UNITED STATES GOVERNMENT MEMORANDUM

To: Public Information (MS 5030)

Plans Section, Office of Field 

Operations (MS 5231)

Public Information copy of DOCD

Control # - S-07734

Type - Supplemental Development Operations Coordinations Document

Lease(s) - OCS-G04940 Block - 18 Green Canyon Area

OCS-G05809 Block - 988 Ewing Bank Area

Operator - Whistler Energy II, LLC

Well No. A-23 ST1

Not Found

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.

Chiquita Hill

Plan Coordinator

WELL/A-23 G05809/EW/988 7914 FSL, 4395 FEL G04940/GC/18

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

Description -

Rig Type -

Subject:

From:

March 30, 2015
Record of Changes – Public Information Copy

Supplemental DOCD Control No. S-7734

Ewing Bank 988 / OCS-G 05809

Whistler Energy II, LLC

Date Section Page Remarks

02/17/15 2 2-6 Amended Blowout Scenario

03/10/15 7 Attachment

7-A

Removed discharges from Well Treatment Fluids
PUBLIC INFORMATION COPY 

February 2, 2015 

SUPPLEMENTAL DEVELOPMENT OPERATIONS 

COORDINATION DOCUMENT 

Ewing Bank Block 988 

OCS-G 05809 

 

Affected States: Louisiana 

Estimated Startup Date: May 1, 2015 

SUBMITTED BY: 

Whistler Energy II, LLC 

3200 SW Freeway, Suite 2050 

Houston, TX 77027 

Robert Wichert 

713-333-3664 

rwichert@whistlerenergy.com

AUTHORIZED REPRESENTATIVE:

Suzy Younger 

J. Connor Consulting, Inc. 

16225 Park Ten Place, Suite 700 

Houston, Texas 77084 

281-698-8520 

suzy.younger@jccteam.com
TOC Pg 1 of 3 

TABLE OF CONTENTS 

SECTION 1 PLAN CONTENTS ................................................................................................. 1

1.1 PLAN INFORMATION ...................................................................................................... 1

1.2 LOCATION ....................................................................................................................... 1

1.3 SAFETY AND POLLUTION PREVENTION FEATURES .................................................. 1

1.4 STORAGE TANKS AND PRODUCTION VESSELS ......................................................... 2

1.5 POLLUTION PREVENTION MEASURES ........................................................................ 2

1.6 ADDITIONAL MEASURES ............................................................................................... 2

SECTION 2 GENERAL INFORMATION .................................................................................... 3

2.1 APPLICATIONS AND PERMITS ...................................................................................... 3

2.2 DRILLING FLUIDS ........................................................................................................... 3

2.3 PRODUCTION ................................................................................................................. 3

2.4 OIL CHARACTERISTICS ................................................................................................. 3

2.5 NEW OR UNUSUAL TECHNOLOGY ............................................................................... 3

2.6 BONDING STATEMENT .................................................................................................. 3

2.7 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) .......................................................... 3

2.8 DEEPWATER WELL CONTROL STATEMENT ................................................................ 3

2.9 SUSPENSION OF PRODUCTION ................................................................................... 4

2.10 BLOWOUT SCENARIO .................................................................................................. 4

SECTION 3 GEOLOGICAL AND GEOPHYSICAL INFORMATION .......................................... 6

3.1 GEOLOGICAL DESCRIPTION ......................................................................................... 6

3.2 STRUCTURE CONTOUR MAPS...................................................................................... 6

3.3 INTERPRETED 3-D SEISMIC LINES ............................................................................... 6

3.4 GEOLOGICAL STRUCTURE CROSS-SECTION ............................................................. 6

3.5 SHALLOW HAZARDS REPORT ...................................................................................... 6

3.6 SHALLOW HAZARDS ASSESSMENT ............................................................................. 6

3.7 HIGH-RESOLUTION SEISMIC LINES ............................................................................. 6

3.8 STRATIGRAPHIC COLUMN ............................................................................................ 6

3.9 TIME VS DEPTH TABLES................................................................................................ 6

SECTION 4 HYDROGEN SULFIDE INFORMATION ................................................................ 7

4.1 CONCENTRATION .......................................................................................................... 7

4.2 CLASSIFICATION ............................................................................................................ 7

SECTION 5 MINERAL RESOURCE CONSERVATION INFORMATION ................................... 8

5.1 TECHNOLOGY & RESERVOIR ENGINEERING PRACTICES AND PROCEDURES ...... 8

5.2 TECHNOLOGY AND RECOVERY PRACTICES AND PROCEDURES ............................ 8

5.3 RESERVOIR DEVELOPMENT ......................................................................................... 8
TOC Pg 2 of 3 

SECTION 6 BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION ................... 9

6.1 DEEPWATER BENTHIC COMMUNITIES ........................................................................ 9

6.2 TOPOGRAPHIC FEATURES (BANKS) ............................................................................ 9

6.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) ............................................... 9

6.4 LIVE-BOTTOMS (PINNACLE TREND FEATURES) ......................................................... 9

6.5 LIVE BOTTOMS (LOW RELIEF) ...................................................................................... 9

6.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES .................................................... 9

6.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS .................................................... 9

6.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND MARINE 

MAMMAL INFORMATION ..............................................................................................10

6.9 ARCHAEOLOGICAL REPORT ........................................................................................11

6.11 SOCIOECONOMIC INFORMATION ..............................................................................11

SECTION 7 WASTES AND DISCHARGES INFORMATION ...................................................12

7.1 PROJECTED GENERATED WASTES ............................................................................12

7.2 MODELING REPORT ......................................................................................................12

SECTION 8 ...............................................................................................................................13

8.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS ......................................13

8.2 SUMMARY INFORMATION ............................................................................................13

SECTION 9 OIL SPILL INFORMATION ..................................................................................14

9.1 OIL SPILL RESPONSE PLANNING ................................................................................14

9.2 SPILL RESPONSE SITES ...............................................................................................14

9.3 OSRO INFORMATION ....................................................................................................14

9.4 WORST-CASE DISCHARGE SCENARIO DETERMINATION .........................................14

9.5 OIL SPILL RESPONSE DISCUSSION ............................................................................15

SECTION 10 ENVIRONMENTAL MONITORING INFORMATION ..........................................16

10.1 MONITORING SYSTEMS .............................................................................................16

10.2 INCIDENTAL TAKES .....................................................................................................16

10.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY ..................................16

SECTION 11 LEASE STIPULATIONS INFORMATION ..........................................................17

11.1 MARINE PROTECTED SPECIES .................................................................................17

SECTION 12 ENVIRONMENTAL MITIGATION MEASURES INFORMATION .......................19

12.1 MEASURES TAKEN TO AVOID, MINIMIZE, AND MITIGATE IMPACTS ......................19

12.2 INCIDENTAL TAKES .....................................................................................................19

SECTION 13 RELATED FACILITIES AND OPERATIONS INFORMATION ...........................20

13.1 RELATED OCS FACILITIES AND OPERATIONS .........................................................20

13.2 TRANSPORTATION SYSTEM ......................................................................................20

13.3 PRODUCED LIQUID HYDROCARBONS TRANSPORTATION VESSELS ...................20
TOC Pg 3 of 3 

SECTION 14 SUPPORT VESSELS AND AIRCRAFT INFORMATION ...................................21

14.1 GENERAL .....................................................................................................................21

14.2 DIESEL OIL SUPPLY VESSELS ...................................................................................21

14.3 DRILLING FLUID TRANSPORTATION .........................................................................21

SECTION 15 ONSHORE SUPPORT FACILITIES INFORMATION .........................................22

15.1 GENERAL .....................................................................................................................22

15.2 SUPPORT BASE CONSTRUCTION OR EXPANSION .................................................22

15.4 WASTE DISPOSAL .......................................................................................................22

SECTION 16 COASTAL ZONE MANAGEMENT (CZM) INFORMATION ................................23

SECTION 17 ENVIRONMENTAL IMPACT ANALYSIS (EIA) ..................................................24

SECTION 18 ADMINISTRATIVE INFORMATION ....................................................................25

18.1 EXEMPTED INFORMATION DESCRIPTION ................................................................25

18.2 BIBLIOGRAPHY ............................................................................................................25
Attachment – Pg. 1 of 1 

SECTION ATTACHMENTS

 

Section 1 Plan Contents

1-A OCS Plan Information Form

1-B Well Location Plat

Section 7 Wastes and Discharges Information

7-A

Waste You Will Generate, Treat and Downhole Dispose or Discharge to 

the GOM

Section 8 Air Emissions Information

8-A Emissions Worksheets

Section 9 Oil Spill Information

9-A Oil Spill Response Discussion

Section 14 Support Vessels and Aircraft Information

14-A Waste You Will Transport and/or Dispose Onshore Table 

14-B Vicinity Map

Section 17 Environmental Impact Analysis (EIA)

17-A Environmental Impact Analysis (EIA)
Whistler Energy II, LLC Section 1 – Pg. 1 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 1 

PLAN CONTENTS 

1.1 PLAN INFORMATION 

Under a previous plan (Control No. S-2880), Mobil developed Lease G-05809, Ewing Bank 

Block 988. Whistler Energy II, LLC was designated operator of the lease in July 2013. All of the 

Ewing Bank Block 988 wells are drilled from Green Canyon Block 18 A, which is a 30-slot, 4-pile 

platform installed in 760’ of water. 

Under this Supplemental Development Operations Coordination Document, Whistler Energy II, 

LLC (Whistler) proposes to re-enter Green Canyon Block 18 (current bottomhole location) Well 

No. A-23 (API No. 60-811-40191-00) and sidetrack to a new bottomhole location in Ewing Bank 

Block 988. These development operations are in approximately 760 feet of water. The well will 

be re-entered and drilled with a platform rig (Noble MODS 201). No right-of-way or lease term 

pipelines will be installed. 

The OCS Plan Information Form BOEM-137 is included as Attachment 1-A.

1.2 LOCATION 

A Well Location Plat depicting the proposed surface and bottomhole location of the proposed 

well, measured depth/true vertical depth and water depth is included as Attachment 1-B. 

No anchors are associated with the proposed activities in this plan. 

1.3 SAFETY AND POLLUTION PREVENTION FEATURES

A description of the drilling unit which complies with all relevant regulations is included on the 

OCS Plan Information Form. Rig specifications will be made part of each Application for Permit 

to Drill. 

The rig will be equipped with safety and fire-fighting equipment required to comply with United 

States Coast Guard (USCG) regulations. Appropriate life saving equipment such as life rafts, life 

jackets, ring buoys, etc. as prescribed by the USCG, will be maintained on the rig at all times. 

Safety features on the drilling unit will include well control, pollution prevention, and blowout 

prevention equipment as described in BSEE regulations 30 CFR 250 C, D, E, O, Q and S; and 

as further clarified by BSEE Notices to Lessees, and current policy making invoked by the 

BSEE, EPA and the USCG. 

Pollution prevention measures include installation of curbs, gutters, drip pans, and drains on 

drilling deck areas to collect all contaminants and debris. Compliance will be maintained with the 

EPA NPDES Permit. The rig will be monitored daily and any waste or fuel resulting in pollution 

of the Gulf waters will be reported to the representative in charge for immediate isolation and 

correction of the problem. Any spill will be reported to the appropriate governmental agencies. 
Whistler Energy II, LLC Section 1 – Pg. 2 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

1.4 STORAGE TANKS AND PRODUCTION VESSELS 

The table below provides storage tanks with capacity of 25 barrels or more that will store fuels, 

oil and lubricants. 

Type of

Storage 

Tank

Type of

Facility

Tank 

Capacity 

(bbls)

Number

of Tanks

Total 

Capacity 

(bbls)

Fluid Gravity

(API)

Production Platform 600 1 600 29°

Production Platform 850 1 850 29°

Production Platform 210 1 210 29°

Production Platform 100 1 100 29°

1.5 POLLUTION PREVENTION MEASURES

These operations do not propose activities for which the State of Florida is an affected state. 

1.6 ADDITIONAL MEASURES 

Whistler does not propose any additional safety, pollution prevention, or early spill detection 

measures beyond those required by 30 CFR Part 250. 

 
U.S. Department of the Interior

Bureau of Ocean Energy Management 

Have you previously provided information to verify the calculations and assumptions for your WCD? X Yes No

If so, provide the Control Number of the EP or DOCD with which this information was provided R-6208

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

Do you propose to use a vessel with anchors to install or modify a structure? Yes X No

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

Description of Proposed Activities and Tentative Schedule (Mark all that apply)

Proposed Activity Start Date End Date No. of Days

Recover slot, drill, complete & produce EW 988 Well No. A-23 

(current BHL GC 18) 05/01/2015 07/11/2015 72

Description of Drilling Rig Description of Structure

Jackup Drillship Caisson Tension leg platform

Gorilla Jackup X Platform rig (Noble 201) Fixed platform Compliant tower

Semisubmersible Submersible Spar Guyed tower

DP Semisubmersible Other (Attach description) Floating production 

system Other (Attach description)

Drilling Rig Name (If known):

Description of Lease Term Pipelines

From (Facility/Area/Block) To (Facility/Area/Block) Diameter (Inches) Length (Feet)

N/A

Form BOEM- 0137 (December 2011 – Supersedes all previous editions of this form which may not be used.) Page 1 

Attachment 1-A 

General Information

Type of OCS Plan: Exploration Plan (EP) X Development Operations Coordination Document (DOCD)

Company Name: Whistler Energy II, LLC BOEM Operator Number: 03269

Address: 3200 SW Freeway, Suite 2050 Contact Person: Suzy Younger

 Houston, Texas 77027 Phone Number: 281-698-8520

E-Mail Address: suzy.younger@jccteam.com

If a service fee is required under 30 CFR 550.125(a), provide the Amount paid $4238 Receipt No. 25JJOKEF

Project and Worst Case Discharge (WCD) Information

Leases: OCS-G 05809 Area: Ewing Bank Blocks: 988 Project Name (If Applicable):N/A

Objective(s) X Oil X Gas Sulphur Salt Onshore Support Base: Fourchon, LA

Platform / Well Name: Platform A Total Volume of WCD: 132554 bbls API Gravity: 29°

Distance to Closest Land (Miles): 76 miles Volume from uncontrolled blowout: 130222

OCS PLAN INFORMATION FORM

OMB Control Number: 1010-0151

OMB Approval Expires: 12/31/14
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): EW 988 #A-23 (well 

is currently GC 18 #A-23)

Previously reviewed under an approved EP or DOCD? X Yes No

Is this an existing well or 

structure? X Yes No If this is an existing well or structure, list the Complex ID or API No. 608114019100

Do you plan to use a subsea BOP or a surface BOP on a floating facility to conduct your proposed activities? Yes X No

WCD Info For wells, volume of uncontrolled 

blowout (Bbls/Day): 54605

For structures, volume of all storage and pipelines 

(Bbls): 2332 API Gravity of fluid 29°

Surface Location Bottom-Hole Location (For Wells) Completion (For multiple completions, enter 

separate lines)

Lease No. OCS-G 04940 OCS-G 05809 OCS

OCS

Area Name GC EW

Block No. 18 988

Blockline 

Departures 

(in feet)

N/S Departure 7914’ FSL N/S Departure 

N/S Departure F __ L

N/S Departure F __ L

N/S Departure F __ L

E/W Departure 4395’ FEL E/W Departure 

E/W Departure F __ L

E/W Departure F __ L

E/W Departure F __ L

Lambert X-Y 

coordinates

X: 2,276,564.65’ X: 

X:

X:

X:

Y: 10,145,514.32’ Y: 

Y:

Y:

Y:

Latitude/

Longitude

Latitude 27° 56’ 37.371” N Latitude 

Latitude

Latitude

Latitude

Longitude 91° 01’ 45.179” W Longitude

Longitude

Longitude

Longitude

Water Depth (Feet): 760’ MD (Feet): TVD (Feet): MD (Feet):

MD (Feet):

MD (Feet):

TVD (Feet): 

TVD (Feet): 

Anchor Radius (if applicable) in feet: N/A 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 

Whistler Energy II, LLC Section 2 – Pg. 3 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 2 

GENERAL INFORMATION 

2.1 APPLICATIONS AND PERMITS 

The table below provides the additional applications to be filed covering operations proposed in 

this DOCD. 

Application/Permit Issuing Agency Status

Application for Plugback to Sidetrack BSEE Pending

Application for Permit to Sidetrack BSEE Pending

Application for Permit to Modify BSEE Pending

2.2 DRILLING FLUIDS 

The table below provides the types and estimated volumes of the drilling fluids Whistler plans to 

use to drill the proposed well.

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be 

Used per Well (bbls)

Water-based (seawater, freshwater, barite) 5000 bbls

Oil-based (diesel, mineral oil) N/A

Synthetic-based (internal olefin, ester) N/A

2.3 PRODUCTION 

Proprietary Information 

2.4 OIL CHARACTERISTICS 

Oil characteristics are not required to be submitted with this plan. 

2.5 NEW OR UNUSUAL TECHNOLOGY 

No new or unusual technology is proposed in this DOCD as defined by 30 CFR 550.200.

2.6 BONDING STATEMENT 

The bond requirements for the activities and facilities proposed in this DOCD are satisfied by an

area-wide bond, furnished and maintained according to 30 CFR 556, Subpart I; NTL No. 2000-

G16, "Guidelines for General Lease Surety Bonds"; and additional security under 30 CFR 

556.53(d) and National NTL No. 2008-N07, “Supplemental Bond Procedures” as required by 

BOEM. 

2.7 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) 

Whistler Energy II, LLC, Operator No. 03269, has demonstrated oil spill financial responsibility 

for the facilities proposed in this DOCD according to 30 CFR Part 553; and NTL No. 2008-N05, 

"Guidelines for Oil Spill Financial Responsibility for Covered Facilities" prior to conducting 

operations covered in this DOCD. 

2.8 DEEPWATER WELL CONTROL STATEMENT 

Operations proposed in this plan are located in water depths less than 300 meters (984 feet); 

therefore, a deepwater well control statement is not provided. 
PUBLIC INFORMATION COPY 

Whistler Energy II, LLC Section 2 – Pg. 4 of 26

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

2.8 DEEPWATER WELL CONTROL STATEMENT 

Operations proposed in this plan are located in water depths less than 300 meters (984 feet); 

therefore, a deepwater well control statement is not provided. 

2.9 SUSPENSION OF PRODUCTION 

Whistler does not anticipate filing any requests for Suspension of Production to hold the leases 

addressed in this DOCD in active status. 

2.10 BLOWOUT SCENARIO 

The Worst Case Discharge in this DOCD is for Ewing Bank Block 988, Well No. A-13 (GC 18 A 

surface location) accepted in Control No. R-06208 approved by the Bureau of Ocean Energy 

Management on January 21, 2015. 

Estimated Flow Rate - Drilling – Calculated ‘Worst Case Drilling Discharge’ estimate for the 

section for the A-13 well, is 130,222 Bbls per day of oil and 127 MMCF per day of gas (based 

on 972 scf/stb (GOR).

Total Volume - Drilling – Total volume based on a ‘Worst Case Drilling Discharge’ estimate of 

130,222 Bbls per day of oil and 127 MMCF per day of gas and a ‘Maximum duration of the 

potential blowout’ of 45 days = 130222 x 45 = 5,859,990 bbls and 5.7 BCF.

Estimated Flow Rate - Production – The production based WCD estimate is based on a 

gravel packed completion with 2-7/8” tubing in the hole. The tubing has the smallest well 

restriction (2.323”). 

Calculated ‘Worst Case Production Discharge’ estimate for the completed well with 2-7/8” 

production tubing is 7159 Bbls per day of oil and 6.95MMCF per day of gas (based on 972 

scf/stb (GOR). 

Maximum duration of the potential blowout – Maximum duration will be the time to drill the 

relief well and kill (45 days), assuming the reservoir does not bridge over. 

Intervention, relief well plans and time required to kill the well: 

The potential for the well to bridge over – The target zone is commonly known to produce 

sand at normal production drawdown pressures, and is routinely gravel packed in completions. 

The drawdown pressure and flow rate during an uncontrolled blowout, without sand control 

would cause sand face failure and lead to large amounts of sand production. However, it is 

impossible to determine if a sand bridge capable of stopping the blowout will form in the casing, 

and it is assumed that the blowout will continue until it can be mechanically stopped by an 

intervention.

The availability of a rig to drill a relief well and rig package constraints 

Each planned well will be drilled from the Green Canyon Block 18 platform location in 760’ of 

water. There are currently a combined number of 58 floating MODU in the GOM that are 

capable of drilling a relief well in this water depth. Attached in report listing of rigs and their 

current location. 
PUBLIC INFORMATION COPY 

Whistler Energy II, LLC Section 2 – Pg. 5 of 26

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

Specify as accurately as possible the time it would take to contract for a rig, move it 

onsite, and drill a relief well, including the possibility of drilling a relief well from a 

neighboring platform or an onshore location 

The well locations are located too far away from the nearest structure in order to drill a relief well 

from a neighboring platform, therefore two scenarios have been defined; the first being; a rig 

being immediately available, and the second being; a rig not being immediately available, and 

suspension of operations is required prior to mobilization. 

The actual hole and casing sizes may vary with final relief well design dependent upon actual 

conditions at the time; this is for estimating time only. There are currently no plans or need to 

drill a relief well from any neighboring structures. 

The first scenario assumes that a rig is available to mobilize to location and commence drilling a 

relief well. The mobilization time is based on utilizing an available rig and the drilling 

performance is based on offset wells to equivalent depth.

OPERATION TIME (DAYS)

Move Rig on Location 3

Drive 30” Pipe to 1355 TVD/MD 2

Drill 26” Conductor Hole to ~2400’ TVD/MD & Run & Cement 18-5/8” 

Casing.

3

Drill 17 1/2” Surface Hole, Run & Cement 13 3/8” Casing (TVD & 

MD will be dependent upon surface location) ±7600’ TVD

10

Drill 12 1⁄4” Hole & Run & Cement 9 5/8” Intermediate Casing (TVD & 

MD will be dependent upon surface location) ±10,000 TVD (just 

above well intersect)

15

Drill 8-1/2” relief hole to intersect with reservoir section or production 

casing 14,500 TVD / 17,500 MD (TVD & MD will be dependent upon 

surface location)

12

TOTAL ESTIMATED DAYS to DRILL RELIEF WELL 45 DAYS

The second scenario assumes that a rig is not immediately available to mobilize to location and 

commence drilling a relief well. The estimated mobilization time incorporates the suspension of 

activities by an operator before the rig can be released for relief well operations. The drilling 

performance is based on offset wells to equivalent depth. 

OPERATION TIME (DAYS)

Suspension of current operations 10

Move Rig on Location 3

Drive 30” Pipe to 1355’ TVD/MD 2

Drill 26” Conductor Hole to ~2400’ TVD/MD & Run & Cement 18-5/8” 

Casing.

3

Drill 17 1/2” Surface Hole, Run & Cement 13 3/8” Casing (TVD & 

MD will be dependent upon surface location) ±7600’ TVD

10

Drill 12 1⁄4” Hole & Run & Cement 9 5/8” Intermediate Casing (TVD & 

MD will be dependent upon surface location) ±10,000’ TVD (just 

above well intersect)

15
PUBLIC INFORMATION COPY 

Whistler Energy II, LLC Section 2 – Pg. 6 of 26

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

Drill 8-1/2” relief hole to intersect with reservoir section or production 

casing 14,500 TVD / approx. 17,500 MD (TVD & MD will be 

dependent upon surface location)

12

TOTAL ESTIMATED DAYS to DRILL RELIEF WELL 55 DAYS

Blowout Prevention Measures 

Describe the measures you propose that would enhance your ability to prevent a 

blowout, to reduce the likelihood of a blowout, and conduct effective and early 

intervention in the event of a blowout, including your arrangements for drilling relief 

wells, and any other measures you propose 

Whistler would adhere and conduct strict compliance with all regulations, including those listed 

in latest Drilling Safety Rule. 

This well is planned in a well-known area and has been designed to control any anticipated 

pressures that might be encountered. 

Liners/Production casings are planned to have two independent floats to prevent any possible 

internal flow back, and are equipped with an annular packer. 

Sufficient cement of appropriate density with anti-gas migration additives will be used to isolate 

any hydrocarbon bearing zones. 

All drill strings are planned to have at least one float valve installed in the BHA as close to the 

bit as practical. 

It is planned that drilling fluids of sufficient density to control all exposed formations will be 

maintained at all times during drilling operations. 
Whistler Energy II, LLC Section 3 – Pg. 6 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 3 

GEOLOGICAL AND GEOPHYSICAL INFORMATION 

3.1 GEOLOGICAL DESCRIPTION 

Proprietary Information 

3.2 STRUCTURE CONTOUR MAPS 

Proprietary Information 

3.3 INTERPRETED 3-D SEISMIC LINES 

Proprietary Information

3.4 GEOLOGICAL STRUCTURE CROSS-SECTION 

Proprietary Information

3.5 SHALLOW HAZARDS REPORT 

The proposed operations will be conducted from previously approved surface location as 

provided for in DOCD (Control No. S-2880); therefore, in accordance with NTL No. 2008-G05, 

“Shallow Hazards Program”, a shallow hazards report is not provided. 

3.6 SHALLOW HAZARDS ASSESSMENT 

The proposed operations will be conducted from previously approved surface location as 

provided for in DOCD (Control No. S-2880); therefore, in accordance with NTL NO.2008-G05, 

Shallow Hazards Program”, a shallow hazards assessment is not provided. 

3.7 HIGH-RESOLUTION SEISMIC LINES

Proprietary Information

3.8 STRATIGRAPHIC COLUMN 

Proprietary Information 

3.9 TIME VS DEPTH TABLES 

Proprietary Information
Whistler Energy II, LLC Section 4 – Pg. 7 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 4 

HYDROGEN SULFIDE INFORMATION 

4.1 CONCENTRATION 

Whistler anticipates encountering 0 ppm H2S during the proposed operations. 

4.2 CLASSIFICATION 

In accordance with Title 30 CFR 250.490(c), Whistler requests that the area of proposed 

operations be classified by the BOEM as H2S absent. 

 
Whistler Energy II, LLC Section 5 – Pg. 8 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 5 

MINERAL RESOURCE CONSERVATION INFORMATION 

5.1 TECHNOLOGY & RESERVOIR ENGINEERING PRACTICES AND PROCEDURES 

Proprietary Information 

5.2 TECHNOLOGY AND RECOVERY PRACTICES AND PROCEDURES 

Proprietary Information 

5.3 RESERVOIR DEVELOPMENT 

Proprietary Information 
Whistler Energy II, LLC Section 6 – Pg. 9 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 6 

BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION 

6.1 DEEPWATER BENTHIC COMMUNITIES 

Activities proposed in this DOCD are in water depths less than 300 meters (984 feet); therefore, 

information as outlined in Attachment A of NTL No. 2009-G40, “Deepwater Benthic 

Communities,” is not provided. 

6.2 TOPOGRAPHIC FEATURES (BANKS) 

Activities proposed in this DOCD do not fall within 305 meters (1000 feet) of a topographic “No 

Activity Zone;” therefore, no map is required per NTL No. 2009-G39, “Biologically Sensitive 

Underwater Features and Areas.”

6.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) 

All activities proposed under this DOCD will be conducted outside all Topographic Feature 

Protective Zones; therefore, shunting of drill cuttings and drilling fluids is not required per NTL 

No. 2009-G39, “Biologically Sensitive Underwater Features and Areas.”

6.4 LIVE-BOTTOMS (PINNACLE TREND FEATURES) 

Green Canyon Block 18 is not located within 61 meters (200 feet) of any pinnacle trend feature; 

therefore, a separate bathymetric map is not required per NTL No. 2009-G39, “Biologically 

Sensitive Underwater Features and Areas.”

6.5 LIVE BOTTOMS (LOW RELIEF) 

Green Canyon Block 18 is not located within 30 meters (100 feet) of any live bottom (low relief) 

feature with vertical relief equal to or greater than 8 feet; therefore, live bottom (low relief) maps 

are not required per NTL No. 2009-G39, “Biologically Sensitive Underwater Features and 

Areas.”

6.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES 

Green Canyon Block 18 is not located within 30 meters (100 feet) of potentially sensitive 

biological features; therefore, biologically sensitive area maps are not required. 

6.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS 

Operations proposed in this plan are located in water depths less than 400 meters (1312 feet); 

therefore, remotely operated vehicle (ROV) surveys for the purpose of biological and physical 

observations are not required per NTL No. 2008-G06, “Remotely Operated Vehicle Surveys in 

Deepwater”.
Whistler Energy II, LLC Section 6 – Pg. 10 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

6.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND MARINE 

MAMMAL INFORMATION 

The federally listed endangered and threatened species potentially occurring in the lease area 

and along the Gulf Coast are provided in the table below. 

Species Scientific Name Status Potential Presence Critical Habitat 

Designated in the Gulf 

of Mexico

Lease 

Area

Coastal

Marine Mammals

Manatee, West 

Indian

Trichechus manatus latirostris E -- X Florida (peninsular)

Whale, Blue Balaenoptera masculus E X

*

-- None

Whale, Finback Balaenoptera physalus E X

*

-- None

Whale, 

Humpback

Megaptera novaeangliae E X

*

-- None

Whale, North 

Atlantic Right

Eubalaena glacialis E X

*

-- None

Whale, Sei Balaenopiera borealis E X

*

-- None

Whale, Sperm Physeter catodon 

(=macrocephalus)

E X -- None

Terrestrial Mammals

Mouse, Beach 

(Alabama, 

Choctawatchee, 

Perdido Key, St. 

Andrew)

Peromyscus polionotus E - X Alabama, Florida 

(panhandle) beaches

Birds

Plover, Piping Charadrius melodus T - X Coastal Texas, Louisiana, 

Mississippi, Alabama and 

Florida (panhandle)

Crane, Whooping Grus Americana E - X Coastal Texas

Reptiles

Sea Turtle, 

Green 

Chelonia mydas T,E** X X None

Sea Turtle, 

Hawksbill 

Eretmochelys imbricata E X X None

Sea Turtle, 

Kemp’s Ridley 

Lepidochelys kempli E X X None

Sea Turtle, 

Leatherback 

Dermochelys coriacea E X X None

Sea Turtle, 

Loggerhead 

Caretta caretta T X X Texas, Louisiana, 

Mississippi, Alabama, 

Florida

Fish

Sturgeon, Gulf Acipenser oxyrinchus 

(=oxyrhynchus) desotoi

T X X Coastal Louisiana, 

Mississippi, Alabama and 

Florida (panhandle)

Corals

Coral, Elkhorn Acopora palmate T - X Florida Keys and Dry 

Tortugas
Whistler Energy II, LLC Section 6 – Pg. 11 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

Coral, Staghorn Acopora cervicornis T - X Florida

Abbreviations: E = Endangered; T = Threatened 

*

 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. 

** Green Sea turtle is threatened, except for the Florida breeding population, which is listed as endangered. 

6.9 ARCHAEOLOGICAL REPORT 

The proposed operations will be conducted from previously approved surface location as 

provided for in the DOCD (Control S-2880); therefore, in accordance with NTL No. 2005-G07, 

“Archaeological Surveys and Reports,” and NTL No. 2011-JOINT-G01, “Revisions to the List of 

OCS Lease Blocks Requiring Archaeological Resource Surveys and Reports,” an 

archaeological survey report is not provided.

6.10 AIR AND WATER QUALITY INFORMATION 

Air and water quality information is not required to be included in this plan per NTL No. 2008-

G04, “Information Requirements for Exploration Plans and Development Operations 

Coordination Documents”.

6.11 SOCIOECONOMIC INFORMATION 

Socioeconomic Information is not required to be included in this plan per NTL No. 2008-G04, 

“Information Requirements for Exploration Plans and Development Operations Coordination 

Documents”. 
Whistler Energy II, LLC Section 7 – Pg. 12 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 7 

WASTES AND DISCHARGES INFORMATION 

7.1 PROJECTED GENERATED WASTES 

“Wastes You Will Generate, Treat and Downhole Dispose or Discharge to the Gulf of Mexico” is 

included as Attachment 7-A. 

7.2 MODELING REPORT 

Modeling reports are not required for the activities proposed in this plan. 
Projected generated waste Projected ocean discharges 

Type of Waste Composition Projected Amount (bbl/well) Discharge rate (bbl/day/well) Discharge Method Answer yes or no

Water-based drilling fluid Water based drilling fluid 7430 106 Discharge overboard No

Cuttings wetted with water-based fluid Water based cuttings 5430 78 Discharge overboard No

Cuttings wetted with synthetic-based fluid N/A N/A N/A N/A No

Domestic waste (kitchen water, shower water) Domestic water: kitchen, shower water @ 65 

USG/Man Day 9208 132 Chlorination and discharge overboard No

Sanitary waste (toilet water) Black Water (Toilet Water @ 10USG/Man 

Day) 85 Men max 1417 20 Red Fox then chlorination and discharge overboard No

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

Deck Drainage Rainwater @ 8"/mo 128770 1840 Drill sump then overboard No

Will you conduct well treatment, completion, or workover? 

Well treatment fluids N/A N/A N/A N/A No

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

Desalinization unit discharge Concentrated seawater 21600 309 Discharge overboard No

Blowout prevent fluid N/A N/A N/A N/A No

Ballast water N/A N/A N/A N/A No

Bilge water N/A N/A N/A N/A No

Excess cement at seafloor N/A N/A N/A N/A No

Fire water N/A N/A N/A N/A No

Cooling water N/A N/A N/A N/A No

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

Produced water Produced water 30,000 BWPD 30,000 BWPD Discharge overboard No

Will you be covered by an individual or general NPDES permit ? Yes GMG 290538

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

Projected 

Downhole 

Disposal

Attachment 7-A
Whistler Energy II, LLC Section 8 – Pg. 13 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 8 

8.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS 

Screen Questions for DOCD’s Yes No

Is any calculated Complex Total (CT) Emission amount (tons) associated with 

your proposed development 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 

250.1105(a)(2) and (3)? X

Do you propose to burn produced hydrocarbon liquids? 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? X

8.2 SUMMARY INFORMATION 

Included as Attachment 8-A are Air Emission Worksheets which show the emissions 

calculations for the Plan emissions and a set of worksheets showing the emissions calculations 

for the Complex Total emissions. 

This information was calculated by: Suzy Younger 

 281-698-8520

 suzy.younger@jccteam.com










Whistler Energy II, LLC Section 9 – Pg. 14 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 9 

OIL SPILL INFORMATION 

9.1 OIL SPILL RESPONSE PLANNING 

All the proposed activities and facilities in this DOCD will be covered by the Oil Spill Response 

Plan (OSRP) filed by Whistler (Operator No. 03269) dated November 18, 2014 and last 

approved on December 18, 2014 (OSRP Control No. 0-707). 

9.2 SPILL RESPONSE SITES 

Primary Response Equipment Location Preplanned Staging Location

Houma, LA

Harvey, LA

Leeville, LA

Houma, LA

Harvey, LA

Fourchon, LA

9.3 OSRO INFORMATION 

Whistler’s primary equipment provider is Clean Gulf Associates (CGA). Clean Gulf Associates 

Services, LLC (CGAS) will provide closest available personnel, as well as a supervisor to 

operate the equipment. 

9.4 WORST-CASE DISCHARGE SCENARIO DETERMINATION 

Category

Drilling Production

Regional

OSRP

WCD

DOCD

WCD

Regional 

OSRP

WCD

DOCD

WCD

Type of Activity Drilling Drilling >10 Miles

Production

>10 Miles

Production

Facility Location 

(Area/Block) GC18

SL is GC 18

BHL is EW 

988

GC 18 GC 18

Facility Designation A A-13 ST A A

Distance to Nearest 

Shoreline (miles) 79 76 79 76

Volume

 Storage tanks & 

flowlines

 Lease term

pipelines

 Uncontrolled 

blowout

Total Volume (bbls)

2332

0

130222

132554

2332

0

130222

132554

2332

0

7159

9491

2332

0

7159

9491

Type of Oil(s)

(crude, condensate, 

diesel)

Crude Crude Crude Crude

API Gravity 30 30 30 30
Whistler Energy II, LLC Section 9 – Pg. 15 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

The DOCD drilling WCD calculations and production WCD volume were submitted under Plan 

Control No. R-06208 approved on January 21, 2015. 

Whistler has determined that the worst-case scenario from the activities proposed in this DOCD 

does not supersede the worst-case scenario from our approved Regional OSRP.

9.5 OIL SPILL RESPONSE DISCUSSION 

The Oil Spill Response Discussion is included as Attachment 9-A.
Attachment 9-A Page 1 

SPILL RESPONSE DISCUSSION 

For the purpose of NEPA and Coastal Zone Management Act analysis, the largest spill volume 

originating from the proposed activity would be a well blowout during drilling operations, 

estimated to be 132,554 barrels of crude oil with an API gravity of 29°. 

Land Segment and Resource Identification

Trajectories of a spill and the probability of it impacting a land segment have been projected 

utilizing information in the BOEM Oil Spill Risk Analysis Model (OSRAM) for the Central and 

Western Gulf of Mexico available on the BOEM website. The results are shown in Figure 1.

The BOEM OSRAM identifies a 7% probability of impact to the shoreline in Cameron Parish, 

Louisiana within 30 days. Cameron Parish includes the east side of Sabine Lake, Sabine National 

Wildlife Refuge, Calcasieu Lake, Lacassine National Wildlife Refuge (inland) and Grand Lake; 

along the Gulf beach from Sabine Pass to Big Constance Lake in Rockefeller Wildlife Refuge. 

This region is composed of open public beaches, marshlands and swamps. It serves as a habitat 

for numerous birds, finfish and other animals, including several rare, threatened and endangered 

species. 

Response

Whistler will make every effort to respond to the Worst Case Discharge as effectively as 

practicable. A description of the response equipment under contract to contain and recover the 

Worst Case Discharge is shown in Figure 2.

Using the estimated chemical and physical characteristics of crude oil, an ADIOS weathering 

model was run on a similar product from the ADIOS oil database. The results indicate 11% or 

approximately 14,581 barrels of crude oil would be evaporated/dispersed within 24 hours, with 

approximately 117,973 barrels remaining. 

Spill Response GC 18 A Barrels of Oil 

WCD Volume 132,554

Less 11% natural evaporation/dispersion 14,581

Remaining volume 117,973

Figure 2 outlines equipment, personnel, materials and support vessels as well as temporary 

storage equipment available to respond to the worst case discharge. The volume accounts for the 

amount remaining after evaporation/dispersion at 24 hours. The list estimates individual times 

needed for procurement, load out, travel time to the site and deployment. Figure 2 also indicates 

how operations will be supported. 

Whistler’s Oil Spill Response Plan includes alternative response technologies such as dispersants 

and in-situ burn. Strategies will be decided by Unified Command based on an operations safety 

analysis, the size of the spill, weather and potential impacts. If aerial dispersants are utilized, 8 
Attachment 9-A Page 2 

sorties (9,600 gallons) from two of the DC-3 aircrafts and 4 sorties (8,000 gallons) from the 

Basler aircraft would provide a daily dispersant capability of 7,540 barrels. If the conditions are 

favorable for in-situ burning, the proper approvals have been obtained and the proper planning is 

in place, in-situ burning of oil may be attempted. Slick containment boom would be immediately 

called out and on-scene as soon as possible. Offshore response strategies may include attempting 

to skim utilizing CGA spill response equipment, with a total derated skimming capacity of 

359,964 barrels. Temporary storage associated with skimming equipment equals 32,447 barrels. 

If additional storage is needed, various tank barges with a total of 332,000+ barrels of storage 

capacity may be mobilized and centrally located to provide temporary storage and minimize offloading time. Safety is first priority. Air monitoring will be accomplished and operations 

deemed safe prior to any containment/skimming attempts. 

If the spill went unabated, shoreline impact in Cameron Parish, Louisiana would depend upon 

existing environmental conditions. Shoreline protection would include the use of CGA’s near 

shore and shallow water skimmers with a totaled derated skimming capacity of 97,839 barrels. 

Temporary storage associated with skimming equipment equals 1,718 barrels. If additional 

storage is needed, an 80,000+ barrel storage barge and three 23,000 barrel storage barges may be 

mobilized and centrally located to provide temporary storage and minimize off-loading time. 

Onshore response may include the deployment of shoreline boom on beach areas, or protection 

and sorbent boom on vegetated areas. A Letter of Intent from OMI Environmental will ensure 

access to 30,000 feet of 18” shoreline protection boom. Figure 2 outlines individual times 

needed for procurement, load out, travel time to the site and deployment. Strategies would be 

based upon surveillance and real time trajectories that depict areas of potential impact given 

actual sea and weather conditions. The State of Louisiana Initial Oil Spill Response Plan, 

applicable Area Contingency and Geographical Response Plans and Unified Command would be 

consulted to ensure that environmental and special economic resources would be correctly 

identified and prioritized to ensure optimal protection. Shoreline protection strategies depict the 

protection response modes applicable for oil spill clean-up operations. The State of Louisiana 

Initial Oil Spill Response Plan provides detailed shoreline protection strategies for this area, and 

it describes necessary action to keep the oil spill from entering Louisiana’s coastal wetlands, 

based on the assumption that removal of the released oil will be much easier and less damaging 

to fragile coastal ecosystems if done in the open waters of the Gulf of Mexico. Supervisory 

personnel have the option to modify the deployment and operation of equipment allowing a more 

effective response to site-specific circumstances. Whistler’s contract Spill Management Team 

holds a copy of the State of Louisiana Initial Oil Spill Response Plan. 

Based on the anticipated worst case discharge scenario, Whistler can be onsite with contracted 

oil spill recovery equipment with adequate response capacity to contain and recover surface 

hydrocarbons, and prevent land impact, to the maximum extent practicable, within an estimated 

69 hours (based on the equipment’s Effective Daily Recovery Capacity (EDRC)).
Attachment 9-A Page 3 

Initial Response Considerations 

Actual actions taken during an oil spill response will be based on many factors to include but not 

be limited to: 

 Weather 

 Equipment and materials availability 

 Ocean currents and tides 

 Location of the spill 

 Product spilled 

 Amount spilled 

 Environmental risk assessments 

 Trajectory and product analysis 

 Well status, i.e., shut in or continual release 

Whistler will take action to provide a safe, aggressive response to contain and recover as much

of the spilled oil as quickly as it is safe to do so. In an effort to protect the environment, response 

actions will be designed to provide an “in-depth” protection strategy meant to recover as much 

oil as possible as far from environmentally sensitive areas as possible. Safety will take 

precedence over all other considerations during these operations.

Coordination of response assets will normally be supervised by the Operations Section as 

necessary for close quarter vessel response activities. A Simultaneous Operations (SIMOPS) 

unit may be established in the Source Control Section to control operations if events require a 

significant number of large vessels to operate independently, but in coordination with each other. 

This unit would normally monitor the subsurface activities of each vessel (ROV, dispersant 

application, well control support, etc.), as well. 

In addition, these activities will be monitored by the spill management team (SMT) and Unified 

Command via a structured Common Operating Picture (COP) established to track resource and 

slick movement in real time. 

Upon notification of a spill, the following actions will be taken: 

 Information will be confirmed 

 An assessment will be made and initial objectives set 

 OSROs and appropriate agencies will be notified 

 ICS 201, Initial Report Form completed 

 Initial Safety plan will be written and published 

 Unified Command will be established 

o Overall safety plan developed to reflect the operational situation and coordinated 

objectives 

o Areas of responsibility established for Source Control and each surface operational 

site 

o On-site command and control established 
Attachment 9-A Page 4 

Offshore Response Actions 

Equipment Deployment

Surveillance 

 Surveillance Aircraft: within two hours of QI notification, or at first light

 Provide trained observer to provide on site status reports 

 Provide command and control platform at the site if needed 

 Continual surveillance of oil movement by remote sensing systems, aerial photography 

and visual confirmation 

 Continual monitoring of vessel assets using vessel monitoring systems 

Dispersant application assets 

 Put ASI on standby 

 With the FOSC, conduct analysis to determine appropriateness of dispersant application 

(refer to Section 18) 

 Gain FOSC approval for use of dispersants on the surface 

 Deploy aircraft in accordance with a plan developed for the actual situation 

 Coordinate movement of dispersants, aircraft, and support equipment and personnel 

 Confirm dispersant availability for current and long range operations 

 Start ordering dispersant stocks required for expected operations 

Containment boom 

 Call out early and expedite deployment to be on scene ASAP 

 Ensure boom handling and mooring equipment is deployed with boom 

 Provide continuing situational status reports to vessels to expedite their arrival at sites 

that will provide for their most effective containment 

 Use Vessels of Opportunity (VOO) to deploy and maintain boom 

Oceangoing Boom Barge 

 Containment at the source 

 Increased/enhanced skimmer encounter rate 

 Protection booming 

In-situ Burn assets 

 Determine appropriateness of in-situ burn operation in coordination with the FOSC and 

affected SOSC 

 Determine availability of fire boom and selected ignition systems 

 Start ordering fire boom stocks required for expected operations 

 Contact boom manufacturer to provide training if required 

 Determine assets to perform on water operation 

 Build operations into safety plan 

 Conduct operations in accordance with an approved plan 
Attachment 9-A Page 5 

Dedicated off-shore skimming systems 

General 

 Deployed to the highest concentration of oil 

 Assets deployed at safe distance from aerial dispersant and in-situ burn operations 

CGA HOSS Barge 

 Use in areas with heaviest oil concentrations 

 Consider for use in areas of known debris (seaweed, and other floating materials) 

CGA 95’ Fast Response Vessels (FRVs)

 Designed to be a first vessel on scene

 Capable of maintaining the initial Command and Control function for on water recovery 

operations

 24 hour oil spill detection capability 

 Highly mobile and efficient skimming capability 

 Use as far off-shore as safely possible 

CGA FRUs 

 To the area of the thickest oil 

 Use as far off-shore as allowed 

 VOOs 100’ minimum in length 

 VOOs with minimum of 18’ x 38’ or 23’ x 50’ of optimum deck space

 VOOs in shallow water should have a draft of <10 feet when fully loaded 

T&T Koseq Skimming Systems 

 To the area of the thickest oil 

 Use as far off-shore as allowed 

 VOOs with a minimum of 2,000 bbls storage capacity 

 VOOs at least 200’ in length

 VOOs with deck space of 100’ x 40’ to provide space for arms, tanks, and crane

 VOOs for shallow water should be deck barges with a draft of <10 feet when fully loaded 

Storage Vessels 

 Establish availability of CGA contracted assets (See Appendix E) 

 Early call out (to allow for tug boat acquisition and deployment speeds) 

 Phase mobilization to allow storage vessels to arrive at the same time as skimming 

systems 

 Position as closely as possible to skimming assets to minimize offloading time 

Vessels of Opportunity (VOO) 

 Use Whistler’s contracted resources as applicable

 Industry vessels are ideal for deployment of Vessel of Opportunity Skimming Systems 

(VOSS) 
Attachment 9-A Page 6 

 Acquire additional resources as needed 

 Consider use of local assets, i.e. fishing and pleasure craft for ISB operations or boom 

tending 

 Expect mission specific and safety training to be required 

 Plan with the US Coast Guard for vessel inspections 

 Place VOOs in Division or Groups as needed 

 Use organic on-board storage if appropriate 

 Maximize non-organic storage appropriate to vessel limitations 

 Decant as appropriate after approval to do so has been granted 

 Assign bulk storage barges to each Division/Group 

 Position bulk storage barges as close to skimming units as possible 

 Utilize large skimming vessel (e.g. barges) storage for smaller vessel offloading 

 Maximize skimming area (swath) to the optimum width given sea conditions and 

available equipment 

 Maximize use of oleophilic skimmers in all operations, but especially offshore 

 Nearshore, use shallow water barges and shuttle to skimming units to minimize 

offloading time 

 Plan and equip to use all offloading capabilities of the storage vessel to minimize 

offloading time 

Adverse Weather Operations: 

In adverse weather, when seas are > 3 feet, the use of larger recovery and storage vessels, 

oleophilic skimmers, and large offshore boom will be maximized. KOSEQ Arm systems are 

built for rough conditions, and they should be used until their operational limit (9.8’ seas) is met. 

Safety will be the overriding factor in all operations and will cease at the order of the Unified 

Command, vessel captain, or in an emergency, ”stop work” may be directed by any crew 

member. 

Surface Oil Recovery Considerations and Tactics 

(Offshore and Near-shore Operations) 

Maximization of skimmer-oil encounter rate

 Place barges in skimming task forces, groups, etc., to reduce recovered oil offloading 

time

 Place barges alongside skimming systems for immediate offloading of recovered oil 

when practicable 

 Use two vessels, each with heavy sea boom, in an open-ended “V” configuration to 

funnel surface oil into a trailing skimming unit’s organic, V-shaped boom and skimmer 

(see page 7, CGA Equipment Guide Book and Tactic Manual (CGATM) 

 Use secondary vessels and heavy sea boom to widen boom swath beyond normal 

skimming system limits (see page 15, CGATM) 

 Consider night-time operations, first considering safety issues 
Attachment 9-A Page 7 

 Utilize all available advanced technology systems ( IR, X-Band Radar, etc.) to determine 

the location of, and move to, recoverable oil 

 Confirm the presence of recoverable oil prior to moving to a new location 

Maximize skimmer system efficiency 

 Place weir skimming systems in areas of calm seas and thick oil 

 Maximize the use of oleophilic skimming systems in heavier seas 

 Place less mobile, high EDRC skimming systems (e.g. HOSS Barge) in the largest 

pockets of the heaviest oil 

 Maximize onboard recovered oil storage for vessels. 

 Obtain authorization for decanting of recovered water as soon as possible 

 Use smaller, more agile skimming systems to recover streamers of oil normally found 

farther from the source. Place recovered oil barges nearby 

Recovered Oil Storage 

 Smaller barges in larger quantities will increase flexibility for multi-location skimming 

operations 

 Place barges in skimming task forces, groups, etc., to reduce recovered oil offloading 

time

 Procure and deploy the maximum number of portable tanks to support Vessel of 

Opportunity Skimming Systems if onboard storage is not available 

 Maximize use of the organic recovered oil storage capacity of the skimming vessel 

Command, Control, and Communications (C3) 

 Publish, implement, and fully test an appropriate communications plan 

 Design an operational scheme, maintaining a manageable span of control 

 Designate and mark C3 vessels for easy aerial identification 

 Designate and employ C3 aircraft for task forces, groups, etc. 

 Use reconnaissance air craft and Rapid Response Teams (RAT) to confirm the presence 

of recoverable oil 
Attachment 9-A Page 8 

On Water Recovery Group 

When the first skimming vessel arrives on scene, a complete site assessment will be conducted 

before recovery operations begin. Once it is confirmed that the air monitoring readings for O2, 

LEL, H2S, CO, VOC, and Benzene are all within the permissible limits, oil recovery operations 

may begin. 

As skimming vessels arrive, they will be organized to work in areas that allow for the most 

efficient vessel operation and free vessel movement in the recovery of oil. Vessel groups will 

vary in structure as determined by the Operations Section of the Unified Command, but will 

generally consist, at a minimum, of the following dedicated assets: 

 3 to 5 – Offshore skimming vessels (recovery) 

 1 – Tank barge (temporary storage) 

 1 – Air asset (tactical direction) 

 2 – Support vessels (crew/utility for supply) 

 6 to 10 – Boom vessels (enhanced booming ) 

Example (Note: Actual organization of TFs will be dependent on several factors including, asset 

availability, weather, spilled oil migration, currents, etc.) 

The 95’ FRV Breton Island out of Venice arrives on scene and conducts an initial site 

assessment. Air monitoring levels are acceptable and no other visual threats have been observed. 

The area is cleared for safe skimming operations. The Breton Island assumes command and 

control (CoC) of on-water recovery operations until a dedicated non-skimming vessel arrives to 

relieve it of those duties. 

A second 95’ FRV arrives and begins recovery operations alongside the Breton Island. Several 

more vessels begin to arrive, including a third 95’ FRV out of Galveston, the HOSS Barge (High 

Volume Open Sea Skimming System) out of Harvey, a boom barge (CGA 300) with 25,000’ of 

42” auto boom out of Leeville, and 9 Fast Response Units (FRUs) from the load-out location at 

C-Port in Port Fourchon. 

As these vessels set up and begin skimming, they are grouped into task forces (TFs) as directed 

by the Operations Section of the Unified Command located at the command post. 

Initial set-up and potential actions: 

 A 1,000 meter safety zone has been established around the incident location for vessels 

involved in Source Control 

 The HOSS Barge is positioned facing the incident location just outside of this safety zone 

or at the point where the freshest oil is reaching the surface 

 The HOSS Barge engages its Oil Spill Detection (OSD) system to locate the heaviest oil 

and maintains that ability for 24-hour operations 
Attachment 9-A Page 9 

 The HOSS Barge deploys 1,320’ of 67” Sea Sentry boom on each side, creating a swath 

width of 800’ 

 The Breton Island and H.I. Rich skim nearby, utilizing the same OSD systems as the 

HOSS Barge to locate and recover oil 

 Two FRUs join this group and it becomes TF1 

 The remaining 7 FRUs are split into a 2 and 3 vessel task force numbered TF2 and TF3 

 A 95’ FRV is placed in each TF

 The boom barge (CGA 300) is positioned nearby and begins deploying auto boom in 

sections between two utility vessels (1,000’ to 3,000’ of boom, depending on conditions) 

with chain-link gates in the middle to funnel oil to the skimmers 

 The initial boom support vessels position in front of TF2 and TF3 

 A 100,000+ barrel offshore tank barge is placed with each task force as necessary to 

facilitate the immediate offload of skimming vessels 

The initial task forces (36 hours in) may be structured as follows: 

TF 1 

 1 – 95’ FRV 

 1 – HOSS Barge with 3 tugs 

 2 – FRUs 

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 8 – 500’ sections of auto boom with gates

 8 – Boom-towing vessels 

 2 – Support vessels (crew/utility) 

TF 2 

 1 – 95’ FRV 

 4 – FRUs 

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 10 – 500’ sections of auto boom with gates

 10 – Boom-towing vessels 

 2 – Support vessels (crew/utility) 

TF 3 

 1 – 95’ FRV 

 3 – FRUs 

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 8 – 500’ sections of auto boom with gates

 8 – Boom-towing vessels 

 2 – Support vessels (crew/utility) 
Attachment 9-A Page 10 

 

Offshore skimming equipment continues to arrive in accordance with the ETA data listed in 

figure H.3a; this equipment includes 2 AquaGuard skimmers and 11 sets of Koseq Rigid 

Skimming Arms. These high volume heavy weather capable systems will be divided into 

functional groups and assigned to specific areas by the Operations Section of the Unified 

Command. 

At this point of the response, the additional TFs may assume the following configurations: 

TF 4 

 2 – Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1 – AquaGuard Skimmer 

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 2 – Support vessels (crew/utility) 

 6 – 500’ sections of auto boom with gates 

 6 – Boom-towing vessels 

TF 5 

 3 – Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1 – AquaGuard Skimmer 

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 2 – Support vessels (crew/utility) 

 8 – 500’ sections of auto boom with gates 

 8 – Boom-towing vessels 

TF 6 

 3 – Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 2 – Support vessels (crew/utility) 

 6 – 500’ sections of auto boom with gates 

 6 – Boom-towing vessels 

TF 7 

 3 – Sets of Koseq Rigid Skimming Arms w/ associated 200’+ PIDVs

 1 – 100,000+ barrel tank barge and associated tug(s) 

 1 – Dedicated air asset for tactical direction 

 2 – Support vessels (crew/utility) 

 6 – 500’ sections of auto boom with gates 

 6 – Boom-towing vessels 
Attachment 9-A Page 11 

Near Shore Response Actions 

Timing 

 Put near shore assets on standby and deployment in accordance with planning based on 

the actual situation, actual trajectories and oil budgets 

 VOO identification and training in advance of spill nearing shoreline if possible 

 Outfitting of VOOs for specific missions 

 Deployment of assets based on actual movement of oil 

Considerations 

 Water depth, vessel draft 

 Shoreline gradient 

 State of the oil 

 Use of VOOs 

 Distance of surf zone from shoreline 

 Sea state 

 Tides 

 Currents 

Surveillance 

 Provide trained observer to direct skimming operations 

 Continual surveillance of oil movement by remote sensing systems, aerial photography 

and visual confirmation 

 Continual monitoring of vessel assets 

Dispersant Use 

 Dispersants are pre-approved with FOSC approval outside of 3 miles and the 10 meter 

depth curve and requires RRT VI approval inside 3 mile and/or 10 meter curve 

 Generally will not be approved within 3 miles of shore or with less than 10 meters of 

water depth 

 Approval would be at Regional Response Team level (Region 6) 

Dedicated Near Shore skimming systems 

 FRVs 

 56’ shallow water skimmers

 Egmopol and Marco SWS (protected waters) 

 Operate with aerial spotter directing systems to observed oil slicks 

VOO 

 Use Whistler’s contracted resources as applicable

 Industry vessels are usually best for deployment of VOSS 

 Acquire additional resources as needed 

 Consider use of local assets, i.e. fishing and pleasure craft 

 Expect mission specific and safety training to be required 

 Plan with the US Coast Guard for vessel inspections 

 Operate with aerial spotter directing systems to oil patches 
Attachment 9-A Page 12 

Shoreline Protection Operations 

Response Planning Considerations 

 Environmental risk assessments (ERA) to determine priorities for area protection 

 Shoreline Cleanup Assessment Team (SCAT) assessments 

 Time to acquire personnel and equipment and their availability 

 Previous contingency planning contained in the appropriate ACP, Geographic Response 

Plan (GRP), and currently for Louisiana, The State of Louisiana Initial Oil Spill 

Response Plan, Deep Water Horizon, dated 2 May 2010 

Actions 

Placement of boom 

 Position boom in accordance with the ERA based on the actual situation or the 

appropriate ACP or GRP. 

 Assess timing of booming operations to ensure it is where it needs to be at time of 

impact. Consider: 

o Trajectories 

o Weather forecast 

o Oil Impact forecast 

o Verified spill movement 

o Boom, manpower and vessel (shallow draft) availability 

o Near shore boom and support material, (stakes, anchors, line) 

Beach Preparation 

Considerations and Actions 

 Use of a 10 mile go/no go line to determine timing of beach cleaning 

 Shoreline Cleanup and Assessment Team Reports and recommendations 

 Determination of Archeological sites and gaining authority to enter 

 Monitoring of tide tables and weather to determine extent of high tides 

 Pre cleaning of beaches by moving waste above high tide lines to minimize waste 

 Staging of equipment and housing of response personnel as close to the job site as 

possible to maximize on-site work time 

 Boom tending, repair, replacement and security (use of local assets may be advantageous) 

 Constant awareness of weather and oil movement for resource redeployment as necessary 

 In-situ burn may be considered when marshes have been impacted 

 Passive clean up of marshes should considered and appropriate stocks of sorbent boom 

and/or sweep obtained 

 Earthen berms and shoreline protection boom may be considered to protect sensitive 

inland areas 
Attachment 9-A Page 13 

Decanting Strategy 

Recovered oil and water mixtures will typically separate into distinct phases when left in a 

quiescent state. When separation occurs, the relatively clean water phase can be siphoned or 

decanted back to the recovery point with minimal, if any, impact. Decanting therefore increases 

the effective on-site oil storage capacity and equipment operating time. FOSC/SOSC approval 

will be requested prior to decanting operations. This practice is routinely used for oil spill 

recovery. 

CGA Equipment Limitations 

The capability for any spill response equipment, whether a dedicated or portable system, to 

operate in differing weather conditions will be directly in relation to the capabilities of the vessel 

the system in placed on. Most importantly, however, the decision to operate will be based on the 

judgment of the Unified Command and/or the Captain of the vessel, who will ultimately have the 

final say in terminating operations. Skimming equipment listed below may have operational 

limits which exceed those safety thresholds. As was seen in the Deepwater Horizon (DWH) oil 

spill response, vessel skimming operations ceased when seas reached 5-6 feet and vessels were 

often recalled to port when those conditions were exceeded. Systems below are some of the 

most up-to-date systems available and were employed during the DWH spill. 

Boom 3 foot seas, 20 knot winds

Dispersants Winds more than 25 knots

Visibility less than 3 nautical miles

Ceiling less than 1,000 feet.

FRU 8 foot seas

HOSS Barge/OSRB 8 foot seas

Koseq Arms 8 foot seas

OSRV 4 foot seas
Attachment 9-A Page 14 

Environmental Conditions in the GOM

Louisiana is situated between the easterly and westerly wind belts, and therefore, experiences 

westerly winds during the winter and easterly winds in the summer. Average wind speed is 

generally 14-15 mph along the coast. Wave heights average 4 and 5 feet. However, during 

hurricane season, Louisiana has recorded wave heights ranging from 40 to 50 feet high and 

winds reaching speeds of 100 mph. Because much of southern Louisiana lies below sea level, 

flooding is prominent. 

Surface water temperature ranges between 70 and 80 ̊F during the summer months. During the 

winter, the average temperature will range from 50 and 60 ̊F. 

The Atlantic and Gulf of Mexico hurricane season is officially from 1 June to 30 November. 

97% of all tropical activity occurs within this window. The Atlantic basin shows a very peaked 

season from August through October, with 78% of the tropical storm days, 87% of the minor 

(Saffir-Simpson Scale categories 1 and 2) hurricane days, and 96% of the major (Saffir-Simpson 

categories 3, 4 and 5) hurricane days occurring then. Maximum activity is in early to mid 

September. Once in a few years there may be a hurricane occurring "out of season" - primarily in 

May or December. Globally, September is the most active month and May is the least active 

month. 
Attachment 9-A Page 15 

FIGURE 1 

TRAJECTORY BY LAND SEGMENT 

Trajectory of a spill and the probability of it impacting a land segment have been projected 

utilizing Whistler’s WCD and information in the BOEM Oil Spill Risk Analysis Model 

(OSRAM) for the Central and Western Gulf of Mexico available on the BOEM website 

using 30 day impact. The results are tabulated below.

Area/Block OCS-G

Launch

Area

Land Segment and/or 

Resource

Conditional 

Probability (%)

within 30 days

Re-enter 7 existing 

wells (Surface 

Location GC 18 A 

platform) and 

sidetrack to new 

bottom hole locations

GC 18 A

76 miles from shore

G04940 C43 Matagorda, TX

Brazoria, TX

Galveston, TX

Jefferson, TX

Cameron, LA

Vermilion, LA

Iberia, LA

Terrebonne, LA

Lafourche, LA

Plaquemines, LA

2

1

3

2

7

3

1

3

1

2
Attachment 9-A Page 16 

WCD Scenario– BASED ON WELL BLOWOUT DURING DRILLING OPERATIONS (76 miles from shore) 

117,973 bbls of crude oil (Volume considering natural weathering) 

API Gravity 29° 

FIGURE 2 – Equipment Response Time to GC 18 A 

Dispersants/Surveillance

Dispersant/Surveillance Dispersant 

Capacity (gal)

Storage 

Capacity Persons Req. From Hrs to Procure

Hrs to 

Loadout

Travel to 

site Total Hrs

ASI

Basler 67T 2000 NA 2 Houma 2 2 0.6 4.6

DC 3 1200 NA 2 Houma 2 2 0.8 4.8

DC 3 1200 NA 2 Houma 2 2 0.8 4.8

Aero Commander NA NA 2 Houma 2 2 0.6 4.6

Offshore Response

Offshore Equipment No 

Staging EDRC Storage Capacity VOO Persons Required From Hrs to Procure

Hrs to 

Loadout

Hrs to 

GOM

Travel to 

Spill Site

Hrs to 

Deploy

Total 

Hrs

CGA

HOSS Barge 43000 4000 3 Tugs 5 Harvey 7 0 8 9.4 1 25.4

95’ FRV 12342 249 NA 4 Galveston 2 0 2 11 0 15

95’ FRV 12342 249 NA 4 Leeville 2 0 2 4 0 8

95’ FRV 12342 249 NA 4 Venice 2 0 3 5.5 0 10.5

Boom Barge (CGA-300)

42” Auto Boom (25000’) NA NA 1 Tug50 Crew

4 (Barge)

2 (Per Crew) Leeville 12 0 6 12.9 2 32.9

Recovered Oil Storage No 

Staging EDRC Storage Capacity VOO Persons Required From Hrs to Procure

Hrs to 

Loadout

Hrs to 

GOM

Travel to 

Spill Site

Hrs to 

Deploy

Total 

Hrs

Kirby Offshore Marine (available through CGA contract)

RO Barge NA 100000+ 1 Tug 6 Venice 45 0 2 13 0 60

RO Barge NA 100000+ 1 Tug 6 Venice 45 0 2 13 0 60

Enterprise Marine Services LLC (available through contract with CGA)

CTCo 2603 NA 25000 1 Tug 6 Amelia 46 0 2 12 0 60

CTCo 2604 NA 20000 1 Tug 6 Amelia 46 0 2 12 0 60

CTCo 2605 NA 20000 1 Tug 6 Amelia 46 0 2 12 0 60

CTCo 2606 NA 20000 1 Tug 6 Amelia 46 0 2 12 0 60

CTCo 5001 NA 47000 1 Tug 6 Amelia 46 0 2 12 0 60
Attachment 9-A Page 17 
Attachment 9-A Page 18 

Staging Area: Fourchon

Offshore Equipment With 

Staging EDRC Storage Capacity VOO Persons Req. From Hrs to Procure

Hrs to 

Loadout

Travel to 

Staging

Travel to 

Site

Hrs to 

Deploy

Total 

Hrs

CGA

Aqua Guard Triton RBS (2) 45560 4000 2 Utility 12 Galveston 4 12 11.4 7.5 1 35.9

Koseq Skimming Arms (5) 89145 10000 5 Utility 30 Galveston 24 24 11.4 7.5 2 68.9

Koseq Skimming Arms (4) 71316 8000 4 Utility 24 Galliano 24 24 0.5 7.5 2 58

Koseq Skimming Arms (2) 35658 4000 2 Utility 12 Harvey 24 24 2.7 7.5 2 60.2

CGA

FRU (1) + 100 bbl Tank (1) 4251 100 1 Utility 6 Galveston 2 2 11.4 7.5 1 23.9

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Harvey 2 2 2.7 7.5 1 15.2

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Aransas Pass 2 2 16.5 7.5 1 29

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Lake Charles 2 2 6.8 7.5 1 19.3

FRU (2) + 100 bbl Tank (2) 8502 400 2 Utility 12 Leeville 2 2 0.4 7.5 1 12.9

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Morgan City 2 2 2.7 7.5 1 15.2

FRU (2) + 100 bbl Tank (4) 8502 400 2 Utility 12 Venice 2 2 4.7 7.5 1 17.2

Hydro-Fire Boom NA NA 8 Utility 40 Harvey 2 4 2.7 7.5 6 22.2
Attachment 9-A Page 19 

Nearshore Response

Nearshore Equipment No 

Staging EDRC Storage Capacity VOO Persons Required From Hrs to Procure

Hrs to 

Loadout

Hrs to 

GOM

Travel to 

Spill Site

Hrs to 

Deploy

Total 

Hrs

CGA

46’ FRV 5000 65 NA 4 Aransas Pass 2 0 2 11.5 0 15.5

46’ FRV 5000 65 NA 4 Lake Charles 2 0 3 3 0 8

46’ FRV 5000 65 NA 4 Morgan City 2 0 3 6 0 11

46’ FRV 5000 65 NA 4 Venice 2 0 3 12 0 17

Trinity SWS 21500 249 NA 4 Galveston 2 6 N/A 48 1 57

Trinity SWS 21500 249 NA 4 Morgan City 2 6 N/A 48 1 57

Kirby Offshore Marine (available through CGA contract)

RO Barge NA 80000+ 1 Tug 6 Venice 23 0 2 35 0 60

Enterprise Marine Services LLC (available through contract with CGA)

CTCo 2607 NA 23000 1 Tug 6 Amelia 44 0 2 14 0 60

CTCo 2608 NA 23000 1 Tug 6 Amelia 44 0 2 14 0 60

CTCo 2609 NA 23000 1 Tug 6 Amelia 44 0 2 14 0 60

Staging Area: Cameron

Nearshore and Inland Skimmers 

With Staging EDRC Storage Capacity VOO Persons Req. From Hrs to Procure

Hrs to 

Load Out

Travel to 

Staging

Travel to 

Deployment Site

Hrs to 

Deploy

Total 

Hrs

CGA

SWS Egmopol 3000 100 NA 3 Galveston 2 2 3.6 2 1 10.6

SWS Egmopol 3000 100 NA 3 Morgan City 2 2 5.3 2 1 12.3

SWS Marco 3588 20 NA 3 Lake Charles 2 2 1.5 2 1 8.5

SWS Marco 3588 34 NA 3 Leeville 2 2 6.8 2 1 13.8

SWS Marco 3588 34 NA 3 Venice 2 2 9.2 2 1 16.2

Rope Mop 77 2 0 3 Harvey 2 2 7 2 1 14

Foilex Skim Package (TDS 150) 1131 45 NA 3 Lake Charles 2 2 1.5 2 1 8.5

Foilex Skim Package (TDS 150) 1131 45 NA 3 Galveston 2 2 3.6 2 1 10.6

Foilex Skim Package (TDS 150) 1131 45 NA 3 Harvey 2 2 7 2 1 14

3 Weir Skimmers (TDS 250) 12753 135 NA 9 Harvey 2 2 7 2 1 14

4 Drum Skimmer (Magnum 100) 686 100 1 Crew 3 Lake Charles 2 2 1.5 2 1 8.5

4 Drum Skimmer (Magnum 100) 686 100 1 Crew 3 Harvey 2 2 7 2 1 14

2 Drum Skimmer (TDS 118) 240 100 1 Crew 3 Lake Charles 2 2 1.5 2 1 8.5

2 Drum Skimmer (TDS 118) 240 100 1 Crew 3 Harvey 2 2 7 2 1 14
Attachment 9-A Page 20 

Shoreline Protection 

Staging Area: Cameron 

Shoreline Protection 

Boom VOO Persons Req. 

Storage/Warehouse

Location

Hrs to 

Procure

Hrs to 

Loadout

Travel to 

Staging

Travel to 

Deployment Site

Hrs to 

Deploy Total Hrs

OMI Environmental (available through Letter of Intent)

10,000’ 18” Boom 4 Crew 10 New Iberia, LA 1 1 4 2 3 11

10,000’ 18” Boom 4 Crew 10 Houston, TX 1 1 3.8 2 3 10.7

10,000’ 18” Boom 4 Crew 10 Port Arthur, TX 1 1 1.4 2 3 8.4

Wildlife Response EDRC Storage 

Capacity VOO Persons Req. From Hrs to Procure

Hrs to 

Loadout

Travel to 

Staging

Travel to 

Deployment

Hrs to 

Deploy Total Hrs

CGA

Wildlife Support Trailer NA NA NA 2 Harvey 2 2 7 1 2 14

Bird Scare Guns (48) NA NA NA 2 Harvey 2 2 7 1 2 14

Bird Scare Guns (12) NA NA NA 2 Galveston 2 2 3.6 1 2 10.6

Bird Scare Guns (12) NA NA NA 2 Aransas Pass 2 2 9.9 1 2 16.9

Bird Scare Guns (24) NA NA NA 2 Lake Charles 2 2 1.5 1 2 8.5

Bird Scare Guns (24) NA NA NA 2 Leeville 2 2 6.8 1 2 13.8

Response Asset Total

Offshore EDRC 359,964

Offshore Recovered Oil Storage 364,447+

Nearshore / Shallow Water EDRC 97,839

Nearshore / Shallow Water Recovered Oil Storage 150,718+
Whistler Energy II, LLC Section 10 – Pg. 16 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 10 

ENVIRONMENTAL MONITORING INFORMATION 

10.1 MONITORING SYSTEMS 

There are no environmental monitoring systems currently in place or planned for the proposed 

activities. 

10.2 INCIDENTAL TAKES 

There is no reason to believe that any of the endangered species or marine mammals as listed 

in the ESA will be “taken” as a result of the operations proposed under this plan. 

It has been documented that the use of explosives and/or seismic devices can affect marine life. 

Operations proposed in this plan will not be utilizing either of these devices. 

Whistler will adhere to the requirements as set forth in the following documents, as applicable, 

to avoid or minimize impacts to any of the species listed in the Endangered Species Act (ESA) 

as a result of the operations conducted herein: 

NTL No. 2012-BSEE-G01, “Marine Trash and Debris Awareness and Elimination”

NTL No. 2012-JOINT-G01, “Vessel Strike Avoidance and Injured/Dead Protected Species 

Reporting”

NTL No. 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program”

10.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY 

Green Canyon Block 18 is not located in the Flower Garden Banks National Marine Sanctuary; 

therefore, relevant information is not required in this DOCD. 
Whistler Energy II, LLC Section 11 – Pg. 17 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 11 

LEASE STIPULATIONS INFORMATION 

Development activities are subject to the following stipulations attached to Lease OCS-G 04940, 

(surface location) Green Canyon Block 18. 

11.1 MARINE PROTECTED SPECIES 

In accordance with the Federal Endangered Species Act and the Marine Mammal Protection 

Act, Whistler will: 

(a) collect and remove flotsam resulting from activities related to exploration, development, and 

production of this lease; 

(b) post signs in prominent places on all vessels and platforms used as a result of activities 

related to exploration, development, and production of this lease detailing the reasons (legal 

and ecological) why release of debris must be eliminated; 

(c) observe for marine mammals and sea turtles while on vessels, reduce vessel speed to 10 

knots or less when assemblages of cetaceans are observed, and maintain a distance of 90 

meters or greater from whales, and a distance of 45 meters or greater from small cetaceans and 

sea turtles; 

(d) employ mitigation measures prescribed by BOEM/BSEE or the National Marine Fisheries 

Service (NMFS) for all seismic surveys, including the use of an “exclusion zone” based upon the 

appropriate water depth, ramp-up and shutdown procedures, visual monitoring, and reporting; 

(e) identify important habitats, including designated critical habitat, used by listed species (e.g., 

sea turtle nesting beaches, piping plover critical habitat), in oil spill contingency planning and 

require the strategic placement of spill cleanup equipment to be used only by personnel trained 

in less-intrusive cleanup techniques on beaches and bay shores; and 

(f) immediately report all sightings and locations of injured or dead protected species (e.g., 

marine mammals and sea turtles) to the appropriate stranding network. If oil and gas industry 

activity is responsible for the injured or dead animal (e.g., because of a vessel strike), the 

responsible parties should remain available to assist the stranding network. If the injury or death 

was caused by a collision with the lessee’s vessel, the lessee must notify BOEM within 24 hours 

of the strike. 

BOEM and BSEE issue Notices to Lessees (NTLs), which more fully describe measures 

implemented in support of the above-mentioned implementing statutes and regulations, as well 

as measures identified by the U.S. Fish and Wildlife Service and NMFS arising from, among 

others, conservation recommendations, rulemakings pursuant to the MMPA, or consultation. 

The lessee and its operators, personnel, and subcontractors, while undertaking activities 

authorized under this lease, must implement and comply with the specific mitigation measures 

outlined in NTL No. 2012-JOINT-G01, “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting;” NTL No. 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation 

Measures and Protected Species Observer Program;” and NTL No. 2012-BSEE-G01, “Marine 

Trash and Debris Awareness and Elimination.” At the lessee’s option, the lessee, its operators, 
Whistler Energy II, LLC Section 11 – Pg. 18 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

personnel, and contractors may comply with the most current measures to protect species in 

place at the time an activity is undertaken under this lease, including but not limited to new or 

updated versions of the NTLs identified in this paragraph. The lessee and its operators, 

personnel, and subcontractors will be required to comply with the mitigation measures, identified 

in the above referenced NTLs, and additional measures in the conditions of approvals for their 

plans or permits. 
Whistler Energy II, LLC Section 12 – Pg. 19 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 12 

ENVIRONMENTAL MITIGATION MEASURES INFORMATION 

12.1 MEASURES TAKEN TO AVOID, MINIMIZE, AND MITIGATE IMPACTS 

Green Canyon Block 18 (surface location) is not located within Florida; therefore, mitigation 

information is not required for the activities proposed in this plan. 

12.2 INCIDENTAL TAKES 

Whistler will adhere to the requirements as set forth in the following documents, as applicable, 

to avoid or minimize impacts to any of the species listed in the Endangered Species Act (ESA) 

as a result of the operations conducted herein: 

 NTL No. 2012-BSEE-G01, “Marine Trash and Debris Awareness and Elimination”

 NTL No. 2012-JOINT-G01, “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting”

 NTL No. 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and 

Protected Species Observer Program”
Whistler Energy II, LLC Section 13 – Pg. 20 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 13 

RELATED FACILITIES AND OPERATIONS INFORMATION 

13.1 RELATED OCS FACILITIES AND OPERATIONS 

Whistler’s two wells in Green Canyon Block 60 flow via existing 6-inch bulk oil pipeline 

Segments 10999 and 18229 (approximately 7.6 miles in length) to the Green Canyon Block 18 

A platform. The platform is a 30-slot 4 pile platform and processes production from platform 

wells with bottom holes in Green Canyon Block 18 and Ewing Bank 988. Separated and 

measured gas production is transported via existing 10-inch right-of-way gas pipeline Segment 

8411 (approximately 7.06 miles in length) to a 16-inch subsea tie-in located in Ewing Bank 

Block 990 for ultimate delivery into Operations Systems No. 26.5 and 24.0. Separated and 

measured liquid hydrocarbons are transported via existing 10-inch oil right-of-way pipeline 

Segment 7905 (approximately 3.05 miles in length) to a 16-inch subsea tie-in located in Ewing 

Bank Block 989 for ultimate delivery into Operations System No. 29.5. The flowlines will have a 

shut-in time of 45 seconds. 

13.2 TRANSPORTATION SYSTEM 

Produced hydrocarbons will be transported as described above. 

13.3 PRODUCED LIQUID HYDROCARBONS TRANSPORTATION VESSELS 

There will not be any transfers of liquid hydrocarbons other than via pipeline. 
Whistler Energy II, LLC Section 14 – Pg. 21 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 14 

SUPPORT VESSELS AND AIRCRAFT INFORMATION 

14.1 GENERAL 

The most practical, direct route from the shorebase as permitted by weather and traffic 

conditions will be utilized. 

Type

Maximum Fuel 

Tank Capacity

Maximum Number 

in Area at Any 

Time

Trip Frequency 

or Duration

Tug Boat N/A N/A N/A

Anchor Handling Boat N/A N/A N/A

Crew Boat 500 gals 1 7

Supply Boat 500 gals 1 7

Helicopter 560 gals As required

14.2 DIESEL OIL SUPPLY VESSELS 

Size of Fuel Supply 

Vessel

Capacity of Fuel 

Supply Vessel

Frequency of Fuel 

Transfers

Route Fuel Supply 

Vessel Will Take

180’ 1500 1 X weekly Shortest route from 

Shorebase to block

14.3 DRILLING FLUID TRANSPORTATION 

Drilling fluid transportation information is not required to be submitted with this plan. 

14.4 SOLID AND LIQUID WASTE TRANSPORTATION 

A table, “Wastes You Will Transport and/or Dispose of Onshore,” is included as Attachment 14-

A. 

14.5 VICINITY MAP 

A vicinity map showing the location of the activities proposed herein relative to the shoreline 

with the distance of the proposed activities from the shoreline and the primary routes of the 

support vessels and aircraft that will be used when traveling between the onshore support 

facilities and the platform is included as Attachment 14-B. 
Projected generated 

waste

Solid and Liquid Wastes 

transportation 

Type of Waste Composition Transport Method Name/Location of Facility

Amount 

bbl/well Disposal Method

Oil-based drilling fluid or mud N/A N/A N/A N/A N/A

Synthetic-based drilling fluid or mud N/A N/A N/A N/A N/A

Cuttings wetted with Water-based fluid N/A N/A N/A N/A N/A

Cuttings wetted with Synthetic-based fluid N/A N/A N/A N/A N/A

Cuttings wetted with oil-based fluids

N/A N/A N/A 50 Approved onshore 

disposal

Well treatment fluids

Acid blends Deck level holding tanks on offshore 

support velles Galliano Waste, Galliano, LA

1500 Recycled

Well completion fluids

Weighted brines Deck level holding tanks on offshore 

support velles Galliano Waste, Galliano, LA

1500 Recycled

Produced sand Produced sand Cuttings boxes Galliano Waste, Galliano, LA 25 Landfill

trash and debris (Non-Recyclables) Plastic, paper, aluminum Trash basket Galliano Waste, Galliano, LA 10500 Landfill

used oil Used oil 550 tote tank on supply boat Martin Energy, Fouchon, LA 10 Recycled

wash water N/A N/A N/A NA N/A

Oily rags, absorbent pads Rags and oil DOT drums Martin Energy, Fourchon, LA 5 Approved Disposal

trash and debris (Recyclables) Trash and recycleables Trash basket Galliano Waste, Galliano, LA 10 Recycled

Chemical product wastes Chemicals Disposal tanks - 25bbl American Recovery, Houma, LA 100 Recycled

Batteries Batteries Battery basket American Recovery, Houma, LA 0.1 Recycled

Waste Disposal

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

Attachment 14-A

Whistler Energy II, LLC Section 15 – Pg. 22 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 15 

ONSHORE SUPPORT FACILITIES INFORMATION 

15.1 GENERAL 

Name Location Existing/New/Modified

Newpark Base Port Fourchon, Louisiana Existing

15.2 SUPPORT BASE CONSTRUCTION OR EXPANSION 

There will be no new construction of an onshore support base, nor will we expand the existing 

shore base as a result of the operations proposed in this DOCD. 

15.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE 

A support base construction or expansion timetable is not required for the activities proposed in 

this plan. 

15.4 WASTE DISPOSAL 

A table, “Wastes You Will Transport and/or Dispose of Onshore,” is included as Attachment 14-

A. 
Whistler Energy II, LLC Section 16 – Pg. 23 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 16 

COASTAL ZONE MANAGEMENT (CZM) INFORMATION 

Coastal Zone Management Information is not required for the activities proposed in this plan. 
Whistler Energy II, LLC Section 17 – Pg. 24 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 17 

ENVIRONMENTAL IMPACT ANALYSIS (EIA) 

The Environmental Impact Analysis is included as Attachment 17-A.
Attachment 17-A Page 1 

Whistler Energy II, LLC (Whistler)

Revised Development Operations Coordination Document 

Green Canyon Block 18 and Ewing Bank Block 988 

OCS-G 04940 and 05809

(A) IMPACT PRODUCING FACTORS 

ENVIRONMENTAL IMPACT ANALYSIS WORKSHEET 

Environment

Resources

Impact Producing Factors (IPFs)

Categories and Examples

Refer to recent GOM OCS Lease Sale EIS for a more complete list of IPFs

Emissions 

(air, noise, 

light, etc.)

Effluents 

(muds, 

cutting, other 

discharges to 

the water 

column or 

seafloor)

Physical 

disturbances to the 

seafloor (rig or 

anchor 

emplacements, 

etc.)

Wastes sent 

to shore for 

treatment 

or disposal

Accidents 

(e.g., oil 

spills, 

chemical 

spills, H2S 

releases)

Discarded

Trash &

Debris

Site-specific at Offshore 

Location

Designated topographic features (1) (1) (1)

Pinnacle Trend area live bottoms (2) (2) (2)

Eastern Gulf live bottoms (3) (3) (3)

Benthic communities (4)

Water quality X X X

Fisheries X X X

Marine Mammals X(8) X X(8) X

Sea Turtles X(8) X X(8) X

Air quality X(9)

Shipwreck sites (known or 

potential)

X(7)

Prehistoric archaeological sites X(7)

Vicinity of Offshore Location

Essential fish habitat X X X(6)

Marine and pelagic birds X X X

Public health and safety (5)

Coastal and Onshore

Beaches X(6) X

Wetlands X(6)

Shore birds and coastal nesting 

birds

X(6) X

Coastal wildlife refuges X

Wilderness areas X
Attachment 17-A Page 2 

Footnotes for Environmental Impact Analysis Matrix 

1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well or platform site or 

any anchors will be on the seafloor within the: 

o 4-mile zone of the Flower Garden Banks, or the 3-mile zone of Stetson Bank; 

o 1000-m, 1-mile or 3-mile zone of any topographic feature (submarine bank) protected by the Topographic 

Features Stipulation attached to an OCS lease; 

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

o Proximity of any submarine bank (500 ft. buffer zone) with relief greater than 2 meters that is not protected 

by the Topographic Features Stipulation attached to an OCS lease. 

2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinnacle 

Trend) Stipulation attached to an OCS lease. 

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

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

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

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. 

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 a prehistoric site that no impact would 

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

8) All activities that you determine might have an adverse effect on endangered or threatened marine mammals or 

sea turtles or their critical habitats. 

9) Production activities that involve transportation of produced fluids to shore using shuttle tankers or barges. 
Attachment 17-A Page 3 

(B) ANALYSIS 

Site-Specific at Green Canyon Block 18 and Ewing Bank Block 988 

Proposed operations consist of the re-entry into GC 18 (current bottomhole location) #A-23 and 

drill to a new target in EW 988 (new bottomhole location) from the existing GC 18 “A” 

platform. 

Operations will be conducted with a platform rig. 

1. Designated Topographic Features 

Potential IPFs on topographic features include physical disturbances to the seafloor, effluents, 

and accidents. 

Physical disturbances to the seafloor: Green Canyon Block 18 and Ewing Bank Block 988 are 

8 miles from the closest designated Topographic Features Stipulation Block (Ewing-1 Bank); 

therefore, no adverse impacts are expected. 

Effluents: Green Canyon Block 18 and Ewing Bank Block 988 are 8 miles from the closest 

designated Topographic Features Stipulation Block (Ewing-1 Bank); therefore, no adverse 

impacts are expected. 

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the 

proposed activities (refer to statistics in Item 5, Water Quality). Oil spills cause damage to 

benthic organisms only if the oil contacts the organisms. Oil from a surface spill can be driven 

into the water column; measurable amounts have been documented down to a 10 m depth. At 

this depth, the oil is found only at concentrations several orders of magnitude lower than the 

amount shown to have an effect on corals. Because the crests of topographic features in the 

Northern Gulf of Mexico are found below 10 m, no oil from a surface spill could reach their 

sessile biota. Oil from a subsurface spill is not applicable due to the distance of these blocks from 

a topographic area. The activities proposed in this plan will be covered by Whistler’s Regional 

OSRP (refer to information submitted in Section 9). 

There are no other IPFs (including emissions and wastes sent to shore for disposal) from the 

proposed activities, which could impact topographic features. 

2. Pinnacle Trend Area Live Bottoms 

Potential IPFs on pinnacle trend area live bottoms include physical disturbances to the seafloor, 

effluents, and accidents. 
Attachment 17-A Page 4 

Physical disturbances to the seafloor: Green Canyon Block 18 and Ewing Bank Block 988 are 

151 miles from the closest live bottom (pinnacle trend) area; therefore, no adverse impacts are 

expected. 

Effluents: Green Canyon Block 18 and Ewing Bank Block 988 are 151 miles from the closest 

live bottom (pinnacle trend) area; therefore, no adverse impacts are expected. 

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the 

proposed activities (refer to statistics in Item 5, Water Quality). Oil spills have the potential to 

foul benthic communities and cause lethal and sublethal effects on live bottom organisms. Oil 

from a surface spill can be driven into the water column; measurable amounts have been 

documented down to a 10 m depth. At this depth, the oil is found only at concentrations several 

orders of magnitude lower than the amount shown to have an effect on marine organisms. Oil 

from a subsurface spill is not applicable due to the distance of these blocks from a live bottom 

(pinnacle trend) area. The activities proposed in this plan will be covered by Whistler’s Regional 

OSRP (refer to information submitted in Section 9). 

There are no other IPFs (including emissions and wastes sent to shore for disposal) from the 

proposed activities which could impact a live bottom (pinnacle trend) area. 

3. Eastern Gulf Live Bottoms 

Potential IPFs on Eastern Gulf live bottoms include physical disturbances to the seafloor, 

effluents, and accidents. 

Physical disturbances to the seafloor: Green Canyon Block 18 and Ewing Bank Block 988 are 

not located in an area characterized by the existence of live bottoms, and this lease does not 

contain a Live-Bottom Stipulation requiring a photo documentation survey and survey report. 

Effluents: Green Canyon Block 18 and Ewing Bank Block 988 are not located in an area 

characterized by the existence of live bottoms; therefore, no adverse impacts are expected. 

Accidents: It is unlikely that an accidental surface or subsurface spill would occur from the 

proposed activities (refer to statistics in Item 5, Water Quality). Oil spills cause damage to live 

bottom organisms only if the oil contacts the organisms. Oil from a surface spill can be driven 

into the water column; measurable amounts have been documented down to a 10 m depth. At 

this depth, the oil is found only at concentrations several orders of magnitude lower than the 

amount shown to have an effect on marine invertebrates. Oil from a subsurface spill is not 

applicable due to the distance of these blocks from a live bottom area. The activities proposed in 

this plan will be covered by Whistler’s Regional OSRP (refer to information submitted in 

Section 9). 
Attachment 17-A Page 5 

There are no other IPFs (including emissions and wastes sent to shore for disposal) from the 

proposed activities which could impact an Eastern Gulf live bottom area. 

4. Benthic Communities 

There are no IPFs (including emissions, physical disturbances to the seafloor, wastes sent to 

shore for disposal, or accidents) from the proposed activities that could cause impacts to benthic 

communities. 

Operations proposed in this plan are in water depths of 750 feet. High-density benthic 

communities are found only in water depths greater than 984 feet (300 meters); therefore, 

Whistler’s proposed operations in Green Canyon Block 18 and Ewing Bank Block 988 would 

not cause impacts to benthic communities. 

5. Water Quality 

IPFs that could result in water quality degradation from the proposed operations in Green 

Canyon Block 18 and Ewing Bank Block 988 include disturbances to the seafloor, effluents and 

accidents. 

Physical disturbances to the seafloor: Bottom area disturbances resulting from the 

emplacement of drill rigs, the drilling of wells and the installation of platforms and pipelines 

would increase water-column turbidity and re-suspension of any accumulated pollutants, such as 

trace metals and excess nutrients. This would cause short-lived impacts on water quality 

conditions in the immediate vicinity of the emplacement operations. 

Effluents: Levels of contaminants in drilling muds and cuttings and produced water discharges, 

discharge-rate restrictions and monitoring and toxicity testing are regulated by the EPA NPDES 

permit, thereby eliminating many significant biological or ecological effects. Operational 

discharges are not expected to cause significant adverse impacts to water quality. 

Accidents: Oil spills have the potential to alter offshore water quality; however, it is unlikely 

that an accidental surface or subsurface spill would occur from the proposed activities. Between 

1980 and 2000, OCS operations produced 4.7 billion barrels of oil and spilled only 0.001 percent 

of this oil, or 1 bbl for every 81,000 bbl produced. The spill risk related to a diesel spill from 

drilling operations is even less. Between 1976 and 1985, (years for which data were collected), 

there were 80 reported diesel spills greater than one barrel associated with drilling activities. 

Considering that there were 11,944 wells drilled, this is a 0.7 percent probability of an 

occurrence. If a spill were to occur, the water quality of marine waters would be temporarily 

affected by the dissolved components and small oil droplets. Dispersion by currents and 

microbial degradation would remove the oil from the water column and dilute the constituents to 

background levels. Historically, changes in offshore water quality from oil spills have only been 

detected during the life of the spill and up to several months afterwards. Most of the components 

of oil are insoluble in water and therefore float. The activities proposed in this plan will be 
Attachment 17-A Page 6 

covered by Whistler’s Regional Oil Spill Response Plan (refer to information submitted in 

Section 9).

There are no other IPFs (including emissions, physical disturbances to the seafloor, and wastes 

sent to shore for disposal) from the proposed activities which could cause impacts to water 

quality. 

6. Fisheries 

IPFs that could cause impacts to fisheries as a result of the proposed operations in Green Canyon 

Block 18 and Ewing Bank Block 988 include physical disturbances to the seafloor, effluents and 

accidents. 

Physical disturbances to the seafloor: The emplacement of a structure or drilling rig results in 

minimal loss of bottom trawling area to commercial fishermen. Pipelines cause gear conflicts 

which result in losses of trawls and shrimp catch, business downtime and vessel damage. Most 

financial losses from gear conflicts are covered by the Fishermen’s Contingency Fund (FCF). 

The emplacement and removal of facilities are not expected to cause significant adverse impacts 

to fisheries. 

Effluents: Effluents such as drilling fluids and cuttings discharges contain components and 

properties which are detrimental to fishery resources. Moderate petroleum and metal 

contamination of sediments and the water column can occur out to several hundred meters downcurrent from the discharge point. Offshore discharges are expected to disperse and dilute to very 

near background levels in the water column or on the seafloor within 3,000 m of the discharge 

point, and are expected to have negligible effect on fisheries. 

Accidents: An accidental oil spill has the potential to cause some detrimental effects on 

fisheries; however, it is unlikely that such an event would occur from the proposed activities 

(refer to Item 5, Water Quality). The effects of oil on mobile adult finfish or shellfish would 

likely be sublethal and the extent of damage would be reduced to the capacity of adult fish and 

shellfish to avoid the spill, to metabolize hydrocarbons, and to excrete both metabolites and 

parent compounds. The activities proposed in this plan will be covered by Whistler’s Regional 

OSRP (refer to information submitted in Section 9). 

There are no IPFs from emissions, or wastes sent to shore for disposal from the proposed 

activities which could cause impacts to fisheries. 

7. Marine Mammals 

GulfCet II studies revealed that cetaceans of the continental shelf and shelf-edge were almost 

exclusively bottlenose dolphin and Atlantic spotted dolphin. Squid eaters, including dwarf and 

pygmy killer whale, Risso’s dolphin, rough-toothed dolphin, and Cuvier’s beaked whale, 
Attachment 17-A Page 7 

occurred most frequently along the upper slope in areas outside of anticyclones. IPFs that could 

cause impacts to marine mammals as a result of the proposed operations in Green Canyon Block 

18 and Ewing Bank Block 988 include emissions, effluents, discarded trash and debris, and 

accidents. 

Emissions: Noises from drilling activities, support vessels and helicopters may elicit a startle 

reaction from marine mammals. This reaction may lead to disruption of marine mammals’ 

normal activities. Stress may make them more vulnerable to parasites, disease, environmental 

contaminants, and/or predation (Majors and Myrick, 1990). There is little conclusive evidence 

for long-term displacements and population trends for marine mammals relative to noise. 

Effluents: Drilling fluids and cuttings discharges contain components which may be detrimental 

to marine mammals. Most operational discharges are diluted and dispersed upon release. Any 

potential impact from drilling fluids would be indirect, either as a result of impacts on prey items 

or possibly through ingestion in the food chain (API, 1989). 

Discarded trash and debris: Both entanglement in, and ingestion of debris have caused the 

death or serious injury of marine mammals (Laist, 1997; MMC, 1999). The limited amount of 

marine debris, if any, resulting from the proposed activities is not expected to substantially harm 

marine mammals. Operators are prohibited from deliberately discharging debris as mandated by 

MARPOL-Annex V and the Marine Plastic Pollution Research and Control Act, and regulations 

imposed by various agencies including the United States Coast Guard (USCG) and the 

Environmental Protection Agency (EPA). 

Whistler will operate in accordance with the regulations and also avoid accidental loss of solid 

waste items by maintaining waste management plans, manifesting trash sent to shore, and using 

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

Special caution will be exercised when handling and disposing of small items and packaging 

materials, particularly those made of non-biodegradable, environmentally persistent materials 

such as plastic or glass. 

Informational placards will be posted on all vessels and facilities having sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 
Attachment 17-A Page 8 

Accidents: Collisions between support vessels and cetaceans would be unusual events, however 

should one occur, death or injury to marine mammals is possible. Contract vessel operators can 

avoid marine mammals and reduce potential deaths by maintaining a vigilant watch for marine 

mammals and maintaining a safe distance when they are sighted. Vessel crews should use a 

reference guide to help identify the twenty-eight species of whales and dolphins, and the single 

species of manatee that may be encountered in the Gulf of Mexico OCS. Vessel crews must 

report sightings of any injured or dead protected marine mammal species immediately, 

regardless of whether the injury or death is caused by their vessel, to the Marine Mammal and 

Sea Turtle Stranding Hotline at (888) 404-3922, the NMFS Southeast Regional Office at (727) 

824-5312, or the Marine Mammal Stranding Network at (305) 862-2850. In addition, if the 

injury or death was caused by a collision with a contract vessel, the BOEM must be notified 

within 24 hours of the strike by email to protectedspecies@boemre.gov. If the vessel is the 

responsible party, it is required to remain available to assist the respective salvage and stranding 

network as needed. 

Oil spills have the potential to cause sublethal oil-related injuries and spill-related deaths to 

marine mammals. However, it is unlikely that an accidental oil spill would occur from the 

proposed activities (refer to Item 5, Water Quality). Oil spill response activities may increase 

vessel traffic in the area, which could add to changes in cetacean behavior and/or distribution, 

thereby causing additional stress to the animals. The effect of oil dispersants on cetaceans is not 

known. The acute toxicity of oil dispersant chemicals included in Whistler’s OSRP is 

considered to be low when compared with the constituents and fractions of crude oils and diesel 

products. The activities proposed in this plan will be covered by Whistler’s OSRP (refer to 

information submitted in accordance with Section 9).

There are no other IPFs (including physical disturbances to the seafloor) from the proposed 

activities which could impact marine mammals. 

8. Sea Turtles 

IPFs that could cause impacts to sea turtles as a result of the proposed operations include 

emissions, effluents, discarded trash and debris, and accidents. GulfCet II studies sighted most 

loggerhead, Kemp’s ridley and leatherback sea turtles over shelf waters. Historically these 

species have been sighted up to the shelf’s edge. They appear to be more abundant east of the 

Mississippi River than they are west of the river (Fritts et al., 1983b; Lohoefener et al., 1990). 

Deep waters may be used by all species as a transitory habitat. 

Emissions: Noise from drilling activities, support vessels, and helicopters may elicit a startle 

reaction from sea turtles, but this is a temporary disturbance. 

Effluents: Drilling fluids and cuttings discharges are not known to be lethal to sea turtles. Most 

operational discharges are diluted and dispersed upon release. Any potential impact from 

drilling fluids would be indirect, either as a result of impacts on prey items or possibly through 

ingestion in the food chain (API, 1989). 
Attachment 17-A Page 9 

Discarded trash and debris: Both entanglement in, and ingestion of, debris have caused the 

death or serious injury of sea turtles (Balazs, 1985). The limited amount of marine debris, if any, 

resulting from the proposed activities is not expected to substantially harm sea turtles. Operators 

are prohibited from deliberately discharging debris as mandated by MARPOL-Annex V and the 

Marine Plastic Pollution Research and Control Act, and regulations imposed by various agencies 

including the United States Coast Guard (USCG) and the Environmental Protection Agency 

(EPA). Whistler will operate in accordance with the regulations and also avoid accidental loss of 

solid waste items by maintaining waste management plans, manifesting trash sent to shore, and 

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

waste. Special caution will be exercised when handling and disposing of small items and 

packaging materials, particularly those made of non-biodegradable, environmentally persistent 

materials such as plastic or glass. 

Informational placards will be posted on all vessels and facilities having sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 

Accidents: Collisions between support vessels and sea turtles would be unusual events, however 

should one occur, death or injury to sea turtles is possible. Contract vessel operators can avoid 

sea turtles and reduce potential deaths by maintaining a vigilant watch for sea turtles and 

maintaining a safe distance when they are sighted. Vessel crews should use a reference guide to 

help identify the five species of sea turtles that may be encountered in the Gulf of Mexico OCS. 

Vessel crews must report sightings of any injured or dead protected sea turtle species 

immediately, regardless of whether the injury or death is caused by their vessel, to the Marine 

Mammal and Sea Turtle Stranding Hotline at (888) 404-3922, the NMFS Southeast Regional 

Office at (727) 824-5312, or the Marine Mammal Stranding Network at (305) 862-2850. In 

addition, if the injury or death was caused by a collision with a contract vessel, the BOEM must 

be notified within 24 hours of the strike by email to protectedspecies@boemre.gov. If the vessel 

is the responsible party, it is required to remain available to assist the respective salvage and 

stranding network as needed. 

All sea turtle species and their life stages are vulnerable to the harmful effects of oil through 

direct contact or by fouling of their food. Exposure to oil can be fatal, particularly to juveniles 

and hatchlings. However, it is unlikely that an accidental oil spill would occur from the proposed 

activities (refer to Item 5, Water Quality). Oil spill response activities may increase vessel traffic 

in the area, which could add to the possibility of collisions with sea turtles. The activities 

proposed in this plan will be covered by Whistler’s Regional Oil Spill Response Plan (refer to 

information submitted in accordance with Section 9).
Attachment 17-A Page 10 

There are no other IPFs (including physical disturbances to the seafloor) from the proposed 

activities which could impact sea turtles. 

9. Air Quality 

The projected air emissions identified in Section 8 are not expected to affect the OCS air quality 

primarily due to distance to the shore or to any Prevention of Significant Deterioration Class I air 

quality area such as the Breton Wilderness Area. Green Canyon Block 18 and Ewing Bank 

Block 988 are beyond the 200 kilometer (124 mile) buffer for the Breton Wilderness Area and 

are 76 miles from the coastline. Therefore, no special mitigation, monitoring, or reporting 

requirements apply with respect to air emissions. 

Accidents and blowouts can release hydrocarbons or chemicals, which could cause the emission 

of air pollutants. However, these releases would not impact onshore air quality because of the 

prevailing atmospheric conditions, emission height, emission rates, and the distance of Green 

Canyon Block 18 and Ewing Bank Block 988 from the coastline. There are no other IPFs 

(including effluents, physical disturbances to the seafloor, wastes sent to shore for treatment or 

disposal) from the proposed activities which could impact air quality. 

10. Shipwreck Sites (known or potential) 

IPFs that could cause impacts to known or unknown shipwreck sites as a result of the proposed 

operations in Green Canyon Block 18 and Ewing Bank Block 988 are disturbances to the 

seafloor. 

Physical Disturbances to the seafloor: Ewing Bank Block 988 is located within the area 

designated by BOEM as high-probability for occurrence of shipwrecks. Whistler will report to 

BOEM the discovery of any evidence of a shipwreck and make every reasonable effort to 

preserve and protect that cultural resource. 

Accidents: An accidental oil spill has the potential to cause some detrimental effects to 

shipwreck sites if the release were to occur subsea. However, it is unlikely that an accidental oil 

spill would occur from the proposed activities (refer to Item 5, Water Quality). The activities 

proposed in this plan will be covered by Whistler’s Regional Oil Spill Response Plan (refer to 

information submitted in accordance with Section 9).

There are no other IPFs (including emissions, effluents, or wastes sent to shore for treatment or 

disposal) from the proposed activities that could cause impacts to shipwreck sites. 

11. Prehistoric Archaeological Sites 

IPFs that could cause impacts to prehistoric archaeological sites as a result of the proposed 

operations in Green Canyon Block 18 and Ewing Bank Block 988 are physical disturbances to 

the seafloor and accidents (oil spills). 
Attachment 17-A Page 11 

Physical Disturbances to the seafloor: Green Canyon Block 18 and Ewing Bank Block 988 are 

located inside the Archaeological Prehistoric high probability lines. Whistler will report to 

BOEM the discovery of any object of prehistoric archaeological significance and make every 

reasonable effort to preserve and protect that cultural resource. 

Accidents: An accidental oil spill has the potential to cause some detrimental effects to 

prehistoric archaeological sites if the release were to occur subsea. However, it is unlikely that 

an accidental oil spill would occur from the proposed activities (refer to Item 5, Water Quality). 

The activities proposed in this plan will be covered by Whistler’s Regional Oil Spill Response 

Plan (refer to information submitted in accordance with Section 9).

There are no other IPFs (including emissions, effluents, wastes sent to shore for treatment or 

disposal) from the proposed activities that could cause impacts to prehistoric archaeological 

sites. 

Vicinity of Offshore Location 

1. Essential Fish Habitat (EFH) 

IPFs that could cause impacts to EFH as a result of the proposed operations in Green Canyon 

Block 18 and Ewing Bank Block 988 include physical disturbances to the seafloor, effluents and 

accidents. EFH includes all estuarine and marine waters and substrates in the Gulf of Mexico. 

Physical disturbances to the seafloor: The Live Bottom Low Relief Stipulation, the Live 

Bottom (Pinnacle Trend) Stipulation, and the Eastern Gulf Pinnacle Trend Stipulation would 

prevent most of the potential impacts on live-bottom communities and EFH from bottom 

disturbing activities (e.g., anchoring, structure emplacement and removal). 

Effluents: The Live Bottom Low Relief Stipulation, the Live Bottom (Pinnacle Trend) 

Stipulation, and the Eastern Gulf Pinnacle Trend Stipulation would prevent most of the potential 

impacts on live-bottom communities and EFH from operational waste discharges. Levels of 

contaminants in drilling muds and cuttings and produced-water discharges, discharge-rate 

restrictions, and monitoring and toxicity testing are regulated by the EPA NPDES permit, 

thereby eliminating many significant biological or ecological effects. Operational discharges are 

not expected to cause significant adverse impacts to EFH. 

Accidents: An accidental oil spill has the potential to cause some detrimental effects on EFH. 

Oil spills that contact coastal bays and estuaries, as well as OCS waters when pelagic eggs and 

larvae are present, have the greatest potential to affect fisheries. However, it is unlikely that an 

oil spill would occur from the proposed activities (refer to Item 5, Water Quality). The activities 

proposed in this plan will be covered by Whistler’s Regional OSRP (refer to information 

submitted in Section 9).
Attachment 17-A Page 12 

There are no other IPFs (including emissions, or wastes sent to shore for treatment or disposal) 

from the proposed activities which could impact essential fish habitat. 

2. Marine and Pelagic Birds 

IPFs that could impact marine birds as a result of the proposed activities include air emissions, 

accidental oil spills, and discarded trash and debris from vessels and the facilities. 

Emissions: Emissions of pollutants into the atmosphere from these activities are far below 

concentrations which could harm coastal and marine birds. 

Accidents: An oil spill would cause localized, low-level petroleum hydrocarbon contamination. 

However, it is unlikely that an oil spill would occur from the proposed activities (refer to Item 5, 

Water Quality). Marine and pelagic birds feeding at the spill location may experience chronic, 

nonfatal, physiological stress. It is expected that few, if any, coastal and marine birds would 

actually be affected to that extent. The activities proposed in this plan will be covered by 

Whistler’s Regional OSRP (refer to information submitted in Section 9).

Discarded trash and debris: Marine and pelagic birds could become entangled and snared in 

discarded trash and debris, or ingest small plastic debris, which can cause permanent injuries and 

death. Operators are prohibited from deliberately discharging debris as mandated by MARPOLAnnex V and the Marine Plastic Pollution Research and Control Act, and regulations imposed by 

various agencies including the United States Coast Guard (USCG) and the Environmental 

Protection Agency (EPA). Whistler will operate in accordance with the regulations and also 

avoid accidental loss of solid waste items by maintaining waste management plans, manifesting 

trash sent to shore, and using special precautions such as covering outside trash bins to prevent 

accidental loss of solid waste. Special caution will be exercised when handling and disposing of 

small items and packaging materials, particularly those made of non-biodegradable, 

environmentally persistent materials such as plastic or glass. Informational placards will be 

posted on all vessels and facilities having sleeping or food preparation capabilities. All offshore 

personnel, including contractors and other support services-related personnel (e.g. helicopter 

pilots, vessel captains and boat crews) will be indoctrinated on waste procedures, and will view 

the video (or Microsoft PowerPoint presentation), “Think About It” (previously “All Washed 

Up: The Beach Litter Problem”). Thereafter, all personnel will view the marine trash and debris 

training video annually. Offshore personnel will also receive an explanation from Whistler 

management or the designated lease operator management that emphasizes their commitment to 

waste management in accordance with NTL No. 2012-G01. Debris, if any, from these proposed 

activities will seldom interact with marine and pelagic birds; therefore, the effects will be 

negligible. 

There are no other IPFs (including effluents, physical disturbances to the seafloor, or wastes sent 

to shore for treatment or disposal) from the proposed activities which could impact marine and 

pelagic birds. 
Attachment 17-A Page 13 

3. Public Health and Safety Due to Accidents. 

There are no IPFs (emissions, effluents, physical disturbances to the seafloor, wastes sent to 

shore for treatment or disposal or accidents, including an accidental H2S releases) from the 

proposed activities which could cause impacts to public health and safety. In accordance with 

NTL No.’s 2008-G04, 2009-G27, and 2009-G31, sufficient information is included in Section 4

to justify our request that our proposed activities be classified by BSEE as H2S absent. 

Coastal and Onshore 

1. Beaches 

IPFs from the proposed activities that could cause impacts to beaches include accidents (oil 

spills) and discarded trash and debris. 

Accidents: Oil spills contacting beaches would have impacts on the use of recreational beaches 

and associated resources. Due to the distance from shore (76 miles) and the response capabilities 

that would be implemented, no significant adverse impacts are expected. The activities proposed 

in this plan will be covered by Whistler’s Regional OSRP (refer to information submitted in 

Section 9). 

Discarded trash and debris: Trash on the beach is recognized as a major threat to the 

enjoyment and use of beaches. There will only be a limited amount of marine debris, if any, 

resulting from the proposed activities. Operators are prohibited from deliberately discharging 

debris as mandated by MARPOL-Annex V and the Marine Plastic Pollution Research and 

Control Act, and regulations imposed by various agencies including the United States Coast 

Guard (USCG) and the Environmental Protection Agency (EPA). Whistler will operate in 

accordance with the regulations and also avoid accidental loss of solid waste items by 

maintaining waste management plans, manifesting trash sent to shore, and using special 

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

caution will be exercised when handling and disposing of small items and packaging materials, 

particularly those made of non-biodegradable, environmentally persistent materials such as 

plastic or glass. 

Informational placards will be posted on all vessels and facilities having sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 
Attachment 17-A Page 14 

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes 

sent to shore for treatment or disposal) from the proposed activities which could impact beaches. 

2. Wetlands 

IPFs from the proposed activities that could cause impacts to wetlands include accidents (oil 

spills) and discarded trash and debris. 

Accidents: It is unlikely that an oil spill would occur from the proposed activities (refer to Item 

5, Water Quality). Due to the distance from shore (76 miles) and the response capabilities that 

would be implemented, no impacts are expected. The activities proposed in this plan will be 

covered by Whistler’s Regional OSRP (refer to information submitted in Section 9). 

Discarded trash and debris: There will only be a limited amount of marine debris, if any, 

resulting from the proposed activities. Operators are prohibited from deliberately discharging 

debris as mandated by MARPOL-Annex V and the Marine Plastic Pollution Research and 

Control Act, and regulations imposed by various agencies including the United States Coast 

Guard (USCG) and the Environmental Protection Agency (EPA). Whistler will operate in 

accordance with the regulations and also avoid accidental loss of solid waste items by 

maintaining waste management plans, manifesting trash sent to shore, and using special 

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

caution will be exercised when handling and disposing of small items and packaging materials, 

particularly those made of non-biodegradable, environmentally persistent materials such as 

plastic or glass. 

Informational placards will be posted on all vessels and facilities having sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes 

sent to shore for treatment or disposal) from the proposed activities which could impact 

wetlands. 

3. Shore Birds and Coastal Nesting Birds 

Accidents: Oil spills could cause impacts to shore birds and coastal nesting birds. However, it is 

unlikely that an oil spill would occur from the proposed activities (refer to Item 5, Water 

Quality). Given the distance from shore (76 miles) and the response capabilities that would be 
Attachment 17-A Page 15 

implemented, no impacts are expected. The activities proposed in this plan will be covered by 

Whistler’s Regional OSRP (refer to information submitted in Section 9). 

Discarded trash and debris: Coastal and marine birds are highly susceptible to entanglement 

in floating, submerged, and beached marine debris: specifically plastics. Operators are prohibited 

from deliberately discharging debris as mandated by MARPOL-Annex V and the Marine Plastic 

Pollution Research and Control Act, and regulations imposed by various agencies including the 

United States Coast Guard (USCG) and the Environmental Protection Agency (EPA). Whistler 

will operate in accordance with the regulations and also avoid accidental loss of solid waste 

items by maintaining waste management plans, manifesting trash sent to shore, and using special 

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

caution will be exercised when handling and disposing of small items and packaging materials, 

particularly those made of non-biodegradable, environmentally persistent materials such as 

plastic or glass. 

 

Informational placards will be posted on vessels and every facility that has sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes 

sent to shore for treatment or disposal) from the proposed activities that could cause impacts to 

shore birds and coastal nesting birds. 

4. Coastal Wildlife Refuges 

Accidents: An accidental oil spill from the proposed activities could cause impacts to coastal 

wildlife refuges. However, it is unlikely that an oil spill would occur from the proposed activities 

(refer to Item 5, Water Quality). Due to the distance from shore (76 miles) and the response 

capabilities that would be implemented, no impacts are expected. The activities proposed in this 

plan will be covered by Whistler’s Regional OSRP (refer to information submitted in Section 9).

Discarded trash and debris: Operators are prohibited from deliberately discharging debris as 

mandated by MARPOL-Annex V, the Marine Plastic Pollution Research and Control Act and 

regulations imposed by various agencies including the United States Coast Guard (USCG) and 

the Environmental Protection Agency (EPA). Whistler will operate in accordance with the 

regulations and also avoid accidental loss of solid waste items by maintaining waste management 

plans, manifesting trash sent to shore, and using special precautions such as covering outside 

trash bins to prevent accidental loss of solid waste. Special caution will be exercised when 
Attachment 17-A Page 16 

handling and disposing of small items and packaging materials, particularly those made of nonbiodegradable, environmentally persistent materials such as plastic or glass. 

 

Informational placards will be posted on vessels and every facility that has sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes 

sent to shore for treatment or disposal) from the proposed activities that could cause impacts to 

coastal wildlife refuges. 

5. Wilderness Areas 

Accidents: An accidental oil spill from the proposed activities could cause impacts to wilderness 

areas. However, it is unlikely that an oil spill would occur from the proposed activities (refer to 

Item 5, Water Quality). Due to the distance from the nearest designated Wilderness Area (178 

miles) and the response capabilities that would be implemented, no significant adverse impacts 

are expected. The activities proposed in this plan will be covered by Whistler’s Regional OSRP 

(refer to information submitted in Section 9).

Discarded trash and debris: Operators are prohibited from deliberately discharging debris as 

mandated by MARPOL-Annex V, the Marine Plastic Pollution Research and Control Act and 

regulations imposed by various agencies including the United States Coast Guard (USCG) and 

the Environmental Protection Agency (EPA). Whistler will operate in accordance with the 

regulations and also avoid accidental loss of solid waste items by maintaining waste management 

plans, manifesting trash sent to shore, and using special precautions such as covering outside 

trash bins to prevent accidental loss of solid waste. Special caution will be exercised when 

handling and disposing of small items and packaging materials, particularly those made of nonbiodegradable, environmentally persistent materials such as plastic or glass. 

 

Informational placards will be posted on vessels and every facility that has sleeping or food 

preparation capabilities. All offshore personnel, including contractors and other support 

services-related personnel (e.g. helicopter pilots, vessel captains and boat crews) will be 

indoctrinated on waste procedures, and will view the video (or Microsoft PowerPoint 

presentation), “Think About It” (previously “All Washed Up: The Beach Litter Problem”). 

Thereafter, all personnel will view the marine trash and debris training video annually. Offshore 

personnel will also receive an explanation from Whistler management or the designated lease 

operator management that emphasizes their commitment to waste management in accordance 

with NTL No. 2012-G01. 
Attachment 17-A Page 17 

There are no other IPFs (emissions, effluents, physical disturbances to the seafloor, or wastes 

sent to shore for treatment or disposal) from the proposed activities that could cause impacts to 

wilderness areas. 

6. Other Environmental Resources Identified 

There are no other environmental resources identified for this impact assessment. 

(C) IMPACTS ON PROPOSED ACTIVITIES 

The site–specific environmental conditions have been taken into account for the proposed 

activities. No impacts are expected on the proposed activities from site-specific environmental 

conditions.

(D) ENVIRONMENTAL HAZARDS 

During the hurricane season, June through November, the Gulf of Mexico is impacted by an 

average of ten tropical storms (39-73 mph winds), of which six become hurricanes (> 74 mph 

winds). Due to their location in the gulf, Green Canyon Block 18 and Ewing Bank Block 988 

may experience hurricane and tropical storm force winds, and related sea currents. These factors 

can adversely impact the integrity of the operations covered by this plan. A significant storm 

may present physical hazards to operators and vessels, damage exploration or production 

equipment, or result in the release of hazardous materials (including hydrocarbons). 

Additionally, the displacement of equipment may disrupt the local benthic habitat and pose a 

threat to local species. 

The following preventative measures included in this plan may be implemented to mitigate these 

impacts: 

1. Drilling & completion 

a. Secure well 

b. Secure rig / platform 

c. Evacuate personnel 

Drilling activities will be conducted in accordance with NTL No.’s 2008-G09, 2009-G10, and 

2010-N10. 

2. Platform / Structure Installation 

 Operator will not conduct platform / structure installation operations during Tropical 

 Storm or Hurricane threat. 

3. Pipeline Installation 

 Operator will not conduct pipeline installation operations during Tropical Storm or 

 Hurricane threat. 
Attachment 17-A Page 18 

(E) ALTERNATIVES 

No alternatives to the proposed activities were considered to reduce environmental impacts. 

(F) MITIGATION MEASURES 

No mitigation measures other than those required by regulation will be employed to avoid, 

diminish, or eliminate potential impacts on environmental resources. 

(G) CONSULTATION 

No agencies or persons were consulted regarding potential impacts associated with the proposed 

activities. Therefore, a list of such entities has not been provided. 

(H) PREPARER(S) 

Matt Harlan 

J. Connor Consulting, Inc. 

16225 Park Ten Place, Suite 700 

Houston, TX 77084 

(281) 578-3388 

matt.harlan@jccteam.com 

(I) REFERENCES 

Authors: 

American Petroleum Institute (API). 1989. Effects of offshore petroleum operations on cold 

water marine mammals: a literature review. Washington, DC: American Petroleum 

Institute. 385 pp. 

Balazs, G.H. 1985. Impact of ocean debris on marine turtles: entanglement and ingestion. In: 

Shomura, R.S. and H.O. Yoshida, eds. Proceedings, Workshop on the Fate and Impact of 

Marine Debris, 26-29 November 1984, Honolulu, HI. U.S. Dept. of Commerce. NOAA 

Tech. Memo. NOAA-TM-NMFS-SWFC-54. Pp 387-429. 

Burke, C.J. and J.A. Veil. 1995. Potential benefits from regulatory consideration of synthetic 

drilling muds. Environmental Assessment Division, Argonne National Laboratory, 

ANL/EAD/TM-43. 

Daly, J.M. 1997. Controlling the discharge of synthetic-based drilling fluid contaminated 

cuttings in waters of the United States. U.S. Environmental Protection Agency, Office of 

Water. Work Plan, June 24, 1997. 
Attachment 17-A Page 19 

Hansen, D.J. 198l. The relative sensitivity of seabird populations in Alaska to oil pollution. U.S. 

Dept. of the Interior, Bureau of Land Management, Alaska OCS Region, Anchorage. BLMYK-ES-81-006-1792. 

Laist, D.W. 1997. Impacts of marine debris: entanglement of marine life in marine debris 

including a comprehensive list of species with entanglement and ingestion records. In: Coe, 

J.M. and D.B. Rogers, eds. Marine debris: sources, impacts, and solutions. New York, NY: 

Springer-Verlag. Pp. 99-139. 

Majors, A.P. and A.C. Myrick, Jr. 1990. Effects of noise on animals: implications for dolphins 

exposed to seal bombs in the eastern tropical Pacific purse-seine fishery–an annotated 

bibliography. NOAA Administrative Report LJ-90-06. 

Marine Mammal Commission. 1999. Annual report to Congress – 1998. 

Piatt, J.F., C.J. Lensink, W. Butler, M. Kendziorek, and D.R. Nysewander. 1990. Immediate 

impact of the Exxon Valdez oil spill on marine birds. The Auk. 107 (2): 387-397. 

Vauk , G., E. Hartwig, B. Reineking, and E. Vauk-Hentzelt. 1989. Losses of seabirds by oil 

pollution at the German North Sea coast. Topics in Marine Biology. Ros, J.D, ed. Scient. 

Mar. 53 (2-3): 749-754. 

Vermeer, K. and R. Vermeer, 1975 Oil threat to birds on the Canadian west coast. The Canadian 

Field-Naturalist. 89:278-298. 

Although not cited, the following were utilized in preparing this EIA: 

 Hazard Surveys 

 BOEM EIS’s:

o GOM Deepwater Operations and Activities. Environmental Assessment. MMS 2000-001 

o GOM Central and Western Planning Areas Sales 166 and 168 Final Environmental 

Impact Statement. MMS 96-0058. 
Whistler Energy II, LLC Section 18 – Pg. 25 of 25

Supplemental DOCD February 2, 2015 

Ewing Bank Block 988 

OCS-G 05809 

SECTION 18 

ADMINISTRATIVE INFORMATION 

18.1 EXEMPTED INFORMATION DESCRIPTION 

The proposed bottomhole location of the planned well has been removed from the Public 

Information copy of the DOCD as well as any discussions of the target objectives, geologic or 

geophysical data, and any interpreted geology. 

18.2 BIBLIOGRAPHY 

1. Supplemental DOCD (Control No. S-2880); approved December 23, 1992. 

2. Revised DOCD (Control No. R-06208); approved January 21, 2015