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

Site Type/Name Botm Lse/Area/Blk Surface Location Surf Lse/Area/Blk

Description -

Rig Type -

Subject:

From:

July 12, 2012
_______________________________________

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 

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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 

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TABLE OF CONTENTS 

 

1 Plan Contents...............................................................................................6

1.1 History of Lease.............................................................................................6

1.2 Description of Activities .................................................................................6

1.3 Location ....................................................................................................7

1.4 Safety and Pollution Prevention Features ......................................................7

1.5 Storage Tanks and Production Vessels ..........................................................8

1.6 Additional Measures ......................................................................................8

2 General Information ....................................................................................9

2.1 Applications and Permits................................................................................9

2.2 Drilling Fluids..................................................................................................9

2.3 Completion Fluids ..........................................................................................9

2.4 Production ..................................................................................................10

2.5 Oil Characteristics ........................................................................................10

2.6 New or Unusual Technologies .....................................................................10

2.7 Bonding Information ....................................................................................10

2.8 Oil Spill Financial Responsibility ...................................................................10

2.9 Deepwater Well Control Statement.............................................................10

2.10Suspension of Production ............................................................................10

2.11Blowout Scenario.........................................................................................11

2.11.1 Blowout Scenario .........................................................................11

2.11.2 The potential for the well to bridge 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 reduce the likelihood of a blowout.............13

2.11.7 Measures that would enhance our ability to conduct early 

 intervention ..................................................................................13

2.11.8 Other Measures ...........................................................................13

2.11.9 Worst Case Discharge Modeling Report......................................14

3 Geological and Geophysical Information ................................................14

3.1 Geological Description .................................................................................14

3.2 Structure Contour Maps ..............................................................................14

3.3 Interpreted 2-D and / or 3-D Seismic Lines ..................................................14

3.4 Geological Structure Cross-Section Maps....................................................14

3.5 Shallow Hazards Report...............................................................................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 

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3.6 Shallow Hazards Assessment......................................................................14

3.7 High-Resolution Seismic Lines.....................................................................14

4 Hydrogen Sulfide (H2S) Information ........................................................15

4.1 Concentration...............................................................................................15

4.2 Classification................................................................................................15

4.3 H2S Contingency Plan ..................................................................................15

4.4 Modeling Report ..........................................................................................15

5 Mineral Resource Conservation Information ..........................................15

5.1 Technology and Reservoir Engineering Practices and Procedures...............15

5.2 Reservoir Development ...............................................................................15

6 Biological and Physical Information.........................................................16

6.1 Benthic Communities Report.......................................................................16

6.2 Biologically Sensitive Underwater Features and Areas ................................16

6.3 Remotely Operated Vehicle (ROV) Monitoring Survey Plan.........................16

6.4 Threatened or Endangered Species, Critical Habitat, and Marine Mammal 

 Information ..................................................................................................17

6.5 Archaeological Report ..................................................................................17

7 Waste and Discharge Information............................................................17

7.1 Projected Generated Wastes.......................................................................17

7.2 Projected Ocean Discharges........................................................................18

8 Air Emissions Information ........................................................................18

8.1 Screening Questions....................................................................................18

8.2 Emissions Worksheets ................................................................................18

9 Oil Spill Information ..................................................................................19

9.1 Oil Spill Response Planning..........................................................................19

9.1.1 Regional Oil Spill Response Plan (OSRP) Information ....................19

9.1.2 Spill Response Sites.......................................................................20

9.1.3 OSRO Information..........................................................................20

9.1.4 Worst-Case Scenario Determination ..............................................21

9.2 Oil Spill Response Discussion......................................................................22

10 Environmental Monitoring and Mitigation Measures ............................22

10.1 Monitoring Systems...................................................................................22

10.2 Incidental Takes .........................................................................................22

10.3 Flower Garden Banks National Marine Sanctuary......................................23

11 Lease Stipulations .....................................................................................23

11.1 Lease Stipulation Information.....................................................................23

12 Related Facilities and Operations Information........................................23

12.1 Related OCS Facilities and Operations ......................................................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 

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12.2 Transportation System ...............................................................................23

12.3 Produced Liquid Hydrocarbons Transportation Vessels .............................24

13 Support Vessels and Aircraft Information...............................................24

13.1 General ..................................................................................................24

13.2 Diesel Oil Supply Vessels General .............................................................24

13.3 Solid and Liquid Wastes Transportation and Disposal................................24

13.4 Vicinity Map ...............................................................................................24

14 Onshore Support Facilities Information ..................................................25

14.1 General ..................................................................................................25

14.2 Support Base Construction or Expansion...................................................25

14.3 Waste Disposal..........................................................................................25

15 Coastal Zone Management Act (CZMA) Information .............................25

15.1 Consistency Certification ...........................................................................25

16 Environmental Impact Analysis (EIA) ......................................................26

17 Administrative Information ......................................................................26

17.1 Exempted Information Description ............................................................26

17.2 Bibliography ...............................................................................................26

17.3 Other Reference Items ..............................................................................26

17.4 Recovery 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 

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1 Plan Contents 

1.1 History of Lease 

The initial DOCD for the Mississippi Canyon Area Block 383, (Kepler Field) was submitted to the 

Minerals Management Service (MMS) in May, 2002 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 Mississippi Canyon Area Block 474, approximately 

10 miles to the southeast. This SDOCD 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 

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This supplemental plan addresses the drilling and 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 targeted 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 subsea 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 host. 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 new 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/communication 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 redundant electric flying leads. Communications 

between the K-4 well to the NaKika facility will 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 proposed 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 deepwater construction and support vessels. The 

rig and all support vessels will be dynamically positioned; the use of anchors 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 development drilling and completion 

operations will include the use of appropriately designed casing and cement programs; 

appropriate blowout preventers, diverters, and other associated well equipment; appropriate mud 

monitoring equipment and sufficient mud volumes 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 

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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 abandon drills will be conducted, and navigational aids, lifesaving equipment, 

and other safety equipment will be installed and maintained 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 that will be used to conduct the development 

drilling and completion operations proposed 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 system of interdependent activities 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 requirements that need to be managed. BP has 

also presented to the BOEMRE a report entitled Deepwater Horizon Containment and 

Response: Harnessing Capabilities 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 

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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 Drill (APD) BSEE Pending Submittal 

Application for Permit to Modify (APM) BSEE Pending Submittal 

Pipeline ROW Modification 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 Documentation BOEM Approved April 26, 2010 

Table 2. Application and Permits

2.2 Drilling Fluids 

A table providing information on the types (including chemical constituents) and amounts of the 

drilling fluids that are planned to be used to drill the proposed 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 chemical constituents) and 

amounts of the completion fluids that are planned 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 

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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 completion 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 proposed 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, “Supplemental 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 Responsibility for Covered 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. 

2.10Suspension of Production 

There are no approved suspensions 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 

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2.11Blowout 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 support 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 “worst case”. However, bridging is possible due 

to the generally low formation strengths 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 enlarges and hydrostatic increases due to this failure, 

the fluid velocity slows, allowing the cavings 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 Drilling 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 approvals. 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 infrastructure 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 

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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 compliance 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 monitored 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 any 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 contractors 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 rigs 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 

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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 relating 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 independent of the cement provider. BPXP 

will provide lab results to the 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 when 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 Guide is in place. 

2.11.7 Measures that would enhance our ability to conduct early intervention

Measures to enhance our ability to conduct early intervention in addition to the regulatory and 

NTL requirements include: 

1. Relief well site(s) identified, surveyed, and assessed 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 contractors and technical specialist; and predesignated facilities, where our teams can provide 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 Gulf 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). Additional correspondence 

related to this plan was submitted by BP Exploration & Production Inc. on October 20, 2011. The 

Revised OSRP describes a number of source control 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 

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2.11.9 Worst Case Discharge Modeling Report 

Appendix C contains Discharge Modeling Reports which 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, including 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, well paths) 3-D seismic lines with depth scale 

within 152-meters (500-feet) of the proposed surface 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 

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4 Hydrogen Sulfide (H2S) 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 H2S has been confirmed”. 

4.1 Concentration 

Based on previous wells drilled in this area, the concentration will be 0-PPM H2S. It is not 

expected that H2S will be encountered during the operations 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 H2S absent, for the drilling program Mississippi Canyon 383 #1, #3 ST. 

4.3 H2S Contingency Plan 

Based on previous drilling, no H2S is known to occur in the area. Based on earlier drilling and 

previous BOEM “H2S absent” classification, an H2S contingency Plan prepared according to 30 

CFR § 250.490(f) is not required. 

4.4 Modeling Report 

H2S concentrations greater than 500-parts per million (ppm) are not expected 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 

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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, 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 (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 development 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 distances from drilling discharges and subsea 

equipment. 

6.2 Biologically Sensitive Underwater Features and Areas 

The proposed development drilling and completion activities 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 Topographic Features, Live Bottom (low-relief), Live 

Bottom (Pinnacle Trend) features, and other potentially 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 Features, “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 monitoring 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 

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6.4 Threatened or Endangered Species, 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 odontocete 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 inhabit 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 submitted 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 solid and liquid wastes likely to be generated by 

the proposed activities is included in Appendix G. 
________________________________________________________________________ 

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 

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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 complex associated with your proposed 

development and production activities process production from eight or 

more wells? 

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

per million (ppm)? 

 x Do you propose to flare or vent natural gas in excess of the criteria set 

forth under 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-139) 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 that 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 

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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 Gulf 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. Saucier dated October 19, 2011, and accepted on October 

20, 2011, BP Exploration & Production Inc. provided 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 include information 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 Notices 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 uncontrolled long-term blowout for the length of time required 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 used 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 remote thickness detection 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 consistent with applicable area contingency plans 

(ACP). 

 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. 
________________________________________________________________________ 

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 

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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 Corporation (MSRC), Clean Gulf 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 

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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 

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BP has determined that the worst case scenario from the activities proposed in this plan does 

not supersede the worst cast scenario in BP’s Regional July 2009 OSRP or the Revised OSRP 

submitted on October 20, 2011. Therefore, pursuant 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 scenario 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 discharge, 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 spill 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 technologies 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 source 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 Profile (ADCP) current monitoring system onboard to 

ensure continuous monitoring and gathering of ocean 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 activities will be conducted in adherence to NTL 2012-

G01 “Marine Trash and Debris Awareness Training and Elimination” and NTL 2012-Joint-G01 

“Vessel Strike Avoidance and Injured/Dead Protected Species Reporting”. As required by NTL 

2012-G01, BP submits an annual “certification” letter for its Marine Debris Awareness Training 

Process. The marine debris awareness training is required annually as identified by “BP’s Gulf of 

Mexico (GoM) Environmental Training Matrix” and “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 

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Monitoring activities are conducted by all personnel on rigs and platforms to prevent accidental 

loss of materials overboard and to report sightings of injured / dead protected species. Reporting 

of dead / injured protected species is addressed in BP’s “Incident 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 activities on the OCS are sometimes subject 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 determined as having high probability for prehistoric 

archaeological resources or historic period shipwrecks. 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-back 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 (MC 383), Ariel (MC 429), East Anstey (MC 508), 

Herschel (MC 520), Fourier MC 522 & MC 566), and Coulomb (MC 667). 

Other than these NaKika project facilities and operations, there are no other existing drilling units, 

production platforms, pipeline accessory platforms, 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 

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12.3 Produced Liquid Hydrocarbons 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 Aircraft Information 

13.1 General 

Support vessels and travel frequency during 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 wastes 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 proposed activities relative to the shoreline, the 

distance of the proposed activities from the shoreline, and the primary route(s) of the support 

vessels and aircraft when traveling between the onshore support facilities and the project areas 

are included in Appendix B.
________________________________________________________________________ 

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 

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14 Onshore Support Facilities Information 

14.1 General 

Mississippi Canyon Area Block 383 is located approximately 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, crane, 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 bases for the proposed, activities which are temporary in nature 

and do not mandate any immediate measures for 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 

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16 Environmental Impact Analysis (EIA) 

Attached as Appendix F is an environmental impact analysis (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 Management Service) has conducted extensive 

environmental analyses examining the possible impacts 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 the Gulf of Mexico covered by the present plan. 

The EIA, in addressing the project-specific environmental impacts of the present plan, contains 

conclusions and supporting analyses that are consistent 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 Capabilities and Lessons Learned. 

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

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 

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17.4 Recovery Fees 

Appendix J contains copies of the receipts showing the total payment of $7,942.00 for the 

service processing fee required by 30 CFR § 250.125, based on the proposed new K-4 and K-5 

wells. 
________________________________________________________________________ 

Title of Document: Kepler SDOCD Document Number: NKPH3-15-RG-PE-000001 

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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 Archeological 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-137 
U.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 89
OCS PLAN INFORMATION FORM (CONTINUED)

Include one copy of this page for each proposed well/structure 

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or 

structure, reference previous name): 

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

20,000 bbls/day 4 bbls
OCS 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 383
OCS 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 information as part of an applicant’s Exploration 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 valid Office 

of Management and Budget Control Number. Responses are mandatory (43 U.S.C. 1334). The public reporting burden for this 

form is included in the burden for preparing Exploration Plans and 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 data, 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 Clearance

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 4
U.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

X
OCS PLAN INFORMATION FORM (CONTINUED)

Include one copy of this page for each proposed well/structure 

Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or 

structure, reference previous name): 

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

20,000 bbls/day 4 bbls
________________________________________________________________________ 

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 Assessment 
QED

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. 
QED

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 2010 
Bathymetry Map

Proposed Mississippi Canyon Block 383 “K-4” Location

Plate 6

Water depths in feet

Contour Interval = 25 feet Images produced 

Vertical exagge

3 miles

MC 382

Proposed

Location

3 miles

GRID

MC 426MC 338

MC 383

MC 384

MC 339MC 427

MC 340

MC 428

-5400’

-5

700

’

-5300’

-5200’

-4800’ Biloxi

Dome

-5800’

-5900

’

-6000

’

-5600’

-4900’

-5100’

-5500’M

-4400’

-4500’ -5300’

Bathymetry data derived 

seismic water bottom time 

using an average water colu

derived from offset w

2,000 ft radius

clearance zone

-5700’

-5720’

Water depths in feet, Cont

-5740’

-5760’

-5780’

MC383 “K-4”

MC383 “

MC

“
________________________________________________________________________ 

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 and 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) 219-3000
Mississippi Canyon Block 383 January 2012

Environmental Impact Analysis 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 Bottoms...................................................................................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 (Endangered) .............................................................................................31

C.3.2 West Indian Manatee (Endangered)................................................................................35

C.3.3 Endangered 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

(Continued)

Page

Mississippi Canyon Block 383 January 2012

Environmental Impact Analysis 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.............................................................................................................68
Mississippi Canyon Block 383 January 2012

Environmental Impact Analysis 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 affected 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 northern Gulf Coast ....................................................................30

7 Wildlife 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 seafloor location of the K-4 well site .................................18

3 Location of selected environmental features in relation to the lease area........................44
Mississippi Canyon Block 383 January 2012

Environmental Impact Analysis 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 Development & 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

H2S 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 Minerals Management Service

MSRC Marine Spill Response Corporation

NAAQS National Ambient Air Quality Standards

NMFS National Marine Fisheries Service

NO2 nitrogen dioxide

NOAA National Oceanic and Atmospheric 

Administration

NOx nitrogen oxides

NPDES National Pollutant 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 

Coordination Document

SHL surface hole location

SOx 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 discharge
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Environmental Impact Analysis for SDOCD Page 1

Introduction

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) (formerly 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 (SDOCD) for the 

drilling of well K-4 in Mississippi Canyon (MC) Block 383 OCS-G-07937.

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 performing 

the necessary topside facilities modifications for an independent 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 Port Fourchon, Louisiana. The 

K-4 well will tie into the existing oil gathering line that is part of the Na Kika host facility, through 

the existing Na Kika North Oil Loop, a 10” by 16” pipe-in-pipe flowline utilizing a spare 

connection hub located on one of the three Ariel Field pipeline end terminations.

The production system will be controlled using a new umbilical to 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 supply 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 steel 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. Construction vessels will be based at the Core shipyard in Theodore, Alabama 

(Figure 1). No new or expanded facilities 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 Regulations (CFR) 250.242(s) and 250.261, 

as well as Notice to 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 Statement (EIS) for 

the Outer Continental Shelf (OCS) Oil 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 Gulf 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 Area lease sales (BOEMRE, 

2011a,b) update environmental baseline information 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 Analysis for SDOCD Page 2

Figure 1. Location of Mississippi Canyon Block 383.
Mississippi Canyon Block 383 January 2012

Environmental Impact Analysis 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 exploratory 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 five 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. Of 151 well blowouts in the Gulf of 

Mexico from 1971 to 1995, only 18 (12%) resulted in oil spills, with a total combined volume of 

1,000 barrels (bbl) of crude oil and condensate released (MMS, 2000). 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 this 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 conduct 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).

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Environmental Impact Analysis for SDOCD Page 4

NTL Title Summary

2009-G40 Deepwater Benthic Communities

Guidance for avoiding and protecting high-density 

deepwater benthic communities (including 

chemosynthetic and deepwater coral communities) 

from damage caused by 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 than 

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 designated 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 commencing such traffic.

2008-G04

Information Requirements for 

Exploration Plans and Development 

Operations Coordination 

Documents

Guidance on the information requirements for 

OCS plans, including EIA requirements and 

information regarding compliance with the provisions 

of the Endangered Species Act and Marine Mammal 

Protection Act.

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

2012-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–G01

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.
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Environmental Impact Analysis 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 impacts or negligible impacts 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 disposal; 

• 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:

• Dynamically positioned (DP) drillships; and

• DP semisubmersibles.

DP drillships and DP semisubmersibles use a global positioning system (GPS), specific computer 

software, sensors, and their own propellers and thrusters to maintain position. Through 

satellite navigation the location of the vessel is precisely 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 floating 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 at low frequencies, averaging 

10 to 500 hertz (Hz) (Richardson et al., 1995; MMS, 2000). All DP vessels maintain exterior 

lighting for navigational and aviation safety in accordance with Federal regulations.
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Environmental Impact Analysis 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 

Emissions

Effluent 

Discharges

Water 

Intake

Onshore 

Waste 

Disposal

Marine 

Debris

Support 

Vessel/Helo 

Traffic

Accidents

Diesel 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) -- -- -- -- -- --

Live 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 whales -- -- -- -- -- -- 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)

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

Fisheries Resources

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

Essential Fish Habitat X X -- X X -- -- -- 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.
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Environmental Impact Analysis 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 banks) protected by the Topographic 

Features Stipulation attached to an Outer Continental Shelf (OCS) lease;

(c) Essential Fish Habitat (EFH) criteria of 500 ft from any no-activity zone; or

(d) Proximity of any submarine bank (500-ft buffer zone) with relief greater than 2 m that is not protected by 

the Topographic Features Stipulation attached to an OCS lease.

• Not applicable. The lease is not within 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 

positioned vessels will be used for the activities in this plan, there will be no seafloor disturbances from 

the use of anchors and there are no features indicative of high-density chemosynthetic communities or 

coral communities within 610 m (2,000 ft) of any drilling mud/cuttings discharge location.

(5) Exploration or production activities where H2S concentrations greater than 500 ppm might be encountered.

• Not applicable. The BOEM Regional Supervisor has classified the area as “hydrogen sulfide (H2S) absent.”

(6) All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you 

determine would impact these environmental resources. If the proposed action is located a sufficient distance 

from a resource that no impact would occur, the EIA can note that in a sentence or two.

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

analyzed in Section C.

(7) All activities that involve seafloor disturbances, including anchor emplacements, in any OCS block designated 

by the BOEM as having high-probability for the occurrence of shipwrecks or prehistoric sites, including such 

blocks that will be affected that are adjacent to the lease block in which your planned activity will occur. If the 

proposed activities are located a sufficient distance from a shipwreck or prehistoric site that no impact would 

occur, the EIA can note that in a sentence or two.

• No impacts on archaeological resources are expected. The lease area is not on the 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 

anchors 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 critical habitats.

• IPFs that may affect marine mammals, sea turtles, or their critical habitats include drilling rig presence 

and emissions, support vessel and helicopter traffic, and accidents. See Section C.

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

• Not applicable.
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Environmental Impact Analysis 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 operations 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 (SOx), nitrogen oxides (NOx), volatile organic compounds 

(VOCs), and carbon monoxide (CO).

The Air Quality Emissions Report prepared in accordance with 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. 

Offshore 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 required 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 seafloor 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 with 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, uncontaminated fresh water and seawater, ballast 

water, and miscellaneous discharges identified in the NPDES permit.
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Environmental Impact Analysis 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 facilities are regulated by 

Section 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 Permit GMG290000. No significant entrainment or impingement impact 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;

• completion fluids;

• domestic wastes;

• recyclables (glass, plastic, cardboard, paper, and aluminum) - non hazardous; and

• waste 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 can 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, USEPA, 

U.S. Coast Guard (USCG), and BOEM regulations 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) requires durable identification markings on equipment, tools and containers 

(especially drums), and other material. USCG and USEPA regulations require operators to 

become proactive in avoiding accidental loss of solid waste items by developing waste 

management plans, posting informational placards, manifesting trash sent to shore, and using 

special precautions such as covering outside trash bins to prevent accidental loss of solid waste. 

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 process. BP’s compliance with all applicable laws, 

regulations, and BSEE NTL 2012-G01 should avoid impacts on the environment.
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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 will 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 transport 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 unpopulated 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 during the

drilling and tie back of Well K‐4.

Vessel/Aircraft Type Maximum Fuel Tank

Storage Capacity

Trip Frequency

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.
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Environmental Impact Analysis 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. Historically, most diesel spills have been ≤1 bbl, and this size is 

predicted to be the most common in ongoing and future OCS activities in the Western and 

Central Gulf of Mexico Planning Areas (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 Council [NRC], 

2003). The constituents of these oils are light-to-intermediate in molecular weight and can be 

readily degraded by aerobic microbial oxidation. Diesel is so light that it will not sink to the 

seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this 

generally occurs only in coastal areas with high suspended solids loads (NRC, 2003) and would 

not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. 

Diesel oil is readily and completely degraded by naturally occurring microbes (National Oceanic 

and Atmospheric Administration [NOAA], 2006).

. The fate 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 duration 

of a diesel fuel spill of 1,000 bbl or less, the opportunity for impacts to occur would be very 

brief. Slicks 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 would 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 components that contribute to crude oil’s longer persistence in the 

environment (MMS 2007b).

The fate of a diesel fuel spill was estimated using NOAA’s Automated Data Inquiry for Oil Spills 

(ADIOS2) model. This model uses the physical properties of oils in its database to predict the 

rate of evaporation and dispersion over time, as well as changes in the density, viscosity, and 

water content of the product spilled. It is estimated that over 90% of a 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 

(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 expected 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 runs, previous weathering analyses, and historical records of spill incidents.
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Spill Response. In the event the 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 Spills 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 evaporation 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 on 

the water surface (NRC, 2003).

. Following a diesel fuel spill, several physical, 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 processes 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 to 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 based on 

the number of blowouts divided by the accumulated operating time 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 blowout frequency estimates to include the recent 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 conduct effective and early intervention in the event of a blowout. BP will also 

comply with NTL 2010-N10 and the Interim Final Drilling Safety Rule, which specifies additional

safety measures for OCS activities.
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Spill Trajectory

A special OSRA run was conducted for the recent BOEMRE Central and Western Gulf of Mexico

Planning Area Supplemental EISs (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 continued for 90 consecutive days, with each trajectory 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 currents 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 but has generally been used by the BOEMRE/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 and Western Gulf of Mexico Planning Areas. These launch points were 

deliberately located in areas 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 area west of the Mississippi River 

(28.98660° 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, 96.76627° 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 current data would continue on a daily basis to help position 

equipment and human resources throughout the duration of any major spill or uncontrolled 

release.
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Table 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).

Season Winter Spring Summer Fall

Day 3 10 30 120 3 10 30 120 3 10 30 120 3 10 30 120

County 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 the water surface. 

Evaporated hydrocarbons are degraded rapidly by sunlight. Biodegradation of oil on the water 

surface and in the water column by marine bacteria removes first the n-alkanes and then the 

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

Photo-oxidation attacks mainly the medium and high molecular weight PAHs in the oil on the 

water surface.

. Following an oil spill, several physical, chemical, and biological processes, 

collectively called weathering, interact to change the physical and chemical 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, photochemical oxidation, microbial degradation, 

adsorption to suspended particulate matter, and stranding on shore or sedimentation to the 

seafloor (NRC, 2003).

Spill Response. BOEMRE has issued recent NTLs following the Macondo spill regarding

additional oil-spill prevention and response planning measures. These NTLs are summarized in 

Table 1, and additional BOEMRE (2011a) guidance is provided below.
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NTL 2010-N10 – Statement of Compliance with Applicable Regulations and Evaluation of 

Information Demonstrating Adequate Spill 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 statement 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 at 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 to 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 covered by the OSRP filed by BP 

America Inc. (Operator No. 21591) in accordance with 30 CFR 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 (SDOCDs). 

The required supplemental 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 that the measures are adequate to promptly respond to a blowout or other loss of 

well control.

BP’s revised OSRP includes information 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 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 used to recover the discharge on the water’s surface. 
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The description 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 consistent with applicable area contingency plans 

(ACPs); 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 Corporation 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 that 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. Primary 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 SDOCD is Port Fourchon, Louisiana.

See SDOCD Section 10 for 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

The 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 

opportunity” using funds set aside from a previous MMS research program. However, this 

study, titled Synthetic-based Fluid Spill of Opportunity Environmental Impact and Recovery, 

suffered a major equipment malfunction and because SBM releases were declining additional 

funding was not provided to continue this study (BOEMRE, 2011c).

. In deepwater drilling, SBMs are preferred over petroleum oil-based 

muds (OBMs) due to the superior environmental properties of SBMs. The synthetic base fluids

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 1990s 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 (>2,381 bbls) quantities of drilling fluids 

(BOEMRE, 2011c).
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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 associated 

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 salts, 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 found 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 operations), 

hydraulic fluids (used in cranes and other hydraulic rig equipment), lubricating oil and grease 

(used in reciprocating and electrical equipment), and sodium hypochlorite (dilute, used as 

laundry bleach and disinfectant).

H2S Release

Pursuant to Title 30 CFR 250.490(c), Contingency Plan preparation according to 

30 CFR 250.490(f) is not required for the proposed activities.

. The BOEM Regional Supervisor has classified the area as “H2S 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 requirements 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 miles (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 the K-4 well site in MC 383 is approximately 1,750 m (5,741 ft) below mean sea 

level. Side-scan sonar data from the John E. Chance and Associates (JECA) 1986 Deep-Tow 

Survey showed a relatively smooth seafloor with a surface reflectivity indicating a clayey 

composition for the surface sediments. Piston cores from Block 383 indicated sediments 

comprised of soft clay and shell hash (BP GoM Resources, 2011).
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Figure 2. Bathymetric map showing the seafloor location of the K-4 well site.
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Based 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 benthic 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 carbonates at, or within, 2,000 ft of the proposed well location. There is 

an area of what appear to be expulsion features along 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 might exist that could support deepwater benthic 

communities will be avoided by the proposed activities.

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

(MMS, 2007b, 2008; BOEMRE, 2011a), including meteorology, oceanography, geology, air and 

water quality, benthic communities, threatened and endangered species, biologically sensitive 

resources, archaeological resources, socioeconomic conditions, and other marine uses. These 

regional descriptions are based on extensive literature reviews and are incorporated by 

reference. General 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.

Following the 2010 Macondo incident, large amounts 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 National Laboratory 

(Berkeley Lab), operated by the University of California, is studying the impacts and fate of 

deepwater oil clouds. Initial study results 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 lead by David Valentine (University of California, Santa Barbara) 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 degradation of sub-sea oil clouds

(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 previously 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 quality in the lease was potentially affected during that 

event. Water and sediment monitoring data reported by the Operational Science Advisory 

Team (OSAT, 2010) show that after August 2010, waters and sediments in the deepwater Gulf of 

Mexico beyond 1.8 miles (3 km) from the Macondo site, including those in the lease area, were 
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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 been 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 as 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 

status of Federal OCS waters is unclassified because there is no provision in the Clean Air Act for 

classification of areas outside State waters (MMS, 2007b).

As of 30 August 2011, all Louisiana, Mississippi, Alabama, and Florida coastal counties and 

parishes are in attainment of the National Ambient Air Quality Standards (NAAQS) for all criteria 

pollutants (USEPA, 2011). Two metropolitan areas in Texas (Dallas-Fort Worth and 

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

nonattainment areas for 8-h ozone. El Paso County, Texas is a nonattainment area for PM10 and 

CO, and Birmingham, Alabama is a non-attainment area for PM2.5 (USEPA, 2011).

Winds in the region are driven by the clockwise circulation around the Bermuda High 

(MMS, 2007b). The Gulf of Mexico is located to the southwest of this center of circulation, 

resulting in a prevailing southeasterly to southerly flow, which is conducive to transporting 

emissions toward shore. However, circulation also is affected by tropical 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 impacts on air quality presented in 

previous lease sale EISs (BOEMRE, 2011a,b).

The IPFs potentially affecting air quality during this project are air pollutant 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 drillship, 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 fuel 
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Environmental Impact Analysis for SDOCD Page 21

motors. Primary air pollutants typically associated with OCS activities are suspended PM, SOx, 

nitrogen dioxide (NO2), 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 along 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 onshore 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 under 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 Breton 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 approximately 75 miles (121 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 quality 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 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 extent and duration of air quality 

impacts from a fuel spill are not expected to be significant.

A fuel spill would 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 803 lbs. 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 those 

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. Real-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 air 
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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 NOx, SOx, 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 miles [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, gas, 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 slick extended over the lease area and, therefore,

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 spill, 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 permit limitations are 

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 will 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 seafloor in accordance with the 

NPDES permit.
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Treated sanitary and domestic wastes will have little or no impact on water quality in the 

immediate vicinity of these discharges. These wastes may have elevated levels of nutrients, 

organic matter, 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 

water, 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. Support 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

Potential 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 measures 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 quality 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 extent and 

persistence of impacts would depend on the meteorological and oceanographic conditions at 

the time and the effectiveness of spill response measures. However, it is estimated that over 

90% of a diesel fuel spill would be evaporated or dispersed within 24 hours (see Section A.9.2). 

The area of the sea surface with diesel fuel on it would range from 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 PAHs, which are 

moderately volatile (NRC, 2003). The constituents of these oils are light to intermediate in 

molecular weight and can be readily degraded by aerobic microbial 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).
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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 water quality are expected to be consistent with those 

analyzed and discussed in recent lease sale EISs (MMS, 2007b, 2008). A large spill would 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. Information from the Macondo spill indicates that clouds of submerged oil droplets 

can be produced when subsea dispersants are applied at the wellhead (Camilli et al., 2010; 

Hazen et al., 2010; Joint Analysis Group, 2010a,b,c). However, dispersants would be applied 

only after approval from the USEPA.

Small droplets in the water may adhere to suspended sediment and be removed from the water 

column (OSAT, 2010). Terry Hazen with the Lawrence Berkeley National Laboratory (Berkeley 

Lab), operated by the University of California, is studying the impacts and fate of deepwater oil 

clouds. Initial study results 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 

led by David Valentine (University of California, Santa Barbara) 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 degradation 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 location (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-McClelland Marine Geosciences, Inc. (FMMG) (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 characterize 

the area (BOEMRE, 2011d).
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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 

(Wei, 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 water depths. Sediments 

at the MT4 station were predominantly clay (45.5%) and silt (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/m2)

Macroinfauna

(individuals/m2)

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); macroinfaunal 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/m2 (Rowe and Kennicutt, 2009). Nematodes, nauplii, and 

harpacticoid copepods were the three dominant groups in the meiofauna, accounting for about 

90% of total abundance.

The benthic macroinfauna (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 

water depths of the lease area are expected to be about 1,500 to 2,000 individuals/m2

.

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 individuals/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 organic carbon 

(Cruz-Kaegi, 1998). Bacterial biomass at the depth range of the lease area typically is about 

1 to 2 g C/m2 in the top 15 centimeters (cm) of sediments (Rowe and Kennicutt, 2009).
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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 muds to

return to the surface. Excess cement slurry also will be released at the seafloor during casing 

installation for the riserless portion 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 Mexico 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 Discharges

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 through 

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 close to the drillsite. Areas 

of SBM cuttings deposition may develop elevated organic carbon concentrations and anoxic 

conditions (Continental Shelf Associates, Inc., 2006). Where SBM cuttings accumulate 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 

H2S 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).

The 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 are 
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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) estimated that a severe subsurface blowout 

could resuspend and disperse sediments within a 300-m (984-ft) radius. While coarse sediments 

(sands) would probably settle 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 assumed 

to largely be silt and clay (Rowe and Kennicutt, 2009).

Recent lease sale EISs (MMS, 2007a, 2008) indicated that oil spills would be unlikely to affect 

benthic communities beyond the immediate vicinity of the wellhead (i.e., due to physical 

impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill 

location.

C.2.2 High-Density Deepwater Benthic Communities

As defined by NTL 2009-G40, high-density deepwater benthic communities are features or areas 

that could support high-density chemosynthetic communities, 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 authigenic 

carbonates created by chemosynthetic communities. Based on a list of sites compiled by the 

BOEMRE (2011e) and maps presented by the U.S. Geological Survey (2011), the nearest known 

chemosynthetic community site is in Viosca Knoll (VK) Block 826, located approximately 48 miles 

(77 km) north-northeast from the lease area and the nearest known deepwater 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 fuel 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).
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The areal extent of the impacts from a DP rig will be small, and NTL 2009-G40 requires that 

high-density deepwater benthic communities and features 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 close 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 Resources, 2011). Monitoring 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 discharges 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 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 were reported at a water depth 

of about 1,100 m (3,600 ft). These 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 approval 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 communities 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., 2002; 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), 

impacts 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.
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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 features 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 Pinnacle 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 43 miles (69 km) north-northeast 

the lease area, along the shelf edge VK 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 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 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 (107 km) northeast of the project area.

There are no IPFs associated with either routine operations or accidents that could cause 

impacts to eastern Gulf live bottom areas due to the distance from the lease area. 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 includes all marine mammal species in the region, which are protected 

under the Marine Mammal Protection Act (MMPA).
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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 features essential to conservation, and those features may require special 

management considerations or protection; and (2) specific areas outside the geographical area 

occupied by the species if the agency determines that the area itself is essential for 

conservation. The 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 endangered 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 Xa -- None

Fin whale Balaenoptera physalus E Xa -- None

Humpback whale Megaptera novaeangliae E Xa -- None

North Atlantic right 

whale Eubalaena glacialis E Xa -- None

Sei whale Balaenoptera borealis E Xa -- None

Sea Turtles

Loggerhead turtle Caretta caretta T X X None

Green turtle Chelonia mydas T, Eb 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.
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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 habitat (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 modify 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 to adversely affect the threatened/endangered species or designated 

critical habitat under USFWS jurisdiction. Following the Macondo oil spill, BOEMRE requested to 

reinitiate 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 existing consultation recognizes 

that BOEMRE-required mitigations and other reasonable and prudent measures should reduce 

the likelihood of impacts from BOEM-authorized activities.

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right 

whale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare 

or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these 

species in the Gulf of Mexico.

Coastal endangered or threatened species include the 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 sections.

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 unsustainable human-caused impacts) by NOAA Fisheries 

(Waring et al., 2009). No critical habitat for sperm whale has been designated in the Gulf of 

Mexico.
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The distribution of sperm whales in the Gulf of Mexico is correlated with mesoscale physical 

features such 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 sperm 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 than 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% utilization 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 

mobility of these marine mammals. Compliance with BSEE NTL 2012-G01 will minimize the 

potential for marine debris-related impacts on sperm whales.

Current threats to sperm whale populations worldwide are discussed in a final recovery plan for 

the sperm whale recently published by NOAA (NMFS, 2010a). 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 

marine 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 frequency 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 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 noise sources. This project would represent a small contribution to the overall noise 

regime.

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 insignificant (NMFS, 2007).
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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, 2010a). 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 

superseding NTL 2007-G04, which, in lieu of a formal observer program, provides specific 

guidelines that should be followed 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 to 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 mitigation 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 protective 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, feeding, or sheltering to individuals, or have any consequences at 

the level of the population. With implementation of the vessel strike avoidance measures 

requirement to maintain a distance of 90 m (295 ft) from sperm whales, the NMFS concluded 

that the potential for harassment of sperm whales would be reduced to discountable levels.

Helicopter traffic also has the potential to disturb sperm whales. Smultea et al. (2008) 

documented responses of sperm whales offshore Hawaii to fixed wing aircraft flying at an 

altitude of 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 occurred 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 

helicopter 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 impacts 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 Leasing Program in the Central and Western Planning Areas of the Gulf of 
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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 available 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% would be evaporated or dispersed naturally 

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.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, 

inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of 

toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and 

noise of response vessels and aircraft (Marine Mammal Commission [MMC], 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.

Impacts 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 physiological effects can include skin irritation, 

inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of 

toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey; and stress from 

the activities and noise of response vessels and aircraft. Complications of the above may lead to 

dysfunction of immune and reproductive systems, physiological stress, declining physical 

condition, and death. Behavioral responses 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 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 

the potential for striking or disturbing these animals.
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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 presence 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 vessel 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, and 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 disturb 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 maintain 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 

mitigation 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 mucous membranes; 

inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey 

(or contaminated vegetation, in the case of manatees); and stress from the activities and noise 

of response vessels and aircraft. Complications of the above may lead to dysfunction of immune 

and reproductive systems, physiological stress, declining physical condition, and death. 

Behavioral responses 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 movement patterns or migration 

(MMC, 2010).
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In the event that a large spill reached coastal waters where manatees were present, the level of 

vessel and aircraft activity associated with spill response could disturb manatees and potentially 

result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate 

in accordance with JOINT NTL 2012-G01 to reduce the potential 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 been reported from the Gulf of Mexico but are considered rare or 

extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species 

in the Gulf of Mexico.

Due to the rare occurrence of these whales in the Gulf of Mexico 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 as 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 those 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 species 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 below, 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 (Balaenoptera 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 have been some in the west-central portion of the 

northeastern Gulf. The minke whale is considered rare in the Gulf of Mexico, with the only 

confirmed records coming from strandings (Würsig et al., 2000). Based on the available data, it 

is possible that Bryde’s whales could occur in the lease area.

Dwarf and pygmy sperm whales. At sea, it is difficult to differentiate dwarf sperm whales 

(Kogia sima) from pygmy sperm whales (Kogia breviceps), and sightings are often grouped 

together as “Kogia spp.” Both species have a worldwide distribution in temperate to tropical 

waters. In the Gulf of Mexico, both species occur primarily along the continental shelf edge and 

in deeper waters off the continental shelf (Mullin et al., 1991). Either species could occur in the 

lease area.
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Beaked whales. Four species of beaked whales are known from the Gulf of Mexico. They are 

Blainville’s beaked whale (Mesoplodon densirostris), Cuvier’s beaked whale (Ziphius cavirostris), 

Sowerby’s beaked whale (Mesoplodon bidens), and Gervais’ beaked whale (Mesoplodon 

europaeus). Stranding records in the Gulf of Mexico suggest that Gervais’ beaked whale is the 

most common and Sowerby’s is extralimital. Due to the difficulties of at-sea identification, 

beaked whales in the Gulf of Mexico are identified either as Cuvier’s beaked whales or are 

grouped into an undifferentiated complex (Mesoplodon spp. and Ziphius spp.). In the northern 

Gulf of Mexico, they are broadly distributed in waters greater than 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), pygmy killer whale (Feresa attenuata), 

short-finned pilot whale (Globicephala macrorhynchus), Risso’s dolphin (Grampus griseus), 

rough-toothed dolphin (Steno bredanensis), spinner dolphin (Stenella longirostris), and striped 

dolphin (Stenella coeruleoalba). The most common non-endangered cetaceans in the 

deepwater environment are the pantropical spotted dolphin, spinner dolphin, and clymene 

dolphin. However, any of these species could occur in the lease area.

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 frequency 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 mammal 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 their 
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vessel to avoid striking protected species, and requires operators to report sightings of any

injured or dead protected species. Vessel operators and crews are required to attempt to 

maintain a distance of 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 Atlantic 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 excessive speed or abrupt changes in direction until the 

cetacean has left the area. Vessel operators are required to reduce vessel speed to 10 knots or 

less when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an 

underway vessel, when safety permits. Compliance with this NTL will minimize the likelihood of 

vessel strikes as well as reduce the chance for disturbing marine mammals, and therefore no 

significant impacts are expected.

Aircraft traffic also has the potential to disturb marine mammals (Würsig et al., 1998). However, 

while flying offshore, helicopters maintain altitudes above 213 m (700 ft) during transit to and 

from the working area. This altitude will minimize the potential for disturbing marine mammals, 

and no significant 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 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 or dispersed naturally 

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.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, 

inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of 

toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and 

noise of response vessels and aircraft (MMC, 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 

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, there are no unique site-specific issues. Impacts of oil spills on marine mammals can 

include direct impacts from oil exposure, as well as indirect impacts due to response activities 
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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 mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) 

directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and 

stress from the activities and noise of response vessels and aircraft. Complications of the above 

may lead to dysfunction of immune and reproductive systems, physiological stress, declining 

physical condition, and death. Behavioral responses 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 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 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 threatened 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 loggerheads 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 the 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 – Loggerheads nest in significant numbers along the Florida Panhandle 

and, to a lesser extent, from Texas through Alabama (MMS, 2007b). The nearest significant 

nesting area of loggerhead turtles is found in Louisiana, on beaches within the Breton NWR;

• 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, Mexico (NMFS et al., 2010). Kemp’s ridley turtles typically do not nest in 

abundance along the U.S. Gulf 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 – Hawksbills typically do not nest anywhere near the project area.

IPFs potentially affecting sea turtles include drilling rig presence, noise, and lights; support 

vessel and helicopter traffic; and two types of accidents - a 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.
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Compliance with BSEE NTL 2012-G01 will minimize the potential for marine debris-related 

impacts on sea turtles.

Impacts of Drilling and Construction 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 offshore 

structures (Lohoefener et al., 1990) and, thus, may be more susceptible to impacts from sounds 

produced during routine operations. Helicopters and service vessels may also affect sea turtles 

due to machinery noise and/or visual disturbances. The most likely impacts would be 

short-term behavioral changes such as diving and evasive swimming, disruption of activities, or 

departure from the area. These short-term impacts are not expected to be biologically 

significant to sea turtle populations.

Artificial lighting can disrupt the nocturnal orientation of sea turtle hatchlings (Witherington, 

1997; Tuxbury and Salmon, 2005). However, hatchlings may rely less on light cues when they 

are offshore than when they are emerging on the beach (Salmon and Wyneken, 1990). 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 vessel 

strikes. Data show that vessel traffic is one cause of sea turtle mortality in the Gulf of Mexico 

(Lutcavage et al., 1997). While adult sea turtles are visible at the surface during the day and in 

clear weather, they can be difficult to spot from a moving vessel when resting below the water 

surface, during nighttime, or during periods of inclement weather. To reduce the potential for 

vessel strikes, 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 

sea turtles and slow down or stop their vessel to avoid striking protected species, and requires 

operators to report sightings of any injured or dead protected species. When sea turtles are 

sighted, vessel operators and crews are required to attempt to maintain a distance of 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 potential 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 for 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.
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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 is available as an option to 

reduce potential for 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% would be evaporated or dispersed naturally 

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.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, 

inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of 

toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and 

noise of response vessels and aircraft (MMC, 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 food; and stress from the activities and noise of response vessels and aircraft. 

Complications of the above may lead to dysfunction of immune and reproductive systems, 

physiological stress, declining physical condition, and death. Behavioral responses can include 

displacement of animals from prime habitat, disruption of social structure, changing food 

availability and foraging distribution and/or patterns, changing reproductive 

behavior/productivity, and changing movement patterns or migration. In the event 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 turtles in an 

affected area may be expected to be exposed. Sea turtles’ diving behaviors also put them at 

risk. Sea turtles rapidly inhale a large volume of air before diving and continually resurface over 

time, which may result in exposure to volatile vapors and oiling (NMFS, 2007).

Spilled oil reaching sea turtle nesting beaches could have effects on nesting sea turtles and egg 

development (NMFS, 2007). An oiled beach could affect nest site selection or result in no 

nesting at all (e.g., false crawls). Upon hatching and successfully reaching the water, hatchlings 
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are subject to the same types of oil spill exposure hazards as adults. Hatchlings that contact oil 

residues while crossing a beach can exhibit a range of effects, from acute toxicity to impaired 

movement and normal bodily functions (NMFS, 2007).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response 

could disturb sea turtles and potentially result in vessel strikes, entanglement, or other injury or 

stress. Response vessels would operate in accordance with 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 lease 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 designated 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 

congregate and feed along tidally exposed banks and shorelines, following the tide out and 

foraging at the water’s edge. It is possible that some deaths of Piping Plovers could occur, 

especially if spills occur during winter months when plovers are most common along the coastal 

Gulf or if spills contacted critical habitat. Impacts could also occur from vehicular traffic on 

beaches and other activities associated with spill cleanup.

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 Canada. 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 reintroduced in central Florida, and another reintroduced 
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population summers in Wisconsin and migrates to the southeastern U.S. for the winter. 

Whooping Cranes breed, migrate, winter, and forage in a variety of habitats, including coastal 

marshes and estuaries, inland marshes, lakes, ponds, wet meadows and rivers, and agricultural 

fields (USFWS, 2007). About 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 would 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 probability 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 sturgeon as a threatened species in 1991. The best known 

populations occur in the Apalachicola and Suwannee Rivers in Florida (Carr, 1996; Sulak and 

Clugston, 1998), the Choctawhatchee River in Alabama (Fox et al., 2000), and the Pearl River in 

Mississippi/Louisiana (Morrow et al., 1998). Critical habitat in the Gulf extends from Lake 

Borgne, Louisiana (St. Bernard Parish) to Suwannee Sound, Florida (Levy County) (NMFS, 2010b) 

(Figure 3). A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the 

recovery plan for this species (USFWS and Gulf States Marine Fisheries Commission, 1995).

A large oil spill (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 waters 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.
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Figure 3. Location of selected environmental features in relation to the lease area.
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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 sturgeon 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, 2007).

C.3.9 Smalltooth Sawfish (Endangered)

Smalltooth sawfish (Pristis pectinata) are found in the tropical and subtropical Atlantic Ocean. 

In the western Atlantic they have historically ranged from New York 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: the 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 along 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)

Potential 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-specific 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 petroleum 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 3
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shows their combined critical habitat. Species descriptions are provided in a recent lease sale 

EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affecting beach mice. There are no IPFs 

associated with 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 Oil 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 area 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 shorelines 

inhabited by beach mice within 120 days (Table 4).

C.3.11 Elkhorn Coral (Endangered)

Elkhorn coral (Acropora palmata) is found primarily in shallow waters with temperatures ranging 

between 26° and 30° Celsius (79° and 86° Fahrenheit) 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, elkhorn 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 were 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 along 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.
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Seabirds of the northern Gulf of Mexico were surveyed from ships during the GulfCet II program. 

Hess and Ribic (2000) reported that terns, storm-petrels, shearwaters, and jaegers were the 

most frequently sighted seabirds in the deepwater area. From these surveys, four ecological 

categories of seabirds were documented in the deepwater areas of the Gulf: summer migrants 

(e.g., shearwaters, storm petrels, and boobies); summer residents that breed in the Gulf 

(e.g., Sooty Tern, Least Tern, Sandwich Tern, and Magnificent Frigatebird); winter residents 

(e.g., gannets, gulls, and jaegers); and permanent resident species (e.g., Laughing Gulls, Royal 

Terns, and Bridled Terns) (Hess and Ribic, 2000).

Common seabird species include Wilson’s Storm-Petrel (Oceanites oceanicus), Magnificent 

Frigatebird (Fregata magnificens), Northern Gannet (Morus bassanus), Masked Booby (Sula 

dactylatra), Brown Booby (Sula leucogaster), Cory’s Shearwater (Calonectris diomedea), Greater 

Shearwater (Puffinus gravis), and Audubon’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 several seabird species, possibly due to 

effects of hydrography on nutrient levels and productivity of surface waters where birds forage. 

GulfCet II did not estimate bird densities; however, Powers (1987) indicates that seabird 

densities over the open ocean typically are <10 birds/km2

.

Trans-Gulf migrant birds including shorebirds, wading birds, and terrestrial birds may also be 

present in the lease area. Migrant birds may use offshore structures and platforms for resting, 

feeding, or as temporary shelter from inclement weather (Russell, 2005). Some birds may be 

attracted to offshore structures because of the lights and the fish populations that aggregate 

around these structures.

IPFs potentially affecting marine and pelagic birds include drilling rig presence, noise, and lights; 

support vessel and helicopter traffic; and two types of accidents - a small fuel spill and a large oil 

spill (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 structures, resulting in death or injury 

(Wiese et al., 2001; Russell, 2005). Mortality of migrant birds at tall towers and other 

land-based structures has been reviewed extensively, and the mechanisms involved in platform 

collisions appear to be similar. In some cases, migrants simply do not see a part of the platform 

until it is too late. In other cases, navigation may be disrupted by noise (Russell, 2005). On the 

other hand, offshore structures are suitable stopover habitats for most trans-Gulf migrant 

species, and most of the migrants that stop over on platforms probably benefit from their stay, 

particularly in spring (Russell, 2005). 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 Aardolie 
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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 did not recommend mitigation 

(Russell, 2005). Factors to consider in evaluating this impact in the Gulf of Mexico would include 

the lower incidence of cloudy and foggy days in the Gulf of Mexico versus the North Sea. 

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 waters. It is likely that individual birds would experience, at most, only short-term 

behavioral disruption, and the impact would not be significant.

Impacts of a 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 that over 90% would be evaporated or dispersed naturally 

within 24 hours. The area of the sea surface with diesel fuel on it would range from 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 

diesel 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 slick, 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 birds (BOEMRE, 2011a,b).
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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/km2

. 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 Frigatebird, 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 (Florida 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 Brown 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, 2010b).

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 shorebirds and coastal nesting birds include support vessel and 

helicopter traffic and a large 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 would 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.
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Impacts of Support Vessel and Helicopter Traffic

Support vessels 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 

individuals; 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 navigation 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 disturbance to birds onshore and offshore. Responses are highly 

dependent on the type of aircraft, the bird species, the activities that animals were previously 

engaged in, and previous exposures to overflights (Efroymson et al., 2000). Helicopters seem to 

cause the most intense responses compared to other human disturbances for some species 

(Bélanger and Bédard, 1989). However, Federal Aviation Administration Advisory Circular 

No. 91-36D recommends that pilots maintain a minimum altitude of 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). According 

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 Tern
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• Gull-Billed 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 oiling.

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 feeding 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 lead to 

death. Bird eggs may be oiled if an oiled adult sits on the nest.

As noted above, 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 Communities and Ichthyoplankton

Biggs and Ressler (2000) reviewed the biology of pelagic communities in the deepwater 

environment of the northern Gulf of Mexico. The biological oceanography of the region is 

dominated by the influence of the Loop Current, whose surface waters are among the most 

oligotrophic in the world’s oceans. Superimposed on this low-productivity condition are 

productive “hot spots” associated with entrainment of nutrient-rich Mississippi River water and 

mesoscale oceanographic features. Anticyclonic and cyclonic hydrographic features play an 

important role in determining biogeographic patterns and controlling primary productivity in the 

northern Gulf of Mexico (Biggs and Ressler, 2000).

Most fishes inhabiting shelf or oceanic waters of the Gulf of Mexico have planktonic eggs and 

larvae (Ditty, 1986; Ditty et al., 1988; Richards et al., 1989, 1993). Pelagic eggs and larvae 

become part of the planktonic community for various lengths of time (10 to 100 days, 

depending on the species) (MMS, 2007b).

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 are 
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assumed to be moving 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 single 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 nekton 

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 discharges 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, plankton, 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 entrainment 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 impacts 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 measures 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 pelagic 
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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 or dispersed naturally 

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.

A diesel 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. While adult and juvenile fishes may actively avoid a large 

spill, planktonic eggs and larvae would be unable to avoid contact. Eggs and larvae of fishes are 

especially vulnerable to oiling because they inhabit the upper layers of the water column, and 

they will 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

Essential Fish Habitat (EFH) is defined as those waters and substrate necessary to fish for 

spawning, breeding, feeding, and growth to maturity. Under the Magnuson-Stevens Fishery 

Conservation and Management Act, as amended, Federal agencies are required to consult on 

activities that may adversely affect EFH designated in Fishery Management Plans developed by 

the regional Fishery Management Councils.

The Gulf of Mexico Fishery Management Council (GMFMC) has prepared Fishery Management 

Plans for corals and coral reefs, shrimps, stone crab, spiny lobster, reef fishes, coastal migratory 

pelagic fishes, and red drum. In 2005, the EFH for these managed species was redefined in 

Generic Amendment No. 3 to the various Fishery Management Plans (GMFMC, 2005). The EFH 

for most of these GMFMC-managed species is on the continental shelf in waters shallower than 

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 shelf-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):
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• 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)

• Longfin 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 species 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 much of the deepwater Gulf of Mexico, including the lease area (Figure 3). The 

areal extent of the HAPC is approximately 15,000 mi2

(300,000 km2). The prevailing assumption 

is that Atlantic bluefin tuna follow an annual cycle of foraging in June through March off the 

eastern United States and Canadian coasts, followed by migration to the Gulf of Mexico to 

spawn in April, May, and June (NMFS, 2009).

Other HAPCs have been identified in the Gulf of Mexico by the GMFMC (2005). These include 

the Florida Middle Grounds, Madison-Swanson Marine Reserve, Tortugas North and South 

Ecological Reserves, Pulley Ridge, and several individual reefs and banks of the northwestern 

Gulf of Mexico (Figure 3). The nearest of these is Jakkula Bank, located approximately 195 miles 

(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 

fishes such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and 

drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994). This FAD 

effect would possibly enhance feeding of epipelagic predators by attracting and concentrating 

smaller fish species. 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 disturbance 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 

continental 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 the region.
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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 quality 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 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 reduce the potential for impacts on 

EFH. Given the open ocean location of the lease area, 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 or dispersed naturally 

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.

A diesel fuel spill could have localized impacts on EFH for highly migratory pelagic fishes, 

including tunas, swordfishes, billfishes, and sharks. These species occur as transients in the 

lease area. A spill would also produce short-term impact on water quality in the HAPC for 

spawning Atlantic bluefin tuna, which covers much of the deepwater Gulf of Mexico. The 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 approximately 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, 

there are no unique site-specific issues with respect to EFH.
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An oil spill in offshore waters would temporarily increase hydrocarbon concentrations on the 

water surface and potentially the subsurface as well. Given the extent of EFH designations in 

the Gulf of Mexico (GMFMC, 2005; NMFS, 2009), some impact on EFH would be highly likely.

A large spill could affect the EFH for many managed species including shrimps, 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 and shellfish species.

The lease area is within the HAPC for spawning Atlantic bluefin tuna (NMFS, 2009). A large spill 

could temporarily degrade the HAPC due to increased hydrocarbon concentrations in the water 

column, with the potential for lethal or sublethal impacts on spawning tuna. 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 reach 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-sponsored 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-G1).

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 miles (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 have been completed.

Impacts of a large oil spill (WCD) are the only accident IPFs considered. A small fuel spill would 

not affect shipwrecks because the oil would float and dissipate on the sea surface.
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Impacts of a Large Oil Spill (WCD)

MMS (2007b) estimated 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 apparently 

resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the 

behavior and impacts of subsurface plumes are not well known, a subsurface plume could 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, reversible 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 

northern 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 shelf shoreward of the 45- to 60-m 

(148- to 197-ft) bathymetric contours has potential for prehistoric 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 America, 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.
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Impacts of a Large Oil Spill (WCD)

Along the northern Gulf Coast, prehistoric sites occur frequently along the barrier islands and 

mainland coast and along the margins of bays and bayous (MMS, 2007b). If a spill did reach a 

prehistoric site along these shorelines it could coat fragile artifacts or site features and 

compromise the potential for radiocarbon dating organic materials in a site (although other 

dating methods are available and it is possible to decontaminate an oiled sample for 

radiocarbon dating). Coastal prehistoric sites could also be damaged by spill cleanup operations 

(e.g., by destroying fragile artifacts and disturbing the provenance of artifacts and site features).

C.7 Coastal Habitats and Protected Areas

Coastal habitats in the northeastern Gulf of Mexico that may be affected by oil and gas activities 

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, wetlands, 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 IPFs 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 related to support vessel 

traffic and a large oil spill (WCD). The support bases at Port Fourchon and Houma, Louisiana and 

Theodore, Alabama are not in wildlife refuges or wilderness areas. 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 prior 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.
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The shorelines within the geographic 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 are 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 Table 7. 

Table 7. Wildlife 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 Wildlife 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 Refuge
Table 7. (Continued).

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County or Parish Wildlife 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, or tarballs (MMS, 2007b). Oil is generally deposited on 

beaches in lines defined by wave action at the time of landfall. Oil that remains on the beach 

will thicken as its volatile components are lost. Thickened oil may form tarballs or aggregations 

that incorporate sand, shell, and other materials into its mass. Tar may be buried to varying 

depths under the sand. On warm days, both exposed and buried tarballs may liquefy and ooze. 

Oozing may also serve to expand the size of a mass as it incorporates beach materials. Oil on 

beaches may be cleaned up manually, mechanically, or both. Some oil can remain on the beach 

at varying depths and may persist for several years as it slowly biodegrades and volatilizes.

Wetlands are sensitive to oiling. The MMS (2007b) 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 about 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 elsewhere in 

the Gulf because of high cumulative stress (MMS, 2007b). In addition to the direct impacts of 

oil, cleanup activities in marshes may accelerate rates of erosion and retard recovery rates, 

which have been reported to require from years to decades following a spill (MMS, 2007b).
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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 consideration of the Macondo spill.

BOEMRE did not find new information that would alter the potential impacts 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 (Continental 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 

oceanographic 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 longlining 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 fishers occur on the upper continental 

slope, well inshore of the project area. Royal red shrimp are caught by trawlers 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 

recreational 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 drilling 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 expected.
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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 fisheries 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 including 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 event of a diesel 

fuel spill. 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. Fishing activities could be 

interrupted due to the activities of response vessels operating 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 spill 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, 2010d). At its peak on 12 July 2010, closures 

encompassed 84,101 mi2 (217,821 km2

), 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 shoreline, and 

nearly all of the diesel fuel would evaporate or disperse naturally within 24 hours. Response 

crews would be equipped with appropriate safety equipment to avoid injury and health effects. 

A diesel 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)

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.
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Depending on the spill rate and duration, the physical/chemical characteristics of the oil, 

meteorological and oceanographic conditions at the time, and the effectiveness of spill response 

measures, the public could be exposed to oil on the water and along the shoreline, 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 also reported by some wildlife-cleaning workers. Personnel 

working on offshore vessels or providing direct oversight to offshore 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 

acute exposure to hydrocarbons or H2S 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 the area. The project will have a negligible 

impact on socioeconomic conditions such as local employment, existing offshore and coastal 

infrastructure (including major sources of supplies, services, energy, and water), and minority 

and lower income groups. Impacts of a 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 response 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 site-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 part of the response effort; it could result in adverse publicity that affects 

employment in coastal recreation and tourism industries; and it could result in another 
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suspension of OCS drilling activities, including service and support operations that are an 

important part of local economies.

C.8.4 Recreation and Tourism

BOEMRE has reexamined the analyses 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 impacts 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 trash or debris being lost 

overboard from the drilling or construction vessels and subsequently 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 response measures. A large spill that reached coastal waters and 

shorelines could adversely affect recreation and tourism by contaminating beaches and 

wetlands, resulting in negative publicity that encourages people to stay away. Based on the 

revised OSRA modeling (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 industrial. 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 facilities.

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 in 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 approved 
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commercial waste disposal facilities to review their waste management practices, permitting, 

and compliance history.

The activities proposed in this project will not generate a large waste stream into these facilities 

and are not expected to affect the overall capacity of these facilities. The capacity 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 conducted 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 would 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, during 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 original 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 area 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 affect 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 

blocks 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 seafloor-disturbing activities occur near the existing 

pipelines and flowlines.
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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 Section 4, the lease area is free of any significant 

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 Current 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 activities 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 alternatives 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 previously 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 different development alternatives were considered for this SDOCD.
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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. 

Project activities will be conducted under BP’s OSRP and will include the measures described in 

SDOCD Section 10.

Additional mitigation 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 waste 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 feasible.

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).
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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 Tables 
please specify if the amount reported is a total or per well amount

Kepler - SS Well K-4

Projected generated waste Projected ocean discha

Type of Waste Composition Projected Amount Discharge rate Discharge 

Will drilling occur ? If yes, you should list muds and cuttings

EXAMPLE: Cuttings wetted with synthetic based fluid 

Cuttings generated while using synthetic based drilling fluid. X bbl/well X bbl/hr/well discharge o

Water Based Fluid Spent drilling fluid drilling riserless hole plus pad mud to fill the hole 48,000 bbl/well 18.7 bbl/hr/well Ocean seafloo

Cuttings wetted with Water Based Fluid Water base interval 4,828 bbl/well 1.88 bbl/hr/well Ocean seaflooExcess Cement Slurry

Excess mixed cement, including additives & waste from equipment wash down after a cement operation

118 bbl/well 0.05 bbl/hr/well Ocean dis

Cuttings wetted with Synthetic Based Fluid Drill cuttings, cement cuttings, & synthetic base mud retained on cuttings 3,756 bbl/well 1.46 bbl/hr/well Ocean dis

Small Volume Drilling Fluid Discharges associated with Cuttings 

Displaced interfaces, accumulated solids in sand traps, pit clean-out solids, & centrifuge discharges made while changing the mud weight

85 bbl/well 0.03 bbl/hr/well Ocean dis

Cement transfer losses Bulk transfer between vessels 146 bbl/well 0.06 bbl/hr/well Ocean disBarite transfer losses Bulk transfer between vessels 82 bbl/well 0.03 bbl/hr/well Ocean dis

Will humans be there? If yes, expect conventional waste

EXAMPLE: Sanitary waste water Sanitary waste from living quarters X bbl/well X bbl/hr/well chlorinate and 

overbo

Domestic Waste Food waste 72,679 bbl/well 24.62 bbl/hr/well Ocean disSanitary Waste Treated human body waste discharged from toilets & urinals 21,086 bbl/well 4.08 bbl/hr/well Ocean dis

Gray Water Drainage from dishwasher, shower, laundry, bath, & washbasin drains 38,209 bbl/well 14.88 bbl/hr/well Ocean dis

Is there a deck? If yes, there will be Deck Drainage

Deck Drainage Deck washdown & rain water 31,715 bbl/well 11.0 bbl/hr/well Ocean dis

Will you conduct well treatment, completion, or workover? 

Well Treatment Fluids Stimulations fluids including acids, solvents & propping agents 3,200 bbl/well 1.25 bbl/hr/well Ocean dis

Completion Fluids Salt solutions, weighted brines, polymers & various additives 2,200 bbl/well 0.86 bbl/hr/well Ocean disWorkover Fluids Salt solutions, weighted brines, polymers, & other specialty additives 400 bbl/well 0.16 bbl/hr/well Ocean dis

Miscellaneous discharges. If yes, only fill in those associated with your activity. 

Desalinization Unit Discharge Wastewater associated with the process of creating freshwater from seawater 71,691 bbl/well 13.88 bbl/hr/well Ocean dis

Blowout Preventer Fluid Fluid used to actuate the hydraulic equipment on the BOP 254 bbl/well 0.10 bbl/hr/well Ocean dis

Uncontaminated Ballast Water Uncontaminated seawater added or removed to maintain proper draft 3,713,897 bbl/well 1,258 bbl/hr/well Ocean disUncontaminated Bilge Water Water that collects in the vessels bilge 92,777 bbl/well 31.43 bbl/hr/well Ocean dis

Cement discharged at seafloor Excess mixed cement slurry 594 bbl/well 0.23 bbl/hr/well Ocean seaflooFire & Utility Water Uncontaminated seawater/freshwater used for fire control or utility purposes 2,783,314 bbl/well 538.78 bbl/hr/well Ocean disCooling Water Uncontaminated seawater 96,150,857 bbl/well 18,612 bbl/hr/well Ocean dis

TABLE 1. WASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE ORDISCHARGE TO THE GOM
please specify if the amount reported is a total or per well amount

Kepler - SS Well K-4

Projected generated waste Projected ocean discha

Type of Waste Composition Projected Amount Discharge rate Discharge 

TABLE 1. WASTES YOU WILL GENERATE, TREAT AND DOWNHOLE DISPOSE ORDISCHARGE TO THE GOM

NA

Biocide, corrosion inhibitors, or other chemicals used to prevent corrosion or fouling of piping or equipment

NA NA N/A 

Sub Sea Fluid Discharges

Wellhead Preservation, Hydrate Control, Umbilical Steel Tube Storage, Leak Tracer, & Riser Tensioner Fluids

168 bbl/well 0.065 bbl/hr/well Ocean seafloo

Will you produce hydrocarbons? If yes fill in for produced water.

NA Water brought up from hydrocarbonbearing strata during extraction of oil & gas NA NA NA 

Will 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. 
please specify whether the amount reported is a total or per wel

Kepler - SS Well K-4

Projected 

generated waste

Solid and Liquid Wastes 

transportation 

Type of Waste Composition Transport Method

Name/Location of Facility Amoun

Will drilling occur ? If yes, fill in the muds and cuttings.

EXAMPLE: Synthetic-based drilling fluid or mud internal olefin, ester

Below deck storage tanks on offshore support vessels

Newport Environmental Services Inc., Ingleside, TX X bb

Synthetic-based drilling fluid Synthetic-based drilling fluid Liquid mud storage on workboat

Baroid / MI Swaco Fouchon LA 3,940 b

Contaminated Synthetic base mud

Contaminated Synthetic base mud

Barged in (15 or 25 barrel cutting boxes)

Newpark Environmental Services, Fourchon LA 180 bb

Drilling mud contaminated absorbents

Absorbent pads contaminated with drilling muds Barged in (Omega 2 yard boxes)

Omega Waste Management, Patterson, LA 0.6 to

Excess barite 

Excess barite from vessel tank cleaning Transported by vehicle (supersacks)

Francis Drilling Mud or River Birch landfill 3 ton

Excess cement

Excess cement from vessel tank cleaning Transported by vehicle (supersacks)

Grand Isle Port Commission or River 3 ton

Washwater

Washwater from boat tank cleaning Transported in (15 barrel cuttings boxes)

Newpark Environmental Services, Fourchon LA 120 bb

Well Related Hazardous Waste

Rig lab titrations containing isopropanol alcohol, silver Barged in (5 gallon DOT containers)

Chemical Waste Management, Sulphur, 3 m3

Rig Maintenance Wastes (painting, blasting)

Paint thinner, paint chips, blast media, aerosol cans Barged in (drums or totes)

L&L Oil and Gas Services Fourchon, LA 3,940 

Rig Maintenance Wastes (non hazardous) Oily rags, pads, oil filters etc. Barged in (totes)

L&L Oil and Gas Services Fourchon, LA 45 ft3

Rig Used oil Lube oil, hydraulic oil, glycol Barged in (drums)

L&L Oil and Gas Services Fourchon, LA 103 m

Domestic waste Municipal trash Barged in (supersacks)

River Birch Landfill, Avondale, LA 18 ton

Scrap Metal

scrap piping, grating and other metals Barged in (scrap baskets) Southern Scrap. LA 7 ton

Universal Waste Batteries Barged in (DOT drums)

L&L Oil and Gas Services Fourchon, LA 3 lb3

Universal Waste Fluorescent light bulbs Barged in (DOT drums)

L&L Oil and Gas Services Fourchon, LA 3 lb3

Misc. unused chemical Pills, spacers, additives etc. Barged in (totes)

River Birch Landfill, Avondale, LA 6 bbl

Rig Drilling washwater Cleaning out of mud tanks

Barged in (15 or 25 barrel cutting boxes)

Newpark Environmental 

Services, Fourchon LA 120 bb

Completion Fluids Used completion fluids 

Barged in (15 or 25 barrel cutting boxes)

Newpark Environmental Services, Fourchon LA 390 bb

Waste 

TABLE 2. WASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHORE 
please specify whether the amount reported is a total or per wel

Kepler - SS Well K-4

Projected 

generated waste

Solid and Liquid Wastes 

transportation 

Type of Waste Composition Transport Method

Name/Location of Facility Amoun

Waste 

TABLE 2. WASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHORE 

Will you produce hydrocarbons? If yes fill in for produced sand.

EXAMPLE: trash and debris (recylables) Plastic, paper, aluminum barged in a storage bin ARC, New Iberia, LA X lb/wel

NOTE: 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. 
________________________________________________________________________ 

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 Information 
DOCD AIR QUALITY SCREENING CHECKLIST 

OMB A

COMPANY BP

AREA Mississippi Canyon

BLOCK Plan and Complex Total Emissions- MC383

LEASE OCS-G 07937PLATFORM Subsea Tieback

WELL K4COMPANY CONTACT Jim Pfeiffer (Air Quality) / Teri Halverson (Plans)TELEPHONE NO. 281-366-1542 (Jim) / 281-366-6292 (Teri)REMARKS Drill, complete, install pipeline, install subsea equipment, produce

LEASE TERM PIPELINE CONSTRUCTION INFORMATION:

YEAR NUMBER OF TOTAL NUMBER OF CONSTRUCTION DAYS

PIPELINES

2012 1 112013201420152016201720182019202020212022

FORM BOEM-0139 (December 2011 - Supersedes all previous versions of this form which may not be used). Page 1 of 4
AIR EMISSIONS COMPUTATION FACTORS

Fuel Usage Conversion Factors Natural Gas Turbines Natural Gas Engines Diesel Recip. Engine RE

SCF/hp-hr 9.524 SCF/hp-hr 7.143 GAL/hp-hr 0.0483 AP42 

Equipment/Emission Factors units PM SOx NOx VOC CO RENG Turbines gms/hp-hr 0.00247 1.3 0.01 0.83 AP42 3.2-NG 2-cycle lean gms/hp-hr 0.00185 10.9 0.43 1.5 AP42 NG 4-cycle lean gms/hp-hr 0.00185 11.8 0.72 1.6 AP42 NG 4-cycle rich gms/hp-hr 0.00185 10 0.14 8.6 AP42 Diesel Recip. < 600 hp. gms/hp-hr 1 1.468 14 1.12 3.03 AP42 Diesel Recip. > 600 hp. gms/hp-hr 0.32 1.468 11 0.33 2.4 AP42 Diesel Boiler lbs/bbl 0.084 2.42 0.84 0.008 0.21 AP42 1.3NG Heaters/Boilers/Burners lbs/mmscf 7.6 0.593 100 5.5 84 P42 1.4-1, 1NG Flares lbs/mmscf 0.593 71.4 60.3 388.5 AP42 1Liquid Flaring lbs/bbl 0.42 6.83 2 0.01 0.21 AP42 1.3-Tank Vapors lbs/bbl 0.03 E&P FFugitives lbs/hr/comp. 0.0005 API SGlycol Dehydrator Vent lbs/mmscf 6.6 La. DGas Venting lbs/scf 0.0034

Sulphur Content Source Value Units

Fuel Gas 3.33 ppm

Diesel Fuel 0.4 % weight

Produced Gas( Flares) 3.33 ppm

Produced Oil (Liquid Flaring) 1 % weight

FORM BOEM-0139 (December 2011 - Supersedes all previous versions of this form which may not be used). Page 2 of 4
AIR EMISSIONS CALCULATIONS - FIRST YEAR

COMPANY AREA BLOCK LEASE PLATFORM WELL CONTACT PHONE REMARKS

BP Mississippi Canyon Plan and Comp OCS-G 07937 Subsea Tieback K4 Jim Pfeiffer (Air Quality) / Teri H 281-366-1542 (JDrill, complete, install pipeline, i

OPERATIONS EQUIPMENT RATING MAX. FUEL ACT. FUEL RUN TIME MAXIMUM POUNDS PER HOUR 

Diesel Engines HP GAL/HR GAL/D

Nat. Gas Engines HP SCF/HR SCF/D

Burners MMBTU/HR SCF/HR SCF/D HR/D DAYS PM SOx NOx VOC CO PM 

Drill: 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 

Fast 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 Offshore 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 Offshore 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 Offshore 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 PIPELINE INSTALLATION:

Skandi Neptune VESSELS>600hp diesel (multi-ser 13685 660.9855 15863.65 24 11 9.65 44.25 331.57 9.95 72.34 1.27 

2012 YEAR TOTAL 73.50 337.20 2526.73 75.80 551.29 41.43 

EXEMPTION CALCULATION DISTANCE FROM LAND IN MILES 1631.70 

49.0

FORM BOEM-0139 (December 2011 - Supersedes all previous versions of this form which may not be used). Page 3 of 4
AIR EMISSIONS CALCULATIONS

COMPANY AREA BLOCK LEASE PLATFORM WELLBP Mississippi Canyon Plan and Complex TotaOCS-G 07937 Subsea Tieback K4

Emitted Substance

Year

 PM SOx NOx VOC 

2012 41.43 190.04 1424.01 42.72 32013 41.43 190.04 1424.01 42.72 32014 41.43 190.04 1424.01 42.72 32015 41.43 190.04 1424.01 42.72 32016 41.43 190.04 1424.01 42.72 32017 41.43 190.04 1424.01 42.72 32018 41.43 190.04 1424.01 42.72 32019 0.00 0.00 0.00 0.00 2020 0.00 0.00 0.00 0.00 2021 0.00 0.00 0.00 0.00 

Allowable 1631.70 1631.70 1631.70 1631.70 45

FORM 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): 

Revised 4/09/12
 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 computed 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. 

Revised 4/09/12
 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 necessary, 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 operations 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 temporarily 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. 

Revised 4/09/12
 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 provide 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 (such as infrared [IR] and X-band radio systems) to 

guide skimming vessels to sufficient concentrations of oil. The specific technologies used will 

be 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, availability 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. 

Revised 4/09/12
 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 organic 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 Contingency 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 significant concentrations of oil. Using inductor 

nozzles installed on fire-water monitors, skid mounted systems, or purpose-built boom-arm 

spray systems, vessels can initially apply dispersant 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 deployment 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, government, 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 supervision 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 production 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 eliminated 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?”) Additional 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, “branch offices” similar to those stood in previous 

responses—can be consulted to ensure that environmental, special economic and cultural 

resources are correctly identified and prioritized 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 Receipt 
1

Cleland, Betsy

From: paygovadmin@mail.doc.twai.gov

Sent: Tuesday, March 20, 2012 3:39 PM

To: Cleland, Betsy

Subject: Pay.gov Payment Confirmation: BOEM Development/DOCD Plan - BD

Your payment has been submitted to Pay.gov and the details are below. If you have any 

questions or you wish to cancel this payment, please contact Pay.gov Customer Service by 

phone at (800) 624-1373 or by email at pay.gov.clev@clev.frb.org.

Application Name: BOEM Development/DOCD Plan - BD Pay.gov Tracking ID: 2563VQUN Agency 

Tracking ID: 74293701592 Transaction Type: Sale Transaction Date: Mar 20, 2012 4:38:35 PM

Account Holder Name: Teri Halverson

Transaction Amount: $3,971.00

Billing Address: 200 Westlake Park Blvd.

Billing Address 2: WL4

City: Houston

State/Province: TX

Zip/Postal Code: 77079

Country: USA

Card Type: AmericanExpress

Card Number: ************1002

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 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY.
1

Cleland, Betsy

From: paygovadmin@mail.doc.twai.gov

Sent: Wednesday, March 21, 2012 9:29 AM

To: Cleland, Betsy

Subject: Pay.gov Payment Confirmation: BOEM Development/DOCD Plan - BD

Your payment has been submitted to Pay.gov and the details are below. If you have any 

questions or you wish to cancel this payment, please contact Pay.gov Customer Service by 

phone at (800) 624-1373 or by email at pay.gov.clev@clev.frb.org.

Application Name: BOEM Development/DOCD Plan - BD Pay.gov Tracking ID: 2564LBN7 Agency 

Tracking ID: 74294406888 Transaction Type: Sale Transaction Date: Mar 21, 2012 10:28:52 AM

Account Holder Name: Teri Halverson

Transaction Amount: $3,971.00

Billing Address: 200 Westlake Park Blvd.

Billing Address 2: WL4

City: Houston

State/Province: TX

Zip/Postal Code: 77079

Country: USA

Card Type: AmericanExpress

Card Number: ************1002

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 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY.