UNITED STATES GOVERNMENT MEMORANDUM

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

Public Information copy of DOCD

Control # - S-07557
Type - Supplemental Development Operations Coordinations Document
Lease(s) - OCS-G07937 Block - 383 Mississippi Canyon Area
Operator - BP Exploration & Production Inc.

Subsea Well K-4 and K-5

DRILLSHIP

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

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

Karen Dunlap Plan Coordinator

G07937/MC/383 G07937/MC/383 5684 FSL, 7675 FWL 5847 FSL, 7870 FWL G07937/MC/383 G07937/MC/383 WELL/K-4 WELL/K-5 Botm Lse/Area/Blk Surface Location Surf Lse/Area/Blk Site Type/Name Description -

Rig Type - Subject: From: July 12, 2012

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# BP Exploration & Production Inc. NaKika Subsea Development Phase 3 Project

Mississippi Canyon Block 383 (Kepler) OCS-G 07937



# Supplemental Development Operations Coordination Document (SDOCD)

PUBLIC COPY

Rev. Date Description Prepared By Checked By Approved By BP Reviewed BP Approved

1 4/24/2012 SDOCD – Kepler (Issued for Use) TH CG SK SD JG
0 4/01/2010 SDOCD - Kepler (Issued for Use) TH LL PB CR CR

Project Abbreviation Sector Designation Discipline Code Document Class Sequence Number Document Revision Document Control Number
NKPH3 15 RG PE 000001 1

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 2 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. AMENDMENT RECORD

Amendment Date Revision Number Amender Initials Amendment

4/16/12 D TH Update with revisions from regulatory, legal, and environmental 4/09/12 C TH Update with new CZM and OSRP information

3/22/12 B TH Update with revisions from environmental team and regulatory team lead 3/08/12 A TH Update with new regulations and well information

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 3 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. TABLE OF CONTENTS



### 1 Plan Cont ents...............................................................................................6 1.1 History of Lease.............................................................................................6 1.2 Description of Activi ties .................................................................................6 1.3 Locat ion ....................................................................................................7 1.4 Safety and Polluti on Prevention Features ......................................................7 1.5 Storage Tanks a nd Production Vessels ..........................................................8 1.6 Additional Measures ......................................................................................8
2 General Info rmation ....................................................................................9 2.1 Applications and Permits................................................................................9 2.2 Drilling Fluids..................................................................................................9 2.3 Completi on Fluids ..........................................................................................9 2.4 Produc tion ..................................................................................................10 2.5 Oil Char acteristics ........................................................................................10 2.6 New or Unus ual Technolog ies .....................................................................10 2.7 Bonding In formation ....................................................................................10 2.8 Oil Spill Financ ial Respons ibility ...................................................................10 2.9 Deepwater Well Control St atement.............................................................10 2.10Suspension of Producti on ............................................................................10 2.11Blowout Scenario.........................................................................................11 2.11.1 Blowout Sc enario .........................................................................11 2.11.2 The potential for the we ll to bri dge over .......................................11 2.11.3 The likelihood for surface intervention to stop the blowout .........11 2.11.4 The availability and timing of a rig to drill a relief well...................11 2.11.5 Measures that would enhance our ability to prevent a blowout...12 2.11.6 Measures that would reduc e the likelihood of a blowout.............13 2.11.7 Measures that would enhance our ability to conduct early interv ention ..................................................................................13 2.11.8 Other Measures ...........................................................................13 2.11.9 Worst Case Disch arge Modeling Report......................................14
3 Geological and Geophysic al Informa tion ................................................14 3.1 Geological De scription .................................................................................14 3.2 Structure Contour Maps ..............................................................................14 3.3 Interpreted 2-D and / or 3-D Seismic Lines ..................................................14 3.4 Geological Structur e Cross-Sect ion Ma ps....................................................14 3.5 Shallow Haza rds Repor t...............................................................................14

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 4 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

### 3.6 Shallow Hazards Assessmen t......................................................................14 3.7 High-Resolution Seismic Li nes.....................................................................14
4 Hydrogen Sulfide (H 2 

### S) Informa tion ........................................................15 4.1 Concentra tion...............................................................................................15 4.2 Classifi cation................................................................................................15 4.3 H 2 

### S Contingenc y Plan ..................................................................................15 4.4 Modeli ng Repor t ..........................................................................................15
5 Mineral Resource Cons ervation Info rmation ..........................................15 5.1 Technology and Reservoir Engineer ing Practices and Procedures...............15 5.2 Reservoir Developm ent ...............................................................................15
6 Biological and Physical Information.........................................................16 6.1 Benthic Communiti es Repor t.......................................................................16 6.2 Biologically Sensitive Unde rwater Features and Areas ................................16 6.3 Remotely Operated Vehicle (ROV) Monitoring Survey Plan.........................16 6.4 Threatened or Endangered Specie s, Critical Habitat, and Ma rine Mammal In formation ..................................................................................................17 6.5 Archaeologica l Report ..................................................................................17

7 Waste and Discharge Informati on............................................................17 7.1 Projected Generated Wastes.......................................................................17 7.2 Projected Oc ean Disch arges........................................................................18
8 Air Emissions In formation ........................................................................18 8.1 Screening Questions....................................................................................18 8.2 Emissions Worksheet s ................................................................................18
9 Oil Spill In formation ..................................................................................19 9.1 Oil Spill Respons e Planni ng..........................................................................19 9.1.1 Regional Oil Spill Response Pl an (OSRP) Information ....................19 9.1.2 Spill Res ponse Site s.......................................................................20 9.1.3 OSRO In formation..........................................................................20 9.1.4 Worst-Case Scena rio Determin ation ..............................................21 9.2 Oil Spill Res ponse Discu ssion ......................................................................22
10 Environmental Monitoring and Mitigation M easures ............................22 10.1 Monitoring S ystems...................................................................................22 10.2 Incidental Takes .........................................................................................22 10.3 Flower Garden Banks Na tional Marine Sa nctuary......................................23
11 Lease Stipul ations .....................................................................................23 11.1 Lease Stipulation Informat ion.....................................................................23
12 Related Facilities and Oper ations Info rmation........................................23 12.1 Related OCS Facilit ies and Oper ations ......................................................23

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 5 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

### 12.2 Transportati on Syst em ...............................................................................23 12.3 Produced Liquid Hydrocarbons Transportati on Vesse ls .............................24
13 Support Vessels and Airc raft Info rmation...............................................24 13.1 Gener al ..................................................................................................24 13.2 Diesel Oil Supply Vessels G eneral .............................................................24 13.3 Solid and Liquid Wastes Tran sportation a nd Dispo sal................................24 13.4 Vicini ty Map ...............................................................................................24

14 Onshore Support Facilitie s Information ..................................................25 14.1 Gener al ..................................................................................................25 14.2 Support Base Construct ion or Expa nsion...................................................25 14.3 Waste Disposal ..........................................................................................25
15 Coastal Zone Management Act (CZMA) Info rmation .............................25 15.1 Consistency Certificat ion ...........................................................................25
16 Environmental Impact Analysis (EIA) ......................................................26

17 Administrative In formation ......................................................................26 17.1 Exempted Inform ation Descr iption ............................................................26 17.2 Biblio graphy ...............................................................................................26 17.3 Other Refe rence Ite ms ..............................................................................26 17.4 Recove ry Fees ...........................................................................................27
18 Appendices.................................................................................................28

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 6 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 1 Plan Contents

1.1 History of Lease

The initial DOCD for the Mississippi Canyon Area Bl ock 383, (Kepler Field) was submitted to the Minerals Management Service (MMS) in May, 20 02 by Shell Offshore, Inc (Shell). The original plan called for the deepening and completion of the OCS-G 07937, Mississippi Canyon Area Block (MC) 383, No. 2 and No. 3 wells and a subsea tie back operation to connect the wells to the semi-submersible shaped ‘host” facility in Mi ssissippi Canyon Area Block 474, approximately 10 miles to the southeast. This SD OCD is the first supplement to the 2002 DOCD which outlines BP’s proposed Kepler development scenario.
Shell acquired lease OCS-G 07937 in Mississippi Canyon Area Block 383 in 1985 for a bonus of $5,487,000. The lease has a 1/8 royalty and is held by production. BP and Shell each have a 50% working interest in the block.
Shell drilled the OCS-G 07937, Mississippi Canyon 383-1 exploratory well to a total measured in 1987. In 2001-2002, Shell drilled the K-1 and K-2 development wells.



## 1.2 Description of Activities

The Kepler Field is one of five subsea developments in the NaKika Phase 3 Project. It is located in approximately 5700' of water in the Gulf of Mexico, approximately 10 miles northwest of the NaKika production facility in MC Block 474 ( Figure 1 ) and 112 miles southeast of Port Fourchon, Louisiana.

Figure 1. Location Map

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 7 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. This supplemental plan addresses the drilling a nd completion of the K-4 well. The plan also includes a mirror location to the K-4 well referred to as the K-5 well. This well is included only for re-spud purposes and targets the same production horizon as the K-4 well. It will encounter the same sands on the path to the targ eted bottom-hole location. The K- 4 will connect to the existing Kepler Oil gathering line that is producing through the NaKika Host.
The K-4 well will tie-in directly adjacent to the existing K-2 well into a dedicated flow line pipeline end terminal (PLET N1) which was installed during the initial field development for this purpose. The existing subsea architecture was set-up with specific expansion purpose directly dedicated to the K-4 well. The Kepler subs ea layout will allow flexibility within the subsea design which includes two extra PLETs to accommodate the tie-in of future wells.
The K1 reservoir is being produced by the K-1 and K- 2 horizontal subsea wells, tied back to the NaKika production facility northern flow loop. The pipeline layout for Kepler involves a pipe-inpipe loop from the host through Ariel (OCS-G 07944, Mississippi Canyon Area Block 429), continuing up to Kepler and then back to the ho st. Currently both Kepler and Ariel are producing through an open loop to the host. Flexibility within the Kepler subsea design includes two extra PLETs to accommodate tie-in of future wells, one allowing tie-in inside the pipeline loop, and allowing one tie-in outside. Any future well will require a pipe-in-pipe loop from the PLET to the well location.
The production system will be controlled using a ne w umbilical to be installed in concurrence with the K-4 well as part of the NaKika Phase 3 expansion project. The control system supplies hydraulic power, chemicals and power/communi cation signals to the tree mounted subsea control modules. Connections between the controls umbilical and the tree system will be completed using steel tube flying leads and redun dant electric flying leads. Communications between the K-4 well to the NaKika facility w ill be conducted using high speed fiber optics.
This supplemental plan also addresses new requirements of NTL 2010-N06. OCS Plan Information Form (Form BOEM-137) for the prop osed K-4 and K-5 well locations is included in Appendix A. The dates notated on the forms are tentative.
The wells will be drilled and completed utilizing a dynamically positioned drilling vessel. Subsea infrastructure will be installed using standard d eepwater construction and support vessels. The rig and all support vessels will be dynamically po sitioned; the use of anch ors will not be required.



## 1.3 Location

Refer to Appendix B for the following Well Location Maps:

 Vicinity Map

 Location Plat Public

 Bathymetry Map



## 1.4 Safety and Pollution Prevention Features

Safety and pollution prevention features utilized during deve lopment drilling and completion operations will include the use of appropri ately designed casing a nd cement programs; appropriate blowout preventers, diverters, and other associated well equipment; appropriate mud monitoring equipment and sufficient mud volu mes for well control; and properly trained

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 8 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. personnel as described in 30 CFR § 250, Subparts C, D, E, F and O, 30 CFR § 550 Subparts B and C, and as further clarified by applicable Notices to Lessees (NTLs).
Appropriate fire and ab andon drills will be condu cted, and navigational aids, lifesaving equipment, and other safety equipment will be installed and main tained as mandated by the U.S. Coast Guard regulations contained in 33 CFR § 144.



## 1.5 Storage Tanks and Production Vessels

Information regarding the MODU storage tanks th at will be used to co nduct the development drilling and completion operations pr oposed in this plan that will store oil, as defined at 30 CFR § 254.6 is provided in the table below. Only those tanks with a capacity of 25 barrels or more are included.

Type of Storage Tank Type of Facility Tank Capacity (bbls) No. of Tanks Total Capacity

(bbls) Fluid Gravity (API)

Fuel Diesel Oil DP Drilling Vessel 17,500 2 35,000 0.87

Base Oil Storage DP Drilling Vessel 2,800 1 2,800 0.85

Active Mud Tanks DP Drilling Vessel 500 12 6,000 2.20

Reserve Mud Tanks DP Drilling Vessel 1,200 5 6,000 2.20

Slugging Tanks DP Drilling Vessel 125 4 500 2.38

Brine Tanks DP Drilling Vessel 1,400 5 7,000 2.20

Production DP Drilling Vessel N/A N/A N/A N/A Table 1. Description of Drill Ship Storage Tanks



## 1.6 Additional Measures

In addition to the safety, pollution prevention, and early spill detection measures proposed in 30 CFR § 250, BP will rely on its Operating Management System (OMS) to help deliver safe and reliable operations. OMS is a sys tem of interdependent ac tivities that drive how BP will actually perform work and comply with internal and external standards and regulations. BP has also implemented an Environmental Management System (EMS) which provides a systematic way to identify risks, potential impacts, and compliance re quirements that need to be managed. BP has also presented to the BOEMRE a report entitled Deepwater Horizon Containment and Response: Harnessing Capab ilities and Lessons Learned . This document assesses the capabilities that are now available to respond to oil spills in the GoM.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 9 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 2 General Information

2.1 Applications and Permits

The table below provides information on the filing or approval status of the individual and/or sitespecific Federal, Stat, and local application approvals or permits that must be obtained to conduct the proposed activities within this amended plan.

Application/Permit Issuing Agency Status

General NPDES Permit EPA Existing

Application for Permit to Dr ill (APD) BSEE Pending Submittal

Application for Permit to Modi fy (APM) BSEE Pending Submittal

Pipeline ROW Modificati on Application (1) BSEE Approved March 30, 2012

Pipeline Application (1 ) BSEE Pending Submittal

Supplemental Deepwater Operations Plan BSEE Pending Submittal

Production Safety System Modification BSEE Pending Submittal Surface Oil and Gas Measurement Amendment BOEM Pending Submittal

Conservation Information Document ation BOEM Approved April 26, 2010 Table 2. Application and Permits



## 2.2 Drilling Fluids

A table providing information on the types (includi ng chemical constituen ts) and amounts of the drilling fluids that are plann ed to be used to drill the pr oposed well is included below.

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be Used Per Well

Water-based (seawater, freshwater, barite) 48,000 bbls

Oil-based (diesel, mineral oil) NA

Synthetic-based (internal olefin, ester) 3,940 bbls
Table 3. Drilling Fluids



## 2.3 Completion Fluids

The following table provides information on the types (including chemi cal constituents) and amounts of the completion fluids that are pl anned to be used to complete the proposed well.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 10 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. Type of Completion Fluid Estimated Volume of Completion Fluid to be Used Per Well

Water-based (seawater, freshwater, barite) 48,000 bbls

Well Treatment Fluids (acids, solvents, propping agents) 3,200 bbls

Completion Fluids (salt solutions, brines, polymers) 2,200 bbls
Table 4. Completion Fluids



## 2.4 Production

2.5 Oil Characteristics

2.6 New or Unusual Technologies

Subsea development drilling and co mpletion activities in MC 383 are not expected to utilize any new or unusual technology within the meaning of 30 CFR § 550.200.



## 2.7 Bonding Information

The bonding requirements for the activities propos ed in this SDOCD are satisfied by an areawide bond, furnished and maintained according to 30 CFR § 256, Subpart I; NTL No. 2000-G16, “Guidelines for General Lease Surety Bonds” ; with additional security under 30 CFR § 256.53(d) and National NTL No.2008-N07, “S upplemental Bond Procedures”.



## 2.8 Oil Spill Financial Responsibility

BP (Operator No. 02481) has demonstrated oil spill financial responsibility for the facilities proposed in this SDOCD plan according to 30 CFR § 253, and NTL No. 2008-N05, “Guidelines for Oil Spill Financial Responsib ility for Cover ed Facilities”.



## 2.9 Deepwater Well Control Statement

BP (Operator No. 02481) has the financial capability to drill a relief well and conduct other emergency well control operations.



## 2.10 Suspension of Production

There are no approved sus pensions of production in existence, or that BP will seek at this time, to hold the leases involved with the proposed SDOCD activities.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 11 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 2.11 Blowout Scenario

2.11.1 Blowout Scenario

The blowout scenario assumes that the pipe has been tripped out of the hole when a problem with the wellhead connector develops resulting in the removal of the blowout preventer stack (BOP). Due to the loss of riser margin, the well flows unrestricted. Day 1 worst case discharge (WCD) is 20,000-bopd, with the calculation s upport package for this rate attached as Appendix C . The maximum duration of the blowout is estimated at 95-days (see relief well timing below). The rate profile associated with the well blowout over this 95-day period (also included in Appendix C) results in a potential worst case spill volume estimated at 1.900-mmbo.

2.11.2 The potential for the well to bridge over

The bridging potential is not considered for the “w orst case”. However, bridging is possible due to the generally low formation st rengths in the Gulf of Mexico. The unrestricted flow scenario creates significant under balance across the exposed shales and sands allowing them to fall quickly into the wellbore. As the wellbore enlar ges and hydrostatic increases due to this failure, the fluid velocity slows, allowing the caving s to bridge and plug the wellbore. Long open hole sections increase the flow of formation cavings, increasing the likelihood that the wellbore will bridge.

2.11.3 The likelihood for surface intervention to stop the blowout

The likelihood for above mudline intervention to stop a blowout is dependent on the failure mechanism. Depending on the circumstances, BP may address a failure of the BOP stack by repairing the control system via remote operating vehicles (ROVs), replacing the BOPs, or adding a BOP on top of the current BOP stack. Failure of the wellhead or casing would be more difficult and require clear access to the well below the failure point in order to run drill pipe and / or tools in the well.

2.11.4 The availability and timing of a rig to drill a relief well

The table below lists the Mobile Offshore Drillin g Units (MODU) that are capable of drilling a relief well and are presently under contract to BP in the GOM, one of which (in addition to the one being used) would be made available to drill a relief well. The estimated time to spud is 10- days pending requirements to safely secure the current operations of the MODU, required material logistics, mobilization to location, and regulatory approv als. The possibility of drilling a relief well from a neighboring platform or land is not applicable to operations proposed in this Plan: there is no existing infrastr ucture in the vicinity of the MC 383 well surface locations.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 12 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. Rig Name Current Location Contract Expire Date Rated WD
(ft) Rated TD
(ft) Rated BOPs
(psi) Moor Type Relevant Drill Package Limitations

Discoverer Enterprise GOM 8/2012 10K 35K 15K DP DWHC connector, 7.5K of riser Development Driller II GOM 11/2013 7.5K 37.5K 15K DP SHDH4
connector Development Driller III GOM 11/2016 7.5K 37.5K 15K DP SHDH4
connector

West Sirius GOM 9/2014 10K 37.5K 15K DP Cameron EVOH4 connector

Table 5 : Available MODUs for Relief Well

The most likely time to drill a relief well is: 10- days to mobilize and spud; 50-days from spud to casing shoe above WCD zone, plus 35-days for ranging, intersection, and kill operation - for a total of 95-days.

2.11.5 Measures that would enhance our ability to prevent a blowout

Measures employed to prevent a blowout are co mpliance with all regulations (30 CFR 250 and 550), current NTLs, and, in particular, the Interim Final Rule focused on BOP verification and reliability. Additional measures include:

1. Volume measurements, relative to the well, will be moni tored at all times during all operations. 2. Flow checks before leaving bottom, after pulling into shoe, and before BHA enters stack. 3. Company representative shall observe well conditions prior to each trip and after well kills or testing. 4. Company representative shall be the only person authorized to initiate opening the well as part or conclusion of well control measures. 5. On rig JSA/contingency plan before running an y non-shearable tools or pipe through the BOP stack. 6. BP has adopted additional voluntary performance standards as outlined in a letter to Director Bromwich, dated July 15, 2011:

1. BPXP will use, and will require its contract ors involved in drilling operations to use, subsea blowout preventers (BOPs) equipped with no fewer than two blind shear rams and a casing shear ram on all drilling ri gs under contract to BPXP for deepwater service operating in dynamic position mode. With respect to moored drilling rigs under contract to BPXP for deepwater drilling service using subsea BOPs, the subsea BOP will be equipped with two shear rams, which will include at least one blind shear ram and either an additional blind shear ram or a casing shear ram.

2. Each time a subsea BOP from a moored or dynamically positioned drilling rig is brought to the surface and testing and maintenance on the BOP are conducted,

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 13 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. BPXP will require that a third party verify that the testing and maintenance of the BOP were performed in accordance with manufacturer recommendations and API RP 53.

3. BPXP will require that lab testing of cement slurries for primary cementing of casing and exposed hydrocarbon bearing zones re lating to drilling operations of deepwater wells be conducted or witnessed by a BPXP engineer competent to evaluate such lab testing, or a competent third party i ndependent of the cement provider. BPXP will provide lab results to th e applicable BOEMRE field office within a reasonable period of time.

2.11.6 Measures that would reduce the likelihood of a blowout

Measures that would reduce the likelihood of a blowout are compliance with all regulations (30 CFR 250 and 550) and current NTLs. Additional measures:

1. Minimize any influx events to the wellbore by using the best pore pressure / frac gradient predictions available, using downhole tools wh en appropriate, such as PWDs, to monitor the wellbore and update pore pressure / frac gradient predictions. 2. Management of change process is in place for all procedure changes. 3. A Well Control Response Guid e is in place.

2.11.7 Measures that would enhance our ab ility to conduct early intervention

Measures to enhance our ability to conduct earl y intervention in addition to the regulatory and NTL requirements include:

1. Relief well site(s) identified, surveyed, and as sessed prior to spud of original well. 2. Wellhead equipment and sufficient casing available for a relief well. 3. A rig(s) is identified and available for a relief well. 4. A Well Control Response Guide is in place. 5. Incident Management System (IMS) is in place.

 The BP IMS is comprised of government approved plans that covers various scenarios; Incident Management Teams that are trained annually in the Incident Command System, which are a part of the National Incident Management System; access to response capability through various contr actors and technical specialist; and predesignated facilities, where our teams can pr ovide adequate oversight to the response.

2.11.8 Other Measures

All the proposed activities and facilities in this amended SDOCD will be covered by the OSRP filed by BP America Inc. (Operator No. 21591) in accordance with 30 CFR § 254 and approved on July 21, 2009.
A Revised GoM Regional OSRP was filed by the Gu lf of Mexico Region of BP Corporation North America, Inc. (Operator 2367) in October 2011 on behalf of several companies listed in the plan including BP Exploration & Production Inc. (O perator No. 02481). Additional correspondence related to this plan was submitted by BP Explor ation & Production Inc. on October 20, 2011. The Revised OSRP describes a number of source contro l options and a list of potential equipment to be deployed.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 14 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 2.11.9 Worst Case Discharge Modeling Report

Appendix C contains Discharge Modeling Reports wh ich is included in the “Proprietary Information” copy of the SDOCD.



## 3 Geological and Geophysical Information

3.1 Geological Description

A discussion of the geological objectives, incl uding a brief description of the hydrocarbon trapping elements, is included in Appendix D in the “Proprietary Information” copy of this SDOCD.



## 3.2 Structure Contour Maps

Structure contour maps are included in Appendix D in the “Proprietary Information” copy of this SDOCD.



## 3.3 Interpreted 2-D and / or 3-D Seismic Lines

Migrated and annotated (shot points, time lines, we ll paths) 3-D seismic lines with depth scale within 152-meters (500-feet) of the proposed su rface location are included with the shallow hazards assessment in Appendix D of the “Proprietary Information” copy of this SDOCD.



## 3.4 Geological Structure Cross-Section Maps

An interpreted geological structure cross-section map is included in Appendix D of the “Proprietary Information” copy of this SDOCD.



## 3.5 Shallow Hazards Report

A shallow hazards and archeological report was submitted May 2010 with the SDOCD, Control Number S-7422, which was cancelled. See Section 17.2 “Bibliography”.



## 3.6 Shallow Hazards Assessment

Shallow hazards assessments are included in Appendix D of this SDOCD.



## 3.7 High-Resolution Seismic Lines

Per the approved Exploration Plan (S-5449), this is not applicable. HR2D waiver approved. Exploration 3-D seismic sections through proposed locations were included in the Shallow Hazards Assessment in Appendix D

.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 15 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 4 Hydrogen Sulfide (H 2 

## S) Information

Pursuant to 30 CFR 250.490(c), BP hereby requests that the area proposed in this plan be classified as “zones where the absence of H 2 S has been confirmed”.



## 4.1 Concentration

Based on previous wells drilled in this area, the conc entration will be 0-PPM H 2 S. It is not expected that H 2 S will be encountered during the oper ations proposed in this plan.



## 4.2 Classification

Pursuant to Title 30 CFR 250.490(c), the BOEM has determined Mississippi Canyon Area Block 383 to be H 2 S absent, for the drilling program Mississippi Canyon 383 #1, #3 ST.



## 4.3 H 2 

## S Contingency Plan

Based on previous drilling, no H 2 S is known to occur in the ar ea. Based on earlier drilling and previous BOEM “H 2 S absent” classification, an H 2 S contingency Plan prepared according to 30 CFR § 250.490(f) is not required.



## 4.4 Modeling Report

H 2 S concentrations grea ter than 500-pa rts per million (ppm) are not ex pected in the operations proposed in this plan; therefore, a modeling report is not required.



## 5 Mineral Resource Conservation Information

5.1 Technology and Reservoir Engineering Practices and Procedures

5.2 Reservoir Development

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 16 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 6 Biological and Physical Information

6.1 Benthic Communities Report

The BOEM requires site-specific surveys and reviews for proposed bottom-disturbing actions in water depths greater than 300-m in order to judge the potential of the region for supporting high density chemosynthetic organisms. NTL No. 2009–G40, formalized the process. BP has conformed to this requirement, and has located wells, platform anchors, anchor chains, and pipeline routes to avoid potential sites for benthic communities during the deepwater development project described by this plan.
MC 383 is located in water depths greater than 300-m; therefore, ther e is the potential for chemosynthetic organisms to be pr esent. The interpretation of the 1997 Deep-Tow survey data and 3D seismic data and amplitude extractions perf ormed at and close to se abed (as described in the Shallow Hazards Assessment submitted in April 2010) do not show any evidence for the presence of fluid or gas expulsion features or other seafloor conditions indicative of antigenic carbonates at, or within, 2,000 ft of the proposed well locations.
Additional subsea equipment for the developm ent of the K-5 well will be located in areas previously surveyed for benthic communities. Hazard reports and Assessments listed in Appendix E provide a current review of available data confirming the absence of high-density benthic communities within the prescribed dist ances from drilling discharges and subsea equipment.



## 6.2 Biologically Sensitive Unde rwater Features and Areas

The proposed development drilling and completion acti vities will be conducted in water depths of approximately 5,741 ft. Therefore, requirements of NTL 2009-G39 for biologically sensitive underwater features and areas such as Topographi c Features, Live Bottom (low-relief), Live Bottom (Pinnacle Trend) features, and other po tentially sensitive biological features when conducting OCS operations in water depths less than 300-m (984-ft) in the Gulf of Mexico do not apply to this plan.
The nearest Topographic Featu res, “No Activity Zones”, Live Bottom (low Relief), and Live Bottom (Pinnacle Trend) Stipulation Blocks described in NTL 2009-G39 and shown on BOEMRE April 2011 Map: “Biologically Sensitive Areas (< 300-m)” are located about 75-miles (121 km) north-northeast from the lease area.



## 6.3 Remotely Operated Vehicle (ROV) Monitoring Survey Plan

Mississippi Canyon Area Block 383 falls within Grid 16. It has been determined by the BOEM that sufficient remotely operated vehicle (ROV ) information has been gathered in Grid 16; therefore, a requirement for a new ROV moni toring survey is not anticipated.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 17 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 6.4 Threatened or Endangered Specie s, Critical Habitat, and Marine Mammal Information

Twenty-nine species of marine mammals occur in the GOM. There are twenty-eight species of cetaceans (seven mysticete and twenty-one odonto cete species), and one sirenian species, the
manatee.
Five baleen whale species, one toothed whale species, and one sirenian species occur in the GOM and are listed as endangered under the Endangered Species Act (ESA) (USDOI, BOEM Final S-EIS CPA 2012-58):

 The Northern Right Whale (Eubalaena glacialis)

 The Blue Whale (Balaenoptera musculus)

 The Fin Whale (Balaenoptera physalus)

 The Sei Whale (Balaenoptera borealis)

 The Humpback Whale (Megaptera novaeangliae)

 The Sperm Whale (Physeter macrocephalus)

 The West Indian Manatee (Trichechus manatus)
Five species of sea turtle are known to i nhabit the waters of the Gulf of Mexico:

 The Leatherback (Dermochelys coriacea)

 The Green (Chelonia mydas)

 The Hawksbill (Eretmochelys imbricata)

 The Kemp's ridley (Lepidochelys kempii)

 The Loggerhead (Caretta caretta)
The Gulf sturgeon (Ancipenser oxyrinchus desotoi) and the small tooth sawfish (Pristis pectinata) are the only listed threatened and endangered fish species in the Gulf of Mexico.
Mississippi Canyon Area Block 383 is not designated as critical habitat for any of these species. Additional information can be found in the Environmental Impact Analysis attached as Appendix F

.


## 6.5 Archaeological Report

Mississippi Canyon Area Block 383 is listed as a block that requires an archaeological resources survey and report as described in NTL 2011-JOINT-G01 (formerly 2008-G20). The Archaeological Survey and Report has been previously submitte d to the BOEM with the SDOCD, Control Number S-7422, which was cancelled. See Section 17.2 “ Bibliography ”.



## 7 Waste and Discharge Information

7.1 Projected Generated Wastes

A table providing information on the projected so lid and liquid wastes lik ely to be generated by the proposed activities is included in Appendix G

.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 18 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 7.2 Projected Ocean Discharges

A table providing information on the projected ocean discharges likely to be generated during the proposed activities is included in Appendix G.



## 8 Air Emissions Information

8.1 Screening Questions

Yes No Screening Questions for DOCD's

X Is any calculated Complex Total (CT) Emission amount (tons) associated with your proposed development and production activities more than 90% of the amounts calculated using the following formulas: CT = 3400D2/3 for CO, and CT = 33.3D for the other air pollutants (where D = distance to shore in miles)?

X Do your emission calculations include any emission reduction measures or modified emission factors?

X Does or will the facility comple x associated with your proposed development and production activities process production from eight or more wells?

x Do you expect to encounter H2S at concentrations greater than 20 parts per million (ppm)?

x Do you propose to flare or vent natural gas in excess of the criteria set forth under 30 CFR 250.1105(a)(2) and (3)?

x Do you propose to burn produced hydrocarbon liquids?

Yes No Screening Questions for DOCD's

x Are your proposed development and production activities located within 25 miles (40 kilometers) from shore?

x Are your proposed development and production activities located within 124 miles (200 kilometers) of the Breton Wilderness Area?



## 8.2 Emissions Worksheets

Emission Worksheets (FORM BOEM-1 39) showing calculated Plan Emissions associated with the activities proposed in this SDOCD are attached as Appendix H . There are no existing facilities or activities co-located with these proposed activities, so Complex Total Emissions are the same as Plan Emissions. Also, please note th at although plan activities are expected to be completed by 2013, the 2012 level of emissions are carried forward on the summary worksheet for the period 2014-2021. This is intended to provide an allowance for any associated well intervention or construction activities that may occur in those outlying years.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 19 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 9 Oil Spill Information

9.1 Oil Spill Response Planning

9.1.1 Regional Oil Spill Response Plan (OSRP) Information

All the proposed activities and facilities in this SDOCD will be covered by the OSRP filed by BP America Inc. (Operator No. 21591) in accordance with 30 CFR § 254 and approved on July 21, 2009.
A Revised GoM Regional OSRP was filed by the Gu lf of Mexico Region of BP Corporation North America, Inc. (Operator 2367) in October 2011 on behalf of several companies listed in the plan, including BP Exploration & Production Inc. (Operator No. 02481).

In a letter submitted to Mr. Michael J. Sauc ier dated October 19, 2011, and accepted on October 20, 2011, BP Exploration & Production Inc. prov ided a certification statement of the kind described in 30 CFR § 254.2 covering its operations in the Gulf of Mexico.

BP has adopted additional voluntary performance standards as outlined in a letter to Director Bromwich, dated July 15, 2011:
4. BPXP’s Oil Spill Response Plan (OSRP) will in clude information about enhanced measures for responding to a spill in open wa ter, near shore re sponse and shoreline spill response based on lessons learned from the Deepwater Horizon oil spill. In complying with the requirements of 30 CFR § 254 and related Noti ces to Lessees, BPXP’s OSRP will include:

 Provisions to maintain access to a supply of dispersant and fireproof boom for use in the event of an uncontrolle d long-term blowout for the length of time re quired to drill a relief well.

 Contingencies for maintaining an ongoing response for the length of time required to drill a relief well.

 A description of the measures and equipment necessary to maximize the effectiveness and efficiency of the response equipment us ed to recover the discharge on the water’s surface. The discussion must include methods to increase encounter rates, the use of vessel tracking, and the use of remote sensing technologies.

 Information on remote sensing technology and equipment to be used to track oil slicks, including oil spill detection systems and remo te thickness detectio n systems (such as Xband/infrared systems).

 Information pertaining to the use of vessel tracking systems and communication systems between response vessels and spotter personnel.

 A shoreline protection strategy that is consis tent with applicable area contingency plans (ACP).

 For operations using a subsea BOP or a surface BOP on a floating facilit y, a discussion regarding strategies and plans related to source abatement and control for blowouts from drilling.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 20 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 9.1.2 Spill Response Sites

Primary Response Equipment Location Preplanned Staging Location(s)

Pensacola, FL ; Mobile, AL ; Pascagoula, MS ; Houma, LA ; Lake Charles, LA ; Fort Jackson, LA ; Venice, LA ; Galveston, TX ; Corpus Christi, TX Fourchon, LA.

Table 6 . Spill Response Sites

9.1.3 OSRO Information

BP is a member of the Marine Spill Response Co rporation (MSRC), Clean Gu lf Associates (CGA), and the National Response Corporation (NRC) and would utilize said OSROs’ personnel and equipment in the event of an oil spill at Mississippi Canyon Area Block 383 area.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 21 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 9.1.4 Worst-Case Scenario Determination

Category Regional OSRP Approved July 2009

Drilling Regional OSRP Approved July 2009 Production Regional OSRP Submitted

October 20, 2011 Drilling NaKika SDOCD MC 383

#K-4 Drilling Regional OSRP Submitted

October 20, 2011 Production NaKika SDOCD MC 383

#K-4 Production Type of Activity Drilling > 10-miles Drilling Subsea Well > 10-miles Subsea Well
Facility Location MC462 MC 778 WR282 MC 383 MC 775 (SL) MC 383

Facility Designation MODUMC462 MC 778 PDQ MODUWR282-1 MODU - MC 383, K-4 Development Well MODU – MC 776-6 Development Well MODU - MC 383, K-4 Development Well Distance to Nearest Shoreline 33-miles 68-miles 252-miles 49-miles 63-miles 49-miles

Volume Facility Storage: - - - - - -

Max Tanks /Vessels 0-bbls 21,400-bbls 0-bbls 0-bbls 0-bbls 0-bbls

Flowlines 0-bbls 2,000-bbls 0-bbls 0-bbls 0-bbls 0-bbls

Lease Term pipelines 0-bbls 13,000-bbls 0-bbls 0-bbls 5, 000-bbls 4-bbls
Daily Production Volume Max Well 0-bbls 141,000-bbls 0-bbls 0-bbls 0-bbls 0-bbls

Volume Uncontrolled Blowout (Day 1) 0-bbls 0-bbls 270,000-bbls 20,000-bbls 295,000-bbls 20,000-bbls

Total Volume 250,000- bbls 177,400-bbls 270,000-bbls 20,000-bbls 300,000-bbls 20,004-bbls
Type of Oil(s) – (Crude Oil, Condensate, Diesel) Crude Crude / Diesel Crude Crude Crude Crude

API Gravity(s) 26.0 33.0 30.0 24.2 30.8 24.2

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 22 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. BP has determined that the worst case scenario fr om the activities proposed in this plan does not supersede the worst cast scen ario in BP’s Regional July 2009 OSRP or the Revised OSRP submitted on October 20, 2011. Therefore, pu rsuant to NTL No. 2008-G04, BP makes the following statement:
Since BP Exploration & Production Inc. has the capability to respond to the worst-case spill scenario included in its Regional Oil Spill Response Plan approved on July 21, 2009 and resubmitted in revised form October 20, 2011, and since the worst-case scenario determined for our SDOCD does not replace the worst-case scenar io in our regional or sub-regional OSRP; BP certifies that it has the capability to respond, to the maximum extent practicable, to a worst-case discharge, or a substantial threat of such a disc harge, resulting from the activities proposed in our SDOCD.
Wellbore data, geologic data, reservoir data, and fluid data used in modeling and making the WCD determination for the Kepler Well K-4, as well as for the Developmental WCD Scenario in the Revised Regional OSRP submitted October 20, 2011, are provided in Appendix C

.


## 9.2 Oil Spill Response Discussion

A detailed discussion of a response to an oil sp ill at the Mississippi Canyon Area Block 383 well location is included in Appendix I . This Appendix addresses topics such as resource identification, release modeling, response te chnologies and source containment/control.



## 10 Environmental Monitoring and Mitigation Measures

10.1 Monitoring Systems

Operational personnel have been instructed to check for pollution daily and, in the event pollution is spotted, to identify and shut-off the sour ce and make immediate notifications as per instructions provided in Section 2 and 3 of BP’s approved OSRP, Volume II.
In accordance with the provisions of Title 30 CFR § 250.417(e) and NTL 2009-G02 “Deepwater Ocean Current Monitoring on Floating Facilities”, dated January 27, 2009, the MODU will be equipped with an Acoustic Doppler Current Profil e (ADCP) current monito ring system onboard to ensure continuous monitoring and gathering of ocea n current data on a real-time basis from the ocean surface and seafloor.
BP participates in the SERPENT program, which provides opportunistic monitoring of animals that swim or float in the deepwater’s of the GOM.



## 10.2 Incidental Takes

To mitigate against incidental takes, all activi ties will be conducted in adherence to NTL 2012- G01 “Marine Trash and Debris Awareness Tr aining and Elimination” and NTL 2012-Joint-G01 “Vessel Strike Avoidance and Injured/Dead Prot ected Species Reporting”. As required by NTL 2012-G01, BP submits an annual “certification” le tter for its Marine Debris Awareness Training Process. The marine debris awareness training is re quired annually as identified by “BP’s Gulf of Mexico (GoM) Environmental Training Matrix” an d “BP’s GoM Health, Safety, and Environmental (HSE) Training Needs Assessment”, both of which are located on BP’s GoM HSE website.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 23 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. Monitoring activities are conducted by all personnel on rigs and platforms to prevent accidental loss of materials overboard and to report sighting s of injured / dead protected species. Reporting of dead / injured protected specie s is addressed in BP’s “Inciden t Notification and Investigation Procedure

- Attachment 1”.



## 10.3 Flower Garden Banks National Marine Sanctuary

This plan does not propose activities within the protective zones of the East and West Flower Garden Banks or Stetson Bank.



## 11 Lease Stipulations

Oil and Gas exploration activiti es on the OCS are sometimes subj ect to mitigating measures in the form of lease stipulations.



## 11.1 Lease Stipulation Information

Mississippi Canyon Area Block 383 is not a part of any Biological Sensitive Area or Shipping Fairway. However, the block has been determi ned as having high probability for prehistoric archaeological resources or historic period sh ipwrecks. See Section 6.5 of this plan for archaeological discussion.
Mississippi Canyon Area Block 383 has no additional stipulations placed on this lease.



## 12 Related Facilities and Operations Information

12.1 Related OCS Facilities and Operations

The NaKika host facility is a semi-submersible production platform supplied with hydrocarbons from six (6) different fields through subsea tie-b ack infrastructure. The NaKika production facility has a maximum POB capacity of 99 people and is operated with a core crew of 52 personnel. The fields producing into NaKika are Kepler (M C 383), Ariel (MC 429), Ea st Anstey (MC 508), Herschel (MC 520), Fourier MC 522 & MC 566), and Coulomb (MC 667).
Other than these NaKika project facilities and operat ions, there are no other existing drilling units, production platforms, pipeline accessory platfo rms, host facilities, or other facilities and operations located on the OCS that directly relate to the proposed development activities within this plan.



## 12.2 Transportation System

Production will connect to the NaKika North Oil Loop by a pipe-in-pipe flowline. The tree will be connected to the flowline using a rigid steel jumper. The production system will be controlled using a new umbilical.
Production will depart the NaKika host facility via the existing sales pipeline with ultimate delivery to shore.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 24 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 12.3 Produced Liquid Hydrocar bons Transportation Vessels

There are currently no plans to transport produced liquid hydrocarbons including well test fluids by means other than the export system described in Section 12.2.



## 13 Support Vessels and Ai rcraft Information

13.1 General

Support vessels a nd travel frequency durin g the proposed development drilling and completion activities are as follows:

Type Max Fuel Tank Storage Capacity Max No. in Area at Any Time Trip Frequency or Duration

Aircraft-Helicopter Sikorsky S-92 760-gals 1 5-flts / week

MSV 6,000-bbls 1 Every 3-5 days

Workboat 3,600-bbls 2 24 hours / day at rig

FSV - Crewboat 1,000-bbls 1 1-2 / week

Table 7 . Vessel Traffic



## 13.2 Diesel Oil Supply Vessels General

BP does not anticipate the need for diesel oil supply vessels for the activities within this plan.



## 13.3 Solid and Liquid Wastes Transportation and Disposal

Information concerning the solid and liquid wast es transported from the site of the proposed activities for onshore storage or disposal has been included in Table No. 2 found in Appendix G.



## 13.4 Vicinity Map

A vicinity map depicting the location of the propo sed activities relative to the shoreline, the distance of the proposed activities from the s horeline, and the primary route(s) of the support vessels and aircraft when travel ing between the onshore support f acilities and the project areas are included in Appendix B.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 25 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 14 Onshore Support Facilities Information

14.1 General

Mississippi Canyon Area Block 383 is located ap proximately 49 statute miles from the nearest Louisiana shoreline and approximately 112 statute miles from the onshore support base located in Fourchon, Louisiana as indicated on the Vicinity Map, in Appendix B

. The following table provides information of the onshore facility that will be used to provide supply and service support for the activities proposed in this plan.

Name Location Existing/New/Modified
Fourchon Service Base C-Port Port Fourchon, LA Existing

MI Base Port Fourchon, LA Existing

BJ Base Port Fourchon, LA Existing

PHI Helicopter Base Houma, LA Existing

Table 8 . Shorebase Facility Information
The C-Port Fourchon facility provides a vehicle parking lot, office space, radio communication equipment, outside and warehouse storage space, cr ane, forklifts, water, and fueling facilities, and boat dock space. The base is owned by Chouest and is leased by BP Exploration & Production Inc. The base is in operation 24 hours each day.



## 14.2 Support Base Construction or Expansion

BP will utilize existing support base s for the proposed, activities which are tempor ary in nature and do not mandate any immediate measures fo r additional land acquisition, construction or expansion of the existing onshore base facilities.



## 14.3 Waste Disposal

Information about the onshore facilities used to store and dispose of solid and liquid wastes generated by proposed activities has been included in Table No. 2 located in Appendix G

.


## 15 Coastal Zone Management Act (CZMA) Information

15.1 Consistency Certification

A Coastal Zone Management Act consistency certification for the State of Louisiana and the State of Mississippi is not required for this plan.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 26 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 16 Environmental Impact Analysis (EIA)

Attached as Appendix F is an environmental impact anal ysis (EIA) prepared for the proposed project by CSA International, Inc., 8502 SW Kansas Avenue, Stuart, Florida 34997.
This EIA analyzes potential impacts from a single new well, installation of subsea equipment, and wells previously approved under prior DOCD’s.
BOEM (or its predecessor, the Minerals Mana gement Service) has conducted extensive environmental analyses examining the possible im pacts produced by oil and gas exploration and production activities in the Final Supplemental EIS for the Central Planning Area, which evaluated impacts from similar activities on the areas in t he Gulf of Mexico covered by the present plan.
The EIA, in addressing the project-specific envi ronmental impacts of the present plan, contains conclusions and supporting analyses that are co nsistent with the extensive prior environmental analyses discussed above.



## 17 Administrative Information

17.1 Exempted Information Description

In accordance with 43 CFR § 2, Appendix E, sections (4) and (9), the following information has been determined by the BOEM GOMR exempt from public disclosure:

 Geologic Objectives (BHL, TVD and MD) on Form BOEM-0137

 Production rates and life of reservoirs

 Proprietary New or Unusual Technology

 Geological and Geophysical Information (except for non-proprietary Shallow Hazard Assessment)

 Hydrogen Sulfide Correlative Well Information

This information is excluded from the “Public Information” copies of the submitted plan.



## 17.2 Bibliography

Plan Control No Lease Block Operator Name Operator Number Plan Type Code Received Date Final Action Code Final Action

Date
S-5449 G07937 MC383 Shell 2139 POE 11/17/2000 A 6/15/2001 N-7443 G07937 MC383 Shell 689 DOCD 5/7/2002 A 7/17/2002 S-7422 G07937 MC383 BP 2481 SDOCD 5/3/2010 X 10/3/2011 Table 9 . Plan Submittal History



## 17.3 Other Reference Items

Deepwater Horizon Containment and Response: Harnessing Capa bilities and Less ons Learned.

USDOI, BOEMRE Final S-EIS CPA 2012-058.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 27 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 17.4 Recovery Fees

Appendix J contains copies of the receipts show ing the total payment of $7,942.00 for the service processing fee required by 30 CFR § 250.125, based on the pr oposed new K-4 and K-5 wells.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 28 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## 18 Appendices

Appendix A: 

## Plan Information Forms

Appendix B: 

## Vicinity and Field Maps, Location Plats, Bathymetry Map

Appendix C: 

## WCD Assumptions and Discharge Model Report

Appendix D: 

## Geologic Description, Geologic Structure Maps, Interpreted Seismic Lines, Cross-section Maps

Appendix E: 

## Shallow Hazards and Arch eological Reports and Hazard Assessements

Appendix F: 

## Environmental Impact Analysis (EIA)

Appendix G: 

## Waste and Discharge Tables

Appendix H: 

## Air Emissions Information

Appendix I: 

## Oil Spill Response Discussion

Appendix J: 

## Recovery Fee Receipt

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 29 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix A: Plan Information Forms

- OCS Plan Information Form BOEM-137U.S. Department of the Interior OMB Control Number: 1010-0151 Bureau of Ocean Energy Management OMB Approval Expires: 12/31/14



### OCS PLAN INFORMATION FORM
General Information Type of OCS Plan: Exploration Plan (EP) Development Operations Coordination Document (DOCD)

Company Name: BOEM Operator Number:

Address: Contact Person:

Phone Number:

E-Mail Address:
If a service fee is required under 30 CFR 550.125(a), provide the Amount paid Receipt No.

Project and Worst Case Discharge (WCD) Information
Lease(s): Area: Block(s): Project Name (If Applicable):
Objective(s) Oil Gas Sulphur Salt Onshore Support Base(s):
Platform/Well Name: Total Volume of WCD: API Gravity:
Distance to Closest Land (Miles): Volume from uncontrolled blowout:
Have you previously provided information to verify the calculations and assumptions for your WCD? Yes No
If so, provide the Control Number of the EP or DOCD with which this information was provided
Do you propose to use new or unusual technology to conduct your activities? Yes No
Do you propose to use a vessel with anchors to install or modify a structure? Yes No
Do you propose any facility that will serve as a host facility for deepwater subsea development? Yes No
Description of Proposed Activities and Tentative Schedule (Mark all that apply)
Proposed Activity Start Date End Date No. of Days
Exploration drilling
Development drilling
Well completion
Well test flaring (for more than 48 hours)

Installation or modification of structure
Installation of production facilities

Installation of subsea wellheads and/or manifolds
Installation of lease term pipelines
Commence production
Other (Specify and attach description) Description of Drilling Rig Description of Structure
Jackup Drillship Caisson Tension leg platform
Gorilla Jackup Platform rig Fixed platform Compliant tower
Semisubmersible Submersible Spar Guyed tower
DP Semisubmersible Other (Attach Description)
Drilling Rig Name (If Known): Floating production system Other (Attach Description)

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

Form BOEM- 0137 (December 2011

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

## X

BP Exploration & Production Inc. 02481

Teri Halverson 200 Westlake Park Blvd, WL4-471A 281-366-6292 (office) / 281-221-5225 (mobile) Houston, Texas 77079 teri.halverson@bp.com

$3,971 2563VQUN

OCS-G07937 MC 383 NaKika Subsea Phase 3 - Kepler Development
X C-Port Service Base Fourchon, Louisiana

MC383 No. 4 (K-4) 20,000 bopd 24.2

49.0 1.900 mmbo

X

X

X

X

N/A N/A N/A

10/01/12 11/08/12 39

2/01/13 3/03/13 31

N/A N/A N/A

N/A N/A N/A

N/A N/A N/A

2/01/13 2/06/13 6

11/01/12 11/11/12 11

2/07/13 2/12/13 6

X

MC 383 MC 383 4.875 89OCS PLAN INFORMATION FORM ( CONTINUED ) Include one copy of this page for each proposed well/structure Proposed Well/Structure Location

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

Is this an existing well or structure? Yes No If this is an existing well or structure, list the Complex ID or API No. Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? Yes No

WCD info For wells, volume of uncontrolled blowout (Bbls/day): For structures, volume of all storage and pipelines (Bbls): API Gravity of fluid
Surface Location Bottom-Hole Location (For Wells) Completion (For multiple completions, enter separate lines)
Lease No. OCS OCS OCS OCS
Area Name

Block No.

Blockline Departures (in feet) N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L
Lambert XY coordinates X: X: X:
X:
X:
Y: Y: Y:
Y:
Y:
Latitude/ Longitude Latitude Latitude Latitude Latitude Latitude Longitude Longitude Longitude Longitude Longitude Water Depth (Feet): MD (Feet): TVD (Feet):

Anchor Radius (if applicable) in feet: MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet):

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

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

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

Form BOEM- 0137 (December 2011

- Supersedes all previous editions of this form which may not be used.) Page 2 of 4 MC383 No. 4 (K-4) 

## X

X

X

24.2

07937


### MC

383

S 

## 5,684

W 

## 7,675



# 1,179,835.00

10,380,884.00

28° 35' 52.255"

88° 26' 08.518"

5,741 

## N/A 4 bbls 20,000 bbls/da yOCS PLAN INFORMATION FORM ( CONTINUED ) 

### Provide the following information for the well with the highest Worst Case Discharge volume:

Worst Case Discharge (WCD) Well Information
WCD Well Name Surface Lease Surface Area/Block Bottom Lease Bottom Area/Block Product Type MD TVD

Analog Well(s)

Area/Block OCS Lease Well No. API No.



### Geologic Data for WCD

Open Hole Interval for WCD Top (TVD in feet) Base (TVD in feet)

Sand 1 Sand 2 Sand 3 Sand 4 Sand 5 Formation Data

Sand Name Estimated Top TVD Estimated Base TVD Estimated Net Sand Height MD (Net Pay if hydrocarbon) Estimated Net Sand Height TVT (Net Pay if hydrocarbon) Fluid Type Used in WCD? (Yes/No)

Seismic Survey Used



### Engineering Data for WCD

WCD Engineering Items WCD (STB/Day) WCD Calculated at Mudline Yes No Atmosphere Yes No Flow Correlation Outlet Pressure (Psia) Gas Turbulence Factor Software Model Used

Sand 1 Sand 2 Sand 3 Sand 4 Sand 5 Formation Data

Sand Name Permeability (mD) Initial Pressure (PSIA)

Form BOEM- 0137 (December 2011

- Supersedes all previous editions of this form which may not be used.) Page 3 of 4 MC383 No. 4 (K-4) OCS-G07937 

### MC 383OCS PLAN INFORMATION FORM ( CONTINUED ) Sand 1 Sand 2 Sand 3 Sand 4 Sand 5 Formation Data Reservoir Temperature (F) Porosity (0.00) Water Saturation (0.00) Rock Compressibility (microsips) Water Salinity (ppm) Drive Mechanism Drainage Area (acres) Oil Reservoir Data Bubble Point Pressure (PSIA) Initial Bo (RB/STB) Bo (RB/STB) @ Bubble Point Rsi (SCF/STB) Initial Oil Viscosity (Cp) Oil Viscosity (CP) @ Bubble Point Oil Compressibility (1/PSIA) Oil API Gravity (API) Specific Gas Gravity (0.00) Gas Reservoir Data Condensate API Gravity (API) Specific Gas Gravity (0.00) Yield (STB/MMCF)

Source of Permeability Used Permeability from MDT Permeability from Core Analysis Percussion core Rotary sidewall core Conventional core

Pressure Transient Analysis Permeability from CMR or NMR log analysis Permeability from other source

Provide Model Input Values for Relative Permeability: Residual Oil to Gas fraction (=1-Slc-Swc) Residual Oil to Water fraction (=Soc)
Critical Gas fraction (Sgc, Gas/Oil-Water Systems)

Residual Gas to Water fraction (Sgc, Gas/Gas-Water Systems) Kro Oil Curve Endpoint (fraction of absolute permeability) Krg Gas Curve Endpoint (fraction of absolute permeability) Krw Water Curve Endpoint (fraction of absolute permeability)

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

Form BOEM- 0137 (December 2011

- Supersedes all previous editions of this form which may not be used.) Page 4 of 4U.S. Department of the Interior OMB Control Number: 1010-0151 Bureau of Ocean Energy Management OMB Approval Expires: 12/31/14



### OCS PLAN INFORMATION FORM
General Information Type of OCS Plan: Exploration Plan (EP) Development Operations Coordination Document (DOCD)

Company Name: BOEM Operator Number:

Address: Contact Person:

Phone Number:

E-Mail Address:
If a service fee is required under 30 CFR 550.125(a), provide the Amount paid Receipt No.

Project and Worst Case Discharge (WCD) Information
Lease(s): Area: Block(s): Project Name (If Applicable):
Objective(s) Oil Gas Sulphur Salt Onshore Support Base(s):
Platform/Well Name: Total Volume of WCD: API Gravity:
Distance to Closest Land (Miles): Volume from uncontrolled blowout:
Have you previously provided information to verify the calculations and assumptions for your WCD? Yes No
If so, provide the Control Number of the EP or DOCD with which this information was provided
Do you propose to use new or unusual technology to conduct your activities? Yes No
Do you propose to use a vessel with anchors to install or modify a structure? Yes No
Do you propose any facility that will serve as a host facility for deepwater subsea development? Yes No
Description of Proposed Activities and Tentative Schedule (Mark all that apply)
Proposed Activity Start Date End Date No. of Days
Exploration drilling
Development drilling
Well completion
Well test flaring (for more than 48 hours)

Installation or modification of structure
Installation of production facilities

Installation of subsea wellheads and/or manifolds
Installation of lease term pipelines
Commence production
Other (Specify and attach description) Description of Drilling Rig Description of Structure
Jackup Drillship Caisson Tension leg platform
Gorilla Jackup Platform rig Fixed platform Compliant tower
Semisubmersible Submersible Spar Guyed tower
DP Semisubmersible Other (Attach Description)
Drilling Rig Name (If Known): Floating production system Other (Attach Description)

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

Form BOEM- 0137 (December 2011

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

## X

BP Exploration & Production Inc. 02481

Teri Halverson 200 Westlake Park Blvd, WL4-471A 281-366-6292 (office) / 281-221-5225 (mobile) Houston, Texas 77079 teri.halverson@bp.com

$3,971 2564LBN7

OCS-G07937 MC 383 NaKika Subsea Phase 3 - Kepler Development
X C-Port Service Base Fourchon, Louisiana

MC383 No. 5 (K-5) 20,000 bopd 24.2

49.0 1.900 mmbo

X

X

X

X

XOCS PLAN INFORMATION FORM ( CONTINUED ) Include one copy of this page for each proposed well/structure Proposed Well/Structure Location

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

Is this an existing well or structure? Yes No If this is an existing well or structure, list the Complex ID or API No. Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? Yes No

WCD info For wells, volume of uncontrolled blowout (Bbls/day): For structures, volume of all storage and pipelines (Bbls): API Gravity of fluid
Surface Location Bottom-Hole Location (For Wells) Completion (For multiple completions, enter separate lines)
Lease No. OCS OCS OCS OCS
Area Name

Block No.

Blockline Departures (in feet) N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L N/S Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L E/W Departure: F____ L
Lambert XY coordinates X: X: X:
X:
X:
Y: Y: Y:
Y:
Y:
Latitude/ Longitude Latitude Latitude Latitude Latitude Latitude Longitude Longitude Longitude Longitude Longitude Water Depth (Feet): MD (Feet): TVD (Feet):

Anchor Radius (if applicable) in feet: MD (Feet): MD (Feet): MD (Feet): TVD (Feet): TVD (Feet): TVD (Feet):

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

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

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

Form BOEM- 0137 (December 2011

- Supersedes all previous editions of this form which may not be used.) Page 2 of 4 MC383 No. 5 (K-5) 

## X

X

X

24.2

07937


### MC

383

S 

## 5847

W 

## 7870



# 1180030.00

10381047.00

28° 35' 53.892"

88° 26' 06.352"

5,741 

## N/A 4 bbls 20,000 bbls/da y

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 30 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix B: Plats

- Vicinity Plat

- Locations Plats
- Bathymetry Map

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 31 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix C: WCD Assumptions and Discharge Model Report
(Included in the “Proprietary Information” copy of the SDOCD)

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 32 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix D: Geologic Information

- Shallow Hazard AssessmentQ E

D

10 BP GoM SPU Appraisal Tiger Team

Shallow Hazards Assessment Proposed MC383 “K-4” Well Location

CONCLUSIONS

This Shallow Hazards Assessment for location MC383 “K-4” (OCS-G-07937) supplements the DOCD for the Kepler, Mississippi Canyon Block 383 Field to be submitted to the Minerals Management Service (MMS). This narrative defines the proposed location and alternate location “K-5” and documents the anticipated tophole drilling conditions within a radius of 1,500 ft of the location, and the potential for chemosynthetic communities within a radius of 2,000 ft from the

location.

Conditions at the proposed drilling location have been evaluated on the basis of: a shallow hazards report for MC338, 382, 383 and 427 prepared by McClelland Engineers for Shell Offshore Inc. (Shell) in 1987 based on HR2D data acquired by Shell and Deep-Tow data acquired by John E. Chance & Associates (JECA) in 1986; a geologic and stratigraphic assessment for MC382 and 426 (and including MC383) prepared by Geoscience Earth & Marine Services, Inc. (GEMS) for Vastar Resources, Inc. (Vastar) in 1999 based on exploration 3D seismic data; a regional shallow hazards survey and study of the Na Kika area prepared by Gardline in 2005 for BP America Inc. (BP) based on exploration 3D seismic data; an Archaeological Assessment for MC338, 382, 383 & 427 prepared by GEMS in 2009 for BP and based on the JECA 1986 Deep-Tow data; and well
information for offset wells MC382#1, MC383#1, K-1 and K-2, MC429 A-1 and MC520 H-1.

Results of the data review indicate

x The seafloor at the proposed “K-4” location is in a water depth of 5,741 ft and dips to the south-southeast at ~1.7°. The southern flank of the Biloxi Dome salt uplift is about 3,000 ft to the north and an area of hummocky seafloor representing buried slump deposits extends south from the salt uplift to within 1,200 ft north of the proposed

location.

x There is no evidence for the existence of high-density chemosynthetic communities within 2,000 ft of the proposed well location.

x There is no evidence for shipwreck debris or sites of archaeological significance at or within 1,500 ft of the proposed well location.

x The proposed wellbore will not intersect any faults between the seafloor and the depth limit of this investigation at Horizon 60 or 4,737 ft bml.

x The risk of encountering shallow gas is ranked as Negligible for the entire tophole

between the Seafloor and Horizon 60.

x The risk of encountering shallow water flow is ranked as: Low within sands of the fan-channel complexes of Unit 5 and Unit 6; and Negligible for all other units or portions of units between the Seafloor and Horizon 60.Q E

D

11 BP GoM SPU Appraisal Tiger Team

Shallow Hazards Assessment Proposed MC383 “K-4” Well Location

x The risk of encountering shallow oil and gas hydrates is ranked as Negligible

between the Seafloor and Horizon 60.

We advise caution, but believe that the risk of danger to personnel and damage to the borehole, equipment and environment is Low , provided strict adherence to proper drilling and cementing procedures is followed concerning these hazards until the first pressure containment string is in place at about 2,290 ft bml.

Prepared By:

Bernie Care Senior Geohazards Specialist, BP GoM SPU, Appraisal Tiger Team 09 December 2010

Reviewed By:

Craig Scherschel Geohazards Specialist, BP GoM SPU, Exploration Tiger Team 09 December 2010Bathymetry MapProposed Mississippi Canyon Block 383 “K-4” LocationPlate 6Water depths in feetContour Interval = 25 feetImages produced in FledermausVertical exaggeration = x0.13 milesMC 382ProposedLocation

3 milesGRIDMC 426MC 338MC 383MC 384MC 339MC 427MC 340MC 428

- 5 4 0 0 ’ -5 7 0 0 ’

- 5 3 0 0’

- 5 2 0 0 ’ -4

8

0 0

’BiloxiDome

- 5 8 0 0
’ - 5 9 0 0 ’ - 6 0 0 0 ’

- 5 6 0 0
’ - 4 9 0 0 ’ -5 1 0 0 ’M

- 5 5 0 0 ’ - 4

4

0

0

’ - 4 5 0 0

’ - 5

3

0

0

’Bathymetry data derived from exploration 3Dseismic water bottom time picks, converted to feetusing an average water column velocity of 4,908 ft/secderived from offset well time-depth pairs2,000 ft radiusclearance zone -5 7 0 0 ’

- 5 7 2 0 ’Water depths in feet, Contour Interval = 10 feet

- 5 7 4 0 ’ - 5 7 6 0 ’

- 5 7 8 0 ’MC 383GRIDMC383 “K-4”MC383 “K-1”MC383 “K-2”MC383 #1

- 5 8 0 0 ’

- 5 6 0 0 ’“K-5”

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 33 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix E: Shallow Hazards a nd Archeological Reports, and

Hazard Assessment

The Shallow Hazards and Archeological reports were submitted in April 2010.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 34 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix F: Environmental Impact Analysis (EIA)

# Environmental Impact Analysis

SUPPLEMENTAL DEVELOPMENT OPERATIONS COORDINATION DOCUMENT Mississippi Canyon Block 383 ( OCS

- G 7937 ) Offshore Louisiana

13 January 2012



### Prepared for:

BP Exploration & Production, Inc.

200 Westlake Park Boulevard Houston, Texas 77079

- 2696



### Prepared by:

CSA International, Inc.
8502 SW Kansas Avenue

Stuart, Florida 34997 Telephone: (772) 219

- 3000Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page ii 

## Contents

Page



### Introduction

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

A. Impact

- Producing Factors

................................ ................................ ....................... 5

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

................................ ................................ .......... 5
A.2 Physical Disturbance to the Seafloor

................................ ................................ ............................. 8
A.3 Air Pollutant Emissions

................................ ................................ ................................ .................. 8
A.4 Effluent Discharges

................................ ................................ ................................ ........................ 8
A.5 Water Intake

................................ ................................ ................................ ................................ .. 9
A.6 Onshore Waste Disposal

................................ ................................ ................................ ................ 9
A.7 Marine Debris

................................ ................................ ................................ ................................ 9
A.8 Support Vessel and Helicopter Traffic

................................ ................................ ......................... 10
A.9 Accidents

................................ ................................ ................................ ................................ ...... 10
A.9.1 Types of Accidents Evaluated

................................ ................................ ........................... 10
A.9.2 Diesel Fuel Spills

................................ ................................ ................................ ............... 11
A.9.3 Crude Oil Spill (Worst Case Discharge)

................................ ................................ ............. 12
A.9.4 Other Accidents Not Analyzed in Detail

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



### B. Affected Environment

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

C. Impact Analysis

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

C.1 Physical/Chemical Environment

................................ ................................ ................................ .. 20
C.1.1 Air Quality

................................ ................................ ................................ ......................... 20
C.1.2 Water Quality

................................ ................................ ................................ ................... 22
C.2 Seafloor Habitats and Biota

................................ ................................ ................................ ......... 24
C.2.1 Soft Bottom Benthic Communities

................................ ................................ ................... 25
C.2.2 High

- Density Deepwater Benthic Communities

................................ ............................... 27
C.2.3 Designated Topographic Features

................................ ................................ .................... 29
C.2.4 Pinnacle Trend Area Live Bo ttoms

................................ ................................ ................... 29
C.2.5 Live Bottom/Low

- Relief

................................ ................................ ................................ .... 29
C.3 Threatened, Endangered, and Protected Species and Critical Habitat

................................ ....... 29
C.3.1 Sperm Whale (Enda ngered)

................................ ................................ ............................. 31
C.3.2 West Indian Manatee (Endangered)

................................ ................................ ................ 35
C.3.3 Endangere d Mysticete Whales

................................ ................................ ......................... 36
C.3.4 Non

- Endangered Marine Mammals (Protected)

................................ .............................. 36
C.3.5 Sea Turtles (Endangered/Threatened)

................................ ................................ ............. 39
C.3.6 Piping Plover (Threatened)

................................ ................................ ............................... 42
C.3.7 Whooping Crane (Endangered)

................................ ................................ ........................ 42
C.3.8 Gulf Sturgeon (Threatened)

................................ ................................ ............................. 43
C.3.9 Smalltooth Sawfish (Endangered)

................................ ................................ .................... 45
C.3.10 Beach Mice (Endangered)

................................ ................................ ................................ 45
C.3.11 Elkhorn Coral (Endangered)

................................ ................................ ............................. 46

## Contents ( C ontinued)

Page

Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page iii C.4 Coastal and Marine Birds

................................ ................................ ................................ ............. 46
C.4.1 Marine and Pelagic Birds

................................ ................................ ................................ .. 46
C.4.2 Shore Birds and Coastal Nesting Birds

................................ ................................ ............. 49
C.5 Fisheries Resources

................................ ................................ ................................ ...................... 51
C.5.1 Pelagic Communities and Ichthyoplankton

................................ ................................ ...... 51
C.5.2 Essential Fish Habitat

................................ ................................ ................................ ....... 53
C.6 Archaeological Resources

................................ ................................ ................................ ............ 56
C.6.1 Shipwreck Sites

................................ ................................ ................................ ................. 56
C.6.2 Prehistoric Archaeological Sites

................................ ................................ ....................... 57
C.7 Coastal Habitats and Protected Areas

................................ ................................ ......................... 58
C.8 Socioeconomic and Other Resources

................................ ................................ .......................... 61
C.8.1 Recreational and Commercial Fishing

................................ ................................ .............. 61
C.8.2 Public Health and Safety

................................ ................................ ................................ .. 62
C.8.3 Employment and Infrastructure

................................ ................................ ....................... 63
C.8.4 Recreation and Tourism

................................ ................................ ................................ ... 64
C.8.5 Land Use

................................ ................................ ................................ ........................... 64
C.8.6 Other Marine Uses

................................ ................................ ................................ ........... 65



### D. Environmental Hazards

................................ ................................ ......................... 66

D.1 Geologic Hazards

................................ ................................ ................................ ......................... 66
D.2 Severe Weather

................................ ................................ ................................ ........................... 66
D.3 Currents and Waves

................................ ................................ ................................ ..................... 66



### E. Alternatives

................................ ................................ ................................ .......... 66

F. Mitigation Measures

................................ ................................ ............................. 67

G. Consultation

................................ ................................ ................................ ......... 67

H. Preparers

................................ ................................ ................................ .............. 67

I. References

................................ ................................ ................................ ............. 68Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page iv 

## List of Tables

Table Page

1 Notices to Lessees and Operators (NTLs) that are referenced in this Environmental Impact Analysis (EIA)

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

2 Matrix of impact

- producing factors and aff ected environmental resources

........................ 6

3 Vessel and aircraft fuel capacity and trip frequency or duration in MC 383 during the drilling and tie back of Well K

- 4

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

4 Conditional probabilities expressed as percent chance that an oil spill starting at Launch Point 3 will contact a certain parish, county, or coastline within 120 days (Modified from: BOEMRE, 2011a, Appendix C)

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

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

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

6 Federally

- listed endangered and threatened species potentially present in the lease area and along the nort hern Gulf Coast

................................ ................................ .... 30

7 W ildlife refuges, wilderness areas, and State and National parks within the geographic range of the potential shoreline contacts after 120 days (From: BOEMRE, 2011a)

................................ ................................ ................................ ...... 59



## List of Figures

Figure Page

1 Location of Mississippi Canyon Block 383

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

2 Bathymetric map showing the seafloo r location of the K

- 4 well site

................................ . 18

3 Location of selected environmental feature s in relation to the lease area

........................ 44Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page v 

## Acronyms and Abbreviations

ACP area contingency plan
ADIOS Automated Data Inquiry for Oil Spills bbl barrels
BMP best management practices
BOEMRE Bureau of Ocean Energy Management, Regulation and Enforcement
(Prior to 1 October 2011) BOEM Bureau of Ocean Energy Management ( Post 1 October 2011 )
BOP blowout preventer
BOPD barrels of oil per day
BP BP Exploration & Production Inc.
B.P. Before Present
BPD barrels per day
BSEE Bureau of Safety and Environmental Enforcement
CEI Coastal Environments, Inc.
CFR Code of Federal Regulations
CGA Clean Gulf Associates
CO carbon monoxide
CWIS Cooling Water Intake Structures
DP dynamically positioned
DPP Developme nt & Production Plan
EA Environmental Assessment
EFH Essential Fish Habitat
EIA Environmental Impact Analysis
EIS Environmental Impact Statement
ESA Endangered Species Act
FAD fish

- attracting device
FMMG Fugro

- McClelland Marine Geosciences,
Inc.
FR Federal Register gal gallon
GC Green Canyon GEMS Geoscience Earth & Marine Services, Inc.
GMFMC Gulf of Mexico Fishery Management Council
GoM Gulf of Mexico
GPS global positioning system
H 2 S hydrogen sulfide
HAPC Habitat Area of Particular Concern
IPF impact

- producing factor JECA John E. Chance and Associates
MARPOL International Convention for the Prevention of Pollution from Ships
MC Mississippi Canyon MGD million gallons per day
MMC Marine Mammal Commission
MMPA Marine Mammal Protection Act
MMS Miner als Management Service
MSRC Marine Spill Response Corporation NAAQS National Ambient Air Quality Standards
NMFS National Marine Fisheries Service
NO 2 nitrogen dioxide
NOAA National Oceanic and Atmospheric Administration
NO x nitrogen oxides
NPDES National P ollutant Discharge Elimination System NPS National Park Service
NRC National Research Council
NTL Notice to Lessees and Operators
NWR National Wildlife Refuge
OBM oil

- based mud
OCS Outer Continental Shelf
OSAT Operational Science Advisory Team
OSRA Oil Spill Risk Analysis
OSRP Oil Spill Response Plan
PAH polycyclic aromatic hydrocarbon
PM particulate matter
PSD Prevention of Significant Deterioration
ROV remotely operated vehicle
SBM synthetic

- based mud
SDOCD Supplemental Development Operations Coordinat ion Document SHL surface hole location
SO x sulfur oxides
USCG U.S. Coast Guard
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
VK Viosca Knoll
VOC volatile organic compound
WCD worst case dischargeMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 1 

## Introduc tion

This Environmental Impact Analysis (EIA) was prepared on behalf of BP Exploration & Production Inc. (BP) for submittal to the Bureau of Ocean Energy Management (BOEM) ( f ormerly the Bureau of Ocean Energy Management, Enforcement and Regulation [ BOEMRE ] prior to
1 October 2011 and previously Minerals Management Service [MMS]). The EIA evaluates the impacts of BP’s Supplemental Development Operations Coordination Document ( S DOCD) for the drilling of well K

- 4 in Mississippi Canyon (MC) Block 383 OCS

- G

- 0 79 37

.

MC Block 383 is a subsea project development. The project consists of drilling and completing the K

- 4 well, installing the subsea infrastructure (jumper and subsea controls), and p erforming the necessary topside facilities modifications for an indepen dent subsea tie

- in to the Na Kika host facility.

Well K

- 4 will be drilled in 1,750 meters ( m ) (5,741 feet [ft]) of water in the Central Gulf of
Mexico Planning Area , approximately 10 miles northwest of the Na Kika production facility in
MC Block 474

, and 112 miles ( 196 kilometers [ km ] ) southeast of Por t Fourchon, Louisiana. The
K

- 4 well will tie into the existing oil gathering line that is part of the Na Kika h ost facility , through the existing Na Kika North Oil Loop, a 10” by 16” pipe

- in

- pipe flowline ut ilizing a spare connection hub located on one of the three Ariel F ield pipeline end termination s

. The production system will be controlled using a new umbilical t o be installed in concurrence with the Ariel A

- 5 and Kepler K

- 4 well additions (i.e.

, Na Kika Phase 3 expansion project). The new control system will suppl y hydraulic power, chemicals

, and power/communication signals
to the tree mounted subsea control modules. Connections between the control umbilical and tree system will be completed using stee l tube flying leads and redundant electric flying leads.

The lease area is located in the deepwater Gulf of Mexico, approximately 49 miles (79 km) from the nearest shoreline (Louisiana), 112 miles (196 km) from the primary onshore support base at
Port Fourchon, Louisiana and 154 miles (248 km) from the helicopter support base in Houma,
Louisiana. C onstruction vessels will be based at the Core shipyard in Theodore, Alabama ( Figure 1 ) . No new or expanded fac ilities will be required for this project.

This EIA is a project

- and site

- specific analysis of BP’s planned activities prepared in accordance with BOEM regulations, including 30 Code of Federal R egulations ( CFR ) 250.242(s) and 250.261, as well as Notice t o Lessees and Operators (NTL) 2008

- G04. An EIA is a project

- specific analysis that focuses on the impacts of this specific plan to the extent feasible. Potential impacts have been analyzed at a broader level in the Programmatic Environmental Impact State ment (EIS) for the Outer Continental Shelf (OCS) Oi l and Gas Leasing Program (MMS, 2007a) and in recent multi

- lease

- sale EISs for the Western and Central Gulf of Mexico Planning Areas (MMS, 2007b, 2008), as well as the Environmental Assessment (EA) for Gul f of Mexico deepwater operations and activities (MMS, 2000). In addition, the Draft Supplemental EIS for the Central Planning
Area and the Final Supplemental EIS for the Western Planning A rea lease sales (BOEMRE, 2011a,b) update environmental baseline inf ormation in light of the Macondo ( Deepwater
Horizon ) incident. Analysis from these documents is incorporated here by reference.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 2

Figure 1. Location of Mississippi Canyon Block 383

.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 3 Statistics from offshore drilling in the U.S. Gulf of Mexico provide a reasonable basis for evaluating oil spill risk during exploratory drilling . According to Holand (1997), the average frequency of a loss of well control incident or “blowout” during exp loratory drilling in the
U.S. Gulf of Mexico is 0.00593 blowouts per well drilled, or one blowout per 169 exploration wells drilled. Similarly, the MMS Safety and Environmental Management Program blowout incident rate for 1996 to 1999 was approximately fi ve blowouts per 1,000 well starts, or one blowout per 200 well starts ( MMS, 2000 ). More recently, in its Draft Supplemental EIS for the Central Gulf of Mexico Planning Area, BOEMRE confirmed that “significant changes to the spill rates for the entire OCS are not anticipated” (BOEMRE, 2011a).

Historically, most blowouts have not resulted in oil spills . O f 151 well blowouts in the Gulf of Mexico from 1971 to 1995, only 18 (12%) resulted in oil spills , with a to tal combined volume of 1,000 barrels ( bbl ) of c rude oil and condensate released (MMS, 200 0 ). Between 1964 and 1999, almost all offshore spills (94%) from drilling and production

- related operations on the OCS were less than or equal to 1 bbl in size (Anderson and LaBelle, 2000) . According to BOEMRE’s Interim Final Drilling Safety Rule ( 75 Federal Register (FR) 63365 dated 10 October 2010 ) issued following the Macondo incident , the baseline risk of a catastrophic blowout is estimated to be about once every 26 years

. Oil spill response

- related activities for facilities included in th is SDOCD are governed by the
BP Regional Oil Spill Response Plan (OSRP). This OSRP meets the requirements contained in
30 CFR 254

.

Sections A through I of this EIA provide the information required by NTL 2008

- G04. The main impact related discussions are in Section A (Impact Producing Factors) and Section C (Impact Analysis). Table 1 summarizes the BOEM and Bureau of Safety and Environmental Enforcement ( BSEE ) NTLs that are referenced in this EIA.

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

NTL Title Summary

2010

- N10 Statement of Compliance with Applicable Regulations and Evaluation of Information Demonstrating Adequate Spill Response and Well Containment
Resources Informs operators using subsea blowout preventers (BOPs) or surface BOPs on floating facilities that applications for well permits must include a statement signed by an authorized company official stating that the operator will conduc t all activities in compliance with all applicable regulations, including the increased safety measures regulations (75 FR 63346). Informs operators that BOEM will evaluate whether each operator has submitted adequate information demonstrating that it has access to and can deploy containment resources to promptly respond to a blowout or other loss of well control.

2010

- N06 Information Requirements for Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents

on the OCS Rescinds the limitations set forth in NTL 2008

- G04 regarding a blowout scenario and worst case discharge scenario, and provides guidance regarding the information required in blowout scenario and worst case discharge scenario descriptions.Table 1. (Continued).

Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 4 NTL Title Summary

2009

- G 40 Deepwater Benthic Communities Guidance for avoiding and protecting high

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

2009

- G39 Biologically

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

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

2009

- G06 Military Warning and Water Test
Areas Provides contact links to individual command headquarters for the military warning and water test areas in the Gulf of Mexico. Lease stipulations require lessees or d esignated operators to enter into an agreement with the appropriate individual military command headquarters concerning the control of electromagnetic emissions and use of boats and aircraft in the applicable warning area or water test area before commenci ng such traffic.

2008

- G04 Information Requirements for Exploration Plans and Development Operations Coordination
Documents Guidance on the i nformation requirements for
OCS plans, including EIA requirements and information regarding compliance with the pro visions of the Endangered Species Act and Marine Mammal
Protection Act.

JOINT BOEM & BSEE
2012

- G01 Vessel Strike Avoidance and Injured/Dead Protected Species Reporting Recommends protected species identification training, recommends that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species.

BSEE
2 0 12

- G01 Marine Trash and Debris Awareness and Elimination Instructs operators to exercise caution in the handling and disposal of small items and packaging materials, requires the posting of placards at prominent locations on offshore vessels and structures, and mandates a yearly marine trash and debris awareness training and certification process.

BOEM & BSEE 2011

- JOINT

– G 0 1 Archaeological Resource Surveys and Reports Provides guidance on regulations regarding archaeological discoveries, specifies requirements for archaeological resource surveys and reports, and outlines options for protecting archaeological

resources.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 5 

## A. Impact

- Producing Factors

Table 2 is a matrix of impact

- producing factors (IPFs) and potentially affected environmental resources. An “X” indicates that an IPF could reasonably be expected to affect a certain

resource . The “

— ” mark indicates a resource in which no impact s or negl igible impact s are expected based on currently available information

. The numbered footnotes in Table 2 refer to specific BOEM guidelines and requirements. Where impacts and possible or expected , an analysis is provided in Section C . Potential IPFs for the proposed activity are listed below and briefly discussed in the following subsections:

• Drilling rig presence (including noise and lights);

• Physical disturbance to the seafloor;

• Air pollutant emissions;

• Effluent discharges;

• Water intake;

• Onshore waste d isposal;

• Marine debris;

• Support vessel and helicopter traffic; and

• Accidents.



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

Two types of development drilling rigs are available for this project:

• D ynamically positioned (DP) drillship s ; and

• DP semi submersible s

. DP drillships and DP semisubmersibles use a global positioning system (GPS ), specific computer software, sensors , and their own propellers and thrusters to maintain position. T hrough satellite navigation the location of the vessel is precise ly monitored, and thrusters positioned at various locations about the vessel’s hull are activated to provide any required station keeping adjustment. This allows operations at sea where mooring or anchoring is not feasible.

The physical presence of a floa ting structure in the ocean can attract pelagic fishes and other marine life, as discussed in Section C.5.1 . Sound and vibration from generators and machinery aboard a floating DP facility are also transmitted into the water. Richardson et al. (1995) noted that underwater noise levels from semisubmersibles are relatively low. Drilling operations produce noise that is not particularly intense and is strongest a t low frequencies, a veraging
10 to 500 hertz ( Hz ) (Richardson et al., 19 95; MMS, 2000). All DP vessels maintain exterior lighting for navigational and aviation safety in accordance with Federal regulations.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 6 Table 2. Matrix of impact

- producing factors and affected environmental resources. X = potential impact;

-- = no impact or negligible impact.

Environmental Resources Impact

- producing Factors Drilling Rig Presence (incl. noise & lights) Physical Disturbance to Seafloor Air Pollutant Emissi ons Effluent Discharges Water Intake Onshore Waste Disposal Marine Debris Support Vessel/Helo

Traffic Accidents D iesel Fuel Spill Oil Spill (WCD) Physical/Chemical Environment Air quality and greenhouse gases

-- -- X ( 9 )

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

-- -- -- X

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

-- X

-- X

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

- density deepwater benthic communities

-- -- (4)

-- -- (4)

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

-- -- (1)

-- -- ( 1)

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

-- -- (2)

-- -- (2)

-- -- -- -- -- -- L ive bottom /Low

- Relief

-- -- (3)

-- -- (3)

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

-- -- -- -- -- X X (8) X (6,8) X (6,8) West Indian manatee (endangered)

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

-- X (6,8) Endangered mysticete whale s

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

-- -- -- Non

- endangered marine mammals (protected) X

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

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

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

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

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

-- -- X (6) Smalltooth sawfish (endangered)

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

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

-- -- -- -- -- -- -- -- -- X (6) Elkhorn coral (endangered)

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

Marine birds X

-- -- -- -- -- -- X X (6) X (6) Shorebird s and coastal nesting birds

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

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

-- -- X X

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

-- X X

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

-- -- (7)

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

-- -- (7)

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

Beaches

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

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

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

-- -- -- -- -- -- -- -- -- X (6) Socioeconomic and Other Resources

Recreational and commercial fishing X

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

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

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

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

-- -- -- -- -- X

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

-- -- -- -- -- -- -- -- -- X (6)
WCD = worst case discharge.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 7 Table 2 Footnotes and Applicability:
(1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well, rig site, or any anchors will be on the seafloor within the following: (a) 4

- mi zone of the Flower Garden Banks, or the 3

- mi zone of Stetson Bank; (b) 1,000

- m, 1

- mi, or 3

- mi zone of any topographic feature (submarine bank s ) protected by the Topographic Features Stipulation attached to an Outer Continental Shelf (OCS) lease; (c) Essential Fish Habitat (EFH) criteria of 500 ft fro m any no

- activity zone; or (d) Proximity of any submarine bank (500

- ft buffer zone) with relief greater than 2 m that is not protected by the Topographic Features Stipulation attached to an OCS lease.

• Not applicable. The lease is not within or near a marine sanctuary, topographic feature, or

no

- activity zone. There are no submarine banks in the blocks.
(2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinnacle Trend ) Stipulation attached to an OCS lease.

• The Live Bottom (Pinnacle Trend) Stipulation is not applicable to the lease area.
(3) Activities within any Eastern Gulf OCS block where seafloor habitats are protected by the Live Bottom (Low

- Relief) Stipulation attached to an OCS lease.

• The Live Bottom (Low

- Relief) Stipulation is not applicable to the lease area.
(4) Activities on blocks designated by the BOEM as being in water depths 300 m or greater.

• No impacts on high

- density deepwater benthic communities are anticipated. Because dynamically

p ositioned vessels will be used for the activities in this plan, there will be no seafloor disturbances from the use of anchors and t here are no features indicative of high

- density chemosynthetic communities or coral communities within 610 m (2,000 ft) of a ny drilling mu d/cuttings discharge location.
(5) Exploration or production activities where H 2 S concentrations greater tha n 500 ppm might be encountered.

• Not applicable. The BOEM Regional Supervisor has classified the area as “ hydrogen sulfide ( H 2 S ) absen t.”
(6) All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you determine would impact these environmental resources. If the proposed action is located a sufficient distance from a resource that no i mpact would occur, the EIA can note that in a sentence or two.

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

. (7) All activities that involve seafloor disturbances, including ancho r emplacements, in any OCS block designated by the BOEM as having high

- probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are adjacent to the lease block in which your planned activity will oc cur. If the proposed activities are located a sufficient distance from a shipwreck or prehistoric site that no impact would occur, the EIA can note that in a sentence or two.

• No impacts on archaeological resources are expected. The lease area is not on t he list of high

- probability blocks for shipwrecks and is well beyond the 60

- m depth contour used by the BOEM as the seaward extent for prehistoric archaeological site potential in the Gulf of Mexico. Because dynamically positioned vessels will be used for the activities in this plan, there will be no seafloor disturbances from the use of
anch ors for facility installation.
(8) All activities that you determine might have an adverse effect on endangered or threatened marine mammals or sea turtles or their cr itical hab itats.

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

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

• Not applicable.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 8 

## A.2 Physical Disturbance to the Seafloor

The seafloor at the proposed K

- 4 well location appears smooth and has an average slope of approximately 1. 7 ° to the southeast (BP GoM Resources, 2011)

. Sources of seafloor disturbance in block MC 383 are limited to the drilling of the K

- 4 well itself. All drilling and facility installation will be done by DP vessels.

In water depths of 600 m (1,969 ft) or greater, DP drillships and DP semisubmersibles disturb only a very small area of the seafloor around the wellbore surface hole location (SHL) where the bottom template and blowout preventer ( BOP ) are located. Depending on the specific well configuration, this area is generally about 0.25 hectares (ha) (0.62 acres [ac]) per well (MMS, 2001, 2007b)

.


## A.3 Air Pollutant Emissions

Air pollutant emissions are estimated in SDOCD Section 9.0 . Sources include construction vessels involved in facility installation, drilling ope rations onboard the drilling vessel, and the engines of service vessels. These emissions occur mainly from combustion of diesel fuel. The combustion of fuels occurs on diesel powered generators, pumps, or motors and from lighter fuel motors. Primary air pollutants typically associated with OCS activities are suspended particulate matter (PM), sulfur oxides (SO
x ), nitrogen oxides (NO
x ), volatile organic compounds (VOCs), and carbon monoxide (CO).

The Air Quality Emissions Report prepared in accordance wit h BOEM requirements demonstrates that the projected emissions are below exemption levels set by the applicable regulations in 30 CFR 550 .303 (See SDOCD Section 9 ) . Based on this and the distance to shore, it can be concluded that the emissions will not significantly affect the air quality of the onshore area for any of the criteria pollutants. No further analysis or control measures are required.



## A.4 Effluent Discharges

Effluent discharges are summarized in SDOCD Section 8.0 , Waste Discharge Information

. O ffshore discharges will be in accordance with the National Pollutant Discharge Elimination System (NPDES) General Permit No. GMG290000 issued by the U.S. Environmental Protection Agency (USEPA). Discharges will be in compliance with and monitored as r equired by the permit.

Water

- based drilling muds and cuttings will be released at the seafloor during the initial well intervals before the marine riser, which allows returns to the surface, is set. Excess cement slurry also will be released at the seaflo or during casing installation for the riserless portion of the drilling operations. All muds associated with synthetic

- based drilling muds (SBMs) will be collected on the rig and either reused by the vendor, or transported to Port Fourchon, Louisiana for recycling and/or disposal in an approved facility. Well bore cuttings with residual SBMs will be treated to levels at or below NPDES requirements and discharged to the seafloor in accordance with the NPDES permit.

Other effluent discharges in accordance w ith the NPDES permit may include excess cement slurries, non

- contact cooling water, treated sanitary and domestic wastes, deck drainage, desalination unit brine, BOP control fluids, uncontamin ated fresh water and seawater, ballast water, and miscellaneous discharges i dentified in the NPDES permit.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 9 

## A.5 Water Intake

Seawater will be drawn from the ocean for once through, non

- contact cooling of machinery on the drilling rig.

Cooling Water Intake Structures (CWIS) on new offshore faci lities are regulated by
Sec tion 316(b) of the Clean Water Act. The DP drillships being considered for this project were built prior to 17 July 2006 and are not subject to the CWIS design requirements stated in
NPDES P ermit GMG290000

. N o significant entrainment or impingement impac t on key species is expected based on the findings of the 2009 desktop CWIS Source Water Biological Baseline Characterization Study, as required in the NPDES permit, Part I.B.12.a.



## A.6 Onshore Waste Disposal

A list of the solid and liquid wastes generated during this type of the project to be disposed of onshore are tabulated in SDOCD Appendix E

, Project Generated Waste

. Typical waste streams requiring onshore disposal from a project of this nature include:

• drilling muds /cuttings ;

• c ompletion fluids ;

• d omest ic wastes ;

• r ecyclables (glass, plastic, cardboard, pa per , and aluminum)

- n on hazardous ; and

• w aste chemicals

. All other wastes generated are considered contractor waste and are identified in the waste table in Appendix E of the SDOCD . These wastes will be managed accordingly to contractor’s waste procedures.

These waste streams will be separated at the rig and transported to shore for disposal in an appropriately permitted facility.



## A.7 Marine Debris

Trash and debris released into the marine environment ca n harm marine mammals, turtles, and birds through entanglement and ingestion. BP will adhere to the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) Annex V requirements, US EPA,
U.S. Coast Guard (USCG), and BOEM regulatio ns and NTLs regarding solid wastes. BOEM regulations at 30 CFR 250.300(a) and (b)(6) prohibit operators from deliberately discharging containers and other similar materials (i.e., trash and debris) into the marine environment, and 30 CFR 250.300(c) requir es durable identification markings on equipment, tools and containers (especially drums), and other material. USCG and USEPA regulations require operators to become proactive in avoiding accidental loss of solid waste items by developing waste management plans, posting informational placards, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to prevent accidental loss of solid waste. BP complies with BSEE NTL 2012

- G01 , which instructs operators to exercise caution in the handling and disposal of small items and packaging materials, requires the posting of placards at prominent locations on offshore vessels and structures, and mandates a yearly marine trash and debris awareness training and certification proc ess. BP’s compliance with all applicable laws, regulations, and BSEE NTL 2012

- G01 should avoid impacts on the environment.Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for SDOCD Page 10 

## A.8 Support Vessel and Helicopter Traffic

BP will use existing shorebase facility at Port Fourchon, Louisiana for onshore vessel support. Air transportation will originate out of Houma, Louisiana. No terminal expansion or construction is planned.

Installation of the pipeline jumper will require a workboat vessel and supply vessels. The workboat vessel based out of Port Fourchon, Louisiana w ill be on site during pipeline jumper installation and tieback. Typically, all vessels involved in this project will move to the project

area via the most direct route from the shorebase.

A helicopter such as the Sikorsky S92, or similar, will be used for crew changes. The helicopter will be used to tr ansport personnel and small supplies and normally will take the most direct

route of travel between the shorebase and the lease area when air traffic and weather conditions permit. Helicopters typically maintain a minimum altitude of 213 m (700 ft) while in
transit offshore, 305 m (1,000 ft) over unpopul ated areas or across coastlines, and 610 m (2,000 ft) over populated areas and sensitive habitats such as wildlife refuges and park properties.

Table 3 summarizes the fuel capacity and trip frequency of these vessels and aircraft.

Table 3. Vessel and aircraft fuel capacity and trip frequency or duration in MC 383 duri ng the drilling and tie back of Well K

‐ 4.

Vessel/Aircraft Type Maximum Fuel Tan k Storage Capacity Trip Frequenc y

or Duration Helicopter 760

‐ gals 5

‐ flts/week Supply Boat 6,000

‐ bbls Every 3 to 5 days
Workboat 3,600

‐ bbls 24 hours/day at rig
Crewboat (FSV) 1,000

‐ bbls 1

‐ 2/week



## A.9 Accidents

A.9.1 Types of Accidents Evaluated

The analysis in this EIA focuses on two potential accidents:

 a diesel fuel spill, which is the most likely type of spill during OCS exploration activities; and

 a crude oil spill worst case discharge (WCD) for this SDOCD, which is an oil spill resulting from an uncontrolled blowout.

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

.

MMS (2007b) and BOEMRE ( 2011a,b) analyze three other types of accidents: riser disconnect and/or SBM spills, chemical spills, and vessel collisions. These types of accidents are discussed briefly in Section A.9.4

.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 11 

### A.9.2 Diesel Fuel Spills

Spill Size . According to the analysis in MMS (2007b), the most likely type of diesel fuel spill is generally less than 1,000 bbl. Historical ly, most diesel spills have been ≤1 bbl, and this size is predicted to be the most common in ongoing and future OCS activities in the Western and Central Gulf of Mexico Planning Areas (MMS, 2007b). The average size for spills ≤1 bbl is
0.07 bbl, and the median size for spills of 1 to 10 bbl is 3 bbl (MMS, 2007b). Operational experience suggests that the most likely cause of a diesel fuel spill would be a hose rupture resulting in the loss of the contents of a diesel fuel transfer hose.

Spill Fate

The water

- soluble fractions of diesel are dominated by two

- and three

- ringed polycyclic aromatic hydrocarbons (PAHs), which are moderately volatile (National Research Cou ncil [NRC], 2003). The constituents of these oils are light

- to

- intermediate in molecular weight and can be readily degraded by aerobic microbial oxidation. Diesel is so light that it will not sink to the seafloor. Diesel dispersed in the water column ca n adhere to suspended sediments, but this generally occurs only in coastal areas with high suspended solids loads (NRC, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes (National Oceanic and Atmospheric Administration [NOAA], 2006). . The f ate of a diesel fuel spill in the lease area would depend on seasonal meteorological and oceanographic conditions at the time, as well as the effectiveness of spill response activities. However, given the open ocean location of the lease area, and the dur ation of a diesel fuel spill of 1,000 bbl or less, the opportunity for impacts to occur would be very brief. S licks from spills <1,000 bbl may persist from a few minutes (<1 bbl), to a few days (10 to 1,000 bbl) on the open ocean. Spilled diesel fuel wou ld rapidly spread out, evaporate, and weather, quickly becoming dispersed into the water column. Most spills <1,000 bbl are expected to be diesel, which dissipates very rapidly. Diesel is a distillate of crude oil and does not contain the heavier compone nts that contribute to crude oil’s longer persistence in the environment (MMS 2007 b ).

The fate of a diesel fuel spill was estimated using NOAA’s Automated Data Inquiry for Oil Spills ( ADIOS2 ) model. This model uses the physic al properties of oils in its database to predict the rate of evaporation and dispersion over time, as well as changes in the density, viscosity, and water content of the product spilled. It is estimated that over 90% of a diesel fuel spill would be

evapor ated or dispersed within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac) depending on sea state and weather conditions (NOAA, 2006).

The ADIOS2 results indicate that a diesel fuel spill in the 1,000 bbl or less range would not have any impacts on coastal or shoreline resources. The lease blocks are approximately 49 miles (79 km) from the nearest shoreline (Louisiana). MMS (2007b) similarly concluded that diesel fuel spills <1,000 bbl are not expect ed to persist as a slick on the surface of the water beyond a few days and are unlikely to make landfall or reach coastal waters prior to breaking up.
MMS (2007b) noted that this conclusion is supported by a previous analysis of 3

- day trajectory model run s, previous weathering analyses, and historical records of spill incidents.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 12 Spill Response . In the event t he shipboard prevention procedures fail to prevent a diesel fuel spill, response equipment and trained personnel would be activated so that any spill effects would be localized and would result only in short

- term environmental consequences.
Section 10

, Oil Spill s Information of this SDOCD provides a discussion of BP’s spill response procedures.

Weathering

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

n

- alkanes and then the light aromatics. Other petroleum components are biodegraded more slowly. Photooxidation attacks mainly the medium and high molecular weight PAHs in the oil o n the water surface (NRC, 2003)

. . Following a diesel fuel spill, several physi cal, chemical, and biological processes, collectively called weathering, interact to change the physical and chemical properties of the diesel, and thereby influence its harmful effects on marine organisms and ecosystems. The most important weathering pro cesses include spreading, evaporation, dissolution, dispersion into the water column, formation of water

- in

- oil emulsions, photochemical oxidation, microbial degradation, adsorption to suspended particulate matter, and stranding on shore or sedimentation t o the seafloor (NRC, 2003).

Diesel fuel spill response

- related activities for facilities included in this SDOCD are governed by BP’s Regional OSRP. The OSRP meets the requirements contained in 30 CFR 254

.



### A.9.3 Crude Oil Spill (Worst Case Discharge)

Spill Size

Historically, blowouts are rare events and most do not result in oil spills. Holand (1997) estimated a probability of 0.0021 for a deep drilling blowout during exploration drilling b ased on the number of blowouts divided by the accumulated operating tim e using U.S. Gulf of Mexico data

. An updated analysis using the SINTEF database estimates a blowout frequency of
0.0017 per exploratory well for non

- North Sea locations (International Association of Oil & Gas Producers, 2010). As noted by MMS (2007b), from 1992 to 2005, half of blowouts lasted less than half a day, and fewer than 10% of blowouts resulted in spilled oil. BOEM is in the process of updating these blow out frequency estimates to include the r ecent Macondo event; however, significant changes to the spill rates for the entire OCS are not anticipated ( BOEMRE, 2011a,b ). As noted in the Introduction , the baseline risk of a catastrophic blowout is estimated to be once every 26 years (BOEMRE Interim Final Drilling Safety Rule, 75 FR 63365, 10 October 2010). . In accordance with requirements of NTL 2010

- N06, BP has estimated a WCD for this
SDOCD as 20,000 barrels of oil per day (BOPD). The expected time to drill a relief well is 90 days, and the total volume of a spill over this duration would be 2.37 million barrels of oil. The detailed analysis of this calculation can be found in SDOCD Section 10

.

Included in SDOCD Section 10 are BP ’s calculations and information as required by
NTL 2010

- N06, including descriptions of measures to prevent a blowout, reduce the likelihood of a blowout, and con duct effective and early intervention in the event of a blowout. BP will also comply with NTL 2010

- N 10 and the Interim Final Drilling Safety Rule, which specif ies additional safety measures for OCS activities.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 13 Spill Trajectory

A special OSRA run was conducted for the recent BOEMRE Central and Western Gulf of Mexico Planning Area Supplemental EIS s ( BOEMRE, 2011a,b) in order to estimate the impacts of a possible future catastrophic long

- duration oil spill. In this OSRA model run a hypothetical high

- volume, long

- duration oil spill was assumed to have occurred, and the analysis emphasized modeling a spill that continue d for 90 consecutive days, with each traject ory tracked for up to 120 days. . The fate of a large oil spill in the lease area would depend on meteorological and oceanographic conditions at the time. The Oil Spill Risk Analysis (OSRA) model is a computer simulation of oil spill transport that uses realistic data for winds and curren ts to predict spill fate. Although this model has received some criticism recently (Earthjustice, 2011), it is still the most widely scientifically accepted model for estimating the fate of fuel spills. The model does not assume a particular spill size b ut has generally been used by the BOEM RE /MMS to evaluate contact probabilities for spills greater than 1,000 bbl.

The OSRA model run for this revised analysis was conducted for five hypothetical launch points in the Central a nd Western Gulf o f Mexico Planning Areas

. These launch point s were d eliberately located in area s identified as having a high possibility of containing large oil

reserves.

The five launch point areas were as follows:

1. Central Gulf of Mexico shelf are a west of the Mississippi River (28.98 660° N latitude, 92.17851 ° W longitude );
2. Central Gulf of Mexico shelf area east of the Mississippi River ( 29.91388 ° N latitude, 88.15338 ° W longitude);
3. Central Gulf of Mexico slope area ( 27.31998 ° N latitude, 90.22203 ° W longitude);
4. Western Gulf of Mexico shelf area ( 27.55423 ° N latitude, 96.7 6627 ° W longitude); and
5. Western Gulf of Mexico slope area (27.51367° N latitude, 94.51836° W longitude).

The results for Launch Point 3 , which are the most applicable to the project area and within the Central Planning Area , are presented in Table 4

.

OSRA is a preliminary risk assessment model designed to determine the relative risk that a specific coastal location will be oiled within a specific amount of time following an oil spill in offshore waters . In the event of an actual oil spill, real

- time monitoring and trajectory modeling would be conducted using current and wind data available from the rigs and permanent production structures in the area

. Satellite and aerial monitoring of the plume and real

- time trajectory modeling using wind and curren t data would continue on a daily basis to help position equipment and human resources throughout the duration of any major spill or uncontrolled release

.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 14 Table 4

. Conditional probabilities expressed as percent chance that an oil spill starting at Launch Po int 3 will contact a certain parish, county, or coastline within 120 days (Modified from: BOEMRE, 2011a, Appendix C).

Season Winter Spring Summer Fall

Day 3 10 30 120 3 10 30 120 3 10 30 120 3 10 30 120
Cou nty or Parish Percent Chance

Cameron, Texas

-- -- -- 2

-- -- -- -- -- -- -- 2

-- -- -- 2 Willacy, Texas

-- -- -- 3

-- -- -- -- -- -- -- 2

-- -- -- 3 Kenedy, Texas

-- -- -- 8

-- -- -- 1

-- -- -- 9

-- -- -- 5 Kleberg, Texas

-- -- 1 6

-- -- -- -- -- -- -- 4

-- -- 1 6 Nueces, Texas

-- -- 1 6

-- -- -- -- -- -- -- 2

-- -- 1 2 Aransas, Texas

-- -- -- 5

-- -- -- 1

-- -- -- 3

-- -- -- 2 Calhoun, Texas

-- -- 1 6

-- -- -- -- -- -- -- 6

-- -- 1 4 Matagorda, Texas

-- -- 2 17

-- -- 3 4

-- -- -- 11

-- -- 1 6 Brazoria, Texas

-- -- 3 12

-- -- 1 3

-- -- 2 8

-- -- 1 5 Galveston, Texas

-- -- 3 10

-- -- 3 6

-- -- 2 5

-- -- 1 4 Jefferson, Texas

-- -- 1 4

-- -- 7 9

-- -- 1 1

-- -- -- 2 Cameron, Louisiana

-- -- 1 4

-- -- 11 12

-- 1 1 4

-- -- -- 4 Vermilion, Louisiana

-- -- 1 2

-- -- 5 6

-- 1 1 2

-- -- -- -- Iberia, Louisiana

-- -- -- 1

-- -- 4 4

-- -- -- -- -- -- -- -- Terrebonne, Louisiana

-- 1 2 3

-- 4 12 14

-- -- -- 2

-- -- -- -- Lafourche, Louisiana

-- -- 1 1

-- 2 8 10

-- -- 1 2

-- -- -- -- Jefferson, Louisiana

-- -- -- 1

-- -- 2 2

-- -- 1 1

-- -- -- -- Plaquemines, Louisiana

-- -- -- 1

-- 2 10 12

-- -- 1 2

-- -- -- -- Jackson, Mississippi

-- -- -- -- -- -- 1 1

-- -- -- -- -- -- -- -- Baldwin, Alabama

-- -- -- -- -- -- 1 1

-- -- -- -- -- -- -- -- Bay, Florida

-- -- -- -- -- -- -- 1

-- -- -- -- -- -- -- -- Franklin, Florida

-- -- -- 1

-- -- -- -- -- -- -- -- -- -- -- -- Monroe, Florida

-- -- -- -- -- -- -- -- -- -- -- 1

-- -- -- 1 Dade, Florida

-- -- -- -- -- -- -- -- -- -- -- 1

-- -- -- --

“

-- ” = Values <1.0%. Areas where there is <0.5% chance of contact within 120 days are not shown.

Weathering

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

- alkanes and then the light aromatics from the oil. Other petroleum compo nents are biodegraded more slowly. Photo

- oxidation attacks mainly the medium and high molecular weight PAHs in the oil on the water surfa ce. . Following an oil spill, several physical, chemical, and biological processes, collectively called weathering, interact to change the physical and che mical properties of the oil, influencing potential effects to marine organisms and ecosystems. The most important weathering processes include spreading, evaporation, dissolution, dispersion into the water column, formation of water

- in

- oil emulsions, phot ochemical oxidation, microbial degradation, adsorption to suspended particulate matter, and stranding on shore or sedimentation to the seafloor ( NRC , 2003).

Spill Response

. BOEMRE has issued re c ent NTLs following the Macondo spill regarding additional oil

- spill preventi on and response planning measures

. These NTL s are summarized in Table 1

, and additional BOEMRE (2011a ) guidance is provided below.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 15 NTL 2010

- N10

– Statement of Compliance with Applicable Regulations and Evaluation of Information Demonstrating Adequate Spil l Response and Well Containment Resources : This NTL, effective 8 November 2010, applies only to operators conducting operations using subsea or surface blowout preventers ( BOPs ) on floating facilities. It explains that lessees and operators submit a stat ement signed by an authorized company official with each application for a well permit indicating that they will conduct all of their authorized activities in compliance with all applicable regulations, including the Increased Safety Measures Regulations a t 75 FR 63346. The NTL also informs lessees that BOEMRE will be evaluating whether or not each operator has submitted adequate information demonstrating that it has access to and can deploy surface and subsea containment resources that would be adequate t o promptly respond to a blowout or other loss of well control. The NTL notifies the operator that BOEMRE intends to evaluate the adequacy of each operator to comply in the operator’s current OSRP

.

NTL 2010

- N06

– Information Requirements for Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents on the OCS

All of the existing and proposed activities and facilities proposed by this Supplemental DOCD for BP Exploration & Production Inc. (Operator No. 2481) will be cove red by the OSRP filed by BP America Inc. (Operator No. 21591) in accordance with 30 CF R Part 254 and approved on July 21, 2009. A revised Regional OSRP was submitted to the BSEE on October 19 , 2011 and is awaiting approval

. : This NTL, effective 18 June 2010, explains the procedures for the lessee or operator to submit supplemental information for new or previously submitted EPs, Development and Production Plans ( DPPs ) , or Development Operations Coordination Documents ( SDOCD s )

. The required suppleme ntal information includes the following: 1) a description of the blowout scenario as required by 30 CFR 254(b) and 254 (h); 2) a description of their assumptions and calculations used in determining the volume of the WCD required by
30 CFR 254 .26 ; and 3) a description of the measures proposed that would enhance the ability to prevent a blowout, to reduce the likelihood of a blowout, and to conduct effective and early intervention in the event of a blowout, including the arrangements for drilling relief wells and any other measures proposed. The early intervention methods of the third requirement could actually include the surface and subsea containment resources that BOEMRE announced in NTL 2010

- N10, which states that BOEMRE will begin reviewing to ensure th at the measures are adequate to promptly respond to a blowout or other loss of well control.

BP’s revised OSRP includes info rmation about enhanced measures for responding to a spill in open water, near shore response and shoreline spill response based on lessons learned from the Deepwater Horizon oil spill. In complying with the requirements of 30 CFR § 254 and related
NTLs

, BP’s revised OSRP includes:

• Provisions to maintain access to a supply of dispersant and fireproof boom for use in the event of an uncontrolled, long

- term blowout, for the length of time required to drill a relief well;

• Contingencies for maintaining an ongo ing response for the length of time required to drill a relief well;

• A description of the measures and equipment necessary to maximize the effectiveness and efficiency of the response equipment used to recover the discharge on the water’s surface.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 16 The des cription will include methods to increase encounter rates, the use of vessel tracking, and the use of remote sensing technologies;

• Information on remote sensing technology and equipment to be used to track oil slicks, including oil spill detection systems and remote thickness detection systems (such as
X

- band/infrared systems);

• Information pertaining to the use of vessel tracking systems and communication systems between response vessels and spotter personnel;

• A shoreline protection strategy that is consist ent with applicable area contingency plans (ACP s ); and

• For operations using a subsea BOP or a surface BOP on a floating facility, a discussion regarding strategies and plans related to source abatement and control for blowouts from drilling.

BP is a member of the Marine Spill Response Corporation (MSRC), Clean Gulf Associates (CGA)

, and the National Response Corpora tion and would utilize said OSRP personnel and equipment in the event of an oil spill in the Gulf of Mexico. CGA is an oil spill cooperative th at owns a large inventory of oil spill clean

- up equipment and is supported by MSRC . MSRC is responsible for storing, inspecting, maintaining, and dispatching CGA’s equipment. MSRC will also provide personnel to supervise and operate the equipment. Prima ry response equipment for the activation of BP’s OSRP is located in Houma , Louisiana, Lake Charles, Louisiana, and Galveston, Texas. The preplanned staging area for this SDOC D is Port Fourchon, Louisiana.

See SDOCD S ection 10 f or a detailed description of BP ’s OSRP and site

- specific response for an oil spill associated with this project.



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

BOEMRE EIAs (MMS, 2007b; BOEMRE 2011a,b ) discuss three other types of accidents which have the potential to occur in this type of a development project: SBM releases resulting from accidental riser disconnects, chemical spills, and vessel collisions. These accidents are discussed briefly here; there are no other site

- specific issues for this SDOCD. The more extensive analysis in the lease sale EISs for these topics is incorporated by reference.

Riser Disconnect SBM Spills

T he frequency of SBM spills in the Gulf of Mexico has been decreasing . An SBM spill of 1,061 bbl which occurred in October 2007 in Green Canyon ( GC ) Block 726 was to be studied as a “spill of opportu nity” using funds set aside from a previous MMS research program. However, t his study

, titled Synthetic

- based Fluid Spill of Opportunity Environmental Impact and Recovery

, suffered a major equipment malfunction and because SBM releases were declining addi tional funding was not provided to continue this study ( BOEMRE

, 2011 c ). . In deepwater drilling, SBMs a re preferred over petroleum oil

- based mud s (OBMs) due to the superior environmental properties of SBMs

. The synthetic base fluid s used in SBM’s are less toxic to the marine environment and have a greater potential to biodegrade. SBMs have been used in the Gulf of Mexico since the mid 1990 s and between
5 and 20 SBM releases are anticipated each year as a result of offshore drilling programs. The majority of these releases are <50 bbls in size, but accidental riser disconnects may result in the release of medium (238 to 2,380 bbls) to large (> 2,3 81 bbls) quantities of dril ling fluids ( BOEMRE , 2011c).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 17 Chemical Spill

A study of environmental risks of chemical products used in OCS activities determined that only two chemicals could potentially affect the marine environment: zinc bromide and ammonium chloride (Boehm et al., 2001). In this project only sodium bromide will be present and the risk of

a spill for this chemical is very low. Most other chemicals are either nontoxic or used in small quantities. No significant impacts are expected from chemical spills. . Chemicals used in drilling operations are required to overcome technical issues in the drilling process, improve the efficiency and safety of operations, and protect a ssociated equipment. To perform these tasks, a variety of chemicals may be mixed together to develop the site

- specific properties required. Examples of chemicals used to achieve these properties include surfactants, bentonite clays, olefins, inorganic sa lts, nut shells, glycols, polymers, barite, and calcium carbonate. Supplies are renewed on a regular basis by transfer in containers on supply boats (Boehm et al., 2001). Other than chemicals used in drilling fluids, examples of chemicals that may be fou nd on or transported to offshore facilities include ethylene glycol (blowout prevention control fluid, used in closed cooling loops for crane and main engines, and brake coolers), cement (used to cement casing in place), solvents (used in painting operatio ns), hydraulic fluids (used in cranes and other hydraulic rig equipment), lubricating oil and grease (used in reciprocating and electrical equipment), and sodium hypochlorite (dilute, used as laundry bleach and disinfectant).

H 2 S Release

Pursuant to Title 30 CFR 250.490(c), Contingency Plan preparation according to
30 CFR 250.49 0(f) is not required for the proposed activities. . The BOEM Regional Supervisor has classified the area as “H 2 S absent.”

Vessel Collisions . As summarized in MMS (2007b), vessel collisions occasionally occur during routine operations. Most collision mishaps are the result of service vessels colliding with platforms or vessel collisions with pipeline risers. Some of these collisions have caused spills of diesel fuel or chemicals. BP will comply with USCG and BOEM

- mandated safety requi rements to minimize the potential for vessel collisions.



## B. Affected Environment

The lease area is in the north central Gulf of Mexico ( Figure 1 ). Overall, the lease area is located 49 miles (79 km) from the nearest shoreline (Louisiana)

, 112 miles (196 km) from the onshore support base at Port Fourchon, Louisiana

, and 135 mile s (217 km) from the construction vessel support base in Theodore, Alabama

. Figure 2 shows the location and bathymetry of the proposed project area.

Water depth at t he K

- 4 well site in MC 383 is approximately 1,750 m (5,741 ft) below mean sea level. Side

- sca n sonar data from the John E. Chance and Associates (JECA) 1986 Deep

- Tow Survey showed a relatively smooth se afloor with a surface reflectivity indicating a clayey

comp osition for the surface sediments . Piston cores from Block 383 indicated sediments comprised of soft clay and shell hash ( BP GoM Resources, 2011 )

.M ississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 18

Figure 2

. Bathymetric map showing the seafloor location of the K

- 4 well site.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 19 Base d on the shallow hazards assessment as summarized in Section 4

, Geological and Geophysical Information of this SDOCD , there are no indications of seafloor features that could support high

- density deepwater b enthic communities at the drill site. MC Block 383 is located in water depths greater than 300 meters ( 984 ft) ; therefore there is the potential for chemosynthetic organisms to be present. The interpretation of the 1997 Deep

- Tow survey data and 3D seismic data and amplitude extractions performed at and close to seabed do not show any evidence for the presence of fluid or gas expulsion features or other seafloor conditions indicative of antigenic car bonates at, or within, 2,000 f t of the proposed well location . There is an area of what appear to be expulsion features al ong the MC 338/339 border which could be associated with chemosynthetic communities, but these features are more than 3 miles (5,000 m) from the wellsite ( BP GoM Resources, 2011 )

. In accordance with NTL 2009

- G40, all areas of the block where features migh t exist that could support deepwater benthic communities will be avoided by the proposed activities.

A detailed description of the regional affected environment i s provided in recent EISs (MMS, 2007b, 2008; BOEMRE , 2011a), including meteorology, oceanograp hy, geology, air and water quality, benthic communities, threatened and endangered species, biologically sensitive resources, archaeological resources, socioeconomic conditions, and other marine uses. These regional descriptions are based on extensive lit erature reviews and are incorporated by reference. General information is presented below, and brief descriptions of each potentially affected resource are presented in Section C of this EIA , including site

- specific and/or new
information if available.

Fo llowing the 2010 Macondo incident, large amount s of ongoing research and studies are being conducted on the impacts to water quality from an oil spill and potential deepwater “clouds” of dispersed oil. For example, Terry Hazen with the Lawrence Berkeley N ational Laboratory (Berk e ley Lab)

, operated by the University of California

, is studying the impacts and fate of deepwater oil clouds

. I nitial study result s suggest that the potential exists for rapid intrinsic bioremediation (bacterial degradation) of sub

- sea dispersed oil in the water column by deep

- sea indigenous microbial activity without significant oxygen depletion (Hazen et al.

, 2010). Additional stud ies lead by David Valentine (University of California, Santa Ba rbara) and John Kessler (Texas A&M University) are researching the effects of deepwater dissolved hydrocarbon gases (e.g.

, methane, propane

, and ethane) and the microbial response to a deepwate r oil spill. Initial study results suggest deepwater dissolved hydrocarbon gases may promote rapid hydrocarbon respiration by low

- diversity bacterial blooms, thus priming indigenous bacterial populations for rapid hydrocarbon degradation of sub

- sea oil cl ouds (Kessler et al.

, 2011; Valentine et al.

, 2010). These and other studies are ongoing and more data will be generated, analyzed, and final conclusions made. As more information from these studies is made publicly available the impacts to water quality from oil spills and potential deepwater clouds will be addressed and analyzed accordingly by the scientific community. Results to date suggest that sub

- surface concentrations of hydrocarbons may be more rapidly degraded by biological means than was previ ously anticipated.

The lease area is located approximately 10 miles (16 km) south

- southwest of the Macondo spill site. Based on an analysis of satellite imagery (ESRI, 2010), the surface slick extended over the lease area, and therefore existing water qua lity in the lease was potentially affected during that event. Water and sediment monitoring data reported by the Operational Science Adviso ry Team (OSAT, 2010) show that after August 2010, waters and sediments in the deepwater Gulf of Mexico beyond 1.8 mi les (3 km) from the Macondo site, including those in the lease area, wereMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 20 below USEPA acute and chronic benchmarks for PAHs and were not hypoxic. These observations indicate that baseline environmental conditions in the lease area are unlikely to have bee n significantly altered by the spill.



## C. Impact Analysis

This section analyses the potential direct and indirect impacts of routine activities and accidents. Impacts have been analyzed extensively in recent multi

- lease

- sale EISs for the Western and Central Gulf of Mexico Planning Areas (MMS, 2007b, 2008) as well as the EA for Gulf of Mexico deepwater operations and activities (MMS, 2000) and the Supplemental EIS for Lease Sale 218 ( BOEMRE , 2011a). Site

- specific issues are addressed in this section a s appropriate.



## C.1 Physical/Chemical Environment

C.1.1 Air Quality

There are no site

- specific air quality data for the project area. Due to the distance from shore

- based pollution sources, offshore air quality is expected to be good. The attainment

statu s of Federal OCS waters is unclassified because there is no provision in the Clean Air Act for classification of areas outside State waters (MMS, 2007b).

As of 30 August 2011, all Louisiana, Mississippi, Alabama, and Florida coastal counties and parishes a re in attainment of the National Ambient Air Quality Standards ( NAAQS ) for all criteria pollutants (USEPA, 2011). Two metropolitan areas in Texas (Dallas

- Fort Worth and
Houston

- Galveston

- Brazoria) and one metropolitan area in Louisiana (Baton Rouge) are

n onattainment areas for 8

- h ozone. El Paso County, Texas is a nonattainment area for PM 10 and CO, and Birmingham, Alabama is a non

- attainment area for PM 2.5 (USEPA, 2011).

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

BOEMRE has reexamined the analysis for air quality presented in MMS (2007b, 2008) based on additional information and in consideration of the Macondo oil spill event

. No substantial new information was found that would alter the potential impact s on air quality presented in previous lease sale EIS s (BOEMRE, 2011a,b).

The IPF s potentially affecting air quality during this project are air polluta nt emissions from normal operations

, a diesel fuel spill , and a large oil spill (WCD).



### Impacts of Air Pollutant Emissions

Air pollutant emissions are the only routine IPF likely to affect air quality. Sources include drilling operations aboard the DP dril lship , and the engines of service vessels and helicopters. These emissions occur mainly from combustion or burning of diesel fuel. The combustion of fuels occurs primarily on diesel

- powered generators, pumps, or motors and from lighter fuelMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 21 motors. Prim ary air pollutants typically associated with OCS activities are suspended PM, SO x , nitrogen dioxide ( NO 2 ) , VOCs, and CO.

Due to the distance from shore, routine operations in the project area are not expected to have any impact on air quality conditions al ong the coast, including nonattainment areas. As noted in the recent lease sale EISs (MMS, 2007b; BOEMRE 2011a,b), emissions of air pollutants from routine activities in the Central Gulf of Mexico Planning Area are projected to have minimal impacts to ons hore air quality because of the prevailing atmospheric conditions, emission heights, emission rates, and the distance of these emissions from the coast.

The Breton Wilderness Area, which is part of the Breton National Wildlife Refuge (NWR), is designated u nder the Clean Air Act as a Prevention of Significant Deterioration (PSD) Class I air quality area. BOEM is required to notify the National Park Service (NPS) and U.S. Fish and Wildlife Service (USFWS) if emissions from proposed projects may affect the Br eton Class I area. Additional review and mitigation measures may be required for sources within 300 km (186 miles) of the Breton Class I area that exceed emission limits agreed upon by the administering agencies (NPS, 2010). The lease area is approximate ly 75 miles (12 1 km) from the Breton Wilderness Area. Due to the distance from shore and level of emissions, BP does not expect any air quality impacts in the Breton NWR.



### Impacts of a Diesel Fuel Spill

Potential impacts of a diesel fuel spill on air quali ty are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008). The probability of a fuel spill would be minimized by BP’s preventative measures during routine operations, including fuel transfer. In the unlikely eve nt of a spill, implementation of BP’s OSRP will be an available option to reduce impacts. Given the open ocean location of the lease area, the extent and duration of air quality impacts from a fuel spill are not expected to be significant.

A fuel spill wo uld affect air quality near the spill site by introducing VOCs through evaporation. The ADIOS2 model ( Section A.9.2 ) indicates that over 90% of a diesel fuel spill would be evaporated or dispersed within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac) depending on sea state and weather conditions. Assuming the evaporated volume is 100% VOCs and assuming a diesel fuel density of
7.08 pounds per gallon ( lb/gal ) , the estimated VOC emissions would be 8 03 lb s . This small volume of VOC emissions would have no impact on coastal air quality.

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



### Impacts of a Large Oil Spill (WCD)

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

A large oil spill (WCD) could potentially affect air quality by introducing VOCs through evaporation from the slick. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response

measures. Rea l

- time wind and current data from the project area would be available at the time of a spill and would be used to assess the fate and effects of VOCs released. Additional airMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 22 quality impacts could occur if response measures included in situ burning of the floating oil. Burning would generate a plume of black smoke and result in emissions of NO x , SO x , CO, and PM, as well as greenhouse gases. However, in situ burning would occur only after authorization from the USEPA.

Due to the lease area location ( 49 mi les [ 79 km]) from the nearest shoreline (Louisiana) , most air quality impacts would occur in offshore waters with minimal chance to affect onshore air quality.



### C.1.2 Water Quality

There are no site

- specific water quality data for the lease area. Due to the lease location in deep offshore waters, water quality is expected to be good, with low levels of contaminants. As noted in the lease sale EIS (MMS, 2007b), deepwater areas in the northern Gulf of Mexico are relatively homogeneous with respect to temperature, salinity, and oxygen. Kennicutt (2000) noted that the deepwater region has little evidence of contaminants in the dissolved or particulate phases of the water column. However, there are localized occurrences of natural seepage of oil, ga s, and brines in near

- surface sediments and up through the water column.

The lease area is located approximately 10 miles (16 km) from the Macondo spill site. Based on satellite imagery (ESRI, 2010), the surface sli ck extended over the lease area and

, the refore

, existing water quality in the lease area may have been affected in the short

- term. The OSAT ( 2010) data show that after August 2010, waters and sediments in the deepwater Gulf of Mexico beyond 1.8 miles (3 km) from the Macondo wellsite, including those in the lease area, were below USEPA acute and chronic benchmarks for PAHs and were not hypoxic. No lingering impacts to water quality in the project area are expected.

IPFs potentially affecting water quality are effluent discharges

, a diesel fuel s pill

, and a large oil spill (WCD).



### Impacts of Effluent Discharges

Effluent discharges include muds and cuttings from the drilling of the K

- 4 well , sanitary and domestic wastes, deck drainage, and NPDES defined “Miscellaneous Discharges” such as cooling water, firewater, ballast and bilge water, and desalination brine. Water quality impacts of effluent discharges are discussed in Section 4.2.1.1.2.2 of the lease sale EIS (MMS, 2007b) and Section 4.1.1.2 of the Supplemental EIS ( BOEMRE , 2011a). NPDES per mit limitations ar e expected to be in compliance.

Water

- based drilling muds and cuttings will be released at the seafloor during the initial well intervals before the marine riser, which allows returns to the surface, is set. Excess cement slurry also wil l be released at the seafloor during casing installation for the riserless portion of the drilling operations. Muds associated with SBMs will be collected on the rig and either reused by the vendor, or transported to Port Fourchon, Louisiana for recycling and/or disposal in an approved facility. Wellbore cuttings wetted with SBMs will be treated to SBM levels at or below NPDES requirements and discharged to the seaflo or in accordance with the
NPDES permit.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 23 Treated sanitary and domestic wastes will have li ttle or no impact on water quality in the immediate vicinity of these discharges. These wastes may have elevated levels of nutrients, organic ma tter, and chlorine, but should dilute to undetectable levels within tens to hundreds of meters from the source. Little or no impact on water quality is anticipated.

Deck drainage includes all effluents resulting from rain, deck washings, and runoff from curbs, gutters, and drains, including drip pans in work areas. Rainwater that falls on uncontaminated areas of the drillship will flow overboard without treatment. However, rainwater that falls on the drilling vessel deck and other areas such as chemical storage areas and places where equipment is exposed will be collected and oil and water separated to meet NPDES permit requirements. Little or no impact on water quality is anticipated.

Other discharges in accordance with the NPDES permit, such as desalination unit brine,
BOP hydraulic fluids, and uncontaminated cooling water, firewater, ballast water, and bilge

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

Support vessels will discharge treated sanitary and domestic wastes. These will have little or no impact on water quality in the immediate vicinity of the discharges. S upport vessel discharges are expected be in accordance with USCG and MARPOL regulations and, as applicable, the NPDES Vessel General Permit, and therefore are not expected to cause significant impacts on water quality.



### Impacts of a Diesel Fuel Spill

Pote ntial impacts of a diesel fuel spill on water quality are expected to be consistent with those analyzed and discussed in recent EISs (MMS, 2007b, 2008; BOEMRE 2011a,b). The probability of a diesel fuel spill would be minimized by BP’s preventative measure s during routine operations, including fuel transfer. In the unlikely event of a spill, implementation of BP’s OSRP will be an available option to reduce the impacts. Given the open ocean location of the lease area, the extent and duration of water quali ty impacts from a diesel fuel spill are not be expected to be significant.

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

The water

- soluble fractions of diesel are dominated by two

- and three

- ringed PAH s, which are moderately volatile (NRC, 2003). The constituents of these oils are light to intermediate in molecular weight and can be readily degraded by aerobic microbial oxidation. Diesel is so light that it is not possible for the oil to sink and pool on the seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this generally occurs only in coastal areas with high suspended solid loads (NRC, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes (NOAA, 2006).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 24 A diesel fuel spill would not affect coastal water quality because the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill (WCD)

Potential impacts of a large oil spill on wate r quality are expected to be consistent with th os e analyzed and discussed in recent lease sale EISs (MMS, 2007b, 2008). A large spill w ould affect water quality by producing a slick on the water surface and increasing the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Most of the oil would be expected to form a slick at the surface. I nformation from the Macondo spill indicates that clouds of submerged oil dro plets can be produced when subsea dispersants are applied at the wellhead (Camilli et al., 2010; Hazen et al., 2010; Joint Analysis Group, 2010a,b,c). However, dispersants would be applied only after approval from the USEPA.

Small droplets in the water ma y adhere to suspended sediment and be removed from the water column (OSAT

, 2010). Terry Hazen with the Lawrence Berkeley National Laboratory (Berk e ley Lab)

, operated by the University of California

, is studying the impacts and fate of deepwater oil clouds

. I nitial study result s suggest that the potential exists for rapid intrinsic bioremediation (bacterial degradation) of sub

- sea dispersed oil in the water column by deep

- sea indigenous microbial activity without significant oxygen depletion (Hazen et al.

, 2010). Additional studies le d by David Valentine (University of California, Santa Ba rbara) and John Kessler (Texas A&M University) are researching the effects of deepwater dissolved hydrocarbon gases (e.g.

, methane, propane

, and ethane) and the microbial response to a deepwater oil spill. Initial study results suggest deepwater dissolved hydrocarbon gases may promote rapid hydrocarbon respiration by low

- diversity bacterial blooms, thus priming indigenous bacterial populations for rapid hydrocarbon degrad ation of sub

- sea oil clouds (Kessler et al.

, 2011; Valentine et al.

, 2010). Results to date suggest that sub

- surface concentrations of hydrocarbons may be more rapidly degraded by biological means than was previously anticipated.

Due to the lease area loc ation ( 49 miles or 79 km from the nearest shoreline [Louisiana] ), it is expected that most water quality impacts would occur in offshore waters, especially in the event of a spill lasting less than 30 days ( Table 4 ).



## C.2 Seafloor Habitats and Biota

Water depths in the MC 383 block range from 1,480 to 1,790 m (4,856 to 5,872 ft) . The seafloor in the lease area is expected to consist mainly of soft bottom communities. Based on the geohazards assessments by Fugro

- M c Clelland Marine Geosciences, Inc. (F MMG) ( 1994 ) and
BP GoM Resources (2011) as summarized in SDOCD Section 4

, Geological and Geophysical Information , there are no indications of seafloor features that could support high density deepwater benthic communities at the drill site in MC 383

.

The BOEM uses a biologically based grid system to ensure broad and systematic analysis of the deepwater Gulf of Mexico, including ROV coverage. The BOEM website indicates that
ROV survey coverage for Grid 16, where the lease area is located, is adequate to ch aracterize the area ( BOEMRE, 2011 d).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 25 

### C.2.1 Soft Bottom Benthic Communities

There are no site

- specific benthic community data from the lease area. However, data from the recent Northern Gulf of Mexico Continental Slope Habitats and Benthic Ecology Study (W ei, 2006; Rowe and Kennicutt, 2009) can be used to describe typical benthic communities in the area. Table 5 summarizes data from two nearby stations in similar wate r depths. Sediments at the MT4 station were predominantly clay (45.5%) and sil t (45.5%). In contrast

, the
MT5 sediments were 64.3% sand, 15.3% silt, and 20.4% clay.

Table 5

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

Station Water Depth (m) Abundance
Meiofauna (individuals/m 2 ) Macroinfauna (individuals/m 2 ) Megafauna (individuals/ha)

MT4 1,403 246,058 3,262 1,548

MT5 2,294 128,964 1,763 1,111
Meiofaunal and megafaunal abundance from Rowe and Kennicutt (2009); m acroinfaunal abundance from Wei ( 2006 )

.

Meiofauna (animals passing through a 0.3

- milimeter [ mm ] sieve but retained on a 0.062

- mm sieve) densities in water depths representative of the lease area typically range from about 148,000 to 800,000 individuals/m 2 (Rowe and Kennicutt, 2009). Nematodes, nauplii, and harpacticoid copepods were the three dominant groups in the meiofauna, accounting fo r about 90% of total abundance.

The benthic macroinfauna (animals retained on a 0.3

- mm sieve) is characterized by small mean individual sizes and low densities, both of which are a reflection of the meager primary production in Gulf of Mexico surface waters (Wei, 2006). Densities decrease exponentially with water depth. Based on an equation presented by Wei (2006), macroinfaunal densities in the

w ater depths of the lease area are expected to be about 1,500 to 2,000 individuals/m 2

. Polychaetes are typically the most abundant macroinfaunal group on the northern Gulf of Mexico continental slope, followed by amphipods, tanaids, bivalves, and isopods. Wei (2006) recognized four depth dependent faunal zones (1 through 4), two of which are divided horizontally. The lease area is in Zone 2E, which consists of stations on the mid Texas

- Louisiana Slope ranging in depth from 625 to 1,828 m (2,050 to 5,997 ft ). The five most abundant species in Zone 2E were the polychaetes Litocorsa antennata

, Aricidea suecica

, Tharyx marioni

, Paralacydonia paradoxa

, and the bivalve Heterodonta sp.

Megafaunal densities from nearby stations ranged from 1,111 to 1,548 individua ls/ha ( Table 5 ). Common megafauna included motile groups such as decapods, ophiuroids, holothurians, and demersal fishes, as well as sessile groups such as sponges and anemones.

Bacteria are also an important component in terms of biomass and cycling of o rganic carbon (Cruz

- Kaegi, 1998). Bacterial biomass at the depth range of the lease area typically is about
1 to 2 g C/m 2 in the top 15 centimeters ( cm ) of sediments (Rowe and Kennicutt, 2009).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 26 IPFs potentially affecting soft bottom benthic communities are physical disturbance to the seafloor, effluent discharges (drilling muds and cuttings), and a large oil spill (WCD) resulting from a well blowout at the seafloor. A diesel fuel spill would not affect benthic communities because the diesel fuel would float and dissipate on the sea surface.



### Impacts of Physical Disturbance to the Seafloor

Sources of seafloor disturbance include the drilling of well K

- 4

. All drilling and well installation will be done by DP vessels. Water

- based drilling muds and cuttings will be released at the seafloor during the initial well intervals before the marine riser is set that allows drilling mud s to
return to the surface

. Excess cement slurry also will be released at the seafloor during casing installation for the riserless porti on of the drilling operations.

The benthic impacts of physical disturbance to the seafloor will be minor. Soft bottom communities are ubiquitous along the northern Gulf of Mexi co continental slope (Gallaway, 1988 ; Gallaway et al., 2003; Rowe and Kennicutt, 2009). Impacts from physical disturbance in the lease area during this project are not expected to be significant in the context of similar soft bottom benthic communities in the region.



### Impacts of Effluent Dis charges

Drilling muds and cuttings are the only effluents that are likely to affect benthic communities

. During initial well intervals before the marine riser is set, cuttings and seawater

- based “spud mud” will be released at the seafloor. Excess cement slurry will also be released at the seafloor during casing installation for the riserless portion of the drilling operations. Cement slurry components typically include cement mix and some of the same chemicals used in water

- based drilling muds (Boehm et al., 2001). The main impacts will be burial and smothering of benthic organisms within several meters to tens of meters around the wellbore. Soft bottom sediments disturbed by cuttings, drilling muds, and cement slurry will eventually be recolonized thro ugh larval settlement and migration from adjacent areas (Neff et al., 2000)

. Discharges of washed SBM cuttings from the rig may affect benthic communities, primarily within several hundred meters of the wellsite. The fate and effects of SBM cuttings have been reviewed by Neff et al. (2000), and monitoring studies have been conducted in the Gulf of Mexico by Continental Shelf Associates, Inc. (2004, 2006). In general, washed cuttings with adhering SBMs tend to clump together and form thick cuttings piles c lose to the drillsite. Areas of SBM cuttings deposition may develop elevated organic carbon concentrations and anoxic conditions (Continental Shelf Associates, Inc., 2006). Where SBM cuttings accumulate in concentrations of approximately 1,000 milligrams per kilogram ( mg/kg ) or higher, benthic infaunal communities may be adversely affected due to both the toxicity of the base fluid and organic enrichment (with resulting anoxia) (Neff et al., 2000). Infaunal numbers may increase and diversity may decrease as opportunistic species that tolerate low oxygen and high
H 2 S predominate (Continental Shelf Associates, Inc., 2006). As the base synthetic fluid is decomposed by microbes, the area will gradually return to pre

- drilling conditions. Disturbed sediments will be recolonized through larval settlement and migration from adjacent areas (Neff et al., 2000)

.

T he areal extent of impacts from drilling discharges will be small. Assuming a typical effect radius of 500 m (1,640 ft) , the affected area around a wellsite would represent about 3% of the seafloor within a lease block (Continental Shelf Associates, 2006) . Soft bottom communities areMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 27 ubiquitous along the northern Gulf of Mexico continental slope (Gallaway, 1988; Gallaway et al., 2003; Rowe and Kennicutt, 2009). Impacts from drilling discharges during this project will have no significant impact on soft bottom benthic communities in the region.



### Impacts of a Large Oil Spill (WCD)

The most likely effects of a subsea blowout on benthic communities would be within a few hundred meters of the wellsite. The MMS (2007b) estimat ed that a severe subsurface blowout could resuspend and disperse sediments within a 300

- m (984

- ft) radius. While coarse sediments (sands) would probably s ettle at a rapid rate within 400 m (1,312 ft) from the blowout site, fine sediments (silts and clays) could be resuspended for more than 30 days and dispersed over a much wider area. Based on previous studies, surface sediments at the project area are ass umed to largely be silt and clay ( Rowe and Kennicutt, 2009 ).

Recent lease sale EISs (MMS, 2007a, 2008) i n dicat ed that oil spills would be unlikely to affect benthic communities beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface dir ectly over the spill location.



### C.2.2 High

- Density Deepwater Benthic Communities

As defined by NTL 2009

- G40, high

- density deepwater benthic communities are features or areas that could sup port high

- density chemosynthetic communities, or features or areas that could support high

- density deepwater corals and other associated high

- density hard bottom communities. Chemosynthetic communities were discovered in the central Gulf of Mexico in
1984 and have been studied extensively (MacDonald, 2002). Deepwater coral communities are also known from numerous locations in the Gulf of Mexico (Brooke and Schroeder, 2007;
CSA International, Inc., 2007). These communities occur almost exclusively on auth igenic carbonates created by chemosynthetic communities. Based on a list of sites compiled by the
BOEMRE (2011 e ) and maps presented by the U.S. Geological Survey (2011), the nearest known chemosynthetic community site is in Viosca Knoll (VK) Block 826, lo ca ted approximately 48 miles (77 km) north

- northeast from the lease area and t he nearest know n deep water coral community is in MC Block 640, 28 miles (44 km) southwest of the lease area (Brooks et al., 2009).

Based on the geohazards assessments by FMMG (1994) and the assessment made by BP ’s Senior Geohazard Specialist ( BP GoM Resources, 2011 ) presented in Section 4 of this SDOCD

, there are no indications of seafloor features that could support high

- density deepwater benthic communities at the drill site in MC 383

. IPFs potentially affecting high

- density deepwater benthic communities include physical disturbance of the seafloor, effluent discharges (drilling muds and cuttings), and a large oil spill (WCD) from a well blowout at the seafloor. A diesel fue l spill would not affect benthic communities because the diesel fuel would float and dissipate on the sea surface.



### Physical Disturbance to the Seafloor

In water depths such as are encountered in the lease area, DP drillships or semisubmersibles disturb the seafloor only around the wellbore (SHL) where the bottom template and BOP are located. Depending upon the specific well configuration, this area is generally about 0.25 ha (0.62 ac).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 28 T he areal extent of the impacts from a DP rig will be small , and NTL 20 09

- G40 requires that high

- density deepwater benthic communities and f eatures or areas that could support high

- density chemosynthetic communities or deepwater corals communities be avoided

. Impacts from the physical disturbance of the seafloor during this project should have no impact

on chemosynthetic or deepwater coral communities in the region

. 

### Impacts of Effluent Discharges

The interpretation of the 1997 Deep

- Tow survey data and 3D seismic data and amplitude extractions performed at and clos e to seabed do not show any evidence for the presence of fluid or gas expulsion features or other seafloor conditions indicative of antigenic carbonates at, or within, 610 m ( 2,000 ft ) of the proposed well location (see Section 4.5 Shallow Hazard Report of this SDOCD ) and the potential for chemosynthetic communities in the lease area is considered low ( BP GoM Resourc es, 2011 )

. Mo nitoring programs on the Gulf of Mexico continental slope have shown that benthic impacts from drilling discharges typically are concentrated within about 500 m (1,640 ft) of the wellsite , although detectable deposits may extend beyond this distance (Continental Shelf Associates, Inc., 2004, 2006 ; Neff et al., 2005). Because of the water depth of the lease area, drilling discharges would be expected to result in thinner, more diffuse accumulations on the seafloor than those documented in the literature. Although small amounts of cuttings particles may reach areas inhabited by high

- density deepwater benthic communities, the discharg es are not expected to impact these communities.



### Impacts of a Large Oil Spill (WCD)

Previous analyses (MMS, 2007a, 2008) concluded that oil spills would be unlikely to affect benthic communities beyond the immediate vicinity of the wellhead (i.e., due to p hysical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface clouds were reported at a water depth of about 1,100 m (3,600 ft)

. The se subsurface clouds apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the behavior and impacts of subsurface clouds of oil particle are not well known, a subsurface cloud of oil droplets could have the potential to contact high

- density deepwater benthic communities beyond the 300

- m (984

- ft) radius estimated by MMS (2007a, 2008)

, depending on its extent, trajectory, and persistence. Potential impacts on sensitive resources would be an integral part of the decision and approv al process for the use of dispersants , and such approval would be obtained from the USEPA prior to the use of dispersants

. Potential impacts of oil on high

- density deepwater benthic communities are discussed in
MMS (2007b). Although chemosynthetic communi ties live among hydrocarbon seeps, natural seepage is very constant and occurs at low rates compared to the potential rates of oil release from a blowout (MacDonald et al., 200 2 ; Ryerson et al.,2012) . In addition, seep organisms also require unrestricted access to oxygenated water at the same time as exposure to hydrocarbon energy sources (MacDonald, 2002). Oil droplets or oiled sediment particles could come into contact with chemosynthetic organisms or deepwater corals. As discussed by MMS (2007b), impa cts could include loss of habitat, biodiversity, and live coral coverage; destruction of hard substrate; and change in sediment characteristics

. Sublethal effects could be long

- lasting and affect the resilience of coral colonies to natural disturbances

.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 29 

### C .2.3 Designated Topographic Features

The lease area is not within or near a designated topographic feature or a no

- activity zone as identified in NTL 2009

- G39. The nearest designated topographic feature is Sackett Bank, located approximately 64 miles (103 km) north of the lease area in West Delta Block 147.

There are no IPFs associated with either routine operations or accidents that could cause impacts to designated topographic features due to the distance from the lease area. A diesel fuel spill would float and dissipate on the surface and would not reach these seafloor features.

In the event of an oil spill from a well blowout (WCD) , a surface slick would not contact these seafloor features. If a subsurface cloud were to occur, impacts on these featur es would be unlikely due to the distance and the difference in water depth

. Near

- bottom currents in the region are predicted to flow along the isobaths (Nowlin et al., 2001) and typically would not

carry a cloud up onto the continental shelf edge

.



### C.2.4 P innacle Trend Area Live Bottoms

The lease area is not covered by the Live Bottom (Pinnacle Trend) Stipulation. The nearest pinnacle trend blocks, as defined by NTL 2009

- G39, are about 4 3 miles ( 69 km) north

- northeast the lease area, along the shelf edge V K Block 778

. There are no IPFs associated with either routine operations or accidents that could cause impacts to pinnacle trend area live bottoms due to the distance from the lease area. A diesel fuel spill would float on the surface and would not reach these seafloor features.

In the event of an oil spill from a well blowout (WCD) , a surface slick would not contact these seafloor features. If a subsurface plume were to occur, impacts on these features would be unlikely due to the distance and the differ ence in water depth

. Near

- bottom currents in the region are predicted to flow along the isobaths (Nowlin et al., 2001) and typically would not carry a plume up onto the continental shelf edge

.



### C.2.5 Live Bottom /Low

- Relief

The lease area is not covered by the Live Bottom (Low

- Relief) Stipulation, which applies to Eastern Gulf of Mexico Planning Area leases in water depths of 100 m (328 ft) or less. The nearest blocks covered by the live bottom stipulation, as defined by NTL 2009

- G39, are about
67 miles (10 7 km) northeast of the project area.

There are no IPFs associated with either routine operations or accidents that could cause impacts to eastern Gulf live bottom areas due to the distan ce from the lease area. A diesel fuel spill would float and dissipate on the surface and would not reach these seafloor features.



## C.3 Threatened, Endangered, and Protected Species and Critical Habitat

This section discusses species listed as endangered or threatened under the Endangered Species Act (ESA). In addition, it i ncludes all marine mammal species in the region, which are protected under the Marine Mammal Protection Act (MMPA).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 30 Endangered or threatened species that may occur in the project area and/or along the northern
Gulf Coast are listed in Table 6 . The table also indicates the location of critical habitat (if designated in the Gulf of Mexico). Critical habitat is defined as (1) specific areas within the geographical area occupied by the species at the time of listing, if they contain physical or biological fe atures essential to conservation, and those features may require special management considerations or protection; and (2) specific areas outside the geographical area occupied by the species if the agency determines that the area itself is essential for

co nservation. The National Marine Fisheries Service (NMFS) has jurisdiction over ESA

- listed cetaceans, sea turtles, and fishes in the Gulf of Mexico. The USFWS has jurisdiction over
ESA

- listed birds and the West Indian manatee.

Table 6

. Federally

- listed en dangered and threatened species potentially present in the lease area and along the northern Gulf Coast.

Species Scientific Name Status Potential Presence Critical Habitat Designated in Gulf of Mexico Lease
Area Coastal

Marine Mammals

Sperm whale Physeter macrocephalus E X

-- None West Indian manatee Trichechus manatus latirostris E

-- X Florida ( Peninsular)
Blue whale Balaenoptera musculus E X a

-- None Fin whale Balaenoptera physalus E X a

-- None Humpback whale Megaptera novaeangliae E X a

-- None North Atlantic right whale Eubalaena glacialis E X a

-- None

Sei whale Balaenoptera borealis E X a

-- None Sea Turtles

Loggerhead turtle Caretta caretta T X X None Green turtle Chelonia mydas T, E b X X None Leatherback turtle Dermochelys coriacea E X X None Hawksbill turtle Eretmochelys imbricata E X X None Kemp’s ridley turtle Lepidochelys kempii E X X None Birds

Piping Plover Charadrius melodus T

-- X Coastal Texas, Louisiana, Mississippi, Alabama, and Florida (Panhandle)

Whooping Crane Grus americana E

-- X Coastal Texas (Aransas National Wildlife Refuge)
Fishes

Gulf sturgeon Acipenser oxyrinchus desotoi T

-- X Coastal Louisiana, Mississippi, Alabama, and Florida (Panhandle)

Smalltooth sawfish Pristis pectinata E

-- X Southwest Florida and the Florida Keys
Invertebrates

Elkhorn coral Acropora palmata E

-- X Flower Garden Banks
Terrestrial Mammals

Beach mice (Alabama, Choctawhatchee, Perdido Key, St. Andrew) Peromyscus polionotus E

-- X Alabama and Florida (Panhandle) beaches

Abbreviations: E = Endangered; T = Threatened.

a The blue, fin, humpback, North Atlantic right, and sei whales are rare or extralimital in the Gulf of Mexico and are unlikely to be present in the lease area.
b The green sea turtle is threatened, except for the Florida breeding population, which is listed as endangered.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 31 The sperm whale and five species of sea turtles are the only endangered or threatened species likely to occur at or near the lease area. No critical habitat has been designated for these species in the Gulf of Mexico.

As mandated by the ESA, BOEMRE consulted NMFS and USFWS on possible and potential impacts from the proposed leasing in the Western Gulf of Mexico Planning Area on endangered/threatened species and their designated critical ha bitat (MMS

, 2007a

, b)

. A biological assessment was prepared for each consultation. The formal ESA consultation with NMFS was concluded with receipt of the Biological Opinion on 3 July 2007 (NMFS, 2007). The Biological Opinion concludes that the proposed lease sales and associated activities in the
Five

- Year Leasing Plan for Western and Central Planning Areas 2007

- 2012 are not likely to jeopardize the continued existence of threatened and endangered species under NMFS jurisdiction or destroy or adversely m odify designated critical habitat. The informal ESA consultation with USFWS was concluded with a letter dated 14 September 2007. The USFWS concurred with BOEMRE’s determination that proposed actions of the current Five

- Year Leasing Plan were not likely t o adversely affect the threatened/endangered species or designated
critical habitat under USFWS jurisdiction. Following the Macondo oil spill

, BOEMRE requested to reinitiat e an ESA consultation with both the NMFS and USFWS on 30 July 2010. The NMFS responded with a letter to BOEMRE on 24 September 2010. The USFWS responded with a letter
to BOEMRE on 27 September 2010. At this time

, the re

- initiated consultation has not been completed and the existing consultation remains in effect. The e xisting consultation recognizes that BOEMRE

- required mitigations and other reasonable and prudent measures should reduce the li kelihood of impacts from BOEM

- authorized activities.

Five endangered mysticete whales (blue whale, fin whale, humpback whale, Nor th Atlantic right whale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

Coastal endangere d or threatened species include the West Indian manatee, Piping Plover, Whooping Crane, Gulf sturgeon, and four subspecies of beach mice. Critical habitat has been designated for all of these species as indicated in Table 6 and discussed in individual sec tions.

Two other coastal species (Bald Eagle and Brown Pelican) discussed by MMS (2007b) are no longer listed as endangered or threatened; these are discussed in Section C.4.2

. There are no other endangered animals or plants in the Gulf of Mexico that are reasonably likely to be affected by either routine or accidental events.



### C.3.1 Sperm Whale (Endangered)

The only endangered marine mammal likely to be present at or near the project area is the sperm whale ( Physeter macrocephalus ). Resident populations of sperm whales occur within the Gulf of Mexico. A species description is presented in a recent lease sale EIS (MMS, 2007b). Gulf of Mexico sperm whales are classified as an endangered species and a “strategic stock” (defined as a stock that may have unsus tainable human

- caused impact s) by NOAA Fisheries (Waring et al., 2009). No critical habitat for sperm whale has been designated in the Gulf of
Mexico.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 32 The distribution of sperm whales in the Gulf of Mexico is correlated with mesoscale physical features su ch as eddies associated with the Gulf of Mexico Loop Current (Jochens et al., 2008). Sperm whale populations are present in the north

- central Gulf of Mexico throughout the year (Davis et al., 2000). Results of a multi

- year tracking study show female sper m whales typically concentrated along the upper continental slope between the 200

- and 1,000

- m (656

- and 3,280

- ft) depth contours (Jochens et al., 2008). Male sperm whales were more variable in their movements and were documented in water depths greater t han 3,000 m (9,843 ft). Generally, groups of sperm whales sighted in the Gulf of Mexico during the MMS funded Sperm Whale Seismic Study consisted of mixed

- sex groups comprising adult females and immatures, and groups of bachelor males. Typical group size for mixed groups was 10 individuals (Jochens et al., 2008). Study results showed that sperm whales transit through the vicinity of the lease area. Movements of satellite

- tracked individuals suggest that this area of the Gulf continental slope is within the home range of the Gulf of Mexico population (within the 95% utiliz ation distribution) (Jochens et al., 2008).

IPFs potentially affecting sperm whales include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents

– a diesel fuel spill and a large oil spill (WCD). Effluent discharges are likely to have negligible impacts on sperm whales due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobili ty of these marine mammals. Compliance with BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on sperm whales.

C urrent threats to sperm whale populations worldwide are discussed in a final recovery plan for the sperm whale r ecently published by NOAA (NMFS, 2010 a ). Threats are defined as “any factor that could represent an impediment to recovery

, ” and include fisheries interactions, anthropogenic noise, vessel interactions, contaminants and pollutants, disease, injury from

ma rine debris, research, predation and natural mortality, direct harvest, competition for resources, loss of prey base due to climate change and ecosystem change, and cable laying.
In the Gulf of Mexico , the impacts from many of these threats are identified as either low or unknown (BOEMRE, 2011a,b)

. 

### Impacts of Drilling Vessel Presence, Noise, and Lights

Noise from routine drilling and pipeline installation activities has the potential to disturb sperm whales. Sperm whales appear to have good midrange frequ ency hearing (Southall et al., 2007), but the available data do not indicate a consistent response to anthropogenic noise (Jochens et al., 2008). Noise associated with offshore oil and gas production is relatively weak in intensity, and an individual anim al’s noise exposure would be transient. There are other
OCS facilities and activities near the lease area, and the region as a whole has a large number of similar noise sources. This project would represent a small contribution to the overall noise regim e.

The NMFS (2007) analyzed the potential for impacts of OCS

- related noise on sperm whales in its Biological Opinion for the Five

- Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. The analysis noted that OCS drilling and production activities produce low sound source levels and concluded that noise from these sources is not expected to produce amplitudes sufficient to cause hearing or behavioral effects in sperm whales; therefore, these effects are insignific ant (NMFS, 2007).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 33 

### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sperm whales, and there is also a risk of vessel strikes, which are identified as a threat in the recovery plan for this species (NMFS, 2 010a). Data concerning the frequency of vessel strikes are presented in the lease sale EIS (MMS, 2007b). To reduce the potential for vessel strikes, BOEM and BSEE have issued JOINT NTL 2012

- G 0 1 superseding NTL 2007

- G04, which

, in lieu of a formal observe r program, provides specific guidelines that should be follow ed to identify and avoid injury to marine mammals and sea turtles. When whales are sighted, vessel operators and crews are required to attempt to maintain a distance of 91 m (300 ft) or greater whenever possible. If the whale is believed to be a North Atlantic right whale, vessels should maintain a minimum distance of 500 yards (457 m) from the animal (50 CFR 2224.103). When safety permits, vessel operators are required to reduce vessel speed t o 10 knots or less when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sperm whales.

The NMFS (2010a) analyzed the potential for vessel strikes and harassment of sperm whales in its Biological Opinion for the Five

- Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. With implementation of the mitig ation measures in
NTL 2007

- G04, the NMFS concluded that the likelihood of collisions between vessels and sperm whales would be reduced to insignificant levels. JOINT NTL 2012

- G01 updates these protective measures and adds additional species specific prote ctive measures. The NMFS concluded that the observed avoidance of passing vessels by sperm whales is an advantageous response to avoid a potential threat and is not expected to result in any significant effect on migration, breathing, nursing, breeding, f eeding, or sheltering to individuals, or have any consequences at the level of the population. With implementation of the vessel strike avoidance measures requirement to maintain a distance of 90 m (295 ft) from sperm whales, the NMFS concluded that the p otential for harassment of sperm whales would be reduced to discountable levels.

Helicopter traffic also has the potential to disturb sperm whales. Smultea et al. (2008) documented responses of sperm whales offshore Hawaii to fixed wing aircraft flying at an altitude of 245 m (800 ft). A reaction to the initial pass of the aircraft was observed during three (12%) of 24 sightings. All three reactions consisted of a hasty dive and occ urred at less than
360 m (1,180 ft) lateral distance from the aircraft. Additional reactions were seen when aircraft circled certain whales to make further observations. Based on other studies of cetacean responses to sound, the authors concluded that the observed reactions to brief overflights by the aircraft were short

- term and probably of no long

- term biological significance.

While flying offshore in the Gulf of Mexico, helicopters maintain altitudes above 213 m (700 ft) during transit to and from the working area. In the event that a whale is seen during transit, the heli copter will not approach or circle the animals. Although responses are possible, based on the Smultea et al. (2008) study, the NMFS (2007) concluded that this altitude would minimize the potential for disturbing sperm whales. Therefore, no significant im pacts are expected.



### Impacts of a Diesel Fuel Spill

Potential diesel fuel spill impacts on marine mammals including sperm whales are discussed in recent EISs (MMS, 2007b, 2008) and by the NMFS (2007) in its Biological Opinion for the
Five

- Year Oil and Gas L easing Program in the Central and Western Planning Areas of the Gulf ofMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 34 Mexico. For this SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts on these animals.

The probability of a diesel fuel spill will be minimized by BP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of BP’s OSRP will be an availa ble option to reduce impacts. Given the open ocean location of the lease area, the duration of a diesel fuel spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates that over 90% woul d be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response v essels and aircraft (Marine Mammal Commission [MMC], 2010). However, due to the limited areal extent and short duration of water quality impacts from a diesel fuel spill, as well as the mobility of sperm whales, no significant impacts would be expected.



### I mpacts of a Large Oil Spill (WCD)

Potential spill impacts on marine mammals including sperm whales are discussed in recent EISs (MMS, 2007b, 2008) and by NMFS (2007)

. For this EP , there are no unique site

- specific issues with respect to spill impacts on these animals.

Impacts of oil spills on sperm whales can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2010). Direct physical and physiol ogical effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey; and stress from the activities and n oise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses may include displacement of animals from pri me habitat

, disruption of social structure

, changing prey availability and foraging distribution and/or patterns
, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 2010).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb sperm whales and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with JOINT NTL 2012

- G01 to reduce th e potential for striking or disturbing these animals.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 35 

### C.3.2 West Indian Manatee (Endangered)

Most of the manatee population is located in peninsular Florida (USFWS, 2001), but manatee sightings in Louisiana have been increasing as manatees extend their pre sence further west of Florida in the warmer months (Wilson, 2003). A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the recovery plan for this species (USFWS, 2001).

IPFs potentially affecting manatees include support vess el and helicopter traffic and a large oil spill (WCD). A diesel fuel spill in the lease area would be unlikely to affect manatees, as the lease area is approximately 49 miles (79 km) from the nearest shoreline (Louisiana). As explained in Section A.9.2

, a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up

. Compliance with JOINT NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on manatees.



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb manatees, and there is also a risk of vessel strikes, which are identified as a threat in the recovery plan for this species (USFWS, 2001).
To reduce the potential for vessel strikes, the BOEM and BSEE have issued JOINT NTL 2012

- G01

, which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, an d requires operators to report sightings of any injured or dead protected species. Compliance with this NTL will minimize the likelihood of vessel strikes, and no significant impacts on manatees are expected.

Helicopter traffic also has the potential to d isturb manatees. Rathbun (1988) reported that manatees were disturbed more by helicopters than by fixed

- wing aircraft; however, the helicopter was flown at a relatively low altitude of 20 to 160 m (66 to 525 ft). Helicopters used in support operations ma intain a minimum altitude of 213 m (700 ft) while in transit offshore, 305 m (1,000 ft) over unpopulated areas or across coastlines, and 610 m (2,000 ft) over populated areas and sensitive habitats such as wildlife refuges and park properties. This mitiga tion measure will minimize the potential for disturbing manatees, and no significant impacts are expected.

Impacts of a Large Oil Spill (WCD)

In the event that manatees were exposed to oil, effects could include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2010). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and muco us membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications o f the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses may include displacement of animals from prime habitat, disruption of social structure, changing pr ey availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 2010).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 36 In the event that a large spill reached coastal waters where manatees were present, the level o f vessel and aircraft activity associated with spill response could disturb manatees and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with JOINT NTL 2012

- G01 to reduce the pote ntial for striking or disturbing these animals, and therefore no significant impacts are expected.



### C.3.3 Endangered Mysticete Whales

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right whale, and sei whale) have be en reported from the Gulf of Mexico but are considered rare or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

Due to the rare occurrence of these whales in the Gulf of Mexico and the limited scope and duration of the project, it is highly unlikely that any endangered mysticete would come into contact with any project activities, either routine operations or accidents. The NMFS (2007) did not include any of these mysticete whales a s affected species in its Biological Opinion for the
Five

- Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. Potential impacts are analyzed in recent lease sale EISs (MMS, 2007b, 2008;
BOEMRE 2011a,b), and th ose analyses are incorporated by reference. If any of these whales were present in the area, potential impacts would be the same as those discussed below in
Section C.3.4

.



### C.3.4 Non

- Endangered Marine Mammals (Protected)

Excluding the seven endangered spec ies that have been cited previously, there are 22 additional species of marine mammals that may be found in the Gulf of Mexico. All marine mammals are protected species under the MMPA. This includes two mysticete whales, the dwarf and pygmy sperm whales, 4 species of beaked whales, and 14 species of delphinids. The most common

non

- endangered cetaceans in the deepwater environment are odontocetes such as the pantropical spotted dolphin, spinner dolphin, and clymene dolphin. A brief summary is presented b elow, and additional information on these groups is presented in a recent lease sale EIS (MMS, 2007b).

Mysticete Whales . Two non

- endangered mysticete whales are known from the Gulf of Mexico: the Bryde’s whale ( Balaenoptera edeni ) and minke whale ( Balaeno ptera acutorostrata ). The Bryde’s whale has been sighted most frequently along the 100

- m (328

- ft) isobath (Davis and Fargion, 1996; Davis et al., 2000). Most sightings have been made in the DeSoto Canyon region and off western Florida, although there hav e been some in the west

- central portion of the northeastern Gulf. The minke whale is considered rare in the Gulf of Mexico, with the only confirmed records coming from strandings (Würsig et al., 2000). Based on the available data, it is possible that Bry de’s whales could occur in the lease area.

Dwarf and pygmy sperm whales . At sea, it is difficult to differentiate dwarf sperm whales ( Kogia sima ) from pygmy sperm whales ( Kogia breviceps ), and sightings are often grouped together as “ Kogia spp.” Both spe cies have a worldwide distribution in temperate to tropical waters. In the Gulf of Mexico, both species occur primarily along the continental shelf edge and in deeper waters off the continental shelf (Mullin et al., 1991). Either species could occur in t he lease area.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 37 Beaked whales . Four species of beaked whales are known from the Gulf of Mexico. They are Blainville’s beaked whale ( Mesoplodon densirostris ), Cuvier’s beaked whale ( Ziphius cavirostris ), Sowerby’s beaked whale ( Mesoplodon bidens ), and Gerv ais’ beaked whale ( Mesoplodon

europaeus ). Stranding records in the Gulf of Mexico suggest that Gervais’ beaked whale is the most common and Sowerby’s is extralimital. Due to the difficulties of at

- sea identification, beaked whales in the Gulf of Mexico a re identified either as Cuvier’s beaked whales or are grouped into an undifferentiated complex ( Mesoplodon spp. and Ziphius spp.). In the northern Gulf of Mexico, they are broadly distributed in waters greater than 1,000 m (3,281 ft) over lower slope and abyssal landscapes (Davis et al., 2000). Any of these species could occur in the lease

area.

Delphinids

IPFs potentially affecting non

- endangered marine mammals include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents

- a small fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on marine mammals due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of marine mammals. Compliance with BSEE NTL 2012

– G01 will minimize the potential for marine debris

- related impacts on marine mammals. . Fourteen species of delphinids are known from the Gulf of Mexico: Atlantic spotted dolphin ( Stenella frontalis ), bottlenose dolphin ( Tursiops truncatus ), clymene dolphin ( Stenella clymene ), false killer whale ( Pseudorca crassidens ), Fraser’s dolphin ( Lagenodelphis hosei ), killer whale ( Orcinus orca ), melon

- headed whale ( Peponocephala electra ), pantropical spotted dolphin ( Stenella attenuata ), py gmy killer whale ( Feresa attenuata ), short

- finned pilot whale ( Globicephala macrorhynchus ), Risso’s dolphin ( Grampus griseus ), rough

- toothed dolphin ( Steno bredanensis ), spinner dolphin ( Stenella longirostris ), and striped dolphin ( Stenella coeruleoalba ). The most common non

- endangered cetaceans in the deepwater environment are the pantropical spotted dolphin, spinner dolphin, and clymene dolphin. However, any of these species could occur in the lease area.



### Impacts of Drilling Vessel Presence, Noise, and Lights

Noise from routine oil and gas production activities has the potential to disturb marine mammals. Most odontocetes (toothed whales and dolphins) use sounds in a higher frequency range than the low fre quency sounds produced by OCS activities (Richardson et al., 1995). Noise associated with OCS drilling activities is relatively weak in intensity, and an individual animal’s noise exposure would be transient. There are other OCS facilities and activities near the lease area, and the region as a whole has a large number of similar sources. This project would represent a small contribution to the overall noise regime, and any short

- term impacts are not expected to be biologically significant to marine mamm al populations.

Platform lighting and presence are not identified as IPFs for marine mammals in recent lease sale EISs (MMS, 2007b, 2008; BOEMRE , 2011a,b).



### Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb marine mammals, and there is also a risk of vessel strikes. Data concerning the frequency of vessel strikes are presented in the lease sale EIS (MMS, 2007b). To reduce the potential for vessel strikes, BOEM and BSEE have issued JOINT
NTL 2012

- G01 , which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop theirMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 38 vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. Vessel operators and crews are required to attempt to

m aintain a distance of 91 m (300 ft) or greater when whales are sighted and 45 m (150 ft) when small cetaceans are sighted. If the whale is believed to be a North A tlantic right whale, vessels should maintain a minimum distance of 500 yards (457 m) from the animal (50 CFR 2224.103). When cetaceans are sighted while a vessel is underway, vessels must attempt to remain parallel to the animal’s course and avoid excessi ve speed or abrupt changes in direction until the cetacean has left the area. Vessel operators are required to reduce vessel speed to 10 knots or less when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel, wh en safety permits. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing marine mammals, and therefore no significant impacts are expected.

Aircraft traffic also has the potential to disturb ma rine mammals (Würsig et al., 1998). However, while flying offshore, helicopters maintain altitudes above 213 m (700 ft) during transit to and from the working area. This altitude will minimize the potential for disturbing marine mammals, and no significa nt impacts are expected (MMS, 2007b).



### Impacts of a Diesel Fuel Spill

Potential diesel fuel spill impacts on marine mammals are discussed in recent EISs (MMS, 2007b, 2008), and oil impacts on marine mammals in general are discussed by Geraci and St. Aubin ( 1990). For this SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts on these animals.

The probability of a diesel fuel spill will be minimized by BP’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of BP’s OSRP will be an available option to reduce impacts. Given the open ocean location of the lease area, the duration of a spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill in offshore wate rs would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and t he effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates that over 90% would be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous me mbranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (MMC, 2010). However, due to the limited areal extent and short duration of water quality imp acts from a diesel fuel spill, as well as the mobility of marine mammals, no significant impacts would be expected.



### Impacts of a Large Oil Spill (WCD)

Potential spill impacts on marine mammals are discussed in MMS (2000, 2007b, 2008). For this
SDOCD , ther e are no unique site

- specific issues. Impacts of oil spills on marine mammals can include direct impacts from oil exposure, as well as indirect impacts due to response activitiesMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 39 and materials (e.g., vessel traffic, noise, and dispersants) (MMC, 2010). D irect physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contami nated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical conditio n, and death. Behavioral responses may include displacement of animals from prime habitat, disruption of social structure, changing prey availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing move ment patterns or migration (MMC, 2010).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb marine mammals and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with JOINT NTL 2012

- G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected.



### C.3.5 Sea Turtles (Endangered/Threatened)

Five species of endangered or threatened sea turtles may be found near the lease area. Endangered species are the leatherback ( Dermochelys coriacea ), Kemp's ridley ( Lepidochelys kempii ), and hawksbill ( Eretmochelys imbricata ) turtles. The loggerhead turtle ( Caretta caretta )
is a t hreatened species. The green turtle ( Chelonia mydas ) is listed as threatened, except for the Florida breeding population, which is listed as endangered. Species descriptions are presented in a recent lease sale EIS (MMS, 2007b).

Leatherbacks and loggerhe ads are the most likely species to be present near the lease area as adults. Green, hawksbill, and Kemp’s ridley turtles are typically inner shelf and nearshore species, unlikely to occur near the lease area as adults. Hatchlings or juveniles of any of t he sea turtles may be present in deepwater areas, including the lease area, where they may be associated with Sargassum and other flotsam.

Sea turtle nesting in the northern Gulf of Mexico can be summarized by species as follows:

• Loggerhead turtles

– Logge rheads nest in significant numbers along the Florida Panhandle and, to a lesser extent, from Texas through Alabama (MMS, 2007b). The nearest significant nesting area of loggerhead turtles is found in Louisiana, on beaches within the Breton NWR;

• Green and leatherback turtles

– Green and leatherback turtles infrequently nest on Florida Panhandle beaches (Florida Fish and Wildlife Conservation Commission, 2010);

• Kemp’s ridley turtles

– The main Kemp’s ridley nesting site is Rancho Nuevo beach, Tamaulipas, Mex ico (NMFS et al., 2010). Kemp’s ridley turtles typically do not nest in abundance along the U. S. G ulf of Mexico coastline, although there are reports of Kemp’s ridleys nesting along the Texas and Alabama coast (Share the Beach, 2010); and

• Hawksbill turtles

– Hawksbi lls typically do not nest anywhere near the project area.

IPFs potentially affecting sea turtles include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents

- a diesel fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on sea turtles due to rapid dispersion, the small area of ocean affected, and the intermittent nature of the discharges.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 40 Compliance with BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on sea turtles.



### Impacts of Drilling and Construct ion Presence, Noise, and Lights

Offshore oil and gas related activities produce a broad array of sounds at frequencies and intensities that may be detected by sea turtles (Geraci and St. Aubin, 1987). Potential impacts may include behavioral disruption and temporary or permanent displacement from the area near the sound source. Certain sea turtles, especially loggerheads, may be attracted to off shore structures (Lohoefener et al., 1990) and, thus, may be more susceptible to impacts from sounds produced during routine operations. Helicopters and service vessels may also affect sea turtles due to machinery noise and/or visual disturbances. The mo s t likely impacts would be short

- term behavioral changes such as diving and evasive swimming, disruption of activities, or departure from the area. These short

- term impacts are not expected to be biologically significant to sea turtle populations.

Artific ial lighting can disrupt the nocturnal orientation of sea turtle hatchlings (Witherington, 1997; Tuxbury and Salmon, 2005). However, hatchlings may rely less on light cues when they are offshore than when they are emerging on the beach (Salmon and Wyneken , 1990). The NMFS (2007) concluded that the effects of lighting from offshore structures on sea turtles are insignificant.



### Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sea turtles, and there is also a risk of v essel strikes. Data show that vessel traffic is one cause of sea turtle mortality in the Gulf of Mexico (Lutcavage et al., 1997). While adult sea turtles are visible at the surface during the day and in clear weather, they can be difficult to spot from a moving vessel when resting below the water surface, during nighttime, or during periods of inclement weather. To reduce the potential for vessel strikes, BOEM and BSEE have issued JOINT NTL 2012

- G01 , which recommends protected species identification trai ning and that vessel operators and crews maintain a vigilant watch for sea turtles and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. When sea turtle s are sighted, vessel operators and crews are required to attempt to maintain a distance of 45 m (150 ft) or greater whenever possible. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sea turtles (NMFS, 2007).

Helicopter traffic also has the potential to disturb sea turtles. However, while flying offshore, helicopters maintain altitudes above 213 m (700 ft) during transit to and from the working area. This altitude will minimize the pote ntial for disturbing sea turtles, and no significant impacts are expected.



### Impacts of a Diesel Fuel Spill

Potential diesel fuel spill impacts on sea turtles are discussed in recent EISs (MMS, 2007b, 2008) and by the NMFS (2007) in its Biological Opinion fo r the Five

- Year Oil and Gas Leasing Program in the Central and Western Planning Areas of the Gulf of Mexico. For the SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts on these animals.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 41 The probability of a diesel fu el spill will be minimized by BP’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of BP’s OSRP is available as an option to reduce potential for impacts. Given the open ocean location of the lease area, the d uration of a diesel fuel spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation produ cts. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates that ove r 90% would be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

Direct physical and physiological effects of e xposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (MMC, 2010). However, due to the limited areal extent and short duration of water quality impacts from a fuel spill, no significant impacts would be expected.

A diesel fuel spill in the lease area would be unlikely to affect sea turtle nesting beaches, as the lease area is 49 miles (79 km) from the nearest shoreline (Louisiana). As explained in
Section A.9.2 , a diesel fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up.



### Impacts of a Large Oil Spill (WCD)

Impacts of oil spills on sea turtles can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes and smoke (e.g., from in situ burning of oil); ingestion of oil (and dispersants) directly or via contaminated fo od; and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat, disruption of social structure, changing food availability and foraging distribution and/or patterns, changing reproductive behavior/productivity, and changing movement patterns or migration. In the even t of a spill, implementation of BP’ s OSRP is expected to minimize the potential for these types of impacts on sea turtles. Section 10 of this SDOCD provides detail on spill response measures.

Studies of oil effects on loggerheads in a controlled setting ( Lutcavage et al., 1995) suggest that sea turtles show no avoidance behavior when they encounter an oil slick, and sea turtle s in an affected area may be expected to be exposed. Sea turtles’ diving behaviors also put them at risk. Sea turtles rapidly inha le a large volume of air before diving and continually resurface over time, which may result in exposure to volatile vapors and oiling (NMFS, 2007).

Spilled oil reaching sea turtle nesting beaches could have effects on nesting sea turtles and egg developme nt (NMFS, 2007). An oiled beach could affect nest site selection or result in no nesting at all (e.g., false crawls). Upon hatching and successfully reaching the water, hatchlingsMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 42 are subject to the same types of oil spill exposure hazards as adults. Ha tchlings that contact oil residues while crossing a beach can exhibit a range of effects, from acute toxicity to impaired movement and normal bodily functions (NMFS, 2007).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb sea turtles and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with JOINT NTL 2012

- G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected.



### C.3.6 Piping Plover (Threatened)

The Piping Plover ( Charadrius melodus ) is a migratory shore bird that overwinters along the southeastern U.S. and Gulf of Mexico coasts. This threatened species is in decline as a result of hunting, habitat loss and modification, predation, and disease (USFWS, 2003). Critical overwintering habitat has been designated, including beaches in Texas, Louisiana, Mississippi, Alabama, and Florida ( Figure 3 ). Piping Plovers inhabit coastal sandy beaches and mudflats, feeding by probing for invertebrates at or just below the surface. They use beaches adjacent to foraging areas for roosting and preening (USFWS, 2010a). A species description is presented in a recent le ase sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affecting Piping Plovers. There are no IPFs associated with routine project activities that could affect these birds. A small fuel spill in the lease area would be unlikely to affect Piping Plovers because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation in
Section A.9.2 ).



### Impacts of a Large Oil Spill (WCD)

The lease area is 51 miles (81 km) from the nearest shorelines inhabited by Piping Plovers ( Figure 3 ). The revised OSRA results (BOEMRE, 2011a) summarized in Section A.9.3 ( Table 4 ) predict that during the spring there is a 4% probability that an oil spill from the lease area would reach a shoreline desig nated as critical habitat for the Piping Plover within 10 days. Plovers could physically oil themselves while foraging on oiled shores or secondarily contaminate themselves through ingestion of oiled intertidal sediments and prey (MMS, 2007b). Plovers

co ngregate and feed along tidally exposed banks and shorelines, following the tide out and foraging at the water’s edge. It is possible that some deaths of Piping Plovers could occur, especially if spills occur during winter months when plovers are most com mon along the coastal Gulf or if spills contacted critical habitat. Impacts could also occur from vehicular traffic on beaches and other activities associated with spill cleanup.



### C.3.7 Whooping Crane (Endangered)

The Whooping Crane ( Grus americana ) is an omnivorous wading bird and an endangered species. There are three wild populations in North America (Whooping Crane Eastern Partnership, 2010). One population winters along the Texas coast at Aransas NWR and summers at Wood Buffalo National Park in Canad a. This population represents the majority of the world’s population of free

- ranging Whooping Cranes and reached a record population of 270 at Aransas NWR in December 2008 (Whooping Crane Eastern Partnership, 2010).
A non

- migrating population has been re introduced in central Florida, and another reintroducedMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SD OCD Page 43 population summers in Wisconsin and migrates to the southeastern U.S. for the winter. Whooping Cranes breed, migrate, winter, and forage in a variety of habitats, including coastal marshes and estuar ies, inland marshes, lakes, ponds, wet meadows and rivers, and agricultural fields (USFWS, 2007). About 9,000 ha (22,240 ac) of salt flats on Aransas NWR and adjacent islands comprise the principal wintering grounds of the Whooping Crane. Aransas NWR is designated as critical habitat for the species ( Figure 3 ). A species description is presented in a recent lease sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affecting Whooping Cranes. A small fuel spill in the lease area wou ld also be unlikely to affect Whooping Cranes, due to the distance from Aransas NWR. As explained in Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up.



### Impacts of a Large Oil Spill (WCD)

A large oil spill is unlikely to affect Whooping Cranes as the lease area is approximately
488 miles (784 km) from its critical habitat designated in the Aransas NWR. The revised OSRA modeling (BOEMRE, 2011a) predicts that there is a 3% or less probabilit y that an oil spill originating in the lease area would reach the Aransas NWR within 30 days and a 17% probability of oil reaching that area in 120 days ( Table 4 )

. In the event of oil exposure, Whooping Cranes could physically oil themselves while foraging in oiled areas or secondarily contaminate themselves through ingestion of contaminated shellfish, frogs, and fishes. It is possible that some Whooping Crane deaths could occur. In the event of a spill, BP would work with the applicable State and Federal agencies to prevent impacts from a spill.



### C.3.8 Gulf Sturgeon (Threatened)

The Gulf sturgeon ( Acipenser oxyrinchus desotoi ) is a threatened fish species that inhabits major rivers and inner shelf waters from the Mississippi River to the Suwannee River, Florida (Barkuloo, 1988; Wakeford, 2001). An anadromous fish that migrates from the sea upstream into coastal rivers to spawn in freshwater, it historically ranged from the Mississippi River to Charlotte Harbor, Florida (Wakeford, 2001). Populations have been depleted or even extirpated throughout the species’ historical range by fishing, shoreline development, dam construction, water quality changes, and other factors (Barkuloo, 1988; Wakeford, 2001). These declines prompted the listing of the Gulf stur geon as a threatened species in 1991. The best known populations occur in the Apalachicola and Suwannee Rivers in Florida (Carr, 1996; Sulak and Clugston, 1998), the Choctawhatchee River in Alabama (Fox et al., 2000), and the Pearl River in Mississippi/Lo uisiana (Morrow et al., 1998). Critical habitat in the Gulf extends from Lake Borgne, Louisiana (St. Bernard Parish) to Suwannee Sound, Florida (Levy County) (NMFS, 2010b) ( Figure 3 ). A species description is presented in a recent lease sale EIS (MMS, 20 07b) and in the recovery plan for this species (USFWS and Gulf States Marine Fisheries Commission, 1995).

A large oil spill (WCD) is the only IPF potentially affecting Gulf sturgeon. There are no IPFs associated with routine project activities that could affect these fish. A diesel fuel spill in the lease area would be unlikely to affect Gulf sturgeon because a small fuel spill would not be expected to make landfall or reach coastal w aters prior to breaking up (see explanation in
Section A.9.2 )

. Compliance with BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on Gulf sturgeon.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 44

Figure 3

. Location of selected environmental features in relation to the lease area.Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 45 

### Impacts of a Large Oil Spill (WCD)

Potential spill impacts on Gulf sturgeon are discussed in recent lease sale EISs ( MMS, 2007b, 2008) and by NMFS (2007)

. For this SDOCD , there are no unique site

- specific issues with respect to this species.

The lease area is approximately 109 miles (175 km) from the nearest Gulf sturgeon critical habitat. The revised OSRA modeling (BOEMRE, 2011a) predicts that a spill in the lease area has 1% or less probability of contacting any coastal areas inhabited by Gulf sturge on within
30 or 120 days ( Table 4 )

. In the event of oil reaching Gulf sturgeon habitat, the fish could be affected by direct ingestion, ingestion of oiled prey, or the absorption of dissolved petroleum products through the gills. Based on the life history of this species, subadult and adult Gulf sturgeon would be most vulnerable to an estuarine or marine oil spill, and would be vulnerable only from
1 September through 30 April when this species is foraging in estuarine and shallow marine habitats (NMFS, 20 07).



### C.3.9 S malltooth S awfish (Endangered)

Smalltooth sawfish ( Pristis pectinata ) are found in the tropical and subtropical Atlantic Ocean. In the western Atlantic they have historically ranged from New Yor k to Brazil, including the Gulf of Mexico and Caribbean Sea. This sawfish primarily occurs in estuarine and coastal habitats such as bays, lagoons, and rivers. The smalltooth sawfish was listed as endangered on
1 April 2003, under the ESA. The critical habitat consists of two units: t he Charlotte Harbor Estuary Unit, which comprises approximately 89,621 ha ( 221,459 ac ) of coastal habitat

, and the Ten Thousand Islands/Everglades Unit, which comprises approximately 250,506 ha ( 619,013 ac ) of coastal habitat. The two units are located al ong the southwestern coast of Florida between Charlotte Harbor and Florida Bay.

A large oil spill (WCD) is the only IPF potentially affecting smalltooth sawfish. There are no IPFs associated with routine project activities that could affect these fish. A diesel fuel spill in the lease area would be unlikely to affect smalltooth sawfish because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill (WCD)

Poten tial spill impacts on smalltooth sawfish are similar to those discussed for other coastal and estuarine species in recent lease sale EISs (MMS, 2007b, 2008) and by the NMFS (2007) in its Biological Opinion. For this SDOCD , there are no unique site

- specifi c issues with respect to smalltooth sawfish.

In the event of oil reaching smalltooth sawfish habitat, the fish could be affected by direct ingestion, ingestion of oiled prey, or the absorption of dissolved petrole um products through the gills.



### C.3. 10 Beach Mice (Endangered)

Four subspecies of endangered beach mice ( Peromyscus polionotus ) occur on the barrier islands of Alabama and the Florida Panhandle: the Alabama, Choctawatchee, Perdido Key, and
St. Andrew beach mice. Critical habitat has been designated for all four subspecies; Figure 3Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 46 shows their combined critical habitat. Species descriptions are provided in a rece nt lease sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affecting beach mice. There are no IPFs associated wi th routine project activities that could affect these animals due to the distance from shore and the lack of any onshore support activities near their habitat. A diesel fuel spill in the lease area would not affect beach mice because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 )

. Compliance with
BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on beach
mice.



### Impacts of a Large O il Spill (WCD)

Potential spill impacts on beach mice are discussed in recent lease sale EISs (MMS, 2007b, 2008). For this SDOCD , there are no unique site

- specific issues with respect to these species that were not analyzed in these documents.

The lease ar ea is about 114 miles (184 km) southwest from the nearest beach mouse critical habitat . The revised OSRA modeling summarized in Section A.9.3 predicts that a spill in the lease area has a 1% or less probability of reaching either the Alabama or Florida sh orelines inhabited by beach mice within 120 days ( Table 4 )

.



### C.3. 1 1 Elkhorn Coral (Endangered)

Elkhorn coral ( Acropora palmata ) is found primarily in shallow waters with temperatures ranging between 26 ° and 30° C elsius ( 79 ° and 86 ° F ahrenheit ) and significant water movement. Elkhorn coral was once one of the most abundant species in waters ranging from 1 to 5 m (3.3 to 16 ft) deep in tropical and subtropical waters. In the northern Gulf

, e lkhorn coral has been found within the coral cap region of the Flower Garden Banks National Marine Sanctuary ( Flower Garden Banks National Marine Sanctuary , 2011).

There are no IPFs associated with routine project activities that could affect this species in the northern Gulf. A diesel fuel spill would not affect elkhorn coral colonies because the oil would float and dissipate on the sea surface. A WCD would be unlikely to affect the coral cap region of the Flower Gardens Bank because of the water depth of the area. Although subsurface clouds of oil droplets wer e reported following the Macondo spill, these clouds resulted from the use of subsea dispersants at the seafloor and were limited to a few miles around the drillsite (Camilli et al., 2010)

.


## C.4 Coastal and Marine Birds

C.4.1 Marine and Pelagic Birds

A variety of seabirds may occur in the pelagic environment of the project areas (Clapp et al., 1982a,b, 1983; Peake, 1996; Hess and Ribic, 2000). Seabirds spend much of their lives offshore over the open ocean, except during breeding season when they nest a long the coast. In addition, other birds such as waterfowl, marsh birds, and shore birds may occasionally be present over open ocean areas. No endangered or threatened bird species are likely to occur at the project area due to the distance from shore. For a discussion of shore birds and coastal nesting birds, see Section C.4.2

.Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 47 Seabirds of the northern Gulf of Mexico were surveyed from ships during the GulfCet II program. Hess and Ribic (2000) reported that terns, storm

- petrels, shearwaters, and jaeger s were the most frequently sighted seabirds in the deepwater area. From these surveys, four ecological categories of seabirds were documented in the deepwater areas of t he Gulf: summer migrants (e.g., shearwaters, storm petrels, and boobies); summer resid ent s that breed in the Gulf (e.g., Sooty Tern, Least Tern, Sandwich Tern, and Magnificent Frigat ebird); winter residents (e.g., gannets, gulls, and jaegers); and permanent resident species (e.g., Laughing Gulls, Royal Terns, and Bridled Terns) (Hess and Ri bic, 2000).

Common seabird species include Wilson’s Storm

- Petrel ( Oceanites oceanicus ), Magnificent Frigatebird ( Fregata magnificens ), Northern Gannet ( Morus bassanus ), Masked Booby ( Sula dactylatra ), Brown Booby ( Sula leucogaster ), Cory’s Shearwater ( Calo nectris diomedea ), Greater Shearwater ( Puffinus gravis ), and Audubon’s Shearwater ( Puffinus lherminieri ). Seabirds are distributed Gulf

- wide and are not specifically associated with the lease area.

Relationships with hydrographic features were found for s everal seabird species, possibly due to effects of hydrography on nutrient levels and productivity of surface waters where birds forage. GulfCet II did not estimate bird densities; however, Powers (1987) indicates that seabird densities over the open ocea n typically are <10 birds/km 2

.

Trans

- Gulf migrant birds including shorebirds, wading birds, and terrestrial birds may also be present in the lease area. Migrant birds may use offshore structures and platforms for resting, feeding, or as temporary shelter from inclement weather (Russell, 2005). Some birds may be attracted to offshore structures because of the lights and the fish populations that aggregate around these structures.

IPFs potentially affecting marine and pelagic birds include drilling rig pres ence, noise, and lights; support vessel and helicopter traffic; and two types of accidents

- a small fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on the birds due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of these animals. Compliance with BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on birds.



### Impacts of Drilling and Construction Vessel Presence, Noise, and Lights

Birds that frequent platforms may be exposed to contaminants including air pollutants and routine discharges, but significant impacts are unlikely due to rapid dispersion. Birds migrating over water have been known to strike offshore str uctures, resulti ng in death or injury (Wiese et al., 2001; Russell, 2005). Mortality of migrant bird s at tall towers and other land

- based structures has been reviewed extensively, and the mechanisms involved in platform collisions appear to be similar. I n some cases, migrants simply do not see a part of the platform until it is too late. In other cases, navigation may be disrupted by noise (Russell, 2005). On the other hand, offshore structures are suitable stopover habitats for most trans

- Gulf migrant species, and most of the migrants that stop over on platforms probably benefit from their stay, particularly in spring (Russell, 2005). Any impacts on populations of either seabirds or trans

- Gulf migrant birds are not expected to be significant.

A recent study in the North Sea indicated that platform lighting causes circling behavior in various birds, especially on cloudy nights; apparently the birds’ geomagnetic compass is upset by the red part of the spectrum from the lights currently in use (Nederlandse AardolieMississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 48 Maatschappij, 2007). The numbers varied greatly, from none at all to some tens of thousands of birds per night per platform, with an apparent effect radius of up to 3 miles (5 km). A study in the Gulf of Mexico also noted the phenomenon, but di d not recommend mitigation (Russell, 2005). Factors to consider in evaluating this impact in the Gulf of Mexico would include the lower incidence of cloudy and foggy days in the Gulf of Mexico versus the North Sea. Lighting impacts, collisions, or other adverse effects from a single floating structure are unlikely, and no significant impacts are expected.



### Impacts of Support Vessel and Helicopter Traffic

Support vessels and helicopters are unlikely to significantly disturb pelagic birds in open, offshore w aters. It is likely that individual birds would experience, at most, only short

- term behavioral disruption, and the impact would not be significant.



### Impacts of a Diesel Fuel Spill

Potential diesel fuel spill impacts on marine birds are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts on these animals.

The probability of a diesel fuel spill will be minimized by BP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a diesel fuel spill, implementation of BP’s OSRP will be an available option to mitigate and reduce the potential for impacts on marine and pelagic birds. Given the open ocean location of the lease area, the duration of a diesel fuel spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates th at over 90% would be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

Birds exposed to oil on the sea surface could experience direct physical and physiological effects including skin irritation; chemical burns of skin, eyes, and mucous membranes; and inhalation of toxic fumes. Due to the limited areal extent and short duration of water quality impacts from a die sel fuel spill, secondary impacts due to ingestion of diesel fuel via contaminated prey or reductions in prey abundance are unlikely. Due to the low densities of birds in open ocean areas, the small area affected, and the brief duration of the surface sli ck, no significant impacts on pelagic birds would be expected.



### Impacts of a Large Oil Spill (WCD)

Potential spill impacts on marine and pelagic birds are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD , there are no unique site

- specific issues with respect to spill impacts on these animals.

BOEMRE has reexamined the analyses for coastal and marine birds presented in MMS (2007b, 2008) and determined that no new information was found that would alter the potential impacts on marine and pelagic bi rds (BOEMRE, 2011a,b).Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 49 Pelagic seabirds could be exposed to oil from a spill at the project area. Hess and Ribic (2000) reported that terns, storm

- petrels, shearwaters, and jaegers were the most frequently sighted seabirds in the deepwater Gulf of Mexico (>200 m). Powers (1987) indicates that seabird densities over the open ocean typically are <10 birds/km 2 . The number of pelagic birds that could be affected in open, offshore waters would depend on the extent and persistence of the oil slick.

The recent Macondo spill provides relevant information about the species of pelagic birds that may be affected in the event of a large oil spill. Birds that have been treated for oiling include several pelagic species such as the Northern Gannet, Magnificent Frigate bird, and Masked Booby (International Bird Rescue Research Center, 2010). The Northern Gannet is among the species with the largest numbers of birds affected by the spill.



### C.4.2 Shore Birds and Coastal Nesting Birds

Threatened and endangered bird species (Piping Plover and Whooping Crane) have been discussed previously in Section C.3 . Various species of non

- endangered birds are also found along the northern Gulf Coast, including diving birds, shore birds, marsh birds, wading birds, and waterfowl. Gulf Coast marshes and beaches also provide important feeding grounds and nesting habitats. Species that breed on beaches, flats, dunes, bars, barrier islands, and similar habitats include the Sandwich Tern, Wilson’s Plover, Black Skimmer, Forster’s Tern, Gull

- Billed Tern, Laughing Gull, Least Tern, and Royal Tern (USFWS, 2010b). Additional information is presented in recent lease sale EISs (MMS, 2007b, 2008).

The Eastern Brown Pelican ( Pelecanus occidentalis ) has been delisted from its endangered status under ESA (USFWS, 2010c). However, this species is listed as a species of greatest conservation need by the State of Mississippi (Mississippi Department of Wildlife, Fisheries and Parks, 2011) and as a species of special concern by the State of Florida (Florid a Fish and Wildlife Conservation Commission, 2010). Brown Pelicans inhabit coastal habitats and forage within both coastal waters and waters of the inner continental shelf. Aerial and shipboard surveys, including GulfCet and GulfCet II, indicate that Bro wn Pelicans do not occur in deep offshore waters (Fritts and Reynolds, 1981; Peake, 1996; Hess and Ribic, 2000). Nearly half the southeastern population of Brown Pelicans live in the northern Gulf Coast, generally nesting on protected islands (USFWS, 2010 b).

The Southern Bald Eagle ( Haliaeetus leucocephalus ) was delisted from its threatened status in the lower 48 states on 28 June 2007. The Bald Eagle is a terrestrial raptor widely distributed across the southern U.S., including coastal habitats along the Gulf of Mexico. The Gulf Coast is inhabited by both wintering migrant and resident Bald Eagles (Johnsgard, 1990; Ehrlich et al., 1992).

IPFs potentially affecting shorebird s and coastal nesting birds include support vessel and helicopter traffic and a la rge oil spill (WCD). A diesel fuel spill in the lease area would be unlikely to affect shorebirds or coastal nesting birds, as the lease area is 49 miles (79 km) from the nearest shoreline (Louisiana) . As explained in Section A.9.2 , a small fuel spill wo uld not be expected to make landfall or reach coastal waters prior to breaking up. Compliance with
BSEE NTL 2012

- G01 will minimize the potential for marine debris

- related impacts on shorebirds.Mississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 50 

### Impacts of Support Vessel and Helicopter Traffic

Support vess els and helicopters will transit coastal areas near Port Fourchon and Houma, Louisiana where shore birds and coastal nesting birds may be found. These activities could periodically disturb individuals or groups of birds within sensitive coastal habitats ( e.g., wetlands that may support feeding, resting, or breeding birds).

Vessel traffic may disturb some foraging and resting birds. The disturbances will be limited to flushing birds away from vessel pathways. Flushing distances vary among species and indi viduals; known distances are from 20 to 49 m (65 to 160 ft) for personal watercraft and
23 to 58 m (75 to 190 ft) for an outboard

- powered boat (Rodgers and Schwikert, 2002). Flushing distances may be similar or less for the support vessels to be used for BP’s project, and some species such as gulls are attracted to boats. Support vessels will not approach nesting or breeding areas on the shoreline, so disturbances to nesting birds, eggs, and chicks is not expected. Vessel operators will use designated na vigation channels and comply with posted speed and wake restrictions while transiting sensitive inland waterways. Any short

- term impacts are not expected to be biologically significant to coastal bird populations.

Aircraft traffic can cause some disturban ce to birds onshore and offshore. Responses are highly dependent on the type of aircraft, the bird species, the activities that animals were previously engaged in, and previous exposures to overflights (Efroymson et al., 2000). Helicopters seem to

cause the most intense responses compared to other human disturbances for some species (Bélanger and Bédard, 1989). However, Federal Aviation Administ ration Advisory Circular
No. 91

- 36D recommends that pilots maintain a minimum altitude of 610 m (2,000 ft) when flying over noise sensitive areas such as wildlife refuges, parks, and areas with wilderness characteristics. This is greater than the distance (slant range) at which aircraft overflights have been reported to cause behavioral effects on most species of birds studied (Efroymson et al., 2000). With these guidelines in effect, it is likely that individual birds would experience, at most, only short

- term behavioral disruption.



### Impacts of Large Oil Spill (WCD)

Data from the Macondo spill provide additional information about the species of coastal birds that may be affected in the event of a catastrophic spill of a similar nature and duration. This information supplements the analysis presented in the lease sale EIS (MMS, 2007b). A ccording to USFWS (2010d) and based on the latest reports, about 5,000 dead birds have been collected since the spill began, and about 1,900 of the dead animals were visibly oiled. In addition, over 2,000 oiled birds have been collected alive and about 1, 200 released (NMFS, 2010c). According to the International Bird Rescue Research Center (2010), bird species that have been treated for oiling include the following:

• Brown Pelican

• White Pelican

• Masked Booby

• Magnificent Frigatebird

• Laughing Gull

• Herring Gull

• Northern Gannet

• Black Crowned Night Heron

• Tri

- colored Heron

• Green Heron • Cattle Egret

• Snowy Egret

• Reddish Egret

• Least Bittern

• Common Tern

• Royal Tern

• Caspian Tern

• Sandwich Tern

• Forster’s Tern

• Black TernMississippi Canyon Block 383 January 2012 Environmental Impact Analysis for S DOCD Page 51 • Gull

- B illed Tern

• Least Tern

• Black Skimmer

• Black Oystercatcher

• White Ibis

• Roseate Spoonbill

• Willet • Sanderling

• Dunlin

• Semipalmated Sandpiper

• Killdeer

• King Rail

• Clapper Rail

• Virginia Rail

According to the USFWS (2010d), species with the largest numbers of dead oiled birds were Laughing Gull, Northern Gannet, Brown Pelican, Royal Tern, Black Skimmer, Least Tern, unidentified Gull, and unidentified Tern. There are no reports of Bald Eagle oi ling.

Coastal birds can be exposed to oil as they float on the water surface, dive during foraging, or wade in oiled coastal waters. Oiled birds can lose the ability to fly, dive for food, or float on the water, which could lead to drowning (USFWS, 2010e) . Oil interferes with the water repellency of feathers and can cause hypothermia in the right conditions. As birds groom themselves, they can ingest and inhale the oil on their bodies. Scavengers such as Bald Eagles and gulls can be exposed to oil by fe eding on carcasses of contaminated fish and wildlife. While ingestion can kill animals immediately, more often it results in lung, liver, and kidney damage, which can le ad to death. Bird eggs may be oiled if an oiled adult sits on the nest.

As noted abov e, the Brown Pelican was recently removed from the Federal endangered species list. Issues for Brown Pelicans include direct contact with oil, disturbance by cleanup activities, and long

- term habitat contamination.



## C.5 Fisheries Resources

C.5.1 Pelagic Co mmunities and Ichthyoplankton

Biggs and Ressler (2000) reviewed the biology of pelagic communities in the deepwater environment of the northern Gulf of Mexico. The biological oceanography of the region is dominated by the influence of the Loop Current, wh ose surface waters are among the most oligotrophic in the world’s oceans. Superimposed on this low

- productivity condition are productive “hot spots” associated with entrainment of nutrient

- rich Mississippi River water and mesoscale oceanographic features. Anticyclonic and cyclonic hydrographic features play an important role in determining biogeographic patterns and controlling primary productivity in the northern Gulf of Mexico (Biggs and Ressler, 2000).

Most fishes inhabiting shelf or oceanic waters of the Gulf of Mexico have planktonic eggs and larvae (Ditty, 1986; Ditty et al., 1988; Richards et al., 1989, 1993). Pelagic eggs and larvae become part of the planktonic community for various lengths of time (10 to 100 days, depending on the species) (MMS, 2007b).

IPFs potentially affecting pelagic communities and ichthyoplankton include drilling rig presence, noise, and lights; effluent discharges; water intakes; and two types of accidents

- a diesel fuel spill and a large oil spill ( WCD).



### Impacts of Drilling Vessel Presence, Noise, and Lights

The drilling vessel, as a floating structure that remains stationary in the deepwater environment for some period of time, will act as a fish

- attracting device (FAD). Construction vessels areMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 52 assumed to be movin g more often than drilling vessels and will therefore not demonstrate the FAD effect. In oceanic waters, the FAD effect would be most pronounced for epipelagic fishes such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994). This FAD effect could possibly enhance the feeding of epipelagic predators by attracting and concentrating smaller fish species. Because the drilling vessel is a sin gle structure, impacts on fish populations, whether beneficial or adverse, are considered minor.



### Impacts of Effluent Discharges

Treated sanitary and domestic wastes will have little or no impact on the pelagic environment in the immediate vicinity of these discharges. These wastes may have elevated levels of nutrients, organic matter, and chlorine, but should be diluted rapidly to undetectable levels within tens to hundreds of meters from the source. Little or no impact on water quality, plankton, and nek ton is anticipated.

Deck drainage will have little or no impact on the pelagic environment in the immediate vicinity of these discharges. Deck drainage from contaminated areas will be passed through an oil

- and

- water separator prior to release, and dischar ges will be monitored for visible sheen. The discharges may have slightly elevated levels of hydrocarbons but should be diluted rapidly to undetectable levels within tens to hundreds of meters from the source. Little or no impact on water quality, plankt on, and nekton is anticipated.

Other discharges in accordance with the NPDES permit, such as desalination unit brine and uncontaminated cooling water, firewater, ballast water, and bilge water are expected to be diluted rapidly and have little or no impact on water column biota.



### Impacts of Water Intakes

Seawater will be drawn from the ocean for once

- through, non

- contact cooling of machinery on the drilling vessel. The estimated intake and discharge of cooling water is approximately 467,657 BPD ( 19.6 MGD).

The intake of seawater for cooling water will entrain plankton. The low intake velocity should allow most strong

- swimming juvenile fishes and smaller adults to escape entrainment or impingement. However, drifting plankton would not be able to escape entr ainment with the exception of a few fast

- swimming larvae of certain taxonomic groups. Those organisms entrained may be stressed or killed, primarily through changes in water temperature during the route from cooling intake structure to discharge structure , and mechanical damage (turbulence in pumps and condensers). Any short

- term impacts of entrainment are not expected to be biologically significant to plankton or ichthyoplankton populations.



### Impacts of a Diesel Fuel Spill

Potential diesel fuel spill impa cts on fisheries resources are discussed in recent EISs (MMS, 2007b, 2008). For the SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts.

The probability of a diesel fuel spill will be minimized by BP’s preventative me asures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of BP’s OSRP will be an available option to help reduce the potential for impacts on pelagicMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 53 communities, including ichthyoplankton. Given the open ocean location of the lease area, the duration of a diesel fuel spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates that over 90% would be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

A dies el fuel spill could have localized impacts on phytoplankton, zooplankton, and nekton. Due to the limited areal extent and short duration of water quality impacts, a diesel fuel spill would be unlikely to produce detectable impacts on pelagic communities.



### Impacts of a Large Oil Spill (WCD)

A large oil spill could affect water column biota including phytoplankton, zooplankton, ichthyoplankton, and nekton. A large spill that persisted for weeks or months would be more likely to affect these communities. Whi le adult and juvenile fishes may actively avoid a large spill, planktonic eggs and larvae would be unable to avoid contact. Eggs and larvae of fishes are especially vulnerable to oiling because they inhabit the upper layers of the water column, and they w ill die if exposed to certain toxic fractions of spilled oil. Impacts potentially would be greater if local

- scale currents retained planktonic larval assemblages (and the floating oil slick) within the same water mass.



### C.5.2 Essential Fish Habitat

Essenti al Fish Habitat (EFH) is defined as those waters and substrate necessary to fish for spawning, breeding, feeding, and growth to maturity. Under the Magnuson

- Stevens Fishery Conservation and Management Act, as amended, Federal agencies are required to cons ult on activities that may adversely affect EFH designated in Fishery Management Plans developed by the regional Fishery Management Councils.

The Gulf of Mexico Fishery Management Council (GMFMC) has prepared Fishery Management Plans for corals and coral r eefs, shrimps, stone crab, spiny lobster, reef fishes, coastal migratory pelagic fishes, and red drum. In 2005, the EFH for these managed species was redefined in Generic Amendment No. 3 to the various Fishery Management Plans (GMFMC, 2005). The EFH for most of these GMFMC

- managed species is on the continental shelf in waters shallower than 183 m (600 ft). The shelf edge is the outer boundary for coastal migratory pelagic fishes, reef fishes, and shrimps. EFH for corals and coral reefs includes some she lf

- edge topographic features on the Texas

- Louisiana OCS, the nearest of which is Sackett Bank, located approximately 64 miles (103 km) from the lease area.

Highly migratory pelagic fishes, which occur as transients in the lease area, are the only remaining group for which EFH has been identified in the deepwater Gulf of Mexico. Species in this group, including tunas, swordfishes, billfishes, and sharks, are managed by NMFS. Highly migratory species with EFH at or near the lease area include the following (NMFS, 2009):Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 54 • Blue marlin (juveniles, adults)

• White marlin (juveniles, adults)

• Swordfish (larvae, juveniles, adults)

• Longbill spearfish (juveniles, adults)

• Albacore tuna (adults)

• Atlantic bluefin tuna (spawn, eggs, larvae, adults)

• Bigeye tuna (adults) • Skipjack tuna (spawn, adults)

• Yellowfin tuna (spawn, juveniles, adults)

• Bigeye thresher shark (all)

• Common thresher shark (all)

• L ongfin mako shark (all)

• Oceanic whitetip shark (all)

• Silky shark (all)

On 27 May 2011, after an extensive scientific review, NOAA announced that Atlantic bluefin tuna currently do not warrant species protection under the ESA . NOAA said the speci es would be classified as a species of concern, however, effectively placing bluefin on a watch list as the agency awaits new data on the impact of a stricter international management regimen

. The central and western Gulf of Mexico may be important spawning habitat for Atlantic bluefin tuna, and NMFS (2009) has designated a Habitat Area of Particular Concern (HAPC) for this species. The HAPC covers m uch of the deepwater Gulf of Mexico, including the lease area ( Figure 3 ). The areal extent of the HAPC is approximately 15,000 mi 2 ( 300,000 km 2 ). The prevailing assumption is that Atlantic bluefin tuna follow an annual cycle of foraging in June through M arch off the eastern United States and Canadian coasts, followed by migration to the Gulf of Mexico to spawn in Apr il, May, and June (NMFS, 2009).

Other HAPCs have been identified in the Gulf of Mexico by the GMFMC (2005). These include the Florida Middle Grounds, Madison

- Swanson Marine Reserve, Tortugas North and South Ecological Reserves, Pulley Ridge, and several individual reefs and banks of the northwestern Gulf of Mexico ( Figure 3 ). The nearest of these is Jakkula Bank, located approximately 195 mil es (313 km) from the lease area.

Routine IPFs potentially affecting EFH include drilling rig presence, noise, and lights; seafloor disturbance; effluent discharges; water intakes; and two types of accidents

– a diesel fuel spill and a large oil spill (WCD).



### Impacts of Drilling Vessel Presence, Noise, and Lights

The drilling vessel presence, as a stationary floating structure in the deepwater environment, will act as an FAD. In oceanic waters, the FAD effect would be most pronounced for epipelagic fish es such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994). This FAD effect would possibly enhance feeding of epipelagic predators by a ttracting and concentrating smaller fish species. Because the drilling vessel is a single structure, any impacts on EFH for highly migratory pelagic fishes are considered minor.



### Impacts of Physical Disturbance to the Seafloor

Sources of seafloor disturban ce include the drilling of well K

- 4

. All operations will be done by
DP vessels. Calculations of the seafloor area potentially impacted have been summarized in
Section A.2 . Soft bottom substrates are ubiquitous along the northern Gulf of Mexico
continent al slope (Gallaway, 1988; Gallaway et al., 2003; Rowe and Kennicutt, 2009). Impacts on soft bottom EFH from physical disturbance to the seafloor during this project are not expected to be significant in the context of similar EFH distributed throughout th e region.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 55 

### Impacts of Effluent Discharges

Effluent discharges potentially affecting EFH by diminishing ambient water quality include produced water, treated sanitary and domestic wastes, deck drainage, and miscellaneous discharges such as desalination unit brine and uncontaminated cooling water, firewater, ballast water, and bilge water. Impacts on water quality have been discussed previously. NPDES permit limitations and requirements are expected to be in compliance, and little or no impact on water quali ty is anticipated. No significant impacts on EFH for highly migratory pelagic fishes are expected from these discharges.



### Impacts of Water Intakes

As noted previously, cooling water intake will cause entrainment and impingement of plankton, including fish eggs and larvae (ichthyoplankton). Any short

- term impacts on EFH for highly migratory pelagic fishes are not expected to be biologically significant.



### Impacts of a Diesel Fuel Spill

The probability of a diesel fuel spill will be minimized by BP’s preventat ive measures during routine operations including fuel transfer. In the unlikely event of a diesel fuel spill, implementation of BP’s OSRP will be an available option to reduce the potential for impacts on EFH. Given the open ocean location of the lease a rea, the duration of a diesel spill and opportunity for impacts to occur would be very brief.

Potential diesel fuel spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008). For the SDOCD, there are no unique site

- specific issues with respect to diesel fuel spill impacts.

A diesel fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a diesel fuel spill and indicates that over 90% would be evaporated o r dispersed naturally within 24 hours. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions.

A diesel fuel spill could have localized impacts on EFH for highly migratory pelagic fishes, including tu nas, swordfishes, billfishes, and sharks. These species occur as transients in the lease area. A spill would also produce short

- term impact on water quality in the HAPC for spawning Atlantic bluefin tuna, which covers much of the deepwater Gulf of Mexico . The areal extent of the affected area would represent a negligible portion of the HAPC.

A diesel fuel spill would not affect EFH for corals and coral reefs, the nearest of these EFH areas being Sackett Bank, located appr oximately 64 miles (103 km) from the lease area. A diesel fuel spill would float and dissipate on the sea surface and would not contact these features.



### Impacts of a Large Oil Spill (WCD)

Potential spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD

, ther e are no unique site

- specific issues with respect to EFH.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 56 An oil spill in offshore waters would temporarily increase hydrocarbon concentrations on the water surface and potentially the subsurface as well. Given the extent of EFH designations in the Gulf o f Mexico (GMFMC, 2005; NMFS, 2009), some impact on EFH would be highly likely.

A large spill could affect the EFH for many managed species including shrimp s , stone crab, spiny lobster, reef fishes, coastal migratory pelagic fishes, and red drum. It would result in adverse impacts on water quality and water column biota including phytoplankton, zooplankton, and nekton. In coastal waters, sediments could be contaminated and result in persistent degradation of the seafloor habitat for managed demersal fish a nd shellfish species.

T he lease area is within the HAPC for spawning Atlantic bluefin tuna (NMFS, 2009). A large spill could temporarily degrade the HAPC due to increased hydrocarbon concentrations in the water column, with the potential for lethal or sub lethal impacts on spawning tuna. Potential impacts would depend in part on the timing of a spill, as this species migrates to the Gulf of Mexico to spawn in April, May, and June (NMFS, 2009).

The Sackett Bank, the nearest topographic feature designated as EFH under the corals and coral reefs management plan is located in West Delta Area, South Addition

, Block 147, located
64 miles (103 km) west of the lease area

. An accidental spill would be unlikely to affect this area, since a surface slick would not re ach these features due to their depth.



## C.6 Archaeological Resources

C.6.1 Shipwreck Sites

Substantial new information that alters the impact conclusion for archaeological resources presented in MMS 2007b and 2008 has come to light as a result of BOEMRE

- spo nsored studies and industry surveys (BOEMRE, 2011a ,b ). Specifically, evidence of damage to significant cultural resources (i.e., historic shipwrecks) has been shown to have occurred because of an incomplete knowledge of seafloor conditions in lease areas >200 m (656 ft) deep that have been exempted from high

- resolution surveys. Since significant historic shipwrecks have been discovered recently outside the previously designated high

- probability areas (some of which show evidence of impacts from permitted activities prior to their discovery), a survey will now be required prior to construction beginning in 2011 in the area of potential effect for all OCS operations as a requirement of the plan permit issued by BOEM ( see NTL 2011

- JOINT

- G 1 )

.

MC 383 is not on the list of lease blocks with a high potential for historic shipwrecks and there were no indications of wrecks or other archaeological resources detected during the site clearance archeological survey ( Geoscience Earth & Marine Services, Inc. [ GEMS ] , 2009 )

. One sonar contact within Block 429 displayed a ship type signature during the C&C Technologies (2011) Archeological, Engineering, and Hazards Study of Blocks 474 to 383, however

, this
contact is approximately 5.17 m iles ( 8.32 km ) from the K

- 4 well site

. BP will abide by the applicable requirements of NTL 2005

- G07, which stipulate that work be stopped at the project site should any previously undetected archaeological resource be discovered after work has begun until appropriate surveys and evaluations h ave been completed.

I mpacts of a large oil spill (WCD) are the only accident IPF s considered. A small fuel spill would not affect shipwrecks because the oil would float and dissipate on the sea surface.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 57 

### Impacts of a Large Oil Spill (WCD)

MMS (2007b) estim ated that a severe subsurface blowout could resuspend and disperse sediments within a 300

- m (984

- ft) radius. Because there are no historic shipwrecks in the lease area, this impact would not be relevant.

Previous analyses (MMS, 2007a, 2008) concluded that oil spills would be unlikely to affect archaeological sites beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface clouds of oil droplets were reported at a water depth of about 1,100 m (3,600 ft), extending at least 22 miles (35 km) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes appa rently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could have the potential to contact shipwreck sites beyond the 300

- m ( 984

- ft) radius estimated by
MMS (2007a, 2008), depending on its extent, trajectory, and persistence. If oil from a subsea spill should come into contact with wooden shipwrecks on the seafloor, it could adversely affect their condition or preservation.

A spill entering shallow coastal waters could conceivably contaminate an undiscovered shipwreck site. As noted by MMS (2007b), should an oil spill contact a coastal historic site, such as a fort or a lighthouse, the major impact would be a temporary, revers ible visual impact from oil contact and contamination of the site and its environment.



### C.6.2 Prehistoric Archaeological Sites

Available evidence suggests that sea level in the northern Gulf of Mexico was at least 90 m (295 ft), and possibly as much as 130 m (427 ft), lower than present sea level during the period 20,000

- 17,000 years Before Present (B.P.) (Nelson and Bray, 1970). Sea level in the northern Gulf reached its present stand around 3,500 years B.P. (Pearson et al., 1986).

During periods that the continental shelf was exposed above sea level, the area was open to habitation by prehistoric peoples. The advent of early man into the Gulf of Mexico region is currently accepted to be around 12,000 years B.P. (Aten, 1983). The sea

- level curve for the

n orthern Gulf of Mexico proposed by Coastal Environments, Inc. (CEI) suggests that sea level at 12,000 years B.P. would have been approximately 45 to 60 m (148 to 197 ft) below the present day sea level (CEI, 1977, 1982). On this basis, the continental she lf shoreward of the 45

- to 60

- m (148

- to 197

- ft) bathymetric contours has potential for prehis toric sites dating after 12,000 years B.P. Because of inherent uncertainties in both the depth of sea level and the entry date of prehistoric man into North Amer ica, the MMS adopted the 60

- m (197

- ft) water depth as the seaward extent for archaeological site potential in Gulf of Mexico region.

With water depths ranging from 1,480 to 1,790 m (4,856 to 5,872 ft) , the lease area is well beyond the 60

- m (197

- ft) depth contour used by BOEMRE as the seaward extent for prehistoric archaeological site potential in the Gulf of Mexico. Because prehistoric archaeological sites are not found in the lease area, the only relevant accident IPF is a large oil spill (WCD). A small fuel spill would not affect prehistoric archaeological resources because the oil would float and dissipate on the sea surface.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 58 

### Impacts of a Large Oil Spill (WCD)

Along the northern Gulf C oast, prehistoric sites occur frequently along the barrier islands and mainland coast and along the margins of bays and bayous (MMS, 2007b). If a spill did reach a prehistoric site along these shorelines it could coat fragile artifacts or site features an d compromise the potential for radiocarbon dating organic materials in a site (although other dating methods are available and it is possible to decontaminate an oiled sample for radiocarbon dating). Coastal prehistoric sites could also be damaged by spil l cleanup operations (e.g., by destroying fragile artifacts and disturbing the provenance of artifacts and site features).



## C.7 Coastal Habitats and Protected Areas

Coastal habitats in the northeastern Gulf of Mexico that may be affected by oil and gas acti vities are described in recent EISs (MMS, 2007b, 2008) and in a literature review by Collard and Way (1997). Sensitive coastal habitats are also tabulated in the OSRP. Coastal habitats inshore of the project area include barrier beaches and dunes, wetlan ds, and submerged seagrass beds. Generally, most of the northeastern Gulf is fringed by barrier beaches, with wetlands and/or submerged seagrass beds occurring in sheltered areas behind the barrier islands and in
estuaries.

Due to the distance from shore, the only IPF s associated with routine activities in the lease area that potentially may affect beaches and dunes, wetlands, seagrass beds, coastal wildlife refuges, wilderness areas, or any other managed or protected coastal area is relate d to support ves sel traffic and a large oil spill (WCD) . The support bases at Port Fourchon and Houma , Louisiana and Theodore, Alabama are not in wildlife refuge s or wilderness area s . Potential impacts of support vessel traffic are addressed briefly below.

A diesel fuel spill in the lease area would be unlikely to affect coastal habitats, as the lease area
is 49 miles (79 km) from the nearest shoreline. As explained in Section A.9.2 , a diesel fuel spill would not be expected to make landfall or reach coastal waters prio r to breaking up.



### Impacts of Support Vessel Traffic

For OCS activities in general, support operations, including crew boats and supply boats, may have a minor incremental impact on wetlands and seagrass beds. Over time, with a large number of vessel trips , vessel wakes can erode shorelines along inlets, channels, and harbors. Support operations, including crew boats and supply boats, may have a minor incremental impact on wetlands and seagrass beds. Impacts should be minimized by following the speed and wake restrictions in harbors and channels.



### Impacts of a Large Oil Spill (WCD)
Potential spill impacts on coastal habitats are discussed in recent EISs (MMS, 2007b, 2008). Coastal habitats inshore of the project area include barrier beaches and dunes, wetlands, and submerged seagrass beds. For this SDOCD , there are no unique site

- specific issues with respect to coastal habitats.

The revised OSRA modeling summarized in Table 4 predicts that during winter there is a
17 % probability of oil from a spill in the lease area reaching shorelines in Texas within 120 days, and a 14 % probability in spring of oil reaching Louisiana shorelines within 120 days.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 59 The shorelines within the ge ographic range predicted by the OSRA modeling ( Table 4 ) include extensive barrier beaches and wetlands, with submerged seagrass beds occurring in sheltered areas behind the barrier islands and in estuaries. NWRs and other protected areas along the

coast a re discussed in a recent lease sale EIS (MMS, 2007b) and BP ’s OSRP. Coastal and near coastal wildlife refuges, wilderness areas , and State and National parks within the geographic range of the potential shoreline contacts after 120 days are presented in T able 7

.

Table 7

. W ildlife refuges, wilderness areas, and State and National parks within the geographic range of the potential shoreline contacts after 120 days (From: BOEMRE, 2011a)

.

County or Parish W ildlife Refuge, Wilderness Area, or State/National Park

Cameron County, Texas Lower Rio Grande Valley National Wildlife Refuge Laguna Atascosa National Wildlife Refuge
Padre Island National Seashore
Isla Blanca Park Andy Bowie County Park Laguna Madre Estuarine and Coastal Marine Area

Willacy County, Texas Lower Rio Grande Valley National Wildlife Reserve Laguna Atascosa National Wildlife Reserve
Padre Island National Seashore Laguna Madre Estuarine And Coastal Marine Area

Kenedy County, Texas Padre Island National Seashore Laguna Madre Estuarine and Coastal Marine Area

Kleberg County, Texas Padre Island National Seashore Laguna Madre Estuarine and Coastal Marine Area

Nueces County, Texas Laguna Madre Estuarine and Coastal Marine Area Mustang Island State Park Lake Corpus Christi State Park
Port Aransas Park
Mission

- Aransas National Estuarine Research Reserve

Aransas County, Texas Mission

- Aransas National Estuarine Research Reserve
Aransas National Wildlife Refuge
Goose Island State Park

Calhoun County, Texas Mission

- Aransas National Estuarine Research Reserve
Aransas National Wildlife Refuge Matagorda Island State Park Guadalupe Delta Wildlife Management Area
Welder Flats Coastal Preserve

Matagorda County, Texas Big Boggy National Wildlife Refuge
Aransas National Wildlife Refuge
Mad Island Wildlife Management Area
San Bernard National Wildlife Refuge

Brazoria County, Texas San Bernard National Wildlife Refuge
Peach Point Wildlife Management Area
Brazoria National Wildlife Refuge Christmas Bay Coastal Preserve and Christmas Bay State Park

Galveston County, Texas Galveston Island State Park
Brazoria National Wildlife Refuge Apffel Park
Seawolf Park
Old Fort Travis Park
Atkinson Island Wildlife Management Area Ft. Anahuc Park
Anahuac National Wildlife Refuge
Mcfaddin National Wildlife RefugeTable 7. (Continued).

Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 60 County or Parish W ildlife Refuge, Wilderness Area, or State/National Park

Jefferson County, Texas Mcfaddin National Wildlife Refuge
Sea Rim State Park Murphree Wildlife Management Area
Texas Point National Wildlife Refuge

Cameron Parish, Louisiana Sabine National Wildlife Refuge
Cameron Prairie National Wildlife Refuge
Lacassine National Wildlife Refuge
Little Pecan Island Natural Area
Peveto Woods Natural Area
Lower Neches Wildlife Management Area
Rockefeller Wildlife Management Area

Vermilion Parish, Louisiana Louisiana Rockefeller Wildlife Management Area Paul J. Rainey Wildlife Management Area

Plaquemines Parish, Louisiana Salvador Wildlife Management Area
Jean Lafitte National Historical Park and Preserve
Delta National Wildlife Refuge

Pass

- a

- Loutre Wildlife Management Area

Breton National Wildlife Refuge
St. Bernard State Park

The level of impacts from oil spills on coastal habitats depends on many factors, including the oil characteristics, the geographic location of the landfall, and the weather and oceanographic conditions at the time (MMS, 2007b). Oil that makes it to beaches may be either liquid weathered oil, an oil

- and

- water mousse, o r tarballs (MMS, 2007b). Oil is generally deposited on beaches in lines defined by wave action at the time of landfall. Oil that remains on the beach will thicken as its volatile components are lost. Thickened oil may form tarballs or aggregations that incorporate sand, shell, and other materials into its mass. Tar may be buried to varying depths under the sand. On warm days, both exposed and buried tarballs may liquefy and ooze. Oozing may also serve to expand the size of a mass as it incorporates be ach materials. Oil on beaches may be cleaned up manually, mechanically, or both. Some oil can remain on the beach at varying depths and may persist for several years as it slowly biodegrades and volatilizes.

Wetlands are sensitive to oiling. The MMS (20 07b) predicted that for every 50 bbl of oil contacting wetlands, approximately 2.7 ha (6.7 ac) of wetland vegetation will experience dieback. The MMS assumed 30 % of these damaged wetlands would recover within 4 years, 85% within 10 years , and a bout 15% of the contacted wetlands would be converted permanently to open

- water habitat. The critical concentration of oil is that concentration above which impacts to wetlands will be long

- term and recovery will take longer than two growing seasons, and which causes plant mortality and some permanent wetland loss. Critical concentrations of various oils are expected to vary broadly for wetland types and wetland plant species. Louisiana wetlands are assumed to be more sensitive to oil contact than elsewh ere in the Gulf because of high cumulative stress (MMS, 2007b). In addition to the direct impacts of oil, cleanup activities in marshes may accelerate rates of erosion and retard recovery rates, which have been reported to require from years to decades fo llowing a spill (MMS, 2007b).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 61 

## C.8 Socioeconomic and Other Resources

C.8.1 Recreational and Commercial Fishing

BOEMRE has reexamined the analysis for recreational and commercial fishing presented in
MMS (2007b, 2008) based on additional information and in c onsideration of the Macondo spill. BOEMRE did not find new information that would alter the potential impact s on commercial fishing (BOEMRE, 2011a,b)

. The main commercial fishing activity in deep waters of the northern Gulf of Mexico is pelagic longlining for tunas, swordfishes, and other billfishes (Continental Shelf Associates, Inc., 2002). Pelagic longlining has occurred historically in the project area, primarily during spring and summer. In August 2000, the Federal government closed two areas in the northeastern Gulf of Mexico to longline fishing (65 FR 47214, 1 August 2000). The lease is outside of the closure

areas.

Longline gear consists of monofilament line deployed from a moving vessel and generally allowed to drift for 4 to 5 hours (Continenta l Shelf Associates, Inc., 2002). As the mainline is put out, baited leaders and buoys are clipped in place at regular intervals. It takes 8 to 10 hours to deploy a longline and about the same time to retrieve it. Longlines are often set near oceanograph ic features such as fronts or downwellings, with the aid of sophisticated on

- board temperature sensors, depth finders, and positioning equipment. Vessels are 10 to 30 m long, and their trips last from about 1 to 3 weeks. The main homeports for Gulf longl ining vessels are in Louisiana (Dulac and Venice) and Florida (Destin, Madeira Beach, and Panama City).

It is unlikely that any commercial fishing activity other than longlining occurs at or near the project area. Benthic species targeted by commercial fi shers occur on the upper continental slope, well inshore of the project area. Royal red shrimp are caught by trawle rs in water depths of about 250 to 550 m (820 to 1,804 ft). Tilefish are caught by bottom longlining in water depths from about 165 to 450 m (540 to 1,476 ft) (Continental Shelf Associates, Inc., 2002).

Most recreational fishing activity in the region occurs in water depths less than 200 m (656 ft) (Continental Shelf Associates, Inc., 1997, 2002). In deeper water, the main attraction to

recr eational fishers would be petroleum platforms offshore Texas and Louisiana. Due to the distance from shore, it is unlikely that recreational fishing activity is occurring in the lease area.

The only routine IPF potentially affecting fisheries are the dril ling and construction vessel presence (including noise and lights) . A diesel fuel spill and a large oil spill (WCD) could both potentially affect fisheries in the lease area.



### Impacts of Drilling and Construction Vessel Presence, Noise, and Lights

There is a slight possibility of pelagic longlines becoming entangled in drilling or construction vessels. For example, in January 1999, a portion of a pelagic longline snagged on the acoustic Doppler current profiler of a drillship working in the Gulf of Mexico (Continental Shelf Associates, Inc., 2002). The line was removed without incident. Generally, longline fishers use radar and are aware of offshore structures and ships when placing their sets. Therefore, little or no impact on pelagic longlining is expe cted.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 62 Because it is unlikely that any recreational fishing activity is occurring in the project area, no adverse impacts are anticipated. Other factors such as effluent discharges are likely to have negligible impacts on commercial or recreational fisheri es due to rapid dispersion, the small area of ocean affected, and the intermittent nature of the discharges.



### Impacts of a Diesel Fuel Spill

The probability of a diesel fuel spill should be minimized by BP’s preventative measures during routine operations i ncluding fuel transfer. Given the open ocean location of the lease area, the duration of a diesel fuel spill and opportunity for impacts to occur would be very brief.

Pelagic longlining activities in the lease area, if any, could be interrupted in the eve nt of a diesel fuel spill. The area of the sea surface with diesel fuel on it wo uld range from 0.5 to 5 ha (1.2 to 12 ac), depending on sea state and weather conditions. Fishing activities could be interrupted due to the activities of response vessels op erating in the lease area. A diesel fuel spill would not affect coastal water quality because the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill (WCD)

Potential s pill impacts on fishing activities are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD , there are no unique site

- specific issues with respect to this activity.

Pelagic longlining activities in the lease area and other fishing activities in the northern Gulf of Mexico could be interrupted in the event of a large oil spill. A spill may or may not result in fishery closures, depending on the duration of the spill, the oceanographic and meteorological conditions at the time, and the effectiveness of spill response measures. The recent Macondo spill provides information about the maximum potential extent of fishery closures in the event of a large oil spill in the Gulf of Mexico (NMFS, 2010 d ). At its peak on 12 July 2010, closures encompassed 84,101 mi 2 ( 217,821 km 2 ), or 34.8% of the U.S. Gulf of Mexico Exclusive Economic
Zone

.



### C.8.2 Public Health and Safety

There are no IPFs associated with routine operations that are expected to affect public health and safety. Impacts of a small fuel spill and a large oil spill (WCD) are addressed below.



### Impacts of a Diesel Fuel Spill

A diesel fuel spill would not have any impacts on public health and safety because it would affect only a small area of the open ocean 49 miles (79 km) from the nearest shorel ine, and nearly all of the diesel fuel would evaporate or disperse naturally within 24 hours. Response crews would be equipped with appropriate safety equipment to avoid injury and health effects. A diesel fuel spill would not be expected to make landfal l or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Impacts of a Large Oil Spill (WCD)

In the event of a large spill from a blowout, the main safety and health concerns are those of the offshore personnel involved in the incident and those responding to the spill. The drilling rig maintains a Shipboard Oil Pollution Emergency Plan as required under MARPOL 73/78.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 63 Depending on the spill rate and duration, the physical/chemical characteristics of the oil, meteorological and oceanographic condi tions at the time, and the effectiveness of spill response measures, the public could be exposed to oil on the water and along the shoreline, including skin contact or breathing VOCs . Crude oil is a highly flammable material

, and any smoke or vapors from a crude oil fire can cause irritation, and in large quantities may pose a health hazard.

Data from the recent Macondo spill provide relevant information about the types of health issues that may occur in the event of a large oil spill (Centers for Disease Control and Prevention, 2010). Wildlife cleaning and rehabilitation workers have reported concerns including scrapes and cuts, itchy or red skin or rash, and symptoms of headache or feeling faint, dizzy, or fatigued. Hand, shoulder, or back pain was als o reported by some wildlife

- cleaning workers. Personnel working on offshore vessels or providing direct oversight to o ffshore vessels, including
USCG personnel, civilian contractors, and other responders who are exposed to oil and dispersants

, may develop upper respiratory symptoms

. Another potential occupational hazard for spill response workers in general was heat stress from work in a hot and humid environment. Initial symptoms from cleanup workers who sought medical care in Louisiana were typical of

a cute exposure to hydrocarbons or H 2 S such as headaches, dizziness, nausea, vomiting, cough, respiratory distress, and chest pain (Solomon and Janssen, 2010).



### C.8.3 Employment and Infrastructure

There are no IPFs associated with routine operations that are expected to affect employment and infrastructure. The project would be supported from existing shorebase facilities in Louisiana and Alabama. No new or expanded facilities will be constructed, and no new employees are expected to move permanently into th e area. The project will have a negligible impact on socioeconomic conditions such as local employment, existing offshore and coastal infrastructure (including major sources of supplies, services, energy, and water), and minority and lowe r income groups. Impacts of a diesel fuel spill and a large oil spill (WCD) are addressed below.



### Impacts of a Diesel Fuel Spill

The probability of a diesel fuel spill will be minimized by BP ’s preventative measures during routine operations including fuel transfer. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A diesel fuel spill that is dissipated within a few hours or days would have little or no economic impact, as the spill resp onse would use existing rig and supply vessel facilities, resources, and personnel.



### Impacts of a Large Oil Spill (WCD)

Potential socioeconomic impacts of an oil spill are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD , there are no unique sit e

- specific issues with respect to employment and coastal infrastructure. A large spill could cause economic impacts in several ways: it could result in extensive fishery closures that put fishermen out of work; it could result in temporary employment as p art of the response effort; it could result in adverse publicity that affects employment in coastal recreation and tourism industries; and it could result in anotherMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 64 suspension of OCS drilling activities, including service and support operations that are a n important part of local economies.



### C.8.4 Recreation and Tourism

BOEMRE has reexamined the analys e s for recreation and tourism presented in MMS (2007b, 2008) based on additional information and in consideration of the Macondo oil spill event.
BOEMRE did not find any new information that would alter the potential impact s on recreation and tourism ( BOEMRE, 2011a,b ).

There are no known recreational uses of the lease area. Recreational resources and tourism in coastal areas would not be affected by any routine activities due to the distance from shore. Compliance with BSEE NTL 2012

- G01 should minimize the chance of tr ash or debris being lost overboard from the drilling or construction vessels and subsequ ently washing up on beaches.
A diesel fuel spill in the lease area would be unlikely to affect recreation and tourism because, as explained in Section A.9.2 , it would not be expected to make landfall or reach coastal waters prior to breaking up. Potential impacts for a large oil spill (WCD) are discussed below.



### Impacts of a Large Oil Spill (WCD)

Potential impacts of an oil spill on recreation and tourism are discussed in recent EISs (MMS, 2007b, 2008). For this SDOCD , there are no unique site

- specific issues with respect to these impacts.

Impacts on recreation and tourism would vary depending on the duration of the spill and its fate including the effectiveness of resp onse measures. A large spill that reached coastal waters and shorelines could adversely affect recreation and tourism by contaminating beaches and wetlands, resulting in negative publicity that encourages people to stay away. Based on the revised OSRA mo deling (BOEMRE, 2011a) as summarized in Section A.9.3 ( Table 4 ), there is a
17 % probability in winter of oil from a spill in the lease area reaching shorelines in Texas within 120 days and a 14 % chance in spring of contacting shorelines in Louisiana within 120 days.



### C.8.5 Land Use

Land use along the northern Gulf Coast is discussed in recent lease sale EISs (MMS, 2007b, 2008). The project will use existing onshore support facilities in Louisiana and Alabama. The land use at the existing shorebases is indu strial. The project will not involve any new construction or changes to existing land use. Levels of boat and helicopter traffic will not have any effect on existing land uses, and the additional demands for goods and services resulting from this project will not require any expansion of the existing shorebase facilities. IPFs from onshore waste disposal include loss, escape, or mismanagement of waste at a shore base facility and potential ground water impacts from onshore waste management or disposal fa cilities.

BP will operate in accordance with regulations to avoid accidental loss of solid waste items by maintaining waste management plans, records of all trash transferred to shore i n accordance with BSEE NTL 2012

- G01

. Facilities that accept OCS

- generated waste such as municipal waste landfills and hazardous
waste treatment, storage, and disposal facilities, are diverse and manage waste for the broad range of industry and governmental facilities

. Section 6 of the SDOCD provides a list of
BP approved vendor sites. BP conducts routine independent audits of their approvedMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 65 commercial waste disposal facilities to review their waste management practices, permitting, and compliance history.

The activit ies proposed in this proj ect will not generate a large waste stream into these facilities and are not expected to affect the overall capacity of the se facilities

. The c apacity of the existing industrial waste management facilities is abundant, and there are no commonly accepted or recognized problems in terms of limited capacity, high

- capacity utilizations, or significant constraints in storing waste from oil and gas facilities, now or in the foreseeable future ( MMS, 2007). Additional research con ducted by BOEMRE (2011a) further supports past conclusions that existing onshore waste disposal infrastructure is adequate to support both existing and projected offshore oil and gas drilling and production needs (Dismukes et al., 2007).

A large oil spill (WCD) is the only relevant accident IPF. A diesel fuel spill would not have any impacts on land use, as the response would be staged out of existing shorebases and facilities.



### Impacts of a Large Oil Spill (WCD)

The initial response for a large oil spill w ould be staged out of existing facilities, with no effect on land use. A large spill would have limited temporary impacts on land use along the coast if additional staging areas were needed. For example, d uring the Macondo spill, temporary staging areas were established in Louisiana, Mississippi, Alabama, and Florida for spill response and cleanup efforts. In the event of a large spill in the lease area, similar temporary staging

areas would be needed. These areas would eventually return to their origin al use as the response is demobilized.

A large oil spill would generate a great deal of oily waste such as sorbent material, booms, etc. which would ultimately have to be disposed of onshore at approved disposal sites.



### C.8.6 Other Marine Uses

The lease are a is not located within any USCG

- designated fairway or shipping lane. The lease area is not within a Military Warning Area. There are no other known marine uses of the lease

area.

There are no IPFs from routine project activities that are likely to affec t other marine uses of the lease area. A large oil spill (WCD ) is the only relevant accident IPF. A small fuel spill would not have any impacts on other marine uses because spill response activities would be mainly within the lease area and the duration would be brief.



### Impacts of a Large Oil Spill (WCD)

An accidental spill would be unlikely to significantly affect shipping or other marine uses. The block s are not located within any USCG

- designated fairway or shipping lane. In the event of a large spill requiring numerous response vessels, coordination would be required to manage the vessel traffic for safe operations.

In the event of a large spill requiring numerous vessels in the area, coordination would be required to ensure that no anchoring or seaflo or

- disturbing activities occur near the existing pipelines and flowlines.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 66 

## D. Environmental Hazards

D.1 Geologic Hazards

Based on the geohazards assessments by FMMG (1994) and site clearance letters by BP GoM Resources (2011) as summarized in SDOCD Sectio n 4 , the lease area is free of any sign ificant geological hazards and is suitable for the proposed activities.



## D.2 Severe Weather

Under most circumstances, weather is not expected to have any effect on the proposed activities. Extreme weather, including high winds, strong currents, and large waves, was considered in the design criteria for the drilling vessel. High winds and limited visibility during a severe storm could disrupt support activities (vessel and helicopter traffic) and make it necessary to suspend some activities on the drilling vessel for safety reasons until the storm or weather event passes. In the event of a hurricane, procedures as outlined in the Hurricane Evacuation Plan would be adhered to.



## D.3 Currents and Waves

Metocean conditions such as sea states, wind speed, ocean currents, etc., will be continuously monitored. Under most circumstances, physical oceanographic conditions are not expected to have any effect on the proposed activities. Strong currents (e.g., caused by Loop Curre nt eddies and intrusions) and large waves were considered in the design criteria for the drilling vessel. High waves during a severe storm could disrupt support activities (i.e., vessel and helicopter traffic) and make it necessary to suspend some activit ies on the drilling vessel for safety reasons until the storm or weather event passes.



## E. Alternatives

The Na Kika field development plan was originally approved in May 2002 . At that time a number of different design, installation, and development alter natives were considered. Design safety, which includes environmental risks, was a key factor for evaluating options and determining the optimal design. The activities addressed within this SDOCD are based on the original design philosophy that was previo usly established and approved by BOEMRE. This supplement includes only minor changes and additions to locations and equipment within the existing field. The changes and additions are described in Section 2

, Plan Contents , of the SDOCD. No significant di fferent development alternatives were considered for this SDOCD.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 67 

## F. Mitigation Measures

The proposed action includes several mitigation measures required by regulations and BOEM lease stipulations and NTLs. The project will comply with applicable Federal, State, and local requirements concerning air pollutant emissions, discharges to water, and solid waste disposal.
P roject activities will be conducted under BP’s OSRP and will include the measures described in
SDOCD Section 10

.
Additional mitigati on measures proposed for this project include the following:

Energy Efficiency

• A power management plan to control engine loads and minimize energy usage will be in place.

Air Emissions and Land Disposal Minimization

• Low sulfur fuel will be used; and

• A wast e management plan has been developed for BP drilling waste that addresses minimization options to recycle and source reduce waste.

Water Quality Optimization

• Water treatment equipment will be properly operated and maintained in accordance with
NPDES discharge requirements;

• Best management practice ( BMP ) plans will be followed to prevent the release of maintenance waste to the best extent practicable for painting and rig maintenance; and

• Use of environmentally

- friendly “Green” products whenever feasibl e

.



## G. Consultation

No persons or agencies were consulted during the preparation of this EIA.



## H. Preparers

The EIA was prepared by CSA International, Inc. Contributors included

• M. John Thompson (Senior Scientist/Project Manager);

• Neal Phillips, Ph.D. ( Senior Scientist);

• Luis Lagera, Ph.D. (Senior Scientist);

• Keith VanGraafeiland (GIS/Remote Sensing Specialist);

• Kris L. Metzger (Library and Information Services Director); and

• Danielle Johnson (Technical Editor).Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 68 

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M igratory Species Fishery Management Plan Essential Fish Habitat. Highly Migratory Species Management Division, Office of Sustainable Fisheries, Silver Spring, MD. June 2009. http://www.nmfs.noaa.gov/sfa/hms/EFH/Final/FEIS_Amendment_Total.pdf National Marine Fisheries Service (NMFS). 2010 a. Final Recovery Plan for the Sperm Whale ( Physeter macrocephalus ). http://www.nmfs.noaa.gov/pr/pdfs/recovery/final_sperm_whale_recovery_plan_21dec.pdf National Marine Fisheries Service (NMFS). 2010b. Gulf sturgeon ( Acipenser oxyrinchus desotoi ). http://www.nmfs.noaa.gov/pr/species/fish/gulfsturgeon.htm National Marine Fisheries Service (NMFS). 2010 c . Sea turtles, dolphins, and whales and the Gulf of Mex ico oil spill. http://www.nmfs.noaa.gov/pr/health/oilspill.htm National Marine Fisheries Service (NMFS). 2010 d

. Deepwater Horizon/BP oil spill: size and percent coverage of fishing area closu res due to BP oil spill. http://sero.nmfs.noaa.gov/ClosureSizeandPercentCoverage.htm National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (USFWS), and SEMARNAT. 2010.
Bi National Recovery Plan for the Kemp‘s Ridley Sea Turtle (Lepidochelys kempii), Second Revision. National Marine Fisheries Service. Silver Spring, Maryland. http://www.fws.gov/kemp sridley/pdfs/DraftKRRP.pdf National Oceanic and Atmospheric Administration (NOAA). 2006. Fact Sheet: Small Diesel Spills (500

- 5,000 gallons). NOAA Scientific Support Team, Hazardous Materials Response and Assessment Division, National Oceanic and Atmosp heric Administration. Seattle, Washington. 2 pp. National Park Service (NPS). 2010. Breton Wilderness 300 km Radius. http://www.fws.gov/refuges/AirQuality/docs/Breton_WA300km. pdf National Research Council (NRC). 2003. Oil in the Sea III: Inputs, Fates, and Effects. National Academies Press, Washington, DC. 182 pp. + app.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 73 Nederlandse Aardolie Maatschappij. 2007. Green light to birds: Investigation into the effect of bird

- f riendly lighting. Nederlandse Aardolie Maatschappij, Assen, The Netherlands. Neff, J.M., S. McKelvie, and R.C. Ayers, Jr. 2000. Environmental impacts of synthetic based drilling fluids. Prepared by Robert Ayers & Associates, Inc. U.S. Department of th e Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000

- 064. 118 pp. Neff, J.M., A.D. Hart, J.P. Ray, J.M. Limia, and T.W. Purcell. 2005. An assessment of seabed impacts of synthetic

- based drilling

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- 9 March 2005, Galveston, Texas, USA. SPE 94086. Nelson, H.F. and E.E. Bray. 1970. Stratigraphy and History of the Holocene Sediments in the Sabine

- Hig h Island Area, Gulf of Mexico. In: Morgam, J.P. (ed.) Deltaic Sedimentation; Modern a nd Ancient. Special Publn.
No. 15. Tulsa, OK: SEPM. Nowlin, W.D., Jr., A.E. Jochens, S.F. DiMarco, R.O. Reid, and M.K. Howard. 2001. Deepwater Physical Oceanography R eanalysis and Synthesis of Historical Data: Synthesis Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2001

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528 pp. Operational Science Advisory Team (OSAT). 2010. Sum mary report for sub

- surface and sub sea oil and dispersant detection: Sampling and monitoring. Prepared for Paul F. Zukunft, U.S. Coast Guard Federal On Scene Coordinator, Deepwater Horizon MC252. December 17, 2010. http://www.restorethegulf.gov/sites/default/files/documents/pdf/OSAT_Report_FINAL_17DEC.pdf Peake, D.E. 1996. Bird surveys, pp. 271

- 304. In: R.W. Dav is and G.S. Fargion (eds.), Distribution and abundance of cetaceans in the north central and western Gulf of Mexico, Final report. Volume II: Technical report. Prepared by the Texas Institute of Oceanography and the National Marine Fisheries Service. U. S. Department of the Interior, Minerals Management Service, Gulf of Mexico OCS Region Office, New Orleans, LA. OCS Study
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- wing airplane versus helicopter surveys of manatees. Mar. Mamm. Sci. 4(1):71

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- 3):1,099

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- 176. Richards, W.J., M.F. McGowan, T. Leming, J.T. Lamkin, and S. Kelley. 199 3. Larval fish assemblages at the Loop Current boundary in the Gulf of Mexico. Bull. Mar. Sci. 53(2):475

- 537. Richardson, W.J., C.R. Greene, Jr., C.I. Malme, and D.H. Thomson. 1995. Marine Mammals and Noise. Academic Press, San Diego. 576 pp. Rodgers , J., Jr. and S. Schwikert. 2002. Buffer Zone Distances to Protect Foraging and Loafing Waterbirds from Disturbances by Personal Watercraft and Outboard

- Powered Boats. Conservation Biology 16:216

- 224. Rowe, G.T. and M.C. Kennicutt II. 2009. Northern G ulf of Mexico Continental Slope Habitats and Benthic Ecology Study. Final Report. U.S. Department of the Interior, Minerals Managem ent Service, Gulf of Mexico
OCS Region, New Orleans, LA. OCS Study MMS 2009

- 039. 456 pp. Russell, R.W. 2005. Interactio ns between migrating birds and offshore oil and gas platforms in the northern Gulf of Mexico: Final Report. U.S. Department of the Interior, Minerals Management Service, Gulf of Mexico
OCS Region, New Orleans, LA. OCS Study MMS 2005

- 009. 348 pp.Mississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 74 Ryerson , T.B., R. Camilli, J.D. Kessler, E.B. Kujawinski, C.M. Reddy, D. Valentine, E. Atlas, D.R. Blake, J. de Gouw,
S. Mein ardi, D.D. Parrish, J. Peischl, J. S. Seewald, and C. Warneke. 2012. Chemical data quantify Deepwater Horizon hydrocarbon flow rate and e nvironmental distribution. Proceedings of the National Academy of
Sciences. doi/10.1073/pnas.1110564109

. Salmon, M. and J. Wyneken. 1990. Do swimming loggerhead sea turtles ( Caretta caretta ) use light cues for offshore orientation? Mar. Freshw. Behav. Phy. 17(4): 233

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- season

- statistics/ Smultea, M.A., J.R. Mobley, Jr., D. Fertl, and G.L. Fulling. 2008. An unusual reaction and other observations of sperm whales near fixed wing aircraft. Gulf Carib. Res. 20:75

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- Spill.pdf Southall, B.L., A.E. Bowles, W.T. Ellison, J.J. Finneran, R.L. Gentry, C.R. Greene, D. Kastak, D .R. Ketten, J.H. Miller, P.E. Nachtigall, W.J. Richardson, J.A. Thomas, and P.L. Tyack. 2007. Marine Mammal Noise Exposure Criteria: Initial Scientific Recommendations . Aquatic mammals 33(4): Special Issue. 497 pp. + apps. Sulak, K.J. and J.P. Clugston. 1998. Early life history stages of Gulf s turgeon in the S uwannee River, Florida.
Trans. Am. Fish. Soc. 127:758

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- 316. U.S. Environmental Protection Agency (USEPA). 2011. The green book nonattainment areas for criteria pollutants.

U.S. Fish and Wildlife Service (USFWS). 2001. Florida manatee recovery plan ( Trichechus manatus latirostris ), Third Revision. U.S. Fish and Wildlife Service, Southeast Region, Atlanta, GA. http://www.epa.gov/air/oaqps/greenbk/

U.S. Fish and Wildlife Service (USFWS). 2003. Recovery plan for the Great Lakes Piping Plover ( Charadrius

me lodus ). Fort Snelling, Minnesota. September 2003. U.S. Fish and Wildlife Service (USFWS). 2007. International Recovery Plan: Whooping Crane ( Grus americana ), Third Revision. Albuquerque, New Mexico. March 2007. U.S. Fish and Wildlife Service (USFWS). 2010a. All about piping plovers. http://www.fws.gov/plover/facts.html U.S. Fish and Wildlife Service (USFWS). 2010b. FWS Deepwater Horizon oil spill response. http://www.fws.gov/home/dhoilspill/pdfs/DHBirdsOfTheGulf.pdf U.S. Fish and Wildlife Service (USFWS). 2010c. Species information, threatened and endangered animals and plants. http://www.fws.gov/endangered/ U.S. Fish and Wildlife Service (USFWS). 2010d. Weekly bird impact data and consolidated wildlife reports. http://www.fws.gov/home/dhoilspill/collec tionreports.html U.S. Fish and Wildlife Service (USFWS). 2010 e . Effects of oil on wildlife and habitat. http://www.fws.gov/home/dhoilspill/pdfs/DHJICFWSOilImpa ctsWildlifeFactSheet.pdf U.S. Fish and Wildlife Service (USFWS) and Gulf States Marine Fisheries Commission. 1995. Gulf Sturgeon Recovery Plan. Atlanta, Georgia. 170 pp. http:// www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_gulf.pdf U.S. Geological Survey. 2011. Cold

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- starts microbial response to a deep oil spill.
Science 330: 208

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– 2009. NOAA Technical Memo. NMFS NE 213. 528 pp. Wei, C

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- sea macrobenthos in the northern Gulf of Mexico. M.S. thesis, Texas A&M University. http://repository.tam u.edu/handle/1969.1/4927 Whooping Crane Eastern Partnership. 2010. About whooping cranes and their recovery. http://www.bringbackthecranes.org/recovery/index.htmlMississippi Canyon Block 383 January 2012 Environmental Impact Analys is for SDOCD Page 75 Wiese, F.K., W.A. Mont evecchi, G.K. Davoren, F. Huettmann, A.W. Diamond, and J. Linke. 2001. Seabirds at risk around offshore oil platforms in the north west Atlantic. Mar. Poll. Bull. 42(12):1,285

- 1,290. Wilson, J. 2003. Manatees in Louisiana. Louisiana Conservationist. July/August 2003, pp. 4

- 7. http://www.lamer.lsu.edu/classroom/manatee/pdf/Manatees_LA.pdf Witherington, B.E. 1997. The problem of photopollution for sea turtles and other noctu rnal animals, pp. 303

- 328. In: J.R. Clemmons and R. Buchholz (eds.), Behavioral Approaches to Conservation in the Wild. Cambridge University Press, Cambridge, England. Würsig, B., S.K. Lynn, T.A. Jefferson, and K.D. Mullin. 1998. Behaviour of cetaceans in the northern Gulf of Mexico relative to survey ships and aircraft. Aquat. Mamm. 24: 41

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### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 35 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix G: Waste and Discharge Tablesplease specify if the amount reported is a total or per well amountKepler - SS Well K-4Projected generated waste Projected ocean dischargesType of Waste Composition Projected Amount Discharge rate Discharge Method Answer yes or noWill drilling occur ? If yes, you should list muds and cuttingsEXAMPLE: Cuttings wetted with syntheticbased fluidCuttings generated while using syntheticbased drilling fluid.X bbl/well X bbl/hr/welldischarge overboard NoWater Based FluidSpent drilling fluid drilling riserless holeplus pad mud to fill the hole48,000 bbl/well 18.7 bbl/hr/well Ocean seafloor discharge NoCuttings wetted with Water Based Fluid Water base interval 4,828 bbl/well 1.88 bbl/hr/well Ocean seafloor discharge NoExcess Cement SlurryExcess mixed cement, including additives& waste from equipment wash down aftera cement operation118 bbl/well 0.05 bbl/hr/well Ocean discharge NoCuttings wetted with Synthetic Based FluidDrill cuttings, cement cuttings, & syntheticbase mud retained on cuttings3,756 bbl/well 1.46 bbl/hr/well Ocean discharge NoSmall Volume Drilling Fluid Dischargesassociated with CuttingsDisplaced interfaces, accumulated solidsin sand traps, pit clean-out solids, ¢rifuge discharges made whilechangingthe mud weight85 bbl/well 0.03 bbl/hr/well Ocean discharge NoCement transfer losses Bulk transfer between vessels 146 bbl/well 0.06 bbl/hr/well Ocean discharge NoBarite transfer losses Bulk transfer between vessels 82 bbl/well 0.03 bbl/hr/well Ocean discharge NoWill humans be there? If yes, expect conventional wasteEXAMPLE: Sanitary waste water Sanitary waste from living quartersX bbl/well X bbl/hr/wellchlorinate and dischargeoverboardNoDomestic Waste Food waste 72,679 bbl/well 24.62 bbl/hr/well Ocean discharge NoSanitary WasteTreated human body waste dischargedfrom toilets & urinals21,086 bbl/well 4.08 bbl/hr/well Ocean discharge NoGray WaterDrainage from dishwasher, shower,laundry, bath, & washbasin drains38,209 bbl/well 14.88 bbl/hr/well Ocean discharge NoIs there a deck? If yes, there will be Deck DrainageDeck Drainage Deck washdown & rain water 31,715 bbl/well 11.0 bbl/hr/well Ocean discharge NoWill you conduct well treatment, completion, or workover?Well Treatment FluidsStimulations fluids including acids,solvents & propping agents3,200 bbl/well 1.25 bbl/hr/well Ocean discharge NoCompletion FluidsSalt solutions, weighted brines, polymers& various additives2,200 bbl/well 0.86 bbl/hr/well Ocean discharge NoWorkover FluidsSalt solutions, weighted brines, polymers,& other specialty additives400 bbl/well 0.16 bbl/hr/well Ocean discharge NoMiscellaneous discharges. If yes, only fill in those associated with your activity.Desalinization Unit DischargeWastewater associated with the process ofcreating freshwater from seawater71,691 bbl/well 13.88 bbl/hr/well Ocean discharge NoBlowout Preventer FluidFluid used to actuate the hydraulicequipment on the BOP254 bbl/well 0.10 bbl/hr/well Ocean discharge NoUncontaminated Ballast WaterUncontaminated seawater added orremoved to maintain proper draft3,713,897 bbl/well 1,258 bbl/hr/well Ocean discharge NoUncontaminated Bilge Water Water that collects in the vessels bilge92,777 bbl/well 31.43 bbl/hr/wellOcean discharge NoCement discharged at seafloor Excess mixed cement slurry 594 bbl/well 0.23 bbl/hr/well Ocean seafloor discharge NoFire & Utility WaterUncontaminated seawater/freshwater usedfor fire control or utility purposes2,783,314 bbl/well 538.78 bbl/hr/well Ocean discharge NoCoolingWaterUncontaminated seawater96,150,857 bbl/well 18,612 bbl/hr/wellOcean discharge NoTABLE 1. WASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE ORDISCHARGE TO THE GOMProjectedDownholeDisposalRev: 5/10/2012please specify if the amount reported is a total or per well amountKepler - SS Well K-4Projected generated waste Projected ocean dischargesType of Waste Composition Projected Amount Discharge rate Discharge Method Answer yes or noTABLE 1. WASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE ORDISCHARGE TO THE GOMProjectedDownholeDisposalNABiocide, corrosion inhibitors, or otherchemicals used to prevent corrosion orfouling of piping or equipmentNA NA N/A NASub Sea Fluid DischargesWellhead Preservation, Hydrate Control,Umbilical Steel Tube Storage, LeakTracer, & Riser Tensioner Fluids168 bbl/well 0.065 bbl/hr/well Ocean seafloor discharge NoWill you produce hydrocarbons? If yes fill in for produced water.NAWater brought up from hydrocarbonbearing strata during extraction of oil & gasNA NA NANoNoWill you be covered by an individual or general NPDES permit ?General Permit GMG290110 GMG290110NOTE: If you will not have a type of waste, enter NA in the row.Rev.2: 5-9-2012Rev: 5/10/2012please specify whether the amount reported is a total or per welKepler - SS Well K-4Projectedgenerated wasteSolid and Liquid WastestransportationType of Waste Composition Transport MethodName/Location ofFacility Amount Disposal MethodWill drilling occur ? If yes, fill in the muds and cuttings.EXAMPLE: Synthetic-based drilling fluid ormudinternal olefin, esterBelow deck storage tanks on offshoresupport vesselsNewport EnvironmentalServices Inc., Ingleside,TXX bbl/well RecycledSynthetic-based drilling fluid Synthetic-based drilling fluidLiquid mud storage on workboatBaroid / MI SwacoFouchon LA3,940 bbls/well ReuseContaminated Synthetic base mudContaminated Synthetic basemudBarged in (15 or 25 barrel cuttingboxes)Newpark EnvironmentalServices, Fourchon LA180 bbls/well Deepwell injection on landDrilling mud contaminated absorbentsAbsorbent padscontaminated with drillingmuds Barged in (Omega 2 yard boxes)Omega WasteManagement,Patterson, LA0.6 tons/well RecycleExcess bariteExcess barite from vesseltank cleaningTransported by vehicle (supersacks)Francis Drilling Mud orRiver Birch landfill3 tons/well Reuse / LandfillExcess cementExcess cement from vesseltank cleaningTransported by vehicle (supersacks)Grand Isle PortCommission or River3 tons/well Reuse / LandfillWashwaterWashwater from boat tankcleaningTransported in (15 barrel cuttings boxes)Newpark EnvironmentalServices, Fourchon LA120 bbls/well Deepwell injection on landWell Related Hazardous WasteRig lab titrations containingisopropanol alcohol, silverBarged in (5 gallon DOT containers)Chemical WasteManagement, Sulphur,3 m3/well Incineration / LandfillRig Maintenance Wastes (painting, blasting)Paint thinner, paint chips,blast media, aerosol cans Barged in (drums or totes)L&L Oil and GasServices Fourchon, LA3,940 lb3/well Incineration / LandfillRig Maintenance Wastes (non hazardous) Oily rags, pads, oil filters etc. Barged in (totes)L&L Oil and GasServices Fourchon, LA45 ft3/well RecycleRig Used oil Lube oil, hydraulic oil, glycol Barged in (drums)L&L Oil and GasServices Fourchon, LA103 m3/well RecycleDomestic wasteMunicipal trashBarged in (supersacks)River Birch Landfill,Avondale, LA18 tons/well LandfillScrap Metalscrap piping, grating andother metalsBarged in (scrap baskets)Southern Scrap. LA7 tons/well RecycleUniversal Waste Batteries Barged in (DOT drums)L&L Oil and GasServices Fourchon, LA3 lb3/well RecycleUniversal Waste Fluorescent light bulbs Barged in (DOT drums)L&L Oil and GasServices Fourchon, LA3 lb3/well RecycleMisc. unused chemical Pills, spacers, additives etc. Barged in (totes)River Birch Landfill,Avondale, LA6 bbls/well Recycle or landfillRig Drilling washwater Cleaning out of mud tanksBarged in (15 or 25 barrel cuttingboxes)Newpark EnvironmentalServices, Fourchon LA120 bbls/well Deepwell injection on landCompletion FluidsUsed completion fluidsBarged in (15 or 25 barrel cuttingboxes)Newpark EnvironmentalServices, Fourchon LA390 bbls/well Deepwell injection on landWaste DisposalTABLE 2. WASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHORERev: 5/10/2012please specify whether the amount reported is a total or per welKepler - SS Well K-4Projectedgenerated wasteSolid and Liquid WastestransportationType of Waste Composition Transport MethodName/Location ofFacility Amount Disposal MethodWaste DisposalTABLE 2. WASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHOREWill you produce hydrocarbons? If yes fill in for produced sand.EXAMPLE: trash and debris (recylables) Plastic, paper, aluminum barged in a storage binARC, New Iberia, LAXlb/well RecycledNOTE: If you will not have a type of waste, enter NA in the row.Will you have additional wastes that are not permitted for discharge? If yes,fill in the appropriate rows.Rev: 5/10/2012

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 36 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix H: Air Emissions InformationDOCD AIR QUALITY SCREENING CHECKLISTOMB Control No. 1010-0151OMB Approval Expires: 12/31/2014COMPANYBPAREAMississippi CanyonBLOCKPlan and Complex Total Emissions- MC383LEASEOCS-G 07937PLATFORMSubsea TiebackWELLK4COMPANY CONTACTJim Pfeiffer (Air Quality) / Teri Halverson (Plans)TELEPHONE NO.281-366-1542 (Jim) / 281-366-6292 (Teri)REMARKSDrill, complete, install pipeline, install subsea equipment, produceLEASE TERM PIPELINE CONSTRUCTION INFORMATION:YEAR NUMBER OF TOTAL NUMBER OF CONSTRUCTION DAYSPIPELINES2012 1 112013201420152016201720182019202020212022FORM BOEM-0139(December 2011 - Supersedes all previous versions of this form which may not be used).Page 1 of 4AIR EMISSIONS COMPUTATION FACTORSFuel Usage Conversion FactorsNatural Gas Turbines Natural Gas Engines Diesel Recip. Engine REF. DATESCF/hp-hr 9.524 SCF/hp-hr 7.143 GAL/hp-hr 0.0483AP42 3.2-1 4/76 & 8/84Equipment/Emission Factorsunits PM SOx NOx VOC CO REF. DATENG Turbines gms/hp-hr 0.00247 1.3 0.01 0.83AP42 3.2-1& 3.1-1 10/96NG 2-cycle lean gms/hp-hr 0.00185 10.9 0.43 1.5AP42 3.2-1 10/96NG 4-cycle lean gms/hp-hr 0.00185 11.8 0.72 1.6AP42 3.2-1 10/96NG 4-cycle rich gms/hp-hr 0.00185 10 0.14 8.6AP42 3.2-1 10/96Diesel Recip. < 600 hp. gms/hp-hr 1 1.468 14 1.12 3.03AP42 3.3-1 10/96Diesel Recip. > 600 hp. gms/hp-hr 0.32 1.468 11 0.33 2.4AP42 3.4-1 10/96Diesel Boiler lbs/bbl 0.084 2.42 0.84 0.008 0.21AP42 1.3-12,14 9/98NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84P42 1.4-1, 14-2, & 147/98NG Flares lbs/mmscf 0.593 71.4 60.3 388.5AP42 11.5-1 9/91Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21AP42 1.3-1 & 1.3-3 9/98Tank Vapors lbs/bbl 0.03E&P Forum 1/93Fugitives lbs/hr/comp. 0.0005API Study 12/93Glycol Dehydrator Vent lbs/mmscf 6.6La. DEQ 1991Gas Venting lbs/scf 0.0034Sulphur Content Source Value UnitsFuel Gas 3.33 ppmDiesel Fuel 0.4 % weightProduced Gas( Flares) 3.33 ppmProduced Oil (Liquid Flaring) 1 % weightFORM BOEM-0139(December 2011 - Supersedes all previous versions of this form which may not be used).Page 2 of 4AIR EMISSIONS CALCULATIONS - FIRST YEARCOMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKSBP Mississippi Canyon Plan and Comp OCS-G 07937 Subsea Tieback K4 Jim Pfeiffer (Air Quality) / Teri H 281-366-1542 (JDrill, complete, install pipeline, install subsea equipment, produceOPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR ESTIMATED TONSDiesel Engines HP GAL/HR GAL/DNat. Gas Engines HP SCF/HR SCF/DBurners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM SOx NOx VOC CODrill: MODU Drillship TBDDrillship main engines PRIME MOVER>600hp diesel 61800 2984.94 71638.56 24 70 43.56 199.83 1497.36 44.92 326.70 36.59 167.86 1257.78 37.73 274.42Fast Supply Vessel/Crew Boat VESSELS>600hp diesel(crew) 7200 347.76 8346.24 6 18 5.07 23.28 174.45 5.23 38.06 0.27 1.26 9.42 0.28 2.06Offshore Supply Vessel #1 VESSELS>600hp diesel(support) 7200 347.76 8346.24 24 18 5.07 23.28 174.45 5.23 38.06 1.10 5.03 37.68 1.13 8.22Offshore Supply Vessel #2 VESSELS>600hp diesel(support) 7200 347.76 8346.24 24 18 5.07 23.28 174.45 5.23 38.06 1.10 5.03 37.68 1.13 8.22Offshore Supply Vessel #3 VESSELS>600hp diesel(support) 7200 347.76 8346.24 24 18 5.07 23.28 174.45 5.23 38.06 1.10 5.03 37.68 1.13 8.22PIPELINE INSTALLATION:Skandi Neptune VESSELS>600hp diesel (multi-ser13685 660.9855 15863.65 24 11 9.65 44.25 331.57 9.95 72.34 1.27 5.84 43.77 1.31 9.552012 YEAR TOTAL73.50 337.20 2526.73 75.80 551.29 41.43 190.04 1424.01 42.72 310.69EXEMPTION CALCULATIONDISTANCE FROM LAND INMILES1631.70 1631.70 1631.70 1631.70 45527.7649.0FORM BOEM-0139(December 2011 - Supersedes all previous versions of this form which may not be used).Page 3 of 4AIR EMISSIONS CALCULATIONSCOMPANY AREA BLOCK LEASE PLATFORM WELLBP Mississippi Canyon Plan and Complex TotaOCS-G 07937 Subsea Tieback K4Emitted SubstanceYearPM SOx NOx VOC CO2012 41.43 190.04 1424.01 42.72 310.692013 41.43 190.04 1424.01 42.72 310.692014 41.43 190.04 1424.01 42.72 310.692015 41.43 190.04 1424.01 42.72 310.692016 41.43 190.04 1424.01 42.72 310.692017 41.43 190.04 1424.01 42.72 310.692018 41.43 190.04 1424.01 42.72 310.692019 0.00 0.00 0.00 0.00 0.002020 0.00 0.00 0.00 0.00 0.002021 0.00 0.00 0.00 0.00 0.00Allowable1631.70 1631.70 1631.70 1631.70 45527.76FORM BOEM-0139(December 2011 - Supersedes all previous versions of this form which may not be used).Page 4 of 4

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 37 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix I: Oil Spill Response Discussion

### KEPLER MC 383
Worst Case Discharge scenario for Kepler, MC 383

1) Worst Case Summary

BP has estimated its worst case scenario for discharge from a mobile drilling rig operation that may occur from Kepler. Given the anticipated reservoir thickness and historical productivity index the worst case discharge is estimated to be 20,000 barrels of crude oil per day. Calculations are based on formulas defined by BSEE regulations.

2) Facility Information

 Type of Operation: Development

 Facility Name: Kepler

 Area and Block: MC 383

 Latitude: 28° 35’ 52.255”

 Longitude: -88° 26’ 08.518”

 Distance to Shore: 49 miles

 Water Depth: 5,741 feet

 API Gravity: 24.2°

 Oil Storage Volume: 0 barrels

3) Worst Case Discharge Volume

Criteria Barrels Estimated highest capacity well uncontrolled blowout volume associated with exploration well (barrels per day) 20,000

TOTAL WORST CASE DISCHARGE (barrels per day) 20,000

4) Land Segment Identification

In compliance with NTL 2006-G21, BP has determined the land areas that could be potentially impacted by a potential MC 383 oil spill using the BSEE Oil Spill Risk Analysis Model (OSRAM) trajectory results. The OSRAM estimates the probability that oil spills from designated locations would contact shoreline and offshore natural resources. (Whether and where a particular spill would reach shore is dependent on various factors, such as weather, currents and product characteristics and, as a result, actual oil movement in the event of a spill may vary from the OSRAM results.) These probabilities are intended to indicate, in terms of percentage, the computed likelihood that an oil spill occurring in a particular launch area will contact a certain county or parish within 3, 10, and 30 days.

OCS Launch Block #57 was utilized as Kepler’s point of origin. Land segments identified by the model are listed below (referenced from “Oil-Spill Risk Analysis: Contingency Planning Statistics for Gulf of Mexico OCS Activities” – OCS Report MMS 2004-026):



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### KEPLER MC 383

Area and Spill Site Land Segment Contact Percent Impact Chance (Days) Land Segment No. & County/ Parish & State 3 10 30
Cameron, LA -- -- 1 Vermilion, LA -- -- 1 Terrebonne, LA -- 1 3 Lafourche, LA -- 1 2 Plaquemine, LA 4 14 21 St Bernard, LA -- 1 3 Hancock & Harrison MS -- -- 1 Jackson, MS -- -- 1 Mobile, AL -- -- 1 Baldwin, AL -- -- 1 Escambia, FL -- -- 1 Okaloosa, FL -- -- 1 Walton, FL -- -- 1 

## Mississippi

Canyon 383

Bay, FL -- -- 1

5) Resource Identification

The land segment that has the highest comput ed probability of being impacted by a release from MC 383 within 30 days is Plaquemine Parish, Louisiana, at 21 percent. Sources which may be used to identify the sensitive resources located within Plaquemine Parish are identified in the Regional OSRP, Section 11

. 6) Response

BP GoM has contracted with OSROs as identified in Figure 7-5 of the Regional OSRP. Upon notification of a spill, BP GoM could request a partial or full mobilization of the resources referenced in the attached Appendix E. The Qualified Individual, Incident Commander or his/her designee may contact other service companies if appropriate.

Release Modeling

A portion of the release will either naturally disperse or evaporate. An ASA Spill Impact Model Application Package (SIMAP) analysis (in conjunction with its blowout model) was completed for a deepwater spill of medium crude (with a Gas-to-Oil Ratio [GOR] of 1:1) release from 5,000 feet below the surface. The SIMAP model uses environmental data and transport and weathering algorithms to calculate the mass of oil components in various environmental compartments (water surface, shoreline, water column, atmosphere, sediments, etc.), oil pathway over time (trajectory), surface oil distribution, and concentrations of the oil components in the water and sediments. Due to the deepwater nature of the release site in this scenario, the ASA SIMAP model was selected to predict the behavior of a release from MC 383.

Based on the ASA SIMAP analysis, the amounts of the released oil that have dispersed into the water column, evaporated or naturally decayed will leave no more than roughly 50% of the oil present at the surface. Using the results of this model, this would leave an estimated 13,159 barrels per day to be addressed by the response technologies discussed below.



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### KEPLER MC 383

Response Technologies Discussion

This section discusses various response technologies (in no prioritized order) that might be employed during a response to a release of oil from MC 383. The particular response technologies applied during a spill event will be coordinated based on the most accurate and up-to-date knowledge of the situation which will determine the types of technology to be used, the locations at which particular technologies are applied, and the implementation of simultaneous operations (SIMOPS). Currently there is not any new or unusual technology proposed for spill prevention, control, or cleanup.

The status boards below set forth a representative list of equipment and are not meant to be exhaustive. The status boards outline on-water containment; on-water recovery; temporary storage; aerial, vessel and subsea dispersant application; in-situ burning and shoreline protection equipment identified as most relevant in addressing the volume of oil that does not either evaporate or naturally disperse into the water column. These status boards estimate times needed for procurement, load out, travel time to the site and deployment.

The status boards show that upon notification of an incident, dispersant operations can commence within an estimated 4 hours, pending regulatory approval, followed by on-water recovery which can be on site and operational within an estimated 12 hours. According to the status boards, BP can be on site with adequate response capacity to contain and recover surface hydrocarbons, and prevent land impact, to the maximum extent practicable, within an estimated 3 days. Consistent with the maximum extent practicable standard, and given the uncertainties and situation- specific variations associated with a marine oil release, this plan cannot guarantee that BP 's response to oil discharged offshore will in all cases prevent oil from reaching shorelines or impacting resources.

Surveillance

Upon notification of a release and mobilization of the response, either a fixed-wing aircraft or a field-support helicopter would be dispatched as promptly as possible (considering available daylight hours, weather conditions and if other safety factors) in order to conduct visual surveillance at the source of the spill. If nece ssary, visual surveillance could be supplemented through use of field vessels. The effectiveness of many response technologies (such as in-situ burning, dispersant application and mechanical recovery) may be enhanced through collaboration with air-based spotters, who can guide these systems to oil concentrations and coordinate SIMOPS. Air-based spotters may be equipped with air to marine/ground communication equipment to facilitate immediate communications with marine- and land-based response assets. Vessel locations may also be monitored in real-time using vessel-tracking technologies (such as AIS data, GPS-based tracking, cell phone data, etc.), which can facilitate vessels being deployed for optimal recovery. Further information regarding methods of identifying and tracking a spill on water are discussed in Section 10 in the Regional OSRP. Specifically, Figure 10-3 sets forth various oil spill detection systems, remote thickness detection systems, and other remote sensing technologies that could be utilized in a response.

Source Containment/Source Control

Source containment and source control operatio ns would be implemented simultaneously with the above response technologies to either reduce or stop the flow of the well into the environment. Source containment is designed to tem porarily stop or redirect the flow from the well. Source control addresses the original source through either well-kill operations or the drilling of a relief well to permanently stop the flow of oil from the well.



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### KEPLER MC 383

The steps applied to achieve flow containment will be very dependent on the specific characteristics and nature of the spill at hand. This could include multidisciplinary initiatives to recover flow to the surface for contained processing and disposal, efforts to shut-in flow at the source using pressure rated, tight seal fit for purpose assemblies, and techniques to kill (cease pressure source) the well. See Section 6 of the Regional OSRP for a non-exhaustive list of potentially applicable techniques.

Slick (Fresh Oil) Containment Systems

Slick (fresh oil) containment systems may be deployed (provided it is safe to do so) in thick, fresh oil to minimize further spreading of oil on the water’s surface. These systems would typically consist of two offshore vessels (capable of trolling speeds of 0.5 knots) towing between 1,000 to 1,500 feet of offshore boom in a “U” or “V” configuration. The containment systems may allow fresh oil to be contained, concentrated and diverted to both skimming systems and in-situ burn task forces, as appropriate, increasing their encounter rate and containment efficiency in order to support enhanced skimming and burning operations.

Mechanical Recovery

Mechanical recovery equipment, include OSRVs, OSRBs and VOSS may be mobilized from contracted OSROs. As necessary, response equipment could be cascaded from locations along the Gulf of Mexico and other regions of the United States, as well as from international locations. This equipment could be deployed either at the source of the release or in concentrations of recoverable oil. Offshore mechanical recovery assets could be organized according to span of control concepts within ICS. Vessels should be organized into task forces or groups with consideration for effective communication and control. As operations increase in scale or complexity, dedicated command/control vessel(s) may be considered for each major operating area or mission. These vessels could pr ovide response activity coordination of all marine assets under their control, as well as provide communication between marine and air assets. Additionally, other technologies (like GPS-based vessel tracking systems) may be used to facilitate coordination of marine assets. Positioning this equipment can be facilitated by collaboration with air-based spotters, who can guide these systems to oil concentrations. During night-time operations, skimming activities could be facilitated through the use of alternative spill surveillance technologies (suc h as infrared [IR] and X-band radio systems) to guide skimming vessels to sufficient concentrations of oil. The specific technologies used willbe chosen based on availability suitability, OSRO recommendations, and other situationspecific considerations.

The Offshore On-Water Recovery/Storage Equipment status for the MC 383 “Kepler” well. The combined EDRC for dedicated skimming vessel systems is 111,889 barrels; total storage volume for these dedicated systems is 166,100 barrels. (EDRC represents a planning standard mandated by governing regulations [30 CFR § 254.44(a)] and is required to be specified in an OSRP. Actual performance of mechanical recovery systems in responding to an oil spill will depend on many situation-specific factors, such as: oil encounter rates, access to heavy concentrations of fresh oil, oil emulsification, av ailability of vessels of opportunity and others. As a result, oil volumes recovered may be significantly lower than stated EDRC volumes.) Additional response equipment is available from BP GoM’s OSROs; the resources identified in the status boards below represent a “first line of defense” of dedicated oil spill response vessels and barges and select VOSS, identified based on recent response experience. However, a secondary line of defense (primarily VOSS) is available to augment the response if necessary and appropriate under the circumstances, as depicted in the illustration below.



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### KEPLER MC 383

Revised 4/09/12 Dispersant Planning Case

We plan whenever possible to use aerial, vessel based, and/or sub-sea application methodologies. BP’s ability to utilize dispersants in a future response will be dependent upon numerous factors, including government actions needed to authorize and support such dispersant use. Most importantly, regulatory approval, pursuant to applicable regulations, must be obtained. As prefaced in Section 18 of the Regional OSRP, inventories of dispersants available via contract to BP GoM are detailed in Figure 18-2 . These inventories reflect stockpiles as of October 2011. BP has contracts to acquire dispersants and to implement measures to deploy them with the parties listed in Appendix D of the Regional OSRP. In addition to OSRO dispersant stockpiles available to BP GoM, Nalco, the current Corexit 9500 manufacturer, has represented that it anticipates being able to ramp up production within 10 to 14 days. During the recent response, Nalco was able to produce sufficient supplies of dispersants to support the continued dispersant usage. To accomplish this, Nalco sought and received a request from the Unified Area Command for production of the requested volumes of dispersants. Nalco has indicated that, in the event of a future response, it may require a similar request

During the use of dispersants, the Operations and Logistics sections will be tracking daily usage and replenishment rates in order to support dispersant activity for the length of time required to drill a relief well. The use of dispersants can, under the right circumstances, reduce responders’ potential exposure to volatile organi c compounds (VOCs) at the surface, thereby allowing increased levels of vertical access for source control responders.

### KEPLER MC 383

Aerial Dispersant Application

Aerial dispersants may be a response option depending on the circumstances of the release. Aerial dispersants are applied under the direction and approval of a designated FOSC, and in a manner consistent with the National Cont ingency Plan and the applicable Regional Response plan(s) and/or ACPs. Spotter aircraft could be activated along with aerial dispersant aircraft to coordinate more precise dispersant application on concentrations of free floating oil and to ensure that dispersant operations do not impact other ongoing response technologies. The table below identifies aerial dispersant application aircraft to which BP GoM has contractual access, as well as their response capacities. A table listing the dispersant stockpile available to BP GoM may be found in Section 18 of the Regional OSRP.

Aircraft Owner/Contractor Dispersant Capacity Possible Sorties per Day Regional Assets DC-3 ASI (through CGA) 1,200 gallons 1-2 BT-67 (DC-3 Turboprop) ASI (through CGA) 2,000 gallons 1-2

C-130 MSRC 3,250 gallons 1-3 C-130 MSRC 4,000 gallons 1-3 Out-of-Region Assets C-130 CCA 5,000 gallons 1-3 Hercules L382G OSR 5,000 gallons 1-3

For planning purposes, BP GoM assumes a 1:20 application rate and approximately a 50 to 75% effectiveness rate. Based on the estimates regarding aircraft dispersant capacities identified in the table above, 16,450 to 65,800 gallons of dispersant could be applied per day, which translates to approximately 3,917 to 23,500 barrels per day based on the stated application rate and range of estimated effectiveness. It is important to note that studies, laboratory tests, and field tests show a relatively wide range for the optimal application rate and actual effectiveness rate of dispersants applied to spilled oil. These rates may vary depending upon an assortment of situation-specific variables such as water temperature, weather, and timely access to the released oil. Further information regarding dispersant application methods and monitoring may be found in Section 18 of the Regional OSRP.

Vessel-Based Dispersant Application

Vessel-based dispersant application may be another effective response option. In previous responses, boat-spray systems were used for both dispersing oil and suppressing vapors on the water surface near the spill source. Vessel-based dispersants are also applied under the direction and approval of a designated FOSC, and in a manner consistent with the National Contingency Plan and the applicable Regional Response Plan(s) and/or ACPs. If appropriate, vessel spray systems can be installed on offshore vessels of opportunity to apply dispersants at the source or at other areas where there are si gnificant concentrations of oil. Using inductor nozzles installed on fire-water monitors, sk id mounted systems, or purpose-built boom-arm spray systems, vessels can initially apply disper sant beginning in the first 12 to 24 hours of the response, and thereafter as needed. In previous responses, boat-spray systems were used for both dispersing oil and suppressing vapors on the water surface near the spill source.



### Revised 4/09/12

### KEPLER MC 383

Subsea Dispersant Application

Depending on the circumstances, the use of a subsea dispersant application system may provide another response option in the event of a subsurface well blowout or other ongoing subsurface release. A modular Subsea Dispersant Application Unit (SDAU)—including an integrated chemical storage, distribution and depl oyment system—may be installed at the spill site, in close proximity to the release.

The subsea application of dispersants is a new variation on proven dispersant technology. Therefore, certain assumptions, including application rates and effectiveness, have been made based on recent experience. However, additional data collection, laboratory tests, and field tests will likely be conducted by industry, gov ernment, and/or academia, and will help evaluate further the optimal application rates and anticipated effectiveness rates for subsea application of dispersants. For planning purposes, and subject to obtaining regulatory approval, BP GoM assumes a 1:75 application rate, at 50 to 75% effectiveness, and a system flow rate of 8 to 11 gallons per minute (approximately 11,500 to 16,000 gallons of dispersant per day). (During a recent response, the EPA limited sub-surface dispersant usage to 15,000 gallons per day.) Under those assumptions, the system might be capable of dispersing approximately 10,268 to 21,429 barrels of oil per day. A table listing the dispersant stockpile available to BP GoM may be found in Section 18 of the Regional OSRP.

In-Situ Burning Planning Case and Strategy

Open-water in-situ burning (ISB) also may be used as a response strategy depending on the circumstances of the release. ISB services may be provided by the primary OSRO contractors. BP GoM plans, whenever possible, to use ISB as a response methodology. In a recent response, ISB was successfully used to remove oil from the response area. Under some circumstances, open water ISB of oil can be a safe and effective oil removal technique. The effective use of ISB depends on specific operational and environmental conditions, and on the composition and condition of the oil to be burned. In addition, the performance of ISB is subject to government regulation, approval and supe rvision throughout the burning process. The amount of ISB Burn boom available to BP GoM increased substantially from 2010 to 2011 as shown in Section 19a (~35,000’ of fire boom is available through BP’s relationship with OSRO’s) of the Regional OSRP.

Additional ISB systems may be purchased, as pr oduction allows, from specialized fire boom manufacturers. For example, Elastec/American Marine, a widely-known supplier of boom in both the US and internationally, is capable of producing boom at a rate of up to one new system every 3 days, after a 6-8 week initial lead time (to allow procurement of source materials and to dedicate fabrication capabilities). Non-consumable components of the fire boom system may be reused with replacement boom, which could allow faster replenishment of available fire boom systems. During the use of ISB, the Operations and Logistics sections will be tracking daily usage and replenishment rates in order to support ISB activities for the length of time required to drill a relief well, as stated in the organizational roles and responsibilities outlined in Section 4 of the Regional OSRP.

If appropriate conditions exist and approvals are granted, one to multiple ISB task forces could be deployed offshore. Task forces typically consist of two to four fire teams, each with two vessels capable of towing fire boom, guide boom or tow line and equipped with either handheld or aerially-deployed oil ignition systems. At least one support/safety boat would be present during active burning operations to provide logistics, safety and monitoring support. Depending upon a number of factors, including weather conditions and the nature and distribution of oil, up



### Revised 4/09/12

### KEPLER MC 383

Revised 4/09/12 to 4 burns per 12-hour day may be completed per ISB fire team. Depending on weather and fire intensity, most fire boom systems can be used for approximately 8 to 12 burns before being replaced. Although the number of barrels elim inated per bun is dependent on many factors, past experience suggests that a typical burn might eliminate approximately 600 to 750 barrels. Based on these assumptions, a single task force of two fire teams assuming appropriate conditions, including weather and safety—each completing four burns per day—might be capable of removing up to approximately 4,800 to 6,000 barrels of oil per day. (See e.g., August 2010 reports: “Deepwater Horizon MC252 Gulf Incident Oil Budget” and “BP Deepwater Horizon Oil Budget: What Happened to the Oil?”) A dditional information on ISB is presented in Section 19 of the Regional OSRP.

Shoreline Response

While historical trajectory modeling is important for planning response tactics, the potential direction and impact of a spill depends heavily upon existing environmental conditions during an actual response. Strategies developed during tactical planning would be based upon surveillance and real time trajectories that depict areas of potential impact given actual sea and weather conditions. Near shore response may include the deployment of shoreline boom to protect beach areas, or protection and sorbent boom for vegetated areas. The ACP and relevant agencies—including, as appropriate, “branc h offices” similar to those stood in previous responses—can be consulted to ensure that env ironmental, special economic and cultural resources are correctly identified and prioriti zed to ensure optimal protection. If impact does occur, onshore cleanup response may include specialized beach and marsh cleanup.

The status boards listed in the latter part of this section show equipment could be deployed for the protection of these shorelines. From the table labeled, “Sample Shoreline Protection and Wildlife Support List”, it is shown that upon receipt of notification, equipment can be onsite and operational within 12 hours.

The Response Group’s Shoreline Response Guides identify response strategies including equipment and personnel needs, possible tactics, and detailed job descriptions (ICS 204 Field Assignments) applicable for oil spill protection and clean-up operations. The guides are a tool for operational planning and logistics to initiate the procurement and deployment of resources while branch operations are established. Early tactical planning and deployment of advance (forward) teams should be considered to establish locations for branch offices as needed. (For more information on resource identification, see Section 11 of the Regional OSRP; for more information on resource protection methods, see Section 13 ; for more information on mobilization see Section 14

.

### ________________________________________________________________________

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 Authority: Jim Grant Revision: 1 Custodian/Owner: Teri Halverson Issue Date: 3/08/2012

Retention Code: ADM3000 Next Review Date (if applicable): NA
Security Classification: BP Confidential Page: Page 38 of 38
Warning: Check DW Docs revision to ensure you are using the correct revision. 

## Appendix J: Recovery Fee Receipt1 

### Cleland, Betsy

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Region: Gulf of Mexico Contact: Betsy Cleland 281-366-7539 Company Name/No: BP Exploration and Production, 02481 Lease Number(s): 07937, , , , Area-Block: Mississippi Canyon MC, 383: , : , : , : , Type-Wells: Supplemental Plan, 1

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### Cleland, Betsy

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Region: Gulf of Mexico Contact: Betsy Cleland 281-366-7539 Company Name/No: BP Exploration Production, 02481 Lease Number(s): 07937, , , , Area-Block: Mississippi Canyon MC, 383: , : , : , : , Type-Wells: Supplemental Plan, 1

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