UNITED STATES GOVERNMENT MEMORANDUM

To: Public Information (MS 5030)

Plans Section, Office of Field 

Operations (MS 5231)

Public Information copy of Exploration Plan

Control # - N-09745

Type - Initial Exploration Plan

Lease(s) - OCS-G34032 Block - A 588 High Island Area

OCS- Block - A 581 High Island Area

Operator - Walter Oil & Gas Corporation

Wells A and B

+BDLVQBOE4FNJTVCNFSTJCMF

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

Description -

Rig Type -

Subject:

From:

November 14, 2013
Public Information 

August, 2013 

INITIAL EXPLORATION PLAN 

 

Lease Number(s): OCS-G 34032 

Area/Block: High Island Block A-588 

Prospect Name: NA 

Offshore: Texas 

Submitted by: Walter Oil & Gas Corporation 

 1100 Louisiana 

 Suite 200 

 Houston, Texas 77002 

 Paul Rodriguez 

 (713) 659-1221 

 prodriguez@walteroil.com 

Estimated start-up date: December 1, 2013 

Authorized Representative: No. Copies Being Submitted: 

Judy Davidson Proprietary: 1 Copy & CD 

J. Connor Consulting, Inc. Public Info: 1 Copy & CD 

16225 Park Ten Place, Suite 700 

Houston, Texas 77084 For BOEM: 

(281) 578-3388 Plan No. 

judy.davidson@jccteam.com Assigned to: 
Record of Changes 

OCS-G 34032 

High Island Block a-588 

Control Number N-9745

Date Section Page Remarks 

09-05-2013 Section 14 Attachment 14-A Signed Texas CZM Certification 
SECTION ATTACHMENTS

Section 1 Plan Contents 

 1-A OCS Plan Information Form 

 1-B Well Location Plat 

 1-C Bathymetry Map 

 1-D Pay.gov Receipt 

Section 2 General Information

 2-B Blowout Assumptions and Worst Case Discharge Calculations 

Section 3 Geological, Geophysical Information 

 3-D Shallow Hazard Assessment 

Section 6 Wastes and Discharges Information 

 6-A Wastes You Will Generate, Treat and Downhole Dispose or 

Discharge to the GOM 

Section 8 Oil Spill Information 

 8-A Oil Spill Response Discussion 

Section 12 Support Vessels and Aircraft Information 

 12-A Waste You Will Transport and/or Dispose Onshore 

 12-B Vicinity Map 

Section 14 Coastal Zone Management Act Information 

 14-A Coastal Zone Consistency Certification 

Section 15 Environmental Impact Analysis (EIA) 

15-A Environmental Impact Analysis (EIA) 
 

TABLE OF CONTENTS 

SECTION 1 PLAN CONTENTS ..................................................................................... 4

1.1 PLAN INFORMATION............................................................................................ 4

1.2 LOCATION............................................................................................................. 4

1.3 SAFETY AND POLLUTION PREVENTION FEATURES ....................................... 4

1.4 STORAGE TANKS AND PRODUCTION VESSELS .............................................. 5

1.5 POLLUTION PREVENTION MEASURES ............................................................. 5

1.6 ADDITIONAL MEASURES .................................................................................... 5

1.7 COST RECOVERY FEE ........................................................................................ 5

SECTION 2 GENERAL INFORMATION........................................................................ 6

2.1 APPLICATIONS AND PERMITS ........................................................................... 6

2.2 DRILLING FLUIDS ................................................................................................. 6

2.3 NEW OR UNUSUAL TECHNOLOGY .................................................................... 6

2.4 BONDING STATEMENT........................................................................................ 6

2.5 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) ............................................... 6

2.6 DEEPWATER WELL CONTROL STATEMENT .................................................... 6

2.7 BLOWOUT SCENARIO AND WORST CASE DISCHARGE CALCULATIONS ..... 7

SECTION 3 GEOLOGICAL AND GEOPHYSICAL INFORMATION ............................. 8

3.1 GEOLOGICAL DESCRIPTION .............................................................................. 8

3.2 STRUCTURE CONTOUR MAP ............................................................................. 8

3.3 INTERPRETED 2-D and / Or 3-D SEISMIC LINE(S) ............................................. 8

3.4 GEOLOGICAL STRUCTURE CROSS-SECTIONS ............................................... 8

3.5 SHALLOW HAZARDS REPORT ........................................................................... 8

3.7 HIGH-RESOLUTION SEISMIC LINES................................................................... 8

3.8 STRATIGRAPHIC COLUMN ................................................................................. 8

3.9 TIME VERSUS DEPTH TABLES ........................................................................... 8

SECTION 4 HYDROGEN SULFIDE INFORMATION .................................................... 9

4.1 CONCENTRATION ................................................................................................ 9

TOC Pg 1 of 25 
4.2 CLASSIFICATION ................................................................................................. 9

SECTION 5 BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION .... 10

5.1 DEEPWATER BENTHIC COMMUNITIES ........................................................... 10

5.2 TOPOGRAPHIC FEATURES (BANKS) ............................................................... 10

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) .................................. 10

5.4 LIVE BOTTOMS (PINNACLE TREND FEATURES) ............................................ 10

5.5 LIVE BOTTOMS (LOW RELIEF) ......................................................................... 10

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP.............................. 10

5.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS ....................................... 10

5.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND 

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

5.9 ARCHAEOLOGICAL REPORT ............................................................................ 12

5.10 AIR AND WATER QUALITY INFORMATION .................................................... 12

5.11 SOCIOECONOMIC INFORMATION .................................................................. 12

SECTION 6 WASTES AND DISCHARGES INFORMATION ...................................... 13

6.1 PROJECTED GENERATED WASTES ................................................................ 13

6.2 MODELING REPORT .......................................................................................... 13

SECTION 7 AIR EMISSIONS INFORMATION ............................................................ 14

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS .......................... 14

7.2 SUMMARY INFORMATION ................................................................................. 14

SECTION 8 OIL SPILLS INFORMATION.................................................................... 15

8.1 OIL SPILL RESPONSE PLANNING .................................................................... 15

8.2 SPILL RESPONSE SITES ................................................................................... 15

8.3 OSRO INFORMATION ........................................................................................ 15

8.4 WORST CASE SCENARIO DETERMINATION ................................................... 15

8.5 OIL SPILL RESPONSE DISCUSSION ................................................................ 16

SECTION 9 ENVIRONMENTAL MONITORING INFORMATION ................................ 17

9.1 MONITORING SYSTEMS.................................................................................... 17

9.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY ....................... 17

SECTION 10 LEASE STIPULATIONS INFORMATION .............................................. 18

10.1 MARINE PROTECTED SPECIES ..................................................................... 18

TOC Pg 2 of 25 
TOC Pg 3 of 25 

SECTION 11 ENVIRONMENTAL MITIGATION MEASURES INFORMATION ........... 19

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

11.2 INCIDENTAL TAKES ......................................................................................... 19

SECTION 12 SUPPORT VESSELS AND AIRCRAFT INFORMATION ...................... 20

12.1 GENERAL .......................................................................................................... 20

12.2 DIESEL OIL SUPPLY VESSELS ....................................................................... 20

12.3 DRILLING FLUID TRANSPORTATION ............................................................. 20

12.4 SOLID AND LIQUID WASTE TRANSPORTATION ........................................... 20

12.5 VICINITY MAP ................................................................................................... 20

SECTION 13 ONSHORE SUPPORT FACILITIES INFORMATION ............................ 21

13.1 GENERAL .......................................................................................................... 21

13.2 SUPPORT BASE CONSTRUCTION OR EXPANSION ..................................... 21

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE ................ 21

13.4 WASTE DISPOSAL ........................................................................................... 21

SECTION 14 COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION ........ 22

SECTION 15 ENVIRONMENTAL IMPACT ANALYSIS .............................................. 24

SECTION 16 ADMINISTRATIVE INFORMATION ....................................................... 25

16.1 EXEMPTED INFORMATION DESCRIPTION .................................................... 25

16.2 BIBLIOGRAPHY ................................................................................................ 25
Walter Oil & Gas Corporation Section 1 – Pg. 4 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 1 

PLAN CONTENTS 

1.1 PLAN INFORMATION 

Walter Oil & Gas Corporation (Walter) proposes to drill and complete two wells, 

Locations A and B, in High Island Block A-588. Well location A will be drilled with a 

moored semi-submersible rig, and Well Location B will be drilled with a jackup. A rightof-use and easement is being submitted under separate cover for Well Location B's 

surface location in High Island Block A-581. 

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

1.2 LOCATION 

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

proposed wells is included as Attachment 1-B. A Bathymetry Map is included as 

Attachment 1-C which includes water depths and anchor radius. 

1.3 SAFETY AND POLLUTION PREVENTION FEATURES 

Safety of personnel and protection of the environment during the proposed operations is 

one of the primary concerns of Walter. 

The Bureau of Ocean Energy Management (BOEM) mandates that the operations 

described in this Initial EP comply with well control, pollution prevention, construction, 

welding procedures, and training described in BSEE regulations 30 CFR 250 C, D, E, O 

and S; and as further clarified by BSEE Notices to Lessees. 

The Bureau of Safety and Environmental Enforcement (BSEE) conducts periodic 

announced and unannounced onsite inspections of offshore facilities to confirm 

operators are complying with lease stipulations, operating regulatory regulations, 

approved plans, and other conditions; as well as to assure safety and pollution 

prevention requirements are being met. The National Potential Incident of 

Noncompliance (PINC) List serves as the baseline for these inspections. 

U.S. Coast Guard regulations contained in Title 33 CFR Part 144 mandate the 

appropriate life rafts, life jackets, ring buoys, etc. be maintained on the facilities at all 

times. 

U.S. Environmental Protection Agency regulations contained in the NPDES General 

Permit GMG290000 mandate that supervisory and certain designated personnel on-
Walter Oil & Gas Corporation Section 1 – Pg. 5 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

board the facility be familiar with the effluent limitations and guidelines for overboard 

discharges into the receiving waters. 

A description of the drilling unit is included on the OCS Plan Information Form which 

complies with all relevant regulations. Rig specifications will be made part of each 

Application for Permit to Drill. Walter will drill Well Location A with a semi-submersible 

which is equipped with a Surface BOP. Once a rig is contracted, BOP information and 

schematics will be included as a part of the Application for Permit to Drill. 

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 

and S; and as further clarified by BSEE Notices to Lessees, and current policy making 

invoked by the BSEE, Environmental Protection Agency and the U.S. Coast Guard. 

Appropriate life rafts, life jackets, ring buoys, etc., will be maintained on the facility at all 

times. 

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

drains on drilling deck areas to collect all contaminants and debris. 

1.4 STORAGE TANKS AND PRODUCTION VESSELS 

All facility tanks with capacity of 25 barrels or more. 

Type of 

Storage Tank 

Type of 

Facility 

Tank 

Capacity 

(bbls) 

Number

of 

Tanks 

Total 

Capacity 

(bbls) 

Fluid 

Gravity 

(API) 

Fuel Oil (Marine 

Diesel) 

SemiSubmersible Rig 18,000 5 70,000 32.50

Fuel Oil (Marine 

Diesel) Jackup 5,000 3 15,000 32.50

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 

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

detection measures beyond those required by 30 CFR 250. 

1.7 COST RECOVERY FEE 

A pay.gov receipt in the amount of $7,346.00 is included as Attachment 1-D. 
U.S. Department of the Interior

Bureau of Ocean Energy Management OMB Control Number: 1010-0151

OMB Approval Expires: 12/31/14 

OCS PLAN INFORMATION FORM 

General Information 

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

Company Name: Walter Oil & Gas Corporation BOEM Operator Number: 00730 

Address: 1100 Louisiana, Suite 200 Contact Person: Paul Rodriguez/Judy Archer 

 Houston, Texas 77002-5299 Phone Number: 713-659-1221 

E-Mail Address: prodriguez@walteroil.com / jarcher@walteroil.com 

If a service fee is required under 30 CFR 550.125(a), provide the Amount paid 7,346.00 Receipt No. 25AVOFMR NA 

Project and Worst Case Discharge (WCD) Information 

Lease(s): G-34032 Area: HI Block(s) A-588 Project Name (If Applicable): NA 

Objective(s) x Oil x Gas Sulphur Salt Onshore Support Base(s): Freeport, Texas 

Platform / Well Name: B Total Volume of WCD: 66,105 bbls. API Gravity: 320

Distance to Closest Land (Miles): 91 Volume from uncontrolled blowout: 4,495,140 

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

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

Do you propose to use new or unusual technology to conduct your activities? Yes 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 

Exploration drilling Well Location A 12-01-2013 01-16-2014 46 

Well completion Well Location A 01-17-2014 02-08-2014 22 

Exploration drilling Well Location B 02-09-2014 03-27-2014 46 

Well Completion Well Location B 03-28-2014 04-18-2014 22 

Installation or modification of structure 

Installation of production facilities 

Installation of subsea wellheads and/or manifolds 

Installation of lease term pipelines 

Commence production 

Other (Specify and attach description) 

Description of Drilling Rig Description of Structure 

Jackup Drillship Caisson Tension leg platform 

x Gorilla Jackup Platform rig Fixed platform Compliant tower 

x 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) 

Form BOEM- 0137 (December 2011 – Supersedes all previous editions of this form which may not be used.) Page 1 of 4 
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): A Previously reviewed under an approved EP or DOCD? Yes x No 

Is this an existing well or 

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

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

WCD Info For wells, volume of uncontrolled 

blowout (Bbls/Day): 66,105 

For structures, volume of all storage and pipelines 

(Bbls): API Gravity of fluid 320

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

separate lines) 

Lease No. G-34032 OCS 

OCS 

Area Name HI 

Block No. A-588 

Blockline 

Departures 

(in feet) 

N/S Departure 4295' FNL 

N/S Departure F __ L 

N/S Departure F __ L 

N/S Departure F __ L 

E/W Departure 5827.19 FWL 

E/W Departure F __ L 

E/W Departure F __ L 

E/W Departure F __ L 

Lambert X-Y 

coordinates 

 

X: 3,497,463' 

X: 

X: 

X: 

Y: 51,145.00' 

Y: 

Y: 

Y: 

Latitude/ 

Longitude 

Latitude 270

 53' 32.469" N 

Latitude 

Latitude 

Latitude 

Longitude 940 21' 50.411" W 

Longitude 

Longitude 

Longitude 

Water Depth (Feet): 492' MD (Feet): TVD (Feet): MD (Feet): 

MD (Feet): 

MD (Feet): 

TVD (Feet): 

TVD (Feet): 

Anchor Radius (if applicable) in feet: 4,000' TVD (Feet): 

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

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

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

Form BOEM- 0137 (December 2011 – Supersedes all previous editions of this form which may not be used.) Page 2 of 4 
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): B Previously reviewed under an approved EP or DOCD? Yes x No 

Is this an existing well or 

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

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

WCD Info For wells, volume of uncontrolled 

blowout (Bbls/Day): 

For structures, volume of all storage and pipelines 

(Bbls): API Gravity of fluid 

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

separate lines) 

Lease No. OCS 

OCS 

Area Name HI 

Block No. A-581 

Blockline 

Departures 

(in feet) 

N/S Departure 3500' FSL 

N/S Departure F __ L 

N/S Departure F __ L 

N/S Departure F __ L 

E/W Departure 6250' FWL 

E/W Departure F __ L 

E/W Departure F __ L 

E/W Departure F __ L 

Lambert X-Y 

coordinates 

 

X: 3,497,885.81' 

X: 

X: 

X: 

Y: 58,940' 

Y: 

Y: 

Y: 

Latitude/ 

Longitude 

Latitude 270

 54' 49.416" N 

Latitude 

Latitude 

Latitude 

Longitude 940 21' 42.260" W 

Longitude 

Longitude 

Longitude 

Water Depth (Feet): 430' MD (Feet): TVD (Feet): MD (Feet): 

MD (Feet): 

MD (Feet): 

TVD (Feet): 

TVD (Feet): 

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

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

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

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

X: Y: 

Form BOEM- 0137 (December 2011 – Supersedes all previous editions of this form which may not be used.) Page 2 of 4 





Walter Oil & Gas Corporation Section 2 – Pg. 6 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 2 

GENERAL INFORMATION 

2.1 APPLICATIONS AND PERMITS 

Following is a table listing all additional applications/permits which will require approval 

prior to conducting the operations proposed in this plan. 

Application/Permit Issuing Agency Status 

Application for Permit to 

Drill 

BSEE To be submitted 

2.2 DRILLING FLUIDS 

The table below provides information on the types and amounts of the drilling fluids 

Walter plans to use to drill the proposed wells. 

Type of Drilling Fluid Estimated Volume of Drilling Fluid to be 

Used per Well 

Water-based 5,000 bbls 

Oil-based (diesel, minerals) 0 

Synthetic-based 0 

2.3 NEW OR UNUSUAL TECHNOLOGY 

No new or unusual technology is proposed to carry out activities in this in this Initial 

Exploration Plan. 

2.4 BONDING STATEMENT 

The bond requirements for the activities and facilities proposed in this EP are satisfied 

by an areawide bond, furnished and maintained according to 30 CFR 256, subpart I; 

NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds." 

2.5 OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) 

Walter, Operator number 730 has demonstrated oil spill financial responsibility for the 

facilities proposed in this EP according to 30 CFR Part 253; and NTL 2008-N05, 

"Guidelines for Oil Spill Financial Responsibility for Covered Facilities." 

2.6 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. 
Walter Oil & Gas Corporation Section 2 – Pg. 7 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

2.7 BLOWOUT SCENARIO AND WORST CASE DISCHARGE CALCULATIONS 

In accordance with NTL 2010-N06, “Information Requirements for Exploration Plans, 

Development and Production Plans, and Development Operations Coordination 

Documents on the OCS,” the blowout scenario and worst case discharge calculations 

are included as Attachment 2-A. The worst case discharge rate for these proposed 

operations is 66,105 bbls/day. 
Attachment 2-A 

OCS-G 34032, High Island Block A-588 

Blowout Scenario and WCD Data 

Blowout Scenario:

Due to the Gulf slowdown there are currently six (6) moored semi-submersible drilling rigs that could drill 

the relief well. There are no other jack-ups that have the leg lengths to work in this water depth. These 

six (6) moored semi-submersible rig can work in this water depth with capabilities available for relief well 

drilling. It is estimated that a contract could be administered and additional equipment procured to drill 

the relief well in sixty eight days (68). Proximity, availability and safety will be the predominant factor for 

selecting the relief well rig. 

Measure to prevent Blowout:

This well is an exploratory well with close offsets. MWD/PWD will provide downhole pressure information 

to mitigate risk of blowout. The use of MWD will also provide accurate location of the zone if an incident 

occurs. Casing will be set above the pay zone of interest to further mitigate any incident. 

Additional precautions and safety procedures:

1. Complete detailed well design program for drilling operations including mud program and cement 

program. Safety meeting will be conducted every tour to communicate importance of operations. 

2. Maintain mud properties consistent with offset wells. 

3. Flow monitoring equipment for the rigs mud return system with real time data provided to 

supervisory personnel. 

4. Real-time gas monitoring for the purpose of measuring gas units contained in the mud system for 

supervisory personnel. 

5. Drilling breaks monitored and check for flow. In the event of flow, mud weight will be increased to 

control the well. 

6. Monitoring of trip volumes both pulling in and out of the hole. Proper fill up volumes will be 

measured. 

7. Control surge and swab pressures. 

8. Circulate bottoms up before trips to insure the well is stable and free of gas. 

9. Testing of BOP’s at a minimum of every two weeks when rams are changed or BOP’s repaired. 

Measures to reduce the likelihood of a blowout:

1. Contractor personnel (driller and tool pusher) have the authority to shut well(s) in should a well flow 

be encountered. Company personnel will be informed of the situation. 

2. Company personnel will go to the floor immediately to assist Contractor personnel in industry-best 

practices kill procedure. 

3. Proper API casing design and cementing practices using centralizers as recommended by 

simulation to insure centralized casing and 360 degree annular fill up of cement. 
4. Production casing will have two barriers (float collar and float shoe). 

5. Upon bumping the plug in cement operations, floats will be checked. In the event the floats do not 

hold, pressure will be maintained for 6-8 hours, and then shoe tract will be rechecked. Remedial 

cementing or setting of bridge plug will be taken if necessary to isolate the shoe tract. 

6. Run cement bond log to verify cement quality before displacing well with completion fluid. 

Arrangements for drilling relief wells:

1. Review shallow hazards survey to determine positioning of relief well. 

2. Contract and mobilize relief well rig. 

3 Contract relief well directional drilling company and relief well drilling experts. Incorporate relief well 

trajectory and well plan 

4. Prepare drilling program based on optimum rig position relative to targeted wellbore to optimize 

intervention. Incorporate relief well trajectory in well plan. 

5. Well control experts may attempt to board the vessel and contain the blowout from the surface 

provided sufficient safety. HFRS equipment may be required to remove debris and provide fire 

fighting boats for access. 

Note: Walter O&G is a member of Clean Gulf and the Helix Well Containment Group and will employ the 

HFPS (Helix Fast Response System) in the event the is a spill. 

Discussion potential for well to bridge over. 

Walter does not have sufficient information to anticipate that this well would likely bridge over; therefore, 

discussion of the likelihood of the well to bridge over is not included in this plan. 

Walter does not have any empirical data. 

Discussion of likelihood for surface intervention to stop blowout. 

An ongoing operation for surface intervention will work in parallel to the relief well operations. “Well 

Control” experts will board the rig, provide there is sufficient safety, to review the possibility of surface 

containment; or coordinate with relief well operations to contain the blowout. Firefighting boats and 

derrick barges will be employed to control the heat/fire and strip away surface equipment that prohibit 

successful surface intervention. A capping stack/diverter arrangement could potentially be used provided 

wellbore/casing integrity is verified during the operation. 

Relief Well

Rig package constraints 

No constraints. 

Estimated time to drill relief well, including: 

Estimated 68 days 

Time to acquire a rig (days): 4 days 

Time to move rig onsite (days): 14 days 

Drilling time (days): 50 days to drill relief well 

 
Statement whether the possibility of using a nearby platform was considered

. 

No nearby platform. 

Measure to enhance ability to conduct effective and early intervention in the event of a blowout.

Walter Oil & Gas Corporation is a member of Helix Well Control Group and the equipment is on standby 

in case of an incident. 
Walter Oil &Gas Corporation Section 3 – Pg. 8 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 3 

GEOLOGICAL AND GEOPHYSICAL INFORMATION 

3.1 GEOLOGICAL DESCRIPTION 

Proprietary 

3.2 STRUCTURE CONTOUR MAP 

Proprietary

3.3 INTERPRETED 2-D and / Or 3-D SEISMIC LINE(S) 

Proprietary

3.4 GEOLOGICAL STRUCTURE CROSS-SECTIONS 

Proprietary 

3.5 SHALLOW HAZARDS REPORT 

In accordance with NTL 2008-G05, “Shallow Hazards Program” (Extended by NTL 

BOEM 2013-G02, “Extension of Prior Notices to Lessees”), a 3-D seismic shallow 

hazards assessment has been prepared for each proposed surface location, evaluating 

seafloor and subsurface geological and manmade features and conditions that may 

adversely affect drilling operations. One hard copy and one CD of the shallow hazards 

report are being submitted under separate cover. 

3.6 SHALLOW HAZARDS ASSESSMENT 

In accordance with NTL 2008-G05, “Shallow Hazards Program” (Extended by NTL 

BOEM 2013-G02, “Extension of Prior Notices to Lessees”), a 3-D seismic shallow 

hazards assessment has been prepared for each proposed surface location, evaluating 

seafloor and subsurface geological and manmade features and conditions that may 

adversely affect drilling operations. A shallow hazards assessment is included as 

Attachment 3-D. 

3.7 HIGH-RESOLUTION SEISMIC LINES 

High resolution seismic lines are included in the Shallow Hazards Report. 

3.8 STRATIGRAPHIC COLUMN 

Proprietary 

3.9 TIME VERSUS DEPTH TABLES 

Proprietary







Walter Oil & Gas Corporation Section 4– Pg. 9 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 4 

HYDROGEN SULFIDE INFORMATION 

4.1 CONCENTRATION 

Walter does not anticipate encountering any H2S during the proposed operations. 

4.2 CLASSIFICATION 

In accordance with Title 30 CFR 550.215, Walter requests that High Island Block A-588 

be classified by the BOEM as H2S absent. 
Walter Oil & Gas Corporation Section 5– Pg. 10 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 5 

BIOLOGICAL, PHYSICAL AND SOCIOECONOMIC INFORMATION 

5.1 DEEPWATER BENTHIC COMMUNITIES 

High Island Block A-588 is located in less than 300 meters (984') of water; therefore, 

information concerning deepwater benthic communities is not included in this plan. 

5.2 TOPOGRAPHIC FEATURES (BANKS) 

Activities proposed in this EP do not fall within 305 meters (1000 feet) of a topographic 

“no activity zone;” therefore, no map is required per NTL 2009-G39, “Biologically 

Sensitive Underwater Features and Areas.” 

5.3 TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) 

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

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

NTL 2009-G39, “Biologically Sensitive Underwater Features and Areas.” 

5.4 LIVE BOTTOMS (PINNACLE TREND FEATURES) 

High Island Block A-588 is not located within 61 meters (200 feet) of any pinnacle trend 

feature; therefore, a separate bathymetric map is not required per NTL 2009-G39, 

“Biologically Sensitive Underwater Features and Areas.” 

5.5 LIVE BOTTOMS (LOW RELIEF) 

High Island Block A-588 is not located within 30 meters (100 feet) of any pinnacle trend 

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

relief) maps are not required per NTL 2009-G39, “Biologically Sensitive Underwater 

Features and Areas.” 

5.6 POTENTIALLY SENSITIVE BIOLOGICAL FEATURES MAP 

High Island Block A-588 is not located within 30 meters (100 feet) of potentially 

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

required. 

5.7 REMOTELY OPERATED VEHICLE (ROV) SURVEYS 

ROV surveys are not required to be submitted with this plan. 

5.8 THREATENED AND ENDANGERED SPECIES, CRITICAL HABITAT, AND 

MARINE MAMMAL INFORMATION 

In accordance with 30 CFR 550, Subpart B, and further outlined in NTL 2008-G04, 

“Information requirements for Exploration Plans and Development Operations 

Coordination Documents” (Extended by NTL BOEM 2013-G02, “Extension of Prior 
Walter Oil & Gas Corporation Section 5– Pg. 11 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

Notices to Lessees”), and NTL 2012-JOINT-G01,”Vessel Strike Avoidance and 

Injured/Dead Protected Species Reporting,” lessees/operators are required to address 

site-specific information on the presence of federally listed threatened or endangered 

species and critical habitat designated under the ESA and marine mammals protected 

under the Marine Mammal Protection Act (MMPA) in the area of proposed activities 

under this plan. 

There are five (5) species of sea turtles that may be found in the Gulf of Mexico (see 

table below). NOAA fisheries currently list all five of these turtles as endangered (E) or 

threatened (T). 

Species Scientific Name Status Potential 

Presence 

Critical 

Habitat 

Designated in 

the Gulf of 

Mexico 

Lease 

Area 

Coastal 

Sea Turtles 

Loggerhead Carettsa caretta T x x None 

Green Chelonia mydas T,E x x None 

Leatherback Dermochelys coriacea E x x None 

Hawksbill Eretmochelys 

imbricata 

E x x None 

Kemp’s 

Ridley 

Lepidochelys kempli E x x None 

In addition, there are 28 species of marine mammals that may be found in the Gulf of 

Mexico. The table provided below identifies the seven (7) species of marine mammals 

that are listed as endangered or threatened. Currently, there are no designated critical 

habitats for the listed species in the Gulf of Mexico Outer Continental Shelf; however, it 

is possible that one or more of these species could be seen in the area during 

operations. 

Species Scientific Name Status Potential 

Presence 

Critical 

Habitat 

Designated in 

the Gulf of 

Mexico 

Lease 

Area 

Coastal 

Marine Mammals 

Sperm 

Whale 

Physeter 

macrocephalus 

E x -- None 

WesIndian 

Manatee 

Trichechus manatus 

latirostris 

E -- x Florida 

(Peninsular) 

Blue Whale Balaenoptera E x -- None 
Walter Oil & Gas Corporation Section 5– Pg. 12 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

masculus 

Fin Whale Balaenoptera 

physalus 

E x -- None 

Humpback 

Whale 

Megaptera 

novaeangliae 

E x -- None 

NorthAtlantic 

Right Whale 

Eubalaena glacialis E x -- None 

Sei Whale Balaenopiera borealis E x -- None 

5.9 ARCHAEOLOGICAL REPORT 

In accordance with NTL 2005-G07 “Archaeological Surveys and Reports,” and NTL 

2011-JOINT-G01, “Revisions to the List of OCS Lease Blocks Requiring Archaeological 

Resource Surveys and Reports,” an Archaeological Survey Report is being submitted 

under separate cover. 

5.10 AIR AND WATER QUALITY INFORMATION 

Air and water quality information is not required to be included in this plan per NTL 

2008-G04, “Information Requirements for Exploration Plans and Development 

Operations Coordination Documents.” 

5.11 SOCIOECONOMIC INFORMATION 

Socioeconomic Information is not required to be included in this plan per NTL 2008-

G04, “Information Requirements for Exploration Plans and Development Operations 

Coordination Documents.” 
Walter Oil & Gas Corporation Section 6 – Pg. 13 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 6 

WASTES AND DISCHARGES INFORMATION 

6.1 PROJECTED GENERATED WASTES 

Generated wastes that will be treated and disposed of downhole are included in 

Attachment 6-A.

6.2 MODELING REPORT 

Modeling reports are not required to be submitted with this plan. 
please specify if the amount reported is a total or per well amount

Projected generated waste Projected ocean discharges 

Type of Waste Composition Projected Amount Discharge rate Discharge Method Answer yes or no

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

EXAMPLE: Cuttings wetted with synthetic based fluid 

Cuttings generated while 

using synthetic based drilling fluid. X bbl/well X bbl/day/well discharge overboard No

Water-based drilling fluid

Water based drilling fluids 5,000 bbls/well 200 bbls /day/well Discharge overboard No

Cuttings wetted with water-based fluid

Cuttings generated 

while using water 

based drilling fluids 3,800 bbls/well 120 bbls/day/well Discharge overboard No

Will humans be there? If yes, expect conventional waste

EXAMPLE: Sanitary waste water

Sanitary waste from living quarters X bbl/well X bbl/hr/well chlorinate and discharge overboard No

Domestic waste Gray Water 15,128 bbls/well 122 bbls/day/well

(2x) Hamworthy Super Trident 8 biological Sewage Treatment Plants, IMO & MED certified & accepted by USCG for non-US flagged vessels in US waters. Discharge through Port side caisson (cutting chute) below sea level. Note Based on Max POB No

Sanitary waste

Human body treat waste discharged from toilets 1849 bbls/well 15 bbls/day/well

USCG approved treatment tank and discharged, Omni-Pure Model 12MC, discharged overboard No

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

Deck Drainage

Rain water and rig wash 6530 bbls/well

15 bbls/hr /dependent on rainfall

Oil Water Seperator, Recovered Energy, Inc., Model Boss 45T/107 discharge overboard No

ATTACHMENT 6-A

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

Projected 

Downhole 

Disposal

Deck Drainage wash 6530 bbls/well rainfall Model Boss 45T/107, discharge overboard No

Will you conduct well treatment, completion, or workover? 

Well treatment fluids

Viscous and csg wash 

spacers using HEC and 

small amounts sodium 200 bbls/well 50 bbls/day/well discharge overboard No

Well completion fluids Calcium Chloride 500 bbls/well 50 bbld/day/well discharge overboard NoCompletion wash fluids from tank cleaning seawater 200 bbls/well 50 bbls/day/well discharge overboard No

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

Desalinization unit discharge NA 106,764 bbls/well 891 bbls/well/day overboard No

Blowout prevent fluid NA NA NA NA No

Ballast water NA NA NA NA No

Bilge water NA NA NA NA No

Excess cement at seafloor NA NA NA NA NoFire water NA NA NA NA No

Cooling water NA NA NA NA No

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

Produced water NA NA NA NA NA

Will you be covered by an individual or general NPDES permit ? General

NOTE: If you will not have a type of waste, enter NA in the row. 
Walter Oil & Gas Corporation Section 7 – Pg. 14 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 7 

AIR EMISSIONS INFORMATION 

7.1 EMISSIONS WORKSHEETS AND SCREENING QUESTIONS 

 Screen Procedures for EP’s Yes No 

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

with your proposed exploration 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 

Are your proposed exploration activities located east of 87.5° W longitude? 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 for more than 48 continuous 

hours from any proposed well? 

x 

Do you propose to burn produced hydrocarbon liquids? x 

7.2 SUMMARY INFORMATION 

Summary information regarding the peak year emissions that will be generated by and 

associated with the Plan Emissions and Complex Total Emissions are provided in the 

table below. 

Air Pollutant Plan Emission 

Amounts (tons) 

Calculated 

Exemption 

Amounts

(tons)

Calculated 

Complex 

Total 

Emission 

Amounts

(tons) 

Carbon Monoxide (CO) 140.31 68,751.74 140.31 

Particular matter (PM) 18.71 3027.97 18.71 

Sulphur dioxide (SO2) 85.82 3027.97 85.82 

Nitrogen oxides (NOx) 643.08 3027.97 643.08 

Volatile organic compounds (VOC) 19.29 3027.97 19.29 

This information was calculated by: Judy Davidson

 (281) 578-3388 

 judy.davidson@jccteam.com 
Walter Oil & Gas Corporation Section 8 – Pg. 15 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588 (OCS-G 34032) 

SECTION 8 

OIL SPILLS INFORMATION 

8.1 OIL SPILL RESPONSE PLANNING 

All the proposed activities and facilities in the EP will be covered by Walter Oil & Gas 

Corporation's last approved Oil Spill Response Plan (OSRP) dated July, 2011 and last 

approved on April 19, 2013 (OSRP Control Number 0-370). 

8.2 SPILL RESPONSE SITES 

Primary Response Equipment 

Location 

Preplanned Staging Location 

Houma, LA Houma, LA 

Harvey, LA Harvey, LA 

Galveston, TX Galveston, TX 

8.3 OSRO INFORMATION 

Walter's primary equipment provider is Clean Gulf Associates (CGA). CGA will also 

provide closest available personnel, as well as supervisors to operate the equipment. 

8.4 WORST CASE SCENARIO DETERMINATION 

Category Regional OSRP 

WCD 

EP 

WCD 

Type of Activity Drilling Drilling 

Facility Location 

(Area/Block) EW 834 HI A-581 Surface Location 

Facility Designation A B 

Distance to Nearest 

Shoreline (miles) 64 90.93 miles 

Volume 

Storage Tanks (Total) 

Uncontrolled blowout 

Total Volume 

169,488 bbls 

169,488 bbls 

66,105 

66,105 

Type of Oil(s) 

(crude, condensate, 

diesel) 

Crude Oil Crude Oil 

API Gravity 240 320
Walter Oil & Gas Corporation Section 8 – Pg. 16 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588 (OCS-G 34032) 

Walter's WCD was verified and approved in Plan Control Number S-7359. Walter has 

determined that the worst-case scenario from the activities proposed in this EP do not 

supersede the worst-case scenario from our approved Regional OSRP.

Since Walter has the capability to respond to the worst-case spill scenario included in 

our Regional OSRP, and since the worst-case scenario determined for our EP does not 

replace the worst-case scenario in our Regional OSRP, Walter hereby certifies that 

Walter has the capability to respond, to the maximum extent practicable, to a worstcase discharge, or a substantial threat of such a discharge, resulting from the activities 

proposed in our EP. 

8.5 OIL SPILL RESPONSE DISCUSSION 

An oil spill response discussion is included as Attachment 8-A.
Attachment 8-A 

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 66,105 barrels of crude oil with an API gravity of 32°. 

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 BSEE Oil Spill Risk Analysis Model (OSRAM) for the Central and 

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

BSEE OSRAM identifies a 15% probability of impact to the shorelines of Matagorda County, 

Texas within 30 days. Matagorda County stretches from Matagorda Bay, across the Colorado 

River and up to the border of San Bernard Wildlife Refuge (immediately west of the San Bernard 

River). The county includes Matagorda Peninsula on the Gulf coast and Matagorda Bay. This 

area is primarily open beach. However, marshland exists along the east side of Matagorda Bay. 

Several bird rookeries are present around the peninsula. Seagrass is present off of Matagorda 

Peninsula on the bay side. 

Response

Walter 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 23% or 

approximately 15,204 barrels of crude oil would be evaporated/dispersed within 24 hours, with 

approximately 50,901 barrels remaining. 

Spill Response HI A-581, Well Location B Barrels of Oil 

WCD Volume 66,105 

Less 23% natural evaporation/dispersion 15,204 

Remaining volume 50,901 

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

storage equipment available to respond to a spill of approximately 50,901 barrels. 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. 

Walter’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 the size of the spill, 

weather and potential impacts. If aerial dispersants are utilized, 8 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 the 

HOSS Barge, nine Fast Response Units (FRUs), and two sets of Aqua Guard Triton RBS 

skimmers, with a total derated skimming capacity of 126,819 barrels. Temporary storage 

associated with skimming equipment equals 9,700 barrels. If additional storage is needed, a 

47,000 barrel storage barge, a 25,000 barrel storage barge, and two 23,000 barrel storage barges 

may be mobilized and centrally located to provide temporary storage allowing the skimmers to 

stay in the area of operations as much as possible. 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 Matagorda County, Texas 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 8,891 barrels. 

Temporary storage associated with skimming equipment equals 210 barrels. If additional storage 

is needed, a 20,000 barrel storage barge may be mobilized and centrally located to provide 

temporary storage allowing the skimmers to stay in the area of operations as much as possible. 

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

and sorbent boom on vegetated areas. A Master Service Agreement with Miller Environmental 

will ensure access to 88,000 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. Applicable Area Contingency Plans (ACPs), Geographic 

Response Plans (GRPs), 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. Each response mode is schematically represented to show optimum 

deployment and operation of the equipment in areas of environmental concern. Supervisory 

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

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

holds copies of the applicable ACPs and GRPs.. 

Based on the anticipated worst case discharge scenario, Walter 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 

50 hours (based on the equipment’s Effective Daily Recovery Capacity (EDRC)). 
Initial Response Considerations 

Actual actions taken during an oil spill response will be based on many factors which include but 

are not 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 

Walter 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 be supervised by the designation of a SIMOPS group as 

necessary for close quarter vessel response activities. Most often, this group will be used during 

source control events that require a significant number of large vessels operating independently, 

but in coordination to complete a common objective, in a small area and in close coordination 

and support of each other. This group must also monitor the subsurface activities of each vessel 

(ROV, dispersant application, well control support, etc.). The SIMOPS group leader reports to 

the Source Control Section Chief. 

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 will be 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 
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. 

Offshore Response Actions 

Equipment Deployment

Surveillance 

• Surveillance Aircraft will be deployed within two hours of Qualified Individual (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 Airborne Support Inc. (ASI) on standby 

• With the Federal On-Scene Coordinator (FOSC), conduct analysis to determine 

appropriateness of dispersant application 

• 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 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 

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 FRUs 

• To the area of the thickest oil 

• Use as far off-shore as allowed 

• VOOs 140’ – 180’ 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 

Storage Vessels 

• Establish availability of CGA contracted assets 

• 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 Walter’s contracted resources as applicable 

• Industry vessels are usually best for deployment of Vessel of Opportunity Skimming 

Systems (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 

In-situ Burn assets 

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

affected State On-Scene Coordinator (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 

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. 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. 
Near Shore Response Actions 

Timing 

• Place near shore assets on standby and deploy 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 

Equipment Deployment 

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 

• 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) 

Vessel Deployment 

Dedicated Near Shore skimming systems 

• Fast Response Vessels (FRV) 

• Egmopol and Marco Shallow Water Skimmer (SWS) 

• Operate with aerial spotter directing systems to observed oil slicks 

VOO 

• Use Walter’s contracted resources as applicable 

• Industry vessels are usually best for deployment of Vessel of Opportunity Skimming 

Systems (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 
Shoreline Protection Operations 

Response Planning Considerations 

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

• Time to acquire personnel and equipment and their availability 

• Previous contingency planning contained in the appropriate Area Contingency Plan, 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 

• 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 be 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 
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 
Environmental Conditions in the GOM

Prevailing winds, waves and currents along the Texas coast are from the southeast and northeast 

quadrants. Ten to 20 foot waves may occur during hurricanes. The combined effect of the 

winds, surface currents, and waves refracting shoreward produce the prevailing westerly 

longshore currents. 

Tides are semi-diurnal and diurnal, and range in height from less than 1 foot to 2.5 feet. The 

direction, force, and duration of the wind has a considerable effect on the tides and currents. 

Fifteen foot tides may be expected during severe hurricanes and very low tides may accompany 

strong northerlies of long duration. 

Surface water temperature averages slightly less than 90° F and ranges between 80 and 100° F 

during the late summer. During the winter the average is slightly less than 60° F and the range is 

between 35 and 80° 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. 
FIGURE 1 

TRAJECTORY BY LAND SEGMENT 

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

utilizing Walter’s WCD and information in the BSEE Oil Spill Risk Analysis Model 

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

Drill and complete 2 

wells 

HI A-581, 

Well Location B 

90.93 miles from shore 

G34032 W17 Cameron, TX 

Kenedy, TX 

Kleberg, TX 

Nueces, TX 

Aransas, TX 

Calhoun, TX 

Matagorda, TX 

Brazoria, TX 

Galveston, TX 

Jefferson, TX 

Cameron, LA 

Vermilion, LA 

1 

2 

2 

2 

3 

5 

15 

8 

12 

5 

7 

1 
WCD Scenario– BASED ON WELL BLOWOUT DURING DRILLING OPERATIONS (90.93 miles from 

50,901 bbls of crude oil (Volume considering natural weathering) API Gravity 32° 

FIGURE 2 – Equipment Response Time to HI A-581, Well Location B 

Dispersants/Surveillance

Dispersant/Surveillance Dispersant Capacity (gal) Storage Capacity Persons Req. From Hrs to Procure Hrs to Loadout Trave

site 

CGA 

Basler 67T 2000 NA 2 Houma 1 1 1.3 

ASI 

DC 3 1200 NA 2 Houma 1 1 1.7 DC 3 1200 NA 2 Houma 1 1 1.7 Aero Commander NA NA 2 Houma 1 1 1.3 

Offshore Response

Offshore Equipment No 

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

CGA 

HOSS Barge 43000 4000 3 Tugs 5 Harvey 7 0 5 Boom Barge (CGA-300) 42” Auto Boom (25000’) NA NA 1 Tug 50 Crew 4 (Barge) 2 (Per Crew) Leeville 4 0 6 

Recovered Oil Storage No 

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

Enterprise Marine Services LLC (available through contract with CGA) 

CTCo 2603 NA 25000 1 Tug 6 Amelia 4 12 4 CTCo 2607 NA 23000 1 Tug 6 Amelia 4 12 4 CTCo 2608 NA 23000 1 Tug 6 Amelia 4 12 4 CTCo 5001 NA 47000 1 Tug 6 Amelia 4 12 4 
Staging Area: Galveston

Offshore Equipment With 

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

T&T Marine (available through contract with CGA) 

Aqua Guard Triton RBS (2) 45560 4000 2 Utility 12 Galveston 4 12 0 

CGA 

FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Galveston 1 2 0 FRU (1) + 100 bbl Tank (1) 4251 100 1 Utility 6 Harvey 1 2 6.5 FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Ingleside 1 2 4 FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Lake Charles 1 2 3 FRU (2) + 100 bbl Tank (2) 8502 400 2 Utility 12 Leeville 1 2 7 FRU (1) + 100 bbl Tank (2) 4251 200 1 Utility 6 Morgan City 1 2 5.25 FRU (2) + 100 bbl Tank (4) 8502 400 2 Utility 12 Venice 1 2 8 Hydro-Fire Boom NA NA 8 Utility 40 Harvey (HFB) 1 4 6.5 
Nearshore Response

Nearshore Equipment No 

Staging EDRC Storage Capacity VOO Persons Required From Hrs to Procure Hrs to Loadout Hrs to GOM 

CGA 

46’ FRV 5000 65 NA 4 Galveston 1 0 0 

Enterprise Marine Services LLC (available through contract with CGA) 

CTCo 2604 NA 20000 1 Tug 6 Amelia 4 12 4 

Staging Area: Galveston

Nearshore and Inland Skimmers 

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

Dep

CGA 

SWS Egmopol 3000 100 NA 3 Galveston 1 2 0 Foilex Skim Package (TDS 150) 891 45 NA 3 Galveston 1 2 0 
Shoreline Protection 

Staging Area: Galveston 

Shoreline Protection Boom VOO Persons Req. Storage/Warehouse Location Hrs to Procure Hrs to Loadout Travel to Staging Travel 

Deploym

Miller Environmental (available through MSA) 

14,000’ 18” Boom 6 Crew 12 Sulphur, LA .5 1 2.75 2 14,000’ 18” Boom 6 Crew 12 Beaumont, TX .5 1 2 2 60,000’ 18” Boom 10 Crew 20 Corpus Christi, TX .5 2 4.25 2 

Beach Boom EDRC Storage Capacity VOO Persons Req. From Hrs to Procure Hrs to Loadout Travel to Staging T

Dep

CGA 

Beach Boom (2000’) NA NA NA 6 Galveston 1 2 0 Beach Boom (1000’) NA NA NA 4 Ingleside 1 2 4 Beach Boom (2000’) NA NA NA 6 Pascagoula 1 2 7.5 

Wildlife Response EDRC Storage Capacity VOO Persons Req. From Hrs to Procure Hrs to Loadout Travel to Staging T

Dep

CGA 

Wildlife Support Trailer NA NA NA 2 Houma 1 2 6 Bird Scare Guns (24) NA NA NA 2 Belle Chasse 1 2 6.5 Bird Scare Guns (12) NA NA NA 2 Galveston 1 2 0 Bird Scare Guns (24) NA NA NA 2 Houma 1 2 6 Bird Scare Guns (12) NA NA NA 2 Ingleside 1 2 4 Bird Scare Guns (24) NA NA NA 2 Lake Charles 1 2 3 Bird Scare Guns (24) NA NA NA 2 Pascagoula 1 2 7.5 

Response Asset Total 

Offshore EDRC 126,819 

Offshore Recovered Oil Storage 127,700 

Nearshore / Shallow Water EDRC 8,891 

Nearshore / Shallow Water Recovered Oil Storage 20,210 
Walter Oil & Gas Corporation Section 9 – Pg. 17 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 9 

ENVIRONMENTAL MONITORING INFORMATION 

9.1 MONITORING SYSTEMS 

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

proposed activities. 

9.2 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. 

Walter 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 2012-JOINT-G01, “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting” 

• NTL 2012 BSEE G01, "Marine Trash and Debris Awareness and Elimination" 

• NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures 

and Protected Species Observer Program” 

9.3 FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY 

High Island Block A-588 is not located in the Flower Garden Banks National Marine 

Sanctuary; therefore, the requested information is not required in this EP. 
Walter Oil & Gas Corporation Section 10 – Pg. 18 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 10 

LEASE STIPULATIONS INFORMATION 

Exploration activities are subject to the following stipulation attached to High Island 

Block A-588. 

10.1 MARINE PROTECTED SPECIES 

The Marine Protected Species lease stipulation is meant to reduce the potential taking 

of marine protected species. Walter will operate in accordance with NTL 2012-JOINTG01, “Vessel Strike Avoidance and Injured/Dead Protected Species Reporting,” to 

minimize the risk of vessel strikes to protected species and report observations of 

injured or dead protected species, and the prevention of intentional and/or accidental 

introduction of debris into the marine environment.
Walter Oil & Gas Corporation Section 11 – Pg. 19 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 11 

ENVIRONMENTAL MITIGATION MEASURES INFORMATION 

11.1 MEASURES TAKEN TO AVOID, MINIMIZE, AND MITIGATE IMPACTS 

High Island Block A-588 is not located offshore Florida; therefore, the information 

requested is not required in this plan. 

11.2 INCIDENTAL TAKES 

Walter 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 2012-JOINT -G01, “Vessel Strike Avoidance and Injured/Dead Protected 

Species Reporting” 

• NTL 2012 BSEE G01, "Marine Trash and Debris Awareness and Elimination" 

• NTL 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures 

and Protected Species Observer Program” 
Walter Oil & Gas Corporation Section 12– Pg. 20 of 25 

Initial Exploration Plan August, 2013

High island Block A-588, OCS-G 34032 

SECTION 12 

SUPPORT VESSELS AND AIRCRAFT INFORMATION 

12.1 GENERAL 

The most practical, direct route from the shore base 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 Boats 3000 bbls 3 2 days 

Anchor Handling Boat 1500 bbls 2 As needed 

Crew Boat 500 bbls 1 4 trips/week 

Supply Boat 500 bbls 1 2 trips/week 

Helicopters 560 bbls 1 As needed 

12.2 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 Once per week Shortest route from 

Shore base to 

block. 

12.3 DRILLING FLUID TRANSPORTATION 

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

12.4 SOLID AND LIQUID WASTE TRANSPORTATION 

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

Attachment 12-A. 

12.5 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 drilling rig is included as Attachment 12-B.
please specify whether the amount reported is a total or per well

Projected generated 

waste

Solid and Liquid 

Wastes transportation 

Type of Waste Composition Transport Method

Name/Location of Facility Amount 

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

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

Below deck storage tanks on offshore support vessels

Newpark, Fourchon, Louisiana X bbl/well 

No spent drilling fluids or cuttings will be disposed of onshore. NA NA NA N

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

Produced sand NA NA NA NEXAMPLE: trash and debris (recylables) Plastic, paper, aluminum barged in a storage bin ARC, New Iberia, LA X lb/well 

Trash and debris While drilling Paper & Plastic

Garbage bags on Supply or Crew Boat

EPS Dock, Fourchon, LA

121 bags at bag/per wel

Rags & Filters

Oily rags/absorbent pads, used oil filters 19 DOT Drums on Supply boat PSC Houston, Texas 22 drums

While Drilling Paint solvents

Waste Dis

ATTACHMENT 12-A

 WASTES YOU WILL TRANSPORT AND /OR DISPOSE OF ONSHORE 

Will you have additional wastes that are not permitted for discharge? If yes, fill in the appropriate rows. 

Chemical product wastes

While Drilling-Paint, solvents, 

light bulbs 19 DOT Drums on Supply boat PSC Houston, Texas 300 lbs.

Used Oil Used engine oil

550 gal portable totes on Supply boat

Simons Petroleum Oklahoma City, OK 10 totes

Cooking Oil Used cooking oil 5 gal jugs on supply boat PSC Houston, Texas 9 - 5 gals. J

Freon Used freon 5 gal cylinders on supply boat PSC Houston, Texas 

1 - 5 gals. C

w

Batteries Batteries 5 gallon drum on supply boat PSC Houston, Texas 10 ga

NOTE: If you will not have a type of waste, enter NA in the row. 


Walter Oil & Gas Corporation Section 13 – Pg. 21 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588 (OCS-G 34032) 

SECTION 13 

ONSHORE SUPPORT FACILITIES INFORMATION 

13.1 GENERAL 

Name of Shore base Location Existing/New/Modified 

Martin Midstream Freeport, Texas Existing 

13.2 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 EP. 

13.3 SUPPORT BASE CONSTRUCTION OR EXPANSION TIMETABLE 

A support base construction or expansion timetable is not required for this plan. 

13.4 WASTE DISPOSAL 

The Table, “Wastes You Will Transport and/or Dispose of Onshore," is included as

Attachment 12-A. 
Walter Oil & Gas Corporation Section 14 – Pg. 22 of 25 

Initial Exploration Plan August, 2013 

High island Block A-588, OCS-G 34032 

SECTION 14 

COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION 

As authorized by the Federal Coastal Zone Management Act (CZMA), the State of 

Texas developed a Coastal Management Program (CMP) to allow for the review of 

proposed Federal license and permit activities affecting any coastal use or resource, in 

or outside of the Texas Coastal Zone.

The OCS related oil and gas exploratory and development activities having potential 

impact on the Texas Coastal Zone are based on the location of the proposed facilities, 

access to those sites, best practical techniques for drilling locations, drilling equipment 

guidelines for the prevention of adverse environmental effects, effective environmental 

protection, emergency plans and contingency plans. 

Below are topics found in other sections of the plan and have been cross referenced for 

ease in locating: 

Topic Cross Reference Comments 

Construction, Operation and 

Maintenance of Oil and Gas 

Exploration and Production 

Facilities 

1 Plan Contents 

2 General 

Discharges of Wastewater 

and Disposal of Waste from 

Oil and Gas Exploration and 

Production Activities 

6 Wastes and Discharges 

7 Air Emissions 

8 Oil Spill 

12 Support Vessels and Aircraft 

13 Onshore Support Facilities 

Construction and Operation 

of Solid Waste Treatment, 

Storage, and Disposal 

Facilities 

6 Wastes and Discharges 

12 Support Vessels and Aircraft 

13 Onshore Support Facilities 

Prevention, Response, and 

Remediation of Oil Spills 

8 Oil Spill 

5 Biological, Physical, 

Socioeconomic 

15 Environmental Impact Analysis 

Discharge of Municipal and 

Industrial Waste Water to 

Coastal Waters 

6 Wastes and Discharges 

Development in Critical 

Areas 

5 Biological, Physical and 

Socioeconomic 
Walter Oil & Gas Corporation Section 14 – Pg. 23 of 25 

Initial Exploration Plan August, 2013 

High island Block A-588, OCS-G 34032 

10 Lease Stipulations 

11 Environmental Mitigation 

13 Onshore Support Facilities 

15 Environmental Impact Analysis 

Construction of Waterfront 

Facilities and Other 

Structures on Submerge 

lands 

2 General 

7 Air Emissions 

13 Onshore Support Facilities 

15 Environmental Impact Analysis 

Dredging and Dredged 

Material Disposal and 

Placement 

13 Onshore Support Facilities 

Construction in the Beach / 

Dune System 

13 Onshore Support Facilities 

Alteration of Coastal 

Historic Areas 

5 Biological, Physical, and 

Socioeconomic 

15 Environmental Impact Analysis 

Transportation 13 Onshore Support Facilities 

Emission of Air Pollutants 7 Air Emissions 

8 Oil Spill 

15 Environmental Impact Analysis 

Appropriations of Water There will be no 

fresh water 

appropriations as a 

result of our 

operations 

A certificate of Coastal Zone Management Consistency for the state of Texas is 

included as Attachment 14-A. 


Walter Oil & Gas Corporation Section 15 – Pg. 24 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 15 

ENVIRONMENTAL IMPACT ANALYSIS 

An Environmental Impact Analysis for High island Block A-588 is included as 

Attachment 15-A. 
Attachment 15-A 

Initial Exploration Plan 

High Island Block A-588 

OCS-G 34032 

(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) 

(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 

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. 
(B) ANALYSIS 

Site-Specific at High Island Block A-588 

Proposed operations consist of the drilling and completion of two locations (Locations A & B). 

Operations will be conducted with a Jack-Up rig and a Semi-Submersible rig. 

1. Designated Topographic Features 

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

and accidents. 

Physical disturbances to the seafloor: High Island Block A-588 is 6 miles from the closest 

designated Topographic Features Stipulation Block (Applebaum Bank); therefore, no adverse 

impacts are expected. 

Effluents: High Island Block A-588 is 6 miles from the closest designated Topographic 

Features Stipulation Block (Applebaum 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 Walter’s Regional 

OSRP (refer to information submitted in Appendix H). 

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. 

Physical disturbances to the seafloor: High Island Block A-588 is 368 miles from the closest 

live bottom (pinnacle trend) area; therefore, no adverse impacts are expected. 
Effluents: High Island Block A-588 is 368 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 Walter’s Regional 

OSRP (refer to information submitted in Appendix H). 

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: High Island Block A-588 is 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: High Island Block A-588 is 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 Walter’s Regional OSRP (refer to information submitted in 

Appendix H). 

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 492 feet. High-density benthic 

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

Walter’s proposed operations in High Island Block A-588 would not cause impacts to benthic 

communities. 

5. Water Quality 

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

Block A-588 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 

covered by Walter’s Regional Oil Spill Response Plan (refer to information submitted in 

Appendix H). 
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 High Island 

Block A-588 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 Walter’s Regional 

OSRP (refer to information submitted in Appendix H). 

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, 

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 High Island Block A588 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). 

Walter 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 Walter 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 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 Walter’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 Walter’s OSRP (refer to information 

submitted in accordance with Appendix H). 

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). 

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). Walter 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 Walter 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 Walter’s Regional Oil Spill Response Plan (refer to 

information submitted in accordance with Appendix H). 

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 Appendix G 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. High Island Block A-588 is beyond 

the 200 kilometer (124 mile) buffer for the Breton Wilderness Area and is 90.93 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 High 

Island Block A-588 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 impact known or unknown shipwreck sites as a result of the proposed operations 

in High Island Block A-588 include disturbances to the seafloor and accidents (oil spill). High 

Island Block A-588 is not located in or adjacent to an OCS block designated by BOEM as 

having a high probability for occurrence of shipwrecks. Walter will report to BOEM the 

discovery of any evidence of a shipwreck and make every reasonable effort to preserve and 

protect that cultural resource. There are no other IPFs (including emissions, effluents, wastes sent 

to shore for treatment or disposal, or accidents) from the proposed activities which could impact 

shipwreck sites. 

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 Walter’s Regional Oil Spill Response Plan (refer to 

information submitted in accordance with Appendix H). 

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 High Island Block A-588 are physical disturbances to the seafloor and accidents 

(oil spills). 

Physical Disturbances to the seafloor: High Island Block A-588 is located inside the 

Archaeological Prehistoric high probability lines. Walter 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 Walter’s Regional Oil Spill Response 

Plan (refer to information submitted in accordance with Appendix H). 

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 High Island Block 

A-588 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 Walter’s Regional OSRP (refer to information submitted 

in Appendix H). 

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 

Walter’s Regional OSRP (refer to information submitted in Appendix H). 

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). Walter 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 Walter 

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. 
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 Appendix 

D 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 (90.93 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 Walter’s Regional OSRP (refer to information 

submitted in Appendix H). 

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). Walter 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 Walter 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 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 (90.93 miles) and the response capabilities that 

would be implemented, no impacts are expected. The activities proposed in this plan will be 

covered by Walter’s Regional OSRP (refer to information submitted in Appendix H). 

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). Walter 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 Walter 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 (90.93 miles) and the response capabilities that would be 
implemented, no impacts are expected. The activities proposed in this plan will be covered by 

Walter’s Regional OSRP (refer to information submitted in Appendix H). 

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). Walter 

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 Walter 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 (90.93 miles) and the response 

capabilities that would be implemented, no impacts are expected. The activities proposed in this 

plan will be covered by Walter’s Regional OSRP (refer to information submitted in Appendix 

H). 

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). Walter 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 Walter 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 (330 

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 Walter’s Regional OSRP 

(refer to information submitted in Appendix H).

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). Walter 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 Walter 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 

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 its location in the gulf, High Island Block A-588 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. Structure Installation 

 Operator will not conduct structure installation operations during Tropical Storm or 

 Hurricane threat. 

(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. 

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. 
 Walter Oil & Gas Corporation Section 16 – Pg. 25 of 25 

Initial Exploration Plan August, 2013 

High Island Block A-588, OCS-G 34032 

SECTION 16 

ADMINISTRATIVE INFORMATION 

16.1 EXEMPTED INFORMATION DESCRIPTION 

The proposed bottom-hole locations of the planned wells have been removed from the 

Public Information copy of the EP as well as any discussions of the target objectives, 

geologic or geophysical data, and any interpreted geology.

16.2 BIBLIOGRAPHY 

1. Marine Surveys, L. L. C. Archaeological and Hazard Survey Block A-588 High 

Island Area.