Gulf of Mexico Deepwater Operations and Activities
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OCS EIS/EA MMS 2000-001 Gulf of Mexico Deepwater Operations and Activities Environmental Assessment Author Minerals Management Service Gulf of Mexico OCS Region Published by U.S. Department of the Interior Minerals Management Service New Orleans Gulf of Mexico OCS Region May 2000 iii EXECUTIVE SUMMARY This Environmental Assessment (EA) addresses the potential effects of oil and gas exploration, development, and production operations in the deepwater areas of the Gulf of Mexico Outer Continental Shelf (OCS) during the 10-year period 1998-2007. The western and central portions of the northern Gulf of Mexico constitute one of the world's major oil and gas producing areas, and have proved a steady and reliable source of crude oil and natural gas for more than 50 years. The pace of exploration and development in the deepwater (water depths greater than 1,000 ft [305 m]) Gulf of Mexico has accelerated rapidly in the last few years. In these water depths, the use of conventional, bottom-founded (fixed) platforms quickly becomes technologically infeasible and uneconomic. As new discoveries are made in progressively deeper water, the technology continues to evolve to meet technical, environmental, and economic needs of deepwater development. As a supplement to this EA, the MMS has prepared a series of technical papers that provide a summary description of the different types of structures that may be employed in the development and production of hydrocarbon resources in the deepwater areas of the Gulf of Mexico (Regg, 2000). This EA is a programmatic assessment of current and projected deepwater activities on the Gulf of Mexico OCS. This document is intended to be used as a planning tool to help both the MMS and industry envision the level and the extent of a National Environmental Policy Act (NEPA) review that will be required for future deepwater activities. The MMS=s specific objectives in this document are the following: • ensure that the deepwater activities occur in a technically safe and environmentally sound manner; • determine which deepwater activities are substantially different from those on the continental shelf; • determine which deepwater activities are substantially the same as those on the continental shelf; • identify and evaluate the potential impacts of deepwater activities; • develop mitigation measures for further evaluation; • identify potential research or studies related to deepwater activities and environmental resources; and • provide a summary document on deepwater technologies, activities, and impacts. Issues The issues addressed in this EA are related to deepwater technology, operations, and operational environment; water and air quality; accidental release of oil or chemical products; and potential impacts on biological communities or the socioeconomic infrastructure. These issues were identified through scoping or by MMS staff as warranting consideration. Many of these issues have been analyzed in previous NEPA documents. iv Operational and Component-based Findings Based on the information and analyses in the EA, MMS finds that a programmatic environmental impact statement (EIS) on regional deepwater activities on the Gulf of Mexico OCS is not required. The components of deepwater operations and associated activities are listed in the summary matrix in Chapter 2. As indicated below, some deepwater components have been addressed by requiring specific mitigation measures, initiating a more in-depth EA, and initiating an EIS. Most deepwater operations and activities are substantially the same as those associated with conventional operations and activities on the continental shelf. These deepwater components and activities include anchoring, mooring, stationkeeping, most drilling and well completion activities (the exceptions are discussed below), well test and cleanup operations, flaring/burning, facility installation and production operations, host facilities, alternative transportation options, operational emissions, routine produced-water discharges, support service activities, decommissioning, and site clearance. Existing NEPA documents, established project-specific and programmatic NEPA review processes, and established mitigation measures are fully sufficient to address these deepwater components and associated activities. Specific deepwater operations and activities that are substantially different from those associated with conventional operations and activities on the continental shelf have been addressed by requiring specific mitigation measures, initiating a more in-depth EA, and initiating an EIS. Seafloor discharges from pre-riser and riserless drilling operation, and the discharge of synthetic drilling fluids (SDF) and cuttings wetted with SDF may pose potentially significant localized impacts to chemosynthetic communities. An appropriate mitigation measure has been developed to avoid or reduce the potential for significant impacts from these factors. Deepwater wells must be at least 1,000 ft away from any potential high-density chemosynthetic communities. Notice to Lessees and Operators (NTL) 98-11 is being modified to include this 1,000-ft buffer zone around all deepwater well sites. As the NTL goes through the formal review and implementation process, this mitigation is currently being applied on a site-by-site basis. Accidental spills of chemical products and the subsea release of oil are low-probability events. Extensive mitigation measures for spill prevention and response are currently required. Deepwater seismic surveying operations are essentially the same as seismic surveying operations on the continental shelf. Historically, the potential impacts of noise associated with seismic surveying have been considered insignificant; this EA does not support changing this position at this time. As this position has recently become controversial, the potential impacts of geological and geophysical (G&G) activities, including seismic surveying operations, on the Gulf of Mexico OCS are currently being analyzed in detail in a separate EA. The decision on the need to prepare an EIS on seismic surveying operations is pending completion of the G&G EA. The use of floating production, storage, and offloading (FPSO) systems represents new and unusual technology for the Gulf OCS and may pose potentially significant impacts to the marine and coastal environments. The need for an EIS was recognized early during the preparation of this EA. A Notice of Intent to Prepare an EIS was published in the Federal Register on June 10, 1999. Deepwater operations have the potential to result in oil spills on the OCS that are greatly larger than those previously analyzed. An occurrence of a spill associated with deepwater operations or activities is a very low-probability event. The behavior and transport dynamics of accidental subsea release of oil are not completely understood. After weathering and dissipation, proportionally greater volumes of oil could remain in the marine environment or be delivered to coastal habitats than spill volumes that have been previously analyzed in MMS NEPA documents. Tankering of oil from deepwater operations has the potential to result in substantially larger OCS oil spills that could occur closer to or directly in coastal habitats. Deepwater-produced oils may contain high asphaltene v concentrations. Spills of such oils may permanently cover water bottoms and wetlands, increasing the occurrence and volume of tar in the marine and coastal environments. The extensive mitigation measures for oil-spill prevention and response currently required are considered adequate to minimize the risk of spills and potential impacts. The unknown aspects of the behavior and transport dynamics of subsea oil releases are being addressed through current and planned contractual studies and joint government/academia/industry research. Resource Analyses The potential impacts and environmental consequences of deepwater activities are analyzed by resource topic. Summaries of the impact conclusions are presented below. Chemosynthetic Communities Chemosynthetic communities are susceptible to physical impacts from structure placement (including templates or subsea completions), anchoring, and pipeline installation. NTL 98-11 prevents these physical impacts by requiring avoidance of potential chemosynthetic communities. Potentially severe or catastrophic impacts could occur to high-diversity communities located near deepwater wells from partial or complete burial by muds and cuttings associated with pre-riser discharges or some types of riserless drilling. Variations in the dispersal and toxicity of synthetic- based drilling fluids may contribute to the potential areal extent of these impacts. Studies indicate that periods as long as hundreds of years are required to reestablish a chemosynthetic community once it has disappeared, although a community may reappear relatively quickly once the process begins. Tube-worm communities may be the most sensitive of all communities because of the combined requirements of hard substrate and active hydrocarbon seepage. Mature tube-worm bushes have been found to be several hundred years old, with individual worms potentially reaching 400 years of age. There is evidence that substantial impacts on these communities would permanently prevent reestablishment. Nonchemosynthetic Benthic Communities Most impacts of deepwater operations to nonchemosynthetic benthic communities are similar to impacts associated with OCS Program activities in general. Some impact to benthic communities