursiops truncatus ), Clymene dolphin ( Stenella clymene ), false killer whale ( Pseudorca crassidens ), Fraser’s dolphin ( Lagenodelphis hosei ), killer whale ( Orcinus orca ), melon-headed whale ( Peponocephala electra ), pantropical spotted dolphin ( Stenella attenuata ), pygmy killer whale ( Feresa attenuata ), short-finned pilot whale ( Globicephala macrorhynchus ), Risso’s dolphin ( Grampus griseus ), rough-toothed dolphin ( Steno bredanensis ), spinner dolphin ( Stenella longirostris ), and striped dolphin ( Stenella coeruleoalba ). The most common non-endangered cetaceans in the deepwater environment are the pantropical spotted dolphin, spinner dolphin, and Clymene dolphin. However, any of these species could occur in the lease area (Waring et al., 2012).

IPFs potentially affecting non-endangered marine mammals include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents (a small fuel spill and a large oil spill). Effluent discharges are likely to have negligible impacts on marine mammals due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of marine mammals. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on marine mammals.

### Impacts of Drilling Rig Presence, Noise, and Lights

Noise from routine drilling activities has the potential to disturb marine mammals. Most odontocetes (toothed whales and dolphins) use higher frequency sounds than those produced by OCS drilling activities (Richardson et al., 1995). Noise associated with drilling is relatively weak in intensity, and an individual animal’s noise exposure would be transient. There are other OCS facilities and activities near the lease area, and the region as a whole has a large number of similar sources. Due to the limited scope, timing, and geographic extent of drilling activities, this project would represent a small temporary contribution to the overall noise regime, and any short-term impacts are not expected to be biologically significant to marine mammal populations.

Drilling rig lighting and presence are not identified as IPFs for marine mammals in recent lease sale EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012a,b,d). Therefore, no significant impacts are expected.



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb marine mammals, and there is also a risk of vessel strikes. Data concerning the frequency of vessel strikes are presented in the lease sale EIS (MMS, 2007b). To reduce the potential for vessel strikes, the BOEM and BSEE ha ve issued NTL 2012-JOINT-G01, which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. Vessel operators and crews are required to attempt to maintain a distance of 300 ft (91 m) or greater when whales are sighted and 150 ft (45 m) when small cetaceans are sighted. When cetaceans are sighted while a vessel is underway, vessels
must attemp t to remain parallel to the animal’s course and avoid excessive speed or abrupt changes in direction until the cetacean has left the area. Vessel operators are required to reduce vessel speed to 10 knots or less when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel, when safety permits. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing marine mammals, and therefore no significant impacts are expected.

Aircraft traffic also has the potential to disturb marine mammals (Würsig et al., 1998). However, while flying offshore, helicopters maintain altitudes above 700 ft (213 m) during transit to and from the working area. In addition, guidelines and regulations specify that helicopters maintain an altitude of 1,000 ft (305 m) within 300 ft (91 m) of marine mammals (BOEM, 2012a,b). This altitude will minimize the potential for disturbing marine mammals, and no significant impacts are expected (BOEM, 2012a,b ).



### Impacts of a Small Fuel Spill

Potential spill impacts on marine mammals are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b), and oil impacts on marine mammals in general are discussed by Geraci and St. Aubin (1990). For thi s EP , there are no unique site-specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by Shell’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP is expected to mitigate

### and reduce the potential for impacts on marine mammals. EP Section 9b provides detail on spill

response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (MMC, 2011). However, due to the limited areal extent and short duration of water quality impacts from a small fuel spill, as well as the mobility of marine mammals, no significant impacts would be expected.



### Impacts of a Large Oil Spill

Potential spill impacts on marine mammals are discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b) and by Geraci and St. Aubin (1990). For this EP , there are no unique site-specific issues.

Impacts of oil spills on marine mammals can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2011). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat, disruption of social structure, changing prey availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 2011 ).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb marine mammals and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012-JOINT-G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected. A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention
measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of
Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on marine mammals are expected.

### C.3.5 Sea Turtles (Endangered/Threatened)

As listed in EP Section 6h , five species of endangered or threatened sea turtles may be found near the lease area. Endangered species are the leatherback ( Dermochelys coriacea ), Kemp's ridley ( Lepidochelys kempii ), and hawksbill ( Eretmochelys imbricata ) turtles. The distinct population segment (DPS) of loggerhead turtle ( Caretta caretta ) that occurs in the Gulf of Mexico is listed as threatened, although other DPSs are endangered. The green turtle ( Chelonia mydas ) is listed as threatened, except for the Florida breeding population, which is listed as endangered. Species descriptions are presented in a recent lease sale EIS (MMS, 2007b).

Leatherbacks and loggerheads are the most likely species to be present near the lease area as

a dults. Green, hawksbill, and Kemp’s ridley turtles are typically inner shelf and nearshore species, unlikely to occur near the lease area as adults. Hatchlings or juveniles of any of the sea turtles may be present in deepwater areas, including the lease area, where they may be
associated with Sargassum and other flotsam.

All five sea turtle species in the Gulf of Mexico are migratory and use different marine habitats according to their life stage. These habitats include high-energy beaches for nesting females and emerging hatchlings and pelagic convergence zones for hatchling and juvenile turtles. As adults, green, hawksbill, and loggerhead turtles forage primarily in shallow, benthic habitats. Leatherbacks are the most pelagic of the sea turtles, feeding primarily on jellyfish.

Sea turtle nesting in the northern Gulf of Mexico can be summarized by species as follows:

12. Loggerhead turtles

– Loggerheads nest in significant numbers along the Florida Panhandle and, to a lesser extent, from Texas through Alabama (MMS, 2007b). The nearest significant nesting area of loggerhead turtles is found in Louisiana, on beaches within the Breton NWR;

13. Green and leatherback turtles

– Green and leatherback turtles infrequently nest on Florida Panhandle beaches (Florida Fish and Wildlife Conservation Commission, 2011);

14. Kemp’s ridley turtles – The main Kemp’s ridley nesting site is Rancho Nuevo beach, Tamaulipas, Mexico (NMFS et al., 2011 ). Approximately 200 Kemp’s ridley turtles nested on Texas beaches in 2009 (Sea Turt le Restoration Project, 2011). Kemp’s ridley turtles typically do not nest anywhere near the project area, although there have been occasional reports of Kemp’s ridleys nesting in Alabama (Share the Beach, 2010); and

15. Hawksbill turtles

–

Hawksbills typically do not nest anywhere near the project area.

IPFs potentially affecting sea turtles include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents - a small fuel spill and a large oil spill. Effluent discharges are likely to have negligible impacts on sea turtles due to rapid dispersion, the small area of ocean affected, and the intermittent nature of the discharges. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on sea
turtles.



### Impacts of Drilling Rig Presence, Noise, and Lights

Offshore drilling activities produce a broad array of sounds at frequencies and intensities that may be detected by sea turtles (Geraci and St. Aubin, 1987). Potential impacts may include behavioral disruption and temporary or permanent displacement from the area near the sound source. Certain sea turtles, especially loggerheads, may be attracted to offshore structures

### (Lohoefener et al., 1990) and, thus, may be more susceptible to impacts from sounds produced

during routine operations. Helicopters and service vessels may also affect sea turtles due to machinery noise and/or visual disturbances. The most likely impacts would be short-term behavioral changes such as diving and evasive swimming, disruption of activities, or departure from the area. Due to the limited scope, timing, and geographic extent of drilling activities, these short-term impacts are not expected to be biologically significant to sea turtle populations.

Artificial lighting can disrupt the nocturnal orientation of sea turtle hatchlings (Witherington, 1997; Tuxbury and Salmon, 2005). However, hatchlings may rely less on light cues when they are offshore than when they are emerging on the beach (Salmon and Wyneken, 1990). NMFS (2007) concluded that the effects of lighting from offshore structures on sea turtles are insignificant.



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sea turtles, and there is also a risk of vessel strikes. Data show that vessel traffic is one cause of sea turtle mortality in the Gulf of Mexico (Lutcavage et al., 1997). While adult sea turtles are visible at the surface during the day and in clear weather, they can be difficult to spot from a moving vessel when resting below the water surface, during nighttime, or during periods of inclement weather. To reduce the potential for vessel strikes, the BOEM and BSEE ha ve issued NTL 2012-JOINT-G01, which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for sea turtles and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. When sea turtles are sighted, vessel operators and crews are required to attempt to maintain a distance of 150 ft (45 m) or greater whenever possible. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sea turtles (NMFS, 2007).

Helicopter traffic also has the potential to disturb sea turtles. However, while flying offshore, helicopters maintain altitudes above 700 ft (213 m) during transit to and from the working area. This altitude will minimize the potential for disturbing sea turtles, and no significant impacts are expected.



### Impacts of a Small Fuel Spill

Potential spill impacts on sea turtles are discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b) and by the NMFS (2007) in its Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. For this EP, there are no unique site-specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by Shell’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP is expected to mitigate and reduce the potential for impacts on sea turtles. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at

### the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate

of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (MMS, 2007b; NMFS, 2010 b; BOEMRE, 2011; BOEM, 2012b). However, due to the limited areal extent and short duration of water quality impacts from a small fuel spill, no significant impacts would be expected.

A small fuel spill in the lease area would be unlikely to affect sea turtle nesting beaches because
the lease area is 49 miles ( 79 km) from the nearest shoreline (Louisiana). As explained in
Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up.



### Impacts of a Large Oil Spill

Impacts of oil spills on sea turtles can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes and smoke (e.g., from in situ burning of oil); ingestion of oil (and dispersants) directly or via contaminated food; and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat, disruption of social structure, changing food availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration (MMS, 2007b; NMFS, 2010c). In the unlikely event of a spill, implementation of Shell’s OSRP is expected to mitigate and reduce the potential for these types of impacts on sea turtles. EP Section 9b provides detail on spill response measures.

Studies of oil effects on loggerheads in a controlled setting (Lutcavage et al., 1995) suggest that sea turtles show no avoidance behavior when they encounter an oil slick, and any sea turtle in an affected area would be expected to be exposed. Sea turtles’ diving behaviors also put them at risk. Sea turtles rapidly inhale a large volume of air before diving and continually resurface over time, which may result in repeated exposure to volatile vapors and oiling (NMFS, 2007).

The OSRA results summarized in Table 3 predict that some shorelines that support sea turtle nesting could be contacted within 10 to 30 days. The nearest nesting area of loggerhead turtles is found in St. Bernard Parish, Louisiana, on beaches within the Breton NWR. Loggerhead turtles also nest to a lesser extent in Okaloosa County, Florida. Both these ar ea s ha ve contact probabilities of 1% after 30 days. Spilled oil reaching sea turtle nesting beaches could have effects on nesting sea turtles and egg development (NMFS, 2007). An oiled beach could affect nest site selection or result in no nesting at all (e.g., false crawls). Upon hatching and successfully reaching the water, hatchlings are subject to the same types of oil spill exposure hazards as adults. Hatchlings that contact oil residues while crossing a beach can exhibit a range of effects, from acute toxicity to impaired movement and normal bodily functions (NMFS, 2007).

### In the event of a large spill, the level of vessel and aircraft activity associated with spill response

could disturb sea turtles and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012-JOINT-G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate an d reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on sea turtles are expected.



### C.3.6 Piping Plover (Threatened)

The Piping Plover ( Charadrius melodus ) is a migratory shorebird that overwinters along the southeastern U.S. and Gulf of Mexico coasts. This threatened species is in decline as a result of hunting, habitat loss and modification, predation, and disease (USFWS, 2003). Critical overwintering habitat has been designated, including beaches in Texas, Louisiana, Mississippi, Alabama, and Florida ( Figure 1 ). Piping Plovers inhabit coastal sandy beaches and mudflats, feeding by probing for invertebrates at or just below the surface. They use beaches adjacent to foraging areas for roosting and preening (USFWS, 2010a). A species description is presented in a recent lease sale EIS (MMS, 2007b).

A large oil spill is the only IPF potentially affecting Piping Plovers. There are no IPFs associated with routine project activities that could affect these birds. A small fuel spill in the lease area would be unlikely to affect Piping Plovers because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation in Section A.9.2 ).



### Impacts of a Large Oil Spill

The lease area is 52 miles ( 83 km) from the nearest shoreline inhabited by Piping Plovers. The
OSRA results summarized in Table 3 predict that Texas and Louisiana shorelines designated as critical habitat for the wintering Piping Plover could be contacted by a spill within 10 to 30 days. Plaquemines Parish, Louisiana, which has the highest probability of contact for the 10- and

30 -day intervals (4% and 8%, respectively), includes Piping Plover critical habitat.

Plovers could become externally oiled while foraging on oiled shores or be exposed internally through ingestion of oiled intertidal sediments and prey (MMS, 2007b). Plovers congregate and feed along tidally exposed banks and shorelines, following the tide out and foraging at the water’s edge. It is possible that some deaths of Piping Plovers could occur, especially if spills occur during winter months when plovers are most common along the coastal Gulf or if spills
contacted critical habitat. Impacts could also occur from vehicular traffic on beaches and other activities associated with spill cleanup. Shell has extensive resources available to protect and rehabilitate wildlife in the event of a spill reaching the shoreline, as detailed in the OSRP.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation o f Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on Piping Plovers are expected.

### Figure 1. Location of selected environmental features in relation to the lease area.

### C.3.7 Whooping Crane (Endangered)

The Whooping Crane ( Grus americana ) is an omnivorous wading bird and an endangered species. There are three wild populations in North America (National Wildlife Federation, 2012). One population winters along the Texas coast at Aransas NWR and summers at Wood Buffalo National Park in Canada. This population represents the majority of the world’s population of free-ranging Whooping Cranes and reached a record population of 278 at Aransas/Wood Buffalo National Park in August 2011 (W hooping Crane Eastern Partnership, 2012). A non-migrating population has been re-introduced in central Florida, and another re-introduced population summers in Wisconsin and migrates to the southeastern U.S. for the winter. Whooping Cranes breed, migrate, winter, and forage in a variety of habitats, including coastal marshes and estuaries, inland marshes, lakes, ponds, wet meadows and rivers, and agricultural fields (USFWS, 2007). About 22,240 ac (9,000 ha) of salt flats on Aransas NWR and adjacent islands comprise the principal wintering grounds of the Whooping Crane. Aransas NWR is designated as critical habitat for the species ( Figure 1 ). A species description is presented in recent lease sale EISs (M MS, 2007b; BOEM, 2012b ).

A large oil spill is the only IPF that could potentially affect Whooping Cranes due to the distance
from Aransas NWR.



### Impacts of a Large Oil Spill

A large oil spill is has a low probability of affecting Whooping Cranes because the lease area is approximately 4 44 miles (7 14 km) from its critical habitat (Aransas NWR, Texas) and the likelihood of contact with the habitat is extremely low (BOEM, 2012b).

In the event of oil exposure, Whooping Cranes could become externally oiled while foraging in oiled areas or internally exposed to oil through ingestion of contaminated shellfish, frogs, and fishes. It is possible that some death of Whooping Cranes could occur. Shell has extensive resources available to protect and rehabilitate wildlife in the event of a spill reaching the shoreline, as detailed in the OSRP.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on Whooping Cranes are expected.



### C.3.8 Gulf Sturgeon (Threatened)

The Gulf sturgeon ( Acipenser oxyrinchus desotoi ) is a threatened fish species that inhabits major rivers and inner shelf waters from the Mississippi River to the Suwannee River, Florida (Barkuloo, 1988; Wakeford, 2001). An anadromous fish that migrates from the sea upstream into coastal rivers to spawn in freshwater, it historically ranged from the Mississippi River to Charlotte Harbor, Florida (Wakeford, 2001). Today, this range has contracted to encompass major rivers and inner shelf waters from the Mississippi River to the Suwannee River, Florida. Populations have been depleted or even extirpated throughout this range by fishing, shoreline development, dam construction, water quality changes, and other factors (Barkuloo, 1988; Wakeford, 2001). These declines prompted the listing of the Gulf sturgeon as a threatened species in 1991. The best known populations occur in the Apalachicola and Suwannee Rivers in

### Florida (Carr, 1996; Sulak and Clugston, 1998), the Choctawhatchee River in Alabama (Fox et al.,

2000), and the Pearl River in Mississippi/Louisiana (Morrow et al., 1998). Critical habitat in the Gulf extends from Lake Borgne, Louisiana (St. Bernard Parish), to Suwannee Sound, Florida (Levy County) (NMFS, 2010d) ( Figure 1 ). A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the recovery plan for this species (USFWS and Gulf States Marine Fisheries Commission, 1995).

A large oil spill is the only IPF potentially affecting Gulf sturgeon. There are no IPFs associated with routine project activities that could affect this species. A small fuel spill in the lease area would be unlikely to affect Gulf sturgeon because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation in Section A.9.2 ).



### Impacts of a Large Oil Spill

Potential spill impacts on Gulf sturgeon are discussed in recent EISs (MMS, 2007b, 2008 ; BO EMRE, 2011; BOEM, 2012b) and by the NMFS (2007) in its Biological Opinion for the Five-Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. For this EP, there are no unique site-specific issues with respect to this species.

The lease area is about 1 15 miles (1 85 km) from the nearest Gulf sturgeon critical habitat. OSRA modeling ( Table 3 ) predicts that a spill in the lease area has a 1% probability of contacting the coastal areas inhabited by Gulf sturgeon within 30 days.

In the event of oil reaching Gulf sturgeon habitat, the fish could be affected by direct ingestion, ingestion of oiled prey, or the absorption of dissolved petroleum products through the gills. Based on the life history of this species, subadult and adult Gulf sturgeon would be most vulnerable to a marine oil spill, and would be vulnerable only during winter months (from September 1 through April 30) when this species is foraging in estuarine and marine habitats (NMFS, 2007).

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. Shell has extensive resources available to protect coastal and estuarine wildlife and habitats in the event of a spill reaching the shoreline, as detailed in the OSRP.

EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on Gulf sturgeon are expected.



### C.3.9 Beach Mice (Endangered)

Four subspecies of endangered beach mouse ( Peromyscus polionotus ) occur on the barrier islands of Alabama and the Florida Panhandle. They are the Alabama, Choctawhatchee, Perdido Key, and St. Andrew beach mouse. Critical habitat has been designated for all four subspecies; Figure 1 shows the critical habitat combined for all four subspecies. Species descriptions are provided in a recent lease sale EIS (MMS, 2007b).

A large oil spill is the only IPF potentially affecting subspecies of beach mouse. There are no IPFs associated with routine project activities that could affect these animals due to the distance from shore and the lack of onshore support activities near their habitat.

### Impacts of a Large Oil Spill

Potential spill impacts on beach mice are discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b). For this EP , there are no unique site-specific issues with respect to these species.

The lease area is about 1 53 miles (2 46 km) from the nearest beach mouse critical habitat. OSRA modeling predicts that a spill in the lease area would not contact beach mouse critical habitat within 30 days. In the event of oil contacting these beaches, beach mice could experience several types of direct and indirect impacts. Contact with spilled oil could cause skin and eye irritation and subsequent infection; matting of fur; irritation of sweat glands, ear tissues, and throat tissues; disruption of sight and hearing; asphyxiation from inhalation of fumes; and toxicity from ingestion of oil and contaminated food. Indirect impacts could include reduction of food supply, destruction of habitat, and fouling of nests. Impacts could also occur from vehicular traffic and other activities associated with spill cleanup.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blo wout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on beach mice are expected.



## C.4 Coastal and Marine Birds

C.4.1 Marine and Pelagic Birds

A variety of seabirds may occur in the pelagic environment of the project areas (Clapp et al., 1982a,b, 1983; Peake, 1996; Hess and Ribic, 2000). Seabirds spend much of their lives offshore over the open ocean, except during breeding season when they nest along the coast. In addition, other birds such as waterfowl, marsh birds, and shorebirds may occasionally be present over open ocean areas. No endangered or threatened bird species are likely to occur at the project area due to the distance from shore. For a discussion of shorebirds and coastal nesting birds, see Section C.4.2

.
Seabirds of the northern Gulf of Mexico were surveyed from ships during the GulfCet II program. Hess and Ribic (2000) reported that terns, storm-petrels, shearwaters, and jaegers were the most frequently sighted seabirds in the deepwater area. From these surveys, four ecological categories of seabirds were documented in the deepwater areas of the Gulf: summer migrants (shearwaters, storm petrels, boobies); summer residents that breed in the Gulf (Sooty Tern, Least Tern, Sandwich Tern, Magnificent Frigatebird); winter residents (gannets, gulls, jaegers); and permanent resident species (Laughing Gull, Royal Tern, Bridled Tern) (Hess and Ribic, 2000).

Common seabird species include Wilson’s Storm -Petrel ( Oceanites oceanicus ), Magnificent Frigatebird ( Fregata magnificens ), Northern Gannet ( Morus bassanus ), Masked Booby ( Sula dactylatra ), Brown Booby ( Sula leucogaster ), Cory’s Shearwater ( Calonectris diomedea ), Greater Shearwater ( Puffinus gravis ), and Audubon Shearwater ( Puffinus lherminieri ). Seabirds are distributed Gulf-wide and are not specifically associated with the lease area.

Relationships with hydrographic features were found for several seabird species, possibly due to effects of hydrography on nutrient levels and productivity of surface waters where birds forage.

### GulfCet II did not estimate bird densities; however, Powers (1987) indicates that seabird

densities over the open ocean typically are <10 birds/km 2



### .
Trans-Gulf migrant birds including shorebirds, wading birds, and terrestrial birds may also be present in the lease area. Migrant birds may use offshore structures and platforms for resting, feeding, or as temporary shelter from inclement weather (Russell, 2005). Some birds may be attracted to offshore structures because of the lights and the fish populations that aggregate
around these structures.

IPFs potentially affecting marine and pelagic birds include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents - a small fuel spill and a large oil spill. Effluent discharges are likely to have negligible impacts on the birds due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of these animals. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on birds.



### Impacts of Drilling Rig Presence, Noise, and Lights

Birds that frequent platforms may be exposed to contaminants including air pollutants and routine discharges, but significant impacts are unlikely due to rapid dispersion of effluents and air pollutants. Birds migrating over water have been known to strike offshore structures, resulting in death or injury (Wiese et al., 2001; Russell, 2005). Mortality of migrant birds at tall towers and other land-based structures has been reviewed extensively, and the mechanisms involved in platform collisions appear to be similar. In some cases, migrants simply do not see a part of the platform until it is too late. In other cases, navigation may be disrupted by noise (Russell, 2005). On the other hand, offshore structures are suitable stopover habitats for most trans-Gulf migrant species, and most of the migrants that stop over on platforms probably benefit from their stay, particularly in spring (Russell, 2005).

A study in the North Sea indicated that platform lighting causes circling behavior in various birds, especially on cloudy nights; a pparently the birds’ geomagnetic compass is upset by the red part of the spectrum from the lights currently in use (Poot et al., 2008). The numbers varied greatly, from none at all to some tens of thousands of birds per night per platform, with an apparent effect radius of up to 3 miles (5 km). A study in the Gulf of Mexico also noted the phenomenon, but did not recommend mitigation (Russell, 2005). Factors to consider in evaluating this impact in the Gulf of Mexico would include the lower incidence of cloudy and foggy days in the Gulf of Mexico versus the North Sea. Impacts on populations of either seabirds or trans-Gulf migrant birds may be adverse but are not expected to be significant (BOEM, 2012b).



### Impacts of Support Vessel and Helicopter Traffic

Support vessels and helicopters are unlikely to significantly disturb pelagic birds in open, offshore waters. It is likely that individual birds would experience, at most, only short-term behavioral disruption, and the impact would not be significant.



### Impacts of a Small Fuel Spill

Potential spill impacts on marine birds are discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b). For this EP , there are no unique site-specific issues with respect to spill impacts on these animals.

### The probability of a fuel spill will be minimized by Shell’s preventative measures during routine

operations including fuel transfer. In the unlikely event of a spill, implementation of
Shell’s OSRP will mitigate and reduce the potential for impacts on marine and pelagic birds.

EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally
within 24 hours. Th e area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

Birds exposed to oil on the sea surface could experience direct physical and physiological effects including skin irritation; chemical burns of skin, eyes, and mucous membranes; and inhalation of toxic fumes. Due to the limited areal extent and short duration of water quality impacts from a small fuel spill, secondary impacts due to ingestion of oil via contaminated prey or reductions in prey abundance are unlikely. Due to the low densities of birds in open ocean areas, the small area affected, and the brief duration of the surface slick, no significant impacts on marine and pelagic birds would be expected.



### Impacts of a Large Oil Spill

Potential spill impacts on marine and pelagic birds are discussed in recent EISs (MMS, 2007b,

2008 ; BOEMRE, 2011; BOEM, 2012b). For this EP , there are no unique site-specific issues with respect to spill impacts on these animals.

Pelagic seabirds could be exposed to oil from a spill at the project area. Hess and Ribic (2000) reported that terns, storm-petrels, shearwaters, and jaegers were the most frequently sighted seabirds in the deepwater Gulf of Mexico (>656 ft [>200 m]). Powers (1987) indicates that seabird densities over the open ocean typically are <10 birds/km 2 

### . The number of pelagic birds that could be affected in open, offshore waters would depend on the extent and persistence of
the oil slick.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on marine and pelagic birds are expected.



### C.4.2 Shorebirds and Coastal Nesting Birds

Threatened and endangered bird species (Piping Plover and Whooping Crane) have been discussed previously in Section C.3 . Various species of non-endangered birds are also found along the northern Gulf Coast, including diving birds, shorebirds, marsh birds, wading birds, and waterfowl. Gulf Coast marshes and beaches also provide important feeding grounds and nesting habitats. Species that breed on beaches, flats, dunes, bars, barrier islands, and similar habitats include the Sandwich Tern, Wilson’s Plover, Black Skimmer, Forster’s Tern, Gull -Billed

### Tern, Laughing Gull, Least Tern, and Royal Tern (USFWS, 2010b). Additional information is

presented in recent lease sale EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012b ).

The Brown Pelican ( Pelecanus occidentalis ) was delisted from federal endangered status in 2009 (USFWS, 2010c). However, this species is listed as a species of greatest conservation need by the State of Mississippi (Mississippi Department of Wildlife, Fisheries and Parks, 2011) and as a species of special concern by the State of Florida (Florida Fish and Wildlife Conservation Commission, 2011). Brown Pelicans inhabit coastal habitats and forage within both coastal waters and waters of the inner continental shelf. Aerial and shipboard surveys, including GulfCet and GulfCet II, indicate that Brown Pelicans do not occur over deep offshore waters (Fritts and Reynolds, 1981; Peake, 1996; Hess and Ribic, 2000). Nearly half the southeastern population of Brown Pelicans lives in the northern Gulf Coast, generally nesting on protected islands (USFWS, 2010b).

IPFs potentially affecting shorebirds and coastal nesting birds include support vessel and helicopter traffic and a large oil spill. Compliance with NTL 2012-BSEE-G01 will minimize the potential for marine debris-related impacts on shorebirds.



### Impacts of Support Vessel and Helicopter Traffic

Support vessels and helicopters will transit coastal areas near Port Fourchon and Boothville, Louisiana, where shorebirds and coastal nesting birds may be found. These activities could periodically disturb individuals or groups of birds within sensitive coastal habitats (e.g., wetlands that may support feeding, resting, or breeding birds).

Vessel traffic may disturb some foraging and resting birds. Flushing distances vary among species and individuals (Rodgers and Schwikert, 2002). The disturbances will be limited to flushing birds away from vessel pathways; known distances are from 65 to 160 ft (20 to 49 m) for personal watercraft and 75 to 190 ft (23 to 58 m) for outboard-powered boats (Rodgers and Schwikert, 2002). Flushing distances may be similar or less for the support vessels to be used for Shell’s project, and some species such as gulls are attracted to boats. Support vessels will not approach nesting or breeding areas on the shoreline, so nesting birds, eggs, and chicks will not be disturbed. Vessel operators will use designated navigation channels and comply with posted speed and wake restrictions while transiting sensitive inland waterways. Due to the limited scope, timing, and geographic extent of drilling activities, any short-term impacts are not expected to be biologically significant to coastal bird populations.

Aircraft traffic can cause some disturbance to birds onshore and offshore. Responses are highly dependent on the type of aircraft, the bird species, the activities that animals were previously engaged in, and previous exposures to overflights (Efroymson et al., 2000). Helicopters seem to cause the most intense responses over other human disturbances for some species (Bélanger and Bédard, 1989). However, Federal Aviation Administration Advisory Circular No. 91 -36D recommends that pilots maintain a minimum altitude of 2,000 ft (610 m) when flying over noise-sensitive areas such as wildlife refuges, parks, and areas with wilderness characteristics. This is greater than the distance (slant range) at which aircraft overflights have been reported to cause behavioral effects on most species of birds studied (Efroymson et al., 2000). With these guidelines in effect, it is likely that individual birds would experience, at most, only short-term behavioral disruption.

### Impacts of Large Oil Spill

The OSRA results summarized in Table 3 predict that shorelines of Texas and Louisiana that include habitat for shorebirds and coastal nesting birds could be affected within 30 days.

The Macondo spill provides additional information regarding impacts on species of coastal and shorebirds that may be affected in the event that a large oil spill reached coastal habitats. Although the Macondo spill had direct and indirect impacts to coastal and marine birds, it is premature to conclude impacts over a long period (BOEM, 2012b). Impacts to birds from the Macondo spill are being studied as part of the Natural Resource Damage Assessment, but results have not yet been released. Antonio et al. (2011) modeled bird mortality from the Macondo spill showing cumulative carcass numbers and mortality rate increasing exponentially from the start of the Macondo spill until the mortality rate began to decline after the 97th day of the spill. Note that the collected animals are a small subset of the total number of impacted birds; therefore, the y represent an underestimate of the overall impact of the Macondo spill (BOEM, 2012b).

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikel y event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on shorebirds and coastal nesting birds are expected.



## C.5 Fisheries Resources

C.5.1 Pelagic Communities and Ichthyoplankton

Biggs and Ressler (2000) reviewed the biology of pelagic communities in the deepwater environment of the northern Gulf of Mexico. The biological oceanography of the region is dominated by the influence of the Loop Current, whose surface waters are among the most oligotrophic in the world’s oceans. Superimposed on this low -productivity condition are productive “hot spots” associated with entrainment of nutrient -rich Mississippi River water and mesoscale oceanographic features. Anticyclonic and cyclonic hydrographic features play an important role in determining biogeographic patterns and controlling primary productivity in the northern Gulf of Mexico (Biggs and Ressler, 2000).

Most fishes inhabiting shelf or oceanic waters of the Gulf of Mexico have planktonic eggs and larvae (Ditty, 1986; Ditty et al., 1988; Richards et al., 1989, 1993). Pelagic eggs and larvae become part of the planktonic community for various lengths of time (10 to 100 days, depending on the species) (MMS, 2007b). A study by Ross et al. (2012) on mid-water fauna to characterize vertical distribution of mesopelagic fishes in selected deepwater areas in the Gulf of Mexico substantiated high species richness, but general domination by relatively few families and species.

IPFs potentially affecting pelagic communities and ichthyoplankton include drilling rig presence, noise, and lights; effluent discharges; water intakes; and two types of accidents -a small fuel spill and a large oil spill.

### Impacts of Drilling Rig Presence, Noise, and Lights

The drilling rig, as a floating structure in the deepwater environment, will act as a fish-attracting device (FAD). In oceanic waters, the FAD effect would be most pronounced for epipelagic fishes such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994). This FAD effect could possibly enhance the feeding of epipelagic predators by attracting and concentrating smaller fish species. Because the drilling rig is a single, temporary structure, impacts on fish populations, whether beneficial or adverse, are considered minor.



### Impacts of Effluent Discharges

Discharges of treated SBM cuttings will produce temporary, localized increases in suspended solids in the water column around the drilling rig. In general, turbid water can be expected to extend between a few hundred meters and several kilometers down current from the discharge point (NRC, 1983; Neff, 1987). NPDES permit limitations and requirements will be met.

Treated sanitary and domestic wastes may have a slight effect on the pelagic environment in the immediate vicinity of these discharges. These wastes may have elevated levels of nutrients, organic matter, and chlorine, but will be diluted rapidly to undetectable levels within tens to hundreds of meters from the source. Minimal impacts on water quality, plankton, and nekton are anticipated.

Deck drainage may have a slight effect on the pelagic environment in the immediate vicinity of these discharges. Deck drainage from contaminated areas will be passed through an oil and water separator prior to release, and discharges will be monitored for visible sheen. The discharges may have slightly elevated levels of hydrocarbons but will be diluted rapidly to undetectable levels within tens to hundreds of meters from the source. Minimal impacts on water quality, plankton, and nekton are anticipated.

Other discharges in accordance with the NPDES permit, such as desalination unit brine and uncontaminated cooling water, fire water, fracturing fluids, and ballast water, are expected to be diluted rapidly and have little or no impact on water column biota.



### Impacts of Water Intakes

Seawater will be drawn from several meters below the ocean surface for various services including firewater and once-through non-contact cooling of machinery on the drilling rig ( EP Table 7a ). Section 316(b) of the Clean Water Act requires NPDES permits to ensure that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available to minimize adverse environmental impact from impingement and entrainment of aquatic organisms. Construction of the rig planned for use in this EP, the Noble Jim Day , started prior to July 17, 2006, and therefore it is not subject to the cooling water intake permit requirements of NPDES Permit GMG290000 . If a different rig is selected, it will also comply with applicable NPDES requirements.



### Impacts of a Small Fuel Spill

Potential spill impacts on fisheries resources are discussed in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012a,b). For this EP , there are no unique site-specific issues with respect to spill impacts.

### The probability of a fuel spill will be minimized by Shell’s preventative measures during routine

operations including fuel transfer. In the unlikely event of a spill, implementation of
Shell’s OSRP will mitigate and reduce the potential for impacts on pelagic communities, including ichthyoplankton. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

A small fuel spill could have localized impacts on phytoplankton, zooplankton, ichthyoplankton, and nekton. Due to the limited areal extent and short duration of water quality impacts, a small fuel spill would be unlikely to produce detectable impacts on pelagic communities.



### Impacts of a Large Oil Spill

A large oil spill could affect water column biota including phytoplankton, zooplankton, ichthyoplankton, and nekton. A large spill that persisted for weeks or months would be more likely to affect these communities. While adult and juvenile fishes may actively avoid a large spill, planktonic eggs and larvae would be unable to avoid contact. Eggs and larvae of fishes in the upper layers of the water column are especially vulnerable to oiling; certain toxic fractions of spilled oil may be lethal to these life stages. Impacts would be potentially greater if local scale currents retained planktonic larval assemblages (and the floating oil slick) within the same

water mass.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on pelagic communities and ichthyoplankton are expected.



### C.5.2 Essential Fish Habitat

Essential Fish Habitat (EFH) is defined as those waters and substrate necessary to fish for spawning, breeding, feeding, and growth to maturity. Under the Magnuson-Stevens Fishery Conservation and Management Act, as amended, federal agencies are required to consult on activities that may adversely affect EFH designated in Fishery Management Plans developed by the regional Fishery Management Councils.

The Gulf of Mexico Fishery Management Council (GMFMC) has prepared Fishery Management Plans for corals and coral reefs, shrimps, stone crab, spiny lobster, reef fishes, coastal migratory pelagic fishes, and red drum. In 2005, the EFH for these managed species was redefined in Generic Amendment No. 3 to the various Fishery Management Plans (GMFMC, 2005). The EFH for most of these GMFMC-managed species is on the continental shelf in waters shallower than

60 0 ft (183 m). The shelf edge is the outer boundary for coastal migratory pelagic fishes, reef

### fishes, and shrimps. EFH for corals and coral reefs includes some shelf-edge topographic

features on the Texas-Louisiana OCS, the nearest of which is located 35 miles ( 57 km) northwest
of the lease area.

EFH has been identified in the deepwater Gulf of Mexico for highly migratory pelagic fishes, which occur as transients in the lease area. Species in this group, including tunas, swordfishes, billfishes, and sharks, are managed by NMFS. Highly migratory species with EFH at or near the lease area include the following (NMFS, 2009):

16. Atlantic bluefin tuna (spawning, eggs, larvae, adults)

17. Atlantic skipjack tuna (spawning, adults)

18. Atlantic yellowfin tuna (spawning, juveniles, adults)

19. Bigeye tuna (juveniles)

20. Atlantic swordfish (larvae, juveniles, adults) 21. Blue marlin (juveniles, adults)

22. White marlin (juveniles, adults)

23. Longbill spearfish (juveniles, adults)

24. Oceanic whitetip shark (all)

25. Shortfin mako shark (all)

26. Silky shark (all)

27. Longfin mako shark (all)

28. Bigeye thresher shark (all)

29. Whale shark (all)

Research indicates the central and western Gulf of Mexico may be important spawning habitat for Atlantic bluefin tuna, and NMFS (2009) has designated a Habitat Area of Particular Concern (HAPC) for this species. The HAPC covers much of the deepwater Gulf of Mexico, including the lease area ( Figure 1 ). The areal extent of the HAPC is approximately 15,000 mi 2 

### (300,000 km 2 

### ). The prevailing assumption is that Atlantic bluefin tuna follow an annual cycle of foraging in June through March off the eastern United States and Canadian coasts, followed by migration to the Gulf of Mexico to spawn in April, May, and June (NMFS, 2009).

Other HAPCs have been identified in the Gulf of Mexico by the GMFMC (2005). These include the Florida Middle Grounds, Madison-Swanson Marine Reserve, Tortugas North and South Ecological Reserves, Pulley Ridge, and several individual reefs and banks of the northwestern Gulf of Mexico ( Figure 1 ). The nearest of these is Jakkula Bank, located 147 miles (236 km) west
of the lease area.

Routine IPFs potentially affecting EFH and fisheries resources include drilling rig presence, noise, and lights; effluent discharges; and water intakes. In addition, two types of accidents

– a small fuel spill and a large oil spill may potentially affect EFH and fisheries resources.



### Impacts of Drilling Rig Presence, Noise, and Lights

The drilling rig, as a floating structure in the deepwater environment, will act as an FAD. In oceanic waters, the FAD effect would be most pronounced for epipelagic fishes such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994). This FAD effect would possibly enhance feeding of epipelagic predators by attracting and concentrating smaller fish species. Any impacts on EFH for highly migratory pelagic fishes are considered minor.

### Impacts of Effluent Discharges

Other effluent discharges affecting EFH by diminishing ambient water quality include drilling mud and cuttings, treated sanitary and domestic wastes, deck drainage, and miscellaneous discharges such as desalination unit brine and uncontaminated cooling water, fire water, fracturing fluids, and ballast water. Impacts on water quality have been discussed previously. No significant impacts on EFH for highly migratory pelagic fishes are expected from these discharges.



### Impacts of Water Intakes

As noted previously, cooling water intake will cause entrainment and impingement of plankton, including fish eggs and larvae (ichthyoplankton). Due to the limited scope, timing, and geographic extent of drilling activities, any short-term impacts on EFH for highly migratory pelagic fishes are not expected to be biologically significant.



### Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by Shell’s preventative measur es during routine operations including fuel transfer. In the unlikely event of a spill, implementation of
Shell’s OSRP will mitigate and reduce the potential for impacts on EFH. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

Potential spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012a,b). For this EP, there are no unique site-specific issues with respect to spill impacts.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions.

A small fuel spill could have localized impacts on EFH for highly migratory pelagic fishes, including tunas, swordfishes, billfishes, and sharks. These species occur as transients in the lease area. A spill would also produce short-term impact on water quality in the HAPC for spawning Atlantic bluefin tuna, which covers much of the deepwater Gulf of Mexico. The affected area would represent a negligible portion of the HAPC, which covers 114,793 mi2 (297,312 km2) of the Gulf of Mexico.

A small fuel spill would not affect EFH for corals and coral reefs; the nearest coral EFH is Sackett Bank, located 35 miles (57 km) northwest of the lease area. A small fuel spill would float and dissipate on the sea surface and would not contact these features.



### Impacts of a Large Oil Spill

Potential spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012a,b). For this EP , there are no unique site-specific issues with respect to EFH.

### An oil spill in offshore waters would temporarily increase hydrocarbon concentrations on the

water surface and potentially the subsurface as well. Given the extent of EFH designations in the Gulf of Mexico (GMFMC, 2005; NMFS, 2009), some impact on EFH would be unavoidable.

A large spill could affect the EFH for many managed species including shrimps, stone crab, spiny lobster, corals and coral reefs, reef fishes, coastal migratory pelagic fishes, red drum, and highly migratory pelagic fishes. It would result in adverse impacts on water quality and water column biota including phytoplankton, zooplankton, ichthyoplankton, and nekton. In coastal waters, sediments could be contaminated and result in persistent degradation of the seafloor habitat for managed demersal fish and invertebrates.

The lease area is within the HAPC for spawning Atlantic bluefin tuna (NMFS, 2009). A large spill could temporarily degrade the HAPC due to increased hydrocarbon concentrations in the water column, with the potential for lethal or sublethal impacts on spawning tuna and their offspring. Potential impacts would depend in part on the timing of a spill, as this species migrates to the Gulf of Mexico to spawn in April, May, and June (NMFS, 2009).

The nearest feature designated as EFH for corals is located 35 miles (57 km) northwest of the lease area. An accidental spill would be unlikely to reach or affect this feature. Near-bottom currents in the region are expected to flow along the isobaths (Nowlin et al., 2001) and typically would not carry a plume up onto the continental shelf edge.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on EFH are expected.



## C.6 Archaeological Resources

C.6.1 Shipwreck Sites

MC 720, 721, and 722 are on the list of archaeological survey blocks (BOEM, 2012c). The archaeological survey conducted by C&C Technologies (20 09 ) detected unidentified sonar targets within the survey areas that were classified as modern debris and are not recommended for investigation or avoidance of the basis of archaeological potential.

Be cause there are no historic shipwreck sites in the lease area (see EP Section 6 ), there are no routine IPFs that are likely to affect these resources. A small fuel spill would not affect shipwrecks in adjoining blocks because the oil would float and dissipate on the sea surface. The impact of a large oil spill that could contact shipwrecks in other areas is considered below a level
of concern.



### Impacts of a Large Oil Spill

There are no known historic shipwrecks in the lease area and a large oil spill would not result in any impact on archaeological resources. A spill entering shallow coastal waters could conceivably contaminate an undiscovered or known historic shipwreck site. The OSRA modeling
summarized in Table 3 predicts that Texas, Louisiana, and Florida shorelines could be contacted by a spill within 10 to 30 days.

### Previous analyses (MMS, 2007a, 2008) concluded that oil spills would be unlikely to affect

archaeological sites beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface plumes were reported at a water depth of about 3,600 ft (1,100 m), extending at least 22 miles (35 km) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could contact shipwreck sites beyond the 984-ft (300-m) radius estimated by MMS (2007a, 2008), depending on its extent, trajectory, and persistence.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on historic shipwrecks are expected. Also as noted by MMS (2007b), should an oil spill contact a coastal historic site, such as a fort or a lighthouse, the major impac t would be a temporary, reversible visual impact from oil contact and contamination of the site and its environment. However, more recent studies suggest that the impacts could be longer term and not easily reversible (BOEM, 2012b).



### C.6.2 Prehistoric Archaeological Sites

With water depths ranging from approximately 3,125 to 3,747 ft (953 to 1,142 m), the wellsites are well beyond the 197-ft (60-m) depth contour used by the BOEM as the seaward extent for prehistoric archaeological site potential in the Gulf of Mexico. Because prehistoric archaeological sites are not found in the lease area, the only relevant IPF is a large oil spill that would reach coastal waters within the 197-ft (60- m) depth contour.



### Impacts of a Large Oil Spill

Because prehistoric archaeological sites are not found in the lease area, they would not be affected by the physical effects of a subsea blowout. The MMS (2007b) estimates that a severe subsurface blowout could resuspend and disperse sediments within a 984-ft (300-m) radius.

Along the northern Gulf Coast, prehistoric sites occur frequently along the barrier islands and mainland coast and along the margins of bays and bayous (MMS, 2007b). The OSRA modeling
summarized in Table 3 predicts that Texas, Louisiana, and Florida shorelines could be contacted by a spill within 10 to 30 days. A spill reaching a prehistoric site along these shorelines could coat fragile artifacts or site features and compromise the potential for radiocarbon dating organic materials in a site (although other dating methods are available and it is possible to decontaminate an oiled sample for radiocarbon dating). Coastal prehistoric sites could also be damaged by spill cleanup operations (e.g., by destroying fragile artifacts and disturbing the provenance of artifacts and site features).

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention me asures as detailed in

EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on archaeological resources are expected.

## C.7 Coastal Habitats and Protected Areas

Coastal habitats in the northern Gulf of Mexico that may be affected by oil and gas activities are described in recent EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012a,b,d) and in a literature review by Collard and Way (1997). Sensitive coastal habitats are also tabulated in the OSRP. Coastal habitats inshore of the project area include barrier beaches and dunes, wetlands, and submerged seagrass beds. Generally, most of the northern Gulf is fringed by barrier beaches, with wetlands and/or submerged seagrass beds occurring in sheltered areas behind
the barrier islands and in estuaries.

Due to the distance from shore, there are no IPFs associated with routine activities that are likely to affect beaches and dunes, wetlands, seagrass beds, coastal wildlife refuges, wilderness areas, or any other managed or protected coastal area. The support bases at Port Fourchon and Boothville are not located in a wildlife refuge or a wilderness area. Potential impacts of support vessel traffic are briefly addressed below.

A small fuel spill in the lease area would be unlikely to affect coastal habitats because it would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation

in Section A.9.2 ).



### Impacts of Support Vessel Traffic

For OCS activities in general, support operations, including the crew boat and supply boats, may have a minor incremental impact on coastal habitats. Over time with a large number of vessel trips, vessel wakes can erode shorelines along inlets, channels, and harbors. Support operations, including the crew boat and supply boats as detailed in EP Section 14 , may have a minor incremental impact on coastal habitats or protected areas. Impacts will be minimized by following the speed and wake restrictions in harbors and channels.



### Impacts of a Large Oil Spill

Potential spill impacts on coastal habitats are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012a,b,d ). Coastal habitats inshore of the project area include barrier beaches and dunes, wetlands, and submerged seagrass beds. For this EP , there are no unique site-specific issues with respect to coastal habitats.

The OSRA results summarized in Table 3 predict that shorelines of Texas, Louisiana, and Florida could be affected within 30 days. Plaquemines Parish, Louisiana, has the highest probability of contact for the 10- and 30-day intervals (4% and 8%, respectively). After 30 days, 11 counties or parishes may be contacted from Galveston, Texas, to Okaloosa, Florida.

The shorelines within the geographic range predicted by the OSRA modeling include extensive barrier beaches and wetlands, with submerged seagrass beds occurring in sheltered areas behind the barrier islands and in estuaries. NWRs and other protected areas along the coast are discussed in the lease sale EIS (MMS, 2007b) and Shell’s OSRP. Coastal wildlife refuges, wilderness areas, and state and national parks within the geographic range of the potential shoreline contacts after 30 days include the following:

### 30. Brazoria NWR

31. Galveston Island State Park ( SP )

32. Apffel Park

33. Seawolf Park

34. Old Fort Travis Park

35. Atkinson Island Wildlife Management Area (WMA)

36. F or t Anah ua c Park

37. Anahuac NWR

38. McFaddin NWR

39. Candy Abshier WMA

40. Atkinson Island WMA

41. Sea Rim SP

42. Murphree WMA

43. Texas Point NWR

44. Sabine NWR

45. Cameron Prairie NWR

46. Lacassine NWR

47. Little Pecan Island Natural Area ( NA )

48. Peveto Woods NA

49. Lower Neches WMA

50. Rockefeller WMA

51. Paul J. Rainey WMA

52. Marsh Island WMA

53. Cypremort Point SP

54. Shell Keys NWR

55. Atchafalaya Delta WMA

56. Mandalay NWR

57. Isles Dernieres Barrier Islands Refuge

58. Pointe au Ch ie n WMA

59. Wisner WMA

60. Grand Isle SP

61. Salvador WMA

62. Jean Lafitte National Historical Park
and Preserve

63. Lafitte Woods NA

64. Delta NWR

65. Pass A Loutre WMA

66. Breton NWR

67. St. Bernard SP

68. Biloxi WMA

69. Bayou Sauvage NWR

70. Gulf Islands National Seashore

71. Pensacola Bay Service Water and Impoundment Monitoring (SWIM) Area

72. Choctawhatchee Bay SWIM Area

### The OSRA results in Table 3 include only shoreline segments with contact probabilities greater than

0.5% within 30 days; other coastal areas could be affected at lower contact probabilities within

30 days, or from a spill persisting for more than 30 days. Additional NWRs and managed wildlife areas occur along the Gulf Coast. These areas include habitats such as barrier beach and dune systems, wetlands, and submerged seagrass beds that support diverse wildlife, including endangered or threatened species.

The level of impacts from oil spills on coastal habitats depends on many factors, including the oil characteristics, the geographic location of the landfall, and the weather and oceanographic conditions at the time (MMS, 2007b). Oil that makes it to beaches may be either liquid weathered oil, an oil-and-water mousse, or tarballs (MMS, 2007b). Oil is generally deposited on beaches in lines defined by wave action at the time of landfall. Oil that remains on the beach will thicken as its volatile components are lost. Thickened oil may form tarballs or aggregations that incorporate sand, shell, and other materials into its mass. Tar may be buried to varying depths under the sand. On warm days, both exposed and buried tarballs may liquefy and ooze. Oozing may also serve to expand the size of a mass as it incorporates beach materials. Oil on beaches may be cleaned up manually, mechanically, or both. Some oil can remain on the beach at varying depths and may persist for several years as it slowly biodegrades and volatilizes.

Coastal wetlands are highly sensitive to oiling and can be significantly impacted because of the inherent toxicity of hydrocarbon and non-hydrocarbon components of the spilled substances (Mendelssohn, 2012). The MMS (2007b) predicted that for every 50 bbl of oil contacting wetlands, approximately 6.7 ac (2.7 ha) of wetland vegetation will experience dieback. Thirty percent of these damaged wetlands are assumed to recover within 4 years, and 85% within 10 years. About 15% of the contacted wetlands are expected to be converted permanently to open-water habitat. The critical concentration of oil is that concentration above which impacts to wetlands will be long-term and recovery will take longer than two growing seasons, and which causes plant mortality and some permanent wetland loss. Critical concentrations of various oils are expected to vary broadly for wetland types and wetland plant species. Louisiana wetlands are assumed to be more sensitive to oil contact than elsewhere in the Gulf because of high cumulative stress (MMS, 2007b). In addition to the direct impacts of oil, cleanup activities in marshes may accelerate rates of erosion and retard recovery rates (MMS, 2007b).

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on coastal habitats are expected.



## C.8 Socioeconomic and Other Resources

C.8.1 Recreational and Commercial Fishing

The main commercial fishing activity in deep waters of the northern Gulf of Mexico is pelagic longlining for tunas, swordfishes, and other billfishes (Continental Shelf Associates, Inc., 2002). Pelagic longlining has occurred historically in the project area, primarily during spring and summer.

It is unlikely that any commercial fishing activity other than longlining occurs at or near the project area. Benthic species targeted by commercial fishers occur on the upper continental slope, well inshore of the project area. Royal red shrimp ( Pleoticus robustus ) are caught by trawlers in water depths of about 820 to 1,804 ft (250 to 550 m). Tilefishes (primarily Lophalotilus chamaeleonticeps )

### are caught by bottom longlining in water depths from about 540 to 1,476 ft (165 to 450 m)

(Continental Shelf Associates, Inc., 2002). The proposed project is in 3,125 to 3,747 ft (953 to 1,142 m) of water. No conflict with commercial fishing activity is expected to occur.

Most recreational fishing activity in the region occurs in water depths less than 656 ft (200 m) (Continental Shelf Associates, Inc., 1997, 2002). In deeper water, the main attraction to recreational fishers would be petroleum platforms in offshore waters of Texas and Louisiana.

The only routine IPF potentially affecting fisheries is drilling rig presence (including noise and lights). Two types of potential accidents are also addressed below

– a small fuel spill and a large oil spill.



### Impacts of Drilling Rig Presence

There is a slight possibility of pelagic longlines becoming entangled in the drilling rig. For example, in January 1999 a portion of a pelagic longline snagged on the acoustic Doppler current profiler of a drillship working in the Gulf of Mexico (Continental Shelf Associates, Inc., 2002). The line was removed without incident. Generally, longline fishers use radar and are aware of offshore structures and ships when placing their sets. Therefore, little or no impact on pelagic longlining is expected.

No adverse impacts on fishing activities are anticipated. Other factors such as effluent discharges are likely to have negligible impacts on commercial or recreational fisheries due to rapid dispersion, the small area of ocean affected, and the intermittent nature of the discharges.



### Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by Shell’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the potential for impacts. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

Pelagic longlining activities in the lease area, if any, could be interrupted in the event of a small fuel spill. The area of the sea surface with diesel fuel on it would range from 1.2 to 12 ac (0.5 to 5 ha), depending on sea state and weather conditions. Fishing activities could be interrupted due to the activities of response vessels operating in the lease area. A small fuel spill would not affect coastal water quality because the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill

Potential spill impacts on fishing activities are discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b,d). For this EP , there are no unique site-specific issues with respect to this activity.

Pelagic longlining activities in the lease area and other fishing activities in the northern Gulf of Mexico could be interrupted in the event of a large oil spill. A spill may or may not result in fishery closures, depending on the duration of the spill, the oceanographic and meteorological conditions at the time, and the effectiveness of spill response measures. A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on fishing activities are expected.

### C.8.2 Public Health and Safety

There are no IPFs associated with routine operations that are expected to affect public health and safety. Impacts of a small fuel spill and a large oil spill are addressed below.



### Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by Shell’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the potential for impacts. EP Section 9b provides detail on spill response

measures.

A small fuel spill would not have impacts on public health and safety because it would likely affect only a small area of the open ocean 49 miles ( 79 km) from the nearest shoreline and nearly all of the diesel fuel would evaporate or disperse naturally within 24 hours. Response crews would be equipped with appropriate safety equipment to avoid injury and health effects. A small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see

Section A.9.2 ).



### Impacts of a Large Oil Spill

In the event of a large spill from a blowout, the main safety and health concerns are those of the offshore personnel involved in the incident and those responding to the spill. The proposed activities will be covered by the OSRP, and, in addition, the drilling rig maintains a Shipboard Oil Pollution Emergency Plan as required under MARPOL 73/78.

Depending on the spill rate and duration, the physical/chemical characteristics of the oil, the meteorological and oceanographic conditions at the time, and the effectiveness of spill response measures, the public could be exposed to oil on the water and along the shoreline, through skin contact or inhalation of VOCs. Crude oil is a highly flammable material, and any smoke or vapors from a crude oil fire can cause irritation. Exposure to large quantities of crude oil may pose a health
hazard.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on public health and safety are expected.



### C.8.3 Employment and Infrastructure

There are no IPFs associated with routine operations that are expected to affect employment and infrastructure. The project involves drilling with support from existing shorebased facilities in Louisiana. No new or expanded facilities will be constructed, and no new employees are expected to move permanently into the area. The project will have a negligible impact on socioeconomic conditions such as local employment, existing offshore and coastal infrastructure (including major sources of supplies, services, energy, and water), and minority and lower income groups. Impacts of a small fuel spill and a large oil spill are addressed below.



### Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by Shell’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the potential for impacts. EP Section 9b provides detail on spill response

### measures. Given the open ocean location of the lease area, the duration of a small spill and

opportunity for impacts to occur would be very brief.

A small fuel spill that is dissipated within a few days would have little or no economic impact, as the spill response would use existing facilities, resources, and personnel.



### Impacts of a Large Oil Spill

Potential socioeconomic impacts of an oil spill are discussed in recent EISs (MMS, 2007b, 2008; BOEM, 2012b,d). For this EP, there are no unique site-specific issues with respect to employment and coastal infrastructure. A large spill could cause several types of economic impacts: extensive fishery closures could put fishermen out of work; temporary employment could increase as part of the response effort; adverse publicity could reduce employment in coastal recreation and tourism industries; and OCS drilling activities, including service and support operations that are an important part of local economies, could be suspended.

The lease area is 49 miles (79 km) from the nearest shoreline. Based on the OSRA modeling predictions ( Table 3 ), Plaquemines Parish, Louisiana, is the coastal area most likely to be affected.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on employment and infrastructure are expected.



### C.8.4 Recreation and Tourism

There are no known recreational uses of the lease area. Recreational resources and tourism in coastal areas would not be affected by routine activities due to the distance from shore. Compliance with NTL 2012-BSEE-G01 will minimize the chance of trash or debris being lost overboard from the drilling rig and subsequently washing up on beaches.



### Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by Shell’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the potential for impacts. EP Section 9b provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in the lease area would be unlikely to affect recreation and tourism. There are no known recreational or tourism activities occurring in the lease area, and as explained in
Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up.



### Impacts of a Large Oil Spill

Potential impacts of an oil spill on recreation and tourism are discussed in recent EISs (MMS, 2007b, 2008; BOEM, 2012b). For this EP , there are no unique site-specific issues with respect to these impacts.

Impacts on recreation and tourism would vary depending on the duration of the spill and its fate including the effectiveness of response measures. A large spill that reached coastal waters and shorelines could adversely affect recreation and tourism by contaminating beaches and wetlands,

### resulting in negative publicity that encourages people to stay away. Based on OSRA modeling as

summarized in Table 3 , Plaquemines Parish, Louisiana, is the area most likely to be contacted by a spill. However, shorelines from Galveston, Texas, to Okaloosa, Florida, could be contacted. These areas include popular beaches and recreational sites along the coast.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on recreation and tourism are expected.



### C.8.5 Land Use

Land use along the northern Gulf Coast is discussed in recent lease sale EISs (MMS, 2007b, 2008; BOEM, 2012b,d). There are no routine IPFs potentially affecting land use. The project will use existing onshore support facilities in Louisiana. The land use at the existing shorebase sites is industrial. The project will not involve new construction or changes to existing land use and, therefore, will not have any impacts. Levels of boat and helicopter traffic, as well as demand for goods and services including scarce coastal resources, will represent a small fraction of the level of activity occurring at the shorebases.

A large oil spill is the only relevant accident IPF. A small fuel spill would not have impacts on land use, as the response would be staged out of existing shorebases and facilities.



### Impacts of a Large Oil Spill

The initial response for a large oil spill would be staged out of existing facilities, with no effect on land use. A large spill could have limited temporary impacts on land use along the coast if additional staging areas were needed. For example, during the Macondo spill, 25 temporary staging areas were established in Louisiana, Mississippi, Alabama, and Florida for spill response and cleanup efforts (BOEM, 2012b). In the event of a large spill in the lease area, similar temporary staging areas could be needed. These areas would eventually return to their original use as the response is demobilized.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j

. In the unlikely event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on land use are expected.



### C.8.6 Other Marine Uses

The lease area is not located within any USCG-designated fairway or shipping lane. MC 720, 721, and 722 are not in a designated Military Warning Area. Shell will comply with BOEM requirements and lease stipulations to avoid impacts on uses of the area by military vessels and aircraft.

The archaeological survey conducted by C&C Technologies (2009) detected unidentified sonar targets within the survey areas that were classified as modern debris or possibly barrels. Shell’s procedure “Waste Barrel Avoidance and Release Response in the Mississippi Canyon Area,” which has been previously approved by MMS and BOEM applies to operations that could cause a disturbance of a
seafloor barrel. Shell’s over‐arching policy is to avoid barrel contact. In the unlikely case that contact is suspected or has been made with any wastes from a barrel, the plan specifies actions to be taken for the topside safety of personnel handling the equipment. The plan also outlines barrel impact reporting procedures.

### There are no IPFs from routine project activities that are likely to affect shipping or other marine

uses. A large oil spill is the only relevant accident IPF. A small fuel spill would not have impacts on other marine uses, as the spill and response activities would be mainly within the lease area and the
duration would be brief.



### Impacts of a Large Oil Spill

An accidental spill would be unlikely to significantly affect shipping or other marine uses. The block is not located within any USCG-designated fairway or shipping lane. In the event of a large spill requiring numerous response vessels, coordination would be required to manage the vessel traffic for safe operations. Shell will comply with BOEM requirements and lease stipulations to avoid impacts on uses of the area by military vessels and aircraft.

A blowout resulting in a large oil spill is an extremely rare event, and the probability of such an event will be minimized by Shell’s well control and blowout prevention measures as detailed in EP Section 2j . In the unlikel y event of a spill, implementation of Shell’s OSRP will mitigate and reduce the impacts. EP Section 9b provides detail on spill response measures. Therefore, no significant spill impacts on other marine uses are expected.



## C.9 Cumulative Impacts

For purpo ses of NEPA, cumulative impact is defined as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-feder al ) or person undertakes such other actions” (40 CFR 1508.7). Any single activity or action may have a negligible impact(s) by itself, but when combined with impacts from other activities in the same area and/or time period, substantial impacts may result.

Prior Studies . Prior to the lease sales, MMS prepared a multisale EIS in which it analyzed the environmental impact of activities that might occur in the multi-lease-sale area. The MMS also recently analyzed the cumulative impacts of OCS development activities similar to those planned in
this EP in several documents. The level and types of activities planned in Shell's EP are within the range of activities described and evaluated in the Final EIS for Gulf of Mexico OCS Oil and Gas Lease Sales 2007-2012: Western Planning Area Sales 204, 207, 210, 215, and 218, and Central Planning Area Sales 205, 206, 208, 213, 216, and 222 (MMS, 2007b), as updated by a 2012 Final Supplemental EIS
for Gulf of Mexico OCS Oil and Gas Lease Sales 2012-2017 : Western Planning Area Lease Sales 229, 233, 246, and 248 and Central Planning Area Lease Sales 227, 231, 235, 241 and 247 (BOEM, 2012b). Past, present, and reasonably foreseeable activities were identified in the cumulative effects scenario of these documents, which are incorporated by reference. The proposed action will not result in any additional impacts beyond those evaluated in the Multisale and Final EISs (MMS, 2007b; BOEM, 2012b).

Description of Activities Reasonably Expected to Occur in the Vicinity of Project Area . Other exploration and development activities may occur in the vicinity of lease blocks MC 720, 721, and 722. Shell does not anticipate other projects in the vicinity of the project area beyond the types of projects analyzed in the Multisale and Supplemental EIS (MMS, 2007b, 2008; BOEMRE, 2011; BOEM,
2012b ).

Cumulative Impacts of Activities in the EP . The MMS (2007b) multi-lease-sale EIS and BOEM (2012b) Final EIS included a lengthy discussion of cumulative impacts, which analyzed the environmental and socioeconomic impacts from the incremental impact of the 11 proposed lease sales, in addition to all activities (including non-OCS activities) projected to occur from past, proposed, and future lease sales during the 40-year period of 2007 to 2046 (see MMS, 2007b; BOEM, 2012b). The EIS considered

### exploration, delineation, and development wells; platform installation; service-vessel trips; and oil

spills. The EIS examined the potential cumulative effects on each specific resource for the entire Gulf
of Mexico.

The level and type of activity proposed in Shell’s EP are within the range of activities described and evaluated in the recent multi-lease-sale EISs. This EIA incorporates and builds on these analyses by examining the potential impacts on physical, biological, and socioeconomic resources from the work planned in this EP, in conjunction with the other reasonably foreseeable activities expected to occur in the Gulf of Mexico. Thus, for all impacts, the incremental contribution of Shel l’s proposed actions to the cumulative impacts analysis in these prior analyses is not significant.



### C.9.1 Cumulative Impacts to Physical/Chemical Resources

The work planned in this EP is limited in geographic scope and duration, and the impacts on the physical/chemical environment will be correspondingly limited.

Air Quality

. Emissions from pollutants into the atmosphere from activities are not projected to have significant effects on onshore air quality because of the prevailing atmospheric conditions, emission rates and heights, and resulting pollutant concentrations. As the BOEM found in the multi-lease-sale EISs, the incremental contribution of activities similar to Shell’s proposed activities to the cumulative impacts is not significant and will not cause or contribute to a violation of national ambient air quality standard (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b). In addition, the cumulative contribution to visibility impairment is also very small (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b). Since the BOEM completed the multi-lease-sale EISs, the USEPA has adopted a new short-term NAAQS for nitrogen dioxide (NO 2 

### ) and sulfur dioxide (SO 2 

### ). As mentioned in previous sections, projected emissions meet the BOEM exemption criteria and would not contribute to cumulative impacts on air quality.

Climate Change . Carbon dioxide (CO 2 

### ) and CH 4 

### emissions from the project would constitute a small incremental contribution to greenhouse gas emissions from all OCS activities. According to the EIS (MMS, 2007a), estimated CO 2 

### emissions from all OCS activities in the 2007-2012 leasing program are about 0.08% to 0.016% of the global CO 2 

### emissions from fossil fuel combustion. Greenhouse gas emissions may contribute to climate change, with important effects on temperature, rainfall, frequency of severe weather, ocean acidification, and sea level rise (Intergovernmental Panel on Climate Change, 2007). In the Gulf of Mexico, sea level rise is an important issue due to the ongoing losses in coastal wetlands, particularly in coastal Louisiana. Greenhouse gas emissions from the EP represent a negligible contribution to the total greenhouse gas emissions from reasonably foreseeable activities in the Gulf of Mexico area and would not significantly alter any of the climate change impacts evaluated in the previous EISs. Globally, Shell is working to reduce greenhouse gas emissions by increasing the efficiency of its operations, establishing a substantial capability in CO 2 

### capture and storage, and continuing to research and develop technologies that increase efficiency and reduce emissions in hydrocarbon production. In 2010, Shell met a voluntary target set in 1998 for direct greenhouse gas emissions from its facilities to be at least 5% lower than the comparable 1990 level (Shell, 2011). Shell’s ongoing efforts to reduce greenhouse gas emission s should offset any incremental contribution from the EP.

Water Quality . Shell’s project will result in some minor water quality impacts due to the NPDES-permitted discharge of SBM cuttings, treated sanitary and domestic wastes, excess cement, non-contact cooling water, deck drainage, desalination unit brine, uncontaminated fire water and ballast water. These effects are expected to be minor (localized to the area within a few hundred meters of the drilling rig), and temporary (lasting only hours longer than the disturbance or discharge). Any cumulative effects to water quality are expected to be negligible.

### Archaeological Resources . MC 720, 721, and 722 are on the list of archaeology survey blocks (BOEM,

2012c). No shipwrecks were detected in the surveys conducted by C&C Technologies, Inc. (2009) and GEMS (2010). There are three marine avoidance zones identified in the vicinity of well location F in

MC 720.

New Information . New information included in the most recent Supplemental and Final EISs (BOEMRE, 2011; BOEM, 2012b) has been incorporated into the EIA, where applicable.



### C.9.2 Cumulative Impacts to Biological Resources

The work planned in this EP is limited in geographic scope and duration, and the impacts on biological resources will be correspondingly limited.

Seafloor Habitats and Biota . Effects on seafloor habitats and biota from discharges of drilling mud and cuttings are expected to be minor and limited to a small area. Areas that may support high-density deepwater benthic communities will be avoided as required by NTL 2009-G40. Soft bottom communities are ubiquitous along the northern Gulf of Mexico continental slope, and theextent of benthic impacts during this project is insignificant regionally. As noted in the multi-leasesale EISs, t he incremental contributions of activities similar to Shell’s proposed activities to the cumulative impacts is not significant (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012b ).

Threatened, Endangered, and Protected Species . Threatened and endangered species reasonably likely to occur in the lease area include the sperm whale and five species of sea turtles. Potential impact sources include drilling rig presence including noise and lights; marine debris; and support vessel and aircraft traffic. Potential effects for these species would be limited and temporary, and would be reduced by Shell’s compliance with BOEM -required mitigation measures including NTLs 2012-BSEE-G01 and 2012-JOINT-G01. No significant cumulative impacts are expected.

Coastal and Marine Birds . Birds may be exposed to contaminants including air pollutants and routine discharges, but significant impacts are unlikely due to rapid dispersion. Shell’s c ompliance with NTL 2012-BSEE-G01 will minimize the likelihood of debris-related impacts on birds. Support vessel and helicopter traffic may disturb some foraging and resting birds; however, it is likely that individual birds would experience, at most, only short-term behavioral disruption.

Due to the limited scope, timing, and geographic extent of drilling activities, collisions or other adverse effects are unlikely, and no significant cumulative impacts are expected.

Fisheries Resources . Exploration and production structures occur in the MC lease blocks proposed for the drilling activities. The additional effect of the proposed drilling activity would be negligible.

Coastal Habitats . Due to the distance of the wellsites from shore, routine activities are not expected to have any impacts on beaches and dunes, wetlands, seagrass beds, coastal wildlife refuges, wilderness areas, or any other managed or protected coastal area. The support bases at Port Fourchon and Boothville are not in wildlife refuge or wilderness areas. Support operations, including the crew boat and supply boats, may have a minor incremental impact on coastal habitats. Over time with a large number of vessel trips, vessel wakes can erode shorelines along inlets, channels, and harbors. Impacts will be minimized by following the speed and wake restrictions in
harbors and channels.

New Information . New information included in the most recent Supplemental and Final EISs (BOEMRE, 2011; BOEM, 2012b) has been incorporated into the EIA, where applicable.

### C.9.3 Cumulative Impacts to Socioeconomic Resources

The work planned in this EP is limited in geographic scope and duration, and the impacts on socioeconomic resources will be correspondingly limited.

The multi-lease-sale and supplemental and final EISs analyzed the cumulative impacts of oil and gas exploration and development in the lease area, in combination with other impact-producing activities, on commercial fishing, recreational fishing, recreational resources, historical and archaeological resources, land use and coastal infrastructure, demographics, and environmental justice (MMS, 2007b; BOEMRE, 2011; BOEM, 2012b). The BOEM also analyzed the economic impact of oil and gas activities on the Gulf states, finding only minor impacts in most of Texas, Mississippi, Alabama, and Florida, more significant impacts in parts of Texas, and substantial impacts on

Louisiana.

Shell’s proposed activities will have negligible cumulative impacts on socioeconomic resources. There are no IPFs associated with routine operations that are expected to affect public health and safety, employment and infrastructure, recreation and tourism, land use, or other marine uses. Due to the distance from shore, it is unlikely that any recreational fishing activity is occurring in the project area, and it is unlikely that any commercial fishing activity other than longlining occurs at or near the project area. The project will have negligible impacts on fishing activities.

New Information . New information included in the most recent Supplemental and Final EISs (BOEMRE, 2011; BOEM, 2012b) has been incorporated into the EIA, where applicable.



# D. Environmental Hazards

D.1 Geologic Hazards

The archaeological and geophysical surveys concluded that the project areas are suitable for the proposed activities (C&C Technologies, Inc., 2009; GEMS, 2010). See EP Section 6a for supporting geological and geophysical information.



## D.2 Severe Weather

Under most circumstances, weather is not expected to have any effect on the proposed activities. Extreme weather, including high winds, strong currents, and large waves, was considered in the design criteria for the drilling rig. High winds and limited visibility during a severe storm could disrupt communication and support activities (vessel and helicopter traffic) and make it necessary to suspend some activities on the drilling rig for safety reasons until the storm or weather event passes. In the event of a hurricane, procedures in Shell’s Hurricane Evacuation Plan would be followed.



## D.3 Currents and Waves

A rig-based acoustic Doppler current profiler will be used to continuously monitor the current beneath the rig. Metocean conditions such as sea states, wind speed, ocean currents, etc. will also be continuously monitored. Under most circumstances, physical oceanographic conditions are not expected to have any effect on the proposed activities. Strong currents (e.g., caused by Loop Current eddies and intrusions) and large waves were considered in the design criteria for the drilling rig. High waves during a severe storm could disrupt support activities (i.e., vessel and helicopter traffic) and

### make it necessary to suspend some activities on the drilling rig for safety reasons until the storm or

weather event passes.



# E. Alternatives

No formal alternatives were evaluated in this EIA. However, various technical and operational options, including the location of the wellsites and the selection of a drilling unit, were considered by Shell in developing the proposed action. There are no other reasonable alternatives to accomplish the goals of this project.



# F. Mitigation Measures

The proposed action includes numerous mitigation measures required by laws, regulations, and BOEM lease stipulations and NTLs. The project will comply with applicable federal, state, and local requirements concerning air pollutant emissions, discharges to water, and solid waste disposal.

P roject activities will be conducted under Shell’s OSRP and will include the measures described in

EP Section 2f

.



# G. Consultation

No persons or agencies were consulted regarding potential impacts associated with the proposed activities during the preparation of this EIA.



# H. Preparers

The EIA was prepared at the direction of Shell Offshore Inc. by its contractor, CSA International, Inc. Contributors included the following:

73. Tracy Albert (Regulatory Specialist, Regulatory Compliance Consultants of LA, LLC);

74. Jeffrey McMenis (Environmental Engineer, Shell Exploration & Production Co.);

75. Michael Mahaffie (Project Leader, Shell Exploration & Production Co.);

76. James Jorgensen (Drilling Engineer, Shell International Exploration and Production);

77. Jamie Crider (Geophysicist, Shell Exploration & Production Co.);

78. John Baird (Reservoir Engineer, Shell Exploration & Production Co.);

79. June Mire, Ph.D. (Senior Ecologist and Project Manager, Tetra Tech EM, Inc.);

80. Carlyle Kalloo (Senior Scientist, CSA International, Inc.);

81. John Thompson (Senior Scientist, CSA International, Inc.);

82. Neal Phillips, Ph.D. (Senior Scientist, CSA International, Inc.);

83. Deborah Fawcett (Project Scientist II, CSA International, Inc.);

84. Stephen Viada (Senior Scientist, CSA International, Inc.);

85. Keith VanGraafeiland (GIS/Remote Sensing Specialist, CSA International, Inc.); and

86. Kim Dunleavy (Technical Editor, CSA International, Inc.).

# I. References

Antonio, F.J., R.S. Mendes, and S.M. Thomas. 2011

. "Identifying and modeling patterns of tetrapod vertebrate mortality rates in the Gulf of Mexico oil spill." Aquatic Toxicology 105(1-2): 177-179.
Barkuloo, J.M. 1988. Report on the conservation status of the Gulf of Mexico sturgeon, Acipenser oxyrinchus desotoi. U.S. Department of the Interior, U.S. Fish Wildlife Service, Panama City, FL. 33 pp.
Bélanger, L. and J. Bédard. 1989. Responses of Staging Greater Snow Geese to Human Disturbance. Journal of Wildlife Management 53:713-719. Biggs, D.C. and P.H. Ressler. 2000. Water column biology, pp. 141-187. In: Continental Shelf Associates, Inc. Deepwater Program: Gulf of Mexico Deepwater Information Resources Data Search and Literature Synthesis. Volume I: Narrative Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000- 049. Boehm, P., D. Turton, A. Raval, D. Caudle, D. French, N. Rabalais, R. Spies, and J. Johnson. 2001. Deepwater program: Literature review, environmental risks of chemical products used in Gulf of Mexico deepwater oil and gas operations. Volume I: Technical report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2001-011. 326 pp.
Brooke, S. and W.W. Schroeder. 2007. State of deep coral ecosystems in the Gulf of Mexico region: Texas to the Florida Straits, pp. 271-306. In: S.E. Lumsden, T.F. Hourigan, A.W. Bruckner, and G. Dorr (eds.), The State of Deep Coral Ecosystems of the United States. NOAA Tech. Memo. CRCP-3. Silver Spring, MD. 365 pp. Brooks, J.M., C. Fisher, H. Roberts, B. Bernard, I. McDonald, R. Carney, S. Joye, E. Cordes, G. Wolff, and E. Goehring. 2009. Investigations of chemosynthetic communities on the lower continental slope of the Gulf of Mexico: Interim Report 2. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2009-046. Bureau of Ocean Energy Management (BOEM). 2011. Grid EA and ROV survey status report. Website accessed on
October 1, 2012 ; updated on October 1, 2012

. http://www.gomr.boemre.gov/homepg/regulate/environ/ea_grid/ea_grid.asp
Bureau of Ocean Energy Management (BOEM). 2012a. Outer Continental Shelf Oil and Gas Leasing Program: 2012- 2017. Final Programmatic Environmental Impact Statement. U.S. Department of the Interior, Bureau of Ocean Energy Management. OCS EIS/EA BOEM 2012- 030. Bureau of Ocean Energy Management (BOEM). 2012b. Gulf of Mexico OCS Oil and Gas Lease Sales: 2012-2017. Western Planning Area Lease Sales 229, 233, 238, 246 and 248. Central Planning Area Lease Sales 227, 231, 235, 241 and 247. Final Environmental Impact Statement. U.S. Department of the Interior, Bureau of Ocean Energy Management, Gulf of Mexico OCS Region. OCS EIS/EA BOEM 2012-019. 3 vols.
Bureau of Ocean Energy Management (BOEM). 2012c. Archaeology Survey Blocks. Website accessed on September 20 , 2012. http://www.boem.gov/Environmental-Stewardship/Archaeology/surveyblocks-pdf.aspx

. Bureau of Ocean Energy Management (BOEM). 2012d. Gulf of Mexico OCS Oil and Gas Lease Sale: 2012. Central Planning Area Lease Sale 216/222. Final Supplemental Environmental Impact Statement. U.S. Department of the Interior, Bureau of Ocean Energy Management, Gulf of Mexico OCS Region. OCS EIS/EA BOEM 2012- 058. 2 vols.Camilli, R., C.M. Reddy, D.R. Yoerger, B.A.S. Van Mooy, M.V. Jakuba, J.C. Kinsey, C.P. McIntyre, S.P. Sylva, and J.V. Maloney. 2010. Tracking hydrocarbon plume transport and biodegradation at Deepwater Horizon . Science DOI: 10.1126/science.1195223.
Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE). 2010. Federal & Academic Scientists Return from Deep-sea Research Cruise in Gulf of Mexico: Scientists Observe Damage to Deep-sea Corals. Press
release dated 4 November 2010. Website accessed on October 1, 2012

. http://www.boemre.gov/ooc/press/2010/press1104a.htmBureau of Ocean Energy Management Regulation and Enforcement (BOEMRE). 2011. Gulf of Mexico OCS Oil and Gas

Lease Sale: 2011. Western Planning Area Lease Sale 218. Supplemental Environmental Impact Statement. U.S. Department of the Interior, Bureau of Ocean Energy Management, Regulation and Enforcement Gulf of Mexico OC S Region. OCS EIS/EA BOEMRE 2011-018. 801 pp.Camilli, R., C.M. Reddy, D.R. Yoerger, B.A.S. Van Mooy, M.V. Jakuba, J.C. Kinsey, C.P. McIntyre, S.P. Sylva, and J.V. Maloney. 2010. Tracking hydrocarbon plume transport and biodegradation at Deepwater Horiz on . Science DOI: 10.1126/science.1195223.
C&C Technologies. 2009. Archaeological Assessment Report, Blocks 676-678, 720-722, 765-766, and Vicinity, Mississippi Canyon Area, Project No. 097403-097494, December, 2009. AUV side-scan sonar and sub-bottom profiler data.
Carr, A. 1996. Suwannee River sturgeon, pp. 73-83. In: M.H. Carr (ed.), A Naturalist in Florida. Yale University Press,
New Haven, CT. Clapp, R.B., R.C. Banks, D. Morgan-Jacobs, and W.A. Hoffman. 1982a. Marine birds of the southeastern United States and Gulf of Mexico. Part I. Gaviiformes through Pelicaniformes. U.S. Fish and Wildlife Service, Office of Biological Services, Washington, DC. FWS/OBS-82/01. 637 pp.
Clapp, R.B., D. Morgan-Jacobs, and R.C. Banks. 1982b. Marine birds of the southeastern United States and Gulf of Mexico. Part II. Anseriformes. U.S. Fish and Wildlife Service, Office of Biological Services, Washington, DC. FWS/OBS-82/20. 492 pp.
Clapp, R.B., D. Morgan-Jacobs, and R.C. Banks. 1983. Marine birds of the southeastern United States and Gulf of Mexico. Part III. Charadriiformes. U.S. Fish and Wildlife Service, Office of Biological Services, Washington, DC. FWS/OBS-83/30. 853 pp.
Collard, S.B. and C. Way. 1997. Chapter 5

– The biological environment. In: Science Applications International Corporation (ed.), Northeastern Gulf of Mexico Coastal and Marine Ecosystem Program: Data Search and Synthesis; Synthesis Report. U.S. Department of the Interior, U.S. Geological Survey, Biological Resources Division and Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. USGS/BRD/CR- 1997 -0005. OCS Study

MMS 96-0014. 313 pp. Continental Shelf Associates, Inc. 1997. Characterization and trends of recreational and commercial fishing from the Florida Panhandle. U.S. Department of Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. USGS/BRD/CR-1997-0001 and OCS Study MMS 97 -0020. 333 pp. Continental Shelf Associates, Inc. 2002. Deepwater Program: Bluewater fishing and OCS activity, interactions between the fishing and petroleum industries in deepwaters of the Gulf of Mexico. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2002- 078

. Continental Shelf Associates, Inc. 2004. Final Report: Gulf of Mexico Comprehensive Synthetic Based Muds Monitoring Program. Report prepared for SBM Research Group, Houston, TX. October 2004. 3 volumes.
Continental Shelf Associates, Inc. 2006. Effects of oil and gas exploration and development at selected continental slope sites in the Gulf of Mexico. Volume II: Technical report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2006-045.
Cruz-Kaegi, M.E. 1998. Latitudinal variations in biomass and metabolism of benthic infaunal communities. Ph.D. dissertation, Texas A&M University, College Station, TX.
CSA International, Inc. 2007. Characterization of northern Gulf of Mexico deepwater hard- bottom communities with emphasis on Lophelia coral. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2007-044. 169 pp. + app.
Davis, R.W. and G.S. Fargion. 1996. Distribution and abundance of cetaceans in the north-central and western Gulf of Mexico: Final report. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. Website accessed on October 1, 2012

. http://www.getcited.org/pub/100201353
Davis, R.W., J.G. Ortega-Ortiz, C.A. Ribic, W.E. Evans, D.C. Biggs, P.H. Ressler, J.H. Wormuth, R.R. Leben, K.D. Mullin, and B. Würsig. 2000. Cetacean habitat in the northern Gulf of Mexico, pp. 217-253. In: R.W. Davis, W.E. Evans, and B. Würsig (eds.), Cetaceans, sea turtles, and seabirds in the northern Gulf of Mexico: Distribution, abundance and habitat associations. Volume II: Technical report. U.S. Geological Survey, Biological Resources Division, USGS/BRD/CR-1999-0006 and U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000-003. 346 pp. Website accessed on October 1, 2012

. http://www.tamug.edu/marb/davisdocs/Deep-Sea%20Res%202001%20Davis%20etal.pdf
Ditty, J.G. 1986. Ichthyoplankton in neretic waters of the northern Gulf of Mexico off Louisiana: Composition, relative abundance, and seasonality. Fish. Bull. 84(4):935- 946.Ditty, J.G., G.G. Zieske, and R.F. Shaw. 1988. Seasonality and depth distribution of larval fishes in the northern Gulf of

Mexico above 26°00’N. Fish. Bull. 86:811

- 823. Efroymson, R.A., W.H. Rose, S. Nemeth, and G.W. Suter II. 2000. Ecological risk assessment framework for low altitude overflights by fixed-wing and rotary-wing military aircraft. Report prepared by Oak Ridge National Laboratory, Oak Ridge, TN. ORNL/TM-2000/289: ES-5048.
Fertl, D., A. Schiro, G. Regan, C. Beck, N. Adimey, L. Price-May, A. Amos, G. Wother, and R. Crossland. 2005. Manatee
occurrence in the Northern Gulf of Mexico west of Florida. Gulf and Caribbean Research 17: 69- 94. Florida Fish and Wildlife Conservation Commission. 2011. Florida's endangered species, threatened species, and species of special concern. Website accessed on October 1, 2012

. http://myfwc.com/media/1515251/Threatened_Endangered_Species.pdf
Fox, D.A., J.E. Hightower, and F.M. Paruka. 2000. Gulf sturgeon spawning migration and habitat in the Choctawhatchee River system, Alabama-Florida. Trans. Am. Fish. Soc. 129:811-826.
Fritts, T.H. and R.P. Reynolds. 1981. Pilot study of the marine mammals, birds, and turtles in OCS areas of the Gulf of Mexico. U.S. Department of the Interior, Fish and Wildlife Service, Biological Services Program. FWS/OBS-81/36.
Gallaway, B. (ed.). 1988. Northern Gulf of Mexico continental slope study, final report: Year 4. Volume II: Synthesis report. Final report submitted to the Minerals Management Service, New Orleans, LA.

Contract No. 14

- 12 -0001-30212. Gallaway, B.J., J.G. Cole, and R.G. Fechhelm. 2003. Selected Aspects of the Ecology of the Continental Slope Fauna of the Gulf of Mexico: A Synopsis of the Northern Gulf of Mexico Continental Slope Study, 1983-1988. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2003-072. Geoscience Earth and Marine Services, Inc. (GEMS). 2010. Geologic and Stratigraphic Assessment of Blocks 720 (OCS- G 33170), 721 (OCS-G 33171), and 722 (OCS-G 33172), Mississippi Canyon Area, Gulf of Mexico, Project # 0609-1691b, dated February 4, 2010. AUV side-scan sonar and sub-bottom profiler, and Reprocessed 3-D seismic data.
Geraci, J.R. and D.J. St. Aubin. 1985. Expanded Study of the Effects of Oil on Cetaceans, Final Report, Part I. Prepared for the U.S. Department of the Interior, Bureau of Land Management, Washington, DC by the University of Guelph,

Ontario. Contract No. 14

- 12

- 0001 -29169. Geraci, J.R. and D.J. St. Aubin. 1987. Effects of offshore oil and gas development on marine mammals and turtles, pp.

587 -617. In: D.F. Boesch and N.N. Rabalais (eds.), Long Term Environmental Effects of Offshore Oil and Gas Development. Elsevier Applied Science Publ. Ltd., London and New York.
Geraci, J.R. and D.J. St. Aubin. 1990. Sea Mammals and Oil: Confronting the Risks. Academic Press, San Diego, CA.

239 pp. Gulf of Mexico Fishery Management Council (GMFMC). 2005. Generic Amendment Number 3 for addressing Essential Fish Habitat Requirements, Habitat Areas of Particular Concern, and adverse effects of fishing in the following Fishery Management Plans of the Gulf of Mexico: Shrimp fishery of the Gulf of Mexico, United States waters red drum fishery of the Gulf of Mexico, reef fish fishery of the Gulf of Mexico coastal migratory pelagic resources (mackerels) in the Gulf of Mexico and South Atlantic, stone crab fishery of the Gulf of Mexico, spiny lobster in the Gulf of Mexico and South Atlantic, coral and coral reefs of the Gulf of Mexico. Gulf of Mexico Fishery Management Council, Tampa, FL.
Hazen, T.C., E.A. Dubinsky, T.Z. DeSantis, G.L. Andersen, Y.M. Piceno, N. Singh, J.K. Jansson, A. Probst, S.E. Borglin, J.L. Fortney, W.T. Stringfellow, M. Bill, M.S. Conrad, L.M. Tom, K.L. Chavarria, T.R. Alusi, R. Lamendella, D.C. Joyner, C. Spier, J. Baelum, M. Auer, M.L. Zemla, R. Chakraborty, E.L. Sonnenthal, P. D’haeseleer, H.N. Holman, S. Osman, Z. Lu, J.D. Van Nostrand, Y. Deng, J. Zhou, and O.U. Mason. 2010. Deep-sea oil plume enriches indigenous oil-degrading
bacteria. Science DOI: 10.1126/science.1195979.
Hess, N.A. and C.A. Ribic. 2000. Seabird ecology, pp. 275-315. In: R.W. Davis, W.E. Evans, and B. Würsig (eds.), Cetaceans, sea turtles, and seabirds in the northern Gulf of Mexico: Distribution, abundance and habitat associations. Volume II: Technical report. U.S. Geological Survey, Biological Resources Division, USGS/BRD/CR-1999-0006 and U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000 -003. 346 pp. Higashi, G.R. 1994. Ten years of fish aggregating device (FAD) design and development in Hawaii. Bull. Mar. Sci. 55(2- 3):651-666.
Holland, K.R., R.W. Brill, and R.K.C. Chang. 1990. Horizontal and vertical movements of yellowfin and bigeye tuna associated with fish aggregating devices. Fish. Bull. 88:493- 507.Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: Synthesis Report. Contribution of Working

Groups I, II and III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland. 104 pp.
Ji, Z-G., W.R. Johnson, C.F. Marshall, and E.M. Lear. 2004. Oil-Spill Risk Analysis: Contingency Planning Statistics for Gulf of Mexico OCS Activities. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region. OCS Report MMS 2004-026. Jochens, A., D. Biggs, K. Benoit- Bi rd, D. Engelhaupt, J. Gordon, C. Hu, N. Jaquet, M. Johnson, R. Leben, B. Mate, P. Miller, J. Ortega-Ortiz, A. Thode, P. Tyack, and B. Würsig. 2008. Sperm whale seismic study in the Gulf of Mexico: Synthesis report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2008-006. 341 pp. Joint Analysis Group. 2010a. Joint Analysis Group (JAG) review of preliminary data to examine subsurface oil in the vicinity of MC252#1 May 19 to June 19, 2010. Website accessed on October 1, 2012. http://gomex.erma.noaa.gov/layerfiles/7229/files/JAG_Data_Report_2_Subsurface%20Oil_Final.pdf
Joint Analysis Group. 2010b. Joint Analysis Group (JAG) review of R/V Brooks McCall data to examine subsurface oil.
Website accessed on October 1, 2012

. http://ecowatch.ncddc.noaa.gov/JAG/files/JAG%20Report%20Brooks%20McCall%20final.pdf
Joint Analysis Group. 2010c. Joint Analysis Group (JAG) review of preliminary data to examine oxygen levels in the vicinity of MC252#1 May 8 to August 9, 2010. Website accessed on October 1, 2012

. http://www.noaa.gov/sciencemissions/PDFs/JAG_Oxygen_Report%20%28FINAL%20090410%29.pdf
Joye, S.B., I.R. MacDonald, I. Leifer, and V. Asper. 2011. Magnitude and oxidation potential of hydrocarbon gases
released from the BP oil well blowout. Nature Geoscience 4: 160- 164. Website accessed on October 1, 2012

. http://www.nature.com/ngeo/journal/v4/n3/abs/ngeo1067.html
Kessler, J.D., D.L. Valentine, M.C. Redmond, M. Du, E.W. Chan, S.D. Mendes, E.W. Quiroz, C.J. Villanueva, S.S. Shusta, L.M. Werra, S.A. Yvon-Lewis, and T.C. Weber. 2011. A persistent oxygen anomaly reveals the fate of spilled methane in the deep Gulf of Mexico. Science 331: 312-315

. Kujawinski, E.B., M.C. Kido Soule, D.L. Valentine, A.K. Boysen, K. Longnecker, and M.C. Redmond. 2011. Fate of dispersants associated with the Deepwater Horizon oil spill. Environ. Sci. Technol. 45(4): 1298- 1306

. Lohoefener, R., W. Hoggard, K. Mullin, C. Ro den, and C. Rogers. 1990. Association of sea turtles with petroleum platforms in the north-central Gulf of Mexico. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 90 -0025. 90 pp. Lutcavage, M.E., P.L. Lutz, G.D. Bossart, and D.M. Hudson. 1995. Physiologic and clinicopathologic effects of crude oil on loggerhead sea turtles. Arch. Environ. Contam. Toxicol. 28:417-422.
Lutcavage, M.E., P. Plotkin, B. Witherington, and P.L. Lutz. 1997. Human impacts on sea turtle survival, pps. 387 -409. In: Lutz, P.L. and J.A. Musick (eds.), The Biology of Sea Turtles. CRC Press, Boca Raton, FL.
MacDonald, I.R. (ed.). 2002. Stability and Change in Gulf of Mexico Chemosynthetic Communities. Volume II: Technical Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2002-036. 456 pp. Marine Mammal Commission (MMC). 2011. Assessing the long-term effects of the BP Deepwater Horizon o il spill on marine mammals in the Gulf of Mexico: A statement of research needs. Website accessed on October 1, 2012

. http://www.mmc.gov/reports/workshop/pdf/longterm_effects_bp_oilspil.pdf
Mendelssohn, I.A., G.L. Andersen, D.M. Baltz, R.H. Caffey, K. R. Carman, J.W. Fleeger, S.B. Joye, Q. Lin, E. Maltby, E.B. Overton, and L. P. Rozas. 2012. Oil Impacts on Coastal Wetlands: Implications for the Mississippi River Delta Ecosystem after the Deepwater Horizon Oil Spill. BioScience, 62(6):562-574. Website accessed on October 1, 2012. http://www.bioone.org/doi/full/10.1525/bio.2012.62.6.7
Minerals Management Service (MMS). 2000. Gulf of Mexico Deepwater Operations and Activities: Environmental Assessment. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 2000-001.

Mi nerals Management Service (MMS). 2001. Gulf of Mexico OCS Oil and Gas Lease Sale 181, Eastern Planning Area, Final Environmental Impact Statement. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA 2001-051. 2 vols.
Minerals Management Service (MMS). 2007a. Outer Continental Shelf Oil & Gas Leasing Program: 2007-2012 Final Environmental Impact Statement. U.S. Department of the Interior, Minerals Management Service, Herndon, VA. OCS EIS/EA MMS 2007-003. April 2007.Minerals Management Service (MMS). 2007b. Gulf of Mexico OCS Oil and Gas Lease Sales: 2007-2012. Western

Planning Area Sales 204, 207, 210, 215, and 218; Central Planning Area Sales 205, 206, 208, 213, 216, and 222. Final Environmental Impact Statement. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region. OCS EIS/EA MMS 2007-018. April 2007. Minerals Management Service (MMS). 2008. Gulf of Mexico OCS Oil and Gas Lease Sales: 2009-2012; Central Planning Area Sales 208, 213, 216, and 222; Western Planning Area Sales 210, 215, and 218. Final Supplemental Environmental Impact Statement. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS EIS/EA MMS 2008-041. September 2008.
Minerals Management Service (MMS). 2010. OCS Regulatory Framework for the Gulf of Mexico Region. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Report 2010-019. May 2010. Mississippi Department of Wildlife, Fisheries and Parks. 2011. Mississippi’s species of greatest conservation need by ecoregion. Website accessed December 2, 2011. http://www.mdwfp.com/homelinks/more/Final/Appendix%208.pdf
Morrow, J.V., Jr., J.P. Kirk, K.J. Killgore, H. Rugillio, and C. Knight. 1998. Status and recovery of Gulf sturgeon in the Pearl River system, Louisiana-Mississippi. North American Journal of Fisheries Management 18:798-808.
Mullin, K., W. Hoggard, C. Roden, R. Lohoefener, C. Rogers, and B. Taggart. 1991. Cetaceans on the upper continental slope in the north-central Gulf of Mexico. OCS Study/MMS 910027. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Regional Office, New Orleans, LA. 108 pp.
Mullin, K.D. 2007. Abundance of cetaceans in the oceanic Gulf of Mexico based on 2003-2004 ship surveys. Available from: National Marine Fisheries Service, Southeast Fisheries Science Center, Pascagoula, MS. 26 pp. National Marine Fisheries Service (NMFS). 2007. Endangered Species Act, Section 7 Consultation

– Biological Opinion. Gulf of Mexico Oil and Gas Activities: Five-Year Leasing Plan for Western and Central Planning Areas 2007-2012.

29 June 2007. National Marine Fisheries Service (NMFS). 2009. Final Amendment 1 to the Consolidated Atlantic Highly Migratory Species Fishery Management Plan Essential Fish Habitat. Highly Migratory Species Management Division, Office of Sustainable Fisheries, Silver Spring, MD. June 2009. Website accessed on October 1, 2012. http://www.nmfs.noaa.gov/sfa/hms/EFH/Final/FEIS_Amendment_Total.pdf
National Marine Fisheries Service (NMFS). 2010a. Final recovery plan for the sperm whale ( Physeter macrocephalus ). Silver Spring, MD. 165 pp. Website accessed on September 21, 201 2. http://www.nmfs.noaa.gov/pr/pdfs/recovery/final_sperm_whale_recovery_plan_21dec.pdf
National Marine Fisheries Service (NMFS). 2010b. Sea turtles, dolphins, and whales and the Gulf of Mexico oil spill. Website accessed on September 21, 2012; updated on September 12, 2011. http://www.nmfs.noaa.gov/pr/health/oilspill.htm
National Marine Fisheries Service (NMFS). 2010c. Impacts of oil on marine mammals and sea turtles. Website accessed on September 21, 2012. http://www.nmfs.noaa.gov/pr/pdfs/health/oil_impacts.pdf
National Marine Fisheries Service (NMFS). 20 10 d. Gulf sturgeon ( Acipenser oxyrinchus desotoi ). Website accessed on September 21, 201 2; updated on March 14, 2012. http://www.nmfs.noaa.gov/pr/species/fish/gulfsturgeon.htm National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (USFWS), and SEMARNAT. 2011. Bi

- National Recovery Plan for the Kemp‘s Ridley Sea Turtle ( Lepidochelys kempii ), Second Revision. National Marine Fisheries Service. Silver Spring, MD. Website accessed on September 21, 2012. http://www.fws.gov/kempsridley/Finals/kempsridley_revision2.pdf
National Oceanic and Atmospheric Administration (NOAA). 2006. Fact Sheet: Small Diesel Spills (500-5,000 gallons). NOAA Scientific Support Team, Hazardous Materials Response and Assessment Division, National Oceanic and Atmospheric Administration, Seattle, WA. 2 pp. National Research Council (NRC). 1983. Drilling Discharges in the Marine Environment. National Academy Press, Washington, DC. 180 pp. National Research Council (NRC). 2003. Oil in the Sea III: Inputs, Fates, and Effects. National Academies Press, Washington, DC. 182 pp. + app.
National Wildlife Federation. 2012. Wildlife library. Whooping Crane. Website accessed on October 12, 2012. http://www.nwf.org/wildlife/wildlife-library/birds/whooping-crane.aspxNeff, J.M. 1987. Biological effects of drilling fluids, drill cuttings and produced waters, pp. 469-538. In: D.F. Boesch and

N.N. Rabalais (eds.), Long-Term Effects of Offshore Oil and Gas Development. Elsevier Applied Science Publishers,
London.
Neff, J.M., S. McKelvie, and R.C. Ayers, Jr. 2000. Environmental impacts of synthetic based drilling fluids. Prepared by Robert Ayers & Associates, Inc. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000-064. 118 pp.
Neff, J.M., A.D. Hart, J.P. Ray, J.M. Limia, and T.W. Purcell. 2005. An assessment of seabed impacts of synthetic-based drilling-mud cuttings in the Gulf of Mexico. 2005 SPE/EPA/DOE Exploration and Production Environmental Conference, 7-9 March 2005, Galveston, Texas, USA. SPE 94086.
Nowlin, W.D., Jr., A.E. Jochens, S.F. DiMarco, R.O. Reid, and M.K. Howard. 2001. Deepwater Physical Oceanography Reanalysis and Synthesis of Historical Data: Synthesis Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2001-064. 528 pp. Operational Science Advisory Team (OSAT). 2010. Summary report for sub-surface and sub-sea oil and dispersant detection: Sampling and monitoring. Prepared for Paul F. Zukunft, U.S. Coast Guard Federal On -Scene Coordinator, Deepwater Horizon MC252. December 17, 2010. Website accessed on October 1, 2012

. http://www.restorethegulf.gov/sites/default/files/documents/pdf/OSAT_Report_FINAL_17DEC.pdf
Peake, D.E. 1996. Bird surveys, pp. 271-304. In: R.W. Davis and G.S. Fargion (eds.), Distribution and abundance of cetaceans in the north-central and western Gulf of Mexico, Final report. Volume II: Technical report. Prepared by the Texas Institute of Oceanography and the National Marine Fisheries Service. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region Office, New Orleans, LA. OCS Study MMS 96-0027. 357

pp. Poot, H., B.J. Ens, H. de Vries, M.A.H. Donners, M.R. Wernand, and J.M. Marquenie. 2008. Green light for nocturnally migrating birds. Ecology and Society 13 (2):47. Website accessed on October 1, 2012. http://www.ecologyandsociety.org/vol13/iss2/art47/
Powers, K. 1987. Seabirds, pp. 194-201. In: J.D. Milliman and W.R. Wright (eds.), The Marine Environment of the U.S. Atlantic Continental Slope and Rise. Jones and Bartlett Publ., Inc. Boston/Woods Hole, MA. 275 pp.
Rathbun, G.B. 1988. Fixed-wing airplane versus helicopter surveys of manatees. Mar. Mamm. Sci. 4(1):71

- 75.
Relini, M., L.R. Orsi, and G. Relini. 1994. An offshore b uoy as a FAD in the Mediterranean. Bull. Mar. Sci. 55(2

- 3):1,099

- 1,105. Richards, W.J., T. Leming, M.F. McGowan, J.T. Lamkin, and S. Kelley-Farga. 1989. Distribution of fish larvae in relation to hydrographic features of the Loop Current boundary in the Gulf of Mexico. Rapp. P.-v. Reun. Cons. Int. Explor. Mer.

191:169-176. Richards, W.J., M.F. McGowan, T. Leming, J.T. Lamkin, and S. Kelley. 1993. Larval fish assemblages at the Loop Current boundary in the Gulf of Mexico. Bull. Mar. Sci. 53(2):475-537.
Richardson, W.J., C.R. Greene, Jr., C.I. Malme, and D.H. Thomson. 1995. Marine Mammals and Noise. Academic Press, San Diego. 576 pp. Rodgers, J., Jr, and S. Schwikert. 2002. Buffer Zone Distances to Protect Foraging and Loafing Waterbirds from Disturbances by Personal Watercraft and Outboard-Powered Boats. Conservation Biology 16:216- 224. Ross, S.W., A.W.J. Demopoulos, C.A. Kellogg

, C.L. Morrison, M.S. Nizinski, C.L. Ames, T.L. Casazza, D. Gualtieri, K. Kovacs, J.P. McClain, A.M. Quattrini, A.Y. Roa-Varón, and A.D. Thaler. 2012. Deepwater Program: Studies of Gulf of Mexico lower continental slope communities related to chemosynthetic and hard substrate habitats: U.S. Geological Survey Open-File Report 2012- 1032

. 301 pp. Rowe, G.T. and M.C. Kennicutt II. 2009. Northern Gulf of Mexico Continental Slope Habitats and Benthic Ecology Study. Final Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2009-039. 456 pp.
Russell, R.W. 2005. Interactions between migrating birds and offshore oil and gas platforms in the northern Gulf of Mexico: Final Report. U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2005-009. 348 pp. Salmon, M. and J. Wyneken. 1990. Do swimming loggerhead sea turtles ( Caretta caretta ) use light cues for offshore orientation? Marine and Freshwater Behaviour and Physiology 17(4): 233- 246. Sea Turtle Restoration Project. 2011. Kemp’s ridley protection campaign. Website accessed on October 1, 2012. http://www.seaturtles.org/article.php?list=type&type=41Share the Beach. 2010. Nesting season statistics. Website ac cessed on October 1, 2012

.

http://www.alabamaseaturtles.com/nesting-season-statistics/

Shell. 2011. Greenhouse Gas Emissions. Website accessed on October 1, 2012

. http://www.shell.com/home/content/environment_society/environment/climate_change/greenhouse_gas_emissi ons/
Smultea, M.A., J.R. Mobley, Jr., D. Fertl, and G.L. Fulling. 2008. An unusual reaction and other observations of sperm whales near fixed wing aircraft. Gulf and Caribbean Research 20:75- 80. Sulak, K.J. and J.P. Clugston. 1998. Early life history stages of Gulf sturgeon in the Suwannee River, Florida. Trans. Am.
Fish. Soc. 127:758- 771. Tuxbury, S.M. and M. Salmon. 2005. Competitive interactions between artificial lighting and natural cues during seafinding by hatchling marine turtles. Biol. Conserv. 121: 311-316. U.S. Environmental Protection Agency (USEPA). 2012. The green book nonattainment areas for criteria pollutants.
Website accessed on October 1, 2012 ; updated on July 20, 2012. http://www.epa.gov/air/oaqps/greenbk/
U.S. Fish and Wildlife Service (USFWS). 2001. Florida manatee recovery plan ( Trichechus manatus latirostris ), Third Revision. U.S. Fish and Wildlife Service, Southeast Region, Atlanta, GA.
U.S. Fish and Wildlife Service (USFWS). 2003. Recovery plan for the Great Lakes Piping Plover ( Charadrius melodus ). Fort Snelling, Minnesota. September 2003. U.S. Fish and Wildlife Service (USFWS). 2007. International Recovery Plan: Whooping Crane ( Grus americana ), Third Revision. Albuquerque, New Mexico. March 2007. U.S. Fish and Wildlife Service (USFWS). 2010a. All about Piping Plovers. Website accessed on October 1, 2012

. http://www.fws.gov/plover/facts.html
U.S. Fish and Wildlife Service (USFWS). 2010b. FWS Deepwater Horizon oil spill response. Website accessed on
October 1, 2012

. http://www.fws.gov/home/dhoilspill/pdfs/DHBirdsOfTheGulf.pdf
U.S. Fish and Wildlife Service (USFWS). 2010c. Species information, threatened and endangered animals and plants.
Website accessed on October 1, 2012 ; updated on September 26, 2012

. http://www.fws.gov/endangered/
U.S. Fish and Wildlife Service and Gulf States Marine Fisheries Commission. 1995. Gulf Sturgeon Recovery Plan. Atlanta, Georgia. 170 pp. Website accessed on October 1, 2012

. http://www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_gulf.pdf
Wakeford, A. 2001. State of Florida conservation plan for Gulf sturgeon ( Acipencer oxyrinchus desotoi ). Florida Marine Research Institute Technical Report TR-8. St. Petersburg, FL. Waring, G.T., E. Josephson, K. Maze-Foley, and P.E. Rosel (eds.). 2012. U.S. Atlantic and Gulf of Mexico Marine Mammal Stock Assessments - 2011. NOAA Tech Memo NMFS NE 221. 330 pp. http://nefsc.noaa.gov/publications/tm/tm221/tm221.pdf
Wei, C-L. 2006. The bathymetric zonation and community structure of deep-sea macrobenthos in the northern Gulf of Mexico. M.S. thesis, Texas A&M University. Website accessed on October 1, 2012

. http://repository.tamu.edu/handle/1969.1/4927
White, H.K., P. Hsing, W. Cho, T.M. Shank, E.E. Cordes, A.M. Quattrini, R.K. Nelson, R. Camilli, A.W.J. Demopoulous, C.R. German, J.M. Brooks, H.H. Roberts, W. Shedd, C.M. Reddy and C.R. Fisher. 2012. Impact of the Deepwater Horizon oil spill on a deep-water coral community in the Gulf of Mexico. Proceedings of the National Academy of Sciences (Early Edition)

. doi: 10.1073/pnas.1118029109. Website accessed on October 1, 2012

. http://www.pnas.org/content/early/2012/03/23/1118029109.full.pdf+html?sid=56e8cdfe-2830-43f8-9d08-
8eca0efd27e2
Whooping Crane Eastern Partnership. 2010. About Whooping Cranes and their recovery. Website accessed on
October 1, 2012 ; updated on May 16, 2012. http://www.bringbackthecranes.org/index.html
Whooping Crane Eastern Partnership. 2012. Whooping Crane Numbers 2002 thru 2011. Website accessed on
October 12, 2012. http://www.bringbackthecranes.org/technicaldatabase/recovery/wc_nos_02to11.html
Wiese, F.K., W.A. Montevecchi, G.K. Davoren, F. Huettmann, A.W. Diamond, and J. Linke. 2001. Seabirds at risk around offshore oil platforms in the north-west Atlantic. Mar. Poll. Bull. 42(12):1,285-1,290. Wilson, J. 2003. Manatees in Louisiana. Louisiana Conservationist. July/August 2003, pp. 4-7. Website accessed on
October 1, 2012

. http://www.lamer.lsu.edu/pdfs/Manatees_LaConservArticle.pdfWitherington, B.E. 1997. The problem of photopollution for sea turtles and other nocturnal animals, pp. 303 -328. In:

J. R. Clemmons and R. Buchholz (eds.), Behavioral Approaches to Conservation in the Wild. Cambridge University Press, Cambridge, England.
Würsig, B., S.K. Lynn, T.A. Jefferson, and K.D. Mullin. 1998. Behaviour of cetaceans in the northern Gulf of Mexico

re lative to survey ships and aircraft. Aquatic Mammals 24:41-50.
Würsig, B., T.A. Jefferson, and D.J. Schmidly. 2000. The Marine Mammals of the Gulf of Mexico. Texas A&M University Press, College Station, TX. 232 pp.SECTION 19 : ADMINISTRATIVE INFORMATION

A. Exempted Information Description (Public Information Copies Only)

The following attachments were excluded from the public information copies of this plan:

Section 1B OCS Plan Information form

– Bottom hole locations & proposed total depth Section 2J Blowout Scenario

– confidential information for NTL 2010 N06 calculation Section 3A Geologic Description Section 3B Structure Contour Maps Section 3C Interpreted 2D or 3D seismic line(s) Section 3D Cross Section(s) Section 3E Stratigraphic Column with Time vs. depth table Section 3G High-Resolution Seismic Lines & Top Hole Progs

B. Bibliography

CSA Environmental Impact Analysis, October 2012

Shallow Hazards Report, prepared by Gems, Inc. (Project No. 0909-1691b) of the shallow drilling hazards

“ Geologic and Stratigraphic Assessment of Blocks 720 (OCS-G 33170), 721 (OCS-G 33171) and 722 (OCS- G 33172) Mississippi Canyon Area, Gulf of Mexico ” dated February 4, 2010.

C&C Technologies, Archaeological Assessment Report, Blocks 676-678, 720-722, 765-766, and Vicinity, Mississippi Canyon Area, Project No. 097403 -097494, December, 2009. AUV side-scan sonar and sub-bottom profiler data.

C& C Technologies, Archaeological and Hazard Report, Blocks 808, 809, 852, 853 and Vicinity, Mississippi Canyon Area, Project No. 083986-084109, February, 2009. AUV side-scan sonar and sub-bottom profiler data.

C&C Technologies, Archaeological Assessment Report, Block 854 and Vicinity (Blocks 809-811, 853, 855, 897- 899), Mississippi Canyon Area, Project No. 072879-072915, August 2007. AUV side-scan sonar and sub-bottom profiler data.

Shell’s Regional OSRP (2012)