OCS EIS/EA

 BOEM

Oil and Gas and Sulphur Operations on 

the Outer Continental Shelf—

Oil and Gas Production Safety Systems

for 30 CFR Part 250 Subpart H

Environmental Assessment 

October 2012

U.S. Department of the Interior Herndon

Bureau of Ocean Energy Management October 2012 
DRAFT FINDING OF NO SIGNIFICANT IMPACT (FONSI)

Oil and Gas and Sulphur Operations on the Outer Continental Shelf—

Oil and Gas Production Safety Systems

(Refer to attached FONSI)
TABLE OF CONTENTS

1.0 INTRODUCTION.........................................................................................................................................1

1.1 Background and Overview..........................................................................................1

1.2 Purpose and Need ............................................................................................................3

2.0 PROPOSED ACTION AND ALTERNATIVES........................................................................................3

2.1 Proposed Action.................................................................................................................3

2.2 No Action Alternative.....................................................................................................4

3.0 AFFECTED ENVIRONMENT.....................................................................................................................4

4.0 ENVIRONMENTAL CONSEQUENCES...................................................................................................4

4.1 Proposed Action.................................................................................................................4

4.2 No Action Alternative.....................................................................................................7

5.0 REFERENCES ............................................................................................................................................10

6.0 LIST OF PREPARERS..............................................................................................................................12
U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

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1.0 INTRODUCTION

1.1 Background and Overview

The Department of the Interior is mandated under the Outer Continental Shelf Lands Act (OCSLA) to manage the 

orderly leasing, exploration, development, and production of mineral resources on the Federal Outer Continental 

Shelf (OCS). The Secretary of the Department of the Interior oversees the OCS oil and gas program and is required 

to balance orderly resource extraction with protection of the human, marine, and coastal environment. To 

effectively manage energy and mineral resources of the OCS, Secretarial Order No. 3299 established the 

responsibilities for BOEM, BSEE, and ONRR as follows: the Bureau of Ocean Energy Management (BOEM) to 

exercise management functions of activities involving resource evaluation, planning and leasing of OCS lands. The 

Bureau of Safety and Environmental Enforcement (BSEE) is authorized to inspect, investigate, summon witnesses 

and evidence, levy penalties, cancel or suspend activities, and regulate safety, response and removal preparedness 

for offshore mineral activities. 

This EA evaluates whether compliance with this rule and the associated implementation of operational procedures to 

improve production safety systems could have a significant impact on the human environment. This EA evaluates 

whether any of these effects, if determined to exist, require mitigation or further analysis. 

Many subsections of this rule address strictly administrative matters that would not have any significant 

environmental impacts or activities that have been previously codified into regulation. These subsections are 

categorized by the nature of the requirement below. No significant impacts are anticipated as a result of these 

revisions and they are therefore not analyzed further.

1. Activities which are informational or advisory in nature:

250.198 (h)(89) Documents Incorporated by Reference

250.801(c) Safety and pollution prevention equipment (SPPE) certification.

250.851(a)(3) Pressure vessels (including heat exchangers) and fired vessels.

250.869(c) General platform operations.

2. Updates and revisions to 30 CFR Part 250 that are activities that have been previously codified into regulation:

250.107(c)(1), (c)(1)(i), (c)(1)(ii) What must I do to protect health, safety, property, and the environment?

250.198(g)(1), (g)(2), (g)(3), (h)(1), (h)(51), (h)(52), (h)(53), (h)(55), (h)(56), (h)(57), (h)(58), (h)(59), (h)(60), 

(h)(61), (h)(62), (h)(65), (h)(66), (h)(68), (h)(70), (h)(71), (h)(73), (h)(74) Documents Incorporated by 

reference.

250.806(a), (b) Hydrogen sulfide.

250.810 Dry tree subsurface safety devices – general.

250.811 Specifications for SSSVs – dry trees.

250.812 Surface-controlled SSSVs – dry trees.

250.813 Subsurface-controlled SSSVs.

250.814(a), (b), (c), (d) Design, installation, and operation of SSSVs – dry trees.

250.815 Subsurface safety devices in shut-in wells – dry trees.

250.816 Subsurface safety devices in injection wells – dry trees.

250.818 Additional safety equipment – dry trees.

250.819 Specification for surface safety valves (SSVs).

250.820 Use of SSVs.

250.821(b) Emergency action.

250.826 Specifications for SSSVs – subsea trees.

250.827 Surface-controlled SSSVs – subsea trees.

250.828 Design, installation, and operation of SSSVs – subsea trees.
U.S. Department of the Interior 30 CFR Part 250

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250.829(a), (a)(1), (a)(2), (b) Subsurface safety devices in shut-in wells – subsea trees.

250.830 Subsurface safety devices in injection wells – subsea trees.

250.832 Additional safety equipment – subsea trees.

250.834 Use of USVs.

250.835(a) Specification for all boarding shut down valves (BSDVs) associated with subsea systems.

250.836 Use of BSDVs.

250.841(a) Platforms.

250.842(a)(2), (a)(3)(i), (b)(1), (b)(3) Approval of safety systems design and installation features.

250.851(a)(1)(i-ii) Pressure vessels (including heat exchangers) and fired vessels.

250.852(a)(1-2), (b)(1-2), (c)(1), (e)(1-4) Flowlines/Headers.

250.853 Safety sensors.

250.855(a), (b) Emergency shutdown system (ESD).

250.856(a), (b) Engines.

250.857(a) Glycol dehydration units.

250.858(a)(1-4) Gas compressors.

250.859(a), (a)(2) Firefighting systems.

250.860(a) Chemical firefighting system.

250.862(a), (b), (c), (d), (e) Fire and gas-detection systems.

250.863 Electrical equipment.

250.864 Erosion.

250.865(a) Surface pumps.

250.867(a) Temporary quarters.

250.869(a), (a)(3) General platform operations.

250.871 Welding and burning practices and procedures.

250.872(a) Atmospheric vessels.

250.873(a) Subsea gas lift requirements.

250.874(a), (f)(1-3) Subsea water injection systems.

250.875(d)(1-4) Subsea Pump Systems.250.880(b)(2), (c)(1)(i-iv), (c)(2)(ii-v), (c)(3)(i-ii), (c)(3)(v-x), (c)(4)(i), 

(c)(4)(iii), (c)(5)(ii)(A) Production safety system testing. The language in this section already exists in federal 

regulation under Section 250.800, 250.806, 250.807, 250.900, and 250.921. This is no more than a reorganization of 

the existing language found in federal regulation.

250.800 General.

The language in this section already exists in federal regulation under the current 250.800. This requirement is 

purely administrative and would not benefit from further analysis.

250.801(a) Safety and pollution prevention equipment (SPPE) certification.

The language in this section already exists in federal regulation under the current 250.806, 250.900, and 250.921. 

This requirement is purely administrative and would not benefit from further analysis.

250.805 Additional requirements for subsurface safety valves and related equipment installed in high 

pressure high temperature (HPHT) environments.

The language in this section already exists in federal regulation under the current 250.807. This requirement is 

purely administrative and would not benefit from further analysis.

3. Regulations for which the impacts are limited to administrative effects and therefore have no impact on the 

environment:

250.107(2) What must I do to protect health, safety, property, and the environment?

250.801(b) Safety and pollution prevention equipment (SPPE) certification.

250.803(a) What SPPE failure reporting procedures must I follow? 

250.842(a)(1), (b)(2), (c), (d), (f) Approval of safety systems design and installation features.

250.850 Production system requirements - general.

250.852(a)(3) Flowlines/Headers.

250.860(a)(1), (a)(2), (a)(2)(i-vi), (b) Chemical firefighting system.
U.S. Department of the Interior 30 CFR Part 250

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250.873(c)(1-3) Subsea gas lift requirements.

250.890 Records.

1.2 Purpose and Need

The purpose of the proposed Federal action is to conduct the rulemaking necessary to amend and update regulations 

under 30 CFR Part 250 regarding oil and gas production safety systems. The need is to update regulations that have 

not kept pace with oil and gas production on the OCS and related technologies. The BSEE is mandated by the 

OCSLA and given the authority by the DOI Secretary to inspect, investigate, summon witnesses and produce 

evidence, levy penalties, cancel or suspend activities, and oversee safety, response, and removal preparedness. The 

need to revise these regulations is important to improve the safety of oil and gas production operations on the OCS.

2.0 PROPOSED ACTION AND ALTERNATIVES

This chapter describes the proposed action and the no action alternative, as required by Council on Environmental 

Quality (CEQ) regulations implementing NEPA.

2.1 Proposed Action

The proposed action is the promulgation of the Oil and Gas and Sulphur Operations on the Outer Continental 

Shelf—Oil and Gas Production Safety Systems Proposed Rulemaking necessary to modify the regulations under 30 

CFR Part 250 Subpart H, to include 71 new or revised sections that will clarify policy and procedures and 

incorporate improved technological standards. This rule specifically will:

(1) Restructure the subpart to have shorter, easier-to-read sections based on the following headings:

-General requirements;

-Surface and subsurface safety systems – Dry trees;

-Subsea and subsurface safety systems – Subsea trees;

-Production safety systems;

-Additional production system requirements;

-Safety device testing; and

-Records and training.

(2) Expand to differentiate the requirements for operating dry tree and subsea tree production systems on the OCS.

(3) Incorporate new industry standards and update the incorporation of certain partially incorporated standards to 

require compliance with the complete standards.

(4) Add regulations for new items that were previously addressed through NTLs (e.g., 2009-G36 and 2006-G04)

and case-by-case conditions of approval of operators’ Deepwater Operations Plans (DWOPs). Proposed new

requirement topics include, but are not limited to the following:

-Safety and pollution prevention equipment (SPPE) life cycle and failure reporting;

-Use of best available and safest technology (BAST) associated with SPPE;

-Foam firefighting systems;

-Electronic-based emergency shutdown systems (ESDs);

-Valve closure timing;

-Valve leakage rates;

-Boarding shutdown valves (BSDV); and

-Equipment used for high temperature and high pressure wells.

(5) Rewrite the subpart in plain language according to:

-Plain Writing Act of 2010; and

-Executive Order13563. 
U.S. Department of the Interior 30 CFR Part 250

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2.2 No Action Alternative

This alternative would keep the existing 1988 30 CFR Part 250 regulations that apply to production safety systems. 

None of the updated policies and practices regarding production safety systems, including those that reduce the risk 

of occurrence of accidents to workers and the environment, would be implemented. This alternative would not 

allow for the proper management and oversight of OCS production operations by requiring compliance with current 

industry standards. 

3.0 AFFECTED ENVIRONMENT

Explosions, fires, and discharges on production platforms can cause human injury and mortality and impacts to the 

biota and water and air quality. A catastrophic oil spill resulting from a production safety system failure can affect 

biological, socioeconomic, and sociocultural resources over extensive coastal and offshore areas. Because of the 

large area over which the environmental effects of an unauthorized discharge or accident can occur, the following 

environmental resources could be affected by this rule:

● Air Quality

● Water Quality

● Marine Mammals

● Marine and Coastal Birds

● Fish Resources and Essential Fish Habitat

● Sea Turtles

● Coastal Habitats

● Seafloor Habitats

● Areas of Special Concern

● Population, Employment, and Regional Income

● Sociocultural Systems and Environmental Justice

● Archeological Resources

● Land Use and Existing Infrastructure

● Tourism and Recreation

● Fisheries

4.0 ENVIRONMENTAL CONSEQUENCES

4.1 Proposed Action

This rulemaking proposes new and revised regulations to improve production safety systems and related procedures 

that will reduce the occurrence of associated incidents and spills (catastrophic or otherwise). This rule will not affect 

the likelihood of oil spills from other sources such as pipelines or vessels. Spill volumes that could result from a 

loss of well control typically exceed those from other potential sources. A spill from a pipeline at or near the 

seafloor is accessible for repairs and the flow into the pipeline can be shut in. A failure of the production safety 

system may result in the release of gas, condensate, oil, sand, or water.

The rule does not require the use of new technologies, procedures and/or materials that could directly result in 

environmental impacts. The inspections, maintenance, testing, and equipment configurations required by the rule 

will be implemented with routine procedures used on OCS facilities. 

The rule includes seventy-one subsections related to the (mostly) procedural effects of new requirements. These 

subsections address requirements for reporting and record keeping, testing, inspections and maintenance, surface 

and subsurface safety systems, production safety systems, and safety devices. These subsections will not result in 

negative impacts because standard operational procedures and equipment will be used to implement their 

technological requirements, and they will result in redundant well control protection without jeopardizing the 

protection provided by current regulations.
U.S. Department of the Interior 30 CFR Part 250

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The following updates and revisions to 30 CFR Part 250 have been reviewed and found to be regulations for which 

the impacts are limited to procedural/technological effects and the impacts are minimal; no significant impacts are 

anticipated as a result of these revisions and are therefore not analyzed further:

250.802(a), (b), (c)(1), (c)(2), (c)(3), (c)(4), (c)(5), (c)(6), (c)(7), (d)(1-3), (e) Requirements for SPPE.

250.803(b), (c) What SPPE failure reporting procedures must I follow? 

250.804 When must I use BAST?

250.817(b), (c), (d) Temporary removal of subsurface safety devices for routine operations.

250.821(a)(2) Emergency action.

250.825(b) Subsea tree subsurface safety devices - general.

250.829(a)(3)(i-iv) Subsurface safety devices in shut-in wells – subsea trees.

250.831 Alteration or disconnection of subsea pipeline or umbilical

250.833(a)(b) Specification for underwater safety valves (USVs)

250.835(b), (c), (d) Specification for all boarding shut down valves (BSDVs) associated with subsea systems.

250.837 Emergency action and safety system shutdown.

250.838 What are the maximum allowable valve closure times and hydraulic bleeding requirements for an 

electro-hydraulic control system?

250.839 What are the maximum allowable valve closure times and hydraulic bleeding requirements for 

direct-hydraulic control system?

250.840 Design, installation, and maintenance - general.

250.841(b) Platforms.

250.842(a)(3)(ii)(A-B), (a)(3)(iii) Approval of safety systems design and installation features.

250.851(a)(2), (a)(4-7), (b), (c)(1), (c)(2) Pressure vessels (including heat exchangers) and fired vessels.

250.852(c)(2), (d), (f), (g), (h) Flowlines/Headers.

250.854 Floating production units equipped with turrets and turret mounted systems.

250.857(b), (c) Glycol dehydration units.

250.858(c) Gas compressors.

250.859(a)(5), (b) Firefighting systems.

250.860(c) Chemical firefighting system.

250.861 Foam firefighting system.

250.865(b-f) Surface pumps.

250.866 Personnel safety equipment.

250.867(b) Temporary quarters.

250.868 Non-metallic piping.

250.869(a)(1), (a)(2), (a)(2)(i-iv), (a)(3)(i-viii), (b), (b)(1), (b)(2), (d), (e) General platform operations.

250.870 Time delays on PSL sensors.

250.872(b), (c) Atmospheric vessels.

250.873(b)(1-3), (d)(i-iii) Subsea gas lift requirements.

250.874(b), (c), (d), (e), (g)(1)(i-ii), (g)(2-3) Subsea water injection systems.

250.875(a), (b), (c), (e) Subsea Pump Systems.

250.876 Fired and Exhaust Heated Components. 

250.880(a)(1-3), (b)(1), (c)(2)(i), (c)(3)(iii-iv), (c)(4)(ii), (c)(4)(iv-v), (c)(5)(i-ii), (c)(5)(ii)(B), (c)(5)(iii-vi) 

Production safety system testing.

250.891 Safety device training.

250.802 (d)(1-3) Requirements for SPPE.

The subsection states, “You must install certified SPPE according to the following table:”

If... Then...

(1) You need to install any SPPE... You must install certified SPPE.

(2) A non-certified SPPE is already in service... It may remain in service on that well.

(3) A non-certified SPPE requires offsite repair, remanufacturing, or any hot work such as welding...You must replace it with certified SPPE.
U.S. Department of the Interior 30 CFR Part 250

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This subsection requires the operator to certify all SPPE as they need maintenance and/or replacement. The 

regulations set forth in 250.801 and 250.802 specify detailed requirements of all safety and shut down valves, and 

the installation, maintenance, and certification thereof. These are procedural steps to ensure the certification of

safety and pollution prevention equipment. No impact is expected from the use of certified safety equipment. 

Therefore, this subsection would not benefit from further analysis. 

250.833(a)(b) Specification for underwater safety valves (USVs)

The subsection states: “(a) Primary USV (USV1). You must install and designate one USV on a subsea tree as the 

USV1. The USV1 must be located upstream of the choke valve. 

(b) Secondary USV (USV2). You may equip your tree with two or more valves qualified to be designated as a 

USV, one of which may be designated as USV2. If the USV1 fails to operate properly or exhibits a leakage rate 

greater than allowed in § 250.880, you must notify the appropriate BSEE District Office and designate the USV2 or 

another qualified valve (e.g., an AIV) that meets all the requirements of this subpart for USVs as the USV1...”

USVs are regulated in §§250.801 through 250.803 as well as API Spec. 6A and 6AVI incorporated by reference

under §250.198. The requirement for both a primary and secondary underwater safety valve comes from common 

conditions of approval of DWOP, as clarified by NTL 2009-G36. This gives industry the option to have redundant 

components, saving time and money to designate a primary and a secondary valve, eliminating the potential need to 

retrofit the system with valves that meet the stringent requirements for a USV. This also saves BSEE the time 

required for reviewing multiple submittals for USV designation. 

This subsection requires redundancy in USVs in addition to industry standard practice to conserve resources and 

would not benefit from further analysis. 

250.868 Non-metallic piping.

The subsection states: “You may use non-metallic piping, such as that made from polyvinyl chloride, chlorinated 

polyvinyl chloride (PVC), and reinforced fiberglass only in atmospheric, primarily non-hydrocarbon service such as:

(a) Piping in galleys and living quarters;

(b) Open atmospheric drain systems;

(c) Overboard water piping for atmospheric produced water systems; and 

(d) Firewater system piping.”

BSEE is specifying the kind of pipe used for these systems so that hydrocarbons are not transmitted through unrated 

PVC pipe. Non-metallic piping is not rated for that kind of service and could be dangerous if used. BSEE wants to 

make certain all hydrocarbon piping is able to withstand the pressures and stresses. This is a technological 

requirement that ensures piping is not subject to corrosive liquids that would otherwise have the potential to cause 

an accident or negative impact. No impact is expected from the promulgation of this requirement and would not

benefit from further analysis.

250.880 Production safety system testing.

In proposed § 250.880, BSEE would revise existing requirements to increase certain liquid leakage rates from 200 

cubic centimeters per minute to 400 cubic centimeters per minute and gas leakage rates from 5 cubic feet per minute 

to 15 cubic feet per minute. These devices exist within a closed system and will leak over time with operational use.

These proposed changes reflect consistency with industry standards (and are already incorporated by reference at 

250.198) and account for accessibility of equipment in deepwater/subsea applications. In 1999, the former Minerals 

Management Service funded Technology Assessment and Research Project #272, “Allowable Leakage Rates and 

Reliability of Safety and Pollution Prevention Equipment”, to review increased leakage rates for safety and pollution 

prevention equipment. In the recommendations section of this study, it states, “there appears to be preliminary 

evidence indicating that more stringent leakage requirements specified in 30 CFR 250 may not significantly increase 

the level of safety when compared to the leakage rates recommended by API”. Requirements for valves that are 

required to have ‘zero leakage’ are not changing. 
U.S. Department of the Interior 30 CFR Part 250

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4.2 No Action Alternative

To take “no action” would mean that the revisions to 30 CFR Part 250 would not be incorporated into federal 

regulation. However, if these revisions are not implemented, the intended benefits will not be realized. Under the 

No Action Alternative a reduction in risk of additional OCS oil spills affecting coastal and marine environments 

would not be realized.

The risk of an unauthorized discharge under the no action alternative would be greater, though still remote, than the 

risk under the proposed action. Below is a synopsis of biological resources that could potentially be impacted by a 

catastrophic spill, based on the example of DWH, however, this proposed rule applies to the national OCS Oil and 

Gas program (including the Gulf of Mexico Region). Implementing the No Action Alternative will result in a 

failure to reduce the risk of impacts such as those described below.

Biological Resources: Though it has not been determined that population level effects have been reached, the 

Deepwater Horizon incident has demonstrated that a high volume, extended spill resulting from a blowout has the 

potential to cause population level impacts, unlike smaller spills in the Gulf of Mexico. 

Marine Mammals: Whales, dolphins and manatees can be exposed to chemicals in oil or dispersants in 

several ways: Internal exposure by consuming oil or contaminated prey or inhaling volatile oil and

dispersant-related compounds; external exposure, by swimming in oil or dispersants and having oil or

dispersants directly on the skin and body; and maternal transfer of contaminants to embryos. In addition to 

chemical exposure, response activities, such as collecting and burning oil at sea, skimmer operations, boom

deployment, berm construction and boat traffic could directly injure marine mammals or cause behavioral 

changes.1

Sea Turtles: Sea turtles can be exposed to chemicals in oil or dispersants in several ways: Internal exposure by 

consuming oil or contaminated prey or inhaling volatile oil and dispersant-related compounds; external exposure to 

sea turtles or eggs from oiled nesting beaches, external exposure by swimming in oil or dispersants and having oil or 

dispersants directly on the skin and body, and maternal transfer of contaminants to embryos and eggs. In addition to 

chemical exposure, response activities, such as collecting and burning oil at sea, skimmer operations, boom

deployment, berm construction, increased light at night on or near nesting beaches, equipment use and storage as a 

result of beach cleanup operations and boat traffic could directly injure sea turtles, block access to turtle nesting 

beaches and/or cause behavioral changes. 2

Coastal and Marine Birds: Birds are likely to be exposed to chemicals in oil or dispersants in a number of ways: 

External exposure directly to skin and feathers caused by resting on the water's surface and diving beneath the 

water’s surface, and utilizing oiled beaches and marshes; internal exposure as the animals preen and try to clean 

their feathers; internal exposure as they as they feed in contaminated water and adjacent beaches and vegetated 

areas, or inhale volatile oil-related compounds; maternal transfer of contaminants to embryos and eggs. Oiled birds 

can lose the ability to fly, dive for food or float on the water, which can lead to drowning. Oil interferes with the

water repellency of feathers and can lead to hypothermia. In addition, birds may ingest or inhale oil while cleaning 

(preening) their feathers, by consuming contaminated vegetation or prey, or by incidental ingestion of contaminated 

sediment. This can either kill the bird or lead to long-term physiological, metabolic, developmental, and behavioral 

effects which ultimately lead to reduced survival and reproduction. Exposure also can reduce the hatching of eggs 

and survival of hatchlings. Therefore, avian injury can be identified through acute mortality, productivity loss, and 

decrease in reproductive success, sublethal effects and loss of prey resources. Seabirds, colonial waterbirds, coastal

marsh birds, shorebirds and a variety of other birds occurring in coastal areas may be susceptible to oiling impacts.3

Fisheries: Fish are exposed to dissolved oil and dispersants and oil droplets through a variety of pathways, including 

direct dermal contact (e.g., swimming through oil and dispersants or waters with elevated dissolved hydrocarbon 

concentrations and other constituents), ingestion (e.g., via food base) and inhalation (e.g., elevated dissolved 

 

1

http://www.gulfspillrestoration.noaa.gov/wp-content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf

2

http://www.gulfspillrestoration.noaa.gov/wp-content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf

3

http://www.gulfspillrestoration.noaa.gov/wp-content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf
U.S. Department of the Interior 30 CFR Part 250

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contaminant concentrations in water passing over the gills). Fish that have recently ingested contaminated prey may 

themselves be a source of contamination for their predators. Further, certain petroleum metabolites can be toxic to 

fish, and the fish can experience stress, reproductive failure and other sublethal effects while metabolizing

hydrocarbons. Studies have suggested that sublethal hydrocarbon exposure on fish can lead to the development of 

lesions. Eggs and larvae of many fish species are highly sensitive to oil exposure, resulting in decreased spawning 

success and abnormal larval development. Other potential direct effects that may occur as a result of exposure to 

hydrocarbons include reduced growth, enlarged livers, changes in heart and respiration rates, fin erosion, and 

reproductive impairment. Recent results from studies looking at potential synergetic effects of dispersants in oil 

exposure have suggested that the dispersants make it easier to move hydrocarbons across membranes – and thus may

enhance exposure. Fish also may be indirectly impacted through degradation of supporting habitat or food base.

Many fish species can metabolize toxic hydrocarbons, which reduces the risk of human exposure to contaminants 

through seafood and the bioaccumulation of contaminants in the food web. There is ample scientific evidence, 

however, that hydrocarbon exposure can result in negative effects (both lethal and sublethal) on fish health and on 

fisheries populations. Fish also can be affected by consumption of contaminated prey and, in turn, can affect upper 

level predators if they have only recently been exposed to toxic hydrocarbons.

Oysters can be exposed to oil and dispersants through dermal contact, feeding and respiration in all life stages and 

through filtration (feeding) for adult life stages. Direct impacts on eggs and larval survival, or changes in the

ecosystem that support the oyster (e.g., reduced water quality) due to oil impacts, also constitute modes of exposure. 

Adult oysters may experience reduced growth and reproductive impairment when exposed to oil. Exposure to water 

quality changes has both direct and indirect impacts on adult oysters as well as on eggs and larval survival. Exposure

to water quality changes can also adversely impact the health of oyster habitat and the ecosystem that supports 

oysters. Once these animals spawn, early larval stages move with the currents near the surface of the water and are 

unable to actively avoid potential injury from exposure to oil, dispersants and other response activities.4 A 

catastrophic spill has the potential to cause the loss of a year class, effecting future stock populations. In addition to 

impacts of oil in coastal waters on shellfish, oyster beds have been damaged by freshwater diversions releasing tens 

of thousands cubic feet of freshwater per second for months in an effort to keep oil out of the marshes. Oyster beds 

could take 2-5 years to recover.5

Nearshore Habitats: Oil and dispersants reaching the nearshore environment are transported on the surface of the

water column by wind and currents. For oil to become incorporated into the bottom sediment, oil particles that are

buoyant must either weather to a dense asphaltic material that can then sink to the bottom or absorb to or adhere to a

heavier particle and sink. Oil droplets may sink as a result of being absorbed onto either marine detritus (non-living

particulate organic material) or inorganic sediment (e.g., sediment particulate introduced to the Gulf from the 

Mississippi River). These same particles can be consumed by organisms and eliminated in excretions (i.e., fecal 

pellets) that sink. Finally, oil that was deposited on shore mixed with sediment and washed back out with the tide, 

eventually settling to the bottom, can result in exposure. This submerged oil creates a hazard to the wide variety of 

organisms that live in the nearshore environment, including grasses, benthic fish, crabs and other invertebrates. 

Many of these animals forage in the sediments for food and are susceptible to oil through dermal contact and intake 

by respiration and direct ingestion. Shrimp and crab species could be impacted from an oil spill due to direct 

mortality of adults or post larvae or due to sublethal impacts such as reduced reproductive success.6

Terrestrial Mammals: Terrestrial species are potentially injured by a spill along with their terrestrial and aquatic

habitats. When oil reaches land, it can severely impact coastal habitats including marshes, mudflats, mangrove 

stands and beaches. The organisms that use these habitats are at risk from direct fouling by the oil, as well as

exposure via consumption of prey that has been contaminated by the oil spill. In particular, diamondback terrapins 

are susceptible to adverse effects from the spill because they inhabit brackish water, spending most of their lives at 

the aquatic-terrestrial boundary in estuaries. Otter and mink may also forage and shelter in contaminated estuarine

environments. Many habitats used by these species likely were negatively impacted by response activities such as

shoreline cleanup efforts, placement of boom and siting of land-based staging areas.7

 

4

http://www.gulfspillrestoration.noaa.gov/wp-content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf

5

http://www.nola.com/news/gulf-oil-spill/index.ssf/2010/07/widespread_oyster_deaths_found.html; 

http://www.wwltv.com/news/gulf-oil-spill/Concerns-Raised-About-Health-Of-Oyster-Beds-Impacted-By-FreshWater-Diversions-98867889.html

6

http://www.gulfspillrestoration.noaa.gov/wp-content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf

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Commercial and Recreational Fishing: Humans, like wildlife, rely on the natural resources of the Gulf of Mexico. 

Outdoor recreationists make more than 150 million trips per year to the Gulf of Mexico. From fishing to sunbathing 

to bird watching and countless other recreational activities, people depend on Gulf Coast waters and nearshore

environments for valuable recreational, cultural and ecological resources and services. Tourism and recreation are 

large contributors to the Gulf of Mexico economy. There are more than 640,000 jobs yielding more than $10 billion 

in tourism and recreation wages paid each year in the Gulf Coast region. In 2009, 2.8 million recreational fishermen 

from the four Gulf of Mexico states participating in the Marine Recreational Fisheries Survey (Florida, Alabama, 

Mississippi and Louisiana) took at least one fishing trip in the Gulf of Mexico region. When recreational fishermen 

visiting from outside these four states are included, approximately 23 million individual fishing trips occurred in the 

Gulf of Mexico. The Gulf region leads the nation in oyster production, with some 67 percent of the total harvest in 

2008. Just the threat of oil exposure can cause beaches and fisheries to be closed to protect the environment and 

public health. Enjoyment of activities such as boating, fishing, hunting, swimming, sunbathing and wildlife 

viewing may be diminished, not only by the presence of oil but also by the threat of oil and by response activities. 

Under OPA a compensable injury has occurred when the public’s access to the enjoyment of their natural resources 

is denied or restricted in some way due to an oil spill.8

 

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Bureau of Ocean Energy Management Environmental Assessment

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5.0 REFERENCES

American Petroleum Institute. API 570 Piping Inspection Code: In-service Inspection, Rating, Repair, and 

Alteration of Piping Systems, Third Edition. November 2009.

ANSI/ASME Boiler and Pressure Vessel Code, Section I, Rules for Construction of Power Boilers; including 

Appendices, 2004 Edition; and July 1, 2005 Addenda, and all Section I Interpretations Volume 55, 

incorporated by reference at §§ 250.851(a)(1)(i), (a)(4)(iii), (a)(5)(i), and 250.1629(b)(1), (b)(1)(i). 

ANSI/ASME Boiler and Pressure Vessel Code, Section IV, Rules for Construction of Heating Boilers; including 

Appendices 1, 2, 3, 5, 6, and Non-mandatory Appendices B, C, D, E, F, H, I, K, L, and M, and the Guide to 

Manufacturers Data Report Forms, 2004 Edition; July 1, 2005 Addenda, and all Section IV Interpretations 

Volume 55, incorporated by reference at §§ 250.851(a)(1)(i), (a)(4)(iii), (a)(5)(i), and 250.1629(b)(1), (b)(1)(i).

ANSI/ASME Boiler and Pressure Vessel Code, Section VIII, Rules for Construction of Pressure Vessels; Divisions 

1 and 2, 2004 Edition; July 1, 2005 Addenda, Divisions 1, 2, and 3 and all Section VIII Interpretations 

Volumes 54 and 55, incorporated by reference at §§ 250.851(a)(1)(i), (a)(4)(iii), (a)(5)(i), and 250.1629(b)(1), 

(b)(1)(i).

ANSI/API Spec. 14A, Specification for Subsurface Safety Valve Equipment, Eleventh Edition, October 2005, 

Effective Date: May 1, 2006; also available as ISO 10432:2004 (Identical), Petroleum and natural gas 

industries—Downhole equipment—Subsurface safety valve equipment, Product No. GX14A11; incorporated 

by reference at §§ 250.802(b) and 250.803(a) 

ANSI/API Spec. 17J, Specification for Unbonded Flexible Pipe, Third Edition, July 2008, Effective Date: January 

1, 2009, Contains API Monogram Annex as part of US National Adoption; also available as ISO 13628-

2:2006 (Identical), Petroleum and natural gas industries—Design and operation of subsea production 

systems—Part 2: Unbonded flexible pipe systems for subsea and marine application; Product No. GX17J03; 

incorporated by reference at §§ 250.852(e)(1), (e)(4), 250.1002(b)(4), and 250.1007(a)(4)(i)(D). 

API 510, Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration, Downstream 

Segment, Ninth Edition, June 2006, Product No. C51009; incorporated by reference at §§ 250.851(a)(1)(ii) and 

250.1629(b)(1);

API RP 2RD, Recommended Practice for Design of Risers for Floating Production Systems (FPSs) and Tension-Leg 

Platforms (TLPs), First Edition, June 1998; reaffirmed, May 2006, Errata, June 2009; Order No. G02RD1; 

incorporated by reference at §§ 250.800(c)(2), 250.901(a), (d), and 250.1002(b)(5);

API RP 2SK, Recommended Practice for Design and Analysis of Stationkeeping Systems for Floating Structures, 

Third Edition, October 2005, Addendum, May 2008, Product No. G2SK03; incorporated by reference at §§ 

250.800(c)(3) and 250.901(a), (d);

API RP 2SM, Recommended Practice for Design, Manufacture, Installation, and Maintenance of Synthetic Fiber 

Ropes for Offshore Mooring, First Edition, March 2001, Addendum, May 2007; incorporated by reference at 

§§ 250.800(c)(3) and 250.901;

API RP 14B, Recommended Practice for Design, Installation, Repair and Operation of Subsurface Safety Valve 

Systems, ANSI/API Recommended Practice 14B, Fifth Edition, October 2005, also available as ISO 10417: 

2004, (Identical) Petroleum and natural gas industries—Subsurface safety valve systems—Design, installation, 

operation and redress, Product No. GX14B05; incorporated by reference at §§ 250.802(b), 250.803(a), 

250.814(d), 250.828(c), and 250.880(c)(1)(i), (c)(4)(i), (c)(5)(ii)(A);

API RP 14C, Recommended Practice for Analysis, Design, Installation, and Testing of Basic Surface Safety 

Systems for Offshore Production Platforms, Seventh Edition, March 2001, Reaffirmed: March 2007; Product 

No. C14C07; incorporated by reference at §§ 250.125(a)(10), 250.292(j), 250.841(a), 250.842(a)(2), 250.850, 
U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

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250.852(a)(1), 250.855, 250.858(a), 250.862(e), 250.867(a), 250.869(a)(3), (b), (c), 250.872(a), 250.873(a), 

250.874(a), 250.880(b)(2), (c)(2)(v), 250.1002(d), 250.1004(b)(9), 250.1628(c), (d)(2), 250.1629(b)(2), 

(b)(4)(v), and 250.1630(a);

API RP 14E, Recommended Practice for Design and Installation of Offshore Production Platform Piping Systems, 

Fifth Edition, October 1991; Reaffirmed, March 2007, Order No. 811-07185; incorporated by reference at §§ 

250.841(b), 250.842(a)(1), and 250.1628(b)(2), (d)(3); 

API RP 14F, Recommended Practice for Design, Installation, and Maintenance of Electrical Systems for Fixed and 

Floating Offshore Petroleum Facilities for Unclassified and Class 1, Division 1 and Division 2 Locations, 

Upstream Segment, Fifth Edition, July 2008, Product No. G14F05; incorporated by reference §§ 250.114(c), 

250.842(b)(1), 250.862(e), and 250.1629(b)(4)(v);

API RP 14FZ, Recommended Practice for Design and Installation of Electrical Systems for Fixed and Floating 

Offshore Petroleum Facilities for Unclassified and Class I, Zone 0, Zone 1 and Zone 2 Locations, First Edition, 

September 2001, Reaffirmed: March 2007; Product No. G14FZ1; incorporated by reference at §§ 250.114(c), 

250.842(b)(1), 250.862(e), and 250.1629(b)(4)(v);

API RP 14G, Recommended Practice for Fire Prevention and Control on Fixed Open-type Offshore Production 

Platforms, Fourth Edition, April 2007; Product No. G14G04; incorporated by reference at §§ 250.859(a), 

250.862(e), and 250.1629(b)(3), (b)(4)(v);

API RP 14H, Recommended Practice for Installation, Maintenance and Repair of Surface Safety Valves and 

Underwater Safety Valves Offshore, Fifth Edition, August 2007, Product No. G14H05; incorporated by 

reference at §§ 250.820, 250.834, 250.836, and 250.880(c)(2)(iv), (c)(4)(iii);

API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, Second 

Edition, May 2001; Reaffirmed: March 2007; Product No. G14J02; incorporated by reference at 

§§ 250.800(b), (c)(1), 250.842(b)(3),and 250.901(a)(14);

API RP 500, Recommended Practice for Classification of Locations for Electrical Installations at Petroleum 

Facilities Classified as Class I, Division 1 and Division 2, Second Edition, November 1997; Errata August 17, 

1998, Reaffirmed November 2002, API Stock No. C50002; incorporated by reference at §§ 250.114(a), 

250.459, 250.842(a)(3)(i), 250.862(a), (e), 250.1628(b)(3), (d)(4)(i), and 250.1629(b)(4)(i);

API RP 505, Recommended Practice for Classification of Locations for Electrical Installations at Petroleum 

Facilities Classified as Class I, Zone 0, Zone 1, and Zone 2, First Edition, November 1997; Errata August 17, 

1998, American National Standards Institute, ANSI/API RP 505-1998, Approved: January 7, 1998, Order No. 

C50501; incorporated by reference at §§ 250.114(a), 250.459, 250.842(a)(3)(i), 250.862(a), (e), 

250.1628(b)(3), (d)(4)(i), and 250.1629(b)(4)(i);

ANSI/API Spec. Q1, Specification for Quality Programs for the Petroleum, Petrochemical and Natural Gas Industry, 

Eighth Edition, December 2007, Effective Date: June 15, 2008, Addendum 1, June 2010, Effective Date: 

December 1, 2010; also available as ISO TS 29001:2007 (Identical), Petroleum, petrochemical and natural gas 

industries—Sector specific requirements—Requirements for product and service supply organizations, 

Effective Date: December 15, 2003, API Stock No. GQ1007; incorporated by reference at § 250.801(b), (c);

API Spec. 6A, Specification for Wellhead and Christmas Tree Equipment, Nineteenth Edition, July 2004, Effective 

Date: February 1, 2005; Contains API Monogram Annex as part of US National Adoption; also available as 

ISO 10423:2003 (Modified), Petroleum and natural gas industries—Drilling and production equipment—

Wellhead and Christmas tree equipment; Errata 1, September 2004, Errata 2, April 2005, Errata 3, June 2006, 

Errata 4, August 2007, Errata 5, May 2009, Addendum 1, February 2008, Addendum 2, December 2008, 

Addendum 3, December 2008, Addendum 4, December 2008, Product No. GX06A19; incorporated by 

reference at §§ 250.802(a), 250.803(a), 250.873(b), (b)(3)(iii), 250.874(g)(2) and 250.1002 (b)(1), (b)(2); 
U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

12

API Spec. 6AV1, Specification for Verification Test of Wellhead Surface Safety Valves and Underwater Safety 

Valves for Offshore Service, First Edition, February 1, 1996; reaffirmed January 2003, API Stock No. 

G06AV1; incorporated by reference at §§ 250.802(a), 250.833, 250.873(b) and 250.874(g)(2);

API 570 Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems, Third 

Edition, November 2009; Product No. C57003; incorporated by reference at § 250.841(b).

Natural Resource Damage Assessment April 2012 Status Update for the Deepwater Horizon Oil Spill; April 2012; 

NOAA federal partnership; http://www.gulfspillrestoration.noaa.gov/wpcontent/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf

6.0 LIST OF PREPARERS

Keely Hite – Environmental Protection Specialist, Division of Environmental Assessment

Bureau of Ocean Energy Management
U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

13

The Department of the Interior Mission

As the Nation's principal conservation agency, the Department of the Interior has responsibility for most

of our nationally owned public lands and natural resources. This includes fostering sound use of our

land and water resources; protecting our fish, wildlife, and biological diversity; preserving the

environmental and cultural values of our national parks and historical places; and providing for the

enjoyment of life through outdoor recreation. The Department assesses our energy and mineral

resources and works to ensure that their development is in the best interests of all our people by

encouraging stewardship and citizen participation in their care. The Department also has a major

responsibility for American Indian reservation communities and for people who live in island territories

under U.S. administration.

The Bureau of Ocean Energy Management Mission

The Bureau of Ocean Energy Management (BOEM) manages the exploration and development of the 

nation's offshore resources. It seeks to appropriately balance economic development, energy 

independence, and environmental protection through oil and gas leases, renewable energy development 

and environmental reviews and studies.

The Bureau of Safety and Environmental Management Mission

BSEE works to promote safety, protect the environment, and conserve resources offshore through 

vigorous regulatory oversight and enforcement.