2> s h « r „ (X P z<™ o w a 5 p m < >i i-i pq *P W W H p H en i- 1 en H m (J ro < 2 u < o u < U < en < P < u en l-H P en W O « °a en & 1—1 ffi en « P O Z n H < O P P LTl Q~- O o ° 00 CM O 00 en O 1— 1 Z P en O 1— 1 K p V— 1 Pm ^ P l-H en 1— H W P PQ P P 1—1 Ph P P 1—1 en P p rrj w p P s l-H p p 1 pq p en en « W w n S 2 pq < w P 1-1 en en p < Eh o PQ P en en P P en en W > p o l-H > Ph p en W Ph ffi en P P O 3 P en en P > en P H en en en H < P « O P > P w Ph Ph >H PQ < O 8 P P P P O P P P « PQ l-H P u p PC en l-H H < U l-H P P P < w p PQ < 1-7 comparable to those available to large and financially strong corporations. Such favorable financing terms are usually not available to the average shipowner. The Title XI program is administered by the Assistant Secretary for Maritime Affairs (Secretary) on behalf of the Secretary of Commerce. The guarantee of the United States Government under this program provides for the prompt payment in full of the interest on the unpaid principal of any guaranteed obligation in the event of default by the shipowner in the payment of any principal and interest on the obligations when due or for other specific defaults. The Federal Ship Financing Fund established pursuant to Title XI is used by the Secretary as a revolving fund for the purpose of underwriting the Government's guarantee and to pay the expenses of the program. In addition, the Secretary is authorized to borrow from the United States Treasury in the event the Fund is insufficient for the purpose of making prompt payments under its guarantee. In 1973 Congress established a Fund ceiling of $5 billion and the Congress is now considering raising this ceiling to $8 billion. As of July 31, 1975 a total of $ 4. 7 billion had been committed to guarantee loans under the Title XI program. 2. ELIGIBILITY REQUIREMENTS Vessels eligible for Title XI assistance generally include vessels designed principally for research or commercial use and over five net tons. However, any towboat, barge, scow, lighter, car float, canal boat, or tank vessel, to be e ligible, must be more than 25 gross tons and floating drydocks must have a capacity of 35, 000 or more lifting tons and a beam of 125 feet or more between the wing walls. The design of the vessel must be adequate from an engineering viewpoint for its intended use, and the delivered vessel must be classed by the American Bureau of Shipping as Class A-l, or meet other standards acceptable to the Secretary. The shipowner must be a United States citizen and have sufficient operating experience and the ability to operate the vessel on an economically sound basis. The shipowner must meet certain financial requirements with respect to working capital and net worth, both of which are based on such factors as the amount of the guaranteed obligations, the ship- owner's financial strength, intended employment of the vessel, etc. These factors also affect the terms of the guarantee with respect to continuing Title XI financial covenants, guarantee fees, reserve fund, etc. No guarantee under this program can be legally entered into unless the. project is determined by the Secretary to be economically sound. 3 . PROCEDURE Application forms for Title XI are obtained from the Maritime Administration. Attached to the application is a copy of General Order 29, Revised, which constitutes the rules and regulations governing the operation of Title XI. Twelve completed sets of the application, including, schedules and exhibits as required, are sent to the Maritime Administration accompanied by a filing fee of $100. 00 which is not refundable. Approval of the application is contingent upon the determination by the Secretary as to whether the vessel(s) and the project meet all the applicable requirements of the existing statutes and regulations. If the application is approved, a conditional letter commitment to guarantee the obligation is issued, stating the requirements necessary for final approval (usually within 90 days). The applicant is notified in writing when the application is not approved. Final approval of the application is accomplished after the formal documentation of the transaction and all the conditions in the letter of commitment are satisfied. At such time the Secretary enters into a formal Commitment to Guarantee and guaranteed obligations (notes and bonds) is issued and sold and a secured interest or a mortgage on the vessel(s) recorded. 4 . AMOUNT GUARANTEED The amount of the obligation guaranteed by the Government is based on the "actual cost" of the vessel as determined by the Secretary. The actual cost of a vessel includes those items which would normally be capitalized as vessel costs under usual accounting practices, such as the cost of construction, reconstruction, or reconditioning (including designing, inspecting, outfitting and equipping) of the vessel, together with commitment fees and interest on the related loan during the period of construction. All items of actual cost must be determined to be fair and reasonable by the Secretary. Some costs are excluded from actual cost (and are sometimes considered capitalizable costs) such as legal and accounting fees, printing costs, guarantee fees, vessel insurance and underwriting fees and any interest on borrowings for the ship- owner's equity in the vessel(s). The Secretary is authorized to guarantee an obligation which does not exceed 75 percent of the actual cost of most eligible vessels. However, obligations may be guaranteed in an amount not exceeding 87 l/Z percent of the actual cost of (1) passenger vessels designed to be of not less than 1, 000 gross tons and capable of a sustained speed of not less than 8 knots, to be used solely on inland rivers and waterways; (Z) oceangoing tugs of more than 2, 500 horse- power; (3) barges; (4) vessels of 25,000 horsepower designed to be capable 1-9 of a sustained speed of not less than 40 knots; and (5) other vessels of not less than 3, 500 gross tons and capable of a sustained speed of 14 knots. Vessels built with construction-differential subsidy or vessels other than barges and passenger vessels in (I) above engaged solely in the transportation of property on inland rivers and canals exclusively are eligible only for a guarantee not exceeding 75 percent of their actual cost. If a Title XI guarantee of an obligation for a vessel is documented after delivery or for refinancing, the actual cost must be depreciated from the date of delivery to the documentation date of guarantee. 5. SOURCE OF FUNDS Since the program is a guarantee program and not a direct loan program, funds secured by the guaranteed debt obligations and used for the financing of the vessel(s) are obtained in the private sector. The main sources for such funds include banks, pension trusts, life insurance companies and bonds sold to the general public. 6. AMORTIZATION AND INTEREST RATE The maximum guarantee period is 25 years from the date of delivery, however, if the vessel has been reconstructed or reconditioned, the life may be extended by the Secretary to include the remaining useful years of the vessel as determined by the Secretary. Amortization in equal payments of principal is usually required, however, other amortization methods such as level debt (equal payments of principal and interest) may also be approved if sufficient security is offered such as long term charters, reduction of the amount of guarantee and/or length of guarantee period. The interest rate of the obligation guaranteed, for both new and refinanced vessels, must be within the range of interest rates prevailing in the private market for similar loans and risks and must be determined to be fair and reasonable by the Secretary. 7. INVESTIGATION FEE An investigation fee, not exceeding one-half of 1 percent of the original principal amount of the obligation to be guaranteed, is charged for the investigation of applications, including related appraisals and inspections. Generally, a fee of only slightly in excess of one-eighth of the 1 percent is charged. If the application is not approved, one-half of the fee is refundable. 1-10 8. ANNUAL GUARANTEE FEES The fee for the guarantee of an obligation for a delivered vessel will be not less than one-half of I percent or more than 1 percent per annum, of the average principal amount of the outstanding obligation, or not less than one-quarter of 1 percent or more than one-half of 1 percent per annum, of the principal amount of an obligation relating to a vessel under construction, reconstruction or reconditioning. Amounts on deposit for the vessel is in escrow fund held by the U. S. Treasury pursuant to Title XI are excluded in the computation of this charge. The fee is required by law to be paid annually in advance. Unless otherwise determined by the Secretary, the annual premium rates are based on a ratio of net worth to long-term debt of the shipowner, and are subject to annual adjustment except during the construction period. 9. "BUY AMERICAN" POLICY The Maritime Administration's long-standing policy has been that vessels built with the aid of Title XI are subject to the "Buy American" provision of Section 505 of the Act which states in part: "In all such construction the shipbuilder, subcontractors, materialmen or suppliers shall use, so far as practicable, only articles, materials and supplies of the growth, pro- duction, or manufacture of the United States as defined in paragraph K of Section 401 of the Tariff Act of 1930. " Pursuant to Title XI the shipowner may be permitted to use components of foreign manufacture, providing: (1) the performance of the vessel will not be adversely affected and (2) the incorporation of such foreign components into the vessel will not impair its entitlement to operate in the coastwise trade of the United States or to carry preference cargoes. However, if foreign components are used, the cost thereof will be excluded from actual cost if the Secretary determines that suitable American domestically produced components are available. This reduction in actual cost will increase the owner's share of the total cost of the vessel and reduce the amount of the guaranteed obligation. 10. REFINANCING Amounts outstanding on existing Title XI obligations, or amounts outstanding on obligations not previously insured or guaranteed (provided they had been issued for the purposes contained in Title XI) may be refinanced under the Title XI program up to the amount of the depreciated actual cost of the vessel(s) I- LI but not exceeding the amount of the existing obligations being refinanced. Such financing under Title XI must meet all the applicable requirements of the existing statutes and regulations, and the original obligation must have been issued within one year after vessel delivery. Vessels purchased as "used" vessels are not eligible under this provision. However, under certain conditions the proceeds of guaranteed obligations issued with respect to any eligible vessel may be used for the construction of a new vessel or for the purchase of certain marine equipment. c • OPERATING, TECHNICAL CHARACTERISTICS AND TYPES OF OF FSHORE OIL AND GAS DRILL I NG VESSEL S One of the key developments in the spectacular growth of the offshore oil industry during the past 25 years has been the development of offshore mobile drilling units. The many unusual designs developed to solve various problems is one of the important engineering achievements of this century. This section will review how these units evolved -- and make some predictions about future developments. An offshore mobile unit, as defined in this section, is any portable unit containing a drilling rig capable of working in open water 20 ft. or deeper. Included are mobile units supported by drilling tenders and the new special mobile workover units. Drilling units, as defined below, can be categorized into one of the following four groups: 1. Submersible - Drilling platform resting on the sea bed during drilling, usually equipped with a lower column section having enough buoyant capacity to keep the rig afloat while being moved. 2. Floating Drillship and Barge - Ship- shaped or barge- shaped hulls equipped for drilling while floating on the water surface. I- 12 3. Jack-up Drill Unit - Self-elevating platform equipped with legs which can be lowered until they reach the sea bed and support the main section of the drilling platform. During drilling operations, this platform is kept in a jack-up position above the water surface. 4. Semi- submersible - Floating drilling platform which by means of water ballast can be submerged to a pr e-determined draft so that a substantial portion of the columns or other stabilizing devices are lowered during drilling operations. There have been three periods of rapid growth -- 1953-58 when many sub- mersibles and jack-ups were designed for the Gulf of Mexico, 1962 to 1967 and 1971 to date when floating and jack-up rigs were built in great numbers for world-wide use. In the past 10 years there has been a substantial increase in number of rigs for the 100-300 ft. range (primarily jack-ups) and a substantial jump in number of floating rigs, including semi- submer sibles which operate in deeper depths. The oil industry's mobile marine drilling fleet is growing at an extremely rapid pace. During the IZ month period ending September 1974, the number of mobile units had increased from 319 units to 408 units. This new figure includes the 268 units in operation and 140 which are under construction or planned. Of the 408 units in operation, 173 (43%) are jack-ups, 128 (31%) are semi- submersibles, 20 (5%) are submer sibles, 87 (21%) are drillships and drill barges. Of the 140 new units under construction and planned, 26 are drill ships and drill barges, 34 are jack-ups and 80 are semi- submer sibles. The continuation of the construction boom is necessary to meet the growing demand for more energy throughout the world. As can be noted, the new and planned vessels will be capable of working in deep water while encountering the most severe sea and weather conditions. Offshore drilling rigs have been developed over a period of time to drill from coastal marshlands out to 3, 000 feet of water in the open sea. There are five classifications of rigs, i.e. Drill Barge, Submersible, Jack-up, Semi-Submersible and finally the Drill Ship for operation in deep water. Drilling operations so far, have not exceeded 2, 300 feet of water depth. Water depth, maximum sea and wind conditions, bottom conditions, and maximum loads to be carried are among the primary factors influencing the design of a unit. 1-13 A careful evaluation of the anticipated service over the lifetime of the rig is needed. This involves estimated future markets and uses for the units as well as the environments in which they are expected to operate. Some of the basic elements which determine the characteristics of a rig design are as follows: Water depth Wind, wave, tide and current Mobility- Loads to be carried Number of crewmen Bottom soil conditions Surface or subsea well completions Desired maximum motions Stability requirements, operational and regulatory Structural design criteria, operational and regulatory In most places of the world, severe oceanographic events, such as hurricanes, typhoons and broad low pressure systems determine design conditions. In these more severe environments, past experience and research is proving to be quite useful. Weather data taken over a period of time, preferably a number of years, is reduced and coupled with mathematical extrapolations to determine rare occurrences. This data includes: Sea state probability Wave period occurrence probability Current occurrence probability Current direction probability Wind velocity probability Wind direction probability 25, 50 and 100 year conditions Some oil producing areas have little or no reliable weather forecasting. As a result, designers and business managers normally plan structures and vessels to sustain the worst known environmental conditions in any given area. This is not to say that there is absolutely no risk involved. To virtually eliminate risk one would have to assume that in a given area the worst sea, current and wind may occur simultaneously and from the same direction. The probability of this occurring in most areas is 1-14 extremely low. A reasonable approach is to establish an order of annual probability for each element and determine their product. The product of the annual probability of simultaneous occurrence should not be higher than 0. OZ. If no reliable direction information is available, sea current and wind are assumed to act from the same direction. The current selection of the most appropriate unit for offshore drilling boils down to water depth considerations. In very shallow water, say 20 ft. deep, a mobile platform could be a simple barge hull with structural support columns to support a raised platform. This hull would be submerged by lowering one end to the bottom first. In going deeper, to about 150 ft. there is a choice between fixed height platform of a jack-up rig. In the case of a fixed height plat- form, the barge would ordinarily have stability columns to permit raising and lowering on an even keel. Such a platform could work bottom- supported to the limit of its proportions, or it could work as a semi- submersible in any water depth in which it could be anchored or dynamically positioned. The largest submersible rig built to date was designed for drilling on the bottom in 17 5 ft. water depth, but this is considered to be about the limit and somewhat beyond the range of economical Construction cost under the present state of technology. Jack-up drill units are designed for water depths of about 300 ft. ; however, a jack-up drill unit could be designed for up to possibly 400 or 500 ft. of water depth depending upon prevailing sea conditions of a particular drilling site. The structural problems are considerable in such extreme water depth and probably 300 ft. is a more practical limit. A semi- submersible or a floating rig is more economical in greater depths. 1. SUBMERSIBLES The first offshore mobile unit, a submersible, was the Barnsdall-Hayward "Breton Rig 20". This rig, which is now Kerr -McGee' s "Rig 40, " is pictured in Figure 1-1. This unit evolved from the inland drill barges which were being used to drill in the marshes and protected bays in 10 ft. of water or less. The first of the inland barge rigs was the Gi lias so -type barge which was built in 1933. It has a U-shaped hull with a long, narrow slot that allowed the derrick to be located approximately amidships. Another type of unit consisted of two barges connected by a truss, with the derrick positioned between the barges. As the water depth requirements increased, the drilling decks were raised by adding vertical structural members; hence these units are often called posted barges. The basic problem being that these units are unstable when the main barge hull is totally submerged. 1-15 The answer to this stability problem was the "Breton Rig 20" design. This unit used pontoons which could stay on the surface while the barge was being set on the bottom. After the barge was in place, the pontoons were lowered to the bottom to minimize wave forces. This concept proved successful, and this unit is still operational. Two other units have been built with vertically movable pontoons - Kerr - McGee's "Rig 44" and "Rig 45. " Other solutions to the stability problem were developed in the mid- 1950 ' s. One early offshore mobile unit, ODECO's "Mr. Charlie" Figure I-Z used hinged pontoons to provide stability while sinking. Only one other unit the "American Tideiands 101, " was built with hinged pontoons. Both of these units were converted to fixed pontoons shortly after they were built. It is interesting to note that "Mr. Charlie" also used large- diameter columns to provide floating stability. This was the first step in the development of the bottle-type unit which will be discussed later. At the same time "Mr. Charlie" was being built, Friede and Goldman developed a design which used recessed pads or feet that could be lowered to the bottom to establish a firm footing before the unit was sunk into position. The California Company's "S-44" and approximately eight other units were built using this principle. All of these units have been converted to bottles to get away from the problem of moving parts. ODECO's "John Hayward" Figure 1-3 was designed with fixed hull extensions fore and aft. This dumbbell hull (so-named because its plan profile resembles a dumbbell) serves two purposes while the barge is being sunk. The extensions on one end of the barge give it mechanical stability as they contact the soil, while the other pair of extensions are providing water -plane area to give floating stability. Approximately seven of these units have been built. One reason for their success is that they have no moving stability members. As indicated above, the trend with the submersible has been away from moving parts which can be damaged or cause operating problems during rig moves. One problem which beset all of the early submersible units was that of being moved off location by moderately severe storms. After several of these units were built, it was discovered that, although the barge hull is resting on the bottom, it is still subjected to some substantial wave forces. Also, the soil is scoured from around the hull by waves and currents. A partial solution to these two problems, which has been used by most of the submersible units operating in soft-bottom areas, was to add mud skirts or fiddle boards to the periphery of the hull. These skirts, which are up to five feet deep, have overcome most of the difficulties. In 1-16 HAYWARD-BARNSDALL "BRETON RIG 20* (KERR-MCGEE RIG 40) MOVABLE PONTOONS ODECO "MR. CHARLIE' HINGED PONTOONS -X7&XK Figure 1-1 xxx 1954 Figure 1-2 X*X -T&- ODECO "JOHN HAYWARO" FIXED HULL EXTENSIONS iVf AL w ISO X 1 20 X 10 1955 ^; > ■777" F igure 1-3 1-17 OFFSHORE "NO. 53" FIXED HULL EXTENSIONS & SPUDS I ;w IT JOO X74XI2 1955 TT a 799T CALCO *S-55" STREAMLINED HULL _____ I 90 X ISO X 11 1 1 c 1956 7W Figure I- 4 KERR-MCGEE "RIG 46" BOTTLE TYPE 7W V ^ V -777: T^^r 1956 -b igure I- 5 1-18 ODECO "MARGARET" CATAMARAN HULL WITH BOTTLES "77* /W 1957 Figure I- 6 KERR-MCGEE ' 'RIG 54 TRIANGULAR SHAPE 79SX 7w: Tvsx: 1963 Figure 1-7 1-19 some cases it is still necessary to use sand bags or oyster shells to protect locations where high currents are present. Another solution to the movement problem is to use spuds to hold the rig on location. The Offshore Company's "Rig No. 53," which has a dumbbell hull, uses spuds to give lateral support. Other units such as the California Company's "S-55, " were designed with a streamlined hull to minimize wave forces and reduce scouring. There are shown in Figure 1-4. In 1956, the trend toward building long, rectangular (approximately 180 x 80 ft. ) mobile units was reversed abruptly by Kerr-McGee's "Rig 46" Figure 1-5 which used 'bottles" at wide spacing to achieve stability in deeper water with no moving parts. This unit which measures 242 x 202 ft. was a very important development because it was also the forerunner of the semi- submersible. It was followed by the ODECO's "Margaret" Figure 1-6 which has large, cylindrical bottles and a catamaran hull. Another bottle design, Penrod's "Rig 50", used spuds to give additional lateral support. The final development in this series was Kerr -McGee ' s 'Rig 54" Figure 1-7 which was included in the sketches primarily to illustrate its tremendous size. It can drill with a 25 ft. deck clearance in 175 ft. of water. This unit will probably remain the largest submersible since it does not appear practical to go to greater water depths with a submersible design. The success of the bottle-type unit is verified by the fact that approximately 14 of them have been built to date, including the recessed- pad conversions mentioned previously. In studying the growth of submersible units it should be noted that the total number of submer sibles, with the exception of the new semi- submer sibles which can also sit on the bottom, has remained essentially constant since 1958. One reason for this trend is that, with the exception of Kerr-McGee "Rig 54", the regular submersibles are limited to a water depth of 80 ft. or less, while wildcat drilling has moved steadily into deeper water. Also, the jackup units have become very popular in the 7 5-150 ft. depth range due to their lower initial cost. 2. FLOATING DRILLING SHIPS AND BARGES Vessels floating on the water surface have been used in offshore drilling operations since the late 1940' s, immediately following World War II. Among the first vessels used offshore were U.S. Navy surplus ships and barges which were readily available, relatively easy to convert for drilling operations, and inexpensive to obtain. 1-20 The first application of floating vessels was in conjunction with fixed platforms, using the ship or barge as a tender. Only a part of the drilling equipment was installed on the vessel, with a large portion of the drilling equipment being placed on the platform which was permanently fixed to the seabed by pilings. U.S. Navy surplus YF (Yard Facility) barges, and LST's (Landing Ship Tank) were widely used in the Gulf of Mexico as floating tenders in support of fixed platforms. In the early to middle 1950' s several small vessels were outfitted with small coring or bottom sampling drilling derricks for use in the Pacific Ocean off California, and in the Gulf of Mexico. These vessels proved the feasibility of conducting drilling operations from a floating vessel, although their operations were generally limited to calm water areas and drilling shallow core holes or stratigraphic test wells. As the search for oil and gas reserves moved farther offshore into deeper water, the cost of installing fixed platforms for exploratory wells increased substantially. When the prospective area proved to be non-productive, the cost of platform installation and removal to drill a dry hole, added to drilling costs, approached the economic limit. Other means had to be devised to continue the search for new reserves in, the deeper waters. One of the ways established to continue the search was to install all equipment required to drill a well onboard a floating vessel-either an ocean going barge or a ship. Thus the drill ship was born. In the late 1950' s several vessels formerly used as tenders were converted to drilling vessels. The derrick hoisting equipment for the drill string, and the supporting structure for this equipment was installed onboard the vessel, making it independent of any structure permanently fixed to the seabed. Some of the vessels drilled over the side, others drilled from a centerline position. These units have proved to be effective in carrying exploration for new oil and gas reserves into new areas economically. Many of the vessels converted in the late 1950' s and in the decade of the 60' s are still in operation in various parts of the world. With the experience gained in the early phase of offshore drilling from floating ships and barges, the need for improved vessels and equipment was apparent. Surplus vessels were not as readily available and were lacking in some of the desired capabilities for drilling vessels. In the 1960's, several new vessels were built in shipyards specifically for the purpose of offshore drilling. These barges and ships were designed from the keel up as drilling vessels. Specific arrangements of machinery areas, storage areas, 1-21 accommodations, mooring facilities and drilling and support equipment were incorporated. The aim was to increase water depth capability, improve sea-keeping qualities, improve stability characteristics, increase load carrying capability, and achieve efficient operations while drilling and also while in transit between drilling locations. These aims have been achieved quite successfully, and are being improved each year with new vessels being built for services in deeper, rougher areas of the oceans, worldwide. Surface floating vessels have several inherent characteristics which are desirable and favor their continued use and development. Due to size, shape or configuration and close kinship to ordinary cargo ships, they can be built in many conventional shipyards of varying size and capacity without the requirement for special facilities. Construction time, costs and methods are comparable to those for other ships or barges and are generally economically favorable. Mobility is a very desirable feature of these vessels. They can be relocated over substantial distances quickly and economically. Transit speed of 10-12 knots is relatively common, utilizing moderate sized propulsion plants of 4,000 to 12,000 horsepower, either as a self-propelled ship or as a towed barge. Load carrying capability is another desirable feature. More recent vessels have loading capabilities allowing them to drill one or more wells at remote locations with little or no re- supply from other vessels or shore facilities. The supplies required can often be loaded in a port in a conventional manner, transported economically to a remote location, and utilized to drill one or more exploratory wells before requiring replenishment. Since the drill ship or barge is not fixed to the bottom by permanent structures, it can operate successfully through a wide range of water depths, from very shallow to very deep. However, different sizes and types of these vessels are more suited to particular ranges of water depths, whether the controlling factors be physical or economic considerations. Some disadvantages are also inherent in a surface floating vessel and tend to limit their operations to areas having generally favorable conditions. The vessels are highly responsive to wave action and can develop excessive motions in certain sea states which prevent conducting normal drilling operations, or in lesser sea conditions cause the operations to be inefficient or hazardous to personnel unless stringent safety precautions are taken including the rigging of life lines. Pitch, roll and heave motions are generally 1-22 directly related to wave and swell height and direction. When any of these motions become severe, operations must be curtailed unless compensating measures can be employed. Wind and current forces can also be substantial and can hamper operations unless compensating measures can be taken. Mooring equipment for floating vessels exposed to wind, wave or current forces from unfavorable directions can be subjected to very large stresses under severe conditions which can prevent normal operations. These disadvantages have led to employment of drill ships and barges in areas of the world or at times and seasons having sea and weather conditions favorable to their continued operation in the desired manner. The disadvantages have also led to the design and construction of improved vessels, with new and improved equipment, plus the development of improved operating techniques, all of which are intended to extend the capabilities of these vessels into more challenging areas. Larger vessels have been built, and others will be constructed, having sizes and shapes particularly suited to drilling while remaining in a relatively constant position on the ocean surface with respect to the seabed. Special mooring arrangements have been developed to permit surface vessels to change heading to minimize motions of the vessel. Having the capability to head the vessel in the most favorable direction, considering the effects of wind, waves and current, permits continuing drilling operations in a more severe environment. Some vessels have been specially reinforced and strengthened to permit operations in areas having some ice accumulations in the ocean. Several vessels have been equipped with special propulsion and thruster units allowing them to remain on location without anchoring. This dynamic positioning equipment can be computer controlled to keep the vessel in the correct location and on a favorable heading in very deep water under varying wave, wind and current conditions. Special equipment has been designed, built and installed to help compensate for vessel roll, pitch and heave. Such equipment further extends the capability of drill ships and barges to continue operations under adverse conditions. The trend in offshore exploration clearly indicates that the Oil Industry must extend its search for oil and gas into water depth beyond the continental shelf. The need for additional oil and gas reserves and the belief that sizeable reserves could indeed exist in greater water depths have encouraged interest in deepwater exploration. This deepwater exploration 1-23 has resulted in the need for new techniques and tools for water depths of 2, 000 feet and greater. The major limiting factors to existing offshore exploration drilling are the anchoring capability and the underwater drilling equipment system. The following describes the SEDCO 445, a Dynamic Stationed Drill Ship, specially designed and equipped with the capability of anchoring in unlimited water depths. The use of new techniques such as Electro-Hydraulic (BOP) Blowout Preventer controls; accoustical re-entry; and riser buoyancy increase the capability of the underwater drilling equipment systems to something greater than 3,000 feet. The SEDCO 445 drilling ship is a typical self-propelled ship, dynamically stationed when on location in deep water, and self-sufficient for several months. Accommodations and laboratory space are provided for drilling, electrical logging, mud logging, diving, petroleum engineering, and geological and management services, all of which are designed to be in- dependent of shore support. However, for emergency supplies, timely re- stocking, personnel access and safety stand-by, the drilling unit is provided with a helideck and is accompanied by a large crew- standby boat and work- boat. It employs, in addition to measuring its position with a high degree of accuracy, propellers capable of exerting thrust in controlled directions and a system for activating propellers to rectify deviations from a pre- determined position. Dynamic stationing for large vessels has only recently become feasible as a result of advances in directional propulsion and position measurement systems, and greater understanding of the behavior of vessels at sea. A vessel equipped with dynamic stationing can head into the waves thereby reducing motion. The SEDCO 445 with its dynamic stationing is expected to hold position and operate in 50 knot winds, 12 foot significant waves and 1. 5 knots current, all acting on the vessel simultaneously and concurrently. The SEDCO 445 is designed to hold location within 100 feet of a well with guidelines connected, heading into 70 knot winds, 3 knot current and 30 foot significant waves. The ship can survive the 100 knot wind, 70 foot significant wave. The ship is a molded hull type, all-welded construction, self-propelled and complies with all requirements of the American Bureau of Shipping 1-24 and SOLAS-!'. United States Coast Guard and United States Public Health Service requirements have been followed. General characteristics are as follows: Length Overall 445 feet Width 70 feet Depth 32 feet Normal Draft 22 feet Underway Speed 14 knots Displacement at 20 foot operating draft 11, 700 long tons Displacement at 25 foot operating draft 15, 100 long tons Variable Load 6, 500 long tons Period of roll: (Ship's natural period of roll) 12 - 13. 5 sees. GM Range 6.9 - 8. 3 feet The drill ship's equipment is installed on three levels within and above the ship's hull. Enclosed within the hull are pumps, tanks, storage, ship support equipment, ship and drilling power generation, and equipment maintenance and work areas. Operating displacements are between 11, 700 and 15, 000 long tons with a variable cargo load of 6, 500 long tons. Above the ship's main deck and amidship, the drilling derrick has been elevated to provide sufficient space for handling the subsea blow out preventer riser, etc. The moon pool opening is 22 feet I. D. Three cranes have been installed above the ship's main deck to facilitate equipment handling at the rig floor. The ship's power plant consists of two basic systems - a main power system and an auxiliary power system - with a bus tie between the two systems to provide for the event of complete failure of the auxiliary system. The main power plant includes five diesel-driven alternators each rated at 2100 KW continuous, and provides power for the three major modes of operation of the drill ship: (I) propulsion while in transit, (2) normal positioning plus drilling, and (3) positioning, maximum thrust required, no drilling. Auxiliary power is provided by two diesel driven alternators, each rated 1050 KW continuous each of which is capable of handling the full design auxiliary load. ■'Safety of Life at Sea 1-25 The ship power is 5 SL6 -E 4 GW - 20EMD 2100 KW, 4160 volt A.C. generators to provide power for the main propellers, stationing propulsion "units, drawworks and other drilling services. The generators totaling 10, 500 KW supply AC power to a common bus bar from which the voltage is reduced by transformers to 600 volt. Baylor Thyristor systems are used to convert to DC and control a variable voltage power supply to the various DC motors (32 in total). In addition there are (2) S-12 EGW-EMD A. C. generators for general ship service and a 350 KW emergency generator. The ship is equipped with all required auxiliary systems for control, navigation, operation and safety. Main propulsion is provided by a total of 9,000 horsepower from 12 DC motors on two 13 foot diameter, 4 bladed stainless propellers. This system is capable of driving the ship at a speed of 14 knots. The ship is provided with a dynamic stationing system which holds the ship on location for offshore drilling operation in water depths from 200 feet to 3, 000 feet while drilling to depths of 20, 000 feet below the ocean floor. The system is capable of holding the ship over a pre-determined point (6% of water depth) and of maintaining drilling operations through 50 knot winds, 12 foot significant waves, concurrently with a 1 1/2 knot current. The system consists of acoustical and taut wire position reference systems, position process controllers and eleven 800 HP thrusters plus main propellers. The system design provides 100 percent redundancy. Similarly , the stationing system is capable of holding the ship closely to a pre-determined percent of water depth in most extreme conditions. The system has two computer centers which continuously check each other and which switch over or signal an alarm if one malfunctions. A digital tape recorder system is provided which records pertinent dynamic stationing data so that any malfunctions can be analyzed. An onboard analysis system is also provided so the digital tape can be processed. There are six methods of position reference checking. Provided are two RS-5 acoustic position indicators with six hydrophones; two taut wire methods (one over the side and one on the guide line); two riser angle indicators, either of which can be moved to alternate positions (top or bottom of riser). All these methods feed into the computer and are capable of being used to position the ship or to check the other systems. 1-26 The thruster system consists of eleven thrusters and the main propulsion screws. The thrusters are positioned to provide the best ship movement capability so the ship can always head into the worst environmental conditions, Dynamic Stationing control is provided by an automatic station keeping (ASK) system specifically designed for position control of offshore drilling vessels. The system provides precise, automatic control of the position and heading of the vessel over long periods of time through automatic control of the vessel's propulsion system. The system measures the vessel's position by means of an Acoustic Position Indicator which provides vessel-position information relative to a single acoustic beacon placed near the sea-floor drilling position. Heading information is provided by the vessel's gyrocompass. Control orders to the propulsion system, in response to deviations from desired position and heading are automatically provided by a digital computer. To ensure precise, smooth control at minimum thrust, the automatic control program is specifically tailored to the vessel and its propulsion system by a dynamic simulation analysis. The system is composed of two acoustic position indicators, two digital computers, two hydrocompasses, automatic switching equipment, thruster control interface, and an operator control and display console. The system provides sensor and computer monitors to effect an automatic transfer from the on-line computer to the standby computer in event of malfunction. The standby computer is continuously updated by the on line computer to allow for smooth, bumpless transfer from one to the other. Table 1-3 tabulates a number of drilling ships and barges with their principal characteristics. Cuss I and LCM Class were converted Navy vessels, while the others were built as drillships from the keel up. In 1962, the Glomar II was the first drilling ship built as new construction. This class was followed by the Glomar Sirte Class in 1965 and the Glomar Grand Isle Class in 1967. A modern drillship, the Discover 534, presently under construction is illustrated in Figure 1-8. Pollution control equipment required to be employed in floating vessel drilling operations includes: a drill cuttings washing system to assure that no oil, or drill cuttings sand, or other solids containing oil, is discharged into the sea (hauling of oil wet cuttings to shore for processing and disposal is utilized if more practicable); drain collectors and gutters to collect all feasible oil-contaminated rig-area washdown fluids; and 1-27 co P W co w P > Q P u 1— 1 -H ffi ft CO ,> i—i (X P I— 1 1 — 1 £ CD a) CD P -*-> * Pi CD <+-! CD cd k !-< P jci 4-a ft CD P +-> X) CD 0) 0) +J P cd K i CD o en cd o - — i H a CO •H P -4-> CD £ <-H rd Xi, U +J M P pi •» n — 1 TJ Jh rt CD CD u d do o rd Pi CD cd -4-1 •H g t— 1 i—l £ CO o ni ^ o r-H 41 3 p O u CM X o CM P o UT) vD O i — i o o o LD CM < ° * S co O P o X X X <¥ <* ■* v£) vO vO X X X, o O o CO oo 00 ro ro ro cd 5 a e r-H CD H CO CO The continental shelf is defined physically as the zone extendin; from the line of permanent immersion around a continent to the depth where there is a marked or rather deep descent toward the great depths. In 1970, the Hague Conference defined the continental shelf as: "...the area between the mean low water line and the change in the inclination of the ocean floor, from about one-eighth of one degree to more than three II-6 degrees, that marks the beginning of the continental slope. This occurs at various depths, usually between 130 and 200 meters; but it can* occur as shallow as 50 meters and as deep as 500 meters. The continental shelf ranges in width from zero to 1500 kilometers." Geographically, the continental shelf is a subpart of the continental margin, a zone separating the submerged part of a continent from the deep-sea bottom. The other subparts are the continental slope and the continental rise. The continental slope is the declivity from the outer edge of the continental shelf into the great depths. There exists a great variation in the steepness of the continental slope. For example, the slope off the northwest coast of Australia is less than 1° whereas that off Australia's southwest coast is 27°. The depth of the continental slope varies from 1400 to 3200 meters. The base of the slope is marked by the continental rise. The rise is a gently sloping and smooth surface formed by the joining of a number of deep-sea fans. Con tine of comp strata General Barbara of long are h e 1 act as of the cir cums cont ine the sho crystal after f f ormat i the U.S include from th meters . and are dams ar and off dams ar nt al osi t and iy, Cha , th d in dams cont t anc nt r re . 1 ine illi on o . ar tho e up Sa the e th the e co she i on t hos (wit nnel i ck pos T inen es , esul Sed roc ng t f a e ex se f ward It d pr i e pr sou ral Ives -. tho e und h the ), th prism it i on ecton t al s cryst ting iment k act he ba s lope ampl e ormed move omes ncipl ine ip theas reefs can b se th er lai exce e con s of by f ic ac lope al 1 in in a is d s as sin , . Th s of by d ment are c e tec le ag tern , man e cl as at are n by i pt ion t inent sedime aul t b t ivi ty has f o e rock basin epos it a dam will s e At la such a iaper of sal ommon tonic ent in coast y of w si f ied i under la gneous a of the a al shelv nt and s locks , d that wa rmed tec is upl i between ed in th t o trap pill ove ntic and ct ivi ty . structur t from a in the w dams in the eas of the U hich are nt o in b nd m r ea es a edim iape s pa t on i fted the is b the r re Pac Ot es w dep est e that tern n i t e st i two prima y sedimen etamorphi north of re the to entary st r s , and r ral 1 el to c dams . paral lei upl if t ed as in ; the sediment suiting i if ic coas her t ecto hich have th of man rn Gulf o area . B Gulf of d States . 11 1 iv ing ry ty t ary c roc the S p sur rata eef s the Under to t rock upl i whi ch n the t s o nic d resu y kil f Mex iogen Mexic The pes ks. anta faces which which base such he and fted f ams lted o- ico ic o se Shelf areas underlain by igneous and metamorphic rocks are found on top of tectonic dams. Many of these shelves had a sediment cover that was stripped by glaciation. An example is the continental shelf off Maine where glacial erosion has removed the sedimentary rocks that once covered such dams. Most of the other continental shelves that are known to be underlain by igneous and metamorphic rocks are at higher latitudes where glacial erosion has been an effective agent. II-7 A very important event in the evolution of the continental shelves occurred during Pleistocene glaciation when the sea level changed as a result- of water being locked up in glacial ice. The sea level was lowered by as much as 150 meters, and a great amount of erosion took place on the sediments of the continental shelves that existed at that time. As a result, about 70 percent of the world's continental shelf-area sedi- ments have been laid down in the past 15,000 years since the last significant glacial lowering of the sea. There are several geomorphic features that occur on the conti- nental shelves and slopes which are significant. Some of the more important features include drowned valleys, tidal channels, drowned glacial troughs, submarine canyons, fan-valleys or channels, delta-front troughs, slope or sea gullies, submarine grabens or rifts, reefs, salt domes, and submarine mounds. G . GEOLOGY OF OIL AND GAS ACCUMULATION Oil and natural gas are hydrocarbons, as are coal, shale oil, and tar sands. Natural gas is primarily methane, the simplest of the hydrocarbon compounds which range from natural gasolines to very viscous crude oils. Intermediate between natural gas and -crude oil are natural gas liquids which are mixtures of propane and heavier compounds. They are extracted during the production of natural gas. Large accumulations of oil and natural gas owe their existence to the interplay of three essential geologic elements. These are: (1) source beds -- rock strata, e.g., marine shales, marls, and limestones, which supply the organic material that is eventually transformed into fluid hydrocarbons; (2) reservoir beds -- porous strata, e.g., sandstone or limestone, into which hydrocarbons migrate; and (3) a trapping mechanism -- a structural or strat igraphic barrier which interrupts further migration and allows significant hydrocarbon accumulations to deve lop . Oil biol that last Thes requ in a comp migr (the even by a lati phas pres 1 owe pres and ogic was 600 e ch i re reas ound at ed hyd tual 1 ay ons e , a ent , st . sure natu al m dep mi 1 emic init of s f o upw roca iy, er o are ssum bei All s du ral g at er i osit e lion al pr ia 1 c rap id rmed ard t rbons ei the f imp densi es th ng mo thes e to as r al ( d in year oces ondi sed in a hrou hav r es erme ty- s e hi re d e li the esul dead thi s on ses t ion imen n ox gh t ing cape abl e trat ghes en se quid weig t fr mar ck 1 wha occu s of t at i ygen he w a lo d in roc if ie t po tha s ex ht o om t ine ayer t wa r at qui on . -def at er wer to t k. d; g sit i n bo ist f ov he slow animal s of se s then extrem ck buri After icient -satura density he atmo Result i as , if on in t th oil under r er lying chem and p dimen the e ely s al su oil a envir ted s than spher ng oi prese he tr and g el at i rock ical lant t s du arth' low r ch as nd na onmen edime wat e e or 1 and nt as ap wh as , a vely st ra chang debr i ring s sur at es thos tural t , th nt ary r) an were gas a se i 1 e a ssume high ta. e of s) the face . and e found gas ey rocks d trapped accumu- parate ny water s the format ion II-8 H BIOLOGICAL FRAMEWORK OF THE CONTINENTAL SHELF 4,5 The offshore environment is broadly divided into the pelagic and benthic realms. The pelagic realm includes all ocean water above the bottom. Over the continental shelf, the waters constitute the meritic province. Waters over the slope and deep ocean bottom constitute the oceanic province. The biota of the pelagic division is generally subdivided into plankton and nekton. The benthic division includes the sea bottom and sub- bottom environment, and its biota is called benthos. Meroplankton refers to marine species which have planktonic stages during their life but are not planktonic in their adult forms. Holoplankton refers to those species which are planktonic throughout their life cycle. 1 . Pelagic Realm - Plankton All motile aquatic organisms, plant or animal, whose powers of locomotion are too feeble to resist the set and drift of currents are termed plankton. The plankton is divided into several different types on the basis of physiology and life history . Phytop 1 ankton includes the acellular (unicellular) floating plants and all floating multi-cellular plants such as Sargassum As plants, all phy t opl ank t er s are capable of producing their own food from raw materials by photosynthesis. The ubiquitous distrubution and occurrence in pelagic waters is influenced by several factors. Both the horizontal and vertical distribu- tions of phy top 1 ankton are dependent on: (1) population origin and life cycles, (2) supply and level of nutrients and growth factors, (3) physiological requirements and adaptability, (4) salinity and temperature, and (5) grazing pressure by heribivores (pi ant - eat ing animals). In addition, vertical distribution alone is influenced by: (1) vertical water mixing, diffusion, and water stability, and (2) depth of the 1 ight ed zone . The animal plankters are called zooplankton. Zooplankton distributions and occurrences are also relatively continuous in pelagic waters. In general, they are influenced by the same factors that affect phytopl ankton distribution and occurrence. Inorganic nutrients and depth of the lighted zone are not as immediately important to zooplankton as to phytoplankt on , but these factors affect distribution and abundance in that greater availability of nutrients and light allow higher primary productivity and consequently a greater food supply for zooplankton. 2 . Pelagic Re aim Nekton Organisms which remain suspended in water and whose powers of locomotion are great enough to resist the set and drift of currents, being subject only to large-scale physical forces, II-9 are called nekton. Nekton for the offshore waters are represented by five major taxonomic categories - marine mammals (whales, dolphins, porpoises, seals, otters, manatees, etc.), marine reptiles, the fishes, the cephalopod mulluscs (octopus and squid), and certain crustoceans (shrimp and swimming crabs). Individuals of this group commonly, but not always, range over broad areas, thus participating in several biotic communities. For example, shrimps have a pelagic planktonic larvae, an estuarine juvenile, and a pelagic adult. However, most nekton are limited in geographic and vertical ranges by the same environmental conditions as less mobile organisms, i.e., temperature, salinity, available food, and types of bottom . The nektonic component of the environment can be divided into strictly open water nekton and nekton which spend some portion of their lives in nearshore, estuarine, or marsh waters, examples of the latter are shrimp, drum, croaker, menhaden, flounder, seatrout, salmon, etc. Many finfish of commercial and sportfishing importance, however, are strictly open water residents, such as red snapper, various groupers, sailfish, and marlin. Many organisms are demersal; i.e., they have a particular habit of living on, or just above the sea bottom. Since distribution and abundance of demersal organisms is generally regulated by sediment type and the bottom communities that supply food, these organisms can be considered to be part of the benthos. Marine birds feed on fish, plankton, and detritus. Fish- eating birds return nutrients from the sea back to shore and are instrumental in recycling nutrients. Feces contain more readily usuable forms of nutrients than the food organ isms. Sea birds also utilize the shoreline, i.e., beaches, marshes, cliffs, etc., for breeding and raising their young Bent hie Realm Benthos Organisms (plant or animal) which, as adults or in sessile stages of their life cycles, live on the bottom are called benthos. The benthos is characterized by the large numbers of sessile or relatively inactive animals which exhibit marked zonation in the inshore region. The organisms are generally distinct for each of the three zones of the neritic province (supratidal or suppralittoral, intertidal or littoral, and subtidal or sub 1 i ttoral ) . Zonation is characterized more by dominant species than by distinct assemblages of numerous species. 11-10 The benthic environment is in general affected and defined by the same factors that influence the waters above the bottom. Additional factors to consider for the sea bottom alone are: (1) nature of the substrate, (2) nature of the sediment, and (3) sub-bottom tempera- tures, salinity, oxygen, and pH, The substrate may be hard or soft depending on the amount and nature of sedimentation and the degree of scouring by horizontal currents. Sediment type is usually described by percentages of carbonates, evaporites, sand, silt, and clay. Sub-bottom temperature, salinity, oxygen, and pH can be much different than the overlying waters, especially oxygen and pH values. The benthic environment becomes more stable at greater depths, i.e., it is less affected by physical forces such as currents, waves, and storm surges. Temperature and salinity data tend to fluctuate less and have smaller ranges of values than in shallow water areas closer to the air-sea interface. The major subdivisions of the biota found in the benthic environment are epiflora, epifauna, infauna, and inflora. Epiflora are plants, cellular or acellular, macroscopic or microscopic, which are attached to or living on the bottom. Inflora are plants found in the interstitial spaces of the bottom substrate. The main benthic floral groups are the seagrasses and the benthic algae. The benthic algae predominantly inhabit rocky coastlines and hard bottom. The scarcity of such habitats allows seagrasses to dominate. Benthic fauna which live on the bottom are termed epifauna. Many species are permanently attached to the bottom, a life style not found in the terrestial environment. Many of the epifauna are colonial or consist of groups of individuals incompletely separated from one another. These organisms have developed life-forms which appear more like conventional plants than animals. Other epifauna creep about on the bottom, and some are highly motile. Epifaunal range from the sessile organisms like sponges and anemones to the slower moving forms such as shrimp, lobsters, and crabs to the highly motile demersal fish such as flounder, red snapper, salmon, croaker and grouper. Infaunal organisms, animals which live buried in unconsolidated sediments or burrows in solid substrates, play a major role in reworking the sediment. Fixed infauna are those which live in permanent burrows; burrowing infauna move about, displacing sediment as they go on by creeping or swimming between the sand grains. If they progress by displacing sediment particles, they are called megafauna (echinoderms , mulluscs, flatworms, and annelids). 11-11 I. NATURAL PHENOMENA AND OCS DEVELOPMENT 5,6 The environments of OCS areas are at times subject to the stress of a variety of natural phenomena, such as earthquakes, tsunamis, severe storms and ice. These phenomena can impact oil and gas operations on the OCS. Earthqu ground quakes the Gu 1 Alaska belt th of Alas Richt er Sound) damage ground point, hor i zon earthqu for the notabl e earthqu this ar they co Gulf of intensi akes crac occu f of and at c ka h sea was ext e def o the tall akes wes int akes ea , ns id Mex ty. r epr es king an rring v Alaska the Ale ircumsc as expe le. Th est imat nded ov rmat ion Gulf fl y about in the tern Gu ens it y of not neither ered we ico , th ent d po ari e is ut ia ribe rien e 19 ed a er 1 s oc oor 80 Gul If o have able of 11 1 ere the maj s sibl e s with subj ect n I s Ian s the P ced ei g 64 Alas t betwe 00 mile curred rose ve feet . f of Me f Mexic been r int ens which p ocated is some or geo lands 1 differ to f r ds are ac i f i c ht ear kan ea en 8.3 s from over 1 rt ica 1 On the xico i o i s z ecorde i ty ha roduce events dange logic ides . ent OC equent part Ocean thquak rthqua and 8 the e 00,000 ly abo other s only ero . d for ve occ d dama In r o f e hazar The S are and of th Si es ab ke (P . 6 Ri pi cen squa ut 30 hand slig No ea this urred ging areas arthq d, r dang as . seve e gr nee ove r inc cht e t er re m fee , th ht . rthq area in t sun of uake esul er o For re e eat 1917 7. e Wi r . and i 1 es t an e ri Se i uake , an the ami s the s of ting f ear exam arthq seism , the on th 1 1 iam S i gni perma At d mov sk of smic s of d onl Gulf nor easte low in th- ple, uakes . ic Gulf e f icant nent one ed risk any y two near were rn Tsun "tid gene floo eart char per hour amp 1 an e tsun dama resu occu the reac 5,00 the seis eart dama ami s a 1 w rate r . hqua act e hour s , b i tud xpos ami ge a It f rr en 1960 hed st larg mic hqua ge . - s aves d by Near kes ri ze ), 1 ut g e s i ed c may nd 1 rom ce m t su Japa ruct est sea ke o eism ") a 1 ar ly a of R d by ong ener n th oast reac oss r emo ay b nami n 24 ure s reco wave f 8 I c s re 1 ge-s II t icht gre peri ally e op , of h a of 1 te d e f e wh i hou and rded no Rich ea w ong- ca le suna er m at s ods 10 en s ten heig ife. istu It t ch b rs 1 75, in more t er aves peri , sh mis agni peed (var to 6 ea . thou ht o Ts rban hous egan at er 000 the tha coul (mo od , or t - are tude s of ying mi Upo sand f 10 unam ces . ands in , ki boat At la n 6 d ca re c high dura asso 6.5 pro fro nute n en s of fe is a Th of Chil llin s . nt ic feet use omm - in t io cia or pag m a s), t er mi et re e i mil e a g 2 An hi 30- on 1 y tens n mo ted gre at io few and ing 1 es and gene mpac es a nd k 00 p eart wou 1 gh- foot ref ity veme with at er n (u min low shal from caus rate t of way . ille er so hqua d pr On wav erred t ocean w nt of t large Tsun p to 60 ut es to observ low wat the so e con s i d local a sing For e d hundr ns and ke of 7 obab ly the oth es and o as aves he s subm ami s mi a f able er a ur ce dera 1 y o le xamp eds dest Ric gene er h sign ea ar ine are 1 es ew long , a ble r can le, there , roy ing ht er - rate a and , an i f i cant 11-12 Recurrent severe weather is a as maximum wind speed and wav Severe weather affects explor phase of operation. Waves ca increase dynamic stresses on cause seasickness. In the No been shut down for weeks at a periods. In the last five ye tions have experienced a 20 t to severe weather from Octobe downtime in the North Sea has weather does not pose as grea especially if pipelines are u shore. If a single-point moo the tanker during stormy weat and cyclones pose the most se By way of example, the Middle subjected to more extreme sev than either the oft times sto Storms with sustained winds o to occur at least once over a whereas in the Gulf of Alaska in the Middle Atlantic it wou wave heights of 55 feet can b during a 100-year period in t in the North Sea, and a 25-ye s impo e heig atory n mo v e equipm rth Se t ime , ars , s o 3 r r thro been t a pr sed to ring i her ca vere s and S ere s t rmy Gu f at 1 90-ye the p Id be e expe he Gul ar per rtant t hts are dri 1 1 in a mobi ent han a , dr i 1 espec i emi subm >rcent ugh Mar about 1 oblem d transp s used, n cause torm th outh At orm con If of A east 10 ar peri er iod w 30 year cted to f of Al iod in da to g mo 1 e p dlin ling ally ers i down ch. 5 pe urin ort ina shu reat 1 ant diti 1 ask kn od i ould s . occ aska the ily struc re th latfo g dev oper dur i ble d t ime The r cent g pro the p bilit tdown to ic OC ons d a and ot s c n the be 5 Furth ur at , a 6 At Ian CS ope tur e d an any rm end' ices a at ions ng win r i 1 1 in attrib annual Sev duct io roduct y t o m s . Hu CS ope S area ue to North an be North year er , si least 0-year tic . rat ions e s i g n . other ugh to nd to have ter g opera- utabl e average ere n, to oor rr icanes rations . s are hurricanes Sea . expected Sea , s , and gni f icant once period Ice can cause or contribute to environmental impacts in northern OCS waters, e.g., north of the Aleutian Islands. Ice can form on fixed structures and ships' superstructures, thus increasing the structural stresses. Ice also presents a potential hazard to fixed structures due to collisions of ice propelled by tidal currents and when icebergs occur in navigation routes. Pack ice in northern waters can pose a hazard to fixed structures. Ice in motion has tremendous force. When it encounters the coastline, ice blocks are thrust up on the beach, scouring and gouging the beach and adjacent sea bottom. The action has been reported to occur in depths of 90 to 150 feet on the outer continental shelf. Scour widths of 100 to 200 feet, lengths of 2 to 3 miles, and scour relief of 30 feet have also been noted. 11-13 REFERENCES TO CHAPTER II Seymour, A. H. and others, Radioact ivi ty in th e Ma rine Environment , National Academy of Sciences. 1971. Gross, M. G., Ocean ograph y: A View of the Earth, Prentice- Hall, Inc. Englewood-Cliffs, New Jersey, 1972. U.S. State Department, Dra_f_t Environment a 1 Inrpact Statement on the Third U.N. Law of the Sea Conference, April 1, 1974. U.S. Interior Department, Draft Env ironmental Im pact Statement - Proposed 197 5 PCS Oil and Gas General Lease , f f s h o re T exas , (PES 7 4 - 8 2 7" A u"g ust27, 1974 U.S. Interior Department, Dr aft Envir onment al Im pact Statement - Proposed In crease in Acr eage to be Off ere d for Oil and Gas Leasing on the Outer Continental Shelf, ( D E S 7 4 - 90), October 18, 1974 . " """ Council on Environmental Quality, OCS Oil and Gas - An Environmental Assessment, April 1974. 1 1 - 1 CHAPTER III ENVIRONMENTAL IMPACT OF VESSELS ENGAGED IN OFFSHORE OIL AND GAS DRILLING OPERATIONS Development of offshore oil and gas resources involves a number of steps: (1) geophysical exploration, (2) exploratory drilling, (3) field development, (4) production, (5) transpor- tation and storage, and (6) processing. The primary environ- mental impacts addressed by this statement are those resulting from offshore oil and gas exploratory drilling operations and the related servicing and support activities. The Maritime Administration Title XI program covers vessels engaged in such activities. Secondary impacts related to the Program include those due to offshore oil and gas field development, production, transportation, and storage and to shipyard construction and repair activities. The continental shelf of the U.S. measures 875,000 square miles (560 million acres). Of this, about 2 million acres are under lease, leaving tremendous expanses of unleased and untested shelf areas. In other areas of the world, there are offshore oil and gas reserves that are being developed. The major offshore areas are the Persian Gulf, Venezuela, and the Gulf of Mexico. Other offshore areas containing significant oil and gas reserves are Australia's Bass Strait; the northwest coast of the island of Borneo; the west central African coast; the Gulf of Suez; and offshore Indonesia, Iran, Libya, Norway, Great Britain, Peru, and the USSR. The development and production activity on the continental margin areas will result in a variety of impacts on the natural environment, on other resource uses, on air and water quality, on land use patterns, on the social order and on economics. Some harmful impacts are the unavoidable result of routine operations while others are caused by occasional human error. Still other impacts are avoidable and can be controlled or avoided by safe operating procedures and by strictly enforced regulations. A. DEVELOPMENT OF OCS OIL AND GAS RESOURCES 1. EXPLORATORY DRILLING (2) Geophysical exploration describes all the techniques, except drilling, used to locate geological formations which may potentially contain oil and gas accumulations. It includes passive reconnaissance techniques such as air and shipborne measurements of the earth's magnetic and gravity fields and of hydrocarbon seeps into the atmosphere as well as active surveying techniques such as seismic analysis, bottom sampling, and bottom coring. III-l After a geophysical survey has located geological formations which possibly contain oil and gas, exploratory drilling is required to determine whether commercial quantities are present. The drilling equipment is mounted on a platform as described in Chapter I, e.g., a barge, a drill ship, a semisubmer s ibl e , or a jackup. The drilling unit is positioned over the site, and the exploratory drilling operation begins by rotating a drill bit on the bottom of a string of pipe. See Figure IIIA-1. Cuttings from the drill face are removed by a fluid called "drilling mud" which is pumped down through the pipe, out through the bit and circulated back to the surface via the annular space between the drill string and the bore hole. At the surface a pipe carries the cuttings in suspension to the drilling unit where the cuttings are removed and the drilling mud is re-used. Sporadically, depending on water depth, when a soft formation is suddenly encountered, it might be required to release the mud column in the riser, whole or in part, by opening a dump valve at the ocean floor. The most serious hazard during exploratory drilling stems from the possibility of a blowout - the sudden surge of oil or gas. pressure up the drill hole causing loss of control over the well. Although most blowouts involve only gas, large quantities of oil may be released to pollute the marine environment. If ignited, oil and gas may burn out of control, threatening personnel and equipment. Drilling companies employ safeguards to minimize the likelihood of blowouts. The heavy "drilling mud" fluid is circulated in the drill hole to counteract the possible sudden flow of oil or gas. Other safeguards used include encasing the upper part of the drill hole with steel pipes set in concrete to minimize the possibility of a blowout around the outside of the drill pipe and installing blowout preventers -- control valves capable of closing off the bore hole in case a blowout does begin The casing provides an anchor to which the blowout preventer (BOP) stack is attached. The BOP stack is a series of control valves which can close part or all of the drill hole if there is a threat of losing control of the well. See Figure IIIA-3. Pipe rams close off the annular space between the casing and the drill pipe if oil or gas blows the drilling mud up the annulus. Blind rams close the entire drill hole when there is no drill pipe in the hole. Shear rams close the holes by shearing the drill pipe and dropping it into the well. III-2 p o I— I J w.-„, r CONDUCTOR*-*! 1 " SURFACE- INTER- V1EDIATE PRODUCTION- CASING CEMENT CASINC SHOE LOOSE j^ SURFACE SOIL if f^SHALE OR CLAY GRAVEL BED SHALE FRESH WATER SAND SHALE LIMESTONE SHALE SHALE Source: Petroleum Extension Service, Division of Exten- sion, University of Texas, A Primer of Oil Well Drilling (3d ed., Austin: Petroleum Extension Service, University of Texas, 1970). Figure IIIA-2 Geological Structure and Casing in a Typical Oil Well III-4 \ 2" FILL LINE OR LARGER Z_ 1 FLOW LINE HYDRIL I X I 2" KILL @) © m © m ? LINE OR £_ PIPE RAMS — I — ^X LARGER IXI IXI ft I SPOOL X X BLIND RAMS E 2" LINE OR LARGER SWACO OR EQUAL 2" LINE OR LARGER © © ©© 1 - 4" Hydraulically operated gate valve 2 - 4" Howco "Lo-Torq" plug valve or equal 3 - 4" x 2" x 2" x 2" flanged cross 4 - 2" Howco "Lo-Torq" plug valve or equal 5 - 2" adjustable choke 6 - 2" or 4" Howco "Lo-Torq" plug valve or equal 7 - 2" flanged tee with 2" companion flange 8 - Cameron pressure gauge or equal 9 - 2" flanged tee with 2" companion flanges 10 - 4" x 2" adapter flanges (if needed) 11 - 2" tapped bull plug 12-2" or 4" flanged check valve (optional) Source: Tetra Tech, Inc., 1973, "The Effect of Natural Phenomena on OCS Gds and Oil Development," prepared for the Council on Environmental Quality under contract No. EQ4AC010. Figure IIIA-3 A Typical Blowout Preventer Arrangement III-5 B 1 owou effect preven and eq being gas is to the mental the es and re Mud , w close t s s of t er . uipm dril bur wel pol capi lief ater the omet the Wh ent led ning 1 he luti ng g wel , an form lmes dril en t are or i I P ad on w as a Is a d/or at io occ ling his empl s pr f po reve ill nd o re d cem n an ur reg mud , does o oyed , oducin ssible nt s ca result i 1 are rilled ent ar d st op ardl the ccur depe g an , th ppin if all to e pu the ess of the counter-balancing casing, and the blowout , certain response techniques nding on whether the well is d whether the escaping oil or e well is capped. When damage g or when serious environ- blowing oil is not consumed, owed to burn at the surface the producing zone or zones, mped down the relief well to blowout . 3 FIELD DEVELOPMENT (2) Discovery of commercial quantities of oil or gas calls for development plans which consider additional exploratory wells to determine the extent and capacity of the field; selection, construction, and assembly of the production facility; number of production wells; and transportation of the oil or gas to a processing plant. These development plans for OCS and state leases are submitted to the responsible Federal and state authorities, respectively, for approval before development begins . a . Field Development Facilities In contrast to exploratory drilling, most offshore development and production facilities are fixed platforms. A fixed plat- form may be used to drill 10 to 30 wells. After all wells are drilled, the drilling rig is disassembled, and production equipment is installed on the platform. An emerging alternative to fixed production platforms is the subsea production system which involves placing the well heads on the ocean floor rather than on platforms. There are three types of subsea systems under development: single subsea wells, encapsulated systems, and nonencapsul at ed multiwell systems . The then a ne of t chain f loo per mar i ext e will invo from equi d i vi sing com arby hese ber s r . squa ne . nded be Ives a v pmen ng b le s plet fix sys enc Work re i If to re la a w esse t is ell ubsea ed on ed pi terns lose men e nch p 1 -atm 3, 000 tivel et sy 1 pos loca (whic we 1 the at f o are esse nt er r es s osph fee y in stem it io ted h do 1 is oce rm o now nt ia the ure) ere t de sens of ned with es n drilled an floor r t o a s active . lly dry 1 -atmos chamber encapsul pths , th i t ive to s everal over the in the s ot requi from Oi hor e For land phere from at ed e cos wate c lus t sys t ys t em re a a m 1 an f aci the well (no a d sys t t of r de ered em . and prof obil d ga lity seco hea mina ivin ems sub pth. sub The is essi e rig and is s are piped to Eighty-two nd type, dry ds on the ocean lly 14.7 pound g bell or sub- can be economically sea completions The third type sea wells drilled production serviced by a onal diver) . III-6 b . Dril l ing and W e ll Co mp let i on After the fixed platform or subsea system is assembled, develop- ment drilling, similar to exploratory drilling, commences. Generally, a number of wells are drilled from a single platform. Directional drilling -- a standard practice which directs the drill off a vertical line to reach lateral sections of the oil or gas reservoir -- makes the most economical use of the expensive platforms. If commercial quantities of oil or gas are found, the well is completed, a term describing various steps in preparing a well for production. Completion can include setting and cementing casing, perforating (cutting holes in the casing which will permit oil or gas to flow from the formation into the well hole), fracturing (applying pressure or using explosives to increase formation permeability), acidizing (using acid to enlarge openings in the formation), consolidating sand (to keep sand from entering the well bore), setting tubing (conduit for routing the oil or gas to the surface), and installing downhole safety devices (valves installed to prevent blow- outs during production). If performed after initial completion, they are considered servicing or workover operations. Development drilling is generally less hazardous than exploratory drilling because the characteristics of the geological formations are better known. The potential threat of a blowout, however, remains . The severity of a development well blowout increases signifi- cantly if oil or gas is being produced simultaneously from wells already completed. If a dry well is drilled, it is plugged with cement and aban- doned. If a well is to be abandoned, either because it is a dry well or all the economically recoverable resource has been extracted, then all casing and piling is severed to at least 15 feet below the ocean floor and is removed. In the past, stubs of casing and piling extending above the bottom have interfered with fishing and navigation. Current procedures for OCS well abandonment are covered in OCS Order No. 3. 3. PRODUCTION (2) Once a well is completed and connected to production facilities, production may begin. If oil, gas and other materials are produced, they must be separated. The oil is separated, metered, and pumped to shore by pipeline, to offshore storage tanks for eventual transfer to a tanker, or directly to a tanker. The gas is separated; if it contains water, it is dehydrated by contacting it with glycol; and then it is pressurized, metered, and pumped to shore by pipeline. Where there is no gas pipe- line or OCS gas production is not economical under prevailing market conditions, the gas is pressurized and reinjected into the res ervoir . II I -7 When Cons char is 1 is 5 may r emo Prot limi oil ment Code near water ist ent ged int 00 part parts be disc ved , as ect i on t at i ons and gas s are c of Fed future is p with o th s pe per arde req Agen and ext onta eral r oduc OCS e oce r mi 1 mill d int uir ed cy ha guid racti ined Regu ed w Orde an . lion ion o th in s re el in on p in a lati ith the r No. 8 The ma ; the a or less e ocean OCS Ord cent ly es for oint so new Pa ons and oil , se ximu vera S aft er N deve the urce rt 4 wil , sep parat m all ge al and p er th o. 7. loped offsh cat e 35 to 1 be arat i ed wa owab 1 lowab roduc e oil The str i ore s gory. Chap app'l i on is r ter may e oil c le oil ed with has be Enviro ngent e egment These ter 40 cabl e i equir ed . be dis- onten t content the oil en nment a 1 ffluent of the require of the n the Because of the possible explosions and fire, storms, and earth- quakes, many devices are installed to warn of impending or existing dangers and to control or stop the flow of gas and oil if trouble is sensed. Some of the safety devices with which fixed platform production facilities are equipped are pressure, level, and combustible gas sensors; manual, automatic and pressure relief valves; and fire detection and fighting equipment. In addition, each well is equipped with a subsurface safety valve which can shut the well down in case of surface equipment failure. Required safety and pollution control equipment and procedures are described in OCS Order No. 8. Although production is a continuous activity, it is sometimes necessary to shut down and reenter a well to improve or restore production. A variety of operations may be involved in workover and servicing, including further drilling to deepen the well. Because the well may be active and/or open, well control is the primary safety consideration, requiring the use of blowout prevention equipment. 4. TRANSPORTATION (2) Crude oil and natural gas liquids may be transported to onshore processing facilities by pipeline. All the natural gas now produced in the Gulf of Mexico and off Southern California is transported to shore by pipeline. All the oil produced off California and 97 to 98 percent of the Gulf oil is piped to shore. Because most of the OCS geological formations with oil and gas potential lie within 200 miles of shore, pipelines will probably continue as the preferred OCS transportation mode . Tankers may well be used for transporting oil during the early phases of field development in areas remote from established producing fields. Production can begin earlier, particularly far offshore, if tankers are loaded from offshore moorings in or near the field. Ill -8 a . Pipel ines Pipelines transport large volumes of oil and natural gas. Once the pipeline route is selected and the volume to be pumped is determined, pipe size and strength are selected, and line pressures calculated. Considered during route selection are bottom and subsurface foundations; current, wave, and tide conditions; and other uses -- shipping, commercial fishing, naval operations, etc. -- of the area to be crossed . Primary techniques for laying pipe in coastal waters are sect ion-by- sect ion or "stove pipe", reel barge, and pipe pulling. In the stove pipe method, short sections of pipe are welded together on a pipelaying barge. While the barge moves slowly forward, the completed pipeline is released into the water and laid on the ocean floor. There are several types of barges and several ways to lower the pipe. The vessel may have a barge or ship hull or it may be semisubmer- sible. The barge hull is the most common, although it limits operations to relatively calm seas -- 6 to 14-foot waves. Semisubmers ib le hulls are the most stable. Behind the barge, the welded pipe section is supported by a pontoon or "stinger" that reduces stress caused by the pipe's own weight. The two most commonly used pontoons are the straight, rigid stinger and the curved stinger. In the reel barge method, pipe is welded together onshore and is wound onto a large reel on the pipelaying barge. The pipe is laid as it unwinds. For pipe diameters in the 4 to 10-inch range, reel barges are often more economical than other types of barges. The technique is limited to pipe diameters of 12 inches or less . Pipe pulling uses barges and tugs to pull sections of welded pipe from an onshore launchway over the pipeline route. This method is limited to pipeline of relatively small diameter and short length. Generally, it is used only for laying pipelines near shore. In water depths of less than 200 feet, present OCS administra- tive procedures require burial of the pipelines. The minimum depth of burial is 3 feet except in shipping fairways and anchorage areas, where the minimum depth is 10 feet. Technology exists to bury pipelines in water depths of 600 feet, for cases where such action is deemed advisable. However, one of the most effective methods of protecting a pipeline from damage due to earthquakes, is to leave the portion in deeper waters on the ocean floor surface where it can maintain as much independent flexibility relative to the surface as possible. Conventional dredging equipment can be used in shallow water, but it is practically impossible to lay a line in a previously prepared trench in deep water. For this reason marine pipelines are commonly buried after the line is laid. III-9 Burial is usually affe underneath the pipelin resulting trench. The consists of a work bar pressure water pumps a a mul t ip le-membered to water line, and air li structure which stradd it on rollers. Affixe several nozzles which pressure, ahead and be out of the narrow tren by the air and deflect fins. The suspended s side of the trench. A the pipeline settles i quite soon by the rewo back into the depressi of original bottom con shallow waters, experi is quite rapid, wherea may be required. The soft formations, but t velocity jets makes th sediments . cted by jetting sediment away from e and allowing it to sink into the equipment used in this operation ge equipped with high volume/high nd air compressors. From the barg wl ine, consist ing of a strength mem ne, extends downward to a U-shape les the pipeline and glides along d to the U-shaped jetting device a direct water and air, under high low the pipeline. Sediments are b ch by the water jets, partially li ed to the sides by various types o ediments fall diffusely along eith s the jetting device is pulled for nto the trench and is partially bu rked sediment as it slips and sett on. Complete burial and restorati tours may require additional time, ence has shown that contour restor s in deeper waters, more than a ye jet method is most effective in fa he use of extremely high pressure, e system effective in most sea flo e, ber , re lasted fted f er ward , ried les on In at ion ar ir ly high or b . Tankers and Barges Although tankers and barges transport less than 3 percent of the oil produced in the Gulf of Mexico, tankers may be used in the initial phases of field development in OCS areas. Transportation of oil by tanker has recently received considerable attention because of the development of Very Large Crude Carriers (VLCC) or supertankers and because of subsequent proposals for siting superports off U.S. coasts. Because a supertanker is economically advantageous only over great distances -- from the Persian Gulf to the United States, Western Europe, or Japan, for example -- VLCCs will probably not be used in OCS operati ons . Oil pjllution from tankers and barges results from collisions and groundings and from operational problems such as equipment failure, human error, and operational discharges. The major source of oil pollution from tankers is intentional discharge -- the pumping of oily ballast water and tank washings into the oceans. Over 70 percent of all oil released from tankers has been due to these routine operations. Another important source of pollution from tankers is spillage as oil is being trans- ferred to and from tankers at marine terminals. Mechanical failure, faulty design, and human error account for most of this spillage. 111-10 Single point moorings (SPM) , also known as single buoy moorings (SBM) , have recently been developed to reduce the hazards of storms to tankers and to minimize oil spills during loading. Over 100 SPMs are in use throughout the world. A tanker is moored to a single point, and loading hoses are connected between it and the buoy. Because the mooring and hoses can circle the buoy, the tanker moves to head into waves, tides, and storms. The SPM thus allows a tanker to remain moored in 15 to 20-foot waves accompanied by winds and currents. 5. OFFSHORE OIL STORAGE (2) As development proceeds farther from shore, it may become economical to store the oil offshore temporarily while awaiting tankers. This is especially important when severe weather conditions prohibit the mooring of tankers for extended periods of t ime . Three types of offshore oil storage systems are now being used in various parts of the world -- elevated, floating, and bottom standing. The size of an elevated storage facility is severely limited because it must be mounted on a platform far enough above the water surface to avoid wave action during the most severe storms. The structural capability of the platform, then, is the limiting factor. In the Gulf of Mexico, maximum storage capacity on an individual platform is 10,000 barrels. Several large floating storage barges are now in use. The one million barrel barge, PAZARGAD, is a storage, desalting, and loading facility in the Persian Gulf. It employs a single point moorint (SPM) system in order to head into the winds and currents and to withstand storms better. Another barge of the same volume, also moored to a SPM, is being used off Indones ia . Storage facilities which rest on the ocean floor either may be submerged or may extend above the water surface. The most outstanding examples are the three dome-shaped tanks of the Dubai Petroleum Company in the Persian Gulf and the cylindrical concrete tank of the Phillips Group in the Ekofisk ar.ea of the North Sea. The Dubai tanks stand in 150 feet of water. Each has a capacity of 500,000 barrels. Oil is loaded into tankers from a SPM. The Phillips tank, with a capacity of one million barrels, stands in 230 feet of water. Production equipment is mounted on top of the tank which extends nearly 100 feet above sea level. The side of the tank is protected from wave action by a perforated outer wall. I II- 1 1 B OCS ACCIDENTS, OIL SPILLS, AND CHRONIC DISCHARGES Marine P Confer en duct i on energy i terious health , impairme amenitie engaged come fro operat io include sources devel opm tation a ollu ce o by m nt o effe hind nt o s . in o m dr ns . sewa of m ent ct iv t ion n the an , d the m ct s a er anc f qua Impac ffsho illin Vess ge, g arine on t h it ies has Hum i rec arin s ha e to lity t s o re d g ac el g arba pol e OC been an E tly e en rm t mar for n th rill t ivi ener ge, luti S ar def nvir or i viro o li ine use e ma ing, ties ated st ac on r e pr ined onmen ndire nment ving act iv of s rine supp and poll k exh esul t cduct by the U n t (June 1 ct ly , of result in resources it ies inc ea water , environme ort , and from vess utants ot aus t , and ing from ion , st or i t ed 972) subst g in , haz ludin and nt fr servi el ca her t nois oil a age, Nati as t ance such ards g fi redu om v ce o sual han e . nd g and ons he intro- s or dele- to human shing, ct ion of essels perations ties and oil Other as transpor- It has been estimated that approximately 6.1 million metric tons of petroleum hydrocarbons (oil) -- or about 0.25 percent of that produced -- entered the ocean annually during the 1971-.1972 time frame. Major petroleum sources were calculated to be: marine transport - 33 percent; river runoff - 27 percent; coastal activities - 18 percent; atmospheric fallout - 10 percent; and offshore petroleum production - 2 percent . » From 1953 through 1972 -- when nearly all the wells were drilled in the U.S. OCS -- 43 major accidents occurred (see Table IIIB-1) Nineteen were associated with drilling, 15 with production, and 4 with pipelines. Over the 19 years, there has been an average rate of 0.005 (0.5 percent) drilling and production accidents per successful OCS well drilled. During the same period, 8 blowouts were recorded in state waters, i.e., within three miles of the coast. The incr has out and dril 1973 mor i a st safe of a c lea f req ease been rais the ling , th tori aff ty e ma j n-up uency of OCS accidents generally increased as activity d until 1968 when the accident frequency peaked. It decreasing since then. The 1969 Santa Barbara blow- ed serious questions on the adequacy of OCS technology, State of California imposed a moritorium on all new on existing state tidelands leases. On December 11, e California State Lands Commission lifted the urn. The three member commission unanimously adopted report indicating that the oil industry had developed quipment and procedures that minimized the possibility or oil spill occurring and provided for effective in the event of a spill. 1 1 1 - 1 2 TABLE I I IB- 1 lajor Accidents on the U.S. Outer Continental Shelf, 1953-1972 Results Drilling Production f Pipeline Collision Weather K Total Number 19 15 4 2 3 43 Oil 3 4 1 3 11 Oil and gas 2 7 9 Gas 17 2 19 Other 3 1 4 Oil spills 2 10 4 1 3 20 Oil volume (thousand barrels) 18.5-780 84-135.4 175 2.6 9.2-9.7 290-1,100 Deaths 23 33 56 Injuries 7-8 91-100 98-108 Fires 7 12 1 20 Major rig/platform damage 4 9 2 15 Duration 2 hrs.-5.5 mos. 10 min.-4.5 mos. 1-13 days 1 day 1 -3 days 10 min -5.5 mos. Sources: University of Oklahoma Technology Assessment Group, Energy Under the Oceans: A Technology Assessment of Outer Continental Shelf Oil and Gas Operations (Norman: University of Oklahoma Press, 1973), using U.S. Geological Survey, U.S. Coast Guard, Offshore, and Oil and Gas Journal data. Since Santa Barbara, three major production platform accidents have occurred in the Gulf of Mexico, the Shell accident (1970), the Chevron accident (1970), and the, Amoco accident (1971). The diminishing number of drilling accidents since 1968 reflects improvements in both technology and practice. Recording and reporting practices with respect to oil spills have improved greatly. The frequency of production accidents has not decreased so markedly, perhaps because old offshore production facilities and pipelines do not, in all instances, meet the specifications now called for in new facilities and pipel ines . 1. OIL SPILLS (2) Although accidents during offshore operations account for only a small portion of the oil that is spilled, locally they can be significant. Their frequency and magnitude and the fate and effects of the oil are important factors in 0CS develop- ment deci s ions . The most important general features of oil spill statistics from 0CS operations are the following: The size range of individual spills is extremely large, from a fraction of a barrel to over 150,000 barrel s . Most spills are at the low end of this range; in 1972, 96 percent were less than 24 barrels (1,000 gallons) and 85 percent were less than 2.4 barrels (100 gallons) . 1 1 1 - 1 3 A few very large spills account for most of the oil spilled. These facts are highlighted in order to point out the meaningless ness of estimating "average" amounts of oil that might be spilled 'at particular steps in the development process. Amounts spilled can vary by a factor of one million, and single large spills distort the statistical distribution of spill magnitudes. Further, as shown in Table IIIB-2, fluctuations from year to year are quite large. Certain patterns emerge from the statistical' analysis of oil spills for the four major sources of offshore oil pollution. Table IIIB-3 shows remarkable similarity in the number of oil spills in each volume category for 1971 and 1972. The data suggest that the same processes, equipment inadequacies, and operator errors are causing the spills. Computer Sciences Corporation, under contract to the Environmental Protection Agency, recently analyzed the failures and errors that have caused these spills. Although restricted by the limited data base, the study suggests that remedy of certain technological and operation inadequacies could significantly reduce the number and size of oil spills. Similarly, the U.S. Coast Guard has analyzed its oil spill data and is incorporating the results into the Federal inspection and enforcement program . 2. PLATFORMS AND PIPELINES (2) Bet wee from p of mor of med least the li over a barre 1 chance of the the ge Figure plat f o about will b spill volume that i n 1964 lat f orm e than ium siz one p la fe of t 25 per s , and of a p fie Ids neral p IIIB-1 rm betw a 40 pe e handl does oc will e t will and 1 s and 1 ,000 e , th t f orm he fi cent for a latfo . Th att er , whi een s r cent ed be cur , xceed excee 972, pip bar ere spi eld. chan lar rm s e pr n ex ch s ucce cha twee ther 2,3 d 23 the e 1 in r el s is a 11 o Fo ce o ge o pill obab hibi hows ssiv nee n la e is 80 b ,800 re were es (Tab of oil bout a ver 1 , r a sma f one p il find over 1 ility o ted by the vo e spill that 25 rge spi an 80 arre Is barrel relat ive 1 le IIIB-4 ) . For an 70 percent 00 barrels 11 oil fie latform sp , there is ,000 barre f pipel ine platform s lume of oi s , indicat mil lion lis. If a percent ch and a 35 p s . y few la lists th oil fie chance will oc Id find, ill over over a Is durin spills pill sta 1 handle es that barrel s large p ance tha ercent c rge spi 1 Is e spills Id find that at cur during there is 1,000 95 percent g the life f ol lows t ist ics . d on a there is of oil latform t the hance Figure IIIB-1 also shows that the probability of successive spills increases rapidly as the size of the find increases. Conversely, this means that large spills will occur more often -- for an equal increase in probability of a spill, 4.5 years will elapse in a small find and only 1.0 year elapse in a large find. Biologically, the time between large spills may be at least as important as the number of such spills 111-14 TABLE IIIB-2 OIL SPILL STATISTICS (Barrels) Type of Spill 1971 1972 Petroleum industry-related spills Terminal Number 1,475 1,632 Volume 125,800 54,700 Ships (offshore) Number 22 32 Volume 400 51,600 Offshore production facilities Number 2,452 2,252 Volume 15,600 5,700 Onshore pipeline Number 74 162 Volume 8,700 29,300 Total Number 4,023 4,078 Volume 150, 500 141,300 All spills Number 7,461 8,287 Volume 205,000 518,000 Source: The Massachusetts Institute of Technology Department of Ocean Engineering, 1974, "Analysis of Oil Spill Statistics, " prepared for the Council on Environmental Quality under contract No. EQC330, using U.S. Coast Guard data. Ill- 15 TABLE IIIB-3 Petroleum Industry- Related Oil Spill Volumes [Gallons] Facility 0-1 1-10 10-100 100- 1,000 1 ,000- 10,000 10,000- 100,000 100,000- 1 ,000,000 1,000,000- 10,000,000 Terminal 1971 384 247 458 282 77 19 7 1 1972 351 347 544 298 71 16 5 Ship (offshore) 1971 4 6 8 4 1972 15 2 10 3 1 1 Pipeline 1971 222 403 496 257 41 13 2 1972 15 24 61 61 32 7 3 Platform 1971 227 304 395 146 13 2 1972 431 784 728 244 20 4 Total 1971 837 960 1,357 685 135 34 9 1 1972 812 1,157 1,343 606 123 27 9 1 1 Forty-two gallons equals 1 barrel. Gallons, rather than barrels, are used to illustrate the fact that most spills involve a small volume of oil. Source: The Massachusetts Institute of Technology Department of Ocean Engineering, 1974, "Analysis of Oil Spill Statistics," prepared for the Council on Environmental Quality under contract No. EQC330, using U.S. Coast Guard data. TABLE IIIB-4 Major Oil Spills from Offshore Production Facilities, 1964-1972 1 Amount Cause Date reported (barrels) Offshore platforms Union "A," Santa Barbara Blowout January 28, 1969 77,400 Shell ST 26 "B," La. Fire December 1, 1970 52,400 Chevron MP 41 "C," La. Fire March 10, 1970 30,950 MP gathering net and storage. La. Storm August 17, 1969 12,200 Signal SS 149 "B," La. Hurricane October 3, 1964 5,000 Platform, 15 miles offshore - July 20, 1972 4,000 Continental El 208 "A," La. Collision April 8, 1964 2,600 Mobil SS 72, La. Storm March 16, 1969 2,500 Tenneco SS 198 "A," La. Hurricane October 3, 1964 1,600 Offshore pipelines West Delta, La. Anchor dragging October 15, 1967 157,000 Persian Gulf Break April 20, 1970 95,000 Coastal channel. La. Hit by tug prop October 18, 1970 25,000 Chevron MP 299, La. Unknown February 11, 1969 7,400 Gulf ST 131, La. Anchor dragging March 12, 1968 6,000 Coastal channel, La. Equipment failure December 12, 1972 3,800 Coastal waters. La. Leak March 17, 1971 3,700 Coastal channel, Tex. Leak November 30, 1971 1,000 Coastal channel. La. Leak September 28, 1971 1,000 'Over 1,000 barrels. Source: The Massachusetts Institute of Technology Department of Ocean Engineering, 1974, "Analysis of Oil Spill Statistics," prepared for the Council on Environmental Quality under contract No. EQC330. II I - 16 o LO CN CN 1 to 2 1 _ 1 2 o 2 LU 1 al O o o F O 1 cc o h- U h- 1 < CN o Z> i - co O 1 m Z) - — ' — a D 1 o o o o DC Q O q_ cc D. 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Dl O o o a) b .c D CI) o h c > n u CD > CI) tu 3 ro .- o 3 r > b — JZ. 3 CD ( 1 Oj 3 a ro U c ra CD F 2 c o 1 a> - CC o c o O 3 bo •H LL LO r-- o LO T LO CN I II - 17 3. TANKERS (2) About 98 percent of all the oil spilled accidentally by vessels is from incidents over 1,000 barrels. Most large tanker spills occur within 50 miles of land. Most result from groundings, rammings (the vessel hits a fixed structure), or collisions. Groundings and rammings occur nearshore. Collision frequency depends on traffic density, which is highest nearshore. Analysis of tanker spill statistics indicates that, if tankers are used to transport the oil to shore, the probability that there will be one tanker spill over 1,000 barrels is about 27 percent during the life of a small find, about 85 percent for a medium find, and nearly 100 percent for a large find. As the size of the find increases, so do the number of expected spills and the overall probability that a spill will occur (see Figure IIIB-2). The possibility of more frequent or larger oil spills resulting from the use of single point moorings (SPMs) has also been analyzed. One might expect more spillage at SPMs than at fixed berth facilities because the SPM adds ship motion, flex- ible hoses subject to wave action, and possible loss of mooring to normal loading operations. 4. TOTAL VOLUME OF OCS OIL SPILLS (2) The total volume spilled over the life of a field, although not as important as the frequency and magnitude of individual spills, is of interest. Table IIIB-5 shows that the number and total volume of spills for platforms, pipelines, and tankers are of the same order of magnitude for a given field size. Platforms have the lowest frequency and volume and tankers the highest . In interpreting these data, one must keep in mind that they are based on past experience and do not adjust for future improvements or production economics. If low-productivity OCS fields are discovered, replacement of pipelines 15 to 20 years into the field's life may be uneconomical; this could lead to higher incidence of pipeline leaks. The tanker spills include those from ships registered in all nations; however, U.S. -flag ships have a better overall record. 1 1 1 - 1 'lo CN 2 2 z CO o o o _l LU DC O O O O Z> h- o D h- 3 < CO CN CD CN D O _ CC Q - O <- CC -» S cc o o a. CL a. 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CO c a> CO ■D T3 C O 0) E o > _2 E o CM I 03 O •H LU LO IX o LO LO CN 111-19 TABLE IIIB-5 OIL SPILLED OVER THE LIFE OF A FIELD Number of Total Volume Spills (barrels) Small Find Platform 0. 28 7, 200 Pipeline 0. 31 13, 900 Tanker 0.41 19, 900 Medium Find Platform 1.3 33, 300 Pipeline 1.4 62, 900 Tanker 1.9 92, 400 Large Find Platform 4.7 120, 500 Pipeline 5. 2 233, 300 Tanker 6.9 335, 700 Source: The Massachusetts Institute of Technology Department of Ocean Engineering, 1974, "Analysis of Oil Spill Statistics", prepared for the Council on Environmental Quality under contract No. EQC330. Although the M.I.T. approach does not consider average spillage rates valid, mean spill rates were derived at the request of the Council, M.I.T. 's computed ratio of the mean spill rate to the total volume of oil handled for platforms is 0.006 percent, for offshore pipelines is 0.011 percent, and for tankers is 0.016 percent. 111-20 5. CHRONIC DISCHARGES (2) Several routine OCS operations result in discharges of oil and other materials to the water. Unlike that for accidental spills, their probability is 1.0 -- they have a 100 percent chance of occurring. Securing production platforms with pilings or anchors, anchoring vessels, and burying pipelines offshore disturb bottom sediments and increase turbidity. As previously described, drilling mud is separated from the drill cuttings, and the mud is recycled and reused. Drill cuttings are discharged overboard; and mud discharge is generally limited to small amounts of material which cannot be effectively separated from the drill cuttings. Drill cuttijigs are shattered and pulverized sediment and native rock. Drilling mud may consist of such substances as bentonite clay, caustic soda, organic polymer, proprietary defoamer, and ferrochrome 1 ignosul f onat e . During the course of drilling an average 15,000 foot well, a maximum of 110 tons of commercial mucl components would be used and 950 tons of drill cuttings generat ed . Drill cuttings are discharged overboard; drilling mud is not routinely discharged. Heavy, highly treated drilling muds are quite expensive and are efficiently recycled and reused. Mud discharge is generally limited to small amounts of materials which cannot be effectively separated from the drill cuttings. The actual amounts of muds which are actually discharged are highly variable and difficult to determine. During production operations, waters from the geological formations are often released. These formation waters may be fresh or may contain mineral salts such as iron, calcium, magnesium, sodium, carbonate and chloride. Their discharge increases the mineral content and lowers dissolved oxygen levels in the area of operations. The waters often contain small amounts of oil. 6. VESSEL GENERATED POLLUTANTS (2) Vessels involved in OCS oil and gas drilling, support, and service operations generate certain chronic pollutants which are common to vessels in general. A discussion of these pollutants follows: a. Sewage A synthesis of current information concerning the treatment and disposal of vessel sanitary wastes is provided in "Treatment and Disposal of Vessel Sanitary Wastes - A Synthesis of Current Information." 7 For the purposes of this statement the following definitions and policy hold: 1 1 1-21 Sewage - human body wastes and the wastes from toilets and other receptacles intended to receive or retain body wastes (35 gallons/man/day); Domestic Wastewater - wastes from sinks, showers, laundries and galleys (35 gallons/man/day); Sanitary Wastewater - sewage and domestic wastewater (70 gallons/man/day), daily per capita weight (grams) BOD 90 and SS 106; The discharge of sewage and domestic wastewater must be in compliance with the Federal Water Pollution Control Act of 1972, Annex IV of the 1973 International Marine Pollution Convention, and the applicable EPA and U.S. Coast Guard regulations. A marine tion onb treat or Sewage i day. Th chemical and inte the mate and urin other ma Urine ha 4.6 to 8 percent dai ly pe appr oxim pH of 6. so 1 ids o 90 grams sanitary hazard t in coast world co must be small am operat in san oard dis s ge e ch pro ract rial al s t eri s a .0. and r ca atel 7. f wh of was o th al w nt ai take ount g in itat a v char nera arac pert ions E comp als spec The 85 p pita y i, Appr ich undi t es e ma at er n li n in of the ion dev essel w ge sewa ted abo ter ist i ies of that t xcludin rises u for whi ific gr water ercent accumu 620 gra oximate 65 perc ssolved into th rine en s . The ving cr to cons biodegr open s ice in hich i ge and ard sh cs of the ma ake pi g the rine , ch the avity conten and th lat ion ms , a ly 10 ent ar solid e open vironm fact eatur e iderat adabl e ea . clud s de any ip a vess t eri ace f lus f ece rec of 1 t of e pH of spec perc e di s . oce ent that s th ion sew es any signed proces t appro el sewa al and between h water s, pape ept acl e .002 to feces from 6 body wa ific gr ent of ssolved The dis an does as sani the oc at also when we age dis equip to re s to ximat ge ar the b var i , the r , an s are 1 . 03 range . 9 to st e h avity the m leav charg not tary eans gene ighin charg ment ceiv trea ely e th iolo ous inp d oc not 5 an s be 7.7 as a of ixtu ing e of cons wast and rate g th ed f for in e , reta t such 35 gall e physi gical c element ut to t cas iona intend d a pH tween 6 The weight 0.98 an re comp a weigh a ship t itut e e disch seas of excr et e relat r om a v sta 1 la- in, sewage . ons/man/ cal and ont ent s of oi let s lly ed. of 5 average of d a rises t of 's as great a arges the ions ively essel Direct overboard discharge of untreated or inadequately treated sewage into relatively shallow territorial waters is objec- tionable and may render the water unhealthy for contact recreational sports and be inhibitive to aquatic life. Such discharge introduces floating and suspended solids, increases turbidity, and causes discoloration of the water. Suspended solids reduce the transparency of water to sunlight which is needed for phytoplankt on and attached algae photosynthesis. Settleable solids can form sludge blankets upon river, estuary or coastal beds which produce undesirable changes in bottom life and subsequently decay, producing gases with objectionable odors. Sewage wastes exert an oxygen demand that reduces III -22 free oxygen in the waterway thus inhibiting the ndrmal activi- ties of aquatic life. These wastes may also contain pathogens that can infect people with such diseases as typhoid fever, dysentery, hepatitis and cholera. Shellfish beds must be closed when significant concent r.a tions of fecal bacteria' become evident. A polluting sewage discharge may be characterized as that which: results in un s ight 1 iness (scum, floating material, oil, foam) ; results in noxious odors; results in sludge deposits; causes damage to properties of the environment; is chemically toxic to human, animal or plant life; yields pathogenic organisms; causes excessive oxygen depletion; stimulates excessive algal and water-weed growth. It i a d i e 1 em a d i way . (BOD and requ mate in b wast a fi quan by m tota oxyg pres sewa r es i t i ve s lud wat e s not schar en t s s char The ) , su pH va ir ed rials oth t e. T v e- da tity easur 1 org en de ent . ge is due . of p ge de rway . f ea ge. that ge h se a spen 1 ue . by m in he s he a y in is B ing anic mand The det The ollu posi sibl e Howe yie 1 as th re me ded s BOD icro - water uspen ccept cubat OD-5. re lat carb as a we i g ermin susp t ion t s , a to ver , d en e po asur olid i s orga T ded ed s i on Ot ed p on c n in ht o ed b ende pot e nd n measure there ough in t ent ia 1 ement s s (SS), a measu nisms t his dem and dis tandard t ime ; a her ass aramet e ontent , di cat io f suspe y filte d solid nt ial i oxious all the po are measure formation t of serious of biochemi number of re of the q o stabilize and is exer solved soli method of more preci essments of rs such as total oxyg n of the qu nded solids ring, dryin s in a sewa n the form odors that 1 lut in ment s o asce ly pol cal ox col if o uant it biode ci sed d e lem BOD me se sym oxyge dissol en dem ant i ty in a g, and ge sam of uns may oc g el erne of cert rtain w luting ygen de rm bact y of ox gradab 1 by orga ent s of asureme bol of n can b ved oxy and, or of pol given v weighi pie are ight 1 in cur in nt s in ain hether a water- mand eria ygen e nisms sanitary nt requires this e obtained gen content, chemical lutant s olume of ng the indi ca- ess , the It is recognized that untreated sewage from vessels, while not the chief contribution of the sewage contamination of our waterways, is certainly additive to pollution from communities along these waterways and from recreational boats. Under the authority of the Federal Water Quality Improvement Act (Section 13) of 1970, the Environmental Protection Agency (EPA) has established standards (Federal Register, Friday, 1 1 1 -23 June 2 3, 1972) of performance for marine sanitation devices to prevent the discharge of untreated or inadequately treated se- wage into or upon the navigable waters of the United States from vessels. Detailed EPA standards (8) can be summarized as foil ows : The long range standards are designed to bring about an end to the discharge of wastes - treated or not - into navigable waters. The EPA standards will become effective for new vessels two years after the Coast Guard imple- menting regulations are established and for ex- isting vessels five years from that time. Incentives are provided for vessel owners to equip their vessels with marine sanitation devices certified by the Coast Guard. Coast Guard certification calls initially for de- vices which will as a minimum requirement reduce fecal coliform bacteria to no more than 1,000 per 100 milliliters and prevent the discharge of visible floating solids. Existing vessels, with certified sanitation devices installed within three years after the initial standards and regulations are promulgated, would be allowed to retain such devices for their useful life. If the equipment is installed between three and five years after the date of promulgation, it could be used for eight years after the date of promulgation . States may ask EPA to issue regulations completely prohibiting vessels from discharging any sewage - whether treated or not - into State waters that re- quire special protection to meet water quality standards and are part of the Nation's navigable wat er sys t em . Significant research and development advances are presently bein; made in the field of shipboard sewage (and sanitary waste) treatment. Section 70 of the Mar Ad Standard Specifications for Merchant Ship Construction (9) has been modified and requires the installation of certified marine sanitation devices. Cer- tification procedures and design and construction requirements of the Coast Guard are contained in Title 33, Part 159 of the Code of Federal Regulations. Sewage generated aboard rigs and platforms is regulated by OCS Order No. 8 of the U.S. Geological Survey . 1 1 1 -24 b. Domestic Wastes (6) Domestic waste means wastewater from laundries, galleys, showers, sinks, etc. The most significant domestic wastes environmentally are laundry detergents and liquid garbage. Domestic waste is generated aboard ship at approximately 35 gallons/man/day. Because of the very low concentrations of detergents and the nature of liquid garbage in domestic waste waters, these wastes are not of great environmental signifi- cance. Polluting domestic waste discharges have many of the same characteristics as polluting sewage discharges. c. Garbage (6) All operating vessels will daily dispose of quantities of garbage in various ways. Although aesthetically unpleasant, over-board discharge of biodegradable garbage in the amount normally produced by vessels in the ocean is not considered hazardous to the environment and may in fact be beneficial to a certain extent by providing additional nutrients to an area where normal low nutrients may be limiting to abundant phytoplank ton growth . In port, on the other hand, local ordinances usually forbid garbage being dumped overboard. Consequently, the garbage and trash are either collected for disposal ashore, or they are contained aboard ship for overboard discharge after the vessel puts to sea. Traditionally, MarAd has subsidized the instal- lation of garbage grinders and, in addition, is considering the possibility of treatment of the effluent in combination with sewage treatment or removal by incineration. d. Stack Exhaust Emissions (6) Stack emissions are usually considered in terms of: (1) smoke appearance or density; (2) quantity and size of particulate matter; and (3) quantity and noxious characteristics of gases, fumes or vapors emitted such as sulphur oxides, nitrogen oxides and unburned hydrocarbons. Shipboard sources of these emissions include the diesel propulsion systems, auxiliary boilers, auxiliary diesel engine driven equipment, and in- cinerators . e . Noise (6) The vessels engaged in offshore oil and gas drilling operations, such as the service vessels, generate noise in their operation 111-25 primarily from their whistles, from the operation of diesel engines, and from other machinery such as pumps. With excep- tion of the noise from whistles, these sounds are limited to the vicinity of the vessel and are of a relatively low level, being muffled by the structure of the vessel itself. f . Oil Oil spills can occur from bilge pumping, fuel tank leaks, and bunkering operations: Bilge pumping - the bilge is the lowest point of the vessel's inner bottom and is used to collect oily wastewater from machinery spaces. This waste water must be discharged at regular intervals. Leaks - Leaks occur due to lack of complete hull integrity. Welded construction and double bottoms tend to reduce leaks to a negligible quantity. Bunkering operations - Refueling discharges are caused by (1) mechanical faults, (2) design faults, (3) human error. C HISTORY OF OCS PETROLEUM DEVELOPMENT ACCIDENTS In any complex industrial operation involving heavy equipment, flammable materials, work at sea, large number of employees, and reliance on complex technology, it is inevitable that ac- cidents will occur. Proper analysis of these accidents is a complex problem. The history of OCS petroleum development ac- cidents provides a substantial data base for estimating the frequencies of future accidents. 1. NATURAL GAS LEAKS ASSOCIATED WITH BLOWOUTS (10) Info 195 6 dur i Mexi OCS. fire The seve made impa inc i OCS rmat to ng co . El s an dura n mo D ct o dent plat ion 1973 CS p No even d fi t ion n ths egr a f ga s a 1 form furn lis et ro gas of ve w of N dat i s 1 e so r ere ishe ts 3 leum leak thes ere thes o es on o aks esu 1 w an d by 8 ga dev s ha e in as so e bl t ima f ai with ted d in the s lea e lopm ve be c iden c iat e owout t es o r qua or w in in dama Geo lo ks as ent o en re t s in d wit s ran f the lity i t hou jury ge or gica 1 soc iat perat i ported the G h oil ged f r amoun i s the t fire and de loss Surve ed wi ons i from ulf o or co om tw t of prim s. S ath o of va y for t th well n the G th Cal f Mexic ndensat o hours gas los ary env everal f membe luab le he period bl owout s ulf of i f orni a o involved e spills. to over t have been ironmental gas leak rs of the equipment . 1 1 1-26 OIL SPILLS GREATER THAN FIFTY BARRELS ON SIZE (10) Pipeline Accidents Dur i line duct Octo anch The dete of o Sout of 1 barr dete ng DCS o acci den ion acci ber 1967 or , wh ic snagged cted for i 1 into hwest Pa 968 , ano el spill rmined c perat ts th dents when h was pipe 1 near the o ss , M ther In ause ions , an fro The a ves inadv ine se 1 y two cean a i s s i s s anchor Febru releas more o m all large s e 1 un ert ent v e r e d •, weeks bout 2 ippi R dragg ary of ed ove il h othe st derw ly 1 and , re mi iver ing 196 r 6, as been spilled from pipe- r types of OCS petroleum pro- CS oil spill occurred in ay during a storm dragged its eft out, across a pipeline, the resulting spill went un- leasing over 160,000 barrels les west of the mouth of Delta, Louisiana. In March incident resulted in a 6,000 9, a pipeline leak of un- 500 barrels into the sea. Starting in 1969, several actions were undertaken to reduce the chances of such accidents and to reduce the volume of these spills. Burial of all new common carrier pipelines with a minimum cover of three feet (10 feet in shipping fairways and anchorage areas) was required by the Bureau of Land Management (BLM) for the right-of-way permits in water depths of less than 200 feet. The water depth requirement for pipeline burial may be increased to 250 feet for certain OCS areas. In water depths of less than 200 feet, only the lines in the gathering system between adjacent platforms of a particular oil or gas field may remain unburied. Permits to construct these gathering lines are granted by the Geological Survey, and the decision on whether to require burial is made on a case- by-case basis. These administrative actions have substantially reduced the risks of futurepipe 1 ine ruptures due to anchor dragging. Additional safeguarding of OCS pipelines and mitigation of accidental spills are provided by regulations promulgated by the Office of Pipeline Safety (OPS), of the Department of Transportation. Petroleum pipelines in offshore areas are re- quired to be coated with tightly banded materials impervious to moisture, followed in many cases by a layer of dense con- crete for mechanical and corrosion protection (49 CFR Parts 192 and 195). To protect against electrolytic corrosion. 1 1 1 - 27 Other features used by industry serve to further mitigate against accidents: continuous metering systems, automatic high pressure shut-downs, and remotely controlled mainline block valves that can isolate sections of the line. The latest pipe-laying and monitoring techniques, combined with modern materials and equip- ment, will further help to insure that the pipelines used in the various OCS areas will function at an acceptably high level of rel iabi 1 ity . Prior to institution of the new pipeline burial requirements, the spillage rate from pipeline accidents was .00624 percent of total production. -With the new regulations, this spillage rate has been substantially reduced to .0017 percent of total production in the period since 1970. Although the new regu- lations and improved industry practices have brought the spillage rate down, the problem of pipeline spills from anchor dragging has not been completely removed. As a part of the pipeline management program, the costs and benefits of extending pipeline burial systems will be investigated. Caution should be inserted at this point. The improved per- formance of pipelines now in existence may not continue. In- dustry spokesmen have estimated that 48 percent of all pipe- line leaks occur in lines that have been in use for 15 years or more. In established offshore petroleum fields where older pipelines are present, corrosion may be in an advanced state. Such pipelines may be poorly buried, if at all, and all of the above mentioned safety and control features may not apply. If serious spillage should occur from some of these older pipe- lines, the s tat i s t i cal improvement of pipeline performance could be reversed. However, in each future OCS lease sale, all of the safety and control requirements discussed above will be en- forced. Therefore, it may be expected that these pipelines should function adequately, since they will be new lines. b . Oil and/or Gas Well Blowouts During Drilling Data from the Geological Survey lists a total of 44 blowouts in Federal OCS petroleum operations during the 1964 - 1974. Only 17 of these blowouts resulted in oil spills of 50 barrels or more. Examination of OCS statistics indicates one blowout per 2,860 wells drilled (or .035 percent of wells drilled blowout), spilling an average of 2,100 barrels of oil and con- densate per blowout. The Santa Barbara oil spill provides an example of a blowout during drilling. 111-28 Santa Barbara Spill On January 29, 1969, a blowout occurred below Platform A about six miles southeast of Santa Barbara, California. Thousands of gallons of oil spewed into the Santa Barbara Channel, as men worked feverishly to regain well control. This blowout and spill occurred through a pre-existing fault in the ocean floor adjacent to the well. The apparent cause was accidental in- jection of high pressure gas from a deep reservoir into the shallow reservoir sands. Pressure built up in the shallow re- servoir sands until the overlying rock layer ruptured. This rupture formed a fissure zone through which the oil moved up to the seabottom and escaped into the overlying waters. The blowout continued for 10 days, until the well was choked with cement on February 7, 1969. The reprieve was only momentary and spillage began anew a few days later. Some seepage con- tinues to this day. The Geological Survey estimated the initial spillage from the Santa Barbara blowout totaled 420,000 gallons (10,000 barrels). Other estimates of the initial spillage range from 2,940,000 gallons to 29,400,000 gallons (70,000 to 700,000 barrels)* An additional seepage of 10,325 barrels occurred between February 7, 1969 and December 31, 1972. During 1973, this seepage con- tinued at a rate of .1,825 barrels per year. c . Oil Spills Resulting from Explosions and Fires Fire OCS arci More igni igni If c ab 1 e inf e well dit i ext i caus in t s ha oper ng e rar t ion t ion augh I rno s ma onal ngui ing he f ve al wa at ions lect r ic ely , li Some of sto t soon fa sto can cau y have f ue 1 t shed wi major s ire and ys b are al e ghtn t ime red enou rage s e m the i o th th 1 true all een a no ex quipm ing o s , pi f ue 1 , gh, t tank a j or r p ip e fir itt le tural too ma j or cept ion ent and r s t at i at form so 1 ven hes e sm or we 1 structu ing sev e . The or no damage often r haza M ove c el fire t s , all 1 ca ral ered ma j dama usu esu 1 rd i ost rhea ectr s re or h fire t che dama and or it ge. ally t in n the fires ted m i c i ty suit eat e s are s on ge. ther y of Unco invo mult petrol are ig echanic is the from ac xchange usual 1 f ire , t Ad j acen eby con fires a nt ro 1 1 a lve num ip 1 e fa eum nit e al d cau c ide r fl y co he r t pr tr ib re q ble erou tali indust ry d by evi ces . se of nt al uids . nt rol 1 - esu 1 1 ing oduc ing ut e ad- ui ck ly fires s wells ties. *Testimony of Dr. Carl H. Oppenheimer, OCS Public Hearing of August 23, 1972, New Orleans, Louisiana. 111-29 The Geological Survey has reported 113 explosions and fires in the 1964-1974 period of Federal OCS activities. Most of these fires were extinguished before serious damage and pollution occurred. Only six of these accidents resulted in oil spills. However, the volume spilled in two of these incidents was very large, 30,500 barrels from one and 53,000 barrels from the other. The total volume spilled from all explosions and fires is approximately 85,000 barrels. Perhaps of greater significance is the injury of 120 men and the death of and additional 59. Due to the serious threat of injury and death, industry is typically very cautious about OCS explosions and fires. However, due to the history of fire caused massive oil spills, OCS orders were amended to require extra safety precautions to reduce the potential for future fire related oil spills. To eliminate blowouts due to malfunctioning velocity-actuated downhole safety devices, OCS Order No. 5 requires surface actuated safety de- vices. If all wells are successfully closed during fires and explosions, the size of future fire caused oil spills should be limited to the volume of flammable stored on the platforms when the fire started. Since 1971, explosion and fire accidents have not resulted in more than minimal oil spills. d . Oil Spills Caused by Severe Storms - Hurricanes In the history of Federal OCS oil and gas activities, there has been only one severe storm which caused significant oil spillage. On October 3, 1964, a hurricane pas sed over the waters off central Louisiana destroying three OCS platforms. The total volume of oil spilled in this hurricane was approximately 12,000 barrels. All of this spilled oil was from tanks used to store produced oil prior to trans-shipment by barge. Since 1964, three major hurricanes have hit the extensive off- shore petroleum production areas off Louisiana. While causing financial damage to the offshore industry, they have not resulted in major pollution incidents from operations in Federal waters. When the Weather Service advises that a hurricane or serious tropical storm is imminent, all oil and gas facilities in or ad- jacent to the path of the storm are evacuated. Before evacuation, all surface equipment and wellhead controls are shut-in. In addition, blank tubing plugs are set in as many wells as possible to further reduce the possibility of pollution in the event the well is damaged . The efficiency of these safety precautions was amply demonstrated during Hurricane Cami 1 1 e . On August 17, 1969, Camille passed along the eastern flank of the Mississippi Delta of Louisiana and into the Mississippi Gulf Coast. Camille's top winds were estimated at 201.5 miles per hour, and the storm surge raised the sea level 22.6 feet above normal at Pass Christian, Mississippi. During Camille's onslaught, one production platform was destroyed, and three were damaged. No significant oil spillage occurred. 111-30 The severity of storms occurring in the various other OCS areas are substantially different from those encountered either in the Gulf of Mexico or off California. With only one in- cident on record, no generalization should be made concerning the maximum spillage which future severe storms may cause. Comm caus This form plat cord from f rei resu sea . form quen erci ing sec s . form s in a p ghte ltin A at io cy o Oil Spills Cause d by S hi ps C olliding wit h P lat forms al vessels can collide with OCS platforms, typically substantial damage to both the vessel and the platform tion deals only with the oil spilled from the plat- The oil spilled from the vessels colliding with the s is dealt with in the next subsection. Accident re- dicate only one instance of a significant oil spill latform caused by ship collision. In April 1964, a r off central Louisiana struck and damaged a platform, g in a fire and loss of 2,560 barrels of oil into the history of one accident does not provide sufficient in n to allow generalization about the magnitude or fre- f future collision related oil spills. f . Tanker and Tank Barge Accidents and Operations Acci oil larg vari est i For data the .08 Tech of m perc spi 1 of o spi 1 trol lati petr haza tank duct that oper tran dent disc est ety mate exam for U.S. perc nolo ean ent . 1 ra il i 1 ha eum ve o ol eu rd i ers ion are at io spor al o harg sour of d s of pie, wor tan ent gy> spi 1 No t es n ta zard is a il s m pr s su and of a a f o n is tati il s ed d ces ata tan the Id- w ker of e us in 1 ra mat is u nker to ver pill oduc bsta barg n ar r co exp on . pills uring of oi sour c ker a Bure i de w fleet ach c gam te to ter w sed , s and t anke y imp haza tion nt ial es ar ea ha nsump osed from norm 1 spi es f o nd ta au of at erb Th argo . ore c the hich the r tank r and ortan rds o can b ly le e use s to tion to th tan al o lis r ta nk b Lan orne is d Th ompl t ota of t esu 1 bar t an t fa f th e pi ss t d. be t in a e hi ker s pera in t nker arge d Ma pet ata e Ma ex d 1 vo he a t is ges k ba ct or e va ped han Furt rans noth gher and t ion he U ace spi nage role indi ssac ata lume bove the is h rge in riou to s the her , port er a rel tan s , a .S. iden 11 r ment urn t cat e huse base of est sam azar tran dist s OC hore oil if ed b rea , at iv k ba re p The t s w at es has rans s a tts , co oil imat e . dous spor ingu S ar , th spi 1 the y ta one e ha rges roba re a or Id var oft port spi 1 Inst mput hand es o Tran T tati i shi eas . e oi 1 ha oil nker e ag zard , as bly re a -wid y wi en u s ca 1 ra itut ed a led f ta spor he h on o ng t If 1 sp z ard and s ou ain s of well as the wide e , and dely . sed 1971 rried by te of e of rat io of .016 nker oil tat ion igh oil f pe- ll e re- the OCS ill when gas pro - t of the tanker It is difficult to assess the total amount of petroleum that will be spilled into the marine environment as a result of the daily operation of U.S. flag tankers and tank barges. Al though there are estimates of the total amount of pollution III -31 resulting from cargo handling, tank barge leaks, and cleaning/ bunkering/ballasting/bilge pumping., (Charter, et al . , (12) and Porricelli, et al., (13)), there is no breakdown according to registry. It should be noted, however, that U.S. Coast Guard regulations and standards are among the most stringent and rigidly enforced in the world. Thro as s e of p form Coun Thei with on e barr appr from occu vess and on t ughput ssment et ro 1 e ed an ci 1 on r anal out me s t imat els. oximat inc id r near el hit rammin raf f ic spi of urn . ext e Env ys is anin ing Anal e ly ents shor s a gs o den 11 ra the o The nsive ironm indi g- T the p ys is 98 pe over e and fixed ccur sity , t es are n i 1 spill Massachus analysis ental Qua cat ed tha heref ore , r obab i 1 i t of tanker rcent of 1 ,000 ba are caus S tructur near shor e whi ch is ot the hazards et t s In of oil lity (1 t avera they c y of sp spill all oil rrel s . ed by g e) , or , and c highes on ly of t s t i tu spi 1 4) • ge sp oncen ills s t at i spi 1 Most round colli ol 1 is t nea avai anke t e o 1 st See ill trat larg stic led lar ings s ion ion rsho labl r tr f Te at i s al so rate ed t er t s in from ge t , ra s . f req re . e meth anspor chnolo tics f Sect i s were heir e han 1 , dicat e vesse anker mmings Ground uency od for tat ion gy per- or the on 1 1 1 B almost f f ort s 000 d that Is is spills (the ings depends M.I.T. expressed oil spill hazards as estimates of the probability of spills larger than 1,000 barrels. As the size of the pe- troleum field increases, so do the number of expected spills and the overall probability that a spill will occur. M.I.T. classified oil and gas discoveries as small finds, i.e. 500 million barrels of oil in place; medium finds, i.e. 2 billion barrels of oil in place; and large finds, i.e. 10 billion barrels in place. Using a complex worldwide data base of past tanker oil spills, M.I.T. estimated that the probability of one tanker spill over 1,000 barrels during the life of a small field, there is approximately 27 percent. During the life of a medium sized field, there is approximately an 85 percent probability of one such spill. For a large find, this prob- ability is nearly 100 percent. M.I.T. also estimated the ex- pected volume of spills over the life of each field size. The results were: small find 0.40 spills, 19,900 barrels; medium find 1.9 spills, 92,400 barrels; large find 6.9 spills, 335,700 barrels. The estimates of volume spilled dramatically state the oil spill hazards of tanker transportation. g . Other Spills of 50 Barrels or More This category is a combination of spills over 50 barrels which had causes other than those discussed above. Accident records 111-32 indicate a total of 15 such spills through 1973. Total dis- charge from these spills amounted to approximately 9,200 barrels. Twelve of these spills were attributed to overflow, malfunction, rupture or failure of platform piping valves or vessels. One spill occurred during abandonment and platform removal. In this operation a well broke and spilled 500 barrels of oil. To help prevent recurrence of this type of spill, OCS operating order No. 3 requires that a redundant series of bridging de- vices, weighted muds, and cement plugs be placed in any well or drill hole prior to abandonment. Well and drill hole abandon- ments performed in this manner should provide an ample margin of protection to prevent future oil spills from abandoned wells or drill holes. Two similar incidents, occurring in July 1971 and January 1973, caused spills totalling 7,100 barrels. Both of these were caused by damage to oil storage barges. h . Minor Spills Starting in 1970, the Geological Survey required reporting of oil spills less than 50 barrels in size. Since then some 5,000 such minor spills by number, volume, and source. Even though the number of minor spills each year has increased slightly during the 1970-1973 period, the total volume spilled has de- creased substantially. During this same period, the total OCS petroleum varied by less than 13 percent, whereas the volume of minor spills decreased by approximately 60 percent. This substantial decrease in the volume of oil spilled in minor spills probably indicates an improvement in industry's per- formance in cleaning up its routine operations and thereby re- ducing the amount of chronic spillage. TABLE IIIC-1 MINOR OIL SPILLS Year 1970 1971 1972 1973 Total Total Number Reported 1, 200 1, 250 1 , 158 1,392 5,000 Number by Source Drilling Pro. $ Trans 4 13 13 10 40 1 , 196 1 , 237 1,14 5 1 ,382 4,960 Total Vo lume Barrels 2,597 2 ,414 1 ,812 1 , 857 8,680 Note: Total OCS petroleum production during the 1970-1973 period was 1,488,242,300 barrels. Therefore, the minor spills spillage rate is 0.000583 percent. Ill i . Summary of Throughput Spillage Rates Each of the eight preceding subsections dealing with oil spills from OCS operations identified the volume of oil spilled for each class of accidents. With the exception of oil spills caused by blowouts, the volume spilled can be expressed as throughput spillage rate, i.e., total volume spilled divided by total volume produced. Spill rates for blowouts are better expressed as blowouts per well drilled This section brings all of these spillage rate estimates together. The reader is cautioned on three points. First, as explained in detial in the preceding discussion, the quality of the data varies among the causes of accidents. For several accident categories, there are not sufficient data to allow extrapolations about expected future spill rates. Second, it must be emphasized again that to date OCS oil and gas operations have occurred in only the Gulf of Mexico and off Southern California. The natural environmental conditions, i.e. severe storms, earthquakes, tsunamis and bottom types encountered in the frontier areas of the OCS, will differ substantially from those experienced to date. Therefore, this historical accident data provides a questionable basis for predicting accident frequencies in areas such as the Gulf of Alaska or Georges Bank. These caveats IIIC-2. aside, the throughput spill rates are shown in Table TABLE IIIC-2 THROUGHPUT SPILL RATES Accident Class 1. Pipeline accidents .00170 percent 1/ 1_/ Pipeline spill rate since 1970. See Section IIIC-2a. The M.I.T. estimate for offshore pipelines is .011 percent (see Table IIIB-5) . 111-34 Ac c i cl en t CI a s s TABLE I I I C - 2 THROUGHPUT SPILL RATES Blowouts I i x p 1 o s i o n s and Fires Severe storms Ship Collisions with Platforms Tanker and Tank barge Other Spills of 50 Barrels or More 8 Minor Spills Total without tankers Total with tankers and without pipelines Total with both tankers and pipelines . 00290 percent 2/ . 00290 . 00041 . 00009 . 01600 3/ . 00032 . 00058 .00890 . 02320 . 02490 2/ Blowouts expressed as throughputs spill rate. An alternative expression is .035 percent of wells drilled blowout with an average spill of 2,100 barrels per blowout. 3/ The M.I.T. estimate of tanker throughput spill rate. MAJOR OIL SPILLS AND THE MARINE ENVIRONMENT (10) Oil spills can be t accident. How wave blowing over an oil combine to move an theless, movement o coastal areas is a concentrated their oil spills reaching Chapter. The prima from the source of change the characte ransported many miles from the site of an s passing underneath an oil slick, winds slick, and currents in the underlying water oil spill is incompletely understood. Never- f oil spills from the sites of accidents to prime concern. M.I.T. in their work for CEQ efforts on estimating probabilities of OCS coastal areas. See Reference 2 to this ry concern in this section is how oil spreads a spill, and further, on the processes which risitics of the oil as it weathers. Consider a large volume of oil suddenly released on the sur- face of the sea. Presume that there are no physical boundaries restricting the spread of this oil in horizontal directions. Under these conditions, which are appropriate for OCS oil spills, the spreading of the oil will occur at different rates as the time from the spill increases. The details of the various forces affecting these spreading rates are beyond the scope of this discussion. Readers interested in these details are re- ferred to the Georges Bank Petroleum Study, Volume II, Massa- chusetts Institute of Technology, Report No. MITSG 73-5, February 1, 1973. For this discussion, it is sufficient to report the results of the MIT analysis. Figure IIIC-1 is taken 111-35 CO E 6 MIN. 1 HR. 10 HR. 100 HR. TIME FIG. Ill C-1 REPRESENTATIVE SPREADING HISTORIES FOR FIVE SPILL VOLUMES, AREA COVERED VS. TIME FROM SPILL TYPICAL CRUDE OIL CHARACTERISTICS TTT.7A from the MIT report and shows the following areas of oil spreading for various sized oil spills: 1, 000 gallon spill, 11. 8 acres in slightly over one hour; 10,000 gallon spill, 66.6 acres in approximately seven hours; 100,000 gallon spill, 370 acres in slightly over 10 hours; and 1,000,000 gallon spill, 2, IZ0 acres in approximately 75 hours. These areas of spread are for one spill continuing as one spreading mass. At some time in the spreading process, variations in the winds, waves and currents usually cause a large continuous spill to break up into several large patches surrounded by many smaller patches. As time goes on, the large patches will separate from one another. This will increase the width of the patch swept by the spill. Apparently such processes were at work on the Santa Barbara oil spill. An oil slick spread over approxi- mately a thousand square miles extending from northwest of Santa Barbara to Ventura and Oxnard on the South and offshore beyond the Channel Islands. Petroleum in seawater is altered chemically by evaporation, dissolution, chemical oxidation, photochemical reactions and microbial action. These processes are often referred to collectively as weathering. How fast crude oil weathers is influenced by the properties of the crude oil as well as light, temperature, winds, waves, and currents. A.11 of these factors affect the rates of evaporation, dissolution, dispersal and sedimentation processes. Additionally, the nutrient content of the water can affect the rate of microbial degradation. Weathering rates also vary for the various components in a crude oil. The more volatile aromatic fractions tend to evaporate rapidly. Certain fractions, usually the heavier ones, do not weather and these may be deposited in sediments or they may float as tar lumps or tar balls. Oil and its breakdown products may remain in sediments indeterminately until they are churned up by turbulence to recontaminate a recovering area. The persistence of crude oil in the differing marine environments of the various OCS areas may vary considerably. Most observations of oil spills are for temperate areas, and little is known about the properties of crude oil in the chilled waters of the Alaskan areas. The viscosity of crude oil increases at lower temperatures, and in frigid Arctic waters many crudes may spread very slowly if at all. Microbial degradation will also be slower in Arctic waters because the oil is more viscious, perhaps forming thick films or clumps which are harder for the bacteria to attack. Further, the low temperature slows the metabolism of the attacking bacteria. In addition, limited winter daylight reduces photochemical oxidation of oil spills in the more northern areas. Oil exposed to the very low temperatures of the Arctic winters may sink. Any oil contaminating bottom sediments in the Alaskan areas is expected to be more persistent than oil in the sediments of more temperate areas, such as Southern California. 111-37 The conditions which led to the blowout of well A- 21 on platfo'rm A in the Santa Barbara Channel were discussed in a previous section. This discussion focuses on the biological effects of this massive oil spill. The factual material for this discussion was taken primarily from the excellent discussion of the Santa Barbara oil spill contained in a lengthy comment received from the Southern California Council of Local Governments,. This discussion presented here is limited to the environmental impacts of the Santa Barbara oil spill. It is virtually impossible to assess the total and long-term damage to the Santa Barbara Channel ecosystem which occurred as a result of the spill. One primary reason for this difficulty is the fact that adequate baseline information is not available. This lack of a detailed ecological description for the affected area prior to the oil spill makes it difficult to be certain that the ecosystem has recovered to pre-spill conditions. Nevertheless, at least one scientist noted that the number of marine organisms appeared to be roughly comparable to pre-spill populations and concluded that the spill's effect on marine life was negligible (15). This controversy about the long-term damage to the marine ecosystem aside, the short-term effects were considerable. Foster (16) estimated the number of organisms killed and the amount of biomass removed as a result of oil pollution and oil cleanup activities. Habitat and Organisms Rocky Intertidal Zone Barnacles Surf gras s 8,770, 000 killed 16 tons of blades and attached algae and invertebrates removed Polychaete worms Limpets 80, 900 killed 51, 800 killed High Intertidal Zone Crevice fauna (mostly arthropids) Mu s s e I s 20, 000 killed 30, 000 killed Sandy Beaches Sandy Beach macrofauna 15, 000, 000 removed during beach cleanup 111-38 Deep Subtidal Zone Benthid invertebrates 6, 000 tons lost Neritic Habitat 9,000 killed Marine Birds (60% loons and grebes) Marine birds losses are the most dramatic example of the environmental consequences of the Santa Barbara oil spill. Oil coated birds usually die. Even in treatment centers, mortality rates of 90 percent and higher have occurred. Oil coating disrupts the water repellent properties of the feathers, causing the birds to become waterlogged and sink. Also, the insulating properties of the feathers are destroyed by oil coating causing loss of body heat. When the birds attempt to clean their feathers, they ingest oil which can become an additional cause of mortality. The damage listed by Foster which occurred to other organisms was less dramatic. The organisms in the rocky intertidal zones which were killed by the oil spill died primarily from the smothering effect of the oil. Sand- blasting and steamcleaning of the rocks to remove the oil stains undoubtedly killed many intertidal and splash zone organisms such as periwinkle, limpets, mussels, pill bugs, etc. Approximately 60 percent of the mussels killed in Santa Barbara harbor were killed as a result of steamcleaning. Sand beach macrofauna, which includes sand hoppers, sand crabs, bloodworms and many additional species, were killed primarily as a result of sand removal during beach cleanup operations. Shallow subtidal organisms, which include giant kelp, other plants, and invertebrates, apparently suffered only minor impacts. The long term effects of the Santa Barbara oil spill are difficult to estimate and there is some disagreement among scientists. Foster (16) concludes: "The continued presence of oil from the initial spill on solid substrata and in sandy beaches, the observed changes in deep subtidal benthic communities, and the fact that oil continues to escape from the platform, all suggest that the Channel has not recovered. " Straughan (15) concluded that the spill's effect on marine life was negligible. With minor exceptions, the area impacted by the Santa Barbara oil spill has for all practical purposes returned to its pre- spill condition. 111-39 The fact that the massive Santa Barbara oil spill apparently has not resulted in major long-term impacts on the Santa Barbara Channel ecosystem should not be used to conclude that massive oil spills in other areas under different circumstances will also result in negligible impacts. What the above discussion points out is that per ceptions of the Santa Barbara oil spill as a catastrophe which permanently destroyed or altered environmental conditions of the area are not factually valid. D. NATURAL PHENOMENA AND THEIR IMPACT ON PCS OIL AND GAS DEVELOPMENT ACTIVITIES (2, 10) OCS oil and gas development operations will at times be subjected to the stress of severe storms, ice, earthquakes, tsuanamis, and unstable bottom conditions. These differences in the natural environmental conditions that can cause impacts on OCS oil and gas operations provide another means of assessing the relative environmental hazards of different OCS areas. The constituent phases of the oil development process to be considered are: exploration, production, storage, and transportation. 1. EXPLORATION PHASE (10) If during exploratory drilling the drilling unit or platform collapses, capsizes, or moves from the drilling site, the marine riser will fail and small volumes of drilling muds and cuttings will be released into the sea. If the drilling has penetrated oil and gas formations, there is also the possibility of a blowout. If sufficient warning is given, all wells can be closed so that chances of a blowout are substantially reduced. Severe storms can affect both floating and fixed platforms. Experience to date indicates that industry has had a certain measure of success in scaling up Gulf of Mexico technology to meet the more hostile storms found in the North Sea. Losses have occurred, however. Since 1965, severe weather was either a prime or contributing factor in the loss of 10 drilling rigs. Prudent operation of a rig dictates that drilling operations stop when weather conditions exceed the operational limits specified in the design. Experience with the severe storm environment in the North Sea shows approximately a 14 percent average annual downtime due to bad weather. Earthquakes affect exploratory drilling in more complex ways. Fixed platforms can be subjected to severe shaking and the stress attendant to these accelerations. Additionally, a number of earthquake related events can disrupt the foundation of the platform. Earthquake hazards to 111-40 fixed platforms can probably be mitigated by proper design and careful placement to avoid bottom types prone to ground rupture, differential settlement, landslides, or liquefaction of sediments. Floating driLLing rigs are less vulnerable than platforms. They would be only s lightly affected by local tsunamis and not at all by earthquakes. Ice in sufficient quantities can present a significant hazard to almost any offshore structure. The hazards of moving ice packs or the threat of ramming by ice islands represent environmental phenomena beyond the present limits of technology. The truly awesome forces exerted by large ice flows, especially ice islands, which can score 30 foot deep trenches on the seafloor, simply preclude Arctic drilling operations except for about two months in the summer. Thus, ice, which is not viewed as a serious problem in the areas other than the more northern Alaskan areas, represents a technological barrier to offshore drilling in the Arctic. However, recent technical developments may offer a means of enduring ice pressures. General Dynamics has developed a design concept for a moored drilling system that includes a cone-shaped hull that is "squeezed" upwards by ice pressure until the weight of the hull breaks the ice. The system is designed to operate in depths up to 660 feet and fast ice accumulations up to 5 feet. Global Marine has also been developing an ice breaking drill ship which employs a Pneumatically Induced Pitching System (PIPS) to break ice. "With new technologies such as these, drilling in Arctic waters may one day b ecome technically feasible. Federal OCS operating experience has demonstrated that unstable bottom sediments can pose a serious threat to bottom fixed structures. This problem can in most areas be circumvented by careful analysis of bottom sediments as part of the drilling rig and production platform siting process. 2. PRODUCTION PHASE (2,10) Almost all offshore production systems installed to date are fixed steel frame platforms. An emerging alternative to fixed production platforms is the subsea production system ( subsea completions) which involves placing the wellheads on the ocean floor rather than on platforms. As water depth increases, the costs of fixed platforms rapidly increase, and this increasing cost is one reason for developing the subsea completion technology. The increasing cost of production platforms has also lead to an increase in the number of wells that each platform must service. Modern platforms are able to serve 20 to 25 wells. Future platforms can be expected to service 40 or more wells. The more wells there are on a platform, the more serious the consequences of damage to the platform. Ill- 41 Fixed production platforms face the same natural hazards as the fixed platforms used in exploration. Severe storms are not as hazardous as they are disruptive. Production operations taking place on fixed platforms should not be seriously disrupted by the yast majority of severe storms. Further, prudent operating practices dictate shutting down production, closing the wells, and abandonment of the rig during truly severe storms. Of course, advance warning of impending severe storms is necessary and in many of the Alaska OCS areas, expected warning times might be as short as one or two hours. Subsea completions generally avoid the hazards of severe storms. Earthquakes can and do result in numerous events disruptive of OCS oil and gas production facilities. Among these are: (I) ground vibration; (2) ground rupture; (3) landslides including subaerial and submarine rock slides, avalanches, andmudflows; (4) liquefaction of sediments; (5) differential settlement; and (6) seismic sea waves (tsunamis) and seiches. All of these events occurred as a result of the March 27, 1964, Alaska earthquake in Prince William Sound. The Cook Inlet oil and gas wells evidently were not appreciably damaged. Some damage could have resulted in 1964 if the present extensive development of these fields was present. Still, in view of the intensity of the Prince William Sound quake (Richter 8. 3 - 8. 6), the lack of damage to the Cook Inlet petroleum fields speaks well for current structural design capabilities in earthquake prone areas. This is not to say that earthquakes will not damage petroleum fields. Damage is more likely to result where local features or situations develop, such as surface rupture where a fault crosses a well and the well is offset as a result of movement or where subaerial or submarine landslides cut a subsea completion or topple a production platform. Such events can occur as a result of earthquakes of far less intensity than the Prince William Sound quake. Destruction considerably out of proportion to the intensity of the quake can occur in localized areas where fortuitous conditions are present. Therein lies the major concern. However, as industry gains additional experience in coping with seismic events, these hazards should be reduced. For example, a 940 foot steel frame platform has been designed, but not yet installed, for use in the earthquake-prone Santa Barbara Channel area. This platform is designed to withstand the maximum expected ground shaking in the Santa Barbara Channel. The landslides, liquefaction of sediments, and differential settlement of sediments associated with earthquakes represent additional hazards for OCS development in seismically active areas. Once again, the awesome Prince William Sound earthquake provides examples of the disastrous effects of such events. Persons interested in the details of the findings related to the Prince William Sound quake are referred to the summary presented in III- 42 U.S. Geological Survey Professional Paper 546. Avoidance of areas of potentially unstable bottoms is the only known method of preventing accidents caused by these major land movements. Extensive test boring programs must be conducted prior to siting production platforms in seismically active areas. This is particularly important because there is no advance warning of impending earthquakes. The potentially disastrous effects of tsunamis are not expected to pose a serious hazard to the majority of offshore production platforms or subsea completions. Decreasing water depths and amplication by coastal features are the primary intensifiers of the destruction forces of tsunamis. In water depths greater than 200 feet tsunamis are expected to cause no damage. The postulated wave heights of tsunamis are considerably less than the design wave height of OCS drilling platforms. Ice related hazards to OCS production arise from four principal sources. First, ice accretion on surface structures increases their weight, freezes equipment, and is a safety hazard. Heating coils and similar devices can mitigate the hazards of ice accretion. Moving pack ice poses more serious hazards in the Alaskan Arctic areas. Offshore production platforms will face many of the same problems as drilling rigs. Modified conventional platforms may be possible, but in general, new technology such as subsea completion systems for deeper water and artificial islands for shallower water will have to be developed before production is practicable in Arctic areas. Ice islands present a particularly difficult problem for Arctic petroleum development. These islands can be over 200 feet thick and range from a few thousand square feet to a few hundred square miles in size. Drift rates can exceed one mile per day. If a truly large island drifts into a drilling platform or even an articifial island, the petroleum production structure will likely be destroyed. It may be possible to protect OCS structures from drifting ice islands by using large ships to tow these islands away from OCS structures. Subsea completions would avoid this hazard in deep water. However, in shallow water where ice islands ground, scouring of trenches 30 feet deep can occur. Obviously subsea completions and pipelines subjected to such forces would fail. 3. STORAGE PHASE (10) There are three types of storage devices used for OCS petroleum production. The most common is the familiar cylindrical oil storage tank used onshore. Offshore storage in either floating or submerged vessels is also possible. 111-43 The volume stored in all three types of storage devices is very large. Tank sizes are rarely smaller than 200,000 barrels and can be as large as 1, 000, 000 barrels. Even larger tanks are being proposed. Onshore, storage tanks can be damaged or destroyed by flooding, by tsunami waves, by earthquake shaking, and by the various forms of soil movement frequently associated with seismic events. Damage from flooding and tsunamis can be prevented by proper site location. The same is true for avoiding damage due to loss of soil stability. The ground vibrations of earthquakes can cause sloshing movements in storage tanks "which can intensify into overturning movements and cause buckling of the base ring with subsequent collapse of the structure. This hazard can be reduced by minimizing the free surface within the tank. Even if damage should occur to onshore storage tanks, secondary protection against oil spills is provided by surrounding the tanks with dikes capable of containing the total amount of stored oil. Severe natural phenomena are least likely to affect onshore storage systems. Both forms of offshore storage can be subjected to the forces of severe events such as storms, tsunamis and moving ice. The principal hazards for floating storage tanks result from the damages inflicted by grounding or capsizing. Breaking mooring lines is the event that sets floating storage tanks adrift. The likelihood of grounding can be reduced by anchoring floating storage tanks in deep water. This same deep water will allow tsunamis to pass without damage. Deep water moorage far from shore also allows more time to recover an adrift storage tank. Capsizing can also be avoided by special design. Storage tanks which are long and thin and float nearly submerged will not likely capsize. The Shell Corporation has built a 300, 000 barrel storage tank of this type for use in the North Sea. Underwater storage tanks are susceptible to damage from severe storms, earthquakes and tsunamis. The passage of large waves during severe storms generates considerable forces. In shallow water, tnese forces penetrate to the bottom. Surrounding storage tanks with wave attenuation barriers will abate these forces and protect the storage tank. This type of system is being installed at the Ekofisk field in the North Sea. Underwater storage tanks are particularly vulnerable to earthquakes and tsunamis. The ground vibrations of earthquakes produce large drag and inertial forces on these bulky structures. For more severe earthquakes, 111-44 these forces can easily exceed those associated with severe storms. If the underwater storage tank survives the earthquake forces, there are still the tsunamis forces to endure. As the tsunami passes, the mean water level increases thereby increasing the bouyant forces. At depth, the passing tsunami increases drag and inertial forces to levels considerably higher than those associated with severe storms. Each of these facts probably make underwater storage impractical for seismically active areas of the OCS. Both surface and underwater storage tanks can be impacted by moving ice. Floating storage is obviously more vulnerable but large ice islands can ground submerged storage tanks unless these structures are secured in water depths sufficient to allow even the largest ice islands to pass over freely. Oil spill containment will be very difficult for both floating and submerged oil storage tanks. The case of spill containment around onshore storage tanks alone would make onshore storage less hazardous. For areas where storage on shore areas is impractical due to large distances to shore, floating storage can be used but such storage will be more hazardous. In general, the hazards of underwater storage would probably rule out this storage method except perhaps for certain Arctic areas where there is a severe ice hazard. 4. TRANSPORTATION PHASE Transportation of OCS oil and gas production can be separated into two segments. Gathering of the production from adjacent producing areas to concentrate a volume sufficient for economical shipment is the first step. The extent of such gathering systems is directly related to the production rates for the petroleum reservoirs. For highly productive fields, gathering systems are typically not as extensive as those needed in less productive fields. Pipelines are the most common transportation means used in gathering systems in the Gulf of Mexico OCS fields. Barges and small tankers moored adjacent to platforms are an alternative gathering system transportation mode. Movement of the petroleum out of the OCS field is the second segment of the OCS transportation system. In areas where the OCS production will be consumed in the adjacent shore area, the production gathered from adjacent tracks is moved to shore areas either by pipelines or tankers and tank barges. Where the OCS production is not consumed in the adjacent coastal areas, it must be exported. As discussed above, storage of OCS petroleum production prior to transshipment can be either onshore or at sea. If on shore storage 111-45 is used, the transportation system is subjected first to the hazards associated with the mode of movement to shore. Then, there are the hazards of storage and finally the hazards of the export transportation system. In areas where at sea storage is practical, single point moorings can be used to load tankers for transshipment. In general, this system should be less hazardous than moving the production to shore storage areas and loading tankers in coastal areas. Most of the petroleum production of the Alaskan OCS areas will b e exported for consumption in other areas. This fact alone is sufficient to make Alaskan OCS petroleum production more hazardous than OCS areas where the petroleum production is consumed in the adjacent areas. a. Pipelines Historically, pipelines have been the safest means of bulk transportation. This is expected to continue in the frontier areas of the OCS. Pipelines are, however, subject to damage from natural phenomena. Elaborate route selection and engineering studies coupled with seismic and test boring programs could minimize the likelihood of having the pipeline traverse areas of unknown soil properties. Where pipelines traverse fault zones or other regions of poor soil stability, installation of check block and pressure i elief valves on both s ides of t he hazardous a reas would help t o minimize spillage if the pipeline should break. The required burial of pipelines in water depths less than 200 feet should provide protection against anchor dragging which has been the cause of most major pipeline breaks. In the Arctic and subarctic areas of Alaska, pipelines will be exposed to the additional hazards of ice and permafrost. The forces ice can exert are substantially greater than those a pipeline can endure. Therefore, pipelines will have to be constructed and placed in ways that will avoid exposure to ice. This requirement can pose some formidable problems. As already noted, ice islands can scour the sea bottom to depths of 3 feet. Similar hazards are encountered at shoreline. The accumulation and movement of ice along the shore in the fall and spring could subject the pipeline to crushing loads of folded ice in the fall and tearing and shearing forces during the spring breakup. Permafrost must be completely avoided, completely eliminated, or completely preserved in all phases of OCS petroleum production. Little is known regarding the presence and extent of permafrost under the oceans. However, where it exists under the oceans it should pose the same problem it does to pipelines on shore. The heat of the pipeline causes melting. The melted 111-46 permafrost may have considerable potential for solifluction or downslope movement. Additionally, where freezing occurs over a deeply buried pipeline (assuming deep burial is adopted to avoid ice hazards), the melted permafrost around the pipeline will be an incompetent layer sandwiched between two frozen and rigid layers. The rigid surface layer is then subject to heaving, cracking and rupture especially during earthquakes. Building the Tj ans -Alaska Pipeline has given industry some experience in permafrost problems; and, as a result, pipeline placement in areas of permafrost is less hazardous today than it was, say, five years ago. b. Tankers Tankers constitute one of the most serious oil spill hazards of any OCS operation. Historical data indicate that the majority of tanker oil spills resulted from groundings, collisions, and structural failure. Natural phenomena such as severe storms, high winds, or fog often contributed to past tanker accidents. However, in virtually every case, the accident could have been avoided by proper maintenance of the vessel and/or use of prudent seamanship either to avoid severe storms or to modify course or speed and thereby minimize wave forces while trapped in bad weather. Even with proper maintenance and use of prudent seamanship, tanker operations will be hazardous in the more arduous frontier OCS environments. Tsunamis pose a serious threat of major oil spillage whenever tankers moor at fixed berths in tsunami-prone areas. Moored at a fixed berth, the tanker is in shallow water where tsunamis develop their most destructive forces. Mooring lines part, and the vessel is at the mercy of the waves and currents until the engines generate sufficient thrust to regain steerage. During the Prince William Sound earthquakes, the tanker ALASKA STANDARD, moored at Seward, was carried several hundred yards out into the harbor. In Valdez, a freighter was not so lucky. The mooring lines on the CHENA parted when the land at shoreline slumped. The freighter was first sucked away from the pier by the outrushing water (during tsunamis the water first rushes outward before the tsunami wave) and was then thrown onto the mud flats by the reflected wave. Similar occurrences have been observed wherever ships have been moored when a major tsunami hit. The hazards of tsunamis in harbors can in many cases be avoided by use of single-point moor oil transfer facilities placed in deep water and away from the shoreline. In deep water, tsunami wave forces are negligible. In the event the moor parts, which is far more likely during severe weather than passage of a tsunami, the ship will have maneuvering i oom to regain control. 111-47 Ice, as previously mentioned, is a major hazard in the more northernly OCS, particularly in the Alaskan Arctic and subarctic areas. Three types of ice exist in the northern seas. (1) Icebergs or ice islands which ,are drifting remnants of ice broken off from continental ice masses. In the Arctic, ice islands are a major hazard. (2) Winter ice which forms each year occurs in the many openings scattered throughout the polar ice pack as well as in the open water of the adjacent seas. In the warmer, more southern areas of Alaska, winter ice forms principally along the shore. In the Arctic, winter ice also forms as the Arctic Ocean freezes to an average depth of 6 to 8 feet. Along the shore, winter ice can be piled by the tides into ridges over 40 feet thick. Strong winds and currents as well as the spring thaw break off fragments of the winter ice, forming winter drift ice. (3) Ice that forms over several years is known as polar ice. The thickness of polar ice In the Arctic is normally 10 to 13 feet by the end of winter, decreasing to about 6 to 10 feet in the summer. Strong winds often push large polar ice flows in shore through areas of thin seasonal ice causing the winter ice to break and pile up into larger pressure ridges. These ridges can be over 40 feet high with keels over 120 feet deep. These keels frequently ground and scour the bottom. Tankers are very vulnerable to ice. Even drift ice can make normal tanker operations hazardous. However, the Manhattan experiment demonstrates that it may be possible to design ice- stregthened merchant ships which are capable of Arctic operations during summer months. Even the largest icebreakers built to date are not capable of operating north of the Arctic Circle during the winter and spring. Perhaps submarine tankers can be designed to operate under the polar ice much as the atomic submarine Nautilus did in 1958. Studies have indicated that transportation of Arctic oil in submarine tankers is feasible using the Northwest Passage to Green- land. E. ENVIRONMENTAL IMPACTS OF VARIOUS DISCHARGES Various OCS oil and gas development discharges can cause adverse impacts upon the marine environment. The most severe impacts that can affect organisms and communities are those that result from discharged oil. Oil discharges can be classified as having two causes: (I) accidental discharges caused by well blowouts, pipeline ruptures, and other unintentional occurrences; and, (2) operational discharges. The more familiar of the two causes, accidental spills, range in size from a few barrels to over a hundred thousand barrels. Operational discharges, those that occur during routine operations such as formation water discharge and separator fluid discharge, may result in environmental stress of large magnitude that is known as chronic low-level pollution (10). 111-48 Evaluating the precise environmental impacts of oil on the marine environ- ment is difficult. The National Academy of Sciences has noted the following (4): "Measuring the effects of oil on marine life is difficult. Each experimental study must include an adequate number of controls whereby single variables are evaluated through interdisciplinary approaches so that the effects of different biological parameters can be resolved. Many earlier studies of the effects of oil cannot be adequately evaluated because ( 1) the experimental work was not properly designed (for example, lack of adequate replication) and (2) the oil concentrations and other variables that affect marine life are inadequately monitored. Well- designed laboratory studies are essential in determining the precise effects of oils on selected marine organisms. Studies are needed to measure the range of oil concentration in chronic and spill-type situations. Laboratory studies are also needed to compare organisms. However, evaluations of effects must be made under adequately monitored field conditions. " I. BEHAVIOR OF OIL IN THE MARINE ENVIRONMENT (2, 6, 10) Crude petroleum is a mixture of hundreds of hydrocarbon compounds derived from biological matter that has accumulated in reservoirs and has been subjected to physical, chemical, and biological processes for millions of years. The physical-chemical composition of petroleum varies greatly, depending upon where it is obtained. Toxicity of each type of oil depends substantially on the water soluble and aromatic fractions of petroleum that it contains. The volatile aromatics are considered the most toxic, although other low boiling hydrocarbons may also be toxic. Petroleum derivatives, the distillate fractions of crude oil - gas, gasoline, kerosene, light gas oil, heavy gas oil, and light lubricating oil, and blends of diesel fuel can also be toxic. Some distillates, such as No. 2 fuel oil and other petroleum derivatives, appear more toxic than crude oil becuase distillates contain higher proportions of medium boiling aromatics which have lower volatility and persist longer in the environment than other fractions, Persistence, or residence time, is the time that oil is detectable in the water, sediments, or biota. However, criteria and techniques for determining or estimating residence time very considerably among investigators, and reported persistence can depend as much on the sensitivity of detection methods as upon how long the oil in fact remains. Visual observation, the least sensitive, is employed most frequently. Although some studies are based on chemical analyses and bioassays, lack of uniform observation and 111-49 detection methods confuses the question of oil persistence. Although visual observations can provide useful data, until methods are standardized, these gross data would be interpreted as underestimating oil persistence. Petroleum in sea water is altered chemically by evaporation, dissolution, microbial action, chemical oxidation, and photochemical reactions - often collectively - and is called weathering. How fast oil degrades is mai kedly influenced by light, temperature, nutrients and inorganic substances, winds, tides, currents and waves. They all affect the microbial degradation, evaporation, dissolution, dispersal, and sedimentation proces ses. Degradation rates appear to vary with the composition of the oil. The more toxic fractions are generally less susceptible to microbial degradation. The heavy residuals that do not degrade may be deposited in sediments or they may float as tar lumps or tar balls. For a detailed analysis of the harmful effects of oil upon marine organisms, see Appendix A. a. Physical and Chemical Changes (6) Because the varying constituents of oil are affected at different rates by "weathering" processes, the i elative composition and, therefore, the biological effects of spilled oil also vary. Evaporation depletes the more volatile components (fractions I, 3 and 5) but causes little separation (fractionation) between hydrocarbons that have the same boiling points but substantially different structures and effects on organisms. Hydrocarbons lost through evaporation go into the atmosphere. Dissolution also removes preferentially the lower molecular weight components from an oil slick. Some potentially toxic fractions, such as the aromatic hydrocarbons, have a higher solubility than other less toxic compounds, e. g. , paraffins of the same boiling point. Once dissolved in seawater, these soluble constituents may follow quite different pathways than the more conspicuous slick. Biochemical (microbial) attack affects compounds within a much wider boiling range than evaporation and dissolution. Hydrocarbons with the same general structures are attacked at roughly the same rates. Normally, paraffins are most readily degraded. Continued biochemical degradation causes gradual removal of the branched alkanes. Cycloalkanes and aromatic hydrocarbons (fractions 3-8) are more resistant and disappear at much slower rate. Chemical degradation processes of oil during weathering are not well understood. Oxidation affects most readily aromatic hydrocarbons of intermediate and higher molecular weight. 111-50 The effect of these weathering processes is the rapid (within 48-96 hours) depletion of lower boiling fractions (boiling point 250°C) from a spilled slick by evaporation and dissolution and the s low degradation (terms of years) of higher boiling fractions by microbial and chemical oxidation. Oil incorporated into marine sediments apparently does not undergo the same changes as those observed in oils exposed to the atmosphere. Also, the absence of a n abundance of dissolved oxygen in most marine sediments and the shielding from sunlight cause the oil tcretain its original composition for much longer periods. Thus, oil originally incorporated in sediment may be later released to the environment (by the actions of waves, tidal current, or dredging) little altered from its original composition. After release, the oilcan be moved into other areas where it can cause deleterious effects. Furthermore, the oil released from sediments may contain pesticides (or their decomposition products) which were originally associated with mineral grains incorporated in the deposits. b. Emulsion Formation (6) Oil when mixed with s eawater tends to form emulsions. Depending on the chemical composition of the oil and presence or absence of other surface active constituents (surfactants), the emulsions may be either oil-in-water (as in milk) or water-in-oil (as in butter). Emulsion formation changes the physical characteristics of the oil and its physical and chemical behavior i n t he ocean and, therefore, alters its effects on marine organisms. Many oils when vigorously mixed with seawater from oil-in-water emulsions. The fine oil droplets are then dispersed through a large volume of water, often disappearing from the ocean surface. In a stable dispersed form, the oil does not "wet" surfaces and also provides maximum surface area for microbila and chemical degradation of the oil. The large surface area also permits soluble constituents in the oil to dissolve more readily in seawater. c. Movement of Oil Slicks (17) A volume of oil suddenly dropped on the sea surface is free to spread horizontally. The oil spreads at three different rates, depending on when one looks at the spill. Each rate is determined by a balance of various properties of oil and water. The first two spreading rates involve balances between the buoyancy - induced spreading force and initially the oil's inertia, then later the water's viscous drag. It is convenient, therefore, to distinguish 111-51 three different phases in the spreading of a spill: an inertia phase; a viscous phase; and finally a surface-tension phase. The duration of each phase depends on the amount o f o il initially released. It is commonly observed that oil slicks cease to spread after some time. Various theories have been developed to explain this phenomenon. One of the more successful theories assumes that the hydrocarbons responsible for the observed surface tension are lost through either evaporation into the air or dissolution into the water. (18) In addition to the well documented spreading phenomena, an oil spill exhibits two other important properties. At some time during the spreading process, variations in the wind, waves, and current usually separate a large spill into aeveral large patches surrounded by many smaller patches. The large patches tend to move apart with time. This increases the width of the path swept by the spill and also increases the rate of dissolution of hydrocarbons into the water. Furthermore, waves on the open ocean or the surf near shore mix a portion of the oil into the s eawater. The tiny oil droplets suspended in the water substantially increase the surface area available for dissolving hydrocarbons into the water. Water-in-oil emulsions may also be formed. The suspension of oil droplets in seawater is related to the turbulence in surface waters. Turbulence is increased when waves break so that winds strong enough to cause whitecaps substantially increase the turbulence of surface waters. The depth to which this wave induced turbulence penetrates varies, but 30 to 100 feet might be a representative range for the depth of penetration of the strong wave generated surface turbulence. Thus, the fine oil droplets dispersed by wind mixing would be most abundant in near surface waters (less than 100 feet). Mixing of waters caused by strong tidal currents in e stuaries can mix oil droplets to much greater depths. Oil droplets respond to turbulence depending on their size; the rise velocity of a small oil droplet will be much less than the rise velocity of a large droplet. Thus, one can expect to find small oil droplets fairly deep, while large droplets should remain near the surface. Increased mixing also increases the depth of droplet penetration into the water. Wind blowing over the water surface imparts momentum to the water and sets the water in motion. At the very surface water layer movement is in the direction of the surface wind. It will continue to move in that direction so long as the wind continues to blow. The motion while the wind blows is of importance, because the surface layer of water and associated oil slicks can move substantial distances. Ill- 52 d. Movement of Oil Slicks in Estuaries (17, 19) In an estuary, movements of oil slicks are complicated by oscillatory tidal currents. Therefore, a slick in an estuary will behave somewhat differently than it would in the open ocean where tidal currents have relatively little effect. In the surface layers, the spilled oil will be extended into an elongated horizontal plume by tidal currents. Through the action of mixing processes previously described, these will develop a widespread slick of relatively low concentration, on which is superimposed, with each tide, a relatively narrow plume of higher concentration. Tidal currents moving past irregularities in the shoreline further disperse the oil. Intense mixing of oil and surface waters can occur where strong tidal currents move slicks across an irregular bottom such as the sills (submerged ridges) in fjord-like estuaries. Frequently, eddies associated with embayments or with points of land that project into the estuary will temporarily trap water containing high concentrations of oil as the plume is carried past by tidal currents. Most of the oil is carried out on past the s hore feature by the tidal current, while the trapped oil slowly spreads out into the main stream causing dispersal behind the main body of the slick. When the tide reverses, the process is repeated, with a resulting dispersion on the opposite side of the slick. e . Transfer of Oil Films to the Atmosphere ( 2 1 Observations of the elimination of oil films from large lakes suggest other important processes may be actively removing oil from sea surface and injecting it into the atmosphere to be carried away by the winds. Recreation spawned oil films are eliminated from the water surface in 70 to 9 hours after boating activity has stopped. There was no evidence that these oils are removed by evaporation or either dissolution or emulsification in the water, the major processes previously discussed. Ins tead it appears that most of the r em ova I occur s by formation of t iny droplets (aerosols) which are injected into the atmosphere. Furthermore, the droplets carried in the atmosphere preferentially absorbed salts and certain polar organic materials from the water. In other words, the chemical composition of the bulk water does not provide a reliable indicator of the chemical composition of these airborne droplets. 111-53 The combined action of bubbles and ultraviolet irradiation was found in laboratory experiments to be most effective in removing oily films from the water surface. Exposure to the atmosphere and ultraviolet radiation apparently oxidized the hydrocarbons in these natural films. The film materials preferentially pick-up other oil- soluble constituents in the water. Surfaces of droplets are also likely to be colonized by bacteria and other micro-organisms. While conclusive data are still lacking, these processes may be the cause of reported rapid disappearance of oil slicks in many marine areas. f. Behavior of Spilled Oil on Shore When an oil slick reaches the shore, its behavior depends on the nature of the oil, its emulsions, and the shore. Usually, much of the oil will be carried to the beach and deposited at the high-water mark by successive tides. Well-weathered or heavy oils mix with sand or plant debris during this process, forming "oil-cakes." These cakes may cause greater trouble by sinking into sand and gravel or clinging to seaweeds. Pebble beaches are more troublesome to clean than sand beaches because of the oil may sink among the pebbles to' a depth of 0. 5 -1 meter. Oil does not sink so readily into wet sand. Breakers may, however, throw fresh sand over the oil containing sand, burying it. In this way a beach may appear clean shortly after an oil slick has come ashore. Later removal of surface layers during storms or in seasonal sand movements exposes the oil. Oil may also persist on dry rock surfaces or among weeds, barnacles, and mussels, where in addition to the biological processes it is slowly removed by drying, hardening, and the incorporation of sand particles, finally eroding or flaking off. Although some oils fail to wet the mucous body surfaces of animals or the mucilaginous surface of certain algae, they cling to the byssus- threads of mussels and the outer layer of shells and certain upper shore weeds which have a naturally oily surface. Oil also has an affinity for some marine grasses and flowering plants. 2. BIOLOGICAL EFFECTS OF SPILLED OIL AND RELATED OCS DEVELOPMENT ACTIVITIES (2, 10) Exposure to spilled oil can affect an organism physiologically and behaviorally. Many of these effects are cellular. How oil affects individual organisms may be generalized as: direct lethal toxicity; sublethal disruption of physiological 111-54 processes and behavior; effects of direct coating by oil; incorporation of hydrocarbons, causing tainting and'or accumulation of hydrocarbons (including carcinogens) in organisms directly or by food-web transfer; and changes in biological habitats. Lethal toxicity (death) can occur when hydrocarbons interfere directly with cellular and subcellular processes, especially membrane activities. Sub- lethal effects may also involve cellular and physiological effects. Although they do not produce immediate death, sublethal responses ultimately can affect survival of individual organisms, their local population dynamics, and the dynamic equilibria of biotic communities*. Important in this category are disrupted behavior, higher susceptibility to disease, reduced photosyn- thesis, reduced fertility, and abnormal development. Coating is generally a ssociated with the high-boiling fractions of oil, i. e. , weathered oil. It can be a problem for intertidal sessile species, plankton, and diving birds. Mobile organisms would seem to have the capacity to avoid prolonged exposure. Subtidal benthic species are somewhat protected from coating because oil does not occur as a film on subtidal sub str ate ** except in the worst local spill situations. Coating smothers or mechanically interferes with movement and feeding or causes loss of feathers, loss of heat, salt balance problems, etc. The incorporation of hydrocarbons, including carcinogens, is of particular concern because they can accumulate in marine organisms and be transferred to other organisms through the food web. Both tainting and accumulation of hydrocarbons can occur in marine organisms exposed to oil. Oil entering a salt marsh, for example, is found in virtually all marine organisms. Once exposure is terminated, however, with time some species have recovered completely. Significant shifts in composition and distribution of species in a region result when a habitat is so changed a s to become unsuitable or less suitable to a species which normally inhabit it. Intertidal and subtidal benthic species are, therefore, important subjects. How much and what kinds of oil *A population is here defined as a group of individuals of the same species inhabiting the same geographic region o f t he marine environment. A community is here defined as a group of populations occupying the same regions or biotic zone in a region. **A substrate is the material or surface from which a plant or animal obtains support. 111-55 prevent species from utilizing a substrate, for example, is largely unknown; but in view of available data, the presence of low to medium boiling point aromatic hydrocarbons at concentrations as low as 10 to 100 parts per billion may chemically perturb many species. The effects of higher boiling, insoluble materials depend on how much an organism relies on its particular substrate and how much it is altered by oil. Species depending on a substrate only for passive support may be little affected by habitat changes caused by the oil. But those living in the substrate or otherwise actively depending on the substrate are surely more vulnerable. Still other effects are acclimation and selection, processes that may alter how individuals and populations tolerate concentrations of oil. Table IIIE-l lists the sensitivities of selected species to oil. Table IIIE-2 is an assessment of toxic sensitivities; only two categories of marine organisms - adult and larval stages are considered. Available data indicate that death may be expected in most adult marine organisms from exposure to 1 to 100 parts per million of total soluble aromatic hydrocarbon derivatives (SAD) within a few hours exposure. For larvae, lethal concen- tration may be as low as 0. 1 parts per million of SAD. These lethal concen- trations can result from unweathered oil slicks. SAD concentrations of 10 to 100 parts per billion may interfere with chemical sensing and communications on which lobsters and anadromous fish depend. The impacts of oil on local populations may be examined by considering parameters such as population size and age distribution. In looking at impacts, one must remember that accidental spills and chronic discharges are not the same. For accidental spills three general stages may be analyzed: prespill equilibrium, immediate postspill impact, and recovery to equilibrium conditions. In contrast, a continuous discharge results in oil contamination at low concentrations, which may not produce immediate, dramatic impacts but may instead show subtle, long term effects. Biological impacts are determined by the following factors: Type of oil spilled, in particular, the concentration of lower - boiling aromatic hydrocarbons Amount of oil Physiography of the spill area Weather conditions at the time Biota in the area Season of the year III- 56 Table IIIE-l Effects of Oil on Selected Species 1 Species Common name Lethal Sublethal Coating Uptake and tainting Habitat change Birds Rissa tridactyla Kittiwake X Fishes Alosa spp. Clupea harengus Fundulus heteroclitus Gadus morhua Micropogon undulatus Morona sax a til is Pseudopleuronectes americanus Alewife Herring Mummichog Atlantic cod Croaker Striped bass Winter flounder X X X X X X X X Crustaceans Acartia spp. Ampelisca vadorum Balanus balanoides Calanus spp. Crangon spp. Emerita spp. Homarus americanus Paqurus longicarpus Pandalus spp. Zooplankter Amphipod Acorn barnacle Zooplankter Shrimp Mole crab American lobster Hermit crab Shrimp X X X X X X X X X X X X X Mollusks Asquipecten spp. Crassostrea spp. Donax spp. Mercenaria mercenaria Modiolus spp. Mya arenia Mytilus edulis Littorina littorea and spp. Nassarius obsoietus Thais lap ill us Scallop Virginia oyster Coquina clam Northern quahog Horse mussel Soft-shell clam Edible mussel Periwinkle Common mud snail Dog whelk X X X X X X X X X X X X X X X X X X X X X X Worms Arenicola marina Nereis virens Stroblosoio benedicti Lugworm Clam worm Polychaete X X X X X Other animals Asterias vulgaris Strongylocentratus drobachiensis Starfish Sea urchin X X X Plants Juncus gerardi Spartina alterniflora Spartina patens Laminaria spp. Marsh rushes March grasses Cord grass Kelp X X X X X 1 Poes not list all species for which data have been reported. Rather, an X represents reported data for those species which were selected for special consideration. An X indicates that some data, regardless of number, have been reported. Source: The Massachusetts Institute of Technology Department of Civil Engineering, 1974, "Atlantic/Alaskan OCS Petroleum Study: Primary Biological Effects," prepared for the Council on Environmental Quality under contract No. EQC330. HI- 57 TABLE E-2 ESTIMATED ACUTE TOXICITY SENSITIVITY (Parts per million) Estimated concentration Class of soluble aromatics causing toxicity Plants 10-100 Finfish 5-50 Larvae (all species) 0.1-1 Pelagic crustaceans 1-10 Gastropods (snails, etc.) 10-100 Bivalves (oysters, clams, etc.) 5-50 Benthic crustaceans (lobsters, crabs, etc. ) 1-10 Other benthic invertebrates 1-10 Source: The Massachusetts Institute of Technology D epartment of Civil Engineering, 1973, "A Preliminary Assessment of the Environ mental Vulnerability of Machias Bay, Maine to Oil Supertankers", prepared for the Council on Environmental Quality (NTIS Accession No. COM 73-10564). HI- 5! Previous exposure of the area to oil Exposure to other pollutants Method of treatment of the spill The potential impacts of offshore oil and gas operations, in particular those of oil spills, are summarized here. a. Impacts on Plankton (10) Planktonic organisms comprise a wide range of life styles, from the phytoplankton (plants) to the zooplankton (permanent zooplankters such as larval forms of benthonic organisms). Phytoplankton are generally adversely affected by crude oils and refined products. Laboratory studies have shown that death and growth rate inhibition can occur in crude oil concentrations of 0. 001 to 1, 000 ppm; other studies have found enhancement of photosynthesis at concentrations below 10 to 30 ppb. Thus, the possibility of both stimulation and suppression of photosynthesis in areas of chronic oil spillage must be recognized. In general, though, the effects are deleterious at the organismic level, but field measurements (e. g. , Santa Barbara) of community primary productivity have generally been inconclusive. Primary production is inhibited under an oil spill, which naturally blocks out light to various degrees. Another widely recognized impact on phytoplankton arises from heavy metal loadings, which generally are toxic, but have also been conjectured as possibly triggering red tide outbreaks. Knowing the low level of oil concentrations that can affect phytoplankton, it is conceivable that the most serious impact comes from chronic low- level pollution. Continuous low level stress could seriously impair phytoplankton growth at both the organism and population levels. This could lead to serious losses in primary productivity, the basic food production and oxygen formation process of these plants. Primary productivity is generally higher over the continental shelf than over deeper waters, as nutrients can cycle more easily. Effects on phytoplankton will be of the same general magnitude for the same level of development wherever they occur, although species composition will vary. The exception to this is the possibility that more serious effects will be felt by the phytoplankton in colder climates. Here, where oil does not chemically weather as rapidly and microbial degradation is slower, spilled oil remains longer and thus could impact for a longer period. Toxic, water soluble aromatic would have a longer time to dissolve in the water. The 111-59 additional problem of oil spilled under ice is an unknown phenomenon; if volatiles cannot escape, they will tend to dissolve in the water to a greater degree, possibly affecting the phytoplankton that live near the ice water interface. Most of the data concerning impacts on the permanent zooplankton (holoplankton) is related to copepods (small crustaceans). Several species suffer high mortality after several days exposure to oil in a concentration of I microliter/ liter of seawater. Longer exposure or higher concentrations (up to I ml/l) increase mortality. No information has been found concerning transfer of pollutants from phytoplankton to herbivories. Shading may also disrupt vertical migration of zooplankton, which is lightcued. Both phytoplankton and zooplankton will also be affected on a small scale because of the turbidity attendant to drilling operations, as well as by the discharge of high salinity, low oxygen formation waters. Of particular interest are the planktonic larvae of various benthic inverte- brates and fish. Many of these species are either actually or potentially harvestable, and impacts on the larvae affect population sizes and distributions. These meroplankter s (planktonic for part of their life cycle) are generally considered to be very sensitive to environmental stress and predation while in the water column. Although they are not as sensitive as holoplankter s; they are, however, more sensitive than the benthic adult forms. The meroplankter s are subject to the same types of impacts as other planktonic organisms; lab studies indicate that death and abnormal growth can be expected in concentrations ranging from 10-100 microliters of oil per liter of seawater. Fish larvae, such as cod and herring, are susceptible to crude oils. In addition, many species of fish have eggs which float in the water column or at the surface; the eggs of several species have sustained high mortailities in some of the more noted spills. Many of these impacts are localized and of short duration; however, there are longer term possibilities that must be mentioned because they have been postulated by scientists but not definitively proven. Many of the organisms with high turnover rates (short lives, high reproductive potential) are probably not significantly affected by noxious substances. For the longer lived creatures, other effects may be noted. One is the possibility of food chain magnification of trace toxics. The widely known example of this phenomenon is food chain magnification of DDT. Noxious substances may be concentrated because of selective absorption of materials in specific 111-60 tissues that are digested by higher trophic level organisms. The possibility then exists of non-toxic levels becoming toxic by this concentrating mechan- ism. Transfer of these substances through food chains probably occurs; magnification may not. Lethal and sublethal effects reduce population levels and potential distribution at least in the short term. Long term reductions of primary and secondary productivity of marine ecosystems may result, but there is no data to support this hypothesis. Of particular concern are the effects on age-classes, and the percentage of eggs that reach adulthood is generally quite small. A particular year-class of eggs or larvae may be small due to low fecundity and high predation. The additional stress of a massive oil spill may reduce a year-class to critically low levels. Like the p hytoplankton, the zooplankton will be affected to approximately the same degrees in all areas, given the same level of oil and gas develop- ment. The cold versus warm argument applies here also. In areas of hea'vy commercial fishing, such a s the North Atlantic, Gulf of Mexico, Gulf of Alaska, and B ering Sea, eggs, larvae, and juveniles of important fisheries could be affected to a great degree. b. Impacts on Fish (10) Little is known about the effects of oil and gas operations on fish at sea. Midwater migratory fish presumably would avoid areas which they sensed were noxious or locally adverse, although some fish might not be able to avoid spilled oil and would suffer from clogged gills and damaged gill tissue. However, tainting of fish is a well-documented occurrence which apparently means that fish cannot always detect noxious conditions. Tainting usually results in a loss to commercial fishermen who cannot sell their catch. Much of the research on the effects on fisheries attempts to analyze declines and rises in catch and catch per effort. In the Gulf of Mexico, where oil and gas operations have been occurring for 2 5 years, no significant long-term changes in fish catch have been noted. However, the record catches of 1954 have never been exceeded, and recent studies at Texas A&M University indicate that the fish catch has remained high due to increased effort. Shrimp catches in the last few years have been declining both in total catch and catch per effort. No explanation has been offered for these occurrences. Several physiological - behavioral effects may take place. Oil may affect fish nutrition by blocking taste receptors and mimicking natural chemical messengers which attract predators to prey. Chemical "static" may affect the migratory patterns of fish, an important point to such chemosensing 111-61 migrants as salmon, which may be prevented from finding their spawning stream. It has also been suggested that hydrocarbons may block reception of chemicals necessary for reproductive attraction; social conflict behavior may also result. Oil spills might block' the estuarine passage of anadromous fish, thus effectively preventing spawning. Direct mortality with severe consequences could occur if a massive oil spill reached nursery areas at <_~rtain times of the year. Demersal fish, especially those with eggs and larvae that remain close to the bottom, should suffer less impacts than the midwater fish. However, entrainment of heavy hydrocarbons and trace metals in sediments is a constantly occurring fate. These entrained substances may enter sea bottom food chains and adversely effect organisms. Bottom organisms may also be affected by turbidity of drilling and pipelaying operations; pipe trenching may resuspend toxic materials that had been entrained. Much of the toxicity work on fish has been conducted in the laboratory. Many species die in response to applications of crude oil, refined products, trace metals, and drilling mud components in concentrations as well as exposure times that could conceivably be encountered in the ocean. The significant fishery resources (finfish) of North America are found in the North and Middle Atlantic, central Gulf of Mexico, Gulf of Alaska, and Bering Sea. Some impacts on these resources must be expected, although magnitude estimation would be speculative. c. Impacts on Benthic Marine Life (10) Environmental impacts which may be expected to affect benthic marine life adversely will likely result from the discharge of drill cuttings and drilling muds, accidental and chronic discharge of oil and other toxic materials, and pipeline burial. Heavy mortalities were noted at the West Falmouth spill of No. 2 fuel oil, but resettlement eventually took place to some degree within two years. Nearshore benthos are most susceptible to mortality from oil spills. Drill cuttings can affect benthic organisms in a number of ways. Many organisms are smothered and crushed outright, since they can't move very well. See Section IIIE-3. Other organisms are able to migrate up through the deposit, and some colonize very rapidly. The nature of the cuttings (consistency and composition) may aid or preclude recolonization, however. Attached plants are also exposed to smothering and crushing. 111-62 Drilling muds and fine sediment are discharged overboard during drilling operations. See Section HIE- 3. This generally creates a plume of fine sediment and mud materials that flows with the prevailing current. The plume may reach to the bottom and deposition would occur. This creates the hazard of clogging of the filter-feeding mechanisms which abound in the benthic community. Respiratory mechanisms are also affected by sediment plumes. Sedimentation is inimical to viable coral reef develop-, ment and has been mitigated against where threats to coral reefs exist. Toxic materials are found in drilling muds, including barium (as barium sulfate, the dominant component of drilling muds) which has generally been considered a small hazard because of operator recovery and its low dissociation in sea water. Most, if not all, benthic biota are either destroyed by the jetting of pipeline trenches or raised into the water column and exposed to predation. See Section IIIE-4. Although recolonization could begin immediately, the native biota could not be fully restored until seasonal reproductive cycles had been completed. Turbidity associated with trenching affects filter -feeders and respiration. Resuspension of toxic heavy metals and p esticides will adversely affect local populations. d. Impacts on Birds (10) In the past, the injuries and deaths of thousands of seabirds, shorebirds, and waterfowl have been the most obvious impacts of massive oil spills. It has been stated that the only organisms damaged directly by oil pollution on a sufficient scale to seriously affect populations are seabirds. A large number of oceanic and shorebirds die as a result of the oil pollution, and chronic pollution probably kills more every year than die after a single catastrophic oil spill. It has been estimated that total annual losses due to oil pollution in the North Sea and North Atlantic alone (excluding specific disasters) range from 150, 000 to 450, 000 seabirds. At least five factors contribute to the precarious status (extreme vulnerability to catastrophic oil spills) of bird populations. I. Bird kills result from coating of the feathers by the weathered or unweathered petroleum, destroying their insulating property. Diving birds show no awareness of oil slicks and dive directly into them. Any shorebirds moving about along the shoreline could be covered with washed up oil. 111-63 2. Bird populations are small and, therefore, have a high risk of extinction. This means that after the original population (pre-spill) is reduced, n atural population fluctuations - easily absorbed in the original stock - could lead to extinction. 3. Bird fecundity - typically two to three young per breeding pair per year - severely limits ability to recoup losses. 4. Maturation usually requires 3-4 years, further delaying recovery. 5. Birds are often highly aggregated, thus exposing the entire breeding population to localized oil slicks. Significant bird populations exist in most coastal areas, at least for part of the year. Many are migrants, and many are threatened o r endangered. Large and diverse bird populations m ay be found in the marshes and bay areas of the East and Gulf Coasts, as well as in marshes and other wild areas of t he Gulf of Alaska and the B ering Sea, especially B ristol Bay. Endangered species may be nearly extinguished if certain circumstances such as a massive spill near a breeding area should occur. Adequate buffer zones and rapidly deployable cleanup equipment could mitigate to some degree these disastrous impacts. Identification of critical habitats is the first step toward such mitigation. e. Impacts on Mammals (10) The impacts of oil pollution on mammals are poorly known, although generally recognized to be less serious than on birds. In the rather closely studied Santa Barbara spill, marine mammal deaths due to oil could not be distinguished from mortality due to natural caused. Mammals can be affected by oil, however. The fur-bearers could be affected like birds, i. e. their insulating capabilities are destroyed. Massive spills could suffocate mammals, and ingestion of oil could result in death by poisoning. Marine mammals may be intelligent enough to avoid adverse conditions, but the avoidance itself may disrupt the herd or the migration pattern. Coating of the sea- land interface could effectively remove breeding and hauling grounds from use, a potentially catastrophic occurrence for some species. Most of the significant mammal populations are on the West Coast and in Alaska, although porpoises of various species are rather ubiquitous. 111-64 f. Impacts on Plants (10) Various types of plant communities could be affected by the different operational discharges and mechanics. The obvious food and oxygen production of plants cannot be overlooked. The phytoplankton community has already been discussed. Benthic algae, seagrasses, kelp beds, nearshore mar shgrasses, mangroves, and seaweeds are all communities that could be seriously damaged by: oil spills, chronic oil discharge, drilling mud and cuttings discharges, pipeline laying and access canal construction, and onshore facilities. Large scale impacts on the plant communities, which, while not expected, must be recognized for their potential impacts on the entire food chain. g. Impacts on Unique and Highly Valued Areas (10) At a higher level of organization than the organism or population level are those areas with distinctive biological characteristics that set them apart from surrounding areas. These areas include marshlands, barrier islands, mangrove swamps, wildlife refuges and sanctuaries, coral reefs and isolated reef-type communities, shellfish and worm reefs, kelp beds, bird rookeries, pinniped rookeries, and topographic highs that serve as commercial fishing banks. Potential impacts on these areas are more important because of the intrinsic value of the areas and the relationship and dependencies within the areas that could be disrupted by impacts on one component. Marshlands and barrier islands can be affected by repeated oilings, but the single large oiling apparently does not prevent recovery of the area. Evidence exists that moderate oilings can produce an increase in production in marshlands. Chronic oil pollution has decidedly deleterious effects on marshlands, however. Mangrove trees have been killed by oil spills. The primary adverse impact on these areas derives from pipeline traversing. Construction and maintenance of pipelines entails channel dredging (both for the pipes and equipment access), the presence of equipment and manpower, creation of dredge spoil banks and the attendant turbidity and resuspension of toxic substances, and alteration of salinity and circulation patterns from channel creation. All these activities can result in decreases in vegetation and habitat for organisms, as well as affecting the water quality on which the spawning and breeding of many commercially valuable species depends. Wildlife refuges and sanctuaries (including estuarine and marine sanctuaries) are created specifically for removal and protection from any man-induced activities. The introduction of possible impacts from OCS activity impinges 111-65 on this basic justification of existence, .in addition t o t he value of the areas in purely ecological terms. The same types of activities mentioned previously could affect these managed areas, such as oil spills and pipelines; onshore facilities might also be sited in these areas. It must b e noted that, in most cases, there are stringent regulations regarding activities other than those for which the managed areas were set aside. Topographic highs or banks are distinctive features on much of the OCS, e.g., in t he Gulf o f M exico. When shallow enough, they may be capped by coral reefs or reef-type communities that are extremely valuable to scientists and the public. The banks also serve as habitat for large schools of commercial fish such as snappers and groupers. These features are at some depth below the surface and would not be directly affected by spilled oil. Primary impacts would be due to sedimentation from drilling and pipe laying operations and mechanical disturbance from fixed platform siting and pipeline crossing. Sedimentation is inimical to reef communities; platforms may cause congregation of commercial fish (thus making it more difficult for fishermen to catch them) or drive them away from traditional fishing areas; and pipelines may cause fishing gear hangups. Chronic pollution by oil and other toxic substances may be injurious to both reef communities and commercial fish populations. Shellfish and worm reefs are found in many areas of the OCS, e.g. the Atlantic and Gulf of Mexico coasts, generally in estuarine locations. Oysters and clams are among the most important commercial intertidal and shallow subtidal organisms of our coasts. Intertidal and subtidal organisms potentially suffer the most damage from spilled oil, either through smothering, fouling, or direct poisoning. Toxic lethal effects are generally rare from a single oiling; mechanical lethality is more common. However, chronic exposure appears to be more harmful than single, isolated oilings; and in chronic exposure, toxicity may be a more important impact-producing factor. Many nearshore and estuarine areas harboring large concentrations of oysters, clams, and shrimp are already stressed from sewage and industrial discharges. Additional loadings from oil spills and chronic oil pollution may reduce the commercial harvest because of tainted taste o r health hazards. The unique kelp beds in Southern California harbor a diverse community of organisms, a s well as being of commercial importance. Oil does not appear to significantly damage kelp itself but may affect other organisms in the community. Some impacts to the kelp may result from laying pipe through the beds. 111-66 Rookeries exist in many areas of the U. S. coast. Bird rookeries will be threatened by human activity associated with operations, pipeline traversing, construction of onshore facilities, and oil spills. Oil spills that approach bird rookeries have potentially serious consequences because of the concentration of birds that may be found at certain times of the year. Pursuit of food may cause large numbers of birds to contact oil on the water. Pinniped rookeries and hauling grounds are primarily threatened by human activity; in comparison, contact with oil is not as significant a problem. Platform construction and maintenance, pipelaying, and onshore c onstruction near breeding and hauling grounds may cause abandonment o f t he grounds. Many pinniped species utilize only one area for breeding, and forced abandonment of a breeding area would have serious repercussions within the population. Sea otters are one group that suffer from contact with oil; like birds, their coats lose insulating qualities when oiled. h. Impacts on Commercial and Sp ort Fisheries (10) Removal of the Sea Floor from Use Those fisheries involved with exploitation of bottom or demersal species are impacted by the removal of fishing grounds. All sites occupied by drilling or production platforms, as well as attendant service boats and barges, must be avoided by fishing boats. Fisheries involved include shrimp (the most valuable fishery in the U.S. ), lobsters, Pacific coast crabs, and bottom fish (flounders, halibut, industrial groundfish). Jack-up drilling units or permanent production platforms effectively remove two to five acres of fishing area per structure. In deeper waters (over 100 meters), a semi- submersible drilling rig with a 300 meter anchoring radius would remove up to 70 acres. The duration of the exploratory drilling ranges from about 45 days for a single well to around six months for multiple well explorations. Permanent production platforms may remain in place for 10 to over 20 years. Structures placed on the sea floor are known to attract large numbers of fish in the Gulf of Mexico and California. (There is no evidence that these new populations are made up of displaced individuals from nearby populations' Commercial and sport fishermen work around these rigs because of the large populations of fish commonly found there. However, purse seining, which requires a large amount of area, may be somewhat restricted by close spacing of rigs and platforms. The total number of platforms required 111-67 to develop a lease area and their spacing relative to each other are important factors in considering potential impact on commercial fishing activities. In addition to the removal of the sea floor for fishing, the structures and additional traffic increase the congestion within an area, requiring fishermen to spend more time navigating and avoiding collisions. Creati on of Obstructi ons Offshore oil and gas operations create obstructions on the sea floor, such as underwater stubs, subsea completions, large pieces of debris, and buried pipelines. Underwater stubs present a hazard to trawlers in that if the net is towed across a stub, the net will certainly be badly damaged or lost. Large pieces of debris, such as equipment, piping, structural members, tools, etc. , may accidentally be lost off a platform, service boat, or barge. If these pieces are not recovered, they may cause damage or destruction of nets or other fishing gear which encounter them. Unburied pipelines (beyond the 200 foot depth contour) may pose a problem to bottom trawl fishermen. However, about 90% of the Gulf of Mexico shrimp catch was harvested inside the 120 foot depth contour. Pacific coast shrimping grounds are generally in areas of low petroleum potential (northern California, Oregon). California trawling fishermen have indicated that unburied pipelines may pose some problems but felt that they could maneuver their vessels so as to m inimize damage or loss of their nets (U.S. Geological Survey, 1974). Due to unstable bottom conditions, the gradual exposure of once-buried pipelines may present even more difficult problems offshore New England. Pipeline corridors and pipeline burial out to the 200 foot depth interval within a lease area reduces the hazard. Contamination of Fish by Spilled Oil Fish which are either externally coated or internally contaminated with oil are unmarketable. Organisms living in the vicinity of chronic oil spillage are likely to be internally contaminated. The extent of contamination in offshore waters is not detectable, but it is so in some coastal areas where waterborne or water soluble petroleum products can become c oncentrated. 111-68 A secondary impact of oil contamination of fish and shellfish is that the marketability of these fishery products is initially reduced due to the direct health or esthetic effect of the oil. Later the fishery product may gain a poor reputation, and the economic effect may far outlast the period for which the fish are actually tainted. R eduction of Fishing Effort Due to Spilled Oil Oil spills may r educe fishing effort, which in turn reduces the total catch. Effort reduction occurs when oil actually fouls fishing nets and gear, or the presence of oil in the water restricts fishermen from fishing for fear of fouling their gear. Landings of rockfish were greatly reduced in the Santa Barbara area because of a reduction of fishing effort caused by oil contamination of boats and gear, as well as the negative esthetic appeal of fishing in polluted waters. Areas of chronic oil pollution may also foul fishing gear on occasion, resulting in extra expense and reduced fishing effort while cleaning or replacing the gear. This may be significant where large purse seines are used at the surface (such as for Alaska salmon). Removal of Onshore Sites Considered for Aquaculture Aquaculture of marine organisms, such as clams, oysters, and juvenile salmon, is emerging as an industry. Pollution effects can be severe on this industry. For example, a single large oil spill in Puget Sound could destroy the area's extensive aquaculture industry. The State of Washington denied oil and gas lease applications in Puget Sound. The state considered such action incompatible with a potential multi-million dollar a year sea- food cultivation industry. Future seafood aquaculture industries may refrain from establishing operations in areas associated with petroleum products if a pollution potential exists. . Sport Fishing A major oil spill will very likely adversely effect sport fishing. Boat fishermen would not want to soil their boats by fishing in the vicinity of an o il slick, and neither boat nor surf fishermen would want to keep fish that has been coated o r contaminated with oil. Therefore, sport fishing would be curtailed in the vicinity and for the duration of the spill incident. 111-69 Extensive evidence exists that overall, oiL and gas operations have a favorable impact on sport fishing activities. The favorable impact is the result of sports fish population enhancement due to the artificial reef effect of offshore platforms. In the open sea, offshore platforms provide both food and cover in areas that are largely devoid of these essentials. Myriad forms of micro-organisms in the water drift by these structures. The average platform in 150 feet of water provides 90, 000 square feet of hard surface for encrusting organisms. Hard substrate is necessary for encrusting organisms such as barnacles, hydroids, corals, mussels, and other invertebrate organisms which serve as links in the food chain. Artificial reefs provide protection, food sources, spawning sites, and spatial orientation markers for fishes. Artificial reefs attract available fish from surrounding waters and increase the size of some populations by providing additional protected areas and food for both young and adults. i. Impacts on Recreational Values If pipelines which result from OCS development are brought ashore in a beach area used for recreation, there will be an impact on recreational activities. The area of a beach disturbed by pipeline construction will be small (about 30-50 feet wide), and the first high tides following burial of the pipeline will serve to restore the beach terrain. A storm tide or high winds may be necessary to obliterate the effects of excavation. Physical interference with recreational activities from excavation will be minimal and short lived. If pipeline terminal or transfer facilities a re located in o r near a beach or other area used for recreation, there will be an adverse impact on recreational activities from disruption during the construction phase and elimination of about 40 acres per terminal plant for recreational uses. This latter impact would be long-term and restoration of the area, if attempted at all, would have to await depletion of the offshore production which the plant would be designed to serve. These impacts will diminish the quality of the area for r ecreational enjoyment. The impacts of pipeline and terminal facilities construction on recreation would be mitigated somewhat if the appropriate governmental authorities were to allow this type of construction only during the time when recreational use of the area is at its lowest point. The impacts from permanent terminal facilities could be mitigated somewhat by locating them at some distance inland where recreational use is not intense. State authorities may wish to consider this alternative. 111-70 Water sports, such as swimming, diving, spearfishing, underwater photography, fishing for finfish and shellfish, boating, and water skiing would also be directly affected by an oil spill. Other seashore related activities such as beachcombing, shell collecting, painting, shoreline nature study, camping and sunbathing would be made much less attractive for an indeterminate period where an oil spill had coated a beach. Removal of oil from beaches used for recreation in the area under consideration would probably involve removal of the contaminated sand and, possibly, replacement of the sand if needed. The t ime reauired for clean- up in this case would depend on the extent of beach affected. Recreational use of the area would be precluded during the time that oil covered the beach and during the c lean-up process also. The impacts of an oil spill discussed above would be more keenly felt if the recreation area involved in intensely used for considered to have unique or outstanding recreational values. Not only would the impact be felt by the recreational users of these areas, but so would the community of businesses whose economic well-being depends on use of their recreational resources by tourists. If an oil spill were to cover outstanding recreational beaches during the height of the recreational season, the impact could be expected to b e more severe in that residents and tourists would not be attracted to a beach area contaminated by oil or undergoing a clean-up process. There would be a resultant economic loss. 3 . DISCHARGE OF DRIL LING M U DS AND DRILL CU TTING S ( 10,21) As the drill bit bores through the bottom sediments and the underlying native rock, it shatters and pulverizes these materials which then move up the riser to the surface where they are cleaned and discharged overboard. Mixed with the drill cuttings as they are discharged overboard can be quantities of commercial drilling muds, although much of the drilling mud is separated and retained for re-use. Drill cuttings are not known to be toxic, and their discharge overboard should cause only minor environmental impacts. However, certain components of drilling muds are known to be toxic to aquatic organisms. Drilling m uds are not normally dumped into the ocean. It is forbidden by OCS Order No. 7 (U.S. Geological Survey, Department of Interior) to dump drilling mud containing oil into the ocean. This OCS Order a Iso forbids the discharging into the ocean of drilling mud that has been treated with chemicals of a type III -7.1 or quantity that would result in the drilling mud being toxic and thus detrimental to the marine environment. The muds normally used pn OCS wells, down to the surface casing setting point, consist of s eawater and gel (bentonite clay) as shown below. This is a lightr-weight mud with few chemicals. Gelled Sea Water Mud Typical Composition Mud com pone at used W ei ght (pounds) Bentonite Clay 56,000 Caustic (Sodium Hydroxide) 5,500 Barium Sulfate (weighting agent) 12, 200 Organic Polymer 3, 700 Ferrochrome Ligno sulfonate 3, 300 (Iron-2.6%, Chromium- 3. 0% Sulfur - 5. 5% Pregelantinized Starch 500 Sea water as r equired Total Mud Components 81, 200 Below the depth of the surface casing, the mud system is generally changed to a seawater lignosulfonate system. Materials widely used are aluminum stearate for foaming c ontrol, bentonite for gelling mud, barite for weighting material, carboxymethylcellulose for reduced fluid loss, lignosulfate for a thinner and for reduced fluid loss, bicarbonate of soda for cement contamination, and caustic soda for pH control. Caustic soda is considered toxic in concentrated form. The muds that are used off- shore have pH's in the r ange of 7 . 5 to 10. The caustic s oda ( sodium hydroxide) used to keep the pH high (alkaline) will i n t he presence of sea- water and within certain pH ranges react to form calcium hydroxide, magnesium hydroxide, and barium hydroxide. The latter is insoluble and will sink immediately to the bottom because of its specific gravity. Of some concern is the presence of chromium in many marine drilling muds a s the organic complex, (ferro) c hrome lignosulfonate. Overboard loss or discharge of drilling fluids would introduce some of this chromium into the marine environment. Overall recent industry tendencies towards maximum recovery of chemical additives minimize any potential hazard to marine life. 111-72 On a weight basis, chromium is p reseat in unweighted commercial lignosul- fonate drilling mud components at a concentration of about 12 parts per thousand (ppt). Required seawater additions to the mud concentrate reduce this value to less than 4 ppt. -- the approximate concentration of chromium in drilling mad, if discharged. In addition, dilution/dispersion effects associated with overboard discharge would be considerable. Although data relating to toxicities of organic compounds containing chromium are scarce, recent work saggests that chrome lignosulfonate, in moderate to strong dilution, is relatively harmless. While readily soluble in seawater, the compound apparently dissociates very little. If inorganic chromate is also present in the drilling mud, however, oxidation of the chrome lignosulfonate occurs, evolving a new organic chromium complex. The nature of this new phase is not well understood. Physical adsorption and ion exchange occur between chrome lignosulfonate and clay components of drilling muds. Both transfer mechanisms effect the removal of chrome components from the water column with subsequent deposition as clay sediment. Once on the sea floor, chrome lignosulfonate is fairly resistant to biodegradation, however, certain benthic invertebrates are known to concentrate trace amounts of various heavy metals over extended time. The possible role of drilling mud chromium additives in this phenomenon is the subject of ongoing research. Normally the drilling mad is retained and used in drilling other wells on the platform. Moreover, i f for any reason this is not the c ase, various companies will buy this liquid mud for re- sale when they have the opportunity and available mud boats to pick it up. Heavy, highly treated mud systems are expensive and economics alone normally rules out the dumping of this type of mud system. Improper disposal of oil contaminated drill cuttings and drilling muds will also be in violation of EPA's recently proposed effluent limitations for the oil and gas extraction industry. See Federal Register of September 15, 1975. Such discharges will be subject to National Pollution Discharge Elimination System (NPDES) permits issued under Section 402 of the Federal Water Pollution Control Act, as amended, upon condition that the discharges will meet the requirements under Sections 304, 306, and 307 of the same Act. 4. DISCHARGE O F PR ODUCED FORMATION WA TERS (10) Petroleum reservoirs often have water associated with the oil and gas, and this water i s c ailed formation water o r oil field b rines. Some petroleum reservoirs contain substantial amounts of formation water, 111-73 whereas others contain almost none. Typically, petroleum reservoirs which have water drive produce very large volumes of formation water while gas drive reservoirs produce little formation water. Before wells are drilled into a petroleum reservoir, the amount of formation water associated with the petroleum deposits is not known. Therefore, at this time it is not possible to estimate the amount of formation water which may be associated with petroleum production from the petroleum deposits of the various undeveloped regions of the OCS. While substantial amounts of formation water will likely be discharged into the sea, a significant portion of the formation water will also be reinjected into subsurface formations either to enhance recovery of the petroleum products or, less frequently, to reduce adverse environmental impacts. Adverse environmental impacts generated by discharge of formation waters are caused by the physical properties of the formation water and the unremoved petroleum hydrocarbons. Current operating regulations require that the hydrocarbon concentrations of any single discharge of formation waters not exceed 100 ppm and, furthermore, that the average hydrocarbon content of the aggregate of discharged formation waters not exceed 50 ppm. These standards are to be made more stringent by Environmental Protection Agency proposed and interim final rulemaking. See the Federal Register of September 15, 1975 and Chapter IV of this document. EPA's proposed effluent limitations for the oil and gas industry eventually will eliminate discharge of formation waters, requiring p hy sical 'chemical treatment followed by reinjection. See EPA's Draft Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Oil and Gas Extraction Industry. The mineral content of formation waters can also generate adverse environ- mental impacts. At this time, the mineral content of the formation waters associated with the undeveloped petroleum reservoirs in the various OCS areas is not known. Some fields in Texas produce almost pure water whereas the average total dissolved solids of 76 samples from southern Louisiana and the OCS was found to be 112,513 milligrams per liter (mg'l) with a range from 270, 000 mg/1 to 61, 552 mg/1. Oil fields brines commonly contain varying amounts of iron, calcium, sodium, bicarbonate, sulphate, and chloride ions. Ocean waters around the world also contain each of these ions in varying amounts. 111-74 The impact-generating potential of discharged formation waters is that the concentrations of these ions in the formation water differ from the concentrations of these ions in the surrounding waters. Discharged formation waters with higher than ambient ion concentrations will sink because they are heavier. Discharged formation waters with dissolved solid concentrations lower than the receiving ocean water will tend to float on top o f t he receiving water. In either case, the discharged formation waters will mix with the surrounding waters, and their mineral content after some time will become indistinguishable from that of the receiving water. Water currents in the discharge area will speed this mixing process. Continuous discharge of formation waters from OCS production will, therefore, alter the dissolved solids characteristics of the waters adjacent to these discharges. The size of the area affected will, of course, depend upon the volume of formation water discharged, the dissolved solids content o f t he formation waters, and the dissolved solids content of the receiving waters. Another characteristic of formation waters which has a capacity for generating adverse environmental impacts is that formation waters are typically devoid of oxygen. Just as the unusual mineral content of formation waters can cause physiological problems for the living marine organisms in the area o f t he discharge, so can the lack of oxygen in these waters. How- ever, the size of this impact will be small. As the formation waters mix with the surrounding waters, the oxygen content of the formation waters will become indistinguishable from the surrounding waters. Not knowing either the expected volume of formation waters or their mineral content precludes quantification of the environmental impacts associated with discharge of these fluids. However, knowledge of the impact-generating potential of discharged formation waters, discussed above, indicates that the magnitude or severity of these impacts should not be large. If studies in specific OCS areas of the impacts generated by either hydrocarbon content or mineral content of formation waters indicate that unacceptable environmental impacts are created by discharging formation waters, appropriate mitigating measures will be adopted. 5. PIPELINE BURIAL (10) Present OCS operating regulations require burial of pipeline in water depths of less than ZOO feet. Present requirements for granting pipeline rights-of- way permits by the Bureau of Land Management stipulate that these pipelines 111-75 be buried to a depth of 3 feet into the sediments where the overlying water depth i s 2 00 feet or less. Gathering lines from clustered rigs or proximate fields do not have to meet this requirement, as they are considered part of the production system. They are generally not buried, as commercial ship traffic is at a minimum close to rigs. Because they are small diameter lines, gathering 1 ines tend to sink into the sediments by themselves. During pipeline burial, a large volume o f b ottom sediments are disrupted and resuspended for a short time in the overlying waters. The dimensions of pipeline burial excavations vary considerably depending upon the nature of the bottom sediments. This makes it difficult to calculate a reasonably accurate volume for the materials disrupted. At some future date, when exact pipeline routes are drawn for each OCS area, the volume of disrupted bottom sediments can be calculated with s ome accuracy. In general, the environmental impacts of pipeline burial are very similar to those of discharges of drill cuttings and drilling muds. a. Dredging in nearshore areas will often result in resuspension of many years accumulation of such materials a s organic matter, phosphates, and other nutrients, as well as toxic heavy metals and pesticides. The heavy metals and pesticides are of particular concern because resuspension of these materials will allow them to exert their toxic effects until they are gradually reincorporated into the sediments. The disruption of the organic matter and nutrients will increase the biochemical oxygen demand (BOD) and could lead to localized problems of insufficient dissolved oxygen to support life. The potential impacts associated with increased BOD should be of s hort duration. b. On hard bottoms, dredging will eliminate suitable sites for attachment of the b iotic communities dependent upon hard substrate attachment (sponges, soft and hard corals, seaweeds, sessile molluscs). This impact will persist throughout the pipeline burial path either permanently or until the substrate gradually becomes compacted. c. Both pipeline burial and discharge of drill cuttings and drilling muds can smother the burrowing and attached benthos. This can occur where these materials settle to the bottom and accumulate to significant depths. 111-76 d. Pipeline burial, like discharges of drilling muds and drill cuttings, increases turbidity in all locations where these activities occur. The small sized particles causing this turbidity can clog the respiratory organs of many marine organisms and the filter -feeding mechanisms of numerous others. e. In coastal wetlands and uplands, pipeline burial operations will displace many species of wildlife during construction and maintenance operations. The effects of pipeline burial in wetlands can have a substantial impact of one to several years duration as a result of devegetation and disruption of substrate. An additional significant impact of pipeline burial in coastal estuaries can result from disruption of the water circulation patterns. F. SHIPYARD CONSTRUCTION AND REPAIR 1. EXPANSION OF FACILITIES In the event of a conventional, long term global war or a critical oil and gas shortage in which the current construction program would not fill the needs of the national emergency, it may be necessary to expand the capability of existing shipyard facilities. The probability of this occurring is extremely remote due t o t he long lead time involved in the expansion of a shipyard. Rather, it would first be prudent to examine yards that could build offshore oil and gas drilling vessels and, for economic and other reasons, had declined to enter into such construction or preferred to build ships. The major constraints to the building of large offshore oil and gas drilling rigs are: a. Sufficient space within a wet basin or launching facilities if a basin is not used. b. A crane with a minimum lifting height of 250 feet must be available in order to effectively serve the construction demands of the large oil rigs. 111-77 c. Bridges along the rivers downstream of the shipyard must be of sufficient width and height to p e^mit the oil rigs to be moved from the shipyard to the open sea. These constraints, however, would not preclude the construction of components of a large oil drilling rig and floating or barging them down river to an assembly site. Only as a last resort would shipyard expansion of any significance be undertaken, and the project would be subject to extensive review by the U. S. Army Corps of Engineers and to hearings which are open to the public. Environmental Impact Statements (except in the case of war) may be prepared for each shipyard expansion and specific attention to the environmental setting of the activity will be required. Expansion of existing shipyards, which are in most cases located in already highly industrialized areas of a waterfront, would generally require certain disruption o f t he adjacent shoreline. Such disruptions may be caused by filling, dredging, pile driving, excavation, bottom stabilization, and/or other hydraulic works depending upon the nature of the expansion. When suitable land area adjacent to the existing facility is not available due to the configuration of the shoreline, location of other industrial plants, proximity of residential sections, or for other reasons, then such land must be created by filling suitable sections of the waterway on which the expansion is contemplated. Additional dredging of access channels to the construction and repair facilities may be required in certain cases because of the relatively deep draft and excessive width of large semi- submersible rigs. Any such dredging and spoil disposal would have an impact on the environment and would, therefore, fall within the jurisdiction of the Army Corps of Engineers. Creation of new acreage by filling existing waterways, whether for expansion of a shipyard or building a new one, causes a permanent impact on the waterway by diminishing its navigable and recreational area. The filled bottom ceases to provide natural habitat and possible spawning grounds for marine life. However, the new shoreline, which is generally stabilized by steel bulkheads, may provide protection for aquatic organisms, especially in localities with strong current or tidal turbulence. Construction III-7J of a new shipyard on Land which requires little or no filling would, of course, have a lesser impact on the ecology, although former wildlife value and biologic productivity will be lost. The disturbance to the environment caused by filling, pile driving, and other hydraulic activities will be of a permanent nature, changing the physical environment, and hence, also the associated biota. Once c onstruction is complete, a new final biological balance will set in. It is self-evident that in areas where profitable harvesting of shell fish has been going on for years, any disturbances to the marine environment, such as filling, will be more objectionable from a c ommercial point of view than filling in areas in which such activities never took place. In constructed areas or in the vicinity of navigable channels, the filling may cause problems to a degree where it may not be permitted at a 11 or diverted to some other location. Recreational aspects of waters which may be affected would also be considered when such planning is in progress. While the waterways 'confined by industrialized shorelines generally serve only the purposes of transportation, any water sport activity such as boating, sailing, swimming, and fishing will utilize such waterways only in transit on the way to more desirable locations. Infringing on adjacent marshlands, when such are found in generally industrialized areas, may have detrimental effects on migratory waterfowl, especially when located along established flyways. In addition, the loss of these lands could have a significant deleterious effect on the aquatic biota of the r egion, especially if the total area o f m arshland in the r egion is small. Though the number of people residing in the areas of industrialized water- fronts will generally be small, in certain instances, individual cases of dislocation may be necessary. Such cases may cause hardship to people involved, who would probably be in the low income bracket. Last but not least, the expansion may destroy prominent landmarks, such as o Id buildings of historical interest, old tree stands, arable lands, and may a Iso affect in a negative way the aesthetic value of the land as the case m ay be. 111-79 While under construction, the facility will contribute to the pollution of water, mainly through disturbances to the bottom, creating continuous high silt loads and stirring of substances which in suspended state are harmful to aquatic life. A result of these conditions will be a temporary- reduction in primary productivity due to increased turbidity. In addition, if organic-rich sediments are resuspended in the water column, the dissolved oxygen concentration in the region could be significantly reduced with resulting deleterious effects on nearby aquatic biota. Among the organisms which could suffer from the above effects are anadromous fishes whose migratory runs could be interfered with, resulting in a reduction in reproductive success. Additional pollution will be caused from the shore run-offs, which in addition to organic matter may contain toxic elements or oil leaking from earth moving equipment and other power machinery. Environmental laws and regulations establish standards for controlling or eliminating such discharges. Open hearings conducted by the U.S. Army Corps of Engineers before construction is started would disclose the methods proposed by builders to adhere to Federal, State, and local regulations. Erosion of the s horeline may be considerable unless the run-off can be controlled by installations, such as vegetative ground cover, concrete or s teel b ulkheads, a nd/or diver sion o f r un-off water through planned canalization or sewer systems during the period of construction. This will be especially pronounced in areas where sandy or clay-type soils are predominant. A certain amount of run-off can be expected as an infinite nuisance when a large land area is sealed by concrete or other man-made material instead of water-absorbing grass or root mat covering. Such run-offs can be aggravated by accidental oil spills or by dilutable substances, which may be picked up by heavy rain waters and which may be present in the area as part of materials u sed in the p rocess o f d rill rig construction. Modern shipyards built along the lines of advanced technology, equipped with modern processing machinery and progressive mechanization and automation, and equipped with the latest pollution control devices, may become competitive on the global scale affecting in this manner our balance of payment in the international market to the advantage of the entire country. Ill- 80 2. POLLUTION FROM CONSTRUCTION AND REPAIR OF DRILLING RIGS Shipyards engaged in construction of drilling rigs are located in industrial areas, generally far removed from residential areas. The shipyard facilities in which the work is done include: (1) buildings which house steel preparation and manufacturing equipment, (2) machine shop, pipe shop, sheet metal shop and others in which material that goes into the hulls is manufactured or otherwise processed; (3) outside storage space in which steel plates are stored; (4) outside plate or other steel assembly areas in which modules or small hull sections are assembled; (5) the shipway or building dock in which the hulls are erected. Part of the drilling construction process is done indoors where pollution control can be effectively practiced. The work that is done outside of buildings, in particular, erection of the hulls, presents greater problems in abating pollution. In addition, the U.S. Federal regulations on pollution control in industrial activities, State and local regulations apply to areas in which shipyards are located. A status report from the Shipbuilding/Repair Industry Shipping SubCouncil of the National Industrial Pollution Control Council (NIPCC) dated September 30, 1971, advises that while tangible improvements in environmental quality in shipyards have been made, additional steps are taken as technology in pollution control are developed and as Federal, State, and regional regulations are formulated as guidelines in the conduct of shipyard operations. Four principal types of pollution are identified with the construction of drilling rigs: air pollution, water pollution, land pollution, and noise pollution. Air Pollution The sources of air pollution fall into three types: products of combustion, airborne particulates, and airborne fumes and vapors. Products of Combustion - Combustion products from yards' boilers and incinerators, smoke from burning and welding operations, exhaust from internal combustion engines and soot from boilers contribute to air pollution. Ill- 81 To reduce pollution from these sources, the major shipyards report only- intermittent use of boilers and in some yards natural gas or low sulfur fuel is used to fire yard boilers. Use of incinerators has been discontinued in favor of having waste removed by licensed disposal firms. Smoke from burning and welding operations and internal combustion engines is generally exhausted to the atmosphere. Airborne Particulates - Dust resulting from abrasive blasting, dust created by woodworking machinery and dust due to unpaved roadway surfaces contribute to pollution from airborne particulates. The problem of airborne particulates from abrasive cleaning is the most difficult to control. The major builders of drilling rigs have installed enclosed abrasive cleaning facilities of major size for cleaning raw stock steel and modular assemblies. The September 30, 1971 NIPCC report advises that abrasive cleaning and painting of hulls on the shipways or at outfitting berths is the subject of an intensive cooperative industry study by the Environmental Control Committee of the Shipbuilders Council of America with representation from the shipbuilding, ship repair, paint, coating and steel industries. Dust collecting systems have been installed in some of the yards for collection of woodworking dust. The yards with unpaved roadways periodically oil and water the roads; however, this practice has been largely discontinued in favor of some form of paving. Airborne Fumes and Vapors - Over spray of protective coatings, evaporation of toxic chemicals and solvents, leakage of toxic or explosive gases in piping, fuel tank venting of explosive vapors, odors from sanitary facilities, and photochemically reactive hydrocarbons in paints and solvents are among the shipyard airborne fumes and vapors. The problem of painting overspray on the shipways or outfitting berths i s under study along with abrasive blasting. One major builder reports approximately 75 percent of painting is done in enclosed areas where over- spray is collected by media type filters. Airless spraying equipment is used as m uch as possible. Regularly scheduled tests are m ade in p ipelines for toxic or explosive gases. Flame arrestors and stops are installed in fuel tank vent lines. . Water Pollution The basic types of discharge that could emanate from shipyards and pollute the waterways fall into two broad categories: liquids and solids. 111-82 Liquids - Liquids include chemical make-up plus suspended solids and thermal change. Sanitary waste discharges, discharge of process chemicals, petroleum spills, overflow and leakage, overspray and spillage of protective coatings and discharge of cleaning fluids are among the liquids that contribute to water pollution. Sanitary waste discharges are disposed of through municipal sewer systems. Collection of process chemicals and cleaning fluids for removal by outside contractors i£ practiced by the major drilling rig builders. Oil spill crafts with booms and other procedures are in use to handle accidental oil spills. Paint overspray and spillage have been minimized by the use of airless spray equipment and rollers. Solids - Overboard discharge of spent abrasives, Waste and scrap materials, debris from launching ways or deteriorated waterfront structures and disposal of dredging spoils are among the solids that contribute to water pollution. Builders of drilling rigs enforce strict regulations on controlling the discharge of spent materials, i. e. , grit, rust, scale, and paint residues into the waterways. In the construction process most of the blasting is done indoors under controlled conditions. Building docks and shipways are cleaned after the blasting operation, and in some of the yards abrasive material is reclaimed. One major shipyard disposes of abrasive materials by making land fill. Overboard discharge of waste or scrap materials is against shipyard policy. Debris from launching ways is retrieved by yard water patrols. This is primarily a function of launching a ship. Disposal of dredging spoils is controlled by the Corps of Engineers through the designation of dumping sites. Solid Waste and Other Pollution Solid waste and other pollution sources include a broad variety of materials used in the various shipbuilding processes and operations. Grit, rust, scale, metal, and paint chips from abrasive cleaning of steel on shipways and outfitting berths are difficult to control. As previously noted, this problem is the subject of a cooperative industry study. Petroleum spills from fuel handling and storage and machinery operation; metallic residues from welding and brazing operations; paint residues from coating processes; solvent spills from cleaning operations; metal scraps and particles from flamecutting operations; sand and resin dust from casting III- 83 operations; and chemical spills from galvanizing all contribute to this pollution. The major drilling rig builders have installed devices and methods to abate much of the pollution from these sources. N oise Pollution The major noise pollutant sources in drilling rig construction have been identified as diesel and gas power source exhausts, high capacity vent fans, p er cussion t ools and air operated tools. The industry is combating noise through the u se of mufflers, s ilencers, equipment modifications, incorporation of noise standards in specifications for eouipment and restricted use of horns and whistles. 3. USE OF MATERIALS Drilling rigs are built primarily of steel. Steel is used in the hulls, machinery, piping and almost all the other systems. In fact, 96 percent of the rigs' w eight is composed of steel and steel a Hoy. The second most important material is copper which is used in the electrical systems, and propellers of the self-propelled rigs. The remainder of the r igs use small amounts of a large number of materials. The major producers of steel for the commercial shipbuilding industry are: C ity Lukens Steel Coatesville, Pennsylvania U.S. Steel 'American Bridge Orange, Texas Bethlehem Steel Bethlehem, Pennsylvania Bethlehem Steel Sparrows Point, Maryland Kaiser Fontana, California U.S. Steel Salt Lake City, Utah Bethlehem Steel San Francisco & San Pedro, C alifornia The geographical source of the remaining 5 to 10 percent of the material weight used is s o diverse that a detailed analysis is difficult. While not significant in weight, they represent 7 5 percent of the material cost of a drilling rig. This includes manufactured items such as: III- 84 Propulsion and Auxiliary Machinery- Shafting, Propeller Motor, Pump Pipe, Cable Deck and Drilling Machinery Electrical Installation Accommodations Ventilation (Many others) 4. REPAIR OF DRILLING RIGS The stationary and mobile drilling rigs operating in American waters are subject tor egulations of the U. S. Coast Guard, Public Health Service, Federal Communication Commission and the American Bureau of Shipping. Consequently, the rigs, subjected to normal wear and tear under operational conditions, require continuous maintenance and repair which varies to some degree from that of sea-going merchant ships. While for sea-going ships most repairs would be effected in port, minor ones at the cargo piers and major ones in the repair yards, the large drilling rigs will usually be repaired at their operational site, far away from the shore line. Only exceptionally heavy damage to underwater components that absolutely cannot be repaired afloat would force an operator to move a rig to the closest shore-based repair facility. In this event the repairs would have to be done afloat as dry- docking of these iigs due to their large size and awkard configuration would be impossible. In the case of mobile rigs such as drilling barges and shipshapes, docking would be possible, and any major repairs done to them would employ the methods used for any sea-going ship. In essence, the pollutants generated by drilling rig repairs are the same as those created in the ship repair process. These fall into the following categories: Ai r Pollution Combustion products, including internal combustion engine exhausts, welding and burning, and boiler operations; Particulates resulting from blasting and painting; Fumes and vapors resulting from evaporation of paint solvents, fuel tank venting, and refuse and sanitary odors. 111-85 Water Pollution Overboard discharges of spent chemicals, sanitary wastes, and refuse and trash. Noise Pollution Sounds of mechanical equipment in operation; Horns, whistles, etc. ; Air-operated percussion tools; Rapid expansion of gases. All three modes of pollution should b e considered o nly where t he rigs a re brought for repairs to yards while, as mentioned above, during all repairs at operational sites, far away from the shore line only the water pollution may have any detrimental effect on the environment. Because o f b etter equipment and longer- lived coating, the new drilling rigs being built under the Title XI program will not require as much maintenance and repair work as older vessels do. Problems of oil pollution of water resulting from the need to wash and gas free bunker tanks of self-propelled rigs prior to accomplishing hot work in the tank have been resolved. Shipyards collect the "slops" of tank cleaning into a barge or collection tank for disposal. No contamination of sea or harbor waters is experienced. G. PROCESSING OF OIL AND GAS I. OIL REFINING (10) Although total national oil refinery capacity has expanded relatively slowly in recent years, it is likely that capacity will grow more rapidly in the next decade. All or much of this growth will occur whether the OCS is developed or not. If the OCS is not developed, oil that could have come from the OCS will very likely be imported from abroad; and much of this oil will be brought to the U.S. in crude, rather than refined form. Hence the "base case against which environmental impacts due to OCS - induced refinery operations is rather small if not zero. Ill- 86 The environmental impact of O CS - induced new capacity might differ somewhat from the impact of new capacity to accommodate imported crude mainly because of the location of the'new capacity might be different under the two cases. In practice, however, this displacement process should not occur to any great extent. The economics of refinery siting have less to do with proximity to sources of crude than with proximity to markets for the refined products and access to transportation networks. An economically viable capacity for a new refinery presently i n t he planning stages is approaching 200,000 bbl. /day. Such a refinery requires 650 acres for all refinery facilities and storage tanks. However, 1, 200 acres is generally regarded as the minimum requirement for a new refinery site. This allows space for expansion and buffer. New refineries are expected to shift toward closed water systems and air cooling systems to reduce water requirements. Most air and water pollution loadings are not expected to present major problems for future refineries because of improved technologies for pollution control and treatment. The main areas of concern regarding refinery effluent water discharges are increases in total dissolved solids, oil, and biological oxygen demand. The primary air pollution concern is hydrocarbon emissions, which will probably continue to pose significant control problems. This is an important constraint to refinery development in areas where hydrocarbon emissions are already a problem. Electric power requirements for refineries are estimated at 6 30, 000 KWH/day per 100, 000 bbl of oil refined. 2. GAS PROCESSING (10) There is presently a great demand for gas fuels due to the shortage of natural gas supplies which has resulted in curtailment of gas deliveries under existing contracts. The capital investment r equirement for a gas processing plant is much less than that required for a refinery. Due to smaller resource requirements of land, water, and electricity and the much smaller degree of air and water pollution, there has not been much opposition to gas processing plants on environmental grounds. Natural gas once produced is sold to a transporter /distributor , but the oil company reserves the right to process the gas before it enters the distribution system. At a g as processing plant the butanes and propanes are stripped from the natural gas after the separation of oil and water has taken place. The stripping of butanes and propanes is not necessary but is desirable as propanes and butanes are in high demand and have high economic value. 111-87 OCS development in frontier areas would stimulate additional gas processing capacity" if natural gas resources could be developed into economic reserves. In a decision to site a gas processing plant, the most important factors are locating near the market, the source of production, and the distribution system. For example, in Alaska, where the market for butanes and propanes is low, plants would locate in the lower 48 States. Natural gas would be transported via pipeline to the market areas, processed, and trucked to distribution points. On the Atlantic coast, where there is a high market demand and an available distribution system but no production, significant growth of gas processing plants as a direct result of OCS development would be expected. In producing areas like the Gulf of Mexico where gas processing plants are already extensively developed, it is expected that further OCS production would replenish depleted supplies, therefore increasing capacity utilization. Given the overall importance of market location, producing areas, and proximity to the distribution (pipeline) system, the siting of gas processing plants, like that of refineries, will ultimately depend upon State and local zoning ordinances, coastal zone regulations, and air and water quality standards. 111-88 REFERENCES TO CHAPTER III 1. U. S. Department, Draft Environmental Impact Statement on the Third U. N. Law of the Sea Conference, April I, 1974. 2. Council on Environmental Quality, PCS Oil &c G as - An Environmental Assessment, Washington, D. C. , April 1974. 3. Taylor, C.C., S tatus of Completion/ Production Technology for the Gulf of Alaska and the Atlantic Coast Offshore Petroleum Operations , EXXON Company, December 5-6, 1973. 4. National Academy of Sciences, Petroleum in the Marin e Env iron- ment , Washington, D.C., 1975. 5. Bates, Charles C. and Pearson, E. , I nflux of Petroleum Hydrocarbons into the Ocean, Paper OTC 2390, 1975 Offshore Technology Conference. 6. U.S. Department of Commerce, Maritime Administration, NTIS Report No. EIS 730725F, F inal Environmental Impact Statement, Maritime Administration Tanker Construction Program , May 30, 1974. 7. Maritime Research Information Service Report, Treatment and Disposal of Vessel Sanitary Wastes - A Synthesis of Current Infor - mation , July 1971. 8. U.S. Environmental Protection Agency, Standards for Marine Sanitation Devices , Federal Register, Volume 37, Number 122, June 23, 1972. 9. U.S. Maritime Administration Standard Specifications for Merchant Ship Construction, Section 70, Pollution Abatement Systems and E quipment , May 26, 1972. 10. U.S. Department of Interior, Final Environmental Impact Statement - Pioposed Increase in Acreage to be O ffered for Oil and Gas Leasing on the Outer Continental Shelf, 197 5. 11. U.S. Army Corps of Engineers, R eport on Hurricane Camille - Report No. 1338, U.S. Army Engineers District, New Orleans, Louisiana, 1970. 111-89 12. Charter, D. B. , R. A. Sutherland, and J. D. Porricelli, Quantitative Estimates of Petroleum to the Oceans , National Academy of Sciences, National Research Council, 1973. 13. Porricelli, J. D. , V.F. Keith, and R. L. Storch, Tankers and the Ecology , Transactions of the Society of Naval Architects and Marine Engineers, Volume 79, 1971. 14. Massachusetts Institute of Technology, Oil Spill Traj e ctory Studies f or Atlantic Coast and Gulf of Al a ska - Primary Physical Impacts o f Offshore Petroleum Developments , prepared for the Council on Environmental Quality under contract No. EQC330, Report No. MITSG 74-20. 15. Straughan, D. (ed. ), Biological and Oceanographical Survey of the Santa Barbara Channel Oil Spill 1969-1971 , Volume I, Allan Hancock Foundation, 1971. 16. Foster, M.S., The Santa Barbara Oil Spill: A Review of Damage to Marine Organisms, (Prepared for the Department of Justice), 1974. 17. Moore, S. F. and R. L. Dwyer, A Prel i minary Assessment of the Envir on mental Vu Inerability of Machias Bay, Maine to Oil Super - tankers, Massachusetts Institute of Technology, Cambridge, Mass., 1972. 18. Blumer, Max, Scien tific Aspects of the Oil Spill Prob lem, Environ- mental Affair s 1:54-73. 19. Seymour, A. H. and others, Radioactivity i n the Marine Environment , National Academy of Sciences, Washington, D. C, 1971. 20. Baier, R. S. , Organic Films on Na tural Waters: Their Retrieval, Identification and Modes of Elimination, J. Geophys, Res. 77: 5062-5075, 1972. 21. U.S. Department of Interior, Draft Environmental Impact Statement - Oil and Gas Development in the Santa Barbara Channel PCS Off California, DES 75-35, 1975. 111-90 CHAPTER IV MITIGATING MEASURES NOW REQUIRED IN CONSTRUCTION AND OPERATION OF OIL AND GAS DRILLING VESSELS The mitigating measures associated with vessels engaged in offshore oil and gas drilling operations are those statutes and regulations that apply to the general construction and operation of vessels that navigate in the navigable waters and contiguous zone of the United States and those regulations that apply to vessel operations in the exploration of oil and gas. Therefore, this section will discuss those mitigating measures as well as those regulations, statutes and conventions that apply to the general concept of jurisdiction of the outer continental shelf. A. INTER NATIONAL STANDARDS 1. JURISDICTION Under the Convention on the Continental Shelf, (1) the United States has exclusive rights over its adjacent continental shelves for the purpose of exploiting their natural resources to a depth of 200 meters and beyond that to where the depth of the superjacent water "admits of the exploitation of the natural resources. " Subsequent to this Convention, the Third United Nations Conference on the Law of the Sea was convened to develop a regime for governing the oceans of the world. The first and second sessions held in Caracas, Venezuela, June 29, 1974 - August 25, 1974 and Geneva, Switzerland, March 17, 1975 - May 9, 1975, respectively did not result in the adoption of a comprehensive treaty. However, the Geneva Conference did result in the development of Informal Single Negotiating Texts. These texts were prepared by the Chairmen of the three main committees. While these Informal Single Negotiating Texts are not considered as negotiated or consensus text, they do represent a take off point for future negotiations. The texts deal with the following subject areas: Committee I Convention on the Sea-Bed and the Ocean Floor and the Sub-Soil thereof beyond the Limits of National Jurisdiction. Committee II Territorial Sea and the Contiguous Zone, Straits Used for International Navigation, Exclusive Economic Zone, Continental Shelf, High Seas ,Landlock States, Archipelagos, Islands and Enclosed and Semi-Enclosed Seas. IV -1 Committee III - Protection and Preservation of the Marine Environment. Another session of the Third U. N. Law of the Sea Conference has been scheduled for eight weeks commencing March 15, 1976, in New York at which time the Conference will try to reach a final treaty on a regime to govern the world's oceans. 2. TECHNICAL VESSEL REQUIREMENTS The Intergovernmental Maritime Consultative Organization (IMCO) at the 197 3 International Conference on Marine Pollution adopted mandatory special requirements for the control of pollution from fixed and floating drilling rigs. The major requirements are outlined as follows: As far as practicable they shall be equipped with an oil discharge monitoring and control system or with oily water separating equip- ment and an effective filtering system the effluent from which does not exceed 15 ppm of oil in water. An alarm system must also be provided to indicate when this level cannot be maintained. Sludge tanks shall be provided to receive the oily residues (sludges) that result from the purification of fuel and lubricating oils and oil leakages in machinery spaces. A record shall be kept of all operations involving oily or oil mixture discharges in a form approved by the IMCO Administration. The discharge into the sea including special areas, of oil or oily mixture shall be prohibited except when the oil content of the discharge without dilution does not exceed 15 ppm. In addition, the 1973 IMCO Marine Pollution Conference adopted regulations for the control of sewage and garbage, Annexes IV and V, respectively, of the 197 3 International Convention for the Prevention of Pollution from Ships which also apply to oil and gas drilling vessels. B. FEDERAL STANDARDS Under the Submerged Lands Act (2), state ownership of the resources beneath U.S. navigable waters, discussed later in this Chapter, is IV -2 subject to the Federal Government's reserved powers, including navigation rights and powers of regulation for security, economic, environmental, and other Federal purposes. There are a wide range of Federal regulatory 'statutes and programs that apply to the area of state resource ownership. Beyond the area of state jurisdictions the Federal Government has exclusive jurisdiction and control over the seabeds and subsoil subject to the international limitations. The major Federal statute for exercising control is the Outer Continental Shelf Lands Act. (3) In addition to making the resources of the OCS subject to Federal "control and power of disposition, ' the act extends the Constitution and Federal laws to the OCS and the productive activities upon it. Among the Federal laws so extended, of course, is the National Environmental Policy Act. (4) 1. DEPARTMENT OF THE INTERIOR Oil and gas leasing and operations in the Outer Continental Shelf outside the U.S. territorial sea are administered by the Department of the Interior (DOI) under the Outer Continental Shelf Lands Act, Titles 30 and 43 of the Code of Federal Regulations and various published OCS operating orders. Within the department, the Bureau of Land Management (BLM) administers the leasing provisions of the Outer Continental Shelf Lands Act and the U.S. Geological Survey oversees development of a tract once it has been leased and provides technical information to BLM. (a) Technic al Re quir ements A general description of operating requirements under the above mentioned regulations are as follows: Plans: Operating plans must be submitted by the operators and approved by the Geological Survey (GS) before each stage of operations is initiated (exploration, development, abandonment). Approval of all operations must be obtained prior to their commencement. . Operator Inspection and Testing: The operator is required to inspect all aspects of the safety systems at specific intervals, e. g. , daily pollution inspection on manned facilities, "frequent" inspection on unmanned facilities, monthly test of check valves. Detailed records of inspections and tests are required. IV -3 Reports: The operator is required to report all spills or leakage of oil to GS without delay. He is also required to notify GS of any unusual condition, problem or malfunction within 24 hours. Safety Devices: Required safety devices on exploratory drilling wells include well casing and cementing, blowout prevention equipment, mud programs, well control surveillance and training, and hydrogen sulfide safety programs. Waste Disposal: The lessee is prohibited from disposing into the ocean any oil (except that oil in produced formation water must average no more than 50 ppm), untreated waste material, or other materials which may be harmful to aquatic life or wildlife. Any drilling mud which may contain toxic substances must be neutralized before it can be disposed of in the ocean. Drill cuttings and sand must be processed, and oil removed, before they can be disposed of in the ocean*. Site Clearance: When an installation is no longer needed, the well is plugged with cement and all casings and piling must be severed and removed to at least 15 feet below the ocean floor and the location must be dragged to clear the site of any obstruction. Debris: Regulations and OCS Orders prohibit the disposal of debris into marine waters. Solid waste must be either incinerated or transported to shore for disposal in accordance with applicable requirements under State and Federal Law. Contingency Plans and Equipment: The operator is required to have an approved plan for controlling and removing pollution which provides for: (1) Standby pollution control equipment, including containment booms, skimming apparatus, and approved chemical dispersants immediately available to the operator at a land based location. (2) Regular inspection and maintenance of such equipment. *Waste disposals must comply with the 1972 Amendments of the Federal Water Pollution Control Act. Permits for disposals must be obtained from EPA under the National Pollutant Discharge Elimination System. IV-4 (b) Inspection Evidence of compliance with the regulations and lease requirements is obtained through surveillance of the operations under the enforce- ment of specific requirements. The inspection system of the Geological Survey (GS) includes: (I) review and approval of plans before each operating stage is initiated, (2) close review and follow-up as necessary, by GS inspectors, of all reports required of the operator by the regulations and orders, (3) on-site inspection and (4) aerial monitoring through the use of helicopters (operators are also required to inform each other of oil spills or other irregularities which they observe). Operator Reports: A comprehensive reporting system covering all oil spills and any unusual conditions (for example: reporting and investigation of a persistent oil slick from an unknown source such as a sunken ship or natural oil seep) is required by the orders and is a key factor in monitoring operations. Operators are also required to maintain records for GS inspection of required periodic tests of safety equipment. Compliance with reporting requirements can be assured only periodic on-the-site inspection and aerial monitoring. On-Site Inspection: During the course of drilling, all operations are inspected at least one time. Leases in certain areas or in a particular development stage may require more inspections to assure the achievement of safety objectives. GS is continuing the systematic inspection program and a more stringent enforce- ment policy. This has resulted in increased operator compliance and better documentation of inspection results. A complete drilling inspection is normally conducted on each drilling rig approximately every six weeks. Random inspections may be made more frequently. Depending on the number of drilling rigs in each District, the frequency of inspections on a rig may vary from six to twelve per year. . Aerial Monitoring: "Fly-overs" of the OCS operating area are programmed on a seven day per week basis by GS inspectors. Any indications of oil pollution or other non-compliance will be followed immediately by an on-site inspection. IV -5 ( c ) E nforcement The enforcement policy is intended to: (I) reduce the frequency of non-compliance with lease requirements which may lead to loss of life, loss of property, or damage to the environment; and (Z) maintain a uniform enforcement policy to be applied to all operations affecting OCS lands in the Gulf of Mexico. When, in the course of an inspection, a requirement pertaining to the prevention of oil pollution or any other safety hazard is found to be in non-compliance with regulations and lease requirements the operation will be shut-in until it is brought into compliance. After a shut-in, the operation can only be resumed by authorization of the GS; in all cases, this requires reinspection or a waiver of the inspection requirement. Minor incidents of non-compliance may require only a warning that corrections be made within a week. The operations will be shut-in if the required corrections are not made. Additional penalties for non-compliance are specific in the Outer Continental Shelf Lands Act, Sec. 5(a)(2). "Any person who knowlingly and willfully violates any rule or regulation prescribed by the Secretary for the prevention of waste, the conservation of the natural resources, or the protection of correlative rights shall be deemed guilty of a misdemeanor and punishable by a fine of not more than $2, 000 or by imprisonment . . . , and each day of violation shall be deemed to be a separate offense. " Also Sec. 5(b) (1) and (2) provides for cancellation of non-producing and producing leases by notice subject to judicial review or appropriate judicial proceedings. (d) Structures If a ship strays from established safety fairways, oil and gas platforms can pose a hazard to commercial shipping. This hazard, however, is minimized by the fact that safety fairways are clearly designated on navigation charts. Directional drilling from outside safety lanes is used to develop tracts lying partially in safety lanes. Pertinent portions of the Federal Regulations (33 CFR Sec. 209. 135 (b) ), governing shipping fairways and anchorage areas are as follows: "The Department of the Army will grant no permits for the erection of structures in the area designated as fairways, since structures located therein would constitute obstructions to navigation. The Department of the Army will grant permits for the erection of structures within an area designated as an IV -6 anchorage area, but the number of structures will be limited by spacing as follows: The center of a structure to be erected shall be not less than two (2) nautical miles from the center of any- existing structures. In a drilling or production complex, associated structures shall be as close together as practicable having the consideration for the safety factors involved. A complex of associated structures, when connected by walkways, shall be considered one structure for the purposes of spacing. A vessel fixed in place by moorings and used in conjunction with the associated structures of a drilling or production complex, shall be considered an attendant vessel and its extent shall include its moorings. When a drilling or production complex includes an attendant vessel and the complex extends more than five hundred (500) yards from the center of the complex, a structure to be erected shall be not closer than two (2) nautical miles from the near outer limit of the complex. An under- water completion installation in an anchorage area shall be considered a structure and shall be marked with a lighted buoy as approved by the United States Coast Guard. " Development of the tracts which lie partially within shipping fairways or anchorage areas if leased will be subject to Federal regulations as presented above so far as placement of structure is concerned and this would help mitigate any potential impact due to the proximity of structures to relatively high frequency sea traffic. Commercial vessels are required to report to the Coast Guard whenever a casualty results in any of the following: (a) actual physical damage to property in excess of $1, 500, (b) material damage affecting the sea- worthiness or efficiency of a vessel, (c) stranding or grounding, (d) loss of life, (e) injury causing any person to remain incapacitated for a period in excess of 72 hours; except injury to harbor workers not resulting in death and not resulting from vessel casualty or vessel equipment casualty. Drilling and production platforms (artificial islands) are required to report to the Coast Guard when involved in a casualty or accident and if any of the following occur: (a) if hit by a vessel and damage to property exceeds $1, 500, (b) damage to fixed structure exceeds $25,000, (c) material damage affecting usefulness of lifesaving or fire- fighting equipment, or (d) loss of life. Under some conditions, offshore drilling operations are an obstacle to commercial fishing activities. Depending on currents and underwater obstacles an offshore structure can remove areas of trawling and purse seining waters. Heavy concentrations of platforms can make trawling and purse seining difficult. IV -7 The erection of more structures on the OCS may affect commercial fishing operations. The impact from platforms may be kept to a minimum, however, by only allowing those structures necessary for proper development and production of the mineral resources, and by placing them with due regard to fishing operations and other competing uses which are evident at the time of platform approval. The Area Oil and Gas Supervisor considers the views of commercial fishing organizations such as the Gulf State Marine Fisheries Committee with regard to placement of platforms. The Supervisor also from time to time requests information from the Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service to be used in his decision-making process of approving or disapproving platform installation. With the constraints of location of the reservoirs and the technology necessary to drill directional wells, the Supervisor is mindful that platform location is an important consideration for commercial fisheries and does make decisions to minimize the impact of platform location on the commercial fishing industry. 2. U.S. COASTGUARD The Coast Guard is the primary agency responsible for the enforcement of federal ship safety laws as well as those pollution abatement regulations pertaining to ship-generated pollutants. To carry out these functions, that agency maintains a specialized staff throughout the U.S. and at selected overseas ports. Those officials are involved in all phases of Mobile Offshore Unit construction and operation. Coast Guard involvement in the design of a unit begins with the submission of initial plans and specifications for approval by the agency. Each unit which is required to be inspected, is periodically inspected while under construction or alteration to ensure that approved plans are being followed. Throughout the vessel's operating life, it is regularly inspected to maintain compliance with safety regulations. Rules and Regulations for Cargo and Miscellaneous Vessels, 46 CFR Sub- chapter I, Marine Engineering Regulations, 46 CFR Subchapter F and Electrical Engineering Regulations, 46 CFR Subchapter J, are the basic regulations and are generally applicable to self-propelled Mobile Offshore Units of 300 gross tons and over. Additionally these regulations are applicable to non- self propelled floating drilling units over 100 gross tons (Seagoing Barges). IV -8 The provisions of the Safety of Life at Sea Convention, I960, are applicable to floating Mobile Offshore Units if such units are self-propelled, 500 gross tons or over and engaged on international voyages. Mobile Offshore Units which drill only in the bottom bearing mode such as the "jack-up" or "submersible" type do not presently come under inspection as vessels. The Coast Guard imposes limited requirements on these units, which may be found in the Rules and Regulations for Artificial Islands and Fixed Structures on the Outer Continental Shelf, 33 CFR Sub- chapter N and the Appendix thereto pertaining to Aids to Navigation. For several years, Industrial or Special Purpose Vessels have been under discussion at IMCO. The expansion of the oil industry to all parts of the world have kindled an interest in arriving at a suitable international agree- ment regarding the Safety of Mobile Offshore Units. Nations which, hereto- fore, were only casually interested now find a need to develop national standards which would apply to units and platforms within their National Jurisdiction. The United Kingdom and Norway have published proposed regulations. Existing regulations previously described, do not provide a concise national standard from which the U.S. delegation may work. This is primarily because existing regulations are oriented to Merchant Vessels whose basic function is considerably different from the Mobile Offshore Unit. The Coast Guard has requested assistance from the National Offshore Operations Industry Advisory Committee to the Coast Guard's Marine Safety Council and an intensive effort is presently underway to develop a new regulatory package, several changes to present inspection schemes will take place. The most significant of which will be that the "jack-up" and "submersible" type units will be subject to the new vessel inspection regulations. The Coast Guard is also responsible for the implementation enforcement of those regulations which apply to general construction and operation of the vessels. In the area of pollution abatement the Coast Guard administers the regulations particularly the 1972 Amendments of the Federal Water Pollution Control Act that apply to the discharge of such pollutants as oil, sewage and hazardous materials and the 1972 Ports and Waterways Safety Act. Specifically, the Coast Guard enforces regulations that mitigate the potential for oil pollution from vessels fall into several categories: standards for design and construction, fire protection requirements, and navigating equipment necessary for safe operation. IV -9 The effectiveness of the enforcement of the pollution abatement regulation is considerably enhanced by the provision in the regulation (33 CFR 151. 20a) which permits Corps of Engineers employees, Bureau of Customs employees, and Coast Guard officers and enlisted personnel to enforce the regulations, including the swearing out of warrants and the making of arrest. 3. ENVIRONMENTAL PROTECTION AGENCY Under the Federal Water Pollution Control Act Amendments of 1970 and 1972, (5) the Environmental Protection Agency has comprehensive regulatory authority over discharges of pollutants into U.S. navigable waters, including the territorial sea, and into the high seas from U. S. point sources other than vessels. One of the major features of the Act is the National Permit Discharge Elimination System (NPDES) which prohibits the discharge of pollutants into the above waters without a permit from EPA approving this discharge. To implement this new Permit System, the Act charges EPA with publishing regulations providing "guidelines" for effluent limitations for point sources. These guidelines will provide three basic things: First, they will define "Best Practicable Control Technology Currently Available" (which are to be achieved no later than July 1, 1977) and, "Best Available Technology Economically Achievable, (which are to be achieved no later than July 1, 1983). Definitions for these two levels of effluent reduction will be developed for each and every industrial group requiring permits, including the offshore oil and gas industry. Second, they will contain the formulae for determining what "effluent limits" are to be imposed. In these guidelines, the degree of effluent reduction attainable through the application of the best practicable control and best available technology in terms of amounts of constituents and chemical, physical, and biological characteristics of pollutants, will be identified. These guidelines can then be applied in setting specific effluent limitations on discharges. Third, the guidelines will identify control measures and practices to eliminate the discharge of pollutants. IV-10 As previously stated, polluting discharges of the offshore oil and gas industry, except those associated with normal vessel operations, are encompassed within the scope of the NPDES and will therefore require permits to discharge any effluents in the waters of the U.S. In addition, under the Federal Water Pollution Control Act the Environ- mental Protection Agency has published for the "Offshore Segment of the Oil and Gas Extraction Point Source Category" Interim Final Rulemaking for effluent limitations and guidelines for existing sources to be achieved by the application of best practicable control technology currently available and proposed Effluent Limitations for Existing Sources, to be achieved by the application of best available technology economically achievable, Standards of Performance and Pretreatment Standards. Both of these Notices were published in the September 15, 1975 Federal Register (40 CFR 435). The Final Interim and Proposed Regulations set forth effluent limitations and guidelines for specific areas of sub-categories: 1. Subpart A - Near Offshore Subcategory. This Subcategory includes those offshore facilities within State waters engaged in the production, field exploration, drilling, well completions and well treatment of the oil and gas extraction industry. 2. Subpart B - Far Offshore Subcategory. This Subcategory includes those Offshore facilities with Federal Waters engaged in the production, field exploration, drilling, well completions and well treatment of the oil and gas extraction industry. These subcategories were primarily based on considerations of (I) geographic location, (2) type of facility and (3) waste water characteristics and treatment ability. The limitations published in the Final Interim regulations apply only to existing sources while the proposed regulations which will supercede the Interim regulations will apply both to existing as well as new point sources of oil and gas extraction. The comment period closed for the proposed regulations on October 15, 1975. A date has not been set for promulgation of the Final Regulations. 4. DEPARTMENT OF DEFENSE /CORPS OF ENGINEERS Within the Department of Defense, several agencies operate upon or have jurisdiction over parts of the OCS and the superjacent waters. The Army IV-ll Corps of Engineers issues permits for any use of navigable waters, including dredging and filling, which may affect navigation. The Secretary of Defense has the power, with the approval of the President, to withdraw any area of the OCS from exploration and development if there is a national defense need, although he must "avoid interference with the exploration and exploitation of mineral resources of the Outer Continental Shelf ... to the maximum extent practical". 5. DEPARTMENT OF COMMERCE ,/NOAA The Secretary of Commerce has the responsibility to administer The Federal Coastal Zone Management Act. This Act provides for Federal- state cooperation in planning for onshore and offshore development induced by OCS operations particularly with respect to the siting of pipe- lines, refineries and other facilities in the Coastal Zone. Under the Marine Protection, Research and Sanctuaries Act (7) the Secretary of Commerce has the authority to designate marine sanctuaries as far seaward as the edge of the OCS for the preservation or restoration of recreational, ecological, and esthetic values. He may issue regulations applicable within such sanctuaries, and no permit or license may be granted for an activity within a sanctuary unless he verifies that it is consistent with the act and his regulations. 6. MARITIME ADMINISTRATION In carrying out its responsibilities under the Title XI program, as described in Chapter I the Maritime Administration reviews technical plans and specifications to ensure that the vessels/rigs are in conformance with good shipbuilding practices and that these units comply with standards established by such regulatory bodies as U.S. Coast Guard, Environmental Protection Agency, American Bureau of Shipping, etc. Periodic construction inspections are conducted to ascertain that these units are actually being constructed in accordance with the approved plans and specifications. Upon completion of the construction of the unit a MarAd representative attends the Sea Trial of the vessel/rig to again ensure that all regulatory requirements and good shipping practices have been carried out. IV- 12 C. STATE JUR ISDIC TION Under the Submerged Land Act of 1953, ownership of the natural resources of lands "beneath navigable waters" of the United States is vested in the respective states. In general, the act extends "land beneath navigable waters" to 3 miles from the coast. Through subsequent litigation, however, Texas and Florida extended their resource ownership out to 9 miles within their historic boundaries (8) and in cases currently before the courts, several Atlantic states are attempting to establish ownership far beyond 9 miles. If state claims for substantially extended jurisdiction are utlimately upheld, the entire system for regulating OCS development in such areas may have to be revised. State regulatory and resource management programs would have to be expanded to an unprecedented scale and mechanisms for interstate planning and coordination devised. In light of present uncertainties, it is unlikely that significant development of contested OCS areas could commence until the courts render a final decision (9) or until the Federal Government and concerned states negotiate an interim agreement. Whatever the extent of their resource jurisdiction, the states and their political subdivisions possess important regulatory authorities within it and within related onshore areas. Through measures such as pollution control programs, land use restrictions, pipeline regulation, and zoning and building codes, states and localities can significantly shape OCS development and the construction and use of related nearshore and onshore facilities. Several states have recently enacted legislation providing for state review of development in "environmentally critical areas" and of the siting of key facilities, including powerplants and refineries. State authority over OCS-related activities may well be strengthened under existing and proposed Federal legislation. The Federal Coastal Zone Management Act of 1972 (7) provides for state development of management programs for the coastal zone (extending 3 miles from the coast). Once the Secretary of Commerce approves a state program, no Federal license or permit may be granted for any activity (without territorial limitation) which affects the state coastal zone unless the state agrees that the activity is consistent with its management program. In addition, the Congress is currently considering broader land use legislation that would foster state planning and regulatory capabilities concerning major land use decisions beyond the coastal zone. IV- 13 D. STATE -FEDERAL An urgent need for effective Federal- state coordination follows from two related facts. First, as noted by Robert R. Jordon, State Geologist of Delaware, "geologic boundaries and exploration and production activities that are dictated by geological conditions do not respect political boundaries. " (11) Effective regulation of OCS production and related activities therefore requires concerted action at all levels of government. Second, OCS decisions at one level of government substantially impact upon the interest and activities at other levels. In particular, Federal decisions concerning the OCS will vitally affect what New York Attorney Louis J. Lefkowitz termed the states' "paramount" interest in protecting "fisheries, harbors, coastal wetlands, beaches and other natural resources from the devastating and lasting damage inflicted by oil spills, " (12) as well as their economic and social interests. To date over 90 percent of U. S. OCS oil production has occurred off the coast of a single state -- Louisiana. The possibility of significant production in other regions underscores the need to develop mechanisms for coordinating the legitimate interests and concerns of affected states. As stated in the CEQ report (13) on the Outer Continental Shelf ". . . comprehensive planning is essential for rational and environmentally sound OCS development and state participation in such planning is an effective way to ensure adequate accommodation of state interests. " The Council on Environmental Quality recommended in its report (13) that the state coastal zone management agencies and concerned Federal agencies jointly participate in developing these portions of the plans. Before approving state coastal zone management program s, the Secretary of Commerce should require the state plans to consider refineries, transfer and conversion facilities, pipelines, and other development within the coastal zone related to OCS operations. Under the statute, the plans must provide "adequate consideration of the national interest involved in the siting of facilities necessary to meet requirements which are other than local in nature. " At the same time they should provide adequate consideration of the full range of state interests in the coastal zone. Because a decision to develop an OCS area may predetermine important decisions concerning uses of the contiguous coastal zone, states should IV -14 give high priority to completing their plans prior to leasing of OCS tracts for development. The Department of the Interior, in its leasing functions, and the state governments, in exercising their limited veto rights for activities inconsistent with their coastal zone programs, would implement the agreements reflected in the plans. E. STAT E AND REGIONAL REGULATIONS As has been indicated previously in this Chapter, there are both national and international regulations which limit the flexibility a private operator has in constructing offshore drilling rigs. These are designed to maximize environmental and safety conditions, yet preserve the economic viability of the vessels vis-a-vis their foreign counterparts. Offshore drillings rigs are also subject to state and/or regional control in their construction and operation, within certain areas. Coastal states exercise almost exclusive jurisdiction over the territorial seas of the U.S. and the submerged land (43 U.S.C. Section 1311). While this jurisdiction is concurrent in areas of navigational safety and in some areas of environmental control, it is clear that if a State desires to limit the amount of drilling that may be conducted within its jurisdiction, a permit system may be set up somewhat similar to the leasing system for the Outer Continental Shelf (see Section IV-B). Further, as part of its coastal management programs, established under the Coastal Zone Management Act of 1972, particular areas within a state's jurisdiction can be set forth as non-available for drilling operations, if such a decision is based on a rational and balanced decision-making process. Already, Delaware has enacted legislation prohibiting the construction of offshore deepwater ports within its jurisdiction. Regional control can be exercised through regional recommendations, 'which are implemented as laws or regulations by the various member states. As an indication of a states power to regulate with respect to pollution control, a recent case before the Supreme Court found that the provisions of the Federal Water Pollution Control Act of 1972 were not exclusive or preemptive on the States, and that State regulations going beyond the Act's provisions could be enforced within the State's jurisdiction ( Askew v. Amer ican Waterways Operators , 1973, 411 U.S. 325, 93 ct. 1590(1973). F. NATIONA L CONTINGENCY PLAN FOR CONTR OLLING OIL SPI LLS The National Oil and Hazardous Substances Pollution Contingency Plan developed in compliance with the Federal Water Pollution Control Act IV -15 provides a mechanism for coordinating the response to an oil discharge in U.S. waters, shoreface, or shelf-bottom. The objectives of this plan are to provide for efficient, coordinated, and effective action to minimize damage from oil, including containment, disposal, and removal. The plan provides for: assignment of duties and responsibility among Federal departments and agencies in coordination with State and local agencies; identification, procurement, maintenance and storage of equipment and supplies; -" establishment or designation of a strike force to provide necessary- services to carry out the plan and establishment, at major ports, of trained and equipped emergency task forces; a system of surveillance and reporting designed to insure the earliest possible notice of discharge of oil and hazardous substances to the appropriate Federal agency; establishment of a national center to provide coordination and direction for operation in carrying out the plan; procedures and techniques to be employed in identifying, containing, dispersing, and removing oil and hazardous substances; a schedule, prepared in cooperation with the States, identifying dispersants and other chemicals, if any, that may be used in carrying out the plan; and a system whereby the State or States affected by a discharge may be reimbursed for reasonable costs incurred in the removal of such discharge. The EPA and the U.S. Coast Guard furnish the Chairman and Vice Chairman of the National Response Team (NRT). The U.S. Coast Guard supplies support and expertise in the domestic /international fields of port safety and and security, marine law enforcement, navigation, construction, manning operations, and safety of vessels and marine facilities. The Department of Commerce is a Primary member of the NRT and provides support through NOAA to the National and Regional Response Teams with respect to marine environmental data living marine resources current and predicted meteoro- logical, hydrological and oceanographical conditions for the high seas, coastal, and inland waters and maps and charts, including tides and currents IV -16 for coastal and territorial waters and the Great Lakes. When requested by the NRT, MarAd will provide advice on the design, construction and operation of merchant ships. Any response required as a result of operations conducted under the Outer Continental Shelf Lands Act are carried out in accordance with a Memorandum of Understanding between the Department of Transportation and the Department of the Interior. The Council on Environmental Quality is responsible for the preparation, publication, and revision of the National Contingency Plan. The current National Contingency Plan now in force has been revised as of February 10, 1975. G. ABS RUL ES FOR BUIL DING AND CLA SS ING OFFSHO R E MOBILE DRILLING UNI TS, 1973 The American Bureau of Shipping's "Rules for Building and Classing Offshore Mobile Drilling Units" was first published in 1968 as a result of the combined efforts of industry experts, the U.S. Coast Guard, and the Bureau's Technical Staff. These Rules were revised and updated in 1973 to reflect new design innovations, data gathered from service experience, and the expansion of offshore drilling exploration into areas of new and varied environmental conditions. These Rules focus on the three basic categories of mobile drilling units commonly in use at present: the surface type (ship and barge) the self elevating type (jack-up) the column stabilized type (submersible and semi- submersible) Each design possesses its own unique design requirements. In addition, the Rules provide for the calssification of units of a novel configuration not specifically falling into one of these categories, or possibly combining the characteristics of two or more of the above types. In this case, all the applicable requirements of the Rules would be utilized, in conjunction with the best engineering practice currently available. The ABS Rules for drilling units are intended to apply to the hull structure, the main propulsion machinery, and the essential auxiliary equipment IV -17 necessary for the safe operation of the unit. Each design is reviewed by- Surveyors of the Bureau's Technical' Staff for compliance with requirements of the Rules with regard to: Structural adequacy of the unit for the design parameters specified by the designer. Use of appropriate materials and welding techniques. Intact and damage stability. Essential machinery, piping, and electrical systems. Emergency mooring equipment. Essential safety features such as fire-fighting equipment life- saving appliances, guard rails, alarms, and the ventilation and electrical installations in restricted areas. In addition, an operating booklet is required to be prepared for each unit as a condition of Classification and to the satisfaction of the Bureau. The booklet is to contain the following information, as applicable to the particular unit. General description of the unit, including experiment results, light ship data, etc. Pertinent data for each operating condition, including design loading, wave height, bottom condition, draft, etc. General arrangement showing watertight compartments, closures, vents, permanent ballast, allowable deck loadings, etc. Hydrostatic curves or equivalents. Capacity plan showing capacities of tanks, centers of gravity free surface corrections, etc. Instructions for operation of the unit including adverse weather, changing modes of operation, any inherent limitations of operations, etc. IV- II StabiLity information in the form of maximum KG versus draft curve or other suitable parameters based upon compliance with the required intact and damaged stability criteria. Representative examples of loading conditions for each mode of operation together with means for evaluation of other loading conditions. It is required that Surveyors to the Bureau verify compliance to material specifications and attend the fabrication of the unit's essential equipment at the place of manufacture. A Surveyor will also attend the construction of the unit and the installation of its equipment. To maintain the drilling unit in classification after construction, periodic surveys are required to ensure that the unit is kept in good operating condition. This examination of the unit's soundness also provides a valuable feedback mechanism as to its performance while in service. It bhould be noted that systems and equipment used solely for the performance of drilling operations are not considered as part of the classification, other than the effect they have on the loading of the structure. An exception to this pertains to requirements concerning the elimination of ignition sources and the ventilation in restricted areas where an explosive atmosphere may exist due to the nature of the operation. Although the Rules, as originally promulgated, were intended to apply primarily to offshore mobile drilling units, there has recently been a trend towards utilizing the advantageous characteristics of these vessels in the design of structures of varied functions, i. e. , oil production and power generating facilities, etc. Due to similarities in structural configuration and mode of operation, these structures can be reviewed in accordance with the applicable requirements of the ABS "Rules for Building and Classing Offshore Mobile Drilling Units. " Full compliance to the standards set forth in these Rules should ensure a structurally sound and seaworthy base structure. This, of course, is an essential prerequisite to minimizing the effect of offshore exploration and exploitation upon the environment. It should be borne in mind that requirements in excess of or additional to those specified in the Rules of the American Bureau of Shipping, may be specified by International Organizations, the Government Authorities IV -19 under which the vessel is registered, and those having jurisdiction over the area in which the vessel is to operate. In this regard, the International Association of Classification Societies is currently developing unified requirements for mobile drilling units, including strength and design parameters, requirements for machinery and electrical installations and stability. It is hoped that drilling units built in accordance with such requirements would be acceptable to many governments for operation in waters under their jurisdiction, with a minimum of modification to suit individual governmental requirements when changing from one location to another. H. OFFSHORE OP ERATO RS COMMITTEE History has recorded that drilling for oil and gas did not have its beginning in offshore waters. However, the petroleum industry has made remarkable technical progress since 1897 when the first offshore platform was erected off Santa Barbara. In 1945 the first offshore well in the Gulf of Mexico was drilled from a structure made of wood, using a converted land rig supported by a tender. The oil operators did not take long to realize the tremendous potential that offshore waters offered. In 1948, the Offshore Operators Committee was formed; however, "By Laws" were not written until 1952. This committee was open to any company who was a lease holder in the Gulf of Mexico. The purpose of the committee was to exchange information and to solve common problems encountered in offshore drilling and producing. The "By Laws" have been amended twice since the original writing. One of these amendments opened the committee doors for the associate member, namely those involved in offshore drilling in the Gulf of Mexico. This group includes the drilling contractor, the service company, the supplier, and others involved in this offshore activity. The Offshore Operators Committee recognized that these associate members were vitally concerned and involved; that they have vast amounts of technical knowledge and operating expertise to offer the industry. The Offshore Committee realized that one of its primary tasks was to prepare a "Safe Practice Manual. " This "Manual of Safe Practices in Offshore Operations" was the joint effort on the part of members of the International Association of Drilling Contractors, the Offshore Operators Committee, the National Offshore Operations Industry Advisory Committee, the Commandant U.S. Coast Guard, and the Western Oil & Gas Association. IV- 20 The latest revision (second) is dated January I, 1972. It should not be implied that prior to going offshore for the search for oil and gas the drilling industry did not provide collective ways for the education of its employees. From the early days, it did not take the industry long to recognize the need for education at all levels. The drilling industry developed a comprehensive program for training its personnel. Assistance in this training program was given by univer sities, ' trade publications and others. IV-21 REFERENCES TO CHAPTER IV 1. U.N. DOC. /A/CONF. 13/L. 55, June 10, 1965. 2. 43 U.S.C. g 1301-15 (1953). 3. 43 U.S.C. §§ 1331 et seq. 4. 42 U.S.C. §§4321-4347(1969) 5. P. Lr. 92-500. 6. 32 CFR § 252 4 (a) and (e). 7. P. L. 92-532. 8. See United States v. L ouisian a; 363 U.S. 1 (1960), rehearing denied, 364 U.S. 856 (I960); Un ited Stat es v. Florid a, 363 U.S. 21 (1960). 9. Mineola public hearings, infra note 11. 10. See University of Oklahoma Technology Assessment Group, Ene r gy U nder the Oceans (Norman: University of Oklahoma Press, 1973), p. 209. 11. Statement at public hearings conducted by the Council on Environ- mental Quality, Ocean City, October 12, 1973. 12. Statement at public hearings conducted by the Council on Environ- mental Quality, Mineola, Long Island, N. Y. , October 12, 1973. 13. Statement at public hearings conducted by the Council on Environ- mental Quality, "OCS Oil and Gas - An Environmental Assessment. IV-22 CHAPTER V ALTERNATIVES TO THE TITLE XI OFFSHORE OIL AND GAS DRILLING PROGRAM A. ALTERNATIVES TO OFFSHORE DEVELOPMENT IN GENERAL The foundation for the MarAd Program is continuation and acceleration of the government's program for leasing offshore lands for development. Offshore oil and gas rights are controlled primarily by the Federal government and to a lesser extent by the states. If the offshore leasing program were terminated there would be little demand for program vessels., The present governmental policy is to accelerate leasing as part of the nation's program to increase domestic energy sources. This policy has stimulated a demand for offshore drilling and service vessels to which the Maritime Administration has responded. The government could review the decisions it has taken to encourage the development of offshore resources and develop other alternatives of energy. While these are not alternatives to the MarAd Program, they are alternatives to the larger program which is supported to some extent by this agency's program. These alternatives include some near-term alternatives such as: Increased conventional onshore production of oil and gas Development of Synthetic Sources of oil and gas Importation of Oil and Gas Development of Coal, Nuclear Power, and Hydroelectric Power. Other less conventional and longer term alternatives could include: Oil shale and tar sand development Solar energy Wind energy Tidal energy Geothermal energy and other more sophisticated sources of power. Finally, our nation's energy problem could be solved through conservation of energy or by using a combination of the above mentioned approaches. As indicated, these alternatives are not available to the Maritime Admini- stration and, for the most part, would require extensive and far-reaching V-l actions on the part of the White House and the Congress. The Department of the Interior analysis entitled, "Energy Alternatives and their Related Environmental Impacts, " _' examines all of these alternatives as follows: I. Energy Conservation Vigorous energy conservation is an alternative that warrants serious consideration. The Project Independence Report of the Federal Energy Administration claims that energy conservation aline can reduce energy demand growth of 0. 7 to I. 2 percent depending on the world price of oil. Aside from these savings, it is now widely recognized that wasteful consumption habits impose social costs such as pollution and an inequitable distribution of fuel, that can no longer be afforded. The residential and commercial sectors of the economy are often characterized as inefficient energy consumers. Inadequate insulation, inefficient heating and cooling systems, poorly designed applicance and excessive lighting are often noticed in these sectors. To achieve reductions in consumption beyond those induced by fuel price increases could require new standards on products and buildings, and/or subsidies and incentives. These incentives could impose standards for improved thermal efficiency in existing homes and offices and minimum thermal standards for new homes and offices. Excessive consumption is also evident in the industrial sector where energy inefficient work schedules, poorly maintained equipment, use of equipment with extremely low heat transfer efficiencies, and failure to recycle heat and waste materials are all common place. Estimated energy savings of between 10 and 30 percent may be available in this sector of the economy. Transportation of people and goods accounts for approximately 25 percent of nationwide energy use. Energy inefficiency in the transportation sector varies directly with automobile usage. Automobiles, which account for 90 percent of all passenger movement in the nation, use more than twice as much energy per passenger mile as buses. Moreover, the average car carries only 1. 3 passengers. Using short and 'mid-term conservation measures such as consumer education, lower speed limits rate and service improve- ments on public transit and rail freight transit, energy savings of 15-25 percent might be possible. Other policies to encourage fuel conservation in transportation could include standards for more efficient new autos and incentives to reduce miles traveled. An important new development in the fuel economy area could j_' Abstracted from DOI Final Environmental Impact Statement - Proposed 1975 Outer Continental Shelf Oil and Gas Lease Sale Offshore Central Gulf OCS Sale No. 38. V-2 be the modifications of the standard internal combustion engine developed by two Vermont engineers. Their modified engine may be able to improve fuel economy of automobiles by an average of 50 percent with no loss in power. Significant energy savings are clearly possible through accelerated conservation efforts. The Project Independence Report estimates that conservation alone could result in a Z. Z million barrel per day reduction in petroleum demand by 1985. These savings will be necessary in order to achieve the goals of energy self-sufficiency. Z. Conventional Oil Supplies Large quantities of oil still remain in the United States. The U.S. Geological Survey estimates that undiscovered recoverable resources of 135-Z70 billion barrels of oil are located onshore. This figure, however, is an estimate of the nation's total petroleum resource base and is not an indication of the oil supply that will be available for future consumption. The term "proved reserves" refers to those volumes of petroleum liquids that are known from drilling and are economically producible at current prices with current levels of technology. The Project Independence Report uses the American Petroleum Institute's latest (January 1, 1974) annual figure on proved reserves, 35. 3 billion barrels. In addition to these reserves, T. A. Hendricks, W. C. Mallory, and associates of the USGS claim that an additional Z5 to 45 billion barrels of petroleum liquids could be added to proved reserves through extensions, revisions, and discoveries of new pools in known fields. Despite the magnitude of the proved reserve estimate, domestic oil production is almost certain to continue its decline fromlhe peak production rate attained in 1970. All of the 1Z oil production forecasts discussed in the Project Independence Blue print claimed that, in the next few years, the petroleum production decline would continue in the United States. Most of these same forecasts predict increasing domestic production by the late 1970's but only under the most favorable conditions in terms of prices, regulations, and environmental constraints. 3. Increased Domestic Gas Supplies a. Deregulation of the Wellhead Price of Natural Gas The regulated price of natural gas has often been cited as an important cause of the meager supply of domestic gas. Eliminating the price ceiling on natural gas may have an inflationary impact though it would encourage V-3 development of native gas reserves and thus help reduce foreign dependence. With regard to the inflation issue, the lack of natural gas supplies causes increased consumption of expensive alternatives; the average price of natural gas after deregulation may well be less than these alternative supplies. In any case, domestic supplies of natural gas have to exist and have to be accessible. The OCS is believed to be one of the most propitious areas for natural gas development. b. Nuclear Stimulation of Gas Formations Nuclear stimulation, an experimental method of manufacturing low permeability gas reservoirs otherwise incapable of sustaining commercial production, has the potential to add materially to U.S. recoverable gas reserves. The Atomic Energy Commission is conducting research and development of nuclear explosives and techniques for utilizing the effects of miltiple nuclear explosives to recover natural gas locked in tight geologic formations. Such gas cannot now be produced economically by conventional methods. Most reserves which are amenable to nuclear stimulation lie in thick, deep reservoirs of very low natural permeability located in the Rocky Mountain area. The Federal Power Commission has estimated that total yearly gas production by 1985 from the Uinta, Piceance, and Green River Basin fields using nuclear stimulation from 110 to 200 wells would be 812 to 1, 939 billion cubic feet. LI Environmental effects of nuclear stimulation to increase natural gas production from tight reservoirs are related to radioactivity and seismic disturbance, both of which concern the surface or subsurface, leaving atmospheric contamination or disturbance unlikely. The depth of the gas formations of interest throughout the Rocky Mountain area is such that the probability of releasing any appreciable amounts of radiation to the atmosphere at detonation time is considered negligible. Most of the radioactivity produced by the explosives will remain underground, trapped in the resolidified rock near the bottom of the chimney or attached to the rock surfaces in the chimney. Project design would consider mobile waters and assure that chimneys remain isolated from them. Methods are being developed to dispose of water produced with the gas and containing low levels of tritium. The potential environmental impacts of nuclear stimulation of a single well or several wells in small geographic areas have been evaluated by the AEC, I Federal Power Commission, April 1973, Natural Gas Technology Task Force for the Technical Advisory Committee of the Natural Gas Survey by the Federal Power Commission, p. II- 7. V-4 for example, for the Rio Blanco and Wagon Wheel Projects. The impacts of more extensive development depends on the frequency and size of explosives and changes in the local environment. The possibility that residual stress from a number of detonations might accumulate and present an earthquake stimulation hazard requires continued appraisal during future nuclear stimulation projects. 4. Coal Coal is the most abundant energy resource in the United States. Coal deposits underlying nearly 460,000 square miles in 37 states constitute one-quarter of the known world supply and account for 80 percent of our proven fuel reserves. Proven reserves of coal contain 125 times the energy consumed in 1970. In many uses, coal is an imperfect substitute for oil or natural gas. In many cases, coal use is restricted by government constraints, limited availability of low sulfur deposits, inadequate mining, conversion and pollution abatement technology, and the hazardous environmental impacts associated with coal extraction and coal-generated electricity. Coal production is also threatened by a unique set of labor problems associated with mining and new strict standards for coal mine safety. As with other extractable hydrocarbons, the quantity of available coal is a function of coal's market price. At the 1972 price, for instance, only 12 percent of the total resource could be considered recoverable. At double this price, the amount of recoverable coal would be equivalent to 2 1/2 times the anticipated aggregate energy demand for the U.S. between I960 and 2000. Current increases in the market price for coal are making more of the resource base available for domestic consumption. Public concern over dangerous underground mine conditions inspired the Federal Coal Mining Health and Safety Act of 1969. This legislation has improved underground mining conditions and therefore has reduced the occupational hazards confronted by many coal mines. This Act has also increased the costs of underground coal mining - an important side effect since most of the nation's coal reserves can be recovered only by under- ground mining. Additionally, the Mining Health and Safety Act has added to strip mining's long established competitive advantage over underground mining since strip mining is far less hazardous than underground mining and is thus subject to fewer of the Act's provisions and regulations. V-5 The advent of new, strict air quality regulations has diminished the attractiveness of coal. One-third of the domestic coal reserve does not meet the low-sulfur requirement. The two-thirds of this reserve that is environmentally acceptable is located mainly in the Rocky Mountain States and is generally of lower Btu value than eastern coals. The cost of transporting Rocky Mountain coal to population centers of the eastern or western United States adds significantly to its price, putting much of it at a competitive disadvantage with other energy sources. 5. Synthetic Sources of Oil and Gas a.. Oil Shale The nation's vast oil shale resources have not in the past been considered as part of the domestic energy supply because of the ready availability of low cost oil and gas. Current needs, however, may necessitate rapid exploration of this fossil fuel. Oil shale can be processed after its extraction using a surface technique, or, in place processing can be conducted. As with coal, oil shale may be extracted using underground or surface (i. e. , strip mining) mining techniques, The Green River Formation covering parts of Colorado, Utah and Wyoming contains the most abundant concentration of oil shale in the nation. Approx- imately 600 billion barrels of oil are believed to be deposited in this location. Oil shale development does pose serious environmental risks however. With surface or conventional underground mining, it is very difficult to dispose of the huge quantities of spent shale which occupy a larger volume than before the oil was extracted. Inducing revegetation in an area where oil shale has been developed is a difficult task often taking in excess of ten . years. The in-place processing alternative avoids many of these environ- mental hazards but disturbance of underground aquifers and contamination of ground waters are side-effects of both development techniques. Commercial development of the Green River Formation would require significant quantities of water. Yet the Colorado Utah-Wyoming area is low on water supplies. Hence, another obstacle to oil shale development is posed. The list of impediments does not end here. The Green River Formation is sparsely settled. Oil shale development will cause major changes in existing land uses and thus have social and economic repurcussions in an V-6 area traditionally devoid of a large scale industry. In that the Colorado oil shale lands have some of the largest migratory deer and elk herds in the world, impacts on the regional wildlife are expected. Roads, mining plant sites, waste disposal areas, and utility line corridors will disrupt the land's vegetative cover and intensify sediment loads in the area's streams. Disposing the hugh volume of waste water containing dissolved inorganic and organic compounds without degrading natural ground waters will severely strain the region's already scarce water resources. Oil shale mining will raise noise pollution levels and the attendant particulate emissions will lower ambient air quality. b. Synthetic Natural Gas and Oil Liquifying and gasifying coal in commercial quantities is another target of current energy research. Synthetic oil is the end product of coal liquefaction while gasification produces synthetic natural gas. Of the two methods, researchers have devoted more effort to gasification because of the high cost encountered in producing synthetic oil. Natural gas can also be synthesized from petroleum. Such gas has been produced commercially in Europe and some forty plants are planned for the United States. High costs and the elementary level of technology have impeded synthetic natural gas and oil development. Pilot plants have been operating domestically but commercial production levels have not been achieved. The role of synthetic natural gas and oil in the nation's future energy supply will depend on environmental standards, the effects of new health and safety standards on coal mining, and the availability of water. Several environmental problems are associated with coal gasification and liquefaction. The ecological side-effects of extracting coal is a major problem because coal is the raw material for either process. Moreover, these processes cause water, air, and noise pollution. According to Dr. Thomas A. Henri (Bureau of Mines, USDI), a typical coal gasification plant will produce 250 million cf/d of pipeline gas, consume six to 10 million tons of coal annually, use about 6, 000 gallons of water per minute, and have capital costs (including coal mine development) of over $400 million. V-7 6. Hydroelectric Power The energy captured from falling watei* 'is termed hydropower. Thi« falling water, regulated and controlled by human technology, is used to drive turbines and thus produce electrical energy. The engineering problems of converting hydropower to electrical energy were mastered early in the development of electrical generation technology and many of the major hydroelectric sites operating today were developed in the early I950's. The Pacific Northwest region and California are served by hydroelectric power to a greater extent than most other regions of the nation because of the wet climate and favorable topography. Theor ectically, increased domestic reliance on hydropower is currently possible. The undeveloped potential for hydroelectric generation in the lower 48 States alone is about 94,000 MW (FPC, 1972). If that potential were developed fully then hydropower could supply nearly 8 percent of the current domestic energy demand, (FPC, 1972). Yet most energy supply forecasts envision a relative decline in hydropower 's future contribution to domestic energy needs. This paradox stems from the following conditions: 1. The sites with the greatest productive capacity and the lowest development costs have already been exploited. 2. Hydroelectric power imposes substantial land use conflicts and environmental side-effects. 3. The dams and reservoirs required by hydropower development have exorbitant capital costs. 4. The amount of energy that can be produced via hydropower varies with the seasons. 5. Manipulation of reservoir storage capacity is constrained by water use and flood control considerations. As a consequence of the above factors, an important future application will be "pumped storage" hydroelectric projects. Pumped storage uses the excess energy generated by nuclear or fossil fuel plants to pump water from a lower reservoir to a higher one. During periods of peak electricity use, the previously pumped water is allowed to fall from the upper reservoir thus producing the electricity required during the period of elevated demand. Pumped storage has at least 2 advantages: V-8 1. It utilizes the excess energy of conventional electricity plants and thus improves their efficiency. 2. It makes available the most economical supply of peak quantities of electricity during periods of accelerated demand. Construction of a hydroelectric dam represents an irreversible commitment of the land resources beneath the dam and lake. Flooding eliminates wild- life habitat and prevents other uses such as agriculture, mining, and free- flowing river recreation. Hydroelectric projects do not consume fuel and do not cause air pollution. However, use of streams for power may displace recreational and other uses. Water released from reservoirs during summer months may change ambient water temperature and lower the oxygen content of the river down- stream, adversely affecting indigenous fish. Fluctuating reservoir releases during peak load operation may also adversely affect fisheries and down- stream recreation. Fish may die from gas-bubble disease if exposed to nitrogen supersaturated water. Nitrogen super saturation results at a dam when excess water escapes from the draining reservoir. High nitrogen levels in the Columbia and Snake Rivers pose a threat to the salmon and steelhead resources of these rivers. 7. Nuclear Power The predominant nuclear system used in the U.S. is the uranium dioxide fueled, light water moderated and cooled nuclear power plant. Research and development is being directed toward other types of reactors, notably the breeder reactor and fusion reactors. Installed nuclear capacity, as of June 1974, was 28, 000 MW. At that time, nuclear power generated about 6 percent of the Nation's electricity. However, about half of the electric power capacity now under construction is nuclear powered. Nuclear power development has encountered delays in licensing and siting, environmental constraints, and manufacturing and technical problems. Future capacity will be influenced by the availability of plant sites, plant licensing considerations, environmental factors, nuclear fuel costs, rate of development of the breeder and fusion reactors, and capital costs. In order to meet future uranium requirements, an increase in exploratory drilling activity will be necessary. V-9 Although nuclear plants do not emit particulates or gaseous pollutants from combustion, serious environmental problems arise. Some radio- activity in the form of radiation, airborne radioactivity, and radioactive liquids, is released to the environment. Although the amount released is very small and potential exposure has been shown to be less than the average background level of natural radiation, special precautions are in effect to control these emissions. The possible release of radioactivity as a result of an accident must be anticipated and the plants are designed to withstand a design basis accident. This is defined as the worst malfunction considered to have a probability of occurrence high enough to warrent corrective action. The probability of a serious nuclear accident occurring in any one of the nuclear generators in an existing generator population is believed to exceed the risk associated with a single nuclear plant when evaluated separately. A report issued recently by the AEC discusses the probability of accident risks in U. S. commercial nuclear power plants (WASH- 1400). Nuclear plants use essentially the same cooling process as fossil-fuel plants and thus share the problem of heat dissipation from cooling water. However, light-water reactors require larger amounts of cooling water and discharge greater amounts of waste heat to the water than comparably sized fossil-fuel plants. The effects of thermal discharges may be beneficial in some cases. Adverse effects can be mitigated by use of cooling ponds or cooling towers. Low level radioactive wastes from normal operation of a nuclear plant must be collected, placed in protective containers, and shipped to a storage site and buried. High level wastes remaining after fuel processing are concentrated and stored in solution. Presently these are being stored in the fuel reprocessing plants and in the future will be solidified and shipped to a Federal repository for storage. 8. Solar Energy Energy from the sun can be used to heat or cool individual buildings and to generate electricity. In the 1940' s and 1950's, prior to the availability of low cost natural gas, firms selling solar water heaters did a booming business in California and Florida. Commercially installed solar heating and cooling in homes will be in use in many parts of the nation by 1985 and will be common by 1993. Moreover, intensifying current research and development could hasten these dates by five years. Solar energy may eventually supply 35 to 50 percent of the nearly 20 percent of the nation's V-10 energy that is now devoted to space conditioning, thus reducing significantly the peak electricity demands of the summer months. Congressional interest in solar energy research has recently been aroused. The Solar Heating and Cooling Demonstration Act of 1974 legislates a $60 million demonstration program aimed at proving the commercial feasibility of solar heating of buildings and homes by 1977 and of combined solar heating and cooling systems for those structures by 1979. Although fuel costs for backup systems and maintenance costs for solar units are miniscule when compared with operating costs of conventional heating and cooling systems, the initial or "fixed" costs of solar units are too high to make them immediately competitive. The typical solar heating system for a home costs $5, 000 - $6, 000 (including costs of a standby conventional furnace) compared to $1,000 - $2,000 for a conventional fossil-fuel home heating unit. However, the rising cost of the gas and oil needed by the conventional heaters means that the initial difference in fixed costs will quickly be overshadowed by the solar systems' lack of fuel costs. Therefore, though more costly at first, the solar unit will be the economical alternative over time. The full potential of solar energy can be realized only after large-scale generation of electricity using solar energy becomes technically and economically feasible. For this reason the Government has requested $33 million for solar electric programs in fiscal 1975 - almost $26 million more than the fiscal 1974 appropriation. A number of technical and engineering problems now prevent commercialization of solar steam- electric plants though pilot projects are well underway. It is estimated that by 1985 solar electricity will provide 0.3 - 0. 6 quadrillion Btu's of space heating annually. Solar-electric energy does have a few disadvantageous aspects -- high capital costs, expensive maintenance of solar collectors, thermal waste disposal, and distortion of local thermal balances being the most prominent. Yet the engineering and technical problems that have not yet been solved are considerably less difficult than those for fission breeders or fusion reactors. The accelerating real costs of fossil fuel plus the serious implications of substantial foreign dependence will continue to increase the attractiveness of the solar energy option. Finally, the environmental impacts of solar energy are significantly less severe than those imposed by the traditional energy sources. V-ll Solar energy cannot substitute for petroleum in all uses, transportation and petrochemicals being the most obvious illustrations. However, as solar energy is used with increasing frequency for heating and electricity generating purposes, oil and gas supplies previously devoted to heating and electricity will be channelled to the petrochemical and transportation industries. Thus solar energy's somewhat restricted applicability, does not constitute a significant disadvantage. 9. Energy Imports a. Oil Increasing this nation's reliance on foreign energy supplies is another alternative to offshore development. Such an action would, however, entail a very high cost. U.S. imports of petroleum in 1973 amounted to 2. 264 billion barrels. At current world oil prices, this quantity of oil would carry a $23 billion price tag. Studies conducted by the Department of the Interior show that oil produced on the OCS of the United States is much cheaper than the foreign alternative. Extraction plus transportation costs for OCS oil are anywhere from $6. 50 - $8. 00 per barrel less than the world oil price. The table on the following page shows projected patterns of import reliance for the next ten years. The sources of oil imports in 1970 is also presented as a comparison. These projections assume an energy growth rate of about 3. 5% plus an expanded role for the OCS in domestic production. V-12 U. S. PETROLEUM SUPPLY -DEMAND AND SOURCE OF OIL IMPORTS (Thousand Barrels per Day) Domestic Demand U.S. Production North Slope Crude Total Imports Source of Imports: From Canada (pipeline) Total Waterbome Imports From Western Hemisphere From Europe Total in small tanker 1970 14, 728 11, 328 3,418 1975 18, 400 10, 800 7, 600 1980 22, 790 10, 500 1, 500 10,790 1985 26, 885 9,725 2, 000 15, 160 766 I, 300 1,800 2, 200 2, 652 6, 300 8,990 12, 960 2,091 3, 200 3, 280 4, 106 177 200 300 400 2, 268 3,400 3, 580 4, 506 From Middle East From S. E. Asia From Africa Possible for large tankers 185 2, 325 4, 610 7, 354 72 175 100 100 127 400 700 I, 000 384 2, 900 5,410 8,454 If the above projections do prove accurate and if current world oil prices are maintained through 1985 then our oil bill will be about $150 million daily or about $55 billion annually. This amount will increase if imports are substituted for domestic OCS production. Importing high cost foreign oil has been singled out as contributing factor to the current inflationary cycle. In addition, increased reliance on foreign oil causes a tangible deterioration in the nation's balance of payments thus weakening the nation's international trade position. It should also be mentioned that imports carry their own set of adverse environmental impacts. Spills from tankers carrying imported oil can result from intentional discharges, accidental discharges, tanker casualties, V-13 and tanker collisions. A study of oil pollution in domestic waters during the years 1969-1970 shows that tankers accounted for about 28% of the polluting oil. b. Natural Gas Pipeline imports of natural gas into the U.S. have come mainly from Canada and Mexico. However, significant expansion of natural gas imports from these countries is questionable because of increasing domestic demand, both current and future, within Canada and Mexico. If new Canadian discoveries result in large reserve additions, surpluses may become available for export to the U. S. The growing shortage of domestic gas has encouraged projects to import liquefied natural gas (LNG) under long term contract. Large scale shipping of LNG is a relatively new industry and the U.S. does not yet have facilities for receiving base load shipments. Several LNG projects are now under consideration on the Pacific, Atlantic, and Gulf coasts. However, the Middle East oil cutback has raised questions concerning the security of foreign, especially Algerian, sources of LNG. The complexity of and length of time involved in implementing these proposals has been increased by the need for negotiating preliminary contract's, securing the approval of the Federal Power Commission and the exporting country, and making adequate provision for environmental and safety concerns in the proposed U.S. facilities. The chief source of possible increased pipeline natural gas imports is Canada. The Canadian policy has been to restrict the level of natural gas exports in order to build a large domestic reserve. Unless this policy changes or significant new Canadian discoveries are made, it is unlikely that more gas would be available to import. LNG import levels will depend on how soon this industry can be introduced into the U. S. The question of security of foreign LNG supplies has caused re-evaluation of these projects. The environmental impacts of LNG imports arise from tankers; terminal, transfer, and r egasification facilities; and transportation of the gas. The primary hazard of handling LNG is the possibility of a fire or explosion during transportation, transfer, or storage. V-14 Receiving and regasification facilities will leauire prime shoreline locations and dredging of channels. Regasification of LNG will release few pollutants to the air or water. LNG imports will influence the U.S. balance of payments. This impact will depend on the origin and purchase price of the LNG, the source of the capital, and the country (U.S. or foreign) in which equipment is purchased and LNG tankers are built. 10. Other Energy Sources The high costs and rapidly shrinking reserves of the traditional energy fuels have encouraged research into new and different sources for potential energy. As the cost of traditional fuels continues to grow at accelerating rates, demand for, and eventual substitution by alternate energy forms will occur. Some of these alternate sources have been known for decades but, high costs and technical problems have prevented their widespread use. Environmental impacts of these alternatives are sometimes difficult to assess, especially if a great amount of research and development remains to be completed before operational scale systems can be developed, tested, and evaluated for production and application. For the following listed alternatives, the date of commercial availability will depend on the cost of the traditional energy fuels, the level of Federally- subsidized research, and the probability of encountering insurmountable engineering and technical problems. Thus some of these energy sources could be installed within the current decade, while others may prove never to be feasible. a. Possible significant energy contribution before 1985 J_' Energy forms Primary limitations Secondary limitations Geothermal energy Resources Economics Tar sands Resources Economics 1/ ~ After: New Energy Forms Task Group 1971-1985, National Petroleum Council Committee on U.S. Energy Outlook, 1972. V-15 b. Improbable significant contributions before 1985 Energy forms Hydrogen Biological (agricultural & wastes) Solar Tidal Wind Primary limitations Economics Economics Technology Resources Resources S econdary limitations Technology Resources Economics Economic s Economics Energy Conversion Devices Fuel cells Thermonics Thermoelectric Mangeto hydrodynamics Technology Technology Technology Technology Economics Economic s Economics Economic s Federal energy research and development funding has expanded signi- ficantly in the last few years. President Nixon announced in his Energy Message of January 23, 1974, that Federal commitment for direct energy research and development will be increased to $1. 8 billion in FY 75. The table below shows the FY 74 funds for different areas of research and the preliminary FY 75 request for funds. FEDERAL ENERGY R&D FUNDING ($ million) Direct Programs FY 74 FY 7 5 Agency' Conservation a. End use (residential & commercial b. Improved efficiency (transmission) c. Improved efficiency (conversion) d. Improved efficiency (storage) e. Automotive f. Other transportation Oil, gas, and shale a. Production b. Resource assessment c. Oil shale d. Related programs 65. 128. 6 15. 27. 9 DOI, other 5. 18. 8 AEC, DOI, NSF 14. 9 29. 8 AEC, DOI, NSF 2. 9 6.4 AEC,NSF 14. 2 23. 7 AEC, EPA, DOT NSF, 13. 22. DOT, DOC 19. 1 41. 8 3. 17. DOI 5. 13. DOI, NSF 2. 3 3. DOI 8. 8 8. 7 AEC, DOI V-16 Coal 164. 4 415. 5 'a. Mining b. Mining, health & safety c. Direct combustion d. Liquefaction e. Gasification (high BTU)*# f. Gasification (low BTU) g. Synthetic fuels pioneer program h. Resource assessment i. Other (incl. common technology) Environmental Control a. Near term SO x b. Advanced SO x c. Other fossil fuel pollutants (incl. NO x , particulates) d. Thermal pollution e. Automotive emissions Nuclear fission a. LMFBR b. Other breeders (GCFER & MSBR) c. HTGR d. LWBR e. Reactor safety research f. Waste management g. Uranium enrichment h. Resource assessment i. Other (incl. advanced tech, ) Nucl ea r fusion a. CTR b. Laser *## Other a. Solar b. Geothermal c. Systems studies I. 5 55. 27. 27. 7 15. 9 36. 2 45. 5 108. 5 33. 65. 3 21. 3 50. 7 42. 1 1. 2 1. 9 11. 7 28. 1 65. 5 178. 5 39. 9 82. 4. 12. 13. 1 57. 1. 5 18. 5 7. 9. 530. 5 724. 7 337. 3 473. 4 4. 11. 13. 8 41. 29. 21.4 48. 6 61. 2 6.2 11. 5 57. 5 66.0 3. 4 10. 4 10. 7 28. 8 101. 1 168. 6 57. 102. 3 44. 1 66. 3 53. 5 157. 5 13. 8 50. 10. 9 44. 7 17. 3 30. DOI DOI DOI, NSF DOI, NSF DOI, NSF, AEC DOI, NSF DOI 1/ DOI DOI EPA, DOI EPA EPA EPA, AEC EPA AEC 1/ AEC AEC, NSF AEC, DOI, NSF AEC, DOT, NSF, FEO, TREA, FPC & OT !/ The AEC research budget was later increased by $40 million. V-17 d. Misc. 11. 5 32. 8 NSF, DOI Support programs Environmental eff e cts research a. Pollutant characterization, measurement & monitoring b. Transport of pollutants c. Health effects d. Ecological effects e. Social & welfare effects f. Environmental assessment & policy formulation Basic research a. Materials b. Chemical, physical, engineering c. Biological d. Plasmas e. Mathematical Manpower development Total (direct energy R&D) Total (support programs) Total (direct & support) 169.7 303.4 16. 3 270. 5 37.4 26.6 55.6 72. 6 112. 5 27. 3 65. 17. 5 19. 8 9.4 13. 1 999.1 1,815.5 486. 5 AEC, EPA, NSF 94. 5 174. 6 AEC, NSF 13. 2 32. 9 30. 8 58. 1 40. 3 60. 5 2. 8 8.2 7.4 14. 9 6.3 8. 5 AEC, NSF 1,269.6 2,302.0 ♦Agency codes: AEC - Atomic Energy Commission DOC - Department of Commerce DOD - Department of Defense DOI - Department of the Interior DOT - Department of Transportation EPA - Environmental Protection Agency FEO - Federal Energy Office FPC - Federal Power Commission NASA - National Aeronautics and Space Administration NSF - National Science Foundation TREA - Department of Treasury ♦♦Funds for high BTU gasification in the Office of Coal Research budget do not include Trust Fund amounts. ♦ ♦♦Includes amounts for laser fusion directed toward military application. V-18 11. Combination of Alternatives In the interest of clarity of presentation this analysis has discussed separately each potential alternative form of energy. It is highly unlikely that there will ever be a single definitive choice to be made between any potential energy form and its alternatives. Each may have a role to play; some way make major contributions to our energy supplies, while others may be subordinated to lesser roles. Some alternatives may be developed rapidly; others may evolve more slowly, perhaps to make a more important contribution at a later date. Forecasting on the basis of present knowledge of the relative roles of these potential alternatives is a highly subjective exercise which must necessarily include a large measure of judgement as to future trends in such variables as the direction and pace of technological development, the identification of usable i esources, the rate of national economic growth and changes in our life style. It seems most probable that many alternatives will be developed to some degree. Understanding of the extent to which they may replace or complement offshore oil and gas requires reference to the characteristics of our total national energy system. Factors most relevant to the issues at hand are outlined below: 1. Historical relationships indicate that energy requirements will grow at approximately the same rate as gross national product. 2. Energy requirements can be constrained to some degree through the price mechanisms in a free market or by more direct constraints. One important type of direct constraint operating to reduce energy requirements is through the substitution of capital investment in lieu of energy, e. g. , insulation to save fuel. Other potentials for lower energy use have more far reaching impacts and may be long range in their implementation -- they include rationing, altered transportation modes, and major changes in living conditions and life styles. Even severe constraints on energy requirements within the time frame of this statement. 3. Energy sources are not completely interchangeable. Solid fuels cannot be used directly in internal combustion engines for example. Fuel conversion potentials are severely limited in the short term although somewhat greater flexibility exists in the longer run and generally involves choices in energy-consuming capital goods. V-19 The principal competitive interface between fuels is in electric power plants. Moreover, the full range of flexibility in energy- use is limited by environmental considerations. 4. A broad spectrum of research and development is being directed to energy conversion - more efficient nuclear reactors, coal gasification and liquefaction, liquified natural gas (LNG), and shale retorting, among others. Several of these should assume important roles in supplying future energy requirements, though their future competitive relationship is not yet predictable. 5. Major potentials for filling the supply 'demand imbalance for domestic resources are: - More efficient use of energy. - Environmentally acceptable systems which will permit production and use of larger volumes of domestic coals. - Accelerated exploration and development of all domestic oil and gas resources. - Development of the Nation's oil shale resources. Of the foregoing increased domestic oil and gas production offers considerable possibilities, although adequate incentives must exist for indicated and undiscovered domestic resources to be discovered and extracted. 6. The acceptability of oil and gas imports as an alternative is diminished by: - The security risks inherent in placing reliance for essential energy supplies on sources which have demonstrated themselves to be politically unstable and prone to use interruption of petroleum supplies to exert economic and political pressure on their customers. - The aggravation of unfavorable international trade and payments balances which would accompany substantial increases in oil and gas imports. -Apparent high costs of liquefying and transporting natural gas other than overland by pipeline. V-20 12. Alternative within the Program - Government Exploratory Drilling Prior to Leasing Exploratory drilling conducted by or sponsored by the Federal Government prior to holding a lease sale would be an alternative within the program. This would involve an alternative approach to one aspect of the present Federal leasing system. At the present time there is no exploratory drilling on the OCS prior to leasing. The U.S. Geological Survey receives all engineering and geological data from companies who have drilled on leases issued on the OCS. These data and geophysical data purchased on the open market are used by the Geological Survey to develop OCS lease policies and evaluate tracts prior to leasing. Oil and gas companies spend millions of dollars acquiring geological and geophysical data, and on data processing and interpretations to enable them to compete in lease sales. In 1971, U.S. exploration expenditures were $2. 4 billion, down from an historical peak of $3. 4 billion in 1968. (This cost includes drilling and equipping exploratory wells, acquiring undeveloped acreage, lease rentals, geological and geophysical expenditures, test well contributions, land department costs including leasing and scouting, and other, including direct overhead. ) _' The value of their information depends upon its exclusive and proprietary nature. Because of the high costs, companies generally combine in "group shoots" and share the expenses of seismic data acquisition or purchase data from geophysical service companies. A very few companies have their own equipment and do their own work under research and development departments. Geophysical service companies acquire data on specific areas on a speculative basis hoping to sell it to several companies. Therefore, although several companies and the Government may have the same data it is proprietary to the purchaser and cannot be revealed. Each purchaser believes his competitive edge is its use in his interpretation and application. Government exploratory drilling would have several advantages. It could establish the existence, possible extent, and quality of oil and gas resources, and signal problems that may occur if development follows. The Government - "What It Costs to Find Hydrocarbons in the U. S. , "World Oil (October 1973), p. 77. V-21 would be in a better position to take the initiative in selecting tracts to be included in a sale, evaluating resource potential, determining pre- sale estimated value, analyzing lease bids, and identifying environmental problems for the protection of sensitive areas through lease stipulations. At the present time, the oil and gas industry sometimes has more seismic data than the Government for some tracts and industry assists Government through the nominations process in the selection of specific tracts in a general area designated for leasing. The availability of data from Government exploratory drilling would tend to eliminate the need for costly exploratory effort by industry and encourage companies to channel their efforts into the acquisition and development of producible leases. Availability of data from exploratory drilling could encourage smaller companies to participate in leasing by greatly reducing capital outlays required to evaluate tracts and reducing the competitive advantage of a few companies which possess exclusive data. These tendencies would be counteracted to the extent that companies distrusted Government findings and continued to undertake independent exploration and data acquisition. Also, large companies having the same data and more money could still outbid smaller companies. However, data from exploratory drilling would provide significantly better resource evaluation than any other method. The cost to the Government of an adequate exploration program would be tremendous, whether the Government contracted out the work or purchased and operated the equipment itself, hired its own personnel, and did all of its own analysis. For example, consider drilling costs alone. To drill a typical offshore exploratory will cost about $2. 1 million dollars. Of this, about 65% represents operating costs and 22% mobilization and demobilization.—' Each company evaluates in depth only the most promising tracts and those in which it has a particular interest. In contrast, a Government exploration program would require a detailed evaluation including seismic work and coring and exploratory drilling, of extensive OCS areas, not of just a few tracts. Under present practice, the cost of seismic data collection is- lowered by being "speculative data" for sale to many companies. A Government exploratory drilling program would result in the Government assuming the risks and costs now borne by companies. Much of the resources devoted to data acquisition and interpretation by private industry would be — "Finance and Economics of Offshore Operations, " World Oil (July 1973) p. 86. V-22 freed for development and production. Such a Government program would be tantamount to finding the oil for industry and leasing the reservoirs to be developed and produced. The interpretation of these data to evaluate resource potential involves not only expertise using the latest state of the art but also highly sophisticated equipment. Under the present system, this expertise is found throughout many companies, each of which devotes a great amount of time and money to the development of better interpretative methods. Each company has its own interpretations and special knowledge, resulting in a diversity of approach to data analysis and use. Any company, as well as the Government, can miss the mark in evaluating a particular tract, but each company believes its competitive edge is its superior interpretation and use of data. Under a system where only the Government did exploratory drilling, the discovery rate could decline. Reserves which the Government underevaluated or overlooked might be less likely to be discovered. The impacts of Government exploration would be essentially the same as industry's explorations. Industry is required to adhere to stringent standards developed by the Government and is inspected by Government employees enforcing those standards. It would be inappropriate to believe the Government would make standards significantly more stringent for its own operations than it has for industry operations. A large number of environmental impact statements have been prepared by the Department of the Interior in connection with their offshore leasing program. Among the more recent are: Proposed Plan Development, Santa Ynez Unit, Santa Barbara Channel, Off California (FES 74-20, May 3, 1974); 1974 OCS Oil and Gas Lease Sale Offshore Texas (#34) (FES 74-14, March 22, 1974); and 1974 OCS Sale No. 36 Oil and Gas General Lease Sale, Offshore Louisiana (DES 74-49, April 30, 1974); Oil and Gas General Lease Sale Offshore Texas; Proposed Increase in OCS Oil and Gas Leasing by Ten Million Acres in 1975; Oil and Gas General Lease Sale Offshore Southern California; and Oil and Gas General Lease Sale Offshore Central Gulf of Mexico. In addition to these statements the recent report of CEQ concerning offshore development on the Atlantic Coast and in the Gulf of Alaska J_' provides pertinent data bearing upon any major policy decision on this area. Also J_'OCS Oil and Gas - An Environmental Assessment, a report to the President by the Council on Environmental Quality dated April 1974. V-23 studies have been performed by the National Science Foundation _ and private organizations which provide relevant information on other forms of energy conservation and use. The environmental consideration of the above mentioned alternatives, as stated in the reference works should be supplemented with the following factors which concern the Mar Ad Program. The adoption of any alternative which would curtail offshore development would also have the effect of reducing the use of resources and the pollution which may arise from the construction and operation of program vessels as detailed subsequently. B. ALTERNATIVES TO THE MARAD PROGRAM In the more restricted area of the MarAd Program itself, certain alternatives are possible. These would be direct alternatives to the MarAd Program. 1. DISCONTINUE THE PROGRAM By refusing to provide MarAd Title XI assistance to the construction of drilling vessels and service craft in U.S. shipyards the following results could be expected: The general program of offshore development would continue and could involve the use of foreign-built vessels constructed without the benefit of strict U. S. safety and environmental standards. Although American built vessels would not be readily available, some construction of privately financed, American vessels would continue, expecially if a shortage of suitable vessels developed which raised the revenue potential of such vessels. With respect to the pace of offshore development, it might be decelerated slightly over a short term period as foreign vessel production was increased and economic pressures made U.S. private financing more viable. The environmental effects of this action would be a lessening in the pollution associated with shipbuilding and in the use of materials. On the other hand, an influx of foreign-built, foreign flag vessels would provide our government with a lesser degree of control over the design, construction and operation of these vessels and consequently some lesser degree of environmental control. y A Technology Assessment of Geothermal Energy Resource Development dated April 15, 1975. V-24 2. SUSPEND THE PROGRAM The program could be suspended in order to provide time to improve the environmental characteristics of the vessels and their operations. Such action alone, however, would have much the same effect as discontinuance of the program. If offshore development were to continue, the action would result in increased use of foreign vessels and ultimately greater reliance on privately financed vessels as prices for these services increased. The intention of such action, break through in design prior to major construction, would not be greatly encouraged by this action because of the availability of alternative vessels. 3. MODIFY THE PROGRAM a. Development of New Standards In this connection reference should be made to the present standards for design, construction and equipment of offshore vessels. Such rules have been developed by the Department of the Interior, the Coast Guard and the American Bureau of Shipping. In addition, certain provisions of IMCO's 1973 Marine Pollution Convention such as the special requirements for drilling rigs and other platforms as described in Regulation 21 of Annex I, will apply to such vessels when the Convention comes into force, and present Law of the Sea proposals contemplate an international authority to set standards for environmental protection for vessels engaged in the exploration and exploitation of offshore minerals. At the present time vessels financed under the MarAd Program must comply with these requirements. An alternative would be for MarAd to attempt to devise environmental standards above and beyond those presently required. The difficulty with this approach is that the types of pollution which pose the most threat are those associated with the drilling process. It is questionable whether such a course of action would result in standards materially different than those presently in effect. A necessary foundation to improving standards for offshore equipment and operations would appear to be increased research and development, especially on the part of the government. While there are presently government research and development projects in process concerning various aspects of marine pollution, little is being done in the areas of the design of offshore equipment to prevent pollution. V-25 Although private industry has not undertaken work on a centrally coordinated basis for the design of offshore equipment to prevent pollution, the companies involved in the offshore drilling industry have through conferences and cooperation between drilling contractors, equipment vendors and operators developed the designs for many new sophisticated pieces of equipment and substantially improved existing equipment and systems to prevent pollution. Such equipment includes: blowout prevention equipment, riser and subsea control systems, well testing equipment, vessel sewage systems, drilling mud control systems, and well completion equipment and systems. V-26 CHAPTER VI ADVERSE ENVIRONMENTAL IMPACTS WHICH CANNOT BE AVOIDED UNDER THE PROGRAM A. USE OF MATERIALS As indicated in Chapter IV, the construction of oil and gas drilling vessels under the Title XI program will require the use of large quantities of steel and other mineral products. While a very large part of these minerals should be recycled, the mining and processing of these materials does involve environmental harm in the form of land use-change, air, and water pollution. However, when the amount of materials used are considered in terms of total production, the amounts are comparatively small. In addition, it is questionable whether domestic production would be reduced, and hence the environmental effects reduced, if construction of the vessels under the program did not take place. The operation of the program vessels will also involve the consumption of diesel fuel and lube oil. The extraction and processing of these products involve impacts generally similar to those concerning materials used in construction. In a like manner, the amounts involved are small and it is questionable whether the program will have any effect upon total production. B. OIL SPILLS Chapter III sets out the various types of oil pollution which oil and gas drilling vessels are likely to produce. Chapter IV describes measures which may be taken to lessen the amounts and effects of oil pollution from oil and gas drilling vessels. These include enforcement of various vessel safety and operation standards, and other measures for controlling, containing, and cleaning up spilled oil. As that and other Chapters indicate, while reduction is possible, some oil pollution is bound to occur. Operational discharges for the most part can be controlled within limits; however, accidental discharges, especially those from casualties, result from the fallibility of man and are more difficult to control. Various safety measures can reduce the chances of accidents and minimize their effects when they occur, but environmentally significant oil spills from accidents involving oil and gas drilling vessels are a distinct possibility. VI-1 When oil discharges from oil and gas drilling vessels occur they can have the following environmental effects. Pollution can affect, in varying degrees, all forms of marine plant and animal life from those that are the lowest in food chain to those at the top. The degree of pollution duration and the physical condition under which it occurs determines the extent of the impact. After the pollution has occurred, a normal balance may be regained in a short period of time or the impact may be more severe and recovery may require a span of many years. Little is known of what effect the chronic incremental discharge of oil may have on the marine food web. In addition to the effects upon plant and animal life, oil discharges of the chronic type, or major spills could affect beaches, water areas and historic sites making them at least temporarily unusable for recreational purposes. If such pollution incidents occurred during periods of normal heavy visitor use, loss of recreational enjoyment and economic benefit to the vicinity could be substantial. Fishing, water sports, boating and many other marine related activities could be made much less attractive for an indeterminate period, depending upon the promptness and efficiency of the cleanup operation. C. OTHER ADVERSE IMPACTS The foregoing subchapters detail the major environmental impacts of the Title XI Offshore Oil and Gas Drilling Vessel's which cannot be avoided. The program will also involve some other impacts which are of lesser significance or which can be attributed only in part to the program. Small amounts of air, water noise, and solid waste pollution will result from construction, operation, repair, and scrapping of these vessels. These forms of pollution can be and are likely to be kept within the limits of local, state, and national standards for these forms of pollution. VI-2 CHAPTER VII RELATIONSHIP BETWEEN LOCAL SHORT TERM USE OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG TERM PRODUCTIVITY The principal short term use of the environment resulting from the program will be the construction of the vessels with the attendant dedication of mineral resources, primarily steel, and possibly limited land resources devoted to shipbuilding and port development. These uses should have a relatively small effect upon the long term productivity of our national environment. The operation of program vessels may contribute to some extent to the development of offshore oil and gas and consequently may contribute to the diminishment of the long term productivity of these mineral resources, in a similar manner the use of these vessels could lead to some lessening of the long term productivity of marine and coastal resources. In connection with the latter point, it should be noted that the long term effects on the oceans of low-level pollution from oil and toxic chemicals are not clearly understood at this time. The additional stress the ecosystem can absorb is limited, but at present the bounds of these limitations are not known. Construction of pipelines and related facilities, if properly conducted, should have a short term affect upon the coastal environment with recovery after a period of time. VII -1 CHAPTER VIII IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES A. MINERAL RESOURCES The construction and operation of program vessels will involve the use of mineral resources, primarily steel, fuel and lube oils, some of which cannot be recovered. The character of these mineral resources is not unique nor will the quantities used be such that their use is significant in terms of our national resources. To a certain extent the program will facilitate the development and extraction of offshore mineral resources. To the extent that these vessels contribute to the production of these resources they also contribute to their irreversible and irretrievable commitment of them. B. LAND RESOURCES As previously indicated, program vessels may contribute to the pressure for the development of shipyards and port facilities with attendant dedication of land. Further, by facilitating offshore development, the program may contribute to a certain extent to onshore and coastal zone construction associated with oil field development, such as pipeline construction. C. FISH AND WILDLIFE RESOURCES An irreversible or irretrievable commitment of fish and wildlife resources and their habitats could occur in the area of a large oil spill, or if frequently subjected to chronic low- levels of oil pollution. At this time there is insufficient evidence to conclude that low- level spillage has led to an irreversible commitment of living resources; however, this matter deserves further study. More dramatic, though less probable, are the major oil spills that could occur. The extent and severity of such a spill's effects would depend on a number of circumstances which cannot be predicted with accuracy. VIII- 1 CHAPTER IX CONSULTATION AND COORDINATION WITH OTHERS This section presents an account of the consultation and coordination processes involved in the preparation of the draft environmental impact statement (DEIS) which was made available to the public on May 2, 1975, the period of review of the DEIS, and the steps leading to the preparation of the final environmental impact statement (FEIS). All official review comments of the DEIS are attached and where appropriate, the disposition of pertinent comments leading to the preparation of the FEIS are indicated. Chapter III has been totally restructured and other chapters revised to reflect all comments pertaining to the original draft wherever considered appropriate. A. PREPARATION OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 1. FEDERAL AND INDUSTRY PARTICIPATION In order to develop the draft environmental impact statement on Title XI Vessels Engaged in Offshore Oil and Gas Drilling Operations it was determined that other Federal agencies and the oil drilling industry should be contacted to provide the necessary expertise that would assist in the preparation of the DEIS. Accordingly the Maritime Administration established an Ad Hoc Working Group comprised of representatives of government and industry to undertake the task of describing or providing information, on those specific areas of offshore drilling operations in which each representative was most knowledgeable. The government and industry participation in the development of the DEIS were as follows: Department of the Interior Office of Environmental Project Review U.S. Geological Survey Department of Transportation U.S. Coast Guard IX-1 Environmental Protection Agency- Department of Commerce National Oceanic and Atmospheric Administration International Association of Drilling Contractors American Bureau of Shipping The Offshore Company- National Oceanic Industries Association Offshore Marine Services Association The following Federal agencies were also invited to comment on the DEIS in addition to those listed above: Department of State Department of Defense Department of Treasury Atomic Energy Commission Federal Power Commission Energy Research and Development Administration 2. STATE PARTICIPATION In the preparation of the Draft Environmental Impact Statement, coastal States were not formally requested to submit information or comments for inclusion in the DEIS. Active State involvement was solicited in review of the program as it was presented in the DEIS. All State comments were considered in the preparation of the Final Environmental Impact Statement and are included in this Chapter. IX -2 B. COORDINATION AND REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT LEADING TO PREPARATION OF THE FINAL ENVIRONMENTAL IMPACT STATEMENT After the DEIS was prepared, copies were made available to Federal and State governmental agencies and the public. Comments and views were solicited from those agencies which have some mandate for enforcing and developing environmental standards. In addition, comments and advice were solicited from the public and the oil and gas drilling industry through formal and informal coorespondence. All review comments of the draft environmental impact statement were considered and, where appropriate, the disposition of the comments is indicated and any unresolved issues are identified. Remarks concerning disposition of comments are to be found immediately following each letter received which has been reproduced v erbatim . In this way, it is hoped that the Department's responses to many of the issues raised can be easily located and oriented to the agency or person that originated the comment. IX -3 United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 In Reply Refer To: EGS-ER-75/447-MS108 JUL 11 1975 Dear Mr. Blackwell: This Department has reviewed the draft environmental statement on Title XI Vessels Engaged in Offshore Oil and Gas Drilling Opera- tions. The statement is valuable as a concise source of informa- tion on vessel types and designs, and for a good summary of Federal and State regulatory activities in coastal and offshore areas. We note that the statement covers only the administrative action of having the Federal Government guarantee the obligations of private ship builders, and so the environmental implications are indirect, in that offshore oil and gas operations would be encouraged. The draft statement carefully considers impacts on salt-water resources and to a lesser extent those on surface-water re- sources, especially estuaries. It should also, however, consider potential impacts on ground-water resources that may result from the implementation of the proposed action. Specifically, the following should be treated, at least briefly: (1) All drillholes which penetrate subsea extensions of artesian aquifers are potential avenues for the release of artesian pressures; such decreases may then ultimately have effects on land. For example, accidental or planned with- drawals of water through the drillholes, during exploration or development, may affect sub-land portions of the aquifers some miles away, causing increases in the rate of decline of water levels and subsidence of the land surface; hastening of salt- water encroachment into fresh-water aquifers can also result. Withdrawal of other fluids under certain circumstances may also cause distant subsidence. Most of these effects would probably be serious only in comparatively near-shore situations where large-scale development of petroleum or gas might occur; IX-4 most effects can probably be avoided by compliance with regulations as mentioned on pages IV-1 to IV-6 but poss- ible impacts and mitigating measures should be evaluated. It is probable that the very large proportion of non- productive holes indicated by Table 1-1 would be most suspect; for example, a casing not fully plugged through all aquifers may soon rust out and allow wild flows of large amounts of fresh water to occur continuously. (2) Effects of oil spills and chronic oil discharges on recharge to shallow aquifers, especially in areas of very permeable surface materials such as beach sands or pebble beaches, should be mentioned. Lenticular fresh-water bodies beneath such materials are often entirely or largely dependent upon direct infiltration of precipitation and therefore are directly subject to con- ditions such as those described in item 14 on page 111-35. Effects of pipeline breaks on shallow aquifers should also be considered. The resource estimates listed on Table III A-l are not in accordance with the latest Geological Survey evaluations which are to be published in the Bureau of Land Management final programmatic impact statement, related to the pro- posed increase in OCS leasing. Reference might also be made to U.S. Geological Survey Circular 725, "Geological Estimates of Undiscovered Recoverable Oil and Gas Resources in the United States" (copy enclosed). The last sentence in the second paragraph on page III-3 is misleading and should be deleted. During exploratory and development drilling, mud is circulated through the drill string and back up the annulus to the rig, no matter what the water depth. In deeper water, where floating rigs are utilized, the casing head and blowout-prevention equipment are on the ocean floor. However, a drilling riser con- nects the ocean floor equipment to the rig and allows the mud and cuttings to be circulated. We do not follow the rationale used in arriving at the conclusion in paragraph 2 on page 111-22 that there is a higher probability of an extremely large spill from large pipelines than from tankers. Table III A-7 clearly pre- dicts that both number and volume of spills would be greater for tankers than pipelines. Also, the text states that the possibility of spills greater than 1,000 barrels is greater for tankers than for pipelines. The largest oil IX -5 spill from an OCS pipeline to date was about 160,000 barrels. However, with the controls that are presently required on OCS pipelines (pressure sensors, volume measurements), recurrence of such a spill would be extremely improbable today. The comparison needs more careful analysis. In most drilling operations , drilling mud is not routinely discharged overboard (p. 111-24), last paragraph). Heavy, highly treated drilling muds are quite expensive and are efficiently recycled and reused. Mud discharge is gen- erally limited to small amounts of materials which cannot be effectively separated from the drill cuttings. The exact amounts of muds which are actually discharged are highly variable and difficult to determine. The statement regarding safety devices on page IV- 5 is in error. The high-low pressure sensing devices and auto- matic shut-in valves on pipelines are required on pro- duction platforms, not on exploratory drilling rigs. Additional safety requirements on all OCS drilling relate to well casing and cementing, blowout-prevention equip- ment, mud programs, well control surveillance and train- ing, and hydrogen sulfide safety programs. The statement should indicate the effect the Title IX is expected to have on the number (and types) of vessels engaged in offshore oil and gas exploration activity. This can then be related to impact analysis to arrive at the net environmental, impacts attributable to the program. This will provide perspective as to the scope of the program, an essential item now missing from the statement. Some additional references and more detailed corrections are attached for use in revising the statement. IX -6 We appreciate the opportunity to review this draft statement and we hope that you will find our comments constructive and useful in the preparation of the final statement. Sincerely yours , Crnsrnjs Deputy Assistant Secretary of the Interior ■A Mr. Robert J. Blackwell Assistant Secretary for Maritime Affairs The Maritime Administration Department of Commerce Washington, D. C. 20 23 Enclosures IX -7 The following are some additional references that have come to our attention and may be useful in revising the EIS: Anderson, J.W., 19 7 4- , • Laboratory studies on the effects' of oil on marine organisms: Texas ASM Univ., rept . in prep, for Am. Petrol. Inst. Burns, K.A. , and Teal, J.M., 1973, Hydrocarbons in the pelagic sargassum community: Deep Sea Research, 20, p. 201-211. Vaughan, B.E., ed . , 1973, Effects of oil and chemically dispersed oil on selected marine biota--A laboratory study; Battelle-Northwest Labs., Richland, Wash.; Am. Petrol. Inst. Pub. No. 4191, Wash., D.C. IX -8 Detailed Comments The data in Table 1-1 (p. 1-5) would be more meaningful if complete years were compared rather than the first half of two succeed ing years. While the operators of the SFDCO 445 (p. 1-10) state its capa- bility to 3,000 feet, the deepest water in which it or any other drill ship has been worked, using a circulatory mud system, is its present location in 2,300 feet. In Table III A-2 (p. III-9) the last line should be "heat (not "head" ) exclianger s . " Offshore Technology Conference paper OTC 2390 "Influx of Petroleum Hydrocarbons into the Oceans" by Charles C. Bates, U. S. Coast Guard, and Earman Pearson, University of California, has up-to-date information on the subject of oil pollution sources (p. 111-10) . Another reason for the apparent lack of significant decrease ,in the number of pollution incidents (p.. 111-13, paragraph 2) is the improvement in recording and reporting practices. The first sentence in paragraph 2 on page 111-25 should read "During production operations, waters from the ..." "Offshore vessels" should evidently be "drilling and service vessels" (p. V-l, line 11). The following should be added to the list of recent OCS environmental statements on page V-2, paragraph 2: (1) Oil and Gas General Lease Sale Offshore Texas; (2) Proposed Increase in OCS Oil and Gas Leasing by Ten Million Acres in 1975; (3) Oil and Gas General Lease Sale Offshore Southern California; and (4) Oil and Gas General Lease Sale Offshore Central Gulf of Mexico. The proposed alternative of modifying the program by giving preference to certain vessel designs that are more environ- mentally sound than others (p. V-4 to V-5) appears not to be a real alternative but to be a part of the MarAd Title XI Program as presently administered. It had been stated earlier (p. PV-17) that the Maritime Administration "reviews technical plans and specifications to ensure that the vessels/rigs are in conformance with good shipbuilding practices and that these units comply with standards established by such regulatory bodies as U. S. Coast Guard, Environmental Protection Agency, American IX -9 Bureau of Shipping, etc." It has teen explained t hat the regulatory standards are intended to increase safety and protect the marine environment, The fact that this alternative is not a modification of the present program, but a part of it, appears to be acknowledged by the conclusion that "the impacts of this course of action would be the same as continuing the program as it presently exists" (p. V--5, lines 5-6) . IX -10 Department of the Interior (DPI) The DOI offered numerous substantative comments designed to improve and expand on those sections dealing with ground-water resources, oil and gas resources, oil spills, drilling technology and safety devices and the recommendation that the Title XI Program description be elaborated upon. Disposition Page 1, para. 1 - No disposition required. Page 1, para. 2 and 3 (1) - The comments relative to sub- sea aquifers being penetrated during drilling operations and the possible subsidence of nearby land areas are considered to be beyond the scope of this environ- mental impact statement. A review of numerous DOI environmental statements relative to the exploration and exploitation of the outer continen- tal shelf revealed no discussion on the subject of aquifers and only a brief mention of land subsidence in the Santa Barbara Channel area as a result of production wells extracting hydrocarbons. Table 1-1 has been replaced with a more meaningful and up to date table; and with regard to a well casing not being fully plugged, the reader is referred to the following passage from DOI draft environmental statement Oil and Gas Development in the Santa Barbara Channel (DES 75-35): "Plugging and abandonment operations must be in conformance with Geological Survey regulations and such operations cannot be commenced prior to obtaining approval from the Geological Survey. The regulations specify acceptable alternate abandonment procedures for various well conditions, open hole, perforations, etc. , and specify tests to ensure that formations are isolated and that the well is left in a safe condition. " Page 2, para. 4 (2) - Chapter III has been completely restructured, however, for the reasons stated above, oil effects on aquifers has not been included. Page 2, para. 5 - Table IIIA-l has been deleted. Page 2, para. 6 - Comment is reflected on page III- 71. Page 2, para. 7 - The statement that there is a higher probability of an extremely large spill from large pipelines than from tankers has been removed. IX -11 Page 3, para. 8 - Comment is reflected in the revision of Chapter III on page III- 71. Page 3, para. 9 - Page IV-4, para 2, has been revised to reflect the comment relative to safety devices. Page 3, para. 10 - Chapter I has been restructured to provide perspective as to the scope of the Title XI Program as it relates to the number and types of vessels engaged in offshore oil and gas drilling operations. Page 3, para. 11 - Added additional references where appropriate Detailed Comments Para. I - Table I-I has been replaced. Para. 2 - Page I- 10 (new page 1-13) has been revised to indicate a water operating depth of 2, 300 feet in lieu of 3, 000 feet. Para. 3 - Correction has been made. Para. 4 - Chapter III has been completely revised and now indicates up-to-date information on oil pollution sources. Para. 5 - Improvements in recording and report pollution incidents has been mentioned in the revision of Chapter III. (Page III- 13). Para. 6 and 7 - Editorial corrections have been made to Chapters III and V. Para. 8 - The list of OCS environmental statements has been included in Chapter V. Para. 9 - The comment that the proposed alternative of "modifying the program by giving preference to certain vessel designs that are more environmentally sound than others is not a real alternative" is concurred with and has been deleted from the Final EIS. IX-12 ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 2 7 JUN 1975 OFFICE OF THE ADMINISTRATOR Dr. Sidney R. Galler Deputy Assistant Secretary Environmental Affairs Department of Commerce Washington, D.C. 20230 Dear Dr. Galler: The Environmental Protection Agency, pursuant to its responsibilities under the National Environmental Policy Act and Section 309 of the Clean Air Act, has reviewed the draft environmental statement for Title XI Vessels Engaged in Offshore Oil and Gas Operations. In general, we believe the statement presents a competent analysis of the Offshore Oil and Gas Drilling and Support Vessel Program and the environmental impacts associated with the program's implementation. There are a few specific issues, however, that should be clarified in the final statement. These are enumerated below: Page 1-4. It is not clear from the statement whether the MARAD offshore drilling program is ongoing or proposed, since no historical reference is cited for the offshore program's inception. Information should be given to explain this program's time frame and its relevance to the National Environmental Policy Act of 1970. Page III- 8 . Improper disposal of oil- contaminated drill cuttings and drilling muds may be in violation of EPA's soon to be proposed effluent limitations for the oil and gas extraction industry (see EPA's Draft Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Oil and Gas Extraction Point Source Category). Such discharges will be subject to NPDES permits issued under Section 402 of the Federal Water Pollution Control Act, as amended, upon condition that the discharges will meet the requirements under Sections 304, 306, and 307 of the same Act. This and other references to the Act (page 111-46 and III- 50) should be modified to reflect the current status of the implementation of this law. In this connection, we also mention that overboard discharge of muds in territorial waters may be in violation of Federally approved State water quality standards. IX -13 Page III- 16. Although equipment is quite thoroughly described, the discussion of pipeline placement and attendant impacts is not adequate. The final should be more thorough in detailing the pipeline laying operation and the extent and duration of environmental disturbance. Page III - 20. The discussion of oil spills from single point mooring facilities and fixed berth facilities may present an invalid comparison of spill probability. SPM spill data are somewhat dated and are compiled from a number of facilities, whereas fixed berth information has been derived from one port with an outstanding record for few spills. A more equitable comparison of situations would be appropriate in the final statement. Page III - 58. Shipyard construction or expansion may be necessary to accommodate the increasing demand for offshore drilling vessels. Clearly, the development of drilling rig construction sites will cause serious socio-economic impact on small communities. The final should examine this issue when evaluating secondary impacts. Page III - 59. The statement mentions the necessity of dredging access channels to construction and repair facilities to accommodate wide, deep draft semi- submersible rigs. The final should describe the impact of this dredging and discuss the disposal of the dredged spoil. Page III 69. This material indicates that shipyards will periodically place oil and water oh unpaved roadways to suppress dust. EPA has found that a large percentage of oil used for dust prevention on dirt roads eventually finds its way into adjacent waterways, and that this practice is therefore environmentally objectionable. In accordance with the EPA rating system for environmental impact statements, we have classified this statement as LO-2. This means we have no substantive objection to the described activity, but feel that more information, as requested in our specific comments, is needed. We thank you for the opportunity to review this statement and hope our comments will assist in the preparation of the final statement. Sincerely, \\pA/-ocs~*>, ^ - Htvy-v--^. *.-, . o-v- Sheldon Meyers Director Office of Federal Activities IX -14 Environmental Protection Agency ( EPA ) Page 1, para. 2 (Page 1-4) - Chapter I has been restructured to provide a more descriptive background of the Title XI Program and its relationship to the offshore drilling industry. With regard to the Program's relevance to the National Environmental Policy Act of 1970, it was determined that the Program constituted a major Federal action that could effect man's use of the environment; therefore, it was felt that the publishing of an environ- mental impact statement was necessary under Section 102(2)(C) of NEPA. Page I, para. 3 (Page III- 8) - Chapter III has been completely restructured, and page III- 7 1 reflects the comment relative to overboard discharges of drill cuttings and drilling muds. Page 2, para. 4 (Page III- 16) - Page 111-75 has been revised to describe pipelin laying and the resultant environmental disturbances. Page 2, para. 4 (Page 111-20) - The comparison of oil spills from single point mooring (SPM) facilities and fixed berth facilities has been deleted as not being pertinent to an EIS of this nature. Mention of SPM's, however, has been retained. Page 2, para. 5 (Page III- 5 8) - Shipyard construction or expansion to meet the demand for offshore drilling vessels is extremely unlikely, and Chapter III has been revised to reflect this improbability. Page 2, para. 6 (Page 111-59) - Page III - 7 8 discusses the dredging of access channels and indicates the role of the U. S. Army Corps of Engineers relating to any such dredging needs. Page 2, para. 6 (Page III- 69) - The oiling of unpaved roadways at shipyards was found to be obsolete, and the practice has largely been discontinued (Page 111-82). e IX-15 DEPARTMENT OF TRANSPORTATION MAILING ADDRESS UNITED STATES COAST GUARD u s COAST GUARD (G-WEP-2/73) WASHINGTON. DC 20590 phone 202-426-9573 ' 5922/9. a 3 JUN1976 Hr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs Department of Commerce Washington, D. C. 20230 Dear Mr. Galler: This is in response to your letters of 2 May 1975 addressed to the Assistant Secretary for Environment, Safety and Consumer Affairs, Department of Transportation, and the U. S. Coast Guard, concerning the draft environmental impact statement, Maritime Administration, Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations. The United States Coast Guard has reviewed the statement and we offer comments as follow: Page III - 20, Provide oil spill data for single point moorings (SPM's) which appear to be based on "Bayesian Analysis of Oil Spill Statistics," J. W. Devanney and R. J. Stewart, Marine Technology, October 1974. The figures of 108 spills in 5,578 ship calls are industry statistics for 10 Shell Oil Company loading SPM's, while Durban is an unloading SPM and its spill record is not included in these figures. None of these facilities is located on the outer continental shelf where vessels con- structed under the proposed program would primarily be utilized. Therefore, these figures may not be representative of SPM's associated with outer continental shelf oil development where sea and weather conditions would be more severe. On page IV-2, reference is made to some provisions of the 1973 IMCO requirements for fixed and floating drilling rigs and on page V-5, reference is made to applying some of the provisions of the 1973 Marine Pollution Convention to vessels built under the proposed project. Since this Convention has not yet been ratified, the sections to be applied should be clearly identified and the reasons for not requiring compliance with other provisions, and the environmental impacts of such non- compliance, should be justified. The proposed program consists primarily of guaranteeing vessel mortgages and not ship design and construction. Table 1-2, on page 1-7, lists the number of applications received and approved under this program, but does not give figures on the dollar amount of mortgages guaranteed. Since this program is primarily financial in nature, it would be appro- priate to give some dollar figures on the size of the government's commit- ments in the EIS describing the project, and the economic impact of those commitments. IX -16 3 JUN197* Subj : Reply to Mr. Galler's letters of 2 May 1975 concerning the draft environmental impact statement, Maritime Administration, Title XI - Vessels Engaged in Offshore Oil and Gas Drilling operations The Coast Guard regulations concerning marine sanitation devices have been promulgated and are attached as enclosure (1) . The current National Contingency Plan was revised as of 10 February 1975 (enclosure (2)). The plan is substantially the same as the super- seded version and no change is required in your description (page IV-24 and 25) except for the last sentence. The opportunity to review the statement is appreciated. Sincerely, K-—^ A t &>-r^ Enclosures JAMES A- ATKINSON Commander, U- S- Coast Guard Assistant Chief, Marine Environmental Protection Division By direction of the Commandant IX-17 Department of Transportation U.S. Coast Guard (USCG) Page 1 (Page 111-20) - In the revision of Chapter III the comments relative to single point moorings and oil spill statistics have been incorporated. Page I (Page IV-2) - Page V-5 of the DEIS has been revised to incorporate the comment and the sections of the IMCO 1973 Marine Pollution Convention that will apply to the program vessels have been identified. The remainder of the comment relative to - reasons for not requiring compliance with other provisions" - is not clear and would fall beyond the purview of this statement. Page 1, Last para. Chapter I has been revised and now provides the number of applications received and the figures on the dollar amount of mortgages guaranteed under the program. Page 2 - Comments on page 2 of the U.S. Coast Guard letter have been incorporated into the FEIS. IX -18 UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration Rockville. Md. 20852 June 17, 1975 TO: Sidney R. Galler William AronT&S^^**** T^ SUBJ: DEIS - Maritime Administration: Title Xl-Vessels Engaged in Offshore Oil and Gas Drilling Operations Attached are' comments from the NOAA-National Marine Fisheries Service, Environmental Data Service, National Weather Service and Marine Ecosystems Analysis Project. on subject DEIS. Attachments IX -19 ^%. <* .*•». ^ '^6-l9l 6 VJ» ^ U.S. DEPARTMENT OF COMNlEfiQE National Oceanic and Atmospheric Administration ENVIRONMENTAL DATA SERVICE Washington. D.C. 20235 D3tS June 11, 1975 Reply to Attrt.of: Dx6/LAP To William Axon Director, Of fide of Ecology and Environmental Conservation, EE ''Lewis A. Pitt Special Projects Subject: EDS Review of Maritime Administration DEIS: in Offshore Oil and Gas Drilling Operations Title Xl-Vessels Engaged The EDS has reviewed the subject DEIS and offers the following comments: When this office reviewed the original Maritime Administration (MARAD) paper, which was the forerunner to the present DEIS, we critically commented on the environmental description. We also offered to assist the Agency in rewriting the applicable section (see attachment) . The EDS offer was not followed through by MARAD. We note now that the DEIS marine environment is described only in general terms (see Chapter II) and the physical oceanography portion has been eliminated. For a detailed discussion the reader is referred to a U.S. Department of Interior Draft EIS: "Proposed Increase in Acreage to be Offered for Oil and Gas Leasing in the Outer Continental Shelf, DES 74-90, October 18, 1974 (Page II-l) , which is no longer in our files. The EDS reviews approximately 40 DEIS per month. These range from approximately 30 pages to as much as 500 pages each. Multiply this by the number of agencies who review the DEIS and the number processed strains the imagination. To further require that these publications be archived in anticipation that a later DEIS will refer back to a stored document not only creates a space/storage/indexing nightmare, it also delays the processing of the environmental statement. In lieu of referring to a separate archived DEIS for an environ- mental description, EDS recommends that the pertinent portion be extracted by the preparing agency and included in the subject DEIS ur.der consideration. This procedure will provide a complete document and facilitate its review. Other POEs are encouraged to comment, Attachment cc : G. Lill, NOS W. Hess, ERL T. LaRoe, CZM Cdr. Swanson, MESA D. Evans, NMFS R. Burns, PMEL R. Pyle, NESS F. Hebard, MR-5 A. Peterson, NWS H. Stewart, AOML IX -20 September 25, 1974 Dx6 Dr. William Aron„ EE Lewi3 A. Pitt Special Pro j seta Staff Clarification of 2S0AA Comments on MarAd Discussion Paper on Title XI Vassel3 Zngaged in Offshore Oil and Gas Drilling Operations (Ref . your memo, same subject, September 19, 1974) HarAd' 3 suggestion that NOAA undertake the task of providing the actual input and revise the language and analysis as necessary is acceptable. 1I0AA/ED3 would be happy to rewrite the physical oceanography section (Chapter II, Section I, pages 48-35) of the paper if funds are furnished. It will take one man about 2 to 3 weeks to do the job at a cost of approximately $12G0-$1800. As an alternate option, EDS would welcome a visit by the KarAd writer of the paper. Wa would show him where the erro r s were noted and provide the reference sources necessary to cover missing areas and strengthen othar descriptive portions. LAPittrjas IX -21 F34/BEH To : EE-Office of Ecology and Environmental Conservation From : Associate Director for Resource Management, F3 Subject : MarAd DEIS on Title XI, Vessels Engaged in Offshore Oil and Gas Drilling Operations (DOC) The National Marine Fisheries Service has reviewed the subject DEIS and offers the following comments: General Comments We appreciate the fact that because "Oil and gas exploratory drilling units and support vessels built under the MarAd Title XI Program could operate at any offshore area in any ocean of the world" (Page II- 1), only a general discussion of the marine environment is warranted. However, to refer the reader to the Department of the Interior's DEIS for "Proposed Increase in Acreage to be Offered for Oil and Gas Leasing on the Outer Continental Shelf" seems inappropriate, in view of the voluminous, critical comments of NMFS/NOAA/DOC concerning the numerous deficiencies of this DEIS, including the section on 'Description of the Environment. " Sections II and III of the subject DEIS, although not completely satisfactory to us, are nevertheless greatly improved over those presented in the Discussion Paper we previously reviewed. Therefore, unless other agencies or individuals submit comments requesting additional data or information on fisheries or the marine environment that NMFS could perhaps seek to provide, if specifically requested to do so within a reasonable period of time, we will have no further comments or suggestions to offer relative to development of the FEIS for this program. IX -22 W16/GAF June 4, 1975 William Aron Director, Office of Ecology and Environmental Conservation, EE George P. Cressman Director, National Weather Service Maritime Administration DEIS: Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations. Subject DEIS fails to address the effects of weather and climate on equipment systems now in use in the OCS zone. Omitted entirely is discussion of weather and sea limitations on equipment, either by general type or category. Therefore, the potential for limited or catastrophic failure is not addressed, and the environmental impact conclusions consequently are deficient in this respect. IX-23 Date 3 June 1975 To -. W. Aron From : R. L. Swanson V^' \"i/ U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration ENVIRONMENTAL RESEARCH LABORATORIES MESA Project Office Old Biology Building S.U.N.Y. Stony Brook, New York 11794 Maritime Administration DEIS: Title Xl-Vessels Engaged in Offshore Oil and Gas Drilling Operations. The discussion of environmental and ecological effects in the subject EIS is very brief and general. While this general discussion appears accurate insofar as it goes, it is a very brief treatment of the most significant impacts In Table 12 (p. A-29) it appears that the concentrations of light and heavy oils from the work of Frankenfeld are re- versed, i.e., the light oils should be 3.5 ppm and heavy oils should be 0.7 ppm (which is consistent with Fig. 5 on p. A-22) . IX-24 UftHTEO 5TATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration Rockvnle, Md 20852 June 30, 1975 TO: Sidney R. Galler FROM: William AronjJA SUBJ: MarAd DEIS: Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations Attached are late comments on subject document from the Coastal Zone Management Office. Attachment IX-25 <# pUJTlQv '>6-l9l fc ^]|J|j]Vn U.S. DEPARTMENT OF COMMERCE PJational Oceanic and Atmospheric Administration Rockville, Md. 20852 JUN * 737 , Oate June 19, 1975 Reply to Attn, of: To From Subject: William Aron EE Edward T. La Roe OCZM Comments on MarAd DEIS: Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations This document has been reviewed only in the narrow context of the relation of the proposal to the Office of Coastal Zone Management and its responsibilities. In this context it would appear that OCZM's role and activities have been described in the subject document in a restrictive and incorrect fashion. For example: p. IV-16: The CZM Act provides much more than simply "a frame- work for Federal -state cooperation in planning for onshore and offshore development induced by OCS operations..." OCZM's charge under the Act is, of course, far broader, and its role in OCS planning should be set in this wider context. The correct title of the Act is The Federal Coastal Zone Management Act, not the Coastal Zone Land Management Act. p. IV-19: Incorrect title. p. IV-21 : Perhaps the greatest strength of the CZMA is that programs developed under it will not be single purpose plans, but will address a multitude of coastal resource needs and uses. States should not only give priority to developing plans prior to OCS leasing, but must be sure to include a balanced approach, taking into account these other values and resources. The implication that this is in fact a weakness of the program should be removed. p. IV-22: Correct the 4th sentence to read: "Further, as part of its coastal management programs, established under the Coastal Zone Management Act of 1972, particular arenas within a state's juris- diction can be set forth as non-available^drill ing operations, if such a decision is based on a rational and balanced decision-making process. " Thank you for the opportunity to comment, IX-26 Department of Commerce National Oceanic and Atmospheric Administration (NOAA) The Environmental Data Service of NOAA in their letter of June 11, 1975 (DX6/LAP) in essence objected to Chapter II in which reference is made to a Department of Interior DEIS for a complete description of the marine environment. The comment was considered valid and Chapter II has now been restructured and, although the description of the marine environment remains somewhat general due to the nature of the program, referring the reader to other environmental impact statements has been removed, additional information is included, and a section on the geology of oil and gas accumulation has been added. The undated memorandum from the Associate Director for Resource Management, F3 (F34/BEH) of the National Marine Fisheries Service (NOAA) makes a similar comment to that received from the Environmental Data Service, therefore the disposition contained in (1) above also applies to the NMFS comment. Memorandum from the Director, National Weather Serviced dated June 4, 1975 (W16 'GAF) states that the DEIS fails to address the effects of weather and climate on equipment systems now in use on the OCS zone, etc. This comment is not considered valid as the EIS, beginning on page 1- 14 describes the design of the equipment, including mooring devices, for the drilling rigs to operate in the most adverse sea and wind conditions. Memorandum from R. L. Swanson of Environmental Research Laboratories dated 3 June 1975. Para. 1 - Chapter II has been revised as stated in (I) and (2) above. Para. 2 - Corrections to Table 12 (p. A-29) have been made in accordance with the comment. Memorandum from Edward T. LaRoe, Office of Coastal Zone Management (OCZM), dated June 19, 1975. Comment relative to p. IV-16: Corrections have been made to reflect a broader role of OCZM under the Coastal Zone Management Act. The title of the Act has also been changed in accordance with the comment. IX-27 Comment relative to p. IV- 19: Title of the Federal Coastal 'Zone Management Act has been corrected. Comment relative to p. IV-21: The comment relates to the second paragraph on page IV-21 of the DEIS. This paragraph has now been deleted in its entirety in response to the comment. Comment relative to p. IV -22: Corrections have been incorporated verbatim. IX-28 UNITED STATES ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION WASHINGTON, D.C. 20545 Mr. George C. Steinman, Chief Environmental Activities Group Maritime Administration U.S. Department of Commerce Washington, D. C. 20230 Dear Mr. Steinman: This is in response to the letter of May 2, 1975, from Dr. Sidney R. Galler inviting the U.S. Energy Research and Development Administration (ERDA) to review and comment on the Department's Draft Environmental Statement (MAEIS-2302-75022-D) prepared by the Maritime Administration for its Title XI Vessels engaged in Offshore Oil and Gas Drilling Operations. It is quite obvious that future exploratory and drilling operations to be environmentally acceptable should have and need the most modern drilling and support vessels. We should like to provide the Department with some comments generated by our review. We understand that, although our comments are being transmitted after the comment period has expired, for which we apoligize, they may be helpful in the preparation of the Final Statement. The Statement carries with it a general feeling that because of the infinite vastness of the oceans that minor insults resulting from oil and gas pro- duction will not be noticeable but still it recognizes the need for quantitative data on the effects of low level chronic discharges of petroleum and drilling chemicals. The Statement does an adequate job of summarizing the important aspects of the marine ecosystem and its basic components. There is yery little depth on how the system functions, and how the different components interrelate, but overall, the major obvious subsystems that may be affected by oil production and related activities are mentioned. If the purpose of the Statement is to list and briefly discuss these potential problem areas, then it is satisfactory. However, we feel the Statement should discuss the relative importance of the systems potentially affected to the continued existence of a balanced marine ecosystem, and what effect degradation of the separate subsystems by oil related activities would have on the system as a whole and the potential losses to other users of the marine ecosystem. IX-29 7 ^6-l9l fe Mr. George C. Steinman - 2 - A good description of the various types of offshore oil and gas drilling vessels was presented (Chapter 1, part c), but it would be more advantageous to summarize with estimates of: (a) the number of each type of craft that may be required for various future levels of exploration; (b) the cost of each type of vessel; (c) the advantages and/or disadvantages of each type of rig; and (d) the DOI leasing schedule, where these vessels would be used and in what quantity. We feel that Chapter 2 should have a more extensive bibliography, and it should show some specific relationship to the Administration's task of evaluating what marine environmental aspects will be impacted by OCS exploration and extraction activities. Thank you for the opportunity to transmit these comments at this time. Sincerely, /j/sl^H. Pennington "" Office of the Assistant Administrator for Environment and Safety cc: CEQ (5) IX-30 Energy Research and Development Administration (ERDA) As a result of a request for an extension of the comment period ERDA submitted comments on the DEIS by letter dated September 8, 1975. The comments were, in the most part, general in nature and are responded to beginning with paragraph three as follows: Page 1, para. 3 - By rewriting and or revising many of the Chapters and sections it is believed that the final EIS no longer carriers a permissive attitude toward low level chronic discharges of petroleum and drilling chemicals. Page 1, -para. 4 - The restructured Chapter III, together with the original Appendix A, now provide a more complete description of the effects of oil to the marine ecosystem as a whole which reflects the intent of the comment. Page 2, para. 5 - This comment contains four parts - (a) thru (d) and are responded to in that order as follows: (a) The numbers of each type of drilling vessel constructed or comtemplated under the Title XI Program is now included in Chapter I. (b) The cost of each individual unit has not been broken down, however, the total cost for each design group has been included in Chapter I. (c) The advantages and'or disadvantages of each type of rig are believed to be adequately described in Chapter I. The type of rig to be constructed is based on the anticipated service over the life- time of the rig. (d) To include the DOI leasing schedule and where and how many Title XI vessels would be used is not considered pertinent information when the nature of the Title XI Program is only to guarantee the construction loan. However, Chapter II has been revised to indicate the environment in which the vessels will, or could, operate. Page 2, para. 6 - Additional references have been added to Chapter II and, it is believed that the rewritten Chapter III responds to the comment regarding marine environmental aspects. IX -31 CLAIRt T. DEDRICK EDMUND G. BROWN JR. SECRErARY GOVERNOR OF RESOURCES BUILDING CAUFORNIA 1416 NINTH STREET 95814 (916)445-5656 esoulc.s Boord ,n, s! Nav,oa„on and \\JX „tr.m,/<'l o.c-ado R,.., Boord -1 3oy Conscvot.on and menl :l Pa. It, „ : R* xer.l t.l *a-er Rturn: ^^O' . *c i Waste Moncge.n.nt Board '.rote L .«.d! Commission 5'aif iUcitniai. on "Board THE RESOURCES AGENCY OF CALIFORNIA C^.'^.uVS^c.^.V."! SACRAMENTO, CALIFORNIA AUG 2 9 1975 Mr. George C. Steinman U. S. Department of Commerce Maritime Administration Washington, D. C. 20230 Dear Mr. Steinman: The State of California has reviewed the "Draft Environmental Impact Statement, Maritime Administration, Title XI, Vessels Engaged in Offshore Oil and Gas Drilling Operations (MA-EIS-7302-75022-D)", undated, which was submitted to the Office of Planning and Research (State Clearinghouse) within the Governor's Office. The review was coordinated with the Depart- ments of Conservation, Transportation, Health, Fish and Game, Parks and Recreation, and Water Resources; the Air Resources Board; the State Water Resources Control Board; The Reclamation Board; the San Francisco Bay Conservation and Development Commission; the Solid Waste Management Board; and the California Coastal Zone Conservation Commission. Our comments on the draft statement are set forth below. California Coastal Zone Conservation Commission Concerns The Commission staff has two general comments which are discussed below. 1. While the biological setting and impact sections appear to be thorough, social setting and impact are completely ignored. Clearly, facilitating the availability of additional oil and gas has an impact upon a society and world which uses such resources. In particular, we would suggest that the final EIS more adequately assess the cumulative effects of resource depletion on a national as well as global scale, and the growth-inducing impacts upon so- ciety of increasing resource use, which this project would facilitate. A discussion of global social impact, while perhaps seemingly trivial, is actually essential, as the DEIS states that the new vessels may operate in any ocean in the world, and it is a fact that the United States currently uses over fifty percent (50$) of the world's resources. IX-32 Mr. George C. Steinman -2- 2. A more thorough discussion of alternatives, without regard to the sponsor's authority or jurisdiction, is needed. Of course, alternatives to the proposed action, including, where relevant, those not within the existing authority of the responsible agency should be rigorously explored and objectively evaluated. In particular, the alternatives of energy conservation and develop- ment of other energy sources should be further explored. Department of Parks and Recreation Concerns The Draft Environmental Impact Statement is not restrictive enough to enforce improvements in the handling of oil by vessels engaged in offshore oil and gas drilling operations. The report includes tables showing the results of oil spills in the past, and indicates that we can expect the same in the future with possibly greater frequency in overall magnitude due to increased oil drilling activity. We would like to believe that with more stringent controls pollution could and should be reduced even with a greater number of wells drilled. It has been recognized by the California Coastal Commission that we have multiple uses of the resources found along our coastal shoreline, and that the use of one resource should not have detri- mental effects on other uses. This would apply to the potential oil pollution conflict with our many state beaches and parks and the recreation they provide. The involvement here is not only with people, but also the effect an oil pollution accident would have on the wildlife that inhabits these areas. In this respect we recommend the inclusion on page IV-1 of the following regula- tions as mitigation measures: 1. No oil facilities constructed under Title XI will be located off the California coast within 6 miles of designated Areas of Special Biological Significance or habitats of rare or endangered species; 2. Produced formation waters shall be reinjected into the oil production zone. Exceptions shall be granted only when the lease * holder can provide adequate data to indicate the waste does not indicate acute or chronic toxicity to representative resident species of aquatic organisms; 3. Waste discharge to marine water shall not exceed 15 ppm of oil in water. IX-33 Mr. George C. Steinman -3- m 2 91975 Fish and Wildlife Concerns The Department of Fish and Game' has several general comments which are discussed below. Attachment No. 1 contains comments which are to be considered as an integral part of the State's comments. The Department finds that the draft EIS is inadequate and presents a funding proposal that would lead to practices which increase the probability of oil spills, and which, therefore, would be in conflict with various federal and state agencies' policies and regulations. However, should the recommendations detailed in our response to specific sections be incorporated and thereby become recommendations of the Department of Commerce, particularly the section on mitigation measures, we would find the proposal mini- mally acceptable. The data presented in Tables IIIA-4, A-5, A-6 and page VI-1 clearly details that pollutants will be discharged into the marine environ- ment. Such discharges would be in conflict with the intent of other agencies such as described in the regulatory concepts of Section 10(a) of the Deepwater Port Act of 197 2 *- (P.L. 93-627), and the Department of the Interior's Environmental Impact State- ment and Senate Joint Review of the Deepwater Port Act.i/ The former regulation indicates that "Regardless of relative merits, the occurrence of oil spills in offshore regions remains unaccep- table, both economically and environmentally." The latter indicates, in part, "the Act empowers the Secretary of Transporta- tion to prescribe regulations . . . required, (a) to prevent pollution of the marine environment." The EIS also appears to conflict with State of California interests The EIS should recognize that California coastal resources are considered to be limited and in need of protection and that meeting the many needs will require close coordination of various interests. The Preliminary Coastal Plan of the California Coastal Zone Conservation Commission indicates that "the essence of the plan is that the coast should be treated not as ordinary real estate but as a unique place, where conservation and special kinds of development should have priority." The plan goes on to indicate, in part, that "energy installations allowed on the coast must be subject to stringent environmental safeguards." The EIS should recognize and address these concepts. 1/ Draft Environmental Impact Statement for Deepwater Port Regula- tions, Department of Transportation, U. S. Coast Guard, Deep- water Port Project, Office of Marine Environment and Systems, Washington D. C. 20590, 6 Jan. 1975. IX-34 Mr. George C. Steinman _ 4 _ AUG a 9 1975 In contrast to the main body of the report, the sections on General Description of the Marine Environment as well as Appendix A, regarding the harmful effects of oil pollution, are very good. We see value in rewriting the report in the style of those sections in order to avoid what appears to be a project-justification approach presenting inadequate supporting data. Heavy emphasis, for example, is placed on the capabilities of "one major builder" without reference or data indicating the capabilities of the industry as a whole, the "average builder" or the range of capa- bilities of all builders. Oil and Gas Concerns The State Division of Oil and Gas has a number of specific comments which are included as Attachment No. 2. These comments are to be considered as an integral part of this letter. Recommendation It is' recommended that the final statement respond to the concerns and include the views set forth in these comments. Thank you for the opportunity to review and comment on the draft statement. Sincerely, Secretary for Resources Attachments Air Mail cc: Director of Management Systems State Clearinghouse Office of Planning and Research 1^00 Tenth Street Sacramento, California 9581^- (SCH No. 750519^2) IX-35 Attachment No. 1 Specific Comments on the Draft Environmental Impact Statement Maritime Administration, Title XI Vessels Engaged in Offshore Oil and Gas Drilling Operations (MA-EIS-7302-75022-D) By Department of Fish and Game, State of California The following comments refer to specific items of the draft environmental impact statement. 1. Page 1-13. A description of the type structure and an eval- uation should be made of the 9^-5-foot platform planned for EXXON in federal waters off Santa Barbara, California. This type of structure could become common off the California area influencing effects of offshore drilling on the marine environment. 2. Page II-7, last paragraph. A good example of an upwelling area, and its effects on world fisheries, occurs in the proposed offshore drilling area off California. The report should elaborate on this and the importance of the Northern anchovy, Engraulis mor dax, fishery and possible adverse effects of oil spills upon larval fish in the area. Larval fish and eggs occur near the surface in the pelagic waters off California. Appendix A indicates toxic fractions of oil are accommodated by sea water and persist in the water column, whereas heavy oils form surface slicks. The data also indicate larval fish, as well as the small pelagic fish tested were gener- ally more susceptible to low concentrations of oil. The report should elaborate on this subject. 3. Page III-3, second complete paragraph, last sentence. This statement should recognize that toxic agents have been used to increase fluidity of drilling mud and that these should not be discharged as toxic waste. 4. Page III-8, first complete paragraph. Same comment as page III-3. 5. Page 111-10, first complete paragraph, first sentence. This statement dismisses the fact that most pollution incidents are avoidable and a large percentage are intentional or a result of negligence. 6. Page 111-24, third complete paragraph. Same comment as page III-3. IX-36 Attachment No. 1 Page 2 7. Page 111-62. second paragraph. Change the first sentence to read as follows: Erosion of the shoreline may be considerable unles s the runoff is controlled by installations such as vegetat ive ground" cover , concrete or steel bulkheads .... (addition • underlined) . Vegetative ground cover has been effectively employed in California to prevent erosion from project areas du ring the period of construction. This is effective in localities having extended dry periods without rainfall followed by a short rainy season. 8. Page III-71.1 second paragraph, third sentence, should include anchovy as an important resident species in place of lingcod which appears in the report as "lingood." The "little" tuna should not be included as a migratory species for California. It is not clear if this sentence represents important commercial fish landed in California or the United States. The information, as corrected, would represent California fish landings. 9. Page IV- 1. Mitigation Measures. We recommend inclusion of the following regulations as mitigation measures: To better assure prevention and control oil spills: (1) no oil facilities constructed under Title XI will be located off the California coast within 6 miles of designated Areas of Special Biological Significance or habitats of rare or endangered species; (?.) produced formation waters shall be reinjected into the oil production zone. Exceptions shall be granted only when the lease holder can provide adequate data to indicate the waste does not exhibit acute or chronic toxicity to representative resident species of aquatic organisms; (3) wastes discharged to marine waters shall not exceed 15 ppm of oil in water. These requirements are necessary to protect living marine resources The data contained in Appendix A indicates the lighter fractions of oil can disperse from a surface layer of oil into the underlying waters. These light fractions are also the more toxic components of crude oil. Tests (page A-10, Table 5) indicate the water soluble fraction of crude oil killed 50 percent of a test popula- tion of Mysids (a shrimplike animal) when the oil exceeded 8.7 ppm oil in water. Also the Water Quality Objectives of the Water Quality Control Plan for Ocean Waters of California as well as the Pish and Game Code would be violated should visable oil enter the State's waters from project facilities. IX -.37 Attachment No. 2 Specific Comments on the Draft Environmental Impact Statement Maritime Administration, Title XI Vessels Engaged in Offshore Oil and Gas Drilling Operations (MA-EIS-7302 -75022-D) By Division of Oil and Gas Department of Conservation, State of California The following comments refer to specific items of the draft environmental impact statement. 1. Page 1-5 ? Table 1-1. The table should show the numbers of wells in each category drilled by the program vessels. 2. Page 1-6, Section C. The approximate costs of all types of program vessels should be given. Portions of this section appear to be taken from other sources; if so, the sources should be iden- tified. 3. Pages 1-53 and 1-5^ > paragraph 5. Many workover operations are not mentioned. To avoid an exhaustive treatment of the subject, a very brief and general summary should suffice. 4. Pages 1-59 and I-6o, paragraph 6b. If U.S.C.G. regulations do not apply to vessels of less than 300 gross tons, this should be mentioned in relation to the voluntary compliance with U.S.C.G. regulations. 5. Pages 11-11 and 11-12. Not all of the shelves are dammed. Most of the California shelf north of the Santa Barbara Channel is not dammed. 6. Page II-14. Many other submarine or drowned subaerial features of deltas, such as prodeltas, island arcs, distributary channels, and interdelta plains are worth mentioning. 7. Chapter III, Introduction and Section A. The relationships between the proposed project and the impacts of the increased oil activity should be fully explained in terms of probable increase of impact caused by the project. Because some of the impacts, such as tanker spills, are far removed in time and sequence frcm the proposed project, the degree of removal should also be stated. The primary source of environmental impacts is not stated, and this omission makes full understanding of "Subchapter A' : difficult. If the primary effect of the proposed project is increased construction of drilling and service vessels, tivjn the Increased construction and 3 possibly, increased use of the vessels in U. S. waters would be the primary sources of environmental impact, and the primary IX-38 Attachment No. 2 Page 2 impacts would be from construction of the vessels (III.B.5)? from the vessels' being on location (III. A. 19)? from drilling (III.A.), and from pipe laying (III.B.3)* Other sources and impacts, such as those from production (particularly platform production), and transportation, should be considered as secondary. 8. Page III-l, Table III A.l. The hydrocarbons in this table should be called "resources", not "reserves", unless their econom- ically feasible producibility has been proven. It is not clear whether this table refers to possible total hydrocarbons in place or to possible recoverable hydrocarbons. 9- Pages III-3 through III-8. The section on blowouts is not clear. 10. Page III-ll, Section A, 2. Drilling accidents should be sep- arated from production and transportation accidents. 11. PageIH-13> Section A. 3- Note that none of the spills in this section are labelled as originating from a drilling or service vessel. 12. Page III-16, Section A. 4. None of the spills in this section originate from a drilling or service vessel. The second sentence is unclear, but a 500 million barrel find is not "medium" in California, and probably not in the United States. 13. Page IH-18, Section A 5. None of the spills in this section originate from a drilling or service vessel. 14. Page 111-22, Section A. 6. None of the spills in this section are labelled as originating from a drilling or service vessel. 15. Page HI -25 ? etc., Sections A.8-A.18. All of these sections deal with oil spills. As noted above, a direct link between oil spills and the construction of drilling or service vessels has not been established in this report. 16. Page IV-29, Section H. The first offshore drilling was at Summerland field in California in 1896. 17. Page V-l, Section A. Even if the U. S. offshore program were terminated, there would still be a demand for drilling and large service vessels overseas. IX-39 State of California The State of California by letter dated June 25, 1975 requested an extension of time for submittal of comments until, August 21, 1975. The Resources Agency of California letter of August '29, 1975, submitted comments from four agencies. The large majority of these comments deal with subjects that apply only to oil and gas development of the outer continental shelf and are properly addressed by the Department of the Interior at the time environmental impact statements are prepared by that department for oil and gas leasing on the outer continental shelf. Response to the comments, however, are made as follows: California Coastal Zone Conservat i on Commissio n C oncerns Page 1, para. I - To include a discussion on global social impact as a result of the improbable use of Title XI rigs conducting exploratory drilling in other parts of the world would be an overwhelming task and the results unreliable and meaningless in an EIS such as this. Page 2, para. 2 - Chapter V has been revised and now incorporates the main issues of this comment. De partment of Parks and Recreation Concern s Page 2, para. I - Comment is considered as an opinion and is not specific enough for a detailed response. Page 2, para. 2 - More stringent controls to prevent oil spills are contained in the May 1975 report "An Analysis of the Feasibility of Separating Exploration from Production of Oil and Gas on the Outer Continental Shelf" by the Congress of the United States - Office of Technology Assessment. Page 2, para. 3 - The following numbered paragraphs are responded to: 1. - Oil facilities are not constructed under the Title XI program. 2. - This EIS is not a regulatory vehicle and, therefore, cannot impose either existing or proposed regulations. Regulations for oil and gas drilling operations are under the auspices of the Department of the Interior. 3. - Response to paragraph No. 2 above also applies to this comment. IX -40 Fish and Wildlife Concerns Pages 3 and 4 - The Fish and Game Department's general comments are concerned with the possibility that Title XI vessels may conflict with state and federal regulations and policies, thereby increasing the risk of oil pollution. The contrary to this concept is the case, however, because not only are the vessels constructed to rigid standards established by the regulatory bodies, but when they become operational must comply with all state and federal legulations, laws and policies that apply to oil and gas exploration of the outer continental shelf. Regarding comment on page 4 relative to "one major builder, it is believed this has reference to the description of the various types of drilling vessels contained in Chapter I. It is not the intent, or the belief that Chapter I emphasizes one owner but describes typical drilling vessels in which Title XI applications have been, or could be, ] eceived for construction loan guarantees. Attachment No. 1 Page I, para. 1 - The EIS applies only to floating drill vessels and not fixed production platforms. Page I, para. 2 - Chapter II has been revised to reflect the comment relative to Northern anchovy. Page I, para. 3 - Chapter III has been completely revised and now i ef lects the comment relating to the discharge of drilling mud. Page I, para. 4 - Response to paragraph 3 above applies to this comment. Page 1, para. 5 - Chapter III has been completely revised and reflects the more stringent standards regarding intentional discharges. Page 1, para. 6 - Response to paragraph 3 applies to this comment. Page 2, para. 7 - Comment is valid and Chapter III, page III- 80 reflects the change. Page 2, para. 8 - In restructuring Chapter III it was found necessary to completely replace the section on commercial and sport fishing. Beginning on page III- 67 the new section is entitled 'Impacts on Commercial and Sport Fisheries" and addresses California along with other coastal states. IX-41 Page 2, para. 9 - Response to these comments relative to regulations has been made on page IV-15. Attachment No. 2 Page i, para. 1 - Table 1-1 has been replaced by a more meaningful table in which this comment would not apply. Page 1, para. 2 - Costs have been included and portions of Chapter I have been rewritten. Page 1, para. 3 - The comment states that many workover operations are not mentioned but does not state what is lacking. It is felt that the workover operations are adequately described. Page 1, para. 4 - Page 1-43 has been revised to reflect this comment. Page I, para. 5 - Page II -7 has been revised to reflect this comment. Page I, para. 6 - The section on drowned valley's etc. , has been deleted as extraneous material not considered pertinent to an EIS of this nature. Page I, para. 7 - Chapter III has been entirely restructured and now reflects the majority of the issues contained in the comments. Page 2, para. 8 - Table IIIA-1 has been removed. Page 2, para. 9 - The section on blowouts has been rewritten and clarified. Page 2, para. 10, 11, 12, 13 and 14 - The statement attempts to address both direct primary and direct secondary effects of OCS oil and gas drilling operations. The effects of development, production, transportation, and storage can be considered direct secondary effects. Page 2, para. 15 - Chapter III has been completely revised. The effects and behavior of crude oil in the marine environment are independent of source. Page 2, para. 16 - Page IV- 20 has been revised to reflect this comment. Page 2, para. 17 - Comment is concurred in however, where Title XI vessels are concerned the program would be terminated. IX-42 Earl M. Starnes STATE PLANNING DIRECTOR State of Florida Department of A&mimHiratinn Division of State Planning 660 Apalachee Parkway - IBM Building Tallahassee 32304 (904) 488-2371 June 30, 1975 Reubin O'D. Askew GOVERNOR U. Gov. J. H. "Jim" Williams SECRETARY OF ADMINISTRATION United States Department of Commerce Maritime Administration Environmental Activities Group Washington, D. C. 20230 Dear Sir: Functioning as the state planning and development clearinghouse contem- plated in U. S. Office of Management and Budget Circular A-95, we have reviewed the following draft environmental impact statement: Maritime Administration Title XI, Vessels Engaged in Offshore Oil and Gas Drilling Operations MA-EIS-7302-75022D SAI: 75-1792 E During our review we referred the environmental impact statement to the following agencies, which we identified as interested: Department of Natural Resources, Board of Trustees of the Internal Improvement Trust Fund, Department of Pollution Control, Game and Fresh Water Fish Commission, and Department of Transportation. Agencies were requested to review the statement and comment on possible effects that actions contemplated could have on matters of their concern. Based on the review of the interested state agencies, the Florida Clearinghouse has no adverse comments on this statement. In accordance with the Council on Environmental Quality guidelines concerning statement on proposed federal actions affecting the environment, as required by the National Environmental Policy Act of 1969, and U. S. Office of Management and Budget Circular A-95, this letter, with attachments, should be appended to the final environmental impact statement on this project. Comments regarding this statement and project contained herein or attached hereto should be addressed in the statement. IX-43 United States Department of Commerce Page Two June 30, 1975 We request that you forward us copies of the final environmental impact statement prepared on this project. EEM/K/dt cc: Mr. J. Landers Mr. W. N. Lofroos Mr. Harmon Shields Dr. Tim Stuart Mr. Estus Whitfield Mr. Walter Kolb Sincerely, '< mn.r.U ,*. n fh,a « fi «> DOLPH BRISCOE DIVISION OF PLANNING COORDINATION \0 .** ^J^ffc^' GOVERNOR ROSE DIRECTOR May 15, 1975 ^ TO: Mr. Joe_ B. Harris, Division of Planning Coordination/Natural Resources 05/27/75 Mr. Bill Duncan, Division of Planning Coordination/Energy Resources 06/06/75 SUBJECT: DRAFT ENVIRONMENTAL IMPACT STATEMENT: MARITIME ADMINISTRATION TITLE XI - VESSELS ENGAGED IN OFFSHORE OIL AND GAS DRILLING OPERATIONS Enclosed for your review and comment is the draft environmental impact state- ment prepared by the Department of Commerce for the Maritime Administration Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations. The Intergovernmental Coordination received a limited number of this draft environ- ment impact statement, so it will be necessary for you to forward it to the next DPC Section listed by the date after your name. Energy Resources should return the draft to this section. Please submit your comments to this section; for questions contact Albert D. Schutz at 6156. Thank you -for your assistance. Sincerely, Wayne N. Brown, Chief Intergovernmental Coordination WNB/ws Enclosure IX-65 P. 0. BOX 12428. CAPITOL STATION, AUSTIN, TEXAS 78711 Phone 51 2/475-2427 Olfices Located in Sam Houston State Office Building TEXAS AIR CONTROL BOARD PHONE 512/451-5711 8520 SHOAL CREEK BOULEVARD CHARLES R. BARDEN, P. E. EXECUTIVE DIRECTOR JOHN L. BLAIR Cha irman HERBERT W.WHITNEY, P.E. Vice-Cha irman AUSTIN, TEXAS - 78758 ALBERT W. HARTMAN, JR., M.D. E.W. ROBINSON, P.E. CHARLES P. JAYNES JAMES D. ABRAMS, P.E. FRED HARTMAN WILLIE L. ULICH. Ph.D., P.E. JOE C. BRIDGEFARMER, P.E, May 23, 1975 Mr. Wayne N. Brown, Chief Intergovernmental Coordination Office of the Governor Division of Planning Coordination P. 0. Box 12428, Capitol Station Austin, Texas 78711 Dear Mr. Brown: Our agency has reviewed the Draft Environmental Impact Statement: Maritime Administration Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations. We feel this document adequately assesses the impact of this project on the environment. . We see no conflict with this project and our State Implementation Plan. Thank you for the review opportunity. If we can be of further assistance, please contact me. erely yours, .1 Stewart, P.E. Director Control and Prevention IX -66 COMMENTS Natural Resource Section PES Maritime Administration Title XI Vessels Engaged in Offshore Oil and Gas Drilling Operations BACKGROUND . The Maritime Administration Title XI program is a vital part of the 1970 Merchant Marine program designed to rejuvenate the declining U. S. Flag Merchant Marine Fleet both for economic and national defense reasons. This program has as its central purpose the encouragement of construction and maintenance of a privately owned and operated Merchant Marine Fleet of modern design and balanced composition. The Federal government guarantees financial obligations and holds all mortgages and notes as security for these obligations. This Draft Environmental Statement deals with the impacts of the offshore gas and drilling and support vessel program [offshore program) and centers on modern drilling and support vessels for exploratory work in discovering petroleum sources located on the Outer Continental Shelf. GENERAL REVIEW . 1. A general discussion of the role of states and other political sub- divisions in resource management may be found on page IV-18. The Coastal Zone Management Act of 1972 is described. The federal consistency provision is mentioned and the need for all federal agencies to coordinate federal plans with approved state coastal zone management plans is explained. 2. Land use legislation pending in Congress and its possible impacts are briefly described. 3. This DES recognizes the need for effective Federal-State coordination because geologic boundaries for exploration and development activities do not correspond to political boundaries. Effective regulation of OCS production and related activities, therefore, requires concerted action at all levels of government. 4. Quite correctly, in a statement on page IV-19, it is indicated that each state's paramount interest is to protect fisheries, harbors, coastal wetlands, beaches, and other natural resources from the devastating longlasting damage inflicted by the extraction of a non- renewable resource as well as to foster continued economic and social well-being. 5. The DES also indicates that under p. L. 92-583 any Coastal Zone Management Plan must provide "adequate consideration of the National Interest involved in the citing of facilities necessary to meet requirements which are other than local in nature." There are important limitations to the Coastal Zone Plan as a vehicle for joint OCS planning. The act creates a non-mandatory system, and its financial IX -67 incentives may be insufficient to accomplish its lofty aims. "The potentially conflicting' interests are so complex as to render impossible fully satisfactory solutions to all issues. At a minimum, however, state Coastal Zone plans can contribute to more rational decisions concerning OCS and Coastal Zone Uses by improving interaction between state and federal decision-makers prior to committing OCS and onshore resources to development." 6. The DES also includes an objective analysis of the impact which can result from conflicting state and regional regulations for environ- mental and safety conditions. Offshore drilling rigs, vessels, and other equipment are subjected to a variety of state and/or regional controls which alter their designated construction and restrict their operation within certain areas. COMMENTS : In summary, this DES does an excellent job of describing the many programs dealing with OCS development and Coastal Zone Management. The report is very thorough and comprehensive. The environmental impacts stemming from public subsidization of the offshore drilling and support vessel program are of a general nature having to do with the potential for spills and other adverse impacts resulting from oil and gas drilling, trans-shipping, and pumping through pipelines within a marine environment. Because of this generality, there are no specific items dealing with particular Texas conditions and no recommendations for improvement are deemed necessary. L_#^aa/VW..^vi --rtjw-:^,, '■' SAI No. Applicant . EXAS COASTAL AND MARINE COUNCIL Sen. A. R. "Babe" Schwartz Chairman Galveston May 28, 1975 Rep. Neil Caldwell Vice Chairman Alvin Richard Keith Arnold Austin Truman G. Blocker. Jr.. MD Galveston John C. Calhoun, Jr. College Station R. N. Conolly Corpus Christi James J. Flanagan Port Arthur Sen. Roy Harrington Port Arthur Sen. 0. H. "Ike" Harris Dallas Joe B. Harris Austin Mrs. J. W. Hershey Houston Mr. Wayne N. Brown, Chief Intergovernmental Coordination Office of the Governor Division of Planning Coordination PO Box 12428 Capitol Station Austin, Texas 78711 Dear Mr. Brown: I have briefly reviewed the document entitled DRAFT ENVIRONMENTAL IMPACT STATEMENT: MARITIME ADMINISTRATION TITLE XI - VESSELS ENGAGED IN OFF- SHORE OIL AND GAS DRILLING OPERATIONS, and the Texas Coastal and Marine Council has no objections or other constructive comments to make. Si nee rely , 6. Joe C. Moseley II jjt >^_ Rep. Greg Montoya Elsa MCM/ma j John J Pepe Houston Rep. Pike Powers Beaumont Cecil Reid Austin Charles P. Turco Beaumont Joe C. Moseley Executive Director IX-71 POST OFFICE BOX 13407 / AUSTIN. TEXAS 78711 / PHONE (512) 476-3561 State of Texas The Office of the Governor distributed copies of the DEIS to various agencies of the government of Texas for their individual review and comments. The consensus of opinion was that the DEIS adequately described the project and only one comment was submitted for consideration in the preparation of the final statement. The comment from the State of Texas relates to Table IIIA-l on page III- 1 of the DEIS concerning OCS oil and gas reserves. This table has been completely removed and Chapter III restructured in its entirety. IX-72 June 19, 1975 2000 West Loop South • Suite 2222 • Houston, Texas 77027 (713)627-3030 • TWX 9108815063 Clay Chiles president Mr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs Department of Commerce Washington, D.C. 20230 Subject: Comments - Draft Environmental Impact Statement Prepared by The Department of Commerce for the Maritime Administration Title XI Dear Mr. Galler: First, I would like to express my appreciation for the opportunity of reviewing the draft environmental impact statement which was prepared by the Department of Commerce for the Maritime Admin- istration Title XI - Vessels Engaged in Offshore Oil and Gas Drill- ing Operations. The impact statement presents an excellent back- ground on the development of the offshore drilling industry and the environmental factors that are related to this portion of the industry, Benefits of the Maritime Administration Title XI financing for offshore drilling vessels were only briefly covered in the draft environmental impact statement. Some of the benefits that we feel should be highlighted include: 1. The Maritime Administration Title XI financing was one of the major factors allowing U.S. offshore drilling companies to build offshore drilling vessels before foreign concerns entered this important market. As a result, many of the U.S. offshore drilling companies are in an advantageous competitive position in the world market. IX-73 A Subsidiary of The Western Company of North America Mr. Sidney R. Galler -2- June 19, 1975 2. The Maritime Administration Title XI financing allowed several smaller U. S. companies to partici- pate in the expansion of the offshore drilling industry which might not have been possible otherwise. This should provide a healthier competition in the offshore drilling industry and ultimately provide lower costs of petroleum products for the consumer. 3. The Maritime Administration Title XI financing has provided additional vessels for work in the United States Continental Shelf areas as the demand for these vessels expanded during the past few years. For example, the Western Company of North America has two vessels, the Western PACESETTER II and the Western PACESETTER III which were financed under the Title XI program and are now working offshore in the Gulf of Mexico. We would like to particularly emphasize our concurrence with the third alternative to the MARAD program which is outlined on Pages V-4, 5 and 6 of the impact statement. The current genera- tion of offshore drilling vessels is designed to meet stringent environmental requirements by the U.S. Coast Guard, the American Bureau of Shipping, the U.S. Geological Survey, and the Department of Defense as well as provisions of IMCO's 1973 Marine Pollution Convention. Therefore, we concur with the statement that it would be difficult for MARAD to attempt to devise environmental standards above and beyond those presently required. Although private industry has not undertaken work on a centrally coordinated basis for the design of offshore equipment to prevent pollution as pointed out on Page V-6, the companies involved in the offshore drilling industry have through conferences and cooperation between drilling contractors, equipment vendors and operators developed the designs for many new sophisticated pieces of equipment and substantially improved existing equipment and systems to prevent pollution. Such equipment includes: blowout prevention equipment, riser and subsea control systems, well testing equipment, vessel sewage systems, drilling mud control systems, and well completion equipment and systems. IX -74 Western Oceanic, Inc. • A Subsidiary of The Western Company of North America Mr. Sidney R. Galler -3- June 19, 1975 In summary, we feel that the U.S. Department of Commerce Maritime Administration has acted judiciously and equitably in requiring that the offshore drilling vessels built under the Title XI program meet the environmental standards set by other related U.S. governmental agencies which have developed sound environmental standards over many years. In addition, the MARAD Title XI program has been extremely beneficial for the U. S. offshore drilling industry and should be continued in the future under the current guidelines. Sincerely yours, Clay Chiles President BKV:dd IX -75 Western Oceanic, Inc. • A Subsidiary of The Western Company of North America JI£BternOc eanic Incorp qrgjwi IX-76 THE OFFSHORE COMPANY R O. BOX 2765 • HOUSTON, TEXAS 77001 713/622-5670 • Cable.OFFDR.ILL June 5, 1975 Mr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs United States Department of Commerce Maritime Administration Washington, D. C. 20230 Dear Mr. Galler, Please find enclosed our comments to your proposed Environmental Impact Statement for MarAd's Title XI program - Vessels Engaged in Offshore Oil and Gas Drilling Operations. If you have any questions relating to our comments or otherwise, we will be glad to assist you. Sincerely, THE OFFSHORE COMPANY y Harold F. Leyh Staff Engineer 1/ HFL/cs Attachment IX-77 COMMENTS BY THE OFFSHORE COMPANY TO ENVIRONMENTAL IMPACT STATEMENT AS PROPOSED BY MARITIME ADMINISTRATION ON MAY 2, 1975 Page III-3 A few revisions should be made so that the layman obtains a proper conception of the role, drilling mud plays. In the first paragraph, last two lines are suggested to be changed as follows: "At the ocean bottom surface a pipe (riser) further carries the cuttings in suspension . , ...etc. Sporadically, depending on water depth, when soft formation is suddenly encountered it might be required to release the mud column in the riser, whole or in part, by opening a dump valve at the ocean floor". Page III-8 Second Paragraph, Change the word "often" to "occasionally" which is factual and consistent with the first sentence of the last paragraph on that same page, Third Paragraph. Change to read " offshore operations c ould discharge a variety of materials. ,, .etc. " Page III-9 Table III A-2, With reference to mercury pollution by sacrificial anodes tests by Dow Chemical and Shell with Galvalun anodes have shown that the mercury discharge added only .08 parts per trillion to the v:ater flowing through under the platform, against a natural average seawater mercury contents of 1200 parts per trillion. Hence, one can hardly state that IX-78 Page 2, the biological impact is significant, even locally. Page 111-10 It is recommended to leave out any estimated figures on worldwide oil pollution, whether through natural seepage, pleasure boats or blowouts. Such figures necessarily are very rough estimates, moreover they do not belong in an Environmental Impact Statement, which is supposed to cover the impact of oil drilling on the environment within the United States ' outer Continental Shelf and which should restrict itself to as many hard and relevant facts as possible. Page III-ll & 12 The Table III A- 3 lists 2 oil spills connected with drilling operations during the 1953-1972 period. According to the text on Page III-ll, the Santa Barbara 1969 blowout accounts for the entire oil spill listed in the table. Hence, either the other event was not an oil spill or the estimated figure of 18,500-780,000 barrels for the Santa Barbara spill is incorrect. It is noted here that an "estimate" with such a range is hardly worth quoting in an official document. It is not understood why a lot of statistical data on oil spills from tankers, platforms and pipelines is included where the Environmental Impact Statement is supposed' to cover only the offshore drilling operation aspect. It is recommended that most of Chapter 2 thru 6 be eliminated and the remainder (if any) be written in such a way that it is comprehensible to the layman, and restricts itself to ex- ploratory drilling and offshore supply vessels. It is pointed out here that exploratory drilling as done by the IX-79 Page 3. drilling units intended to be the subject of this Environmental Impact Statement (see listing on Page 1-8) is not done by platforms. The latter are fixed units used for production drilling. It is stressed here that due to the closely spaced multiple wells drilled from a production platform, a blowout in one causes, an inherently greater risk for a large oil spill than exists when drill- ing one exploratory well. The text on the bottom of Page III-ll and top of Page III- 12 shows oil spill figures which total to 84,000 barrels as a minimum and 161,000 barrels as a maximum. However, Table III A-3 shows the same arithmetic as 84,000 to 135,400 barrels. One of the maximum figures must be wrong. Page 111-24 We object to the use of as yet completely unfounded state- ments such as: "Some scientists believe that over the life of a field these intentional releases may damage the environ- ment as much as the large accidental oil spill." We request that this sentence be eliminated. The E,I,S, is not to serve as a summary of speculative statements. Further on Page 111-24 & -25, we object to stating mud dis- charge figures without stating a time period over which this discharge takes place. In pollution matters, the discharge rate is more important than quantity, The 110 tons of mud may represent a rate cf 0.1 tons/hour but since barite has a specific gravity of 4.5 and the mud contains approximately 90% water, it amounts to slightly less than 2 cubic feet of IX -80 Page 4. barite solids per hour. The realization of the 1,120 wells may take 10 to 15 years. Page 111-29 In the second paragraph, the sentence, "Furthermore, the oil released from sediments may contain pesticides .. .etc . is objected to as being too speculative and not relevant to the subject of the report. Page 111-31 The second sentence of the second paragraph, "Energy imparted by winds. .. .etc. " is not clear. It could be eliminated . Page V-3 thru 6 With reference to Chapter B, we do not see the importance of it in an environmental impact statement, the requirement of which is based on the presumption that the MarAd program continues as is. Besides, the economic logic at various points in the text is questionable. With respect to Page V-6, we certainly do not see a need for the Federal Government to enter into research activities concerning design of equipment. Page VI-1 Chapter VI, Para. A, does not belong in the E.I.S. for Mobile Offshore Drilling Units and Support Vessels. The pollution impact by steel mills and other industries neces- sary for construction of drilling units and vessels is sup- posed to be dealt with in separate E.I.S.'s relating to those industries. If one would allow Chapter VI to be included, then one v.'ould also have to look at the possible extra machinery and equipment needed by the steel mills or other industries and, in turn, would have to be manufactured, thereby forming a pollution risk, etc., etc.. One may assume IX -81 Page 5, that any material necessary for the construction of Mobile Offshore Drilling Units and Support Vessels can be manufactured within the standards set by E.P.A. Don't blame the Offshore Drilling activity for steel mill pollution! Appendix Page A-23 thru -30 On Page A-23 thru A-26 of the Appendix, an interest-- ing expose, by itself, is given on the very young field of chemical communication. It is felt that this does not belong in the E.I.S, since it is dealing with a field which is in its infancy and no positive and con- clusive figures can be presented showing the relation- ship between an oil spill rate and the interruption of, or impedance with, chemosensitivity. The E.I.S. should not allow itself to penetrate itself into all the various intricate mechanisms by which marine life can be detri- mentally affected but should keep itself to measurable and conclusive total results. In other words, : 'how much". Let the scientists figure out "why". The same comment, to some extent, holds true for Page A-27 thru -30. It is a fascinating scientific resume on toxidity levels but it does not serve the purpose of the E.I.S. and does not belong in it as such. General One very interesting research activity by Gulf Universities Research Consortium is overlooked. It is described in 1975 O.T.C. Paper Nr.2384 and states that no harmful, sometimes IX -82 Page 6, beneficial, effects in the ocean were measured as a result of offshore drilling. Other beneficial effects, which do exist, are not addressed at all in the E.I.S. For example, improved and more timely weather data collection, better search and rescue systems due to more frequent sailing of supply boats and fly over of helicopters and. in general, a vast expansion and acceleration of research activity and use of computer techniques in the fields of ship dynamics, stress mechanics, welding, corrosion, and fatigue, just to name a few, which benefit other re- lated industries and designs , thereby reducing their environmental impact risk. One important trend should be mentioned which is that the continued search for offshore oil brings the drilling unit further and further from shore and into deeper water (a 5000 ft. depth design is presently under consideration). This means that any accidental oil pollution requires much more time to reach shore allowing more time for clean up preparation while drifting to shore but also increasing the chance for breakdown as described in the E.I.S. (evaporation, photo chemical, biochemical, etc.) The increased water depth will greatly reduce the pollu- tion danger to ocean bottom life firstly because of the longer sinking tine and consequently greater dillution; secondly, because bottom life reduces as depth increases, IX -83 Page 7 In conclusion, we can state that, taking our above comments into consideration, the E.I.S. is correct in that it cannot produce hard evidence of long range detrimental environmental impacts. IX -84 T he Offshore Compa ny Disposition of comments submitted by the Offshore Company are identified as they relate to the page number of the DEIS shown on the attachment to their letter of June 5, 1975. Page III- 3 - Comment is reflected on page III- Z. Page III- 8 - Comment is reflected in the revision of Chapter III on page III- 7 1. Page III - 9 - Table IIIA-2 has been removed from the Statement. Page III- 10 - A more accurate estimate of worldwide oil pollution has been included in the revision of Chapter III on page III- 12. By including data on worldwide oil pollution from all sources, the oil pollution from offshore oil and gas operations can be viewed in perspective. Pages III -LI and 12 - Comments referring to oil spill volumes have been addressed by changes on pages 111-13. The EIS addresses the environmental impact of offshore oil and gas field development, production, transportation, and storage operations because these activities are direct results of exploratory drilling. Page III- 24 - Comment is reflected in the levision to Chapter III on page III- 12. Page III- 24 and 25 - The comment concerning mud discharge figures has been noted, and changes to the text have been made on page 111-73. Page III - 29 - The statement: "Furthermore, the oil released from sediments may contain pesticides . . . etc. " has been retained for purposes of presenting a complete analysis. Page III- 31 - Comment is noted on page III- 52. IX-85 AMERICAN PETROLEUM 1801 K STREET, NORTHWEST INSTITUTE WASHINGTON, D.C. 20006 WILSON M. LAIRD. Director Department of Exploration Affairs (202) 833-5722 May 14, 1975 Mr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs Maritime Administration U.S. Department of Commerce Washington, D.C. 20230 Dear Sid: As requested in your May 7 letter, enclosed are comments on the draft environmental impact statement prepared by the Maritime Administration on "Vessels Engaged in Offshore Oil and Gas Drilling Operations." Although restricted primarily to Chapter II, "General Description of the Marine Environment," and Chapter III, "Environmental Impact of OCS Drilling, Servicing and Support Operations," I hope my somewhat hurried review will prove helpful. Enclosed is a copy of the Spring 1975 issue of FLUOR Magazine which is devoted to The Marine Environ- ment. Your attention is directed particularly to the article beginning on page 11 entitled, "The Offshore Ecology Investigation." Sincerely, WML : am j cc: Paul Wollstadt Enclosures - 1) FLUOR Magazine 2) Fishing's Great Along the Louisiana Coast I 3) The Gulf is Rigged for Fishing 4) New Estimates of Nation's Oil and Gas Resources IX -86 Comments on Draft Environmental Impact Statement Maritime Administration Title XI - Vessels Engaged in Offshore Oil and Gas Drilling Operations p. 11-10 The section entitled "Geological Framework of the Continental Shelf" is naive beyond belief. In fact, this apparently has been written with the idea that the reader is so poorly informed that he can ' t understand even the most elementary geological facts. It is totally unacceptable and should be entirely rewritten. The definitions of the various physiographic forms found in the sea bottom should be made to conform with the definitions in the "Glossary of Geology" published by the American Geological Institute. Chapter III, p. III-l The resource figures used herein will be outdated when the new USGS estimates are released in June 1975. p. III-3, A. Primary Source Geophysical investigations do not determine if oil and gas formations are present. This type of survey simply gives information as to the thickness of potential oil- bearing formations and possibly something about the geo- logical structural configuration of the area under study. In no case are the drilling muds and cuttings discharged directly into the ocean because the materials are not returned IX -87 to the surface due to the depth of the water. It would be impossible to drill a hole in this fashion. The drilling mud and the cuttings are returned to the floor of the rig by means of a riser pipe which in turn is used to return the mud to the drilling face where the bit is cutting the forma- tion. The cuttings and the mud, if no longer usable, may be disposed of overboard provided any oil which might be contained therein is removed. p. III-8 There is no positive evidence that the disposal of the drilling mud and cuttings causes any damage to the ocean. In fact, the drill cuttings may provide a hard substrate upon which bottom dwelling organisms may live even where such were not able to survive before. In addition, the amount of salt water released into the ocean is so small that it is diluted beyond recognition a very short distance from the point of discharge. p. 111-10 I question the figures which are quoted without reference which are attributed to the Woods Hole Oceanographic Institute and the Coast Guard. I refer you to the accompanying table 1-5 taken from the National Academy of Sciences report entitled "Petroleum in the Marine Environment" published in 1975. You will note that the NAS report estimates that the amount IX-88 PETROLEUM IN THE MARINE ENVIRONMENT TABLE 1-5 Budget of Petroleum Hydrocarbons Introduced into the Oceans Input Rate (m ta) fl Source Best Estimate Probable Range Reference Natural seeps 0.6 0.2-1.0 Wilson e/ a/ (1973) Offshore production 0.08 0.08-0.15 Wilson era/. (1973) Transportation LOT tankers 0.31 0.15-0.4 Results of workshop Non-LOT tankers 0.77 0.65-1.0 panel deliberations Dry docking 0.25 0.2-0.3 Terminal operations 0.003 0.0015-0.005 Bilges bunkering 0.5 0.4-0.7 Tanker accidents 0.2 0.12-0.25 Nontanker accidents 0.1 0.02-0.15 Coastal refineries 0.2 0.2-0.3 Brummage (1973a) Atmosphere 0.6 0.4-0.8 Feuerstein (1973) Coastal municipal wastes 0.3 - Storrs(1973) Coastal, Nonrefining, industrial wastes 0.3 - Storrs(1973) Urban runoff 0.3 0.1-0.5 Storrs(1973), Hallhagen (1973) River runoff 1.6 - Storrs (1973), Hallhagen (1973) TOTAL 6.113 mta, million metric tons. barrels per barrel of oil produced. This loss factor should be representative of other U.S. offshore opera- tions. In this case, the total loss due to minor spills from U.S. offshore operations is 1,500 barrels per year (based on 1971 U.S. offshore production of 618 mil- lion barrels, McCaslin, 1972). In some other parts of the world, quantitative re- ports suggest that losses due to minor spills may aver- TABLE 1-6 Comparison of Estimates for Petroleum Hydrocarbons Annually Entering the Ocean, circa 1969-1971 Authority (Millions of Tons per Annum) Source Marine transportation Offshore oil production Coastal oil refineries Industrial waste Municipal waste Urban runoff River runoff" SUBTOTAL Natural seeps Atmospheric rainout TOTAL PHC input from recreational boating assumed to be incorporated in the river runoff value. "Based upon assumed 10 percent return from the atmosphere. MIT SCEP USCG Impact NAS Report Statement Workshop (1970) (1973) (1973) 1.13 1.72 2.133 0.20 0.12 0.08 0.30 - 0.2 - 1.98 0.3 0.45 - 0.3 - - 0.3 - - 1.6 2.08 3.82 4.913 7 ? 0.6 9.0* 7 0.6 11.08 7 6.113 age 10 times greater than those that occur in U.S. waters. Accordingly, the loss due to minor offshore spills outside the United States is estimated to be 62,000 barrels per year (based on 1971 foreign offshore pro- duction of 2,580 million barrels per year, McCaslin, 1972). Thus, the total worldwide loss of oil through minor spills during normal offshore operations is esti- mated at 63,500 barrels or approximately 0.01 mta. The estimate of oil loss via field brine discharges is obtained in a similar manner. Brines that are pro- duced along with the oil and gas are usually discharged into the sea after passing through an oil-water separator. These brines still contain small amounts of oil. Under present federal regulations, this amount of oil cannot exceed 50 parts per million (ppm) of produced brine. According to the U.S. Department of the Interior (1972b), 7.3 barrels of waste oil per day were dis- charged into the Gulf of Mexico, along with 180,000 barrels per day of brine, resulting in an average oil content of 41 ppm. This occurred during the daily production in the Gulf of Mexico of 1.2 million barrels of oil during 1971. It is equivalent to a loss of 6.0 barrels per million barrels of oil produced. Depending on the separator used, the oil content of treated brines in other parts of the world may be up to four times higher than the level allowed in the Gulf of Mexico at present. While worldwide data on volumes of produced brines arc not available, it is not likely that economic self-interest will allow higher brine percentages from producing wells in other parts of the IX- 89 of oil going into the ocean on a worldwide basis from oil drilling operations is about 1%. p. 111-24 In discussing the matter of chronic spills, the statement is made, "Some scientists believe that over the life of a field these intentional releases may damage the environment as much as the large accidental oil spill." In the first place, this statement has not been proven and, secondly, it implies that the releases are always intentional. p. 111-36 It should be pointed out that, in listing what effects oil may have on an organism, there is the possibility that the oil may have no lasting effect at all. p. 111-37 The statement, "The incorporation of hydrocarbons, includ- ing carcinogens, is of particular concern because they accumu- late in marine organisms and can be transferred to other organisms through the food web" , is not necessarily substantiated in fact. For example the NAS report says: (p. 37) "Measuring the effects of oil on marine life is difficult. Each experimental study must include an adequate number of controls whereby single variables are evaluated through interdisciplinary approaches so that the effects of different biological para- meters can be resolved. Many earlier studies of the effects of oil cannot be adequately evaluated because (1) the experimental work was not properly de- signed (for example lack of adequate IX -90 replication) and (2) the oil concentra- tions and other variables that affect marine life were inadequately monitored." p. 111-39 I find Table IIIA-8 difficult to rationalize, particularly when it comes to fish. Fish will swim away from any area in which they find life unbearable for any reason. The only exception would be where the spill occurred in some enclosed or semi-enclosed basin where the nektonic life was unable to escape. In addition, this table does not indicate what con- centrations would be lethal. Obviously, practically any substance unnatural to the organism would be lethal if the organism were exposed to it long enough and in great enough quantity. That all oil is not lethal to fish and some other marine life, one has only to make observations in the Santa Barbara Channel where the marine life has been exposed to natural seeps of considerable size over tens of thousands of years. For larva, the conditions would obviously be different as such might not have the mobility of mature forms . p. 111-42 As far as birds are concerned, it is true that an oil spill is a disastrous occurrence in local areas. Bird mortality is high under natural conditions and under the pressure of hunting. I doubt if as many birds die due to exposure to oil spills as are killed illegally each year, IX-9L especially in the case of migratory birds which fly to countries having less rigorous hunting laws than the United States. In any event, it is highly unlikely that all the birds on a given flyway would be entrapped in an oil spill, so recovery would not depend only on those which were unfortunate enough to be caught in any given oil spill. p. 111-46 The sewage which is produced by human occupants of the rigs and platforms is regulated by OCS order number 8 of the U.S. Geological Survey. A copy of that portion of the order which covers this matter is appended herewith. It is 'worth noting, that this treatment is far better than the plants which are daily discharging contaminated effluent into the Potomac River here in the Washington area. p. III-7-, 72 In the discussion of commercial fishing, it is interest- ing to note that no mention was made of the fishing industry in Louisiana. California is listed as the second most important fishing state, but no mention is made of which state is first. Incidently, there is no Table III-B-1 in the copy which I read. It is also notable by its absence that no mention is made of the sport fishing associated with the offshore rigs in the Louisiana area where excellent fish- ing is well documented. IX-92 (b) All electrical generators, motors, and lighting systems shall be installed, protected, and maintained in accordance with the most current edition of the National Electric Code and API RF 500A and B, as appropriate. (c) Marine-armored cable or metal-clad cable may be substituted for wire in conduit in any area. (9) Sewage disposal systems shall be installed and used in all cases where sewage is discharged into the Gulf of Mexico. Sewage is defined as human body wastes and the wastes from toilets and other receptacles intended to receive or retain body wastes. Following sewage treatment, the effluent shall contain 50 ppm or less of biochemical oxygen demand (BOD), 150 ppm or less of suspended solids, and shall have a minimum chlorine residual of 1. mg/ liter after a minimum retention time of fifteen minutes. B. The requirements of subparagraphs 2. A (3), (4), (8), and (9) shall apply to all mobile drilling structures used to conduct drilling or wofkover operations on Federal leases in the Gulf of Mexico. Asi^tM y2; ^-^Asl^lS Robert F, Evans Supervisor Approved: October 30, 1970 Russell C. Way land Chief, Conservation Division IX-93 p. A-18 If there is a direct correlation between light oil concentration and cancer it should be definitely noted and the source of the information indicated. May 14, 1975 Submitted to; Sidney R. Galler IX-94 DEPARTMENT off the INTERIO GEOLOGICAL SURVEY Forrester (703) 860-7444 FROM For Release on Receipt (May 7, 1975) WILSON M. LAIRD DIVISION OF EXPLORATION NEW ESTIMATES OF NATION'S OIL AND GAS RESOURCES AF C AIRS New estimates of the Nation's crude oil and natural gas liquids and natural gas have been prepared by a team of geologists of the U. S. Geological Survey, Department of the Interior. The estimates have been compiled by a new Resource Appraisals Group under the leadership of Harry Thomsen, a petroleum geologist at the Survey's Denver, Colo., office. Only summary figures of estimates are available now. A full, more detailed report, now in final preparation, will be delivered by the end of May to the Federal Energy Administration, and will be made public at the same time. Although considerably lower than the Survey's estimates of March 1974, the new estimates indicate that the target for exploration is substantial. For example, undiscovered recoverable resources of oil are estimated to be in the range of 50 to 130 billion barrels and 320 to 655 trillion cubic feet of natural gas. In addition, some 30 billion barrels of oil and 180 trillion cubic feet of gas are estimated to be recoverable from unexplored parts of known fields. In discussing the new appraisals, Dr. V. E. McKelvey, USGS Director, said that they are derived primarily from geologic evaluations, and, as in any dynamic process, are subject to considerable change with time and with application of new geologic data and techniques. Moreover, the new estimates have not assumed high prices because of the difficulty of assessing their impact to date, but the estimates would be increased by assumptions of continued higher prices and exploration on the OCS beyond 200 meters. (more) IX-95 McKelvey said that the Thomsen group started its special mission in February 1974 with guidelines to "think in other categories," and to develop a set of appraisals that would make the wide range of estimates more useful for planning purposes. Departing from previous approaches to oil and gas estimates, the Thomsen group — involving more than 70 regional specialists — analyzed more than 100 possible petroleum provinces individually, and combined them into 15 regions comprising the onshore and offshore conterminous lower 48 States and Alaska. Offshore estimates were made for continental shelf areas out to water depths of 200 meters (600 feet) . New methods and techniques for resource appraisals were adopted, particularly geologic evaluation on a province-by-province basis. Additionally, large quantities of new geologic and geophysical data, hitherto not available to the USGS, were obtained and used. "Perhaps the most important departure from previous approaches," McKelvey said, "was that the group applied probability limits for the estimates. " "By applying probabilities to these appraisals," McKelvey said, "we hope to establish, in a numerical sense, how much confidence can be placed in the various oil and gas estimates that now exist." The USGS Director said that, "the problem is somewhat analogous to that of the insurance actuarian or statistician who, for example, might be asked how long a person can expect to live, and how much his insurance rates should therefore be. The statistician might be 95 percent sure that the person will live another year, but only 5 percent sure that he will live another 40 years." "Similarly," McKelvey said, "the Thomsen group has tried to determine how much petroleum they can be 95 percent sure is available, and on the long-shot end of the scale, how much petroleum they are only 5 percent sure :s." "Bearing this in mind," McKelvey said, "it is obvious that at the 95 percent confidence level, the estimated resource is small, but the chances are 19 in 20 that such amounts of petroleum do exist. On the other end, the 5 percent confidence end of the scale, the estimates are much larger, but the chances are only 1 in 20 that they are correct." "The net effect of tightening previous estimates to fit the 95 and 5 percent confidence levels is to reduce the range of all estimates," McKelvey said. (more) IX-96 "In considering such estimates," McKelvey emphasized, "it is most important to differentiate the categories being appraised, which fall under two general headings — reserves and resources. Distinguishing between them gives a very rough count of 'birds in hand' and an estimate of 'birds in the bush. ' Reserves are identified deposits known to be recoverable with current technology under present economic conditions, and can be estimated with a high degree of confidence. Resources, on the other hand, carry a high degree of uncertainty although some under- standing of their potential is critical for the future. They include materials that may have been identified, but cannot now be extracted because of economic or technologic factors, as well as economic or subeconomic materials that are yet to be discovered." "We are using probabilities in the case of resources," McKelvey said, "because in this broad category, we are trying to decipher the unknown, and this is particularly true of frontier areas in which not a single exploratory well has been drilled, and there is no assurance that petroleum in commercial quantities exists at all." "The effect of changing economic and technologic conditions could appreciably affect the estimates," McKelvey said. "Thus, there are no 'true' or 'false' or 'right' or 'wrong' estimates for all time. They can, at best, be the very roughest guidelines and are subject to con- siderable change over time. For example, at the present time, in listing both reserves and resources, the Thomsen group assumed the usual 32 percent recovery factor; that is, that on the average, only 32 percent of fhe oil actually in the ground is recovered with sufficient economic incentive. The application of advanced secondary or tertiary oil recovery techniques, might, in the reasonably near future, boost the rate to 40 percent. It is not inconceivable that recoveries of 50 or even 60 percent may be achieved eventually. In addition, improvement of drilling technology and exploration science and technology might also increase the estimates. It is possible that the present meager data on frontier areas is misleading and has caused an underestimate of their potential. Finally, the petroleum resources of the Nation's continental shelves from 200-2,500 meters (600 feet to 7,500 feet) has not been estimated due to lack of data and this could materially alter the estimates." While the new estimates are much lower than those released a year ago, they are higher than those of another U. S. Geological Survey scientist, Dr. M. King Hubbert, and are in the same range as those of the National Research Council of the National Academy of Sciences, and of those of the National Petroleum Council, which were used to develop Project Independence Blueprint estimates of possible future production. (more) IX-97 The new use of the probabilistic approach in resource estimation allows a better comparison of previous differing estimates. For example, viewed in the context of the Thomsen group estimate, the 1974 Hubbert estimate of 55 billion barrels yet to be produced beyond proved reserves, which is lower than the Thomsen group estimate of 85 billion barrels for equivalent categories at the 95 percent probability level, would have a higher than 95 percent probability. Even though somewhat broader in its assumptions, the previous low estimate released by the Survey in 1974 of 200 billion barrels would have a much smaller probability than 5 percent judged by the probabilities established by the Thomsen group. "These and the other higher and lower estimates all carry the same message on several important policy questions," McKelvey emphasized. "All indicate that substantial amounts of fluid hydrocarbons remain to be discovered if exploration is encouraged. All indicate that one of the largest targets for future production is the oil presently remaining in place that might be available if recovery technology is advanced. All emphasize the importance of frontier areas, and all show that it is necessary soon to develop otner sources of energy as the mainstay of our future energy supply." (Note to Editors: The new estimates are summarized in the attached table.) 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QJ c •— !_ i_ U CM X OJ O OJ 1 QJ O u 4-1 QJ CLd* in ro X 3 o u O > LA 4J E 4-< ro o »— OJ ^ E o 4-1 CA •^ •— in l- Q. in o. O o ro E 4-1 CO >4- X X QJ X i_ OJ X >4- in o_ O 4-1 LU l_ LU 14- CC \- O LU CN CA| vO| IX-99 American Petroleum Institute Disposition of comments submitted by the American Petroleum Institute are identified as they relate to the page number of the DEIS shown on the attachment to their letter of May 14, 1975. Page 11-10 - The Statement is written for the intelligent layman; a previous understanding of the marine environment is not presumed. Chapter II has been edited, however, to include a discussion of natural phenomena. Page III- I - The resources figures of Table IIIA-1 have been removed from the Statement. Page III- 3 - The Statement has been revised to indicate that a geophysical survey is used to locate geological formations which may potentially contain oil and gas. The Statement concerning "the discharge of drilling mud and cuttings into the ocean" has been removed. Chapter III has been thoroughly revised and includes a detailed discussion of the disposal of drill cuttings and drilling muds. Page III- 8 - As noted previously, the revision of Chapter III includes a more thorough discussion of the disposal of drill cuttings and drilling muds. Page III - L0 - Comment is reflected in the revision to Chapter III on page IH-13. Page 111-24 - Comment is reflected in the revision to Chapter III on page III- 12. Page III- 36 - Chapter III has been revised to provide a more thorough discussion of the environmental effects of various discharges, especially of oil discharges. Page III- 37 - The quoted statement from the NAS report has been included in the Statement on page III- 49. Page III- 39 - The text of Section III-E notes the mobility of fish and their tendency to avoid areas which are sensed as noxious or locally adverse. Page 111-42 - Comment regarding "entire breeding populations" and "all the birds on a given flyway" is reflected by a minor change in the revision to Chapter III on page III- 63. IX-100 Page 111-46 - Comment is reflected in the revision to Chapter III on page III- 21. Page III-7-72 - The revision to Chapter III includes a more thorough discussion of fishing and the effects of offshore oil and gas operations upon fishing. IX-101 K. '#. WALDORF President Zapata Marine Service, Inc. June 12, 1975 Dr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs Department of Commerce Washington, D.C. 20230 Dear Dr. Galler: With reference to the draft of the Environmental Impact Statement Maritime Administration Title XI vessels engaged in offshore oil and gas drilling operations, we have reviewed that portion of Chapter I which refers to offshore service vessels. Aside from obvious spell- ing and typographical errors, the below listed items are submitted as suggested changes to the draft. Chapter I Page 1-60, line 16 line 18 Page 1-62, line 3 ■ line 4 ■ line 8 ■ Yours very truly, - change HP range to 3000 - 8000 HP - change speed range to 12 - 16 knots change fuel capacity to 90,000 - 130,000 gallons change bulk capacity to 2000 - 6000 cubic feet change cost estimate to 2-1/2 - 5 million dollars /nrd IX -102 1601 HOUSTON CLUB BUILDING • HOUSTON. TEXAS 77002 Zapata Marine Service, Inc. Comments relative to horsepower, speed and quantities have been incorporated and the figures revised accordingly. IX -10 3 H. E. DENZLER 101 NORLAND AVE. NE* ORLEANS, LA. 70 I 14 july 3, 1975 THE HONORABLE SIDNEY R. G A L L E R DEPUTY ASSISTANT SECRETARY DEPARTMENT OF COMMERCE MARITIME ADMINISTRATION WAS! INGTON D. C. 20 '30 DEAR "HI, SECRETARY: YOUR INVITATION TO REVIEW AND COMMENT UPON THE DRAFT ENVIRONMENTAL I M I- A C T STATEMENT OF THE MARITIME ADMINISTRATION TITLE XI - VESSELS ENGAGED IN OFFSHORE OIL AND GAS DRILLING OPERATIONS IS VERY MUCH APPRECIATED. ALSO APPRECIATED IS THE TIME EXTENSION GRANTED BY CAPTAIN STEINWAN, UNTIL JULY 15, FOR THE SUBMISSION OF THESE COMMENTS. THE IMPACT STATEMENT IS VERY WELL DONE AND IT PRESENTS AN EXCELLENT REVIEW OF THE DEVELOPMENT OF THE OFFSHORE DRILLING INDUSTRY. INASMUCH AS THE MARITIME ADMINISTRATION HAS ALREADY EMBARKED ON THE TITLE XI PROGRAM IT IS SUGGESTED THAT IT MIGHT BE PROPER, AND BENEFICIAL, TO INCLUDE SOME POSITIVE STATEMENTS INDICATING THE REASONS IvHY M\R\0 IS WILLING TO CON- TINUE AND IF NECESSARY EXPAND THIS PROGRAM. SOME REASONS MIGHT BE; TO EN- COURAGE U.S. CONSTRUCTION VERSUS FOREIGN; TO ENABLE SMALLER COMPANIES TO PARTICIPATE IN THE ACTIVITY; AND TO ASSIST IN FINANCING SUFFICIENT NUMBERS OF UNITS AND VESSELS FOR ORDERLY AND TIMELY DEVELOPMENT. IT MIGHT ALCT BE OBSERVED TH?T THE U.S. ENERGY SUPPLY IS ALREADY CONSIDERABLY LESS THAN DEMANDS BY SOME 35 - 50/o AND THIS HAS A DECIDEDLY ADVERSE EFFECT ON THE U.S. BALANCE OF PAYMENTS POSITION. DISTURBING IS THE USE AMD CITATION OF ITEMS THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY PAPER ON THE "ANALYSIS . •. SPILL STATISTICS", E C A U S E FRANKLY, THEY ARE CONFUSING AND INACCURATE IN RELATION TO THE AIMS AND PURPOSES OF YOUR IMPACT STATEMENT. ONE ITEM WHICH iS PARTICULARLY TAKEN FROM T I ' ~ OF OIL THESE FIGURES, FROM THE OIL AND GAS JOURNAL, INDICATE THE EXTREME UNLIKELY- HOOD OF SUCH MONSTEROUS "FINDS" EVER BEING DISCOVERED IN WATERS UNDER OUR IX -104 T H E H C N R A B L E I DNE Y R. GALLEH JULY 3, 1975 - 2 JURISDICTION. SINCE NO bUCH "FINDS HAVE BEEN DISCOVERED IN DRILLING THE BEST PROSPECTS OVER THE PAST TWENTY FIVE YEARS THE PROBABILITIES OF DIS- COVERING SUCH IN THE FUTURE ARE PRACTICALLY NFGLIGIBLE. CONSIDERING THESE FACTS ONE V U S T WONDER ABOUT THF VALIDITY OF THE ASSUMPTIONS MADE IN SECTION 4 OF CHAPTER III SINCE NONE OF THEM CAN BE BASED ON FACTS RELATED TO OFFSHORE OPERATIONS IN WATERS UNDER THE JURISDICTION OF THE UNITED STATES, AND ONLY DUBIOUSLY TO WORLDWIDE WATERS. AN EXAMINATION OF TABLES IIIA-5 AND IIIA-6 REVEALS A DECIDED VARIANCE BE- TWEFN THE QUANTITIES ATTRIBUTED TO PLATFORMS AND PIPELINES IN THE TWO TABLES. WHICH IS TO BE BELIEVED? ANOTHER QUESTION IS THF RELATION BETWEEN TERMINALS AND OFFSHORE OPERATIONS? IT IS SURELY OBVIOUS FRO'" THE QUANTITIES SHOWN THAT ALL THESE SPILLS CANNOT BF CONNECTED tt I T H OFFSHORE OPERATIONS. IN THE PIPELINE PORTION OF THE TABLE IIIA-6 QUANTITIES APPEAR WHICH HAVE NO RELATION TO U.S. OFFSHORE DRILLING OR PRODUCING OPERATIONS; SPECIFICALLY THOSE IN THE PERSIAN GULF AND COASTAL CHANNELS ALONG THE GULF COAST. THESE ARE NOT TRULY RELEVANT TO THE PURPOSE OF THIS IMPACT STATEMENT. AS FOR SECTION 5. TANKERS, THE SAME COMMENTS APPLY AS- HAVE BEEN PREVIOUSLY EXPRESSED. HERE WE APPARENTLY HAVE AN UTT'CVi-T TO APPLY STATISTICS DERIVED FROM BOF1LDW I DE TANKER OPERATIONS TO AN EKTIR-LY DIFFERENT OPERATION. THE USE OF TANKERS IN OFFSHORE DRILLING AND PRODUCING OPERATIONS COULD AT BEST BE ONLY A MINUTE PORTION OF PETROLEUM MOVEMENT BY TANKERS. IN FACT TWO MODERN TANKERS W I L L CARRY MORE THAN _OME OF OUR MAJOR OFFSHORE FIELDS WILL PRODUCE IN AN ENTIRE YEAR.' (iTEM 4 ON PACE 111-57, OR AT LEAST A REFERENCE TO IT, COULD INSERTED IN THIS SECTION 5 FO; CLARITY). FINALLY M.I.T. TABLES IIIA-4 AND lllA-7 COULD BE ELIMINATED BECAUSE OF THEIR MEAN INGLESSNESS TO U.S. OPERATIONS. PLEASE BE ASSURED THAT THESE COMMENTS ARE NOT INTENDED TO BE CRITICAL OF YOUR IMPACT STATEMENT WHICH IS VERY WELL DOME. THFY ARE SUBMITTED IN THE INTEREST OF F'ROVIDING INFORMATION WHICH YOU MAY WISH TO USE IN COMPILING THF FINAL ST A TEMENT . S I N CFRELY , H. E. DFN?lER, JR. OFFSHORE CONSULTANT IX -10 5 H. E. Denzler, Jr., Offshore Consultant Mr. Denzler submitted comments on the DEIS in response to an invitation to review and comment sent to the International Association of Drilling Contractors. Beginning with the third paragraph of Mr. Denzler 's letter the comments are responded to as follows: Page 1, para. 3 - Chapter I has been revised to provide a better understanding of the Title XI program and also reflects the beneficial aspects to U.S. companies versus foreign competition. Page I, para. 4 - The comment relative to energy supply and demand is acknowledged however, due to wide fluctuations, it was considered prudent not to include this comment. Pages I and 2, para's. 5,6,7 and 8 - The comments contained in these paragraphs take exception to data taken from the Massachusetts Institute of Technology Paper "Analysis of Oil Spill Statistics. " While the comments may be valid the EIS must rely on published data. Page 2, para's. 9 and 10 - Although Chapter III has been rewritten the tables identified as IIIA-5 and IIIA-6 in the DEIS have been kept for the same reasons stated above. Page 2, para. II and 12 - These comments also take exception to the published MIT data therefore the same response applies to these two paragraphs. IX -106 U Hi JM 1 JllXi 1751 N STREET. NW WASHINGTON. DC 20036 202 6720670 FOR -j- a t x 7 Roger S Foslcr LAW Richard A Frank 20 June 19 75 PmiHftmdmm A XTT*^ Paul Gew* u ■C\iM XJ Eldon V C GreenbciQ Marcia Greenberger SOCIAL COPY - Robert M Mailman Benjamin w Heineman. Jr LeonardC Meeker POLICY Joseph N Onek Marilyn G Rose Lois J Schiller _ _ , , Edward P Scon Dr. Sidney R. Galler Horbwisemmei Deputy Assistant Secretary for a™^,^*. Environmental Affairs United States Department of Commerce Washington, D.C. 20230 Maritime Administration Draft Environmental Impact Statement on Title XI Financing Program for Construction of Offshore Drilling Vessels Dear Dr. Galler: We are writing in response to the solicitation of views by the Federal Maritime Administration ("Marad") on the draft Environmental Impact Statement (MA-EIS-7302-75022-D) released on May 2, 1975, relating to the Title XI financing program for the private construction of offshore oil and gas drilling and service vessels (the "EIS") . Our comments on the EIS are submitted on behalf of the Environmental Defense Fund, the Natural Resources Defense Council, and the National Parks and Conservation Association. These national environmental organizations have a total membership of approximately 100,000 persons, and each was a plaintiff in a lawsuit which led to Marad 1 s preparation of an environmental impact statement relating to its tanker construction program ( Environmental Defense Fund v. Peterson , D.D.C. Civil Action No. 2164-72). In addition, these organizations have taken a continuing and active interest in Marad ' s other programs, as well as in the subject of marine pollution generally. IX - 10 7 Dr. Sidney R. Galler 20 June 1975 page 2 Summary of Comments (1) The EIS does not provide enough factual information on the Marad financing program to enable an understanding of its operations, thereby making it difficult to determine whether the program should continue, and if so, in what form. (2) The EIS' treatment of the environmental impact of offshore drilling and service vessels is overly general. There is insufficient information to assess oil-spill effects from drilling and service vessels, and almost no discussion of non- spill impacts. The analysis ought to be focused on the impacts of the particular vessels with which we are concerned as opposed to general data on the effects of oil on the marine environment, and on the relationship of vessels to different physical con- ditions. Quantification of environmental impacts is ignored, and ought to be addressed. (3) The EIS fails to consider current and possible future safety design features of offshore drilling and service vessels. As a result, it cannot and does not compare the environmental safety of various rig types, or analyze design alternatives. (4) The EIS is inadequate in its review of alternatives to the Marad program, both alternatives to offshore development generally and to the particular Title XI financing program. IX-108 Dr. Sidney R. Galler 20 June 1975 page 3 (1) The EIS Fails to Explain the Operation of the Marad Financing Program Initially, the EIS should clearly and precisely describe the workings of the Title XI program itself; the brief account included in the EIS gives no sense of the program's operation. Numerous questions arise: What application procedure is in- volved and what information is called for from an applicant? How much time is required to process an application? What criteria are considered in the decision whether to grant as- sistance? How important is the Title XI program in the overall construction of rigs? What proportion of all U.S. -built rigs is aided? Has Marad financing been significant in causing vessels to be constructed in the U.S.? How important has the Title XI program been to OCS development generally? What are the projections of the program's future growth and significance? Without adequate information on the program's nature, dimensions, and effects, it is difficult to assess either its impacts or alternatives to it. Because of this deficiency, followed by a dearth of facts and analysis elsewhere in the body of the EIS regarding impacts and alternatives, no reasoned determination can be made whether, and if so, how, to continue the program. Thus, the EIS fails in its role under the National Environmental Policy Act of 1969 ("NEPA") as an aid in the decisionmaking process. IX-109 Dr. Sidney R. Galler 20 June 1975 page 4 (2) The EIS Fails to Adequately Evaluate the Impact of Drilling and Service Vessels Upon the Environment The EIS, in setting out the environmental impact of OCS drilling, servicing and support operations, refers to other environmental impact statements for analyses and then sets out a "general survey of environmental impacts" (III-3) . More than this "general survey" is necessary. The EIS discusses the impact of oil generally on the marine environment, but avoids both site- and vessel-specific analysis, and does not address the issue of varying impacts of different size spills. Since environmental impacts will differ enormously based on these factors, the EIS should ap- proach the problem in specific, situational terms. It is key to relate spill probabilities and spill sizes to the different vessel varieties. Although the EIS purports to cover the en- vironmental impacts of both drilling and service vessels, there is very little differentiation of the impacts of the different vessels, and minimal information on the effects of service vessels is supplied. The overly general nature of the EIS also results in an avoidance of those impacts of drilling and service vessels which are neither immediate nor obvious. Little attention is directed to the long-term effects of using the vessels. The environmental impacts of chronic discharges of substances other than oil are mentioned but not adequately analyzed; although ix- no Dr. Sidney R. Galler 20 June 1975 page 5 such discharges are said to have a 100% chance of occurring and may be as damaging as accidental oil spills (111-24), the actual impacts of chemical substances in drilling muds, drill cuttings and other discharges are not discussed, but merely mentioned as being "significant" or not; some impacts are listed as "unknown" (III-9).* The EIS discusses the environmental impacts of shipyard expansion, but does not explore the circumstances under which expansion would be required, nor the probability of the re- quirement. There is merely a conclusory statement that the present capability of the industry is "adequate", and that "an unexpected political or economic emergency may accelerate these programs; and the expansion of ship building facilities may become a necessity " (111-58) . The EIS gives no indication as to the limitations of existing shipyards, and since the continuing effects of the Title XI program and projected re- quirements for drilling and service vessels are not set out, no projection is possible. The EIS should discuss the specifics of shipyard expansion: What are the current limitations and what is their relation to existing and future needs? What circumstances will require some sort of shipyard expansion? Will expansion require construction of new facilities, where would they be located, and what would their impact be? To the extent that the impacts are not known, and, for example, the biological effects of drilling mud additives may not be well understood, it is incumbent on the drafters of the EIS, here as elsewhere, to specify remedies for the lack of knowledge. IX- 111 Dr. Sidney R. Galler 20 June 1975 page 6 Finally, quantification of possible damage is omitted from the EIS; much more extensive discussion of the probable costs resulting from spills or other conditions associated with the use of drilling and service vessels is required. Impacts are more adequately assessed and often more readily understood if their dollar costs are set out.* (3) The Marad EIS is Inadequate in its Comparison of the Environmental Consequences of Existing Drilling Rig Designs and in its Consideration of Alternative Rig Designs and Equipment (a) Comparison of Current Rig Designs Perhaps the central element of the EIS should be the assessment of the environmental soundness of current designs. Unfortunately, Marad, based on the erroneous assumption that there is no information on the environmental soundness of different vessels, does not make such an assessment. In order to assess the impact of the program, the various types of offshore drilling vessels (e.g., jack-up drill unit, surface floating, semi-submersibles) can and should be compared, not only in terms of their technical and operational characteristics, as they are in the EIS, but also for their safety devices and past safety records. There is very k Various other deficiences are found in the EIS treatment of environmental impacts, including: the environmental impacts of onshore treatment and storage facilities are not handled in the analysis of secondary impacts; the socioeconomic impacts of the operations are inadequately considered; and possible impacts of offshore drilling on commercial and sport fishing and recreation are unassessed. IX-112 Dr. Sidney R. Galler 20 June 1975 page 7 little individual evaluation of the environmental sound- ness of vessels, and no comparison at all. In its description of vessels, the EIS notes, in separate sections, that surface floating drilling ships and barges are the most widely used type of vessel, and that the disadvantages of this type of vessel limit their use to "areas having generally favorable conditions." (1-25). Wave action can cause the operations to be "in- efficient or hazardous" (1-25) . The EIS later states that these deficiencies have led to improvements in equipment and technique, but the problems apparently remain, the disadvantages being "inherent in a surface floating vessel." The advantages of the jack-up drilling unit are set out but seem to be focused more on economic and technical efficiency than environmental concerns. These analyses are insufficient; it is essential that the decisionmaker and the public know which vessels are safer under what circumstances or whether there are vessels which are generally more environmentally sound. A comparison of the different vessel varieties of a single type (e.g., within the category semi-submersibles) is also necessary. It is not apparent from the discussion in the EIS whether different construction patterns are used, or whether there is any design standardization among various companies. Information on individual design features would seem essential to informed decisions on vessel financing, and should be included in the EIS. In its failure to include these facts and its general lack of assessment of rig designs, the Marad EIS fails in its most essential purpose. IX- 113 Dr. Sidney R. Galler 20 June 1975 page 8 (b) Consideration of Alternative Rig Designs and Equipment Despite fleeting recognitions of the inadequacy of current technology, the EIS does not explore the proposition that some technologies for OCS drilling and service vessels might be more environmentall sound than those presently employed or that further study on this subject is needed before construction and drilling should proceed. This failure is unjustifiable. At certain points in the text, the EIS indicates that current technologies may be inadequate and can be im- proved. There is an admission that the 1969 Santa Barbara spill "raised serious questions on the adequacy of OCS technology," (III-ll) , and the EIS reproduces a table showing that although the number of spills decreased from 1971 to 1972, their volume more than doubled (111-15).* In assessing the environmental impact of OCS drilling, servicing and support operations, Marad notes that data on oil spills during 1971 and 1972 suggest that "the same processes, equipment inadequacies, and operator errors are causing the spills" (111-16). A study conducted by Computer Services Corporation and included in the EIS also suggests that the number and size of oil spills could be significantly reduced by technological and operational improve- ments (111-16) . * The lack of incentives to report drilling accidents may even mean that spills are more numerous. DC -1 14 Dr. Sidney R. Galler 20 June 1975 page 9 Yet these indications that technologies may be inadequate, do not lead, as they should, to an analysis in the EIS of possible problems or improvements. The EIS states: "liittle is being done in the areas of the design of offshore equipment to prevent pollution" (V-6) , but the statement only results in the offhand observation that increased research and de- velopment is necessary, and the EIS' basic conclusion seems to be: "It is questionable whether such a course of action [an attempt to devise stricter environmental standards] would result in standards materially different than those presently in effect" (V-5) . Marad's failure to consider rig design features that could minimize pollution is at least partially based on industry's identification of human error as the primary problem producing accidents. The EIS states: "the types of pollution which pose the most threat are those associated with the drilling process" (V-5) . However, Marad needs to explore the other accident- causing factors, and to recognize that increased attention to rig design could aid in solving "process" weaknesses. Drilling process dangers are not dissociated from the improvement of safety factors of the equipment used to do the drilling. Rather, dangers centered on human error make equipment per- fection all the more essential. The search for improved technology must include an increased understanding of human criteria in equipment design, with an emphasis on the develop- ment of fail-safe systems and techniques. IX-115 Dr. Sidney R. Galler 20 June 1975 page 10 Contrary to Marad's pessimistic assumptions, the EIS seems particularly well suited to a consideration of methods of decreasing adverse environmental impacts of OCS operations through the use of more efficient equipment and procedures. If information is indeed lacking, then there should be analysis of why the assessment information is lacking, and what time and other factors are involved in its compilation. Postpone- ment of OCS leasing until the best available technology is being employed by all, or until the technology can meet the particular safety problems of different areas, must be seriously considered, not summarily treated as it now is, based upon professed lack of knowledge. The revision of current standards governing vessel de- sign is certainly one alternative that should be examined. It is wrong to presume design adequacy, as the EIS does, from the fact that vessels covered under the Title XI pro- gram are acceptable under present standards. As noted authorities on the subject of OCS operations have said: "In a narrow sense, the problem of technological inadequacy can be related to the generally permissive nature of govern- ment regulations on the OCS... the OCS regulations have always been well within the state of the art as practiced by the industry so that compliance has presented no serious technical challenge". See Kash, et al., Energy Under the Oceans 113 (1973) (hereinafter cited as "Energy" ) . Since IX-116 Dr. Sidney R. Galler 20 June 1975 page 11 technological improvements have normally occurred because of the pressure of government regulation ( Energy , p. 123) , the alternative of stricter government standards should not be so easily dismissed. Regulations since the Santa Barbara spill have become more specific, presumably with beneficial results, and there appear to be sound reasons to continue this trend. In fact, there appear to be specific technological improvements which could enhance the environmental soundness of Marad-f inanced vessels. While it is recognized that it is unrealistic to exclude the possibility of drilling or blowout accidents ( Energy , p. 117) , various changes may be desirable and have been outlined in other texts.* The draft environmental impact statement prepared by the U.S. Geological Survey for the offshore development of the Santa Ynez Unit also enumerated types of drilling equipment and procedures that lessen the probability of a blowout. See U.S. Dept. of the Interior - U.S. Geological Survey, Draft Environmental Statement -- Proposed Plan of Development of Santa Ynez Unit , IV-113f (DES 73-45) (1973) . Such concrete alternatives must be fully- assessed in the EIS. * Desirable changes in drilling and blowout control technologies set out in Energy , pp. 117-18, include longer-lasting bits, improved downhole instrumentation and mud monitoring systems to facilitate identification of potential blowouts, separation of wellheads, fail-safe design of multi-well platforms, control consoles for blowout preventer sacks, and survivable event re- corders. IX-117 Dr. Sidney R. Galler 20 June 1975 page 12 (4) The EIS Also Fails to Review Alternatives to the Marad Program Not Involving Alternative Vessel Design and Equipment Although the EIS approaches the issue of alternatives correctly in terms of addressing both alternatives to offshore development in general and alternatives to the Marad financing program, the discussion is inadequate both in exploring possible alternatives and in discussing their impacts. While it could be argued that less attention should be directed at alternatives to offshore drilling in an environmental impact statement on rig financing, this program involves government sponsorship of OCS development, and such an argument, if accepted, can only lead to a continual failure to examine these alternatives. The existing discussion of alternatives is so general that it is useless -- a mere six page "analysis" is quite out of proportion in an environmental impact statement that should include a meaningful exploration of alternatives. (a) Alternatives to OCS Development As an alternative to offshore development, conservation is fleetingly mentioned, and other alternatives are merely listed. A Department of the Interior analysis of alternatives is cited but not discussed; at least the major points of this analysis should be included in the text of the EIS. IX-118 Dr. Sidney R. Galler 20 June 1975 page 13 Marad needs to explore the impacts that would be involved in discontinuing OCS development, particularly in terms of possible substitution of energy sources. It continues to be apparent that the adoption of an integrated national energy policy requires consideration. (b) Alternatives to the Marad Program The EIS presumes that any delay or discontinuance of the Marad program would automatically result in the use of either privately financed or foreign vessels, and that this would involve decreased control and therefore less safe vessels. But such presumptions cannot be accepted before the facts are inquired into and analyzed.. The EIS should include information on the availability of such vessels, their costs, and their safety characteristics in relation to Marad requirements. The presumption that control would be diminished needs to be in- vestigated. The EIS ignores the possibility that postponement or discontinuance could include a program of regulation of privately financed or foreign vessels, perhaps one involving stricter standards. Marad' s assumption that drilling process factors cause the most danger was previously explored in this comment in terms of design improvements which could eliminate the process dangers. Increased focus on these process-associated dangers IX-119 Dr. Sidney R. Galler 20 June 1975 page 14 should also include attention to personnel training and supervision. Formalized training programs need to be established and accredited, which will initially require definition and standardization of operating procedures. The training programs' content should in turn be standardized and made universal by a requirement of personnel certification. Later supervision of methods and constant evaluation of procedures could complete the program. Marad should consider whether the formalization of programs and their supervision could be done by Marad itself, or whether other agencies should be added or substituted to assure an efficient system. If it is true that dangers associated with the drilling process are the most critical, certainly these steps should at least be considered. Another area in which alternatives may be possible is the supervision of operations and enforcement of government regulations. Possible inadequacies are not considered by the EIS -- there should at least be an open assessment of whether supervisory needs are satisfied. Prior to the Santa Barbara spill, enforcement tended to be lax and waivers were easily obtained, and if this reflects the current situation, action should be taken which could involve supervision by different or additional agencies. In relation to all program alternatives, the importance of government research and development must be stressed. IX-120 Dr. Sidney R. Galler 20 June 1975 page 15 Government sponsorship of research and development for OCS-related activities is minimal compared to its support of research and development in other areas, and industry investment itself is fairly low. Particularly with the expansion of OCS development into the Atlantic Ocean, the Gulf of Alaska, and deeper water, the need for increased sponsorship is manifest: these moves create more severe threats to the environment from amplified storm and seismic conditions, and generally changed circumstances in deeper water. ( Energy , p. 117) . For example, research aimed at identifying and reducing impacts of chronic discharge is particularly needed, and a program for such study should be proposed.* Government should increase its own technical knowledge in order to meet the challenge of developing improved technologies; it needs to achieve an information-gathering function, and possibly to coordinate with private industry in this regard. Formal government systems that will enable identification of equipment and procedural deficiencies and provide for their correction are essential. Ways to develop such systems should be explored in depth in the EIS. * It may be within the state of the art to reduce the discharges by minimal improvements of existing technology or merely by increased attention to procedures. 1 OCS Oil and Gas - An Environmental Assessment : a Report to the President by the Council on Environmental Quality 42 (April 1974). IX-121 Dr. Sidney R. Galler 20 June 1975 page 16 * Conclusion The failure of the EIS. to evaluate fully the environ- mental impact of and alternatives to the Marad vessel financing program renders it inadequate under NEPA. The EIS requires substantial revision to meet NEPA's requirements, and, as a matter of sound policy, to ensure that, if the program con- tinues, subsidized vessels are designed, constructed and operated in the most environmentally sound manner. If you have any questions concerning these comments, please do not hesitate to contact the undersigned. Sincerely, Leonard C. Meeker Eldon V. C. Greenberg Counsel to Environmental Defense Fund, Natural Resources Defense Council, and National Parks and Conservation Association *Caryl A. Bartelman * Student Intern at the Center for Law and Social Policy and third year law student at the University of California, Los Angeles. IX-122 Cente r for Law and Social Pol icy The comments received from this organisation were submitted on behalf of three environmental groups and consist primarily of outlining alleged inadequatness of the draft environmental impact statement. Responses to the comments are as follows and begin with page 3 item (I) of their letter dated 20 June 1975: (1) The EIS Fails to E xp lain th e Operation of the Ma rAd Fina n cing Pr ogr am The comments contained on page 3 under this general heading have been resolved in the most part by rewriting Chapter I which now reflects the Title XI Program in detail and its application to offshore drilling vessels. ( 2 ) The EIS Fails to Adequate l y Evaluate the Impact o f Dr illing and Se rvice Vessels Upon the Env iro nment Under this general heading the comments cover a wide spectrum from page 4 to 6. Beginning with paragraph one of page 4, item 2, the response to each comment follows: Page 4, para. I - Referring the reader to other environmental impact statements for analysis has been removed, and Chapter III has been completely restructured to afford a more descriptive and analytical assessment of the marine environment. Page 4, para. 2 - To endeavor to relate spill probabilities and spill sizes to the different vessel varieties would have no significance. Each oil and gas drilling vessel, regardless of its configuration, has the same equipment which is designed to bore an exploratory hole in the OCS. However, Chapter III now reflects the impact of natural occurrences such as earthquakes on the different vessel varieties. A drilling vessel (when not actually drilling) and a service vessel generate similar impacts on the environment by the emission of engine exhaust fumes, sewage, wastes and bilge discharges. These impacts are addressed in Chapter III under 'Other Vessel Generated Pollutants. " Page 4-5, para. 3 - Chapter III has been rewritten and now reflects a more detailed description and analysis of environmental impacts of chronic discharges into the marine environment. IX-123 Pages 5-6, para. 4 - The possibility of shipyard expansion as a result of the Title XI program has been addressed on page III- 77. ( 3 ) The Mar Ad EIS is Inadequate in its Comparison of th e Environmental C onsequences of Existing Drilling Rig Designs and its Consideratio n of Alt ernati ve Rig D es igns and Equipment ( a ) Co mparison of Current Rig Designs From page six to twelve inclusive comments are made requiring a comparison of the different types of offshore drilling vessels to show past safety records, safety devices and environmental soundness of each design. Responses to these comments are as follows: Pages 6-7, para. 1-3 - To compare the different designs of offshore drilling vessels for environmental soundness and safety devices is to say that one design is less safe and could cause greater environmental harm than another design. This is not the case, for each type of vessel, whether it is a jack-up drill unit, surface floating or semi-submersible must meet the rigid construction and operational standards that are discussed in Chapter IV, both from a safety as well as environmentally sound standpoint. There are no known casualties of any design associated with the offshore drilling vessels constructed under the Title XI program. A footnote at the bottom of page 6 states that other deficiencies were found in the draft EIS treatment of environmental impacts. These have been considered together with paragraph 3 on page 7 and, where appropriate, have been addressed in the revision of Chapters I and III. Page 7, para. 4 - Information on individual design features j_s_ essential and is evaluated at the time an applicant applies for a Title XI financing guarantee. This is discussed in the revised version of Chapter I. ( b ) Consideration of Altern a tive Rig Designs and Equipmen t Under this sub-heading the comments also imply that some OCS drilling and service vessels are less environmentally sound than others. It is reiterated that such is not the case as all vessels constructed and operated under the Title XI program must meet the rigid standards that are discussed in Chapter IV. The second paragraph on page eight refers to the 1969 Santa Barbara spill and the adequacy of OCS technology at the time of this spill. Page III- 12. IX -124 indicates that on December 11, 1973 the California State Lands Commission unanimously adopted a staff report indicating that the oil industry had developed safety equipment and procedures that minimized the possibility of a major oil spill occurring and lifted a moritorium on new drilling on existing state tidelands leases. Comments relative to the number of oil spills also on page eight, are responded to in a Department of the Interior comment - 'Another reason for the apparent lack of significant decrease in the number of pollution incidents (p. Ill- 13 , paragraph 2) is the improvement in lecording and reporting practices. " Page 9, para. I - Chapter V has been revised to show that private industry has and is continuing to take steps in the design of equipment and systems to prevent pollution. Page 9, para. 2 - The Department of the Interior in its detailed comments included herein, contend that the proposed alternative of modifying the program by giving preference to certain vessel designs that are more environmentally sound than others (p. V-4 to V-5) appears not to be a real alternative but to be a part of the MarAd Title XI program as presently administered. This contention has been concurred in and Chapter V has been revised accordingly. Page 10, para. I - The comment implies that the equipment and procedures used by the Title XI drilling vessels are inefficient, whereas the contrary is true. It is a known fact that the standards for equipment and operating procedures of these vessels are among the highest in the world and have been copied by other nations. Page 10, para. 2 - The comments contained on pages 10 and 11 are based on abstracts from the book "Energy Under the Oceans' by D. E. Kash and others. The abstracts are taken from Chapter VI entitled "Adequacy of OCS Technologies" in which the abstracts quoted are somewhat critical. In making the comments, that are based strictly on requiring improved OCS drilling technology the Summary to Chapter VI has been ignored. This, in part states - "The significant improvements in the use of failure analysis, component redundancy, and system design which have taken place in other technical fields in the past twenty years have been applied only recently to the OCS oil industry. The industry has substituted a hit -or- miss program of operator training for a true human-factors approach to IX-125 design and to the development of methods for measuring and displaying vital information to the tool pusher and production supervisor. Industry representatives rightly point out that some recent wells have been drilled to record depths and in particular adverse conditions using truly impressive equipment monitored through computer programs and embodying up-to-date fail-safe concepts." -- It is within the frame-work of the above quotes that the Title XI program vessels are built and operated. ( 4 ) The EIS also Fails to Review Alternatives to the MarAd Program Not Involving Alternative Vessel Desi gn and Equipment Under this general heading comments are submitted relative to Chapter V - Alternatives to the Title XI Offshore Oil and Gas Drilling Program. Responses to these comments are as follows: Page 12 (a) Alternatives to PCS Develop m ent As a result of comments also submitted by others Chapter V has been restructured and now contains the major points of the Department of the Interior analysis of energy alternatives including conservation. Page 13 (b) Alternatives to the MarAd Program The comment that - "The EIS presumes that any delay or discontinuance of the MarAd program would automatically result in the use of either privately financed or foreign vessels, and this would involve decreased control and therefore less safe vessels. " The EIS does not state that this would happen, only that it was a possibility that should be considered. To claim that it would happen is to draw conclusions that do not belong in an environmental impact statement. Page 14 - The comments on this page are concerned primarily with establishing training and supervision requirements. Response to these comments are found in Energy Under the Oceans by Kash et. al. , in the summary on page 122 which, as previously mentioned, states - "The industry has substituted a hit-or-miss program of operator training for a true human-factors approach to design and to the development of methods for measuring and displaying vital information to the tool pusher and production supervisor." IX-126 It is believed that it was not the intent, or the desire of NEPA for the Federal government to interfere with private industry under such a program as that of Title XI loan guarantees. Page 15 - Comments on this page further discuss the need for government sponsored research and development programs related to OCS technology. Response to these comments are taken from "An Analysis of the Feasibility of Separating Exploration from Production of Oil and Gas on the Outer Continental Shelf" by the Congress of the United States - Office of Technology Assessment, dated May 1975. Page 240 - Research and Development to Improve Technology for OCS Development The Secretary of the Interior is, under S. 3Z21, directed to carry out a research and development program designed to improve technology related to develop- ment of oil and gas resources of the OCS. Areas of investigation shall include: downhole safety devices, methods for re-establishing control of blowing out or burning wells, methods for containing and cleaning up oil spills, new or improved methods of development in water depths over 600 meters, and subsea production systems. IX -127 APPENDIX A THE RELATIVE HARMFUL EFFECTS OF LIGHT AND HEAVY OILS A-l THE RELATIVE HARMFUL EFFECTS OF LIGHT AND HEAVY OILS Introduction The International Convention for the Prevention of Pollution of the Sea by Oil (1954) as amended, controls the discharge from tankers of the so-called black or heavy oils (crude oil, residual fuel oil, heavy diesel, etc. ). Light oils (No. 2 fuel oil, jet fuel, gasoline, etc. ) were not included in the Convention and their discharges into the sea are not controlled. However, the U. S. Environmental Protection Agency has investigated both the impact of light oils into the world ocean from tanker operations (1) and the relative effects of refined products and crude oil (2). These studies show that light oils are discharged from tankers in sufficient quantity and in such a manner as to have potential harmful effects on the marine environment. They also indicate that light oils are substantially more toxic to marine life and potentially more harmful than heavy oils. Hence, the IMCO Marine Pollution Conference of 197 3 determined that light petroleum derived oils will be subject to at least the same stringent regulations imposed on crude oil and heavy petroleum products. A-2 In a continuing effort to evaluate the relative harmful effects of petroleum products to aquatic organisms as set forth by- Resolution No. 6 of the Marine Pollution Conference of 1973 (MP/ CONF/WP. 46), the U.S. EPA has to date conducted original investigations to determine the acute toxicity of six petroleum products to four test organisms; also, selected physicochemical properties of water emulsions of the selected oils have been determined. Additionally, a thorough literature review has been conducted to further elucidate the relative effects of different refined fractions of crude oil. Future studies will concentrate on the relative effects of oils on specific biological processes occurring in the pelagic environment. The immediate result of these investigations is an updated relative hazards profile of the type introduced in a previous document (2). The present profile is directed in consideration to phenomena occurring in the open ocean (pelagic) ecosystem and limited in scope to acute toxicity, inhibition of photosynthesis, bioac cumulation and carcinogenicity, accomodation and persistence, and chemical communication. A-3 Acute toxicity During the past year, the U.S. EPA has completed a program" of acute toxicity bioassays with four organisms and' six petroleum products. The organisms tested include the menhaden, Brevoortia patronus; the mullet, Mugil cephalus; the shrimp, Palaemonetes vulgaris; and the sunfish, Lepomis macrochirus . The petroleum products tested include a Louisiana crude oil, a No. 6 fuel oil, a No. 2 fuel oil, a jet fuel, and a leaded and an unleaded gasoline. Procedures The static bioassays were conducted according to the general principles and methods set forth in Standard Methods for the Examination of Water and Waste Water (3). High speed blending was experimentally determined to produce the most stable oil in water dispersion and was therefore chosen as the method of mixing. The concentration of oil in the water column was determined 96 daily by means of infrared spectroscopy (4) and TL (96 hr. median m tolerance limit) values were computed on this basis. Fish mortality and behavior were observed several times each day and tolerance limits were estimated by straightline graphic interpolation using the total concentration of oil added and the actual concentration of oil in the water column. Dissolved oxygen concentration, temperature A-4 and pH were monitored daily. The results below are based on the amount of oil actually found to be present in the water column at the initiation of the assay. A dash indicates that no test was conducted. Menhaden The tolerance of juvenile menhaden to the six petroleum products has been determined and the results are presented in Table 1. TABLE 1 96 TL (mg/1) Test Material m leaded gasoline 2 unleaded gasoline fuel oil No. 2 5 jet fuel 2. 1 crude oil 5 fuel oil No. 6 10 Mullet The tolerance of juvenile mullet to the six petroleum products is summarized in Table 2. TABLE 2 96 TL (mg/1) Test Material m leaded gasoline 4 unleaded gasoline 2 fuel oil No. 2 13 jet fuel 45 crude oil 56 fuel oil No. 6 A-5 Shrimp The tolerance of the shrimp Palaemonetes vulgaris to the petroleum products is presented in Table 3. TABLE 3 96 TL (mg/1) Test Material m leaded gasoline 1 unleaded gasoline 1 fuel oil No. 2 2 jet fuel ■ 4 crude oil 15 fuel oil No. 6 25 Sunfish The tolerance of juvenile sunfish, Lepomis macrochirus, to the six petroleum products is presented in Table 4. TABLE 4 96 TL (mg/1) Test Material m leaded gasoline 7 unleaded gasoline 7 fuel oil No. 2 95 jet fuel 100 crude oil 160 fuel oil No. 6 127 As can be seen from the above results, there is substantial variation in the tolerance of the tested organisms to all of the A-6 petroleum products tested. However, the phenomenon of higher relative toxicity of the lighter oils is consistent among the species tested. This is illustrated graphically in Figure 1. Only a few other studies have been conducted which measured the relative toxicity of petroleum products to aquatic organisms. Although the amounts determined to cause a particular toxicity vary according to the experimental methods employed and the characteristics of the specific products used, there is general agreement as to the relative toxicity of heavy versus light oils in these static bioassays. Anderson et..al.(5) tested the toxicity of the water soluble fractions and oil in water dispersions of four oils to six marine species. Two crude oils, a South Louisiana crude and a Kuwait crude, and two refined oils, No. 2 fuel oil and bunker C residual oil (No. 6 fuel oil), were used in these investigations. The test species were ranked according to increasing sensititivity to oil as follows: the sheepshead minnow, Cyprinodon variegatus; the tidewater silverside, Menidia beryllinia; the longnose killfish; A-7 s« be E 70" 60- 50- 40- 30- 20- 10- -4 © Sj MENHADEN MULLET SHRIMP SUNFISH FIG. 1. RELATIVE TOXICITIES TO SELECTED SPECIES A-ti Fundulus similus; the brown shrimp, Penaeus aztecus postlarvae; the grass shrimp, Palaemonetes pugio and the mysid, Mysidopsis almyra. The water soluble fractions and oil in water dispersions of the refined oils were considerably more toxic to the six test species than were those of the crude oils (Table 5). Tagatx (6) tested the toxicity of gasoline, diesel fuel, and No. 6 fuel oil to juvenile American shadAlosa sapidissima. Gasoline was the most toxic, diesel fuel somewhat less toxic and bunker oil least toxic (Table 6). The lethality of petroleum products to shad was found to increase when accompanied by low dissolved oxygen,, Inhibition of Photosynthesis As the process of photosynthesis by marine phytoplankton is responsible for the fixation of much of the energy utilized by marine ecosystems, determining what effect petroleum products have on this process is an important step in the evaluation of the relative potential harm of these products. Gordon and Prouse (7) examined the effects of three oils (Venezuelan crude, No. 2 fuel, and No. 6 fuel) on the photosynthesis of natural phytoplankton communities from Bedford Basin, Nova Scotia, and the northwest Atlantic Ocean using a radiocarbon method. A-9 TABLE 5. 48 Hour TLm values compiled from data presented by- Anderson (1974). Species S. La. Crude Bunker C #2 Fuel Oil -OWD **WSF OWD WSF OWD WSF Sheepshead minnow Tidewaie r silverside Longnose killifish Gras s shrimp Brown shrimp 33,000 19.8 5,000 8.7 6,000 16.8 1,650 16.8 4.4 Z00 6.9 2. 7 125 2.27 36 5. 2 4. 7 2.8 3.4 4.1 3. 5 9.4 5. 0. 9 1. 3 0. 9 1,000 19.8 Mysid 37.5 8.7 *OWD - Oil in water dispersion **WSF - Water soluble fraction Concentra ions of OWD's are expressed as ppm oil added to the water, and of WSF's as ppm total oil hydrocarbons in the aqueous phase as dete rmined b/ IR analysis. Table 6. TL (median tolerance limit) values of gasoline, diesel fuel oil, and bunker oil for juvenile American shad, Alosa sapidissima. Tagatz (1961). Product TL (mg/1) 24 hour 48 hour 96 hour Gasoline Diesel fuel oil Bunker oil 91 204 91 167 2.417 1, 952 A -10 150 00 o OS 100 90 80 70 60 50 • x *v LtL-VLn x i ,D * c« Z UJ 0. o H © II a. OS 93 £ H U> — " u. Q O W CD £ H u Q OS Z H £ - w H -J » aa K -j OS — o O (/J es OS H w H £ < < B* J >< u. H O U a o u. W bb