OCS EIS/EA BOEM


# Oil and Gas and Sulphur Operations on **the Outer Continental Shelf —**  **Oil and Gas Production Safety Syste ms**  **for 30 CFR Part**  **250 Subpart H** 
**Environmental Assessment October**  **201 2** 

**U.S. Department of the Interior Herndon**  **Bureau of Ocean Energy Management**  **October 2012** 

### D **RA FT FINDING OF NO SIGNIFICA**  **NT IMPA CT (FONSI)**  **Oil and Gas and Sulphur Operations on the Outer Continental Shelf**

**— Oil and Gas Production Safety System**  **s**
(Refer to attached FONSI)

## T **ABLE OF** 

## C **ONTENTS**

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
................................ ................................ ................................ .............................. 12U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

1 

# 1.0 **INTRODUCTION 1.1**  **Background and Overview** The Department of the Interior is mandated under the Outer Cont inental Shelf Lands Act (OCSLA) to m anage the orderly leasing, exploration, development, and production of mineral resour ces 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. T o 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 invol ving 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 com pliance with this rule and the associated implementation of operational procedures to im prove production safety systems could have a significant im pact on th e hum an 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 environmenta l impacts or activities that have been previously codified into regulation. These subsections are categorized by the nature of the requirement below. N o significant impacts are anticipated as a result of these revisions and they are therefore not analyze d further
. 1. A ctivities which are informational or advisory in nature: **250.198 (h)**  **(8 9) Docum**  **ents Incorporated by Reference 250.801(c)**  **Safety and pollution prevention equipment (SPPE) certification. 250.851(a)(3)**  **Pressure vessels (including heat e xchangers) and fired vessels.**  **250.869(c) General platform operations.**  2. Updates and revisions to 30 CFR Part 250 that are a ctivities that have been previously codified into regulation : **250.107 (c**  **) (1), (c**  **) (1)(i), (c**  **) (1)(ii)**  **What m ust 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) Docu**  **me nts 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 SSS**  **Vs. 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 equi**  **pm ent** 
**– dry trees.**  **250.819 Specification for surface safety valves**  **(SSVs). 250.820**  **Use of SSVs. 250.821**  **(b )**  **Em ergency action.**  **250.826 Specifications for SSSVs** 

**– subsea trees.**  **250.82 7**  **Surface -**  **controlled SSSVs**

**– subsea trees.**  **250.82 8**  **Design, inst allation, and operation of SSSVs** 

**– subsea trees.** U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

2 **250.82 9**  **(a), (a)(1), (a)(2) , (b)**  **Subsurface safety devices in shut -**  **in wells**

**– subsea trees.**  **250.8 30**  **Subsurface safety devices in injection wells**

**– subsea trees.**  **250.832 Additional safety equipment** 

**– sub**  **sea 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)**  **Platform s.**  **250.84 2**  **(a)(2), (a)(3)(i) , (b)(1**  **) , (b)(3)**  **Approval of safety systems des ign 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) Em**  **ergency shutdown system (ESD ).**  **250.856 (a), (b)**  **Engines. 250.857**  **(a) Glycol dehydration units.**  **250.858(a) (1**  **- 4)**  **Gas com pressors.**  **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) Tem**  **porary quarters. 250.869**  **(a) , (a)(3)**  **General platform operations.**  **250.871 Welding and burning practices and procedures.**  **250.872(a) Atm ospheric vessels.**  **250.8 73(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)( i**  **i -**  **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 Sec tion 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 w ould not benefit from further analysis. **250.80 1**  **(a) Safety and pollution prevention equipment (SPPE) certification .**  The language in this section already exists in federal regulation under the current 250.80 6, 250.900, and 250.921
. This requirement is purely administrative and w ould not benefit from further analysis. **250.80 5 Additional requirements for subsurface sa**  **fety valves and related equipment installed in high pressure high temperature (HPHT) environm**  **ents .**  The language in this section already exists in federal regulation under the current 250.80 7
. This requirement is purely administrative and w ould not benefit from further analysis. 3. Regulations for which the impacts are limited to administrative effects and the refore have no impact on the environment : **250.1 07**  **(2 )**  **What m ust I do to protect health, safety, property, and the environm**  **ent? 250.801(b)**  **Safety and pollution prevention equipment (SPPE) certification.**  **250.803 (a**  **) What SPPE failure reporting procedures must I follow?**  **250.84 2**  **(a)(1) , (b)(2)**  **, (c), (d), (f) Approval of safety systems design and installation features.**  **250.850 Production system re**  **quirements -**  **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

Bureau of Ocean Energy Management Environmental Assessment

3 **250.873(c)(1 -**  **3) Subsea gas lift requirements.**  **250.890 Records.** 

## 1.2 **Purpose and Need** The purpose of the proposed Federal a cti on 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 w ith oil and gas production on the OCS and related t echnologies. 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 preparednes s . The need to revis e these regulations is im portant to im

prove the safety of oil and gas production operations on the OCS. 

# 2.0 **PROPOSED AC**  **TION AN**  **D AL**  **TERNA TIVES**  This chapter describes the proposed action and the no action alternative, as required by Council o n 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 necessar y 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 hav e 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 sys tem 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 w ith 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) Rew rite 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 w ould keep the existing 1988 30 CFR Part 250 regulations that apply to production safety systems
. No ne 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 , wo uld be implemented. This alternative w ould not allow for the proper management and oversight of OCS production operations by requiring compliance with current industry standards. 

# 3.0 **AF FECTED ENVIRONMENT**  E xplosions, fires, and discharges on production platforms can caus e human injury and mortality and impacts to the biota and w ater and air quality. A catastrophic oil spill resulting from a production safety system failure can affect biological, socioeconomic, and sociocultural resources over extensi ve coastal and offshore areas. Because of the large area over which the environmenta l effects of a n 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 **ENVIRONMENT**

**AL CONSEQUENCES**  **4.1 Proposed Action**  Th is r ule ma king proposes new and revised regulations to improve producti on safety systems and related procedures that will reduce the occurrence of associated incidents a nd spills ( catastrophic or otherw ise) . This rule will not affect the likelihood of oil spills from other sources such as pipeline s or vessel s . Spill volume s that could result from a loss of well control ty

pically 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 w ater . 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 r ule includes seventy - one subsections related to the (mostly) procedural effects of new requirements. These subsections address requi rements 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 w ell control protection without jeopardizing the protection provided by current regulations.U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

5 The follow ing 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) Requirem ents 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) Tem**  **porary rem**  **oval of subsurface safety devices for routine operations. 250.821(a)(2) Em**  **ergency 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 Alterati on 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 Em ergency action**  **and safety system shutdown.**  **250.838 What are the m aximum allowable valve closure tim**  **es and hydraulic bleeding requirements for an electro**  **- hydraulic control system**  **? 250.839 What are the m**  **aximum allowable valve closure tim es and hydraulic bleeding requir**  **em ents for**  **direct -**  **hydraulic control system ?**  **250.840 Design, installation, and m aintenance**  **- general.**  **250.841(b) Platform s.**  **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 m ounted systems.**  **250.857 (b**  **) , (c)**  **Glycol dehydrat ion units.**  **250.858(c ) Gas com**  **pressors. 250.859**  **(a)(5 )**  **, (b) Firefighting systems.**  **250.860(c ) Chem**  **ical firefighting system. 250.861 Foam** **firefighting system .**  **250.865( b**  **- f** 

**) Surface pum ps.**  **250.866 Personnel safety equipment. 250.867**  **(b) Temporary qu arters.**  **250.868 Non**  **- me**  **tallic 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) Atm ospheric vessels.**  **250.873 (b)(1**  **- 3)**  **, (d)(i -**  **ii i) 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 Com ponents.**  **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) Requirem**  **ents for SPPE.** The subsection states, “You must install certified SPPE accordi ng 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 m ay remain in service on that w ell. (3) A non
- certified SPPE requires offsite repair, re
manu facturing, or any hot w ork such as welding... You must replace it with certified SPPE.U.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

6 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 certif ication of safety and pollution prevention equipment . No impact is expected from the use of cert ified safety equipment. Therefore, this subsection wo uld 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 w ith tw o or m ore valves qualified to be designated as a USV, one of which may be designated as USV2. If the USV1 fails t o 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 w ell as API Spec. 6A and 6AVI incorporated by reference under §250.198. Th e requirement for both a primary and secondary underw ater safety valve com es from comm on conditions of approval of DWOP , as clarified by NTL 2009
- G36. This gives industry the option to have redundant components, sav ing 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 review ing multiple submittals for USV designation. This subsection requires redundancy in USVs in addition to industry standard practice to conserve resources and wo uld not benefit from further analysis.
**250.868 Non -**  **me tallic 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
- hyd rocarbon service such as: (a) Piping in galleys and living quarters; (b) Open atmospheric drain systems; (c) Overboard w ater piping for atmospheric produced w ater systems; and (d) Firew ater system piping. ” BSEE is specifying the kind of pipe used for these systems so that hydrocarbons are not transmitted through unrated PVC pipe. N on - metallic piping is not rated for that kind of service and could be dangerous if used
. BSEE want s to make certain all hydrocarbon piping is able to withst and the pre ssures and stresses
. Th is is a technological requirement that ensure s 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 requirem ent and w ould 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 centime ters 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 (an d 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 Rat es 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 indicatin g 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 w ould not be incorporated into federal regulation. How ever, if the se revisions are not implemented, the intended benefits will not be realized. Under the No Ac tion Alternative a reduction in risk of additional OCS oil spills affecting coastal and marine environments wo uld not be realized. T he 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 , how ever, this proposed rule applies to the national OCS Oil and Gas program (including the Gulf of Mexico Region)
. Im plementing the No Action Alternative will result in a fail ure to reduce the risk of impacts such as those described below
. Biological Resources: Though it has not be en determined that population level effects have been reached, the D eepw ater Horizon incident has demonstrated that a high volume, extended spill resulting from a blow out has the potential to cause population level impacts, unlike smaller spills in the Gulf of Mexico. Marine Mammals : Wh ales, dolphins and manatees can be exposed to chemicals in oil or dispersants in several ways: I nternal exposure by consuming oil or contaminated prey or inhaling volatile oil and dispersant
- related com

pounds ; e xternal exposure, by swimming in oil or dispersants and having oil or dispersants directly on the skin and body ; and maternal transfer of contam inants 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 c ould 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 cons uming oil or contaminated prey or inhaling volatile oil and dispersant
- related compounds ; e xternal exposure to sea turtles or eggs from oiled nesting beaches, e xternal exposure by swimming in oil or dispersants and having oil or dispersants directly on the skin and body, and m aternal transfer of contaminants to embryos and e ggs. 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 bea ch 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 wa ys: 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; i nternal exposure as the animals preen and try to clean their feathers; i ntern al exposure as they as they feed in contaminated w ater and adjacent beaches and vegetated areas, or inhale volatile oil
- related compounds; m aternal transfer of contaminants to embryos and eggs. Oiled birds can lose the ability to fly, dive for food or floa t on the w ater, which can lead to drow ning. 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 w aterbirds, 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 co ntact ( e.g. , swimming through oil and dispersants or w aters 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.pdfU.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

8 contaminant concentrations in w ater passing ove r the gills). Fish that have recently ingested contaminated prey may themselves be a source of contam ination for their predators. Further, certain petroleum metabolites can be toxic to fish, and the fish can experience stress, reproductive failure and othe r sublethal effects while metabolizing hydrocarbons. Studies have suggested that sublethal hydrocarbon exposure on fish can lead to the development o f lesions. Eggs and larvae of many fish species are highly sensitive to oil exposure, resulting in decreas ed spawning success and abnormal larval development. Other potential direct effects that may occur as a result of exposure to hydrocarbons include reduced grow th, enlarged livers, changes in heart and respiration rates, fin erosion, and reproductive impair me nt. 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 i mpacted 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 contam inants in the food w eb. There is am ple 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 upp er level predators if they have only recently been exposed to toxic hydrocarbons. Oy sters 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. Direc t impacts on eggs and larval survival, or changes in the ecosystem that support the oyster ( e.g. , reduced w ater quality) due to oil impacts, also constitute modes of exposure. Ad ult oysters may experience reduced grow th and reproductive impairment when exp osed to oil. Exposure to w ater quality changes has both direct and indirect impacts on adult oysters as well as on eggs and larval survival. Exposure to w ater quality changes can also adversely impact the health of oyster habitat and the ecosystem that sup ports 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 im pacts 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 y ears to recover. 5 Nearshore Habitats: 

### O il and dispersants reaching the nearshore environment are transported on the surface of the water column by

w ind and cur rents. For oil to become incorporated into the bottom s ediment, 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 a s 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 e liminated in excretions (i.e., fecal pellets) that sink. Finally, oil that was deposited on shore mi xed with sediment and w ashed back out with the tide, eventually settling to the bottom, can result in exposure. This submerged oil creates a hazard to the w ide 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 respirat ion and direct ingestion. Shrimp and crab species could be impacted from an oil spill due to direct mo rtality of adults or post larvae or due to sublethal impacts such as reduced reproductive success. 6 Terrestrial Mammals: Terrestrial species are potenti ally injured by a spill along with their terrestrial and aquatic habitats. When oil reaches land, it can severely im pact coastal habitats including marshes, mud flats, mangrove stands and beaches. The organisms that use these habitats are at risk from direc t 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 thei r 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 clea nup 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
- Im

pacted
- By
- Fresh
Water
- Diversions
- 98867889.html 6 http://www.gulfspillrestoration.noaa.gov/wp
- content/uploads/FINAL_NRDA_Statu sUpdate_April2012.pdf 7 http://www.gulfspillrestoration.noaa.gov/wp
- content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdfU.S. Department of the Interior 30 CFR Part 250

Bureau of Ocean Energy Management Environmental Assessment

9 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 w ages paid each year in the Gulf Coast region. In 2009, 2.8 million recreational fishermen from the fo ur 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, w ith som e 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 oi l 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

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

Bureau of Ocean Energy Management Environmental Assessment

10 

# 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 Pow er Boilers; in cluding 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 fo r 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 availab le 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 §§ 250.8 52(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; inco rporated 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; inco rporated 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 Sy stems, ANSI/API Recommended Practice 14B, Fifth Edition, October 2005, also available as IS O 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 Sy stems 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

11 250.852(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. 8 11
- 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 Unc lassified 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 De sign 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 r eference 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 Underw ater Safety Valves Offshore, Fifth Edition, August 2007, Product No. G14H0 5; 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; Produc t 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); A PI 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 Instit ute, 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, petroc hemical 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

—Dri lling 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 Saf ety Valves and Underw ater 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/wp
content/uploads/FINAL_NRDA_StatusUpdate_April2012.pdf 

# 6.0 **LIST OF PREP**

**ARERS** Keely Hite

– Environmental Protection Specialist , Division of Environmental Assessment Bureau of Ocean Energy ManagementU.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 Nati o n's principal co n servation ag e ncy, the Dep a rtment of the Interior has responsibility for most of our nationally o wne d public la n ds and natural resources. This includes fo stering sound use of our land and w ater resour c es; protecting our fish, w ildli f e, and biologi c al diversity; preserving the environmental and cultural v alues 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 w orks to ensure that their development is in t he best interests of all our people by encouraging s te w ards h ip a n d citizen parti c ipation in their care. The Department also has a major responsibility for Ame r ican Indian r e servation co m munities and for people w ho live in island territories under U.S. a d ministration.



### The Bureau of Ocean Energy **Management Mission** The Bureau o f 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 ene rgy 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.