■ i * * V ' I *»• >' - — ' •' f ■ ■ i ' ' , . . » %. . -Vft. •-.t •'* - • ■ < ■ ‘V.." -■•••■' . ■ V> .' ■ ■ ; V.:';. • . . • ■ . . - -v •» • •• •» •• • V . Ot»W: • > ' • • " ‘ V 3 ' * ' .... V >.*. •> • s . -w* ... • •• » *•'- • .*•••• • , • vi> 4 , 1 -. >< -: •: 1 1 ■' t - v » l- • ■ ..v v.'y»' . • • - , , - t.*. vi.'.V' *. -.S V - ..... - V- •«* . - VV. ".;:-v,v. . .\v :r r -.v :• .U .. X'-.- . * ...... ... , * » ■ ' • 1 . . . .. - ■ V ' v " 4 - ‘ ....... i.. . •- •- .*v• '>’'*• ‘ ' * ' ’ > • ‘ v ' ■ • • • ‘ ’ - . ' ••-* ' xv ' ' ' ..... ■ • • ■. . :- , r: •*! • ■ , „ 1 . . . - ..•.... . ,** . . . .. '• . ' '• • • • •• •• • ; • - - - ... .. . - , .... .. ....... .... ..... ' ' ' . ..•- •••.;. ::r. . .- v • ..••.••• ■ ■ . ■ 1 , . ,, 4 , 1 . . ..| I •» r • • »,*'« .. ; ■ ■ y, , - *-V > • ■ ^ / . ... -' 4 * f 1 - rr ». ,, ,'( «. if ,.v {,> r • i ' . , ... ■ ■ 1 ’ J ' ... I. Mir "*M *•*” r ■■ . ' ' ■ : • ■ . v. • • • • * ■ ... ry-' ' /••«»«»■•••• ■ . » : * r •. ■ ■ ' . . • . ■ ■ ... .; ..... . ’ . ....*•< ».» » * '* '• .'... . >. If . •• 4 *t» 1 *' f '•*'*'*»! ■?*.: • • .“.'V VV/.V-V i V» s. ■ (.'i' ■ . . . •, V V .. » . • • ; y.VY • .m > - 1'''WfXZ <;£*•>?*“ v '% • ■ .. ' . ’. . ■ • • •; v 1 1 ' ,«7 • 1 *V. i ♦ . •’ • • ' v'.vv * UNITED STATES DEPARTMENT OF THE INTERIOR FINAL ENVIRONMENTAL STATEMENT VOLUME 3 OF 3 OIL AND GAS DEVELOPMENT IN THE SANTA BARBARA CHANNEL OUTER CONTINENTAL SHELF OFF CALIFORNIA ■S: K* -i PREPARED BY THE UNITED STATES GEOLOGICAL SURVEY DEPARTMENT OF THE INTERIOR (Director) 0 I ' ° {Jrsb^be AT* h CONVERSION FACTORS FOR READER INFORMATION Gravity in degrees API (°API) = •^^.•-5. - 131.5 Example: Sp. gr. Water = 10° API 1 nautical or geographical mile = 6,076.12 feet = 1,852.00 meters 1 statute mile = 5,280 feet = 1,609.35 meters 1 knot = 1 nautical mile per hour = 1.151 statute miles per hour = 1.69 feet per second (ft/sec) 1 cubic meter = 264.2 If. S. gallons = 35.31 cubic feet 1 cubic foot = 7.48 U. S. gallons 1 oilfield barrel = 42 U. S. gallons = 159 liters Parts per million (ppm) = milligrams per liter (mg/L) Parts per thousand (ppt) = milligrams per milliliter (mg/mL) = grams/liter (g/L) 1 grain = 0.064798918 grams 1 grain per gallon (gpg) = 17.118 milligrams/liter (mg/L) = 17.118 parts per million (ppm) 1 metric ton (M ton) = 1,000 kilograms = 2,204.62 pounds avoirdupois 1 U. S. standard pound avoirdupois = 453.592 grams 1 kilogram = 2.205 U. S. standard pounds avoirdupois Weight of fresh water at 4° C = 62.43 pounds per cubic foot = 8.346 pounds per gallon Average specific gravity of sea water = 1.025 Average weight of sea water at 4° C = 63.99 pounds per cubic foot = 8.555 pounds per gallon 1 megawatt (MW), = 1,000,000 watts (W) = 1,340 horsepower (hp) 1 British Thermal Unit (BTU) = heat required to raise the q temperature of one pound of water at its maximum density 1 F. 1 horsepower (hp) = 42.418 BTU per minute = 746 watts 1 kilowatt-hour (kwh) = 1,000 watt-hours (wh) = 1.341 horsepower-hours (hph) = 3,413 BTU UKURUY 11 OF #_ MftJBS IAM-CHAMPAIGH CONVERSIONS DEPTH meters feet o- 200- 400 - 600 - o 1000 2000 800 - 1000 - 1200 - - 1400 - 1600 -" 1800 -- 2000 -' 2200 -' 2400 -_ 2600 - 2800 -' 3000 4000 3000 6000 7000 8000 9000 3000 0000 3200 -- 34 00 -' 3600 - 3800 -- 1000 2000 4000 3000 4200 - 4400 - 4600 - 4800 - 5000 - 5200 - 5400 - 5600 - 5800 - 6000 - 6200 - 6400 - 6600 - 6800 - 7000 - 7200 - 7400 - 7600 - 7800 - 8000 8 200 8400 8600 8800 9000 9 200 4000 5000 6000 7000 8000 9000 20000 21000 22000 23000 24000 25000 26000 27000 28000 29000 30000 TEMPERATURE degrees Fahrenheit 32 50 100 - 150 200 250 300 350 400 450 500 550 degrees Celsius o 10 20 30 40 50 60 70 80 90 100 no 120 130 140 150 160 170 180 190 200 210 2 20 230 1-240 '-250 - - 260 -270 -280 290 -Ljoo OIL GRAVITY o Api specific gravity @ 60 .6 100 - -■ .62 90 - .64 - - .66 80 - - -.68 70 - -.70 . - .72 60 - -.74 - - .76 50 - - .78 - .80 40 - - .82 - .84 - .86 30 - - .88 - .90 - .92 20 - - .94 - .96 - 98 • 0 - - 1.00 - 1.02 1.04 - 1.06 0 1.08 TABLE OF CONTENTS VOLUME 3 of 3 Page IV. MITIGATING MEASURES IV- 1 A. General Mitigations Related to OCS Oil and Gas Operations and Facilities - 1 1. Regulations - 1 a. U. S. Geological Survey- 2 b. Department of Transportation - 3 (1) U. S. Coast Guard- 3 (2) Office of Pipeline Safety - 3 c. Regulation of Waste Water Discharged into the Santa Barbara Channel OCS Waters - 4 d. Environmental Protection Agency - 5 (1) The Federal Water Pollution Control Act Amendments of 1972 - 5 (2) State of California and U. S. Geological Survey Responsibilities as to Ocean Waste Discharges Arising from Oil and Gas Operations - 8 e. Corps of Engineers, United States Army - 8 f. Other Agencies--- 9 g. Pacific Area OCS Orders - 10 h. Policies and Recommendations of the California Coastal Zone Conservation Commission on Petroleum Development - 28 2. Inspection Programs and Approval Requirements - U. S. Geological Survey- 33 a. On-Site Inspections - 34 b. Semi-Annual Inspections and Enforcement Procedures - 35 c. Other Inspections - 36 3. Enforcement- 37 4. Contingency Plans - 38 a. Organizations Formed by Companies for Spill Containment and Removal - 39 b. Clean Seas, Incorporated - 40 (1) Inventory of Equipment and Materials-Status as of November 1975 - 41 (a) Containment- 41 (b) Recovery- 42 (c) Miscellaneous - 45 c. National Oil and Hazardous Substances Pollution Contingency Plan- 45 d. Region Nine Multi-Agency Oil and Hazardous Materials Pollution Contingency Plan - 46 (1) Regional Response Team and On-Scene Coordinator Functions - 49 (2) U. S. Geological Survey and U. S. Coast Guard Responsibilities - 80 e. California Oil Spill Disaster Contingency Plan --- 51 Page B. 5. Status of Oil Spill Containment and Clean-up Technology- 7 ~~ " 6 . Mitigating Factors Involving the Relationship ot Potential Activities to Shipping ---- 7. Mitigating Factors Involving the Relationship of Potential Activities to Missile Overflights -- 8 . Studies on OCS Management and Operating Practices a. OCS Studies Analyzed by U. S. Geological Survey Work Group - b. OCS Technology Assessment Group Study - University of Oklahoma --- c. Supplement No. 1 to the Geological Survey Work Group Report --- 7 " d. Council on Environmental Quality OCS Oil and Gas Operations Environmental Report for the Atlantic OCS and the Gulf of Alaska - April 1974 - e. Supplement No. 2 to the Report of the Work Group on OCS Safety and Pollution Control - f. General Accounting Office (GAO) Study and Report g. Bureau of Land Management Study Groups 9. Memoranda of Understanding - 7 10. Mitigating Factors Related to the Detrimental Effects of Oil Spills in the Santa Barbara Channel - a. Long-Term Impact - b. Effect of Different Types of Oil - c. Animals with Tolerance to Oil -- d. Natural Assimilation of Crude Oil - Mitigations Related to the Specific Phases and Components of Potential Activities 1. Specific Proposals Require Geological Survey Approval- 2. Well-Control Training Programs for Operating Personnel - 3. Platform Beautification Studies - 4. Platform Removal - 7~~7~ 5. Non-Use of Polychlorinated Biphenyl (PCB) Liquids - 6 . Subsurface Safety Valves - 7. Subsidence - a. Subsidence Potential -- b. Subsidence Detection Program - 8 . Dos Cuadras Field Seismometer Array 9. Archeological and Historic - 10. Platform Seismic Design Criteria -- 11. Programs of Research Aimed at Reducing the Potential for Adverse Impact from Certain Geologic Events - 12. Other Environmental Research - 13. Air Quality Impacts- 7 -7 _ "I"T"T a. Marine Tanker.Loading Terminal Air Emissions b. Onshore Treating Facilities Emissions IV- 52 54 55 57 57 73 75 75 76 77 79 80 81 81 81 82 82 82 82 84 84 85 85 86 86 86 88 89 90 91 92 94 99 99 99 Page Appendices to Section IV Appendix IV-1 Copy of Standard OCS Lease Form- IV-100 Appendix IV-2 Supplement No. 1 to Report of the Work Group on OCS Safety and Pollution Control, May 1973 - 105 Appendix IV-3 Supplement No. 2 to Report of the Work Group on OCS Safety and Pollution Control, May 1973 - 134 References- 150 V. UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS - V- 1 A. Oil Pollution Effects on Marine Environment - 1 1. Marine and Marine-Associated Birds and Mammals -- 1 a. Birds- 2 b. Mammals- 2 2. Benthic Organisms - 3 3. Bottom Sediments - 3 4. Beaches and Shoreline Recreation - 3 B. Construction and Operation Effects - 4 1. Wildlife Along Pipeline Routes and Near Onshore Facilities - 4 2. Benthic Organisms - 5 3. Bottom Sediments - 8 4. Beaches and Shoreline Recreation - 6 a. Construction Phase - 6 b. Operation Phase - 6 C. Compatibility of Commercial Fishing - 6 D. Relationship to Shipping Traffic - 7 E. Effect on Truck Traffic - ^ F. Archeological and Cultural Resources - 8 G. Debris-- H. On-Land Impacts - I. Air Pollution- 9 J. Water Pollution - K. Impact on Humans- 10 VI. VII. VIII. Page RELATIONSHIPS BETWEEN LOCAL SHORT-TERM USE AND MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY - IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES VII- A. Mineral Resources - B. Fish and Wildlife Resources - C. Archeological and Historical Resources ALTERNATIVES TO THE FURTHER DEVELOPMENT OF OIL AND GAS RESOURCES OF THE OCS PORTIONS OF THE SANTA BARBARA CHANNEL VIII A. No Action-- B. Operational Alternatives - C. Authorize Full Development on Existing Producing Leases - 1. No Action - 2. Defer Action--- 3. Prevent Further Development of Existing Producing Leases - a. Suspension of Operations-- b. Refuse to Approve Future Applications for Developmental Actions - c. Cancel the Leases - d. Federal Acquisition of the Leases - 4. Allow Full Development of Selected Producing Areas -- 5. Impose Additional Special Terms and Conditions to Further Mitigate Environmental Damage - D. Authorize Full Development on Existing Leases Not Presently Developed - 1. No Action - 2. Defer Action --—-- 3. Prevent Further Development of Existing Leases a. Suspension of Operations - b. Refuse to Approve Future Applications for Exploration and/or Developmental Actions - c. Cancel the Leases - d. Federal Acquisition of the Leases - 4. Allow Exploration and Development of Selected Areas Now under Lease -- 5. Impose Additional Special Terms and Conditions to Further Mitigate Environmental Damage - E. Lease, Explore and Develop Presently Unleased Areas 1. No Action - 2. Hold Future Lease Sales of Presently Unrestricted Areas of the Channel OCS - 1 1 1 1 2 -1 3 4 4 4 5 5 6 7 7 9 10 11 11 11 12 12 13 13 15 16 16 17 17 18 Page 3. The Federal Buffer Zone- VI11'20 a. No Action- 21 b. Rescind the Order and Make the Lands Again Available for Leasing- 21 4. The Federal Ecological Preserve - 22 a. No Action- 23 b. Rescind the Order and Make the Lands Again Available for Leasing- 23 F. Establishment of a Federal Energy Reserve - 25 1. No Action- 27 2. Resubmit Proposed Legislation, Unchanged, to the Congress for Consideration- 28 3. Submit New Proposed Legislation for Establishment of a National Energy Reserve but with a Different Selection of Lands To Be Encompassed- 30 G. Alternative Sources of Energy - 32 1. Energy Conservation - 46 2. Conventional Oil and Gas Supplies- 57 a. Deregulation of the Wellhead Price of Natural Gas 58 b. Nuclear Stimulation of Gas Formations - 58 3. Coal - 59 4. Synthetic Sources of Oil and Gas- 61 a. Oil Shale- 61 b. Synthetic Natural Gas and Oil - 63 5. Hydroelectric Power - 65 6. Nuclear Power- 68 7. Solar Energy- 70 8. Energy Imports- 72 a. Oil - ^2 b. Natural Gas- 7 ^ 9. Other Energy Sources - 77 10. Combination of Alternatives - 78 Appendices to Section VIII Appendix VIII-1 H. R. 7500 -- 87 Q 4 References--- IX. CONSULTATION AND COORDINATION WITH OTHERS - IX " 9 A. Summary of Public Hearing Testimony and Responses 40 B. Written Comments - W9Wdi*vH3-SirwKa r »/j -/ jo -n Avxraari LIST OF PLATES (Plates in Separate Envelope) Plate 1. Map showing oil and gas fields, leased areas, and seeps m the Santa Barbara Channel region. Erratum: The Mesa Oil Field has been abandoned. 2. Geologic map and cross sections, Santa Barbara Channel region. 3. Line drawings from acoustic profiles, showing geologic interpre¬ tations across the Santa Barbara Channel. 4. Map showing subsea faults of the Santa Barbara Channel, with insets illustrating interpretation of acoustic profiles from which locations and character of faults were determined. 5. Composite columnar sections, Santa Barbara Channel region. 6 . Complete Bouguer gravity anomalies, Santa Barbara Channel region. 7. Recency of faulting, Santa Barbara Channel region. LIST OF TABLES VOLUME 3 of 3 VIII. Alternatives to the Further Development of Oil and Gas Resources of the OCS Portions of the Santa Barbara Channel Table VIII-1 Energy Needed from Other Sources to Replace the Estimated Oil and Gas Production from Various Potential Levels of Santa Barbara Channel OCS Development- Page VIII-35 75 2 Estimated Annual Oil Pollution of the Oceans 3 Federal Energy R$D Funding- 79 IV. MITIGATING MEASURES A. General Mitigations Related to PCS Oil and Gas Operations and Facilities 1. Regulations All Santa Barbara Channel OCS oil and gas operations would comply with applicable regulations of county. State, and Federal agencies including, but not limited to, the U. S. Geological Survey, the U. S. Environmental Protection Agency, the U. S. Army Corps of Engineers, the U. S. Coast Guard, the California State Lands Commission and Division of Oil and Gas, the Regional Water Quality Control Board, and appropriate State, regional, and county air pollution control agencies depending on jurisdiction. The State and counties would have jurisdiction, for exam¬ ple, over portions of pipeline on State land and onshore facilities that process OCS production. Under the provisions of the Outer Continental Shelf Lands Act (43 U.S.C. secs 1331-1343) and the Supreme Court’s decision (U. S. v. California 381 U. S. 139 (1965)), the subsoil and the seabed of the Outer Contin¬ ental Shelf more than three miles seaward from shores of the United States appertain to the United States and are subject to its jurisdiction and control. Since enactment of the National Environmental Policy Act of 1969 on January 1, 1970 (42 U.S.C. secs. 4321-4347), oil and gas lease sales on the Outer Continental Shelf have been made subject to the NEPA review (environmental impact statement) process. The Secretary of the IV-1 LIBRARY U- Ut I {/AOAMA-CHAMPAIBM through the bureau of Land Management, is authorized, under the provisions of section 8 of the OCS Lands Act, to grant oil and gas leases to the highest responsible qualified bidder by competitive sealed bid procedures. By the terms of the lease, the lessee is granted the exclusive right to drill for, produce, and sell oil and gas (except helium) from deposits underlying the leased areas and to construct and maintain platforms and other necessary structures within the leased area. A copy of a standard OCS lease form is in¬ cluded at the end of this section as appendix IV-1. After the leases are issued by the Bureau of Land Management, De¬ partment of the Interior, oil and gas operations are administered by the Department of the Interior through the Geological Survey. Appro¬ priate national operating regulations (30 CFR 250) were first issued in 1954, and supplemented by regional regulations, known as OCS Orders for the Pacific Region. The regulations (30 CFR 250.34) also provide that the Geological Survey is authorized to approve permits to drill in order for the lessee to enjoy the rights granted by the lease. a. U. S. Geological Survey The Geological Survey Regulations governing Outer Continental Shelf (OCS) oil and gas operations in the Santa Barbara Channel are contained in Part 250, Title 30, Code of Fed¬ eral Regulations. These Regulations are further implemented by Pacific Area OCS Orders Nos. 1 through 12. IV-2 After the Platform A spill of January 28, 1969, the Geological Survey OCS Regulations were revised effective August 22, 1969, and the latest revision of the Pacific Area OCS Orders was effective May 1, 1975. The net effect of the changes that have been made in these latest revisions has been to define more clearly the responsibility of lessees to conduct safe operations and authority of the supervisor to regulate operations, to exercise tight control over drilling, production, and waste disposal, and to require equip¬ ment fully adequate for the safe conduct of operations. b. Department of Transportation (1) U. S. Coast Guard The OCS Lands Act delegates to the Coast Guard the authority to promulgate and enforce regulations covering warning devices, safety equipment, and other matters related to the promotion of safety of life and property on fixed OCS platforms and drilling vessels. The imple¬ menting regulations for this delegation are contained in Title 33 of the Code of Federal Regulations, Part 67 and Sub-chapter N. Parts 140 to 147. Other Coast Guard regulations cover safety equipment on all types of offshore facilities and boats, specific personnel licensing procedures, minimum manning levels for ships and boats, and prohibit the discharge of pollutants from all vessels.^ (2) Office of Pipeline Safety The Department of Transportation is authorized under the Natural Gas Pipeline Safety Act of 1968 (49 U.S.C. secs. 1671, et seq.) 1 The Coast Guard's responsibility as to oil spill containment and clean-up is discussed under the heading "Contingency Plans" in this section. A memorandum of understanding between the U. S. Geological Survey and the U. S. Coast Guard is also discussed under this heading. IV-3 LIBRARY U- OF #_ Ufill SI Afyt - CHAMPAIGH to establish gas pipeline safety standards for transportation of gas and for pipeline facilities. The standards apply to the design, installation, inspection, testing, construction, extension, operation, replacement, and maintenance of pipeline facilities. Gathering, transmission or distribution by pipeline or storage in or affecting interstate or foreign commerce is included in the meaning of transportation of gas. The Secretary of Trans¬ portation is authorized to advise, assist and cooperate with other Federal departments in the planning and development of the standards and in methods for inspecting and testing to determine compliance with the standards. Regulations implementing the Department's authority are found at 49 CFR Parts 192 and 195. c . Regulation of Waste Water Discharged into the Santa Barbara Channel PCS Waters See section II.G.2.d.(3) for a description of the present waste discharges resulting from the five existing OCS Santa Barbara Channel platforms. The presently existing standards for oil and gas operation related discharges into OCS waters are cited in this section in the OCS Order discussion (see the excerpts from OCS Orders 7 and 8), however, it should be pointed out that these requirements and standards could be sub¬ stantially changed in the future. The OCS Orders are continuously evolving and the sections governing waste water disposal requirements are presently under consideration for revision. Also contributing to the likelihood that waste water disposal requirements will be continuously revised as deemed necessary in the future, are certain sections of the Federal Water Pollution Control Act Amendments of 1972 applicable to some aspects of OCS discharges resulting from oil and gas operations. IV-4 d. Environmental Protection Agency The Environmental Protection Agency as administrator of certain sections of the Federal Water Pollution Control Act as amended in 1972 have responsibilities and jurisdiction for certain aspects of OCS oil and gas operations waste disposal programs. (See the following subsection for further discussion of the Federal Water Pollution Control Act Amendments of 1972.) By memorandum of April 13, 1973, to the Environmental Protection Agency, the Department of the Interior suggested that the feasibility of a memorandum of understanding between the two agencies be considered in order to facilitate the administration of the 1972 amended act as it applies to discharges arising from OCS lease operations and to minimize any redundancy of efforts by the Geological Survey and the Environmental Protection Agency. (1) The Federal Water Pollution Control Act Amendments of 1972 The Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C. §§ 1251-1376 (Supplement III, 1973) (hereinafter, the Act) makes the discharge of any pollutant by any person, except in compliance with certain sections of the Act, unlawful. To carry out the objectives of the Act, there shall be achieved not later than July 1, 1977, effluent limitations for point sources which shall require the application of the best practicable control technology currently available. A National Pollutant Discharge Elimination System (hereinafter, NPDES) is created by section 402 and made applicable to discharges into the territorial sea, the waters of the contiguous zone, or the oceans by section 403. Permits for such dis» charges will be issued by the Administrator (Environmental Protection Agency) in compliance with guidelines to be promulgated by him. Prior to promulgation of such guidelines, permits may be issued if the Administrator determines it to be in the public interest. While the NPDES appears to IV-5 UBRARY U. Of /. «f?a4AM-CHAMPAIBH apply to fixed platforms and structures, it does not apply to ( 1 ) the addi¬ tion of any pollutant to the waters of the contiguous zone or the ocean from any vessel or floating craft, except drill ships, or ( 2 ) water, gas, or other material which is injected into a well to facilitate production of oil or gas, or water derived in association with oil or gas production and dis¬ posed of in a well, if the well used either to facilitate production or for disposal purposes is approved by authority of the State in which the well is located, and if such State determines that such injection or disposal will not result in the degradation of ground or surface water resources. Regula¬ tions governing the NPDES may be found at 40 CFR, Part 125, 38 F 0 R. 13528 (1973) and the guidelines issued pursuant to section 403(c) of the Act may be found at 40 CFR, Part 227, 38 F 0 R. 12872 (1973). To assist in administering the Act the Administrator is authorized by section 501Cb) to utilize the officers and employees of any other agency of the United States (with the consent of the head of such agency). By memorandum of April 13, 1973, to the Environmental Protection Agency (EPA), the De partment of the Interior suggested that the feasibility of a memorandum of understanding between the two agencies be considered in order to facilitate the administration of the NPDES as it applies to discharges arising from OCS lease operations and to minimize any redundancy of efforts by the Geological Survey and the Environmental Protection Agency. The Federal Water Pollution Control Act Amendments of 1972 (33 U.S.C. §§ 1251 - 1376 (Supplement III, 1973)) requires that the States adopt and enforce certain guidelines and standards, subject to the Environmental Protection Agency (EPA) approval, within a given time for certain things to be accomplished. IV-6 In early 1975, standards, regulations, and enforcement responsibilities under the FWPCA Amendments of 1972 should become better defined and estab¬ lished by EPA and the U. S. Geological Survey for OCS produced waste water discharges. The Environmental Protection Agency (EPA) prepared a "Draft Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Oil and Gas Extraction Point Source Category" (October 1974). This is a draft document, subject to changes resulting from comments received, which presents the findings of an extensive study of the oil and gas extraction industry for the purposes of developing effluent limitation guidelines and pre-treatment standards for the industry to implement Sections 304, 306 and 307 of the FWPCA of 1972 (PL 92-500). Supporting data and rationale for the development of proposed effluent limitation guidelines and standards of performance are contained in this development document. In late 1974, EPA issued Santa Barbara Channel OCS platform operators draft permits to discharge treated produced waste water into Federal OCS waters. These are draft permits and the stipulations and conditions are subject to change. In the Federal Register, Vol. 40, No. 179 (September 15, 1975) the Environ¬ mental Protection Agency published interim final effluent limitations and guidelines for existing discharge sources by establishing 40 CFR Part 435. Portions of this interim final rule making (Subpart B) is applicable to the discharge of produced waste water (and other waste) into OCS waters. In Subpart B, the oil and grease maximum for any one day is 72 ppm and the average daily values for 30 consecutive days shall not exceed 48 ppm. IV-7 (2) State of California and U. S. Ge ological Survey Responsibilities as to Oce an Waste Discharges Arising from Oil and Gas Operations According to the Environmental Protection Agency (EPA), under section 402 of the Federal Water Pollution Control Act (FWPCA), permits are authorized to be issued by the Administrator (EPA). However, a State may develop and submit to the Administrator (EPA) a program for the issuance of permits for waste discharge into waters within its jurisdiction. Approval of a State program by the Administrator (EPA) does not confer upon the State the authority which the FWPCA grants the Administrator (EPA) with respect to the issuance of permits for discharge into the contiguous zone and the ocean. If a platform is located within the territorial waters of the State of California, a State permit would be required. If, however, the platform is located beyond the 3-mile limit (as would be any platforms installed as a means of furthering Santa Barbara Channel OCS production) application must be made to the Administrator (EPA) for a permit to discharge into waters at the platform and the U. S. Geological Survey would enforce such permit require- r waste discharge ments. OCS operators will have to comply with the applicable/regulations existing at the time production begins. Those regulations might rule out certain types of discharge or they might have effluent characteristics speci¬ fications which would be economically infeasible for certain production opera tions. Should this be the case, the operator would be required to propose an alternative disposal method such as subsurface injection, which would also be under stringent regulations. e. Corps of Engineers, United States Army The OCS Lands Act provides that the authority of the Secretary of the Army to prevent obstruction to navigation in the navigable waters of the United States is extended to structures located in the OCS. The Corps of Engineers implements this delegated authority by issuing navi¬ gational permits for exploration drilling vessels and fixed and mobile IV-8 platforms. In issuing these permits, the Corps only considers those hazards related to navigation and national defense. f. Other Agencies The California State Lands Commission is responsible for California tidelands to their boundary with Federal waters. The California Division of Oil and Gas reviews proposals for underground water disposal to insure that potable water sources will not be adversely affected. The waste water disposal by onshore subsurface injection (i.e., as proposed for the Santa Ynez Unit onshore treating and storage facility) would be in accord¬ ance with Section 502(6)(B) of the Federal Water Pollution Control Act (1972 amendment), and subject to approval by the California State Division of Oil and Gas. The State of California and the Counties of Santa Barbara and Ventura have each established air quality regulations for facilities within their jurisdiction. The U. S. Bureau of Land Management is respon¬ sible for the administration and issuance of OCS leases, and under the National Environmental Policy Act of 1969 is responsible for the assessment of foreseeable environmental impacts that could result from the development of mineral deposits on the public lands. The U. S. Bureau of Sport Fish¬ eries and Wildlife is responsible for the conservation and management of fish and wildlife resources and can provide advice and assistance on bio¬ logical, chemical, and physical factors affecting these resources. National Marine Fisheries Service has similar responsibilities by law in the marine and estuarine areas. The Geological Survey cooperates with the Sport Fish¬ eries and Wildlife and the National Marine Fisheries Service in helping to minimize harm to fish and wildlife resources.* Numerous other agencies ^ A memorandum of understanding exists between the U.S. Geological Survey, the U.S. Bureau of Land Management, and the U.S. Bureau of Sport Fisheries and Wildlife as to the regulation of geophysical operations involving explosives. IV-9 UBRARY U- OF *- U litlSl PJSi. Clf/liUPAlKM regulate various aspects of the proposed development including construction and operation of the product transportation units; occupational health and safety; pipeline and marine berth design and operation; and emissions from internal combustion engines. Anyone wishing to obtain detailed information on specific regulations applicable to a particular part of this proposal should contact the appropriate agency. Inasmuch as the Geological Survey regulations, and more specifically the Pacific Area OCS Orders, cover the basic OCS oil and gas operations they will be briefly described here and referred to throughout this Environ¬ mental Impact Statement. g. Pacific Area OCS Orders The twelve Pacific Area OCS Orders are the field level implementation of the authority delegated to the Secretary of the Interior by the Outer Continental Shelf Lands Act of 1953. The authority for each OCS Order is a subpart of Part 250 of Title 30 of the Code of Federal Regulations. These orders are issued by the Pacific Area Supervisor, with prior approval of the Chief, Conservation Division, U. S. Geological Survey. The field-level enforcement of these OCS Orders is performed by the Santa Barbara District Engineer and his staff. The present Pacific Area OCS Orders evolved from the earliest issued orders dated March 31, 1965. Additional OCS Orders will be prepared and issued and the existing orders are revised as the need occurs. Several existing OCS Orders are presently undergoing revision and new orders 1 These regulations (Part 250, Title 30, Code of Federal Regulations) and the Pacific Area OCS Orders may be obtained from the U. S. Geological Survey, Oil and Gas Operations, Pacific Area, 7744 Federal Building, 300 North Los Angeles Street, Los Angeles, California 90012. IV-10 are being prepared by the Geological Survey • PCS Order No. 1 OCS Order No. 1, entitled "MARKING OF WELLS, PLATFORMS, AND FIXED STRUCTURES," covers the identification of wells and structures as required by the Geological Survey. With respect to structures, this order specifies that the identification be of a size and so located as to be legible from either the surface of the water or the air. There are addi¬ tional requirements that all structures be equipped with navigational aids but these are Coast Guard requirements covered by their regulations (33 CFR, Subchapter N. Parts 140 to 147). OCS Order No. 2 OCS Order No. 2 presents an example of constant review of OCS Orders. Currently OCS Order No. 2 is in its second major revision and was printed in the Federal Register, Vol. 40, No 0 222, November 17, 1975. It should become effective April 1, 1976, barring any other major changes. After an OCS Order is published in the Federal Register, comments are accepted from interested parties prior to its finalization. In general, the draft OCS Order No c 2, "DRILLING PROCEDURES", covers requirements for well casing and cementing, blowout prevention, mud programs, supervision and training, direction surveys, hydrogen sulfide control, critical operations, and curtailment plans. Well casing and cementing requirements indicate casing setting depths and how the casing is to be driven or set. Blowout prevention and mud programs are spelled out in detail in OCS Order IV-11 LIBRARY U. OF /. OOA/I AM - CHAMPAiBH No 0 2 to aid prevention of well blowout and encourage safety of personnel. Prescription of directional survey frequencies for each portion of drilling activity is provided to assure bottom hole locations for safe, efficient, and authorized operations. - In the revised OCS Order No c 2, hydrogen sulfide detection and control requirements are spelled out in detail. At all times, from when drilling operations are initiated until the well s completion or abandonment, OCS Order No. 2 requires maintenance of rig floor surveillance by a member of the drilling crew or the supervisor. Training program requirements include well control and abnormal pressure detection methods. Also required in the order are weekly blowout prevention drills. Written verification of compliance with Order provisions is re¬ quired to be filed with the District Engineer. OCS Order No. 2 requires filing of critical operations and curtailment plans with the District Engineer for approval. Minimum critical operation and guidelines for curtailment plans are provided in the Order. OCS Order No. 3 OCS Order No. 3, "PLUGGING AND ABANDONMENT OF WELLS," spells out in detail the plugging, with cement or mud, that must be done for either a permanent or temporary abandonment„ A permanent abandonment requires the placement of a top cement plug and various other plugs across all oil, gas, and fresh water zones so as to prevent the migration of formation fluids from one zone to another. All casing, wellhead equipment, and anchor piling must be removed to a depth of at least five feet below the ocean floor. IV-12 OCS Order No. 4 Entitled "SUSPENSIONS AND DETERMINATION OF WELL PRODUCIBILITY," OCS Order No. 4 established the criteria for determining whether a well is capable of producing oil or gas in paying quantities. It is significant because establishing producibility of at least one well on a lease permits extension of the primary term of the lease. This is the only OCS Order that has no relationship to safety and environmental protection. OCS Order No. 5 OCS Order No. 5, "INSTALLATION OF SUBSURFACE SAFETY DEVICE," is completely related to safety and environmental protection. A subsurface safety device is a valve installed in the tubing of a well, at some distance below the mudline, which closes and shuts the well in if abnormal producing conditions develop. There are two basic types: (1) direct-controlled, which depends upon an increase in velocity or pressure differential across the valve to cause it to close or (2) surface-controlled, which is a spring- loaded, normally closed valve that is held open by the application of pres¬ sure from the surface. Industry and the U. S. Geological Survey consider that surface-controlled valves are more dependable than direct-controlled valves. In the Pacific Area, the use of surface-controlled subsurface safety devices became mandatory not later than one year after the effective date of the current OCS Orders, or on June 1, 1972. Actually, this require¬ ment did not create a major problem because Santa Barbara Channel OCS operators had only about a dozen direct-controlled valves in use at the time of the effective date of the OCS Orders. These few valves have been changed to surface-controlled valves. To insure safety, or security, subsequent OCS Orders require that a primary control system be backed up by secondary and in some cases even tertiary IV-13 LIBRARY U- OF l W/JylAM CirfAMPAlKH systems. The subsurface safety valve system backup is provided as follows: First, the safety valve is backed up by automatic wellhead valves. Then, as production moves downstream from the wellhead, there is additional backup. Production vessels and surge tanks are equipped with high-low level and pressure shut-in sensors. , Shipping pumps, for moving production to shore, are similarly equipped. In the Pacific Area an electronic system is in operation that compares input to a pipeline that serves several platforms with receipts onshore. The system maintains a continuous short-term and long-term readout of this comparison at the onshore facility. If a differ¬ ential exists between these readouts, and exceeds a preset value, an alarm sounds and emergency action is taken. When this system was originally installed, it was tested by simulating a leak of one barrel per minute (through a bypass) on a pipeline carrying 58 barrels per minute and the system responded immediately. A leak of 1.4 percent of the flow rate can be immediately detected. Thus, for a production rate of 40,000 barrels per day a leak of more than 24 barrels per hour would be quickly detected. Additional safety devices are installed within the surface pressure system that maintains the subsurface safety valves in the open position. This pressure control system is an integral part of the platform shut-in system. It can be activated manually, automatically, locally, or remotely. Fusible links are placed at strategic points in the pressure control lines which, if melted, dissipate pressure and activate all valves in the system. PCS Order No. 6 OCS Order No. 6, "PROCEDURE FOR COMPLETION OF OIL AND GAS WELLS," addresses itself to the pressure specifications and testing of wellhead equipment and the procedure for multiple tubingless completions. IV-14 OCS Order No. 7 The title of OCS Order No. 7 is ’’POLLUTION AND WASTE DISPOSAL.” 1 2 This Order is of major importance. It covers the full gamut of pollution control from prevention to removal. With respect to prevention, it speci¬ fies the appropriate manner in which liquid and solid wastes may be dis- 2 posed. Additionally, it requires that all production facilities be operated and maintained in a manner necessary to prevent pollution and that both operator and non-operator personnel be informed and instructed in equipment operation for the prevention of pollution. As a preventive measure, it requires that all drilling and production facilities be inspected periodi¬ cally by the operator for potential sources of pollution (Geological Sur¬ vey personnel also perform frequent inspections and tests). If pollution does occur, the Order sets forth a reporting procedure for notifying appro¬ priate persons and agencies and requires that immediate corrective action be taken. Additionally, it requires that pollution control equipment be readily available to all operations. This equipment may be maintained on the particular facility or, at the discretion of the Area Supervisor, may be land based. Over the past few years, several nonprofit organizations have been formed 3 along the Pacific Coast, for pollution control and removal. Excerpts from OCS Order No. 7 are reproduced on the following three pages. 1 OCS Order No. 7 has been printed as a poster notice and this notice must be posted in a conspicuous place on all OCS drilling vessels, platforms, and related crew and supply boats. 2 The disposal of produced wastewater and sewage is covered by the pro¬ visions of OCS Order No. 8. However, the Geological Survey plans to move all provisions on waste disposal to OCS Order No. 7. ^ Oil Spill Contingency Plans will be discussed later in this section. IV-15 LIBRARY U. OF g. iJRBSi JV4 CigAM AlGH 2. Pollution Prevention. In the conduct of ell oil and gas operations, the operator shall not pollute land or water. The operator shall comply with the following pollution prevention requirements. A. Liquid Disposal . (1) The disposal of produced waste water and sewage shall be in accordance with the provisions of OCS Order No. 8. (2) Oil shall not be disposed of into ocean waters. (3) Liquid waste materials containing substances which may be harmful to aquatic life or wild¬ life, or injurious in any manner to life or property, shall be treated to avoid disposal of harmful substances into the ocean waters. (4) Drilling mud containing oil or toxic substances shall not be disposed of into the ocean waters. B. Solid Waste Disposal . (1) Drill cuttings, sand, and other solids containing oil shall not be disposed of into the ocean waters. (2) Mud containers and other solid waste materials shall be transported to shore for disposal. C. Production Facilities . (1) All production facilities, such as separators, tanks, treaters, and other equipment, shall be operated and maintained at all times in a manner necessary to prevent pollution. IV-16 (2) The operator's personnel shall be thoroughly instructed in the techniques of equipment main¬ tenance and operation for the prevention of pollution. Non-operator personnel shall be informed in writing, prior to executing con¬ tracts , of the operator's obligations to prevent pollution. 2 • Inspections and Reports . The operator shall comply with the following pollution inspection and reporting requirements and operators shall comply with such instructions or orders as are issued by the Supervisor for the control or removal of pollutants: A. Pollution Inspections . (1) Manned drilling and production facilities shall be inspected daily to determine if pollution is occurring. Such maintenance or repairs as are necessary to prevent pollution of ocean waters shall be immediately undertaken and performed. (2) Unattended facilities, including those equipped with remote control and monitoring systems , shall be inspected at intervals as prescribed by the District Engineer and necessary maintenance or repairs immediately made thereto. B. Pollution Reports . (1) All spills or leakage of oil and liquid pollutants shall be reported orally without delay to the District Engineer and the Coast Guard and shall be followed by a written report to the District Engineer showing the cause, size of spill, and action taken. (2) All spills or leakage of oil and liquid pollutants of a substantial size or quantity and those of any size or quantity which cannot be immediately con¬ trolled, shall be reported orally without delay to the Supervisor, the District Engineer, the Coast Guard, and the Regional Director, Environmental Protection Agency. (3) Operators shall notify each other upon observation of equipment malfunction or pollution resulting from another's operation. Control and Removal . a Corrective Action. Immediate corrective action shall be taken in all cas^s where pollution has occurred. Each operator shall have an emergency plan for initiating corrective action to control and remove pollution and _ such plan shall be filed with the Supervisor. Corrective action taken under the plan shall be subject to modi 1 - cation when directed by the Supervisor. B. Equipment. Standby pollution control equipment shall be maintained at each operation or shall be immediately available to each operator at an onshore location. This equipment shall include, but need not be limited to, containment booms, skimming apparatus, and chemical dispersants and shall be available prior to the commence¬ ment of operations. This equipment shall be the most effective available resulting from the current state of pollution control and removal research and development efforts. The equipment shall be regularly inspected an maintained in good condition for use. The equipment and the location of land bases shall be approved by the Supervisor. Chemical dispersants shall not be used without prior approval of the Supervisor . The operator shall notify the Supervisor of the location at which such equipment is located for operations conducted on each lease. All changes in location and equipment maintained at each location shall be approved by the Supervisor. IV-18 OCS Order No. 8 OCS Order No. 8 "APPROVAL PROCEDURE FOR INSTALLATION AND OPERA¬ TION OF PLATFORMS, FIXED AND MOBILE STRUCTURES, AND ARTIFICIAL ISLANDS," is quite lengthy, totaling a little over 12 pages. In part, it covers general design and non-design features, the manner in which the application for installation must be filed, and a requirement that the detailed struc¬ tural design plans be certified by a registered professional engineer. Also, it covers safety and pollution control equipment and procedures for welding practices. Various backup systems as applied to production handling facilities were men¬ tioned under OCS Order No. 5, and one example was given. Much of the detail of these systems is set forth in OCS Order No. 8. In the part covering weld¬ ing practices and procedures, the requirements are relatively general in nature, touching only on the highlights of safe welding precautions. The main thrust of this part of the Order is to minimize all welding and burning on any structure. To this end, the policy according to the regulations is: if it can be done onshore, do it there and haul it out to the structure; if it must be done on the structure, it should be done in a pressurized welding room, but, if this proves impossible, use backup measures to insure safety. These backup measures consist of the appointment of one or more persons des¬ ignated as "fire watch" dressed in distinctive attire and equipped, at a mini¬ mum, with a portable gas detector and fire extinguishers. Although waste disposal is for the most part dealt with in OCS Order No. 7, a portion of OCS Order No. 8 addresses itself to the disposal of produced waste water and sewage. This portion of OCS Order No. 8 will be moved to OCS Order No. 7 in the near future. Excerpts from OCS Order No. 8 are reproduced on the following three pages. IV-19 LIBRARY U- OF I. UK BA. AM Ci tAM PAI B H (3) Curbs, gutters, and drains shall be constructed and maintained in good condition in all deck areas in a manner necessary to collect all contaminants, unless drip pans or equivalent are placed under equipment and piped to a sump which will automatically maintain the oil at . a level sufficient to prevent discharge of oil into the ocean waters. Alternate methods to obtain the same results may be approved by the Supervisor. These systems shall not permit spilled oil to flow into the wellhead area. (4) An auxiliary electrical power supply shall be installed to provide emergency power capable of operating all electrical equipment required to maintain safety of operation in the event the primary electrical power supply fails. (5) The following requirements shall apply to the handling and disposal of all produced waste water discharged into the ocean waters overlying the submerged lands of the OCS. The disposal of waste water other than into these waters shall be approved by the Supervisor . (a) Water discharged shall not create conditions which will adversely affect the public health or the use of the waters for the propagation of aquatic life, recreation, navigation, or other legitimate uses. (b) Waste water disposal systems shall be designed and maintained to reduce the oil content of the disposed water to not more than fifty ppm. An effluent sampling station shall be located at a point prior to discharge into the receiving waters where a representative sample of the treated effluent can be obtained. On one day each month the effluent shall be sampled hourly for 8 hours and the following determinations shall be made on the composite sample: suspended solids, settleable solids, pH, total oil and grease content, and volume of sample obtained. Also the temperature of each hourly sample shall be recorded. All IV-20 samples shall be taken and all analyses for oil and grease content shall be per¬ formed in accordance with the latest edition of "Standard Methods for the Examination of Water and Wastewater”, published by the American Public Health Association, Inc. The Supervisor may approve different methods for determina¬ tion of oil and grease content if the method to be used is indicated to be reliable. A written report of the results shall be furnished to the Regional Office monthly. The report shall contain dates, time and location of sample, volumes of waste discharge on the date of sampling in barrels per day, and the results of the specific analysis and physical obser¬ vations. A visual inspection of the appearance of the receiving waters in the discharge area shall be made daily and the results recorded and included in the monthly report. (6) A firefighting system shall be installed and maintained in an operating condition in accordance with the following: (a) A fixed automatic water spray system shall be installed in all wellhead areas. These systems shall be installed in accordance with the current edition of National Fire Protection Association's Pamphlet No. 15. (b) A firewater system of rigid pipe with fire hose stations shall be installed and may include a fixed water spray system. Such a system shall be installed in a manner necessary to provide needed protection in areas where production handling equipment is located. A firefighting system using chemicals may be considered for installation in certain areas in lieu of a firewater system in that area, if determined by the Supervisor to provide equivalent fire vrotection control. (c) Pumps for the firewater systems shall be test- operated weekly. A record of the tests shall be maintained on a structure in the field and submitted semi-annually to the District Office. An alternate fuel or power source shall be installed to provide continued pumv operation during platform shutdown unless an alternate firefighting system is provided. IV-21 (d) Portable fire extinguishers shall be located in the living quarters and in other strategic areas. (e) A diagram of the firefighting system showing the location of all equipment shall be posted in a prominent place on the structure and a copy submitted to the District Office. (7) An automatic gas detector and alarm system shall . be installed and maintained in an operating condition in accordance with the following: (a) Gas detection systems shall be installed in all enclosed areas containing gas handling facilities or equipment and in other enclosed areas which are classified as hazardous areas as defined in API RP 500 A and B and the current edition of the National Electric Code. (b) All gas detection systems shall be capable of continuously monitoring for the presence of combustible gas in the areas in which the detection devices are located. (c) The central control shall be capable of giving an alarm at a point not higher than 60 percent of the lower explosive limit. (d) The central control shall automatically activate shut-in sequences and emergency equipment at a point not higher than 90% of the lower explosive limit. (9) Sewage disposal systems shall be installed and maintained in satisfactory operating condition in all cases where sewage is discharged into the ocean waters. 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 1.0 mg/liter after a minimum retention time of fifteen minutes. Sewage treatment records shall be maintained and made available for inspection upon request. The records shall reflect the results of monthly tests. These tests shall include determination of BOD, suspended solids, and chlorine residual. IV-22 OCS Order No. 9 OCS Order No. 9 is entitled "APPROVAL PROCEDURES FOR PIPELINES". This title is somewhat misleading in that it covers more than approval procedures. It covers general design, appli¬ cation procedure for installation, and a completion report of the actual installation, including testing. Under general design, there are requirements for safety devices which function to protect the line as well as minimize pollution in the event that damage or failure occurs. Also, there are operating procedures directed to¬ ward protection, inspection, and maintenance of the line throughout its lifetime. The metering system which provides a continuous comparison of the input to a line at a structure, or structures, with deliveries onshore, was mentioned under OCS Order No. 5. This metering system is a general design requirement of OCS Order No. 9. Order No. 9 does not apply to common-carrier pipelines except where one is connected to or crosses a platform. In this sense, the pipe¬ lines which are being referred to are the gathering lines or flow lines used to move production to an onshore processing facility. In the Pacific Area, the production as it leaves a platform is not in a saleable condition. It is treated at the onshore facility to a saleable condition after which it passes a "point of sale" and is no longer under the jurisdiction of the Geological Survey. The Area Oil and Gas Supervisor is authorized to grant easements or rights-of-way and to approve the installation of gathering lines or flow lines. He is not authorized to take these same actions for IV-23 common carrier pipelines. This authority is vested in the Bureau of Land Management. Excerpts from OCS Order No. 9 follows. (1) All oil and gas pipelines leaving a structure receiving production from the structure shall be equipped with a high-low pressure sensor to shut in the wells on the structure. (2) All oil and gas pipelines delivering production to either offshore or onshore production facili¬ ties , or both, shall be equipped with an automatic shut-in valve, at or near the receiving facility, connected to an automatic and a remote shut-in system. (3) All oil and gas pipelines coming onto a structure or delivering production to an onshore facility shall be equipped with a check valve or a quick- operating manual valve, as approved by the Supervisor, at or near the structure or facility to control backflow. (4) All oil and gas pipelines crossing a structure which do not deliver production to the structure, but which may or may not receive production from the structure, shall be equipped with sensors to activate an automatic shut-in valve to be located in the upstream portion of the pipeline at or near the structure to avoid uncontrolled flow at the structure. This automatic shut-in valve shall be connected to either the structure automatic and remote shut-in system or to an independent remote shut—in system. (5) All oil pumps and gas compressors shall be equipped with high-low pressure shut-in devices. (6) All oil pipelines shall have a metering system to provide a continuous volumetric comparison of input to the line at the structure, or structures, with deliveries onshore. The system shall include an alarm system and shall be of adequate sensitivity to detect significant variations between input and discharge volumes. In lieu of the foregoing, any system capable of detecting small leaks in the pipeline may be substituted with the approval of the Supervisor. B. All oil and gas and other pipelines shall be protected from loss of metal that would endanger the strength and safety of the lines by methods such as protective coatings or cathodic protection. IV-24 C. All oil and gas and other pipelines shall be installed and maintained to be compatible with trawling operations and other uses. D. All oil and gas and other pipelines shall be hydrostat¬ ically tested to 1.25 times the designed working pressure for a minimum of 2 hours prior to placing the line in service. E. All oil and gas pipelines shall be maintained in good operating condition at all times and the ocean surface above the pipeline shall be inspected a minimum of once each week for indication of leakage using aircraft, floating equipment or other means. Records of these inspections including the date, methods, and results of each inspection shall be maintained by the operator and submitted to the District Engineer annually by April 1. The operator shall immediately notify the District Engineer of any pipeline leak and within one week shall submit a report to him with respect to the cause, effect, and remedial action taken. F. All oil and gas and other pipelines shall be designed and maintained for protection against water currents, storm scouring, soft bottoms, and other environmental factors. G. An external inspection of all pipelines by side scan sonar or other means acceptable to the Supervisor shall be made at least once each year to identify all exposed portions of pipelines. All exposed portions of pipelines shall then be inspected in detail by photographic or other means acceptable to the Supervisor to determine if any hazards exist to the line or other users of the area. If a hazard is found to exist, appropriate corrective action shall be taken. Records of these inspections including the date, methods, and results of each inspection, shall be maintained by the operator and submitted to the District Engineer when the records become available. 2. Application . The operator shall submit in duplicate the following to the District Engineer for forwarding and approval by the Supervisor: A. Drawing on a plat or plats showing the major features and other pertinent data including: (1) water depth, (2) route, (3) location, (4) length, (5) connecting facilities, (6) size, and (7) burial depth, if buried. IV-25 OCS Order No. 10 OCS Order No 0 10, "DRILLING OF TWIN CORE HOLES," was of major significance during the years immediately preceding the February 6, 1968 lease sale in the Santa Barbara Channel. It allowed twinning of State- permitted core holes which had been drilled, under State jurisdiction, in the disputed area of the Santa Barbara Channel, following a 1965 Supreme Court decision that established the areas of State and Federal jurisdiction 0 Under this twin-coring program, 53 twin core holes were drilled, thus per¬ mitting a freer exchange of information among the potential bidders at the Santa Barbara Channel lease sale. Order No. 10 is still effective and au¬ thorizes the drilling of twin core holes on the unleased lands of the Outer Continental Shelf off the coast of southern California. However, it appears unlikely that there will be any such action in the near future. OCS Order No. 11 OCS Order No 0 11 entitled "OIL AND GAS PRODUCTION RATES, PRE¬ VENTION OF WASTE, AND PROTECTION OF CORRELATIVE RIGHTS," provides for the prevention of waste and conservation of the natural resources of the Outer Continental Shelf, the protection of correlative rights and is applicable to all oil and gas wells on Federal leases in the Outer Continental Shelf of the Pacific area. Methods to establish oil and gas production rates are spelled out in OCS Order No. 11 and covers establishing, increasing, decreasing, conditions for cancellation, and justification for continuance by quarterly well test. The Order requires operators to submit plans and to initiate enhanced oil and gas recovery operations. The Order prescribes balancing periods to establish continuous production IV-26 at the well's maximum production rate or the reservoir's maximum efficient rate. Provisions for mandatory balancing is provided for in OCS Order No. 11 . Provisions for flaring and venting are included in the Order to minimize waste and due considerations for economics and safety. An application for approval must include all appropriate engineering, geologic, economic data showing premature abandonment of oil and gas production or curtailment of lease development, and a comparison of additional oil and gas that would not be recovered should the application to flare or vent be rejected. The Order requires well completions, enabling maximum efficient recovery control. Requirements are given for competitive reservoirs providing for definitions, development and production plans, and possible unitization. In the interest of conservation, the Conservation Manager can require unitization. Well testing requirements include provisions for type, fre¬ quency, and reporting. OCS Order No. 11 includes provisions enabling the Conservation Manager to call conferences on his own initiative or at the request of interested parties. The Order requires copies of decisions be given to all interested parties and situations for appeals are provided for. OCS Order No. 12 OCS Order No. 12 was established due to Public Law 90-23 "Public Information Act" requiring identifiable agency records be made available for inspection. It specifies which records may be available, and provides for appeals to the Solicitor of the Department of the Interior. Rules included in this order may result in increased production of oil and gas by making available useful information. OCS Order No. 12 enables dissemination of information in a fair, orderly manner and still keeping confidentiality of privileged documents. h o Policies and Recommendations of the California Coastal Zone Conservation Commission on Petroleum Development As noted earlier (section I.F.2.a.) the California legis- lature has two years, December 1975 through 1977, to act upon these policies and recommendations, and subsequently concurrence by the Department of Commerce is required for Federal status. Additionally local implementation plans are recommended by the Commission, and are to be completed within three years after California State adoption of the Plan (California Coastal Zone Conservation Commission, 1975). The following policies specific to petroleum development are reproduced from p. 123-127 of the Plan. The USGS, along with numerous other agencies and entities commented on the Preliminary Coastal Plan through regular channels. Policies 81. Basic Policy for Offshore Petroleum Develop¬ ment. New offshore oil and gas development shall be permitted if: • The Federal Government (for Federal Outer Continental Shelf lands) or the State Energy Commission, State Lands Commission, coastal agency, and other appropriate State agencies (for offshore State lands) have clearly identified development of the offshore petroleum resource as: (1) an integral and high-priority part of a comprehensive, balanced national energy con¬ servation and development program that gives consideration to full-scale energy conservation programs, alternative energy source develop¬ ment, and short- and long-term resource availa¬ bility; or (2) a necessary energy source for California and Petroleum Administration for Defense District V (PAD V, consisting of Cali¬ fornia, Arizona, Nevada, Oregon, Washington, Alaska, and Hawaii), considering energy con¬ servation and alternative energy sources de¬ velopment measures and also considering the anticipated inflow to California and PAD V of oil and other forms of energy from all other sources (e.g., onshore oil production, Alaska North Slope oil and gas production, production IV-23 in other regions of Alaska, and foreign oil an< gas imports) and California’s projected capa¬ cities to refine and store the anticipated inflov of oil from these sources; and * The coastal agency has determined that the possible impacts on coastal marine, air, and onshore resources resulting from offshore petroleum development are acceptable under the policies set forth in the Coastal Plan. 82. Recommendation to Separate Permit Revi«/ of Petroleum Exploration Phase and Developmer/ Production Phase. In order that, prior to a decisin whether to grant private companies the right to develop and produce publicly owned offshore arl onshore petroleum resources in the coastal zone as much data as possible can be acquired about the resources, their value, and the offshore an< onshore environmental impacts of production, it is recommended that the present system foi leasing State lands for oil and gas production t changed to separate permit review of the explo ration phase from the development/productior phase, as follows: a. Exploratory Phase. Exploratory drilling on lease shall proceed only after (1) the State Lands Commission has prepared an enviroi mental impact report (EIR) on the exploratory phase activities; (2) the coastal agency has issued a permit for the exploratory phase ac¬ tivities;' and (3) the State Lanas Commission has approved an exploration program. Development and Production Phase. Develop¬ ment and production shall proceed only after (1) the State Lands Commission has prepared an EIR on all aspects of the development and production phase; (2) the Energy Commission has made a formal finding of-need for the oil and gas resources discovered during explo¬ ration; (3) the coastal agency has reviewed the Energy Commission’s finding of need, evaluated the environmental and land use planning aspects of the development and pro¬ duction phase, and has issued a permit; (4) the Energy Commission, if it is given statewide authority for siting offshore and onshore oil and gas production activities and facilities (as recommended in Policy 76), has issued its certification; and (5) the State Lands Com¬ mission has approved a development and pro¬ duction program. The EIR on the development and production phase shall include one-, five-, and 10-year plans for development, production, and all related offshore and onshore develop¬ ment, including platforms, submerged pro¬ duction systems, pipelines, separation, treat¬ ment, and storage facilities, refineries, harbor facilities, and tanker terminals anticipated. It shall also describe the economic, environ¬ mental, and aesthetic impact on the immediate area and the entire coastal zone of offshore and onshore facilities and operations, including all transportation and distribution facilities, and all measures to mitigate any environmental hazards of onshore and offshore activities, in¬ cluding alternatives to the anticipated facilities, programs for containment and recovery of potential oil spiils, and improvements in marine traffic lanes, navigational equipment, and traffic control. To the extent such infor¬ mation is not provided in the EIR, the coastal agency shall require that it be submitted during the coastal permit review. Following sub¬ mission of an application for development and production that includes complete and adequate information about the resource and all proposed activities and facilities, a decision shall be rendered within a defined period of time, to be set by the Legislature. It is recom¬ mended that the Legislature also give full con¬ sideration to possible alterations in other aspects af leasing that may be complementary to the proposed separation of the exploration and pro¬ duction decisions, including alternative forms of bidding that could reduce the size of cash bonus bids; government sponsorship of or par¬ ticipation in exploration; and appropriate com¬ pensation for any company denied the right to produce discovered petroleum reserves. c. If the Leasing System Is Not Changed. If the present leasing system is not changed as recommended above, the EIR preparation and permit review process proposed above for the development and production phase shall be applied for all phases prior to granting permission for exploration. 83. Criteria for Siting and Design of Petroleum Facilities. On publicly or privately owned lands in the coastal zone, offshore and onshore drilling and production and related facilities shall be per¬ mitted where, in addition to the standards set forth in Policy 11, all of the following criteria are met. Compliance shall be required by the coastal agency as a condition of any required coastal permit, by the State Lands Commission as a condition of a lease on State-owned lands, and by the Division of Oil and Gas. a. Use Best Well Sites. Proposed well sites shall be the least environmentally hazardous and aesthetically disruptive sites feasible. b. Assure Geologic Safety. The geologic charac¬ teristics of proposed well sites shall be ade¬ quately evaluated and determined to be con¬ sistent with safe drilling and production. c. Consolidate Drilling, Production, and Pro¬ cessing Sites. Petroleum-related facilities and operations shall be consolidated (i.e., drilling, production, separation facilities, and support sites shall be unitized — developed and operated as a unit by a single company or group of companies for the benefit of all interested companies — or shall be shared) to the maximum extent feasible and legally permissible, unless such consolidation will have adverse environmental consequences and will not significantly reduce the number of producing wells, support facilities., or sites required to produce the reservoir economically and with minimal environmental impacts. Unitization negotiations shall be entered into by all operators covpring one producing struc¬ ture, and unitization of a new offshore field shall be carried out before commercial pro¬ duction is initiated. The unitization or conso¬ lidation requirements shall apply to (1) all types of offshore platforms; (2) submerged production systems; (3) onshore drilling and IV-29 LIBRARY U. OF /_ UK BA. AM CHAMRA1 B H production facilities; (4) pipelines; (5) separa¬ tion, treatment, and storaae facilities; (6) trans¬ fer terminals related to petroleum production; (7) rights-of-way for transporting produced oil and gas; (8) equipment lay-down areas; and (9) port facilities to supply and service offshore platforms. d. Use Submerged Systems Where Feasible and Environmentally Safe. Subsea completion of wells and submerged production systems shall be used where environmentally safe, as demon¬ strated through adequate testing of equipment by industry, observed by the appropriate go¬ vernment agencies, and where technically and economically feasible. Where oil platforms or islands would have a substantial adverse envi¬ ronmental effect, including degradation of aesthetic values, no offshore drilling shall be permitted unless and until subsea comple¬ tions or submerged production systems are demonstrated to be environmentally safe. e. Platforms Preferred Over Islands; Minimize Impact of Platforms. Where subsea drilling, completion, or production is found to be in¬ feasible or environmentally unsafe, thereby making platforms or islands necessary to de¬ velopment of the resource, or where platforms are necessary to service subsea systems, the following criteria shall apply: • Platforms shall be preferred over islands wherever safety considerations permit. • The number of offshore platforms shall be minimized by using each platform to drill as many wells, and/or to service as many subsea completion and production systems, as is technically and economically feasible. • The design of the platforms or islands shall be consistent with the general design criteria of the Coastal Plan and shall be subject to review and approval by the immediately land¬ ward local governments as well*as by the coastal agency and State Lands Commission. • The waters surrounding new platforms or islands shall be open to sport fishing, diving, and boating, consistent with boating safety rules and practices. • If an island is determined to be needed, multi-purpose public interest uses, including small-boat landing piers and amenity public recreation areas, scientific and educational facilities (e.g., marine biology, oceanography and metereology research stations), Coast Guard or U.S. Weather Service station, or aquaculture operations, shall be incorporated into the project to the extent technically and economically feasible and consistent with public safety and other policies of the Coastal Plan. • All water that contacts working surfaces of oil islands (including rain runoff) shall be contained and not allowed to drain in an un¬ treated state into the ocean. Treatment shall be adequate to remove essentially all petro¬ leum or unnatural amounts of chemical re¬ sidues from the estimated maximum amounts of runoff water. • Platforms or islands shall not be sited where a hazard to vessel traffic might result from the facility or related operations. Platforms shall not be permitted until a navigational safety system for coastal waters is in effect, in accordance with Policy 119. f. Minimize Impact of Petroleum Facilities Onshore. Drilling, production, and support facilities onshore, including separation and treatment plants, pipelines, transfer terminals storage facilities, and equipment lay-down areas, shall be designed and located to minima their adverse environmental impacts consisten with recovery of the resource. Where such or shore development would result in substantia impacts on the resources of the coastal zone it shall be permitted only where there is a need for the project (as specified in Policy 81), when feasible alternatives would have a greater ad¬ verse environmental impact, and technology that would substantially reduce such impacl will not be available in the immediate future (e.g., new technology for carrying out subse< production, oil and gas separation, storage and natural gas liquefaction that might redus the need for large onshore facilities). g. Prevent Subsidence; Reinject Oil Field Brinei Liquid and gas extraction projects thatcoul cause or contribute to subsidence hazard (where there is a potential for significant present or future damage to property or envi¬ ronment) shall be prohibited; such existing operations shall be stopped, unless it is dete mined that there is no reasonable alternate In such cases, the best available technique for minimizing or preventing land subsidenc shall be utilized. Lease or unit operators coi structing new facilities shall reinject all oil fiel brines into oil producing zones unless injectic into other subsurface zones will reduce env ronmenta! risks. Exceptions to reinjection wi be granted only after approval bytheappri IV-30 priate agencies (including the Regional Water Quality Control Board) of detailed plans ade¬ quately providing for the elimination of petro¬ leum odors and all potential fresh water or ocean water quality problems. Monitoring pro¬ grams to record land surface and nearshore ocean floor movements shall be continued in all areas of subsidence problems and shall be initiated in locations of new large-scale fluid extraction on land or nearshore before opera¬ tions begin. Such monitoring shall continue during and after liquid and gas extraction operations until surface conditions have sta¬ bilized. Costs of monitoring and mitigation programs shall be borne by liquid and gas extraction operations, overseen by an appro¬ priate State agency. . Recommendations for Increasing Oil Recovery ficiency. It is recommended that the Legislature enact legislation to require the California vision of Oil and Gas and the State Lands Com- ssion to regulate petroleum completion and Dduction for individual wells, including setting tximum efficient rates of production, as ana- jous government agencies do in other major -producing states; and (2) adopt a resolution ling for the Federal Energy Administration encourage primary, secondary, and tertiary Jduction from existing wells. . Recommendation for Disclosing Exploration d Production Data. To improve the information se for State energy planning and to encourage Moratory activities, thereby encouraging pos- »le petroleum discovery and production both shore (where petroleum activities are environ- >ntally preferable) and offshore, it is recom- inded that the Legislature require all original Dioratory and production data from surveys drilling of wells (including all logs, complete II histories, cores, drilling cutting, water nples, chemical analyses, pressure and tem- rature measurements, etc., but excluding jprietary interpretive information) on publicly privately owned California lands to be sub- tted within 60 days after finishing to the /ision of Oil and Gas, with appropriate as- 'ances of strict confidentiality, and to be made blic information one year after submittal, :ept that where such public disclosure would iult in severe inequity to a well operator, year- year extensions of confidentiality may be inted by the Division of Oil and Gas. The ergy Commission and the State Lands Com- ssion shall be allowed access to all such data a confidential basis for the purposes of energy ource development planning. 86. Recommendations for Avoiding Adverse Impacts of Federal OCS Petroleum Development. It is recommended that the Governor, the Legis¬ lature, the California congressional delegation, and all concerned State agencies seek agreement from the Department of Interior and other Federal authorities that Federal Outer Continental Shelf (OCS) leases will be approved by the Department of Interior only if the following conditions are met: a. Demonstration of Need. Need for Federal OCS develoDment off California shall be clearly determined as required in Policy 81. b. Develop and Disclose Long-Term Plans. One-, five-, and ten-year plans for petroleum pro¬ duction and all related development as des¬ cribed above in Policy 82, and their impacts on the California coast, shall be fully developed and disclosed. It is recommended that the present leasing system be changed to separate pre-production exploration from the decision to develop and produce on a lease, in order that data about the OCS resource, its value, and the offshore and onshore environmental and planning implications of developing and producing the resource can be accumulated prior to a decision as to whether private com¬ panies should be given the right to produce. c. Provide for Public Review. Opportunities for effective review of proposed OCS exploration and development plans shall be provided for the general public, interested units of State, regional, and local government, and other segments of the communities most immediately affected by OCS development activities. d. Prevent Drainage of State Petroleum Sanctua¬ ries. The leases in question shall be sufficiently separated from the State petroleum sanctuaries to prevent drainage of oil and gas reservoirs that may lie partially on State submerged lands. e. Establish Stringent Safety Standards. Petro¬ leum production under Federal jurisdiction off the California coast shall be made subject to safety standards at least as stringent as those for production on State-regulated offshore areas, including those contained in the Cali¬ fornia Division of Oil and Gas regulations and the manual of procedures of the State Lands Division and standards set forth in Coastal Plan policies. (See especially Policies 11, 83, and 119.) f. Evaluate Unitization or Consolidation Possibi¬ lities. The possibility of unitization or conso¬ lidation of all operations and facilities both offshore and onshore shall be fully evaluated and required where feasible, as described in Policy 83(c) for California operations. IV-31 LIBRARY li. OF /. UK BA, NLA. PAI fci M g. Consider Use of Subsea Systems. The possi¬ bility of use of submerged drilling, completion, and production systems that have been ade¬ quately tested to meet rigid environmental safety standards shall be fully evaluated as a partial alternative to platforms and required where technically and economically feasible, except where use of platforms would not cause any significant adverse aesthetic or other envi¬ ronmental impact. h. Some OCS Revenues Should Go to States. It is recommended that the Federal government provide funds to California and to other coastal states prior to leasing, with the funds to be reimbursed either through a fee related to pro¬ duction volumes, or by making available a portion of its revenues from OCS lease sales or production royalties, or by granting funds from some other source, to assist the State and local governments in (1) planning for and over¬ coming or mitigating any adverse impact of this production (e.g., planning for transportation terminals, additional refineries, pipelines, sepa¬ ration, treatment, and storage facilities, and other support facilities in a way that minimizes environmental impacts); and (2) purchasing land for recreation or providing other amenities along the coast to help offset the impact of OCS development. i. Designate Sanctuaries in Certain Areas. Sites and tracts shall be designated as Federal petroleum resource sanctuaries (1) if they are unusually subject to the risk of oil spills due to geological seismic disturbance; or (2) if they offer unusual coastal aesthetic assets or the local economy is particularly dependent upon the protection of coastal aesthetic assets. Portions of the Santa Barbara Channel, Mon¬ terey Bay, Santa Monica Bay, and San Pedro Bay would appear to be candidates for sanc¬ tuary status. j. Compatibility with Coastal Plan Policies. Federal OCS development and related acti¬ vities shall be compatible with all other policies set forth in the Coastal Plan. IV-32 2 « Inspection Progra ms and Approval Requirements - Uo S. Geological Survey To see that the Geological Survey Regulations and OCS Orders are fully observed, a comprehensive inspection system has been developed. OCS operators must receive approval before commencing any work. Operators are required to submit a notice and detailed description of all work they desire to perform. All applications to drill are submitted to the District Engineer, and are thoroughly reviewed and analyzed prior to approval or recommendation for approval to the Supervisor. Simple procedures such as removing, servicing, or replacing a sub-surface valve, modifying a header, flowline, or other piping, also require approval. Each procedure or appli¬ cation is reviewed by a petroleum engineer 0 If necessary, the program is either discussed with the operator or additional information is requested and reviewed prior to approval. The objective in this requirement for ad¬ vanced approval is to insure that no operation is conducted without thorough planning for safety, conservation, and protection of the environment, and to determine that all oprations meet the requirements established by the re¬ vised regulations and OCS Orders. Santa Barbara Channel OCS operation inspections are performed by the Santa Barbara District office. Before the January 28, 1969 Platform A spill, one petroleum engineer and one engineering technician were assigned to the Santa . (February 1976) Barbara District. The Santa Babara District staff presently/consists of three petroleum engineers and eight engineering technicians. The engineering tech¬ nicians spend nearly full time in the field. The Assistant District Engin¬ eer divides his time between the office and the field and the District IV-33 3 ivJiwHrj wv vaxn / Ja Engineer spends most of his time in the office. The eight engineering tech¬ nicians spend an average of 300 man-hours per week inspecting operations in the Santa Barbara Channel, where currently there are five OCS platforms and two onshore facilities receiving production from the platforms. At present two floating drilling vessels operate in the Santa Barbara Channel; except for brief intervals, no more than two floating drilling vessels have oper¬ ated at the same time. The ratio of Santa Barbara District personnel to the number of Santa Barbara Channel operations has permitted the Geological Survey to scrutinize closely all operations. In addition to this detailed field supervision provided by the Santa Barbara District, the Pacific Area office, the Western Region office, and the Geological Survey headquarters also closely follow and direct the Santa Barbara Channel operations. a. On-Site Inspections All operations, regardless of the activity, receive regular on-site inspection for compliance with the regulations and OCS Orders. Operations in the Dos Cuadras field (Platform Hillhouse, Lease OCS-P 0240, and Platforms A and B, Lease OCS-P 0241) are inspected daily. The inspector is on the facility for an 8-hour period, randomly observing various opera¬ tions, testing equipment, and checking for pollution. The production and drilling decks are checked at least three times during this inspection period. Conversation with operating and contract personnel has proven to be a worthwhile means of being alerted to potential hazards and the need to replace or modify existing equipment. Platforms Hogan and Houchin, Lease OCS-P 0166 are inspected at least once a week. Critical operations are observed regardless of what time of day or night they occur. Two onshore processing facilities handle all of the Federal OCS lease fluid and gas production. The production from Lease OCS-P 0166 is processed at the Phillips La Conchita plant and production from Leases OCS-P 0240 and OCS-P 0241 is processed at the Mobil Sea Cliff plant; both plants are near Rincon Point. These two plants are inspected weekly. Also Lease Automatic Custody Transfer (LACT) meter provings are regularly monitored at these two onshore facilities. If a floating drilling vessel or drilling unit has not been in service for some time or if a drilling unit is new to the area, a IV-34 detailed inspection is performed to insure conformance with regu¬ lations and OCS Orders, before commencement of drilling operations. These predrilling inspections are comprehensive and often require several days to complete. After a well has been spudded and normal drilling is in progress, drilling inspections are performed at least weekly. It is not uncommon to make daily drilling inspections at certain wells. Again, all critical phases of drilling operation are observed whatever time during the day or night they may occur. C-^i-tii-cal phases include, but are not limited to, casing-cementing operations, casing and blowout equipment pressure tests,line-lap pressure tests, wireline work, drill-stem formation tests, and any other tests or operations not considered to be routine. When a well is either abandoned or suspended, a Geological Survey inspector witnesses the setting of all required cement plugs, the cutting off of the several casing strings below the sea floor, and the removal of all subsea equipment. b. Semi-Annual Inspections and Enforcement Procedures In addition to the daily and weekly inspections, and the observation of all critical operations, each onshore and off¬ shore facility is subjected to a 6-month inspection. During this comprehensive test, an inspection team tests each safety device and piece of equipment as required by the OCS Orders. If the device or equipment malfunctions, it must be repaired or replaced. During a typical inspection, approximately 650 items are tested at a facil¬ ity. All malfunctioning equipment and incidents of noncompliance IV-35 LIBRARY U- OF /. UKBAKA-CHAMPM&H. (INC) must be immediately corrected by the operator. Normally these detailed inspections require 2 weeks for the inspection team to inspect one onshore or offshore facility. Following is a tabulation of INC's that were issued for Santa Barbara Channel Platforms A and B, lease OCS-P 0240 during seven semi-annual inspections. NUMBER OF INC's ISSUED Inspection Date March 1974 Sept. 1973 March 1972 Dec. 1972 June 1972 Jan. 1972 June 1971 The June 1971 semi-annual inspection was the first of this type detailed inspection. It must be kept in mind that for example the S incidents of noncompliance (INC's) issued for Platform A during the March 1974 inspection were minor in nature and resulted from the testing of approximately 2,400 items (there are thousands of potential INC's). Platform A 5 8 35 44 35 15 122 Platform B 8 7 10 30 26 10 113 c. Other Inspections In addition to inspecting and witnessing operations, beach walks are frequently made to check for oil pollution. Fixed-wing aircraft and helicopter flights are made (normally biweekly) to check for oil pollu¬ tion and to chart the natural oil seepage. Also, boat surveys are made in immediate areas of operation and many points in the Santa Barbara Channel to check for oil pollution. These beach walks and aerial and boat surveillances cover an area from Point Conception to Port Hueneme. The testing of new oil-spill containment and cleanup equipment in the Santa IV-36 Barbara Channel is frequently witnessed. Also inspected are the areas utilized by various oil companies and Clean Seas, Inc., for storing booms, skimmers, pumps, barges, and other oil-spill containment and cleanup equipment. 3. Enforcement The enforcement policy is intended to reduce the frequency of noncompliance with lease requirements that may lead to loss of life, loss of property and resources, or damage to the environment. In 1971 new and more detailed standardized inspection procedures were established for OCS operations. The requirements in the OCS Orders and Regulations were expressed as a check list of specific items relating to safety equipment and procedures. The items reflect the existence of potentially hazardous condi¬ tions if the specified equipment is missing or not operable, or specified procedures are not followed. This compilation of items is titled "List of Potential Items of Noncompliance and Enforcement Action," and referred to as the (PINC) list. The Santa Barbara District has prepared a PINC list, consisting of approximately 2,400 items, for each platform and onshore facility. During the inspection of drilling and production operations, depending on the hazard presented toward safety or pollution, either a written warning is given that allows the operator 7 days to correct the incident of non- compliance (INC), or a shut-in order is issued. The shut-in order may be applied only to the equipment affected by the incident of noncompliance (INC), such as a particular piece of production equipment or a producing zone, or to the entire drilling rig, production platform, or onshore facility. To date, in the Santa Barbara Channel, incidents of noncompliance have been IV-37 LIBRARY U. OF /_ URBAN A PAJ B M minor in nature, requiring only a warning that corrections be made within 7 days. The operators have never failed to comply within the 7-day limit except on a few occasions whereby the operator acquired an extension of several days from the Geological Survey. There have been a few cases where the operator was required to immediately bypass a particular piece of equipment until it was repaired or replaced and in certain instances this in turn necessitated that production be temporarily cut back or that drilling be temporarily interrupted. Additional penalties for noncompliance are specified in sec. 5(a)(2) of the Outer Continental Shelf Lands Act (43 U.S.C. sec. 1334(a)(2)). "Any person who knowingly and willfully violates any rule or regulation prescribed by the Secretary for the prevention of waste, the conservation of 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 the violation shall be deemed a separate offense.” Also sec. 5(b)(1) and (2) provide for cancellation by notice of nonproducing and producing leases subject to judicial review or appropriate judicial proceedings. 4. Contingency Plans Oil spills occasionally occur as a result of natural disasters, equipment failure, or human error. For this reason OCS Order No. 7 sets forth a reporting procedure for notifying appropriate persons and agencies and requires that immediate corrective action be taken. 1 Additionally, it requires that all OCS operators have an approved spill contingency plan 1 Earlier in this section OCS Order No. 7 was discussed and exerpts were included. IV-38 which includes spill cleanup and containment equipment. This pollution control equipment may be maintained on the particular facility or, at the discretion of the Area Supervisor, may be land based. The operators in the Santa Barbara Channel have pooled resources and formed Clean Seas, Incorpo¬ rated, to supplement their individual spill cleanup contingency plans. Additionally, there is the National Contingency Plan which in turn requires Regional Contingency Plans. a * Organizations Formed by Companies for Spill Contain ment and Removal --- During the past 5 years, organizations have been formed, along the Pacific Coast, for pollution control; these function in the manner of fire stations. These organizations are of two basic types: (1) a nonprofit corporation which has its own equipment; or (2) a cooperative organization which has contracted for the use of local, privately owned equipment. The Washington State Oil Spill Cooperative operates off the State of Washington. Although this organization covers all of the coast of Washing¬ ton, its primary area of interest is Puget Sound. The Oregon State Oil Spill Cooperative is headquartered in Portland. It has been organized to contain and remove any oil spillage on either the coastline or rivers of Oregon. A small cooperative has been formed at Eureka, California, and operates off the northern California coast. In the San Francisco area, a corporation known as Clean Bay, Incorporated has been founded. In the Santa Barbara Channel, some 15 State and Federal lease operators have formed a nonprofit corporation called Clean Seas, Incorporated. In the Los IV-39 UBRAR.V li. OF /. fWB^/M-CHAASPAIBS Angeles-Long Beach-San Diego area, there is a cooperative group known as P.I.C.E., which is an acronym for Petroleum Industry Coastal Emergency Cooperative (recently changed to "Clean Coastal Waters"). These six cooperative groups provide complete coverage of the Pacific (hast between the Canadian Mexico borders. In addition, similar type groups are presently being formed in Alaska, Canada, and Hawaii. These nine organizations are referred to as the "Pacific Basin Oil Spill Cleanup Organizations." Inasmuch as Clean Seas, Incorporated, is the emergency cooperative that covers the Santa Barbara Channel, it will be discussed in more detail. b. Clean Seas, Incorporated Clean Seas, Incorporated, (CSI), is comprised of 15 oil companies operating in the Santa Barbara Channel Area. The membership agreement allows the member companies involved to supple¬ ment their individual contingency plans by using all, or any part of, the CSI organization. CSI is also available to nonmembers and government agencies such as the Coast Guard, the Environmental Protection Agency, and the Navy for combating oil spills related to nonmembers. The managers of the Pacific Basin Oil Spill Cleanup Organizations meet in planning sessions approximately every 3 months. One bene¬ ficial product of these meetings is a mutual assistance agreement, involving Clean Seas, Inc., Clean Bay, Inc., and the other clean-up IV-40 organizations, providing Clean Seas, Incorporated, with considerable back¬ up equipment to support its own inventory. Provisions can be made for the rapid transportation of this equipment by Coast Guard C-130 aircraft or helicopter 0 The Coast Guard and Navy also have spill containment and clean¬ up equipment that will be made available for spill situations meriting such action. Following is an inventory of CSI basic equipment on hand as of November 1975„ (1) Inventory of Equipment and Materials-Status as of November 1975 (a) Containment • 2,000* Bottom-Tension Boom : This is a heavy duty, open ocean containment boom with 4' x 13 1 floats and 8* curtain, extending 3-1/2* above water line and 4-1/2* below water line 0 Usually stored on land and deployed from beach; requiring 24 hours for 1,000* length if unassembled. At the present time Clean Seas Incorporated is working on an assembled mode storage on land. Capability : Will contain oil in 6-8 foot significant waves and winds to 25 knots at currents up to 1-1/4 knots 0 • 1,600* Vikoma Seapack and Seaboom 2 units For very fast response to oil spills, the VIKOMA Seapack with 1,600’ of Seaboom has been purchased. Seapack is based on a 23 foot hull and contains 1,600* of Seaboom connected at one end to a diesel driven fan and ducted propeller water pump a The VIKOMA Sea¬ pack unit can be transported by road trailer, towed by a small vessel or carried on a workboat or tanker. It could also be trans¬ ported by aircraft. Capability : Experience in the English Channel and by the Swedish Coast Guard over the past several years indicated this boom can be on a scene and deployed in less than an hour c It is effective in preventing spread of oil in significant waves up to 6 feet and winds of 20 to 25 knots. In the mode in which this boom is used, there is little or no current across boom which could cause loss of oil due to IV-41 underflow. CSI exercises with this boom would parallel the Swedish Coast Guard's response and deployment time. Response is the major factor. Deployment is instantaneously accomplished on arrival at the site, 10-12 minutes. Harbor Protection Booms : 2,000 feet medium duty boom (16 M x 12” skirt - Kepner Sea Curtain) for harbor protection. 2,000 feet light duty boom (8” x 12” skirt - Kepner Sea Curtain) for secondary harbor protection. 1,210 feet Goodyear Sea Sentury medium duty boom 12-1/2” x 24", without fence in 55 foot sections) for harbor protection. 1 000 feet Expandi medium duty oil boom (12” x 18’ skirt). This boom may be used for offshore rapid deployment for contain¬ ment as well as harbor protection. (b) Recovery • CSI Skimmer System: One (1) CSI Skimmer System consisting of 45' x 17' x type adjustable weir skimmer barge, two 240' lengths Sea Curtain Boom, a 2,000 GPM pumping system and two oil-water, separation tanks. For fast response, the boom on board is anchored in Santa Barbara Harbor„ 6' catamaran- of 30” Kepner (2) 100 barrel skimmer with Capability : This system is capable of recovering all grades of oil from light to bunker C at rates up to 2,000 GPM plus some debris and sorbent material in moderate sea states. Modification to this skimmer will elininate the necessity of the tanks by installing a pump onboard and a 5,000 gallon floating storage bag. • Sea Dragon : One (1) Sea Dragon Skimmer System consisting of a 45' x 26' x 8' catamaran-type barge equipped with a liquid oil recovery system and a conveyor system for recovery of sorbent and debris, two 240' lengths of 30" Kepner Sea Curtain Boom and hydraulic system driven by a Niesen power package. The skimmer barge is anchored in Santa Barbara Harbor. Capability : This system is capable of recovering all grades of oil from light to bunker C at rates up to 150 GPM plus large amounts of debris and sorbent material in moderate sea states. IV-42 Mark-II Skimmer: Two (2) Mark-II Skimmers, 14* * x 30' weir type are available in Carpinteria Yard. These may be used, one on each side of a vessel or may be used singularly with a vessel. Recovery system can be either an 80-barrel, skid mounted vacuum tank or compressed air driven Wilden pumps and 100 bbl. oil-water separation tanks, all of which are available. Capability : These are very simple skimmers and may be used in a number of ways to solve the particular problem at hand. All grades of oil from light to bunker C can be recovered plus small amounts of debris. Fluid recovery rates from 50 GPM to 200 GPM are available. These skimmers are limited to light winds and light sea states. Trailers capable of carrying these skimmers on the highway have been con¬ structed. Also, one of these skimmers has been equipped with an 0/B motor, self-contained pump and 1,200 gallon floating storage bag. • Work Boat : One (1) 19' Larson skiff with 125 HP Johnson motor kept in Santa Barbara Harbor for use as work boat around skimmers and barge. One (1) 14' Valeo Skiff with 15 HP 0/B kept in CSI's Carpinteria Yard. • Truck : One (1) 2 1/2-tone used to tow Vikoma Seapack, boats, haul boom, absorbents, etc. • Compressor : One (1) Gardner-Denver 600 cfm rotary, diesel engine driven, wheel mounted compressor stored in Carpinteria Yard. Usually used with air tools and to drive the Exxon Floating Weir skimmers. Acme skimmers or the Wilden pumps. • Lines, Hoses, Tools : Complete set of all necessary sizes of nylon and polypropeline lines for deploying and towing booms and skimmers. Hoses of 2", 3" and 6" size for skimmers, all fitted with Camlock fittings. Air hoses for compressor. Complete sets of tools for all equipment. • Radio Communications System : A complete, clear channel, radio system on 40.04-48.62 MHz., pro¬ vides solid communication throughout the CSI area of interest. This system consists of: IV-43 LIBRARY U. OF /_ URBANJi CHAMPAi K M 1 base station in Santa Barbara office 1 base station in Carpinteria Warehouse 1 portable base station 1 repeater on Santa Ynez Peak 1 mobile unit in Manager's car 14 portable Handie-Talkie Units • Oil Mop MK-11-9 : One (1) MK-11-9 Oil Mop System consisting of a two-wheel trailer. Oil Mop Machine, Tail Pulleys and 400' of 9" Mop. Stored at CSI's Carpinteria Yard. Capability : This system is primarily used in protected waters, will recover all grades of oil. Maximum capacity 100 bbls/hr. • 40' Enclosed Trailer Vans : Two (2) Trailers stocked with booms, absorbents, small skimmer, miscellaneous cleanup equipment. Will be stored in CSI's Carpin¬ teria Yard at this time. • Exxon Floating Weir Skimmers : Three (3) Floating Weir Skimmers, compressed air driven Acme-type pump, are available in Carpinteria Yard. These were designed to collect oil concentrated in the B-T Boom area and work best in thick concentrations of oil. Also, ideal for recovery of oil in harbor areas and quiet waters. Capability : These skimmers will handle light to fairly heavy oil with no debris in 2-3 foot waves. Fluid recovery rates are up to 300 GPM for each skimmer. • One (1) Acme 39T Gasoline or air driven pump, available in Carpinteria Storage Yard. This pump is designed to collect oil in somewhat heavy concentration. Ideal for harbor areas. Will recover oil in open ocean in light seas. Fluid recovery rates up to 340 GPM. Light in weight can be handled by two men. One (1) Acme 5IT Same as above and will recover oil in open ocean in light to moderate seas. • Tide-Mar VII Barge : One (1) 641-ton tank barge, Tide-Mar VII, for collecting oil picked up by skimmers as they work in an oil spill. This is a 160'x39'xl3' IV-44 ocean-going barge with 10 tanks, capacity of 7,840 barrels, and six diesel engine driven pumps. Presently moored in the harbor at Port Hueneme, California. • Air Driven Pumps : Two (2) M15 Wilden double diaphram pumps. • Floating Storage Bags : (For interim storage awaiting transfer) 2 - 5,000-gallon Kepner Floating Storage Bags 2 - 1,200-gallon Kepner Floating Storage Bags (c) Miscellaneous • Absorbents and Chemicals : A large inventory of absorbents, including, Conwed: sweeps, blankets, booms, rugs; 3-M: sweeps, sheets and booms, and Dow Imbibers: bags and blankets, also, smaller quantities of Oil Herder, are kept in the Carpinteria Warehouse. Additional quantities are available as "back-up" from warehouses in the Los Angeles area. c « National Oil and Hazardous Substances Pollution Contingency Plan The National Oil and Hazardous Substances Pollution Contingency Plan was developed pursuant to the provisions of the Federal Water Pollution Control Act as amended. Section 11(c)(2) of that statute authorizes the President to prepare and publish such a plan. The National Contingency Plan was developed by the Council on Environmental Quality (CEQ) in June 1970, and revised in August 1971. The revised National Contingency Plan, after publication in the Federal Register (36 F.R. 162, August 20, 1971, p. 16215 et seq.), and amended on September 9, 1972 and December 21 1972, became the required national procedure for response to spills of oil and hazardous material. A new National Contingency Plan has been prepared by CEQ and published in the Federal Register (38 F.R. 155, Part II, August 13, 1973). This new Plan supersedes the one set forth in the Federal Register of August 20, 1971 (36 F.R. 16215) as amended on September 9, 1972 and December 21, 1972. The new National Contingency Plan has been prepared IV- 45 in conjunction with the National Response Teajn in light of both operating experience under the 1971 Plan and new requirements contained in Public Law 92-500. The plan is effective for all United States navigable waters, their tribu¬ taries, and adjoining shorelines. This includes inland rivers, the Great Lakes, coastal territorial waters, the contiguous zone, and high seas where there exists a threat to U. S. waters, shore-face, or shelf-bottom. Implementation of the objectives of the National Contingency Plan requires that a nationwide net of detailed regional contingency plans be developed. The U. S. Department of Transportation (Coast Guard) is responsible for regional plans for coastal waters and the Environmental Protection Agency (EPA) is responsible for regional plans for inland waters. The regional plan covering the Santa Barbara Channel waters will be discussed m detail inasmuch as it is the plan likely to be involved should a spill result from Santa Barbara Channel operations. d. Region Nine Multi-Agency Oil and Hazardous Materials Pollution Contingency Plan The Region Nine Contingency Plan, prepared by the Coast Guard, is effective for coastal waters within the Standard Federal Adminis¬ trative Region Nine, which is the area of California, Hawaii, Guam, American Samona and the U. S. Trust Territory of the Pacific Islands. The Region Nine Contingency Plan was issued by the Commander, Twelfth Coast Guard Dis¬ trict, December 1970 and revised December 1971„ This plan provides for a pattern of coordinated and integrated response by departments and agencies of the Federal Government to protect the environ¬ ment from damaging effects of spills. It also promotes the coordination and direction of Federal, State, and local response systems and encourages the development of local government and private capabilities to handle spills. The Region Nine Contingency Plan provides for and describes the functions of a Regional Response Team (RRT) and an on-Scene Coordinator (OSC ■'"The Coast Guard and the Environmental Protection Agency have an agreement as to geographic areas of responsibility relating to coastal waters and inland waters. IV-46 The roles of the RRT and the OSC as related to spills resulting from oil and gas operations will be further discussed later in this section. Region Nine is divided into sub-regions and zones for pollution planning purposes. Therefore the Region Nine Contingency Plan contains five appendices, one for each sub-region. The California Sub-region is divided into two zones, southern California (includes the Santa Barbara Channel) and northern California. The Appendix for California (Appendix I) is divided into two sections. The five appendices, one for each State and Territory are listed below: • Appendix I - California (Sub-region one) Zone One Section - southern California (includes Santa Barbara Channel) 1 Zone Two Section - northern California • Appendix II - Hawaii (Sub-region Two) • Appendix III - American Samoa (Sub-region Three) • Appendix IV - Territory of Guam (Sub-region Four) • Appendix V - The Trust Territories of the Pacific Islands (Sub-region Five) There are three Coast Guard districts within Region Nine: the Eleventh headquarters in Long Beach which is responsible for Appendix I, zone one; the Twelfth headquarters in San Francisco 1 Appendix I, Sub-region One, Zone One Section contains detailed, specific data that would be applicable to a Santa Barbara Channel spill. IV-47 which is responsible for Appendix I, zone two; and the Fourteenth Coast Guard District, Honolulu, which is responsible for Appendices II, III, IV, and V. For Sub-region One, zone one (the Southern California zone includ¬ ing the Santa Barbara Channel) the pre-designated On-Scene Coordi¬ nator (OSC) is the Commander, Eleventh Coast Guard District. In order to more effectively coordinate cleanup activities and to expeditiously establish and maintain liaison with local communities, the Commander, Eleventh Coast Guard District has delegated the res¬ ponsibility of OSC as follows: • Captain of the Port, San Diego - for waters adjacent to San Diego County. • Captain of the Port, Los Angeles/Long Beach - for waters adjacent to Los Angeles and Orange Counties. • Commander, Coast Guard Group Santa Barbara - for waters adjacent to Santa Barbara and Ventura Counties (the Santa Barbara Channel area) The Eleventh Coast Guard District, with the help of State and Federal agencies such as the California Department of Fish and and the Bureau of Sports Fisheries $ Wildlife, has compiled hundreds of pages of data for the southern California area, to aid the OSC in advising and making decisions during an oil-spill emergency. These data consist of such information as: coastline characteristics (shore and shoreline, accesses, outfall and inlets, beach usage, property owners controlling beach access, etc.), critical water uses. IV-48 marine biological factors, meterological and climatological factors, oceano graphic factors (i.e., current patterns, water characteristics). A portion of these data are physically incorporated into the Regional Contingency Plan; the remainder are on file and readily available. These data would be used to predict the movement of an oil spill and to determine the order of priority for protection and clean-up of certain areas. C 1 ) Regional Response Team and Qn-Scene Coordinator Functions ~ In the event of a spill originating from an oil and gas operation, the spiller is responsible for combating the spill. The Coast Guard OSC is to determine pertinent facts about the particular spill and give advice and assistance. If it is determined by the OSC and the RRT that the spiller is not capable of, or is not willing to, adequately combat the spill, the OSC will take over control of the operation and become the On-Scene Commander rather than On-Scene Coordinator. The Commanders of the Coast Guard Districts are responsible for chairing the regular RRT meetings and activating the RRT in the event of a spill situation meriting such action. The RRT consists of regional representa¬ tives of the primary and selected advising agencies, as appropriate. Twice in 1972, the RRT Chairman has arranged similated oil spills (one in the San Francisco Bay and one in the Santa Barbara Channel) to determine how the RRT and private concerns, such as oil companies and Clean Seas, Inc., would respond. These practices pointed out the need for more efficient communication and coordination between Federal agencies. State agencies, and private organizations such as Clean Seas, Inc. Appropriate private organizations are frequently invited. IV-49 LIBRARY U. OF /. £Wfi4ft^-CHAlWPAISM to attend the regular RRT meetings. The Coast Guard and Navy are Government members of the RRT with capability to supply oil-spill- combating equipment, and will do so for spills originating from oil and gas operations if the situation -justifies such action. The RRT advises the OSC during time of emergency and performs review and advisory functions relative to the regional plan. Additionally the RRT helps to determine if and when the On-Scene Coordinator should take over a spill-combating operation. The OSC is to fully inform and coordinate closely with the RRT to ensure the maximum effectiveness of the Federal effort to protect the natural resources and the environment from pollution damage. (2) U. S. Geological Survey and U. S. Coast Guard Responsibilities A memorandum of understanding between the Departments of the Interior and Transportation outlines the respective responsibilities of the Geological Survey and the Coast Guard as to spills originating from oil and gas operations. It spells out that the Geological Survey is responsible for the coordination and direc¬ tion of measures to abate the source of pollution. The Coast Guard is responsible for containment and removal operations. In 1973 it was determined that the Geological Survey and Coast Guard areas of responsibilities should be more specifically covered in the Regional Contingency Plan. A section (designated as Tab J) has been added to Appendix I of the Region Nine Contingency Plan, IV-50 describing the respective areas of responsibility and jurisdiction. Whereas the above-mentioned memorandum of understanding covers OCS oil and gas operations, the Tab J section, included in the Regional Contingency Plan, additionally covers the responsi¬ bilities of the California State Division of Oil and Gas and the Coast Guard as to spills originating from oil and gas operations in State waters. This Tab J section points out that abatement activities have priority over containment and removal operations. It also points out that the use of dispersants and other chemicals must be in accordance with Annex X of the Region Nine Contingency Plan. e » California Oil Spill Disaster Contingency Plan The State of California has developed the California Oil Spill Contingency Plan. This State Plan is similar to the National and Regional Contingency Plans but has been written from the standpoint of the State of California and the State agencies. It was framed in such a way as to serve as an extension of the Federal Plans. It provides also for the State's response organi¬ zations to act, whether or not Federal forces are activated. The State Contingency Plan provides for a State Operating Authority (SOA), and the SOA is charged with the responsibility and delegated authority for planning and directing the coordinated overall opera¬ tions for all State and local government agencies engaged in helping to combat a spill. The SOA coordinates these operations with Fed¬ eral agencies and private organizations and regularly participates IV-51 in the Regional Response Team meetings. The SOA, under the leadership of the Federal On-Scene Coordinator, directs the State and local government agency oil spill response operations. The State Oil Spill Contingency was revised March 1974. 5 . Status of Oil Spill Containment and Cleanup Technology Government, industry, and universities have pursued multi¬ million dollar research programs since the 1969 Platform A, Santa Barbara Channel oil spill to improve procedures and equipment to effectively deal with offshore oil spills. To date, however, no system or equipment has been developed which is completely effective in controlling and removing pollution under all weather and sea conditions. Development of improved systems is being continued at an accelerated level and the state of the art is improving rapidly. As a result of the Platform A blowout and the resulting subsequent pollution, the California State Lands Commission, in February 1969 revoked all existing exploration drilling permits and imposed a moratorium on all new drilling on existing State offshore leases. The basis for the moratorium, according to the State Lands Commission, was "the lagging state of technology in providing reliable oil containment and recovery techniques and devices." Due to advancing state of the art, on December 11, 1973, the State Lands Commission lifted the five year moratorium. The three member commission unanimously adopted a staff report indicating the oil industry has developed safety equip¬ ment and procedures that minimize the possibility of a major spill occurring and provide for effective clean-up in the event of a spill. The lifting of tl moratorium permitted drilling to be resumed on a lease-by-lease basis from existing facilities but does not include blanket approval of exploration drilling from floating drilling vessels, or the issuing of new leases. IV-52 In subsection IV.A.4., the National,regional, State,and industry oil spill contingency plans were described and their relationship to each other was discussed. It was also pointed out that simulated oil spill situations had been arranged so that all concerned were required to respond accordingly. A detailed inventory of Clean Seas, Inc. equipment (and capabilities) is included in this section. At the State Lands Commission hearings in Santa Barbara on September 20-21, 1973, the Coast Guard made a presentation on their research and development of a light-weight containment barrier that can be mobilized and deployed anywhere m the United States within four hours. This boom has contained soybean oil in seas approaching its effective design containment limit of five-foot seas. At the presentation the Coast Guard stated that they have people whose full-time job is dedicated to containment and removal technology and they mentioned that the Navy, Environmental Protection Agency, and industry are also deeply involved in the same type of research and development. A presentation on the state-of-the-art of oil containment and recovery devices was made by the Western Oil and Gas Association at the State Lands Commission hearings and Exxon made a similar presentation at the Santa Ynez Unit hearings in Santa Barbara on October 2-4, 1973. Exxon described its Bottom-Tension (B-T) containment boom which is the strongest such boom available today. Exxon stated that the boom had not been tested on the equivalent of the Santa Barbara Channel Platform A spill during a storm but that the B-T boom had, however, contained natural seep oil in six-to eight-foot seas. The ability of the B-T boom to operate and contain oil m at least six- to eight-foot seas allows the boom to be used in about 94 percent of Santa Barbara Channel sea conditions, and is approaching the limit that men can stay out and work safely. Table II-6 which presents information on the frequency of waves of IV-53 various heights and periods in the Santa Barbara Channel, shows that waves of six feet or greater heights can occur in all months of the year with minimum frequency of occurrence in July and August, Each boom (the B-T and Coast Guard boom) serves a definite purpose. The B-T boom provides three and one-half feet of freeboard (above the water) and four and one-half feet of barrier below the water. The Coast Guard boom was designed for quick deployment and provides 21 inches of freeboard and 27 inches of draft. The two booms are designed on a similar principle although the B-T boom is obviously designed for containment and survivability in more severe sea states than the air transportable Coast Guard boom. 6 . Mitigating Factors Involving the Relationship of Potential Activities to Shipping The main shipping lanes leading northward from Long Beach, California, traverse the Santa Barbara Channel (see plate I). The traffic lane scheme provides for a one-mile-wide traffic lane for each northbound or southbound ship, with a two-mile zone of separation between the lanes. By mutual agreement between the Coast Guard, the Corps of Engineers, and the shipping and oil industries, islands or fixed structures (fixed oil and gas platforms) must be located at least one-half mile from the boundary of the sea lanes. IV-54 The past record (no platform-vessel collisions off the west coast) consid¬ ered along with the present regulations, modern equipment, and the potential platform location areas, is the basis for the Geological Survey's concluding that the probability of a collision between a major ocean-going vessel and Santa Barbara Channel platforms is remote 0 Several witnesses at the Santa Ynez Unit public hearings expressed concern about the possibility of a vessel-platform collision because of the bad weather conditions "off Point Conception;" one individual pointed out that Point Conception historically was a center of marine disasters. However, it is important to realize that weather conditions "off Point Conception" are not indicative of the conditions in the general Santa Barbara Channel area. Also review of present traffic patterns should be made and consider¬ ation given to establishing areas of further control to minimize the chance of collision. Generally, visibility will be adequate to permit safe navi¬ gation. During periods of low visibility the existence of modern radar and adequate bridge attention should preclude the danger of collision. 7o Mitigating Factors Involving the Relationship of Potential Activities to Missile Overflights Vandenburg Air Force Base on occasion launches missiles that pass over parts of the Santa Barbara Channel area. These overflights are limited primarily to the extreme western part of the area. In October 1968, a detailed impact analysis was completed by Corn-Consultants, Inc., for the Western Oil and Gas Association, et al. The probability of platform damage resulting from missile overflight was determined to be ex¬ tremely low for all areas considered in the analysis. Corn-Consultants con¬ cluded that any construction design of protective shelters would probably be based upon subjective rather than objective engineering criteria. Prior to the February 1968 OCS Santa Barbara Channel lease sale, no quanti¬ tative analysis had been made to determine the effect of missile debris resulting from flight termination upon petroleum operations in the Santa Barbara Channel. Therefore, the oil companies were presented with "hold harmless" or "unconditional evacuate" lease stipulations as a part of certain IV-55 Santa Barbara Channel OCS leases. Certain of the Santa Barbara Channel leases contain one or the other, or both of the two stipulations quoted below Stipulation 1 . The lessee, recognizing that mineral explorations and exploitation and recovery operations on the leased areas of tide and submerged lands can impede tactical military operations, hereby recognizes and agrees that the United States reserves and has the right to temporarily suspend operations of the lessee under this lease in the interests of national security requirements. Such temporary suspension of operations, including the evacuation of personnel, will come into effect upon the order of Air Force Western Test Range Safety Officer, or higher authority, that national security interests necessitates such action. It is understood that any temporary suspension of operations ordered by said official may not exceed seventy-two hours, however, any suspension may be extended by order of the Secretary of Defense. During such periods equipment may remain in place. Stipulation 2 . The lessee assumes all risk of damage or injury to any person or persons who are the agents, employees or invitees of the lessee, its agents, sub-contractors or any independent contractor doing business with the lessee in connection with any activities being performed by the lessee on the leased premises, and of any damage to any property of the lessee, its agents, employees, invitees, sub-contractors or independent contractors doing business with the lessee and which occurs on the leased premises, and which injury to such person or property occurs by reason of the activi¬ ties of any agency of the United States Government being conducted as a part of or in connection with the programs and activities of the Air Force Western Test Range, whether such injury or damage is caused in whole or in part by any act or omission, regardless of negligence or fault, of the United States or its contractors, or any of their officers, agents or employees, and whether or not based upon any concept of strict or absolute liability or other¬ wise; and the lessee agrees to idemnify and save harmless the United States against, and to defend at its own expense, all such claims for loss, damage or injury sustained by the lessee, its agents, employees, invitees, sub-contractors or any independent contractors doing business with the lessee in connection with its activities on the leased premises, or their agents or employees, which such claims may arise by reason of injury or damage occurring in connection with the programs and activities of the said Air Force Western Test Range, whether the same be caused in whole or in part, by the negligence or fault of the United States or its contractors or any of their officers, agents and employees, or based upon any concept of strict liability or otherwise. IV- 56 The following leases require Stipulations 1 and 2: OCS-P 0168, 0169, 0170, 0171, 0172, 0173, 0174, 0175, 0176, 0177, 0178, 0179, 0182, 0183, 0184, 0185, 0193, 0194, 0195, 0196 and 0197. The following leases require only Stipulation 2: OCS-P 0180, 0181, 0187, 0188, 0189, 0190, 0191, 0192, 0200, 0201, 0206, 0211, 0212 and 0213. Santa Barbara Channel oil and gas operations must be coordinated with all military (Navy and Air Force) activity in the area. This mutual cooperation and coordination relationship has been successful with ongoing oil and gas, and military activities. 8. Studies on PCS Management and Operating Practices The purpose of this section is to describe studies recently completed and in progress. All of these studies efforts are directly re¬ lated to improvement of OCS management practices, operating procedures, and data bases. These studies and research efforts, by identifying problem areas, gaps, weaknesses, and prescribing preventive or corrective measures, fulfill an invaluable role for achieving the goal of reducing or eliminat¬ ing potential hazards to human life and to the environment. n. PCS Studies Analyzed by U. S. Geological Survey Work Group The U. S. Geological Survey Conservation Division contracted with the National Aeronautics and Space Administration (NASA) 1 , the Marine NASA, "Applicability of NASA Contract Quality Management and Failure Mode Effect Analysis Procedures to the USGS Outer Continental Shelf Oil and Gas Lease Management Program," November 1971. IV-57 LIBRARY U. OF I. llftBAKA-CHAMPAt&H. Board of the National Academy of Engineering , and an internal System 2 Laboratory Group of the Water Resources Division of the Geological Survey , to study its Outer Continental Shelf management and operating practices. These studies, initiated to obtain impartial and objective opinions and financed by the USGS Conservation Division, identified weaknesses in OCS operating regulations and procedures and recommended remedial measures. An analysis of the results of these studies was completed by a special Work Group of the U. S. Geological Survey in May, 1973, and a report on OCS safety and pollution control was issued. Implementation has commenced on all 15 recommendations made by the Work Group in its report. This initial Work Group report, dated May 1973, has been supplemented by a later report. Supplement No. 1, dated May 1974. The supplemental report (appendix IV-2) is for the purpose of considering recommendations from yet a later study, "Energy under the Ocean" (University of Oklahoma Report). The Council on Environmental Quality (CEQ) perforated a study, and prepared a report to the President of the United States on the environmental impacts of oil and gas operations on the Atlantic OCS and the Gulf of Alaska (April 1974). The Geological Survey has prepared a work group report, dated Novem ber 4, 1974, titled "Supplement No. 2 to Report of the Work Group on OCS Safety and Pollution Control, May 1973" (appendix IV-3). These later studies and responding supplemental Work Group reports Numbers 1 and 2 are discussed in subsections IV.A.B.b., c., d. and e, which follow 1 Marine Board, National Academy of Engineering, "Outer Continental Shelf Resource Development Safety: A Review of Technology and Regulation for the Systematic Minimization of Environmental Intrusion from Petroleum Products", December 1972. 2 USGS, "Outer Continental Shelf Lease Management Study", May 1972. IV-58 immediately the presentation below of the status of implementing the original 15 recommendations resulting from the initial studies. In many cases, the recommendations resulting from the later "Energy under the Ocean" study and the "CEQ Oil and Gas Operations Impact" study were varia¬ tions to the original 15 recommendations discussed below. Therefore, the Work Group supplemental reports Numbers 1 and 2, in considering these later recommendations, modified, added to, and improved on the 15 original recom¬ mendations . • Implementation Status of the Original Fifteen Recommendations The U. S. Geological Survey, Gulf of Mexico Area, is taking the lead responsibility for implementation of several of these recommendations. The Pacific Area is developing portions of the recommendations and is in the process of developing and revising OCS Orders. Pacific Area engineers are spending a part of their time in the Gulf of Mexico Area in coordina¬ ting these activities of the two Area offices. Inasmuch as the progress of the Pacific Area is related to the progress of the Gulf of Mexico Area, activities of both Areas are described. As of December 1975, the status of implementation actions were as follows (modification of these implementation actions as required by additional recommendations contained in Supplements 1 and 2, see appendices IV-2 and IV-3, are under way): IV-59 Recommendation No. 1. Failure Reporting and Corrective Action Action Taken: OCS Order No. 5 for the Gulf of Mexico has been revised and now requires operators to submit quarterly failure-analysis reports on subsurface safety devices. The Geological Survey is devel¬ oping procedures for closed loop failure report¬ ing and corrective action system which will include all critical platform safety components. The output from these systems will be computer¬ ized and will be analyzed by the safety review committee. The Pacific Area has been furnished the Gulf of Mexico Area revised OCS Order No. 5 for consider¬ ation and adaptation to the Pacific Area. The Pacific Area OCS Order No. 5 presently requires surface-controlled subsurface safety devices. Recommendation No. 2 . Accident Investigation and Reporting Action Taken : The legality of publishing investigation reports of major accidents has been affirmed by the Solicitor's Office of the Department of the Interior. The Regional offices of the Geological Survey are developing accident investigation reporting procedures which are more responsive to cause and effect relationships. The Pacific Area has performed a study on the advisability of statistics of accidents per man-hours worked by companies and reviewed all forms used in IV-60 accident reporting. Recommendation No. 3. Information Exchange Action Taken: A "Safety Alert" system has been initiated in the Pacific Area and Gulf of Mexico Area. With this system, operators are advised of accidents occur- ring during OCS drilling and producing operations to let industry know immediately of its own mis¬ takes and malfunctions so that improvements can be made where applicable. An information dissem¬ ination system will be designed to provide in¬ dustry with the results of the failure reporting and corrective action systems, accident investi¬ gations, inspections, and other potential hazard elements. Recommendation No. 4. Research and Development Action Taken: A cooperative committee on offshore safety and an "ti-pollution research was formed in conjunction with the American Petroleum Institute (API). The purpose of the committee was to determine the research and development efforts being undertaken by industry and Government in this area; determine specific needs for additional efforts; and tn con¬ tract research and development in areas where industry response was lacking or unsatisfactory. The committee was involved with the following projects: a) Sand probe IV-61 b) Orifice Coefficient program c) Oil detection and removal The committee disbanded, but the Geological Sur¬ vey is sponsoring the following projects: a) Pipeline behavior study b) Shallow high pressure gas zone research c) Mississippi River Delta Project. Recommendation No. 5. Standards and Specifications Action Taken: The cooperative committee on offshore safety and anti-pollution standards function was to estab¬ lish standards and specifications for safety and anti-pollution equipment. The first project undertaken by the committee was a recommended practice for design, installation and operations of subsurface safety valves„ The final copies of these standards are available from API. In connection with this, a facility for testing of subsurface safety valves was constructed and is operated by an independent research institute. With regards to existing devices, the Offshore Safety and Anti-Pollution Committee (OSAPE) reported that the procedures and requirements set forth in API Spec. 14-A and RP 14-B will enable the industry to identify problem areas and improve the reliability of subsurface safety valves (SSV’s). Specifically API 14-A requires IV-62 SSV performance and functional testing, manufac¬ turer quality assurance programs, and operator- manufacturer analysis. API RP 14-B and 14-B(S) provide updated installation and maintenance pro¬ cedures in addition to an accurate computer pro¬ gram for sizing subsurface controlled subsurface safety valves. The OSAPE Committee felt that the areas identified by industry for additional SSSV research such as operational reliability, perform¬ ance testing, design analysis and sizing, and seating and control hardware will be addressed in API 14-A and 14-B. In addition, the two API research projects on SSSV orifice coefficients and sand erosion are of highest priority and will also help establish better SSSV sizing calculations and improve SSSV reliability. In summary, the OSAPE Committee does not feel that additional research on existing SSSV equipment should be initiated until SSSV performance data generated from the use of API 14-A and 14-B has been gathered and analyzed and the two previously mentioned research projects have been completed. API RP 14C, a recommended practice for Analysis, Design, Installation and Testing of Basic Surface Safety Systems on Offshore Production Platforms, was the third document published by API. Pacific Area and Gulf of Mexico Area engineers IV-63 participated in the committee meetings. The joint API-GS committee was disbandedo The following additional standards have or will be issued by the API Committee: API Spec. 14D - Wellhead Surface Safety Valves API RP 14E - Design and Installation of Pro¬ duction Platform Piping Systems The following API documents are being formulated: API RP 14F - Electrical Systems on Offshore Production Platforms API RP 14G - Fire Control Systems on Offshore Production Systems The following appeared in the Federal Register Vol. 40, No. 25, Tuesday, December 30, 1975: OUTER CONTINENTAL SHELF Procededures for the Development of OCS Standards Pursuant to Supplement No. 2, November 1974, to the Geological Survey, "Report of the Work Group on OCS Safety and Pollution Control," May 1973, the Geological Survey hereby gives notice that the following procedures have been established for the development of specific safety and pollu¬ tion-prevention standards for equipment and pro¬ cedures used during drilling and producing oper¬ ations on oil and gas leases issued on the Outer Continental Shelf: 1. Identify needs for new or modified standards and establish priorities. 2. Publish a notice in the Federal Register of intent to prepare specific standards request¬ ing input and assistance. IV-64 3 . Prepare drafts of new, updated, and revised standards by one or a combination of the following methods: A. By use of input derived from step 2. above. B. By use of available in-house expertise. C. By arrangement with ANSI, ASME, ASTM, API, or other organizations who prepare stand¬ ards o 4° Polish draft standards in the Federal Register for comments. 5 0 Consider the comments received, publish the final standards in the Federal Register, and incorporate them in an appropriate OCS Order by reference. Specific environmental hazards and problems that are characteristic of different areas of the OCS shall be taken into account when incorporating standards into OCS Orders. Recommendation No, 6 . System Analysis Action Taken: System analyses were performed on 13 installa¬ tions in the Gulf of Mexico under two Geological Survey contracts. These studies are currently being evaluated with the objective of possible adoption into the lease management program in connection with the work being done in this area by the committee on standards and specifications. A grant has been given to Rice University whereby they will draft a standard on systems design analysis. This grant has a completion date of December 31, 1975. Forthcoming from this draft standard will be a draft of a proposed OCS Order on Systems Design Analysis. IV-65 Exxon, in its effort to provide an environmentally and functionally safe system for the Pacific Area, Santa Barbara Channel, Santa Ynez Unit, contracted with General Electric to make a Functional Systems Analysis (Hazard Analysis) of the initial Hondo Field development. The study looked in detail at the offshore production facilities, the pipelines to shore, and the alternate offshore storage and terminal system from the viewpoint of safety to personnel and oil in water pollution. The study concludes that of 2,400 functional components studied, only 28 were in need of addi¬ tional analysis and with suggested design improve¬ ments would render the systems very safe. It was also concluded that for a facility of its size and complexity, the proposed Santa Ynez Unit facilities had minimal problems when compared to similar facilities studied by General Electric in the Gulf of Mexico. Volume 1 of The Functional Systems Analysis for the initial Santa Ynez Unit, Hondo Field develop¬ ment was submitted to the U 0 So Geological Survey. Recommendation No. 7 . Engineering Documentation Action Taken: This recommendation has been fully implemented in the Pacific Area to the extent that all of the recommended documentation is in each operator s IV-66 -V *X field office. Similar documentation is in the U. S. Geological Survey Area and District offices except for parts lists and specifications for all functioning components. The current Pacific Area OCS Order No. 8 requires this information to a large degree although, in some cases, the partic¬ ular items recommended for documentation are not specifically addressed. Thorough inspection practices have assisted in accomplishing this implementation. However, the Pacific Area will review the Gulf of Mexico revised OCS Order No. 8, when completed, for consideration and possible adaptation to the Pacific Area. Recommendation No, 8. Wearout Prevention Action Taken : The proposed revision of Gulf of Mexico Area OCS Order No. 8 includes an erosion control program. This is also the subject of one of the research and development committee's projects. The Pacific Area will review the Gulf of Mexico Area OCS Order No. 8, when completed, for adaptation of the erosion control section to the Pacific Area. Recommendation No, 9. Training Action Taken : The committee formed in conjunction with the API on offshore safety and anti-pollution training and motivation outlined the training needed for personnel working offshore, setting up training programs, and establishing a time framework for IV-67 > a a ml J OF *- VKBA/MA-CHAMFM&H. accomplishing this. Documents API RPT-1 and RPT-2 for training and certification of operator personnel were established by the committee. The Geological Survey is establishing a more formalized training program for their own person¬ nel and have plans for developing a training course in OCS Orders and regulations for presen¬ tation to the industry. The Pacific Area has made a study for formal training available on the Pacific Coast. Training programs will be coordi¬ nated with the Gulf of Mexico Area. paring April 1974, Geological Survey technicians from the Gulf Coast and Santa Barbara Channel attended training courses consisting of ten sessions. Each session covered a different sub¬ ject and was conducted by a different instructor with appropriate expertise. The basic course objective was to improve pollution prevention and control. During 1975 the Geological Survey OCS personnel attended numerous technical courses of various types. Recommendation No. 10 . Motivation Program Action Taken : The API and oil industry are taking the lead in developing a motivation program. The joint committee with API published API Bulletin T-5 Employee Programs for Safety and Prevention of Pollution in Offshore Operations. IV-68 Recomme ndation No. 11 . Lease Management Program Ac tion Ta ken: Additional personnel have been hired for the Pacific Area and Gulf of Mexico Area OCS offices. The areas of responsibilities and goals of the individual organizational units are being devel¬ oped. Also under development, is a system for incorporating reports from other program areas into an annual review. The pollution report form has been revised and is required for use by the operators in the proposed revision of OCS Order No. 7. Recommen dation No. 12 . Inspection Procedures A ction Taken : Data processing equipment has been installed in the Gulf of Mexico Area office. Inspection check¬ lists are being updated to keep current with OCS Orders. Special inspections are conducted bi¬ monthly as data gathering exercises. Consistent enforcement policy is being applied in each OCS area. Computerized data files regarding inspec¬ tions, platforms, and accidents have been estab¬ lished and are used as input for the safety review committee. The Pacific Area has reviewed formalized inspection procedures for the Gulf of Mexico Area and fully IV-69 LIBRARY U. OF /. OOOAAM-CHAAJPAIBM Recommendation No. 13 . Action Taken: Recommendation No. 14 . Action Taken: Recommendation No. 15 . Action Taken: implemented similar enforcement inspection pro- cedures. OCS Order Development Procedures The Geological Survey has developed formalized procedures for the evaluation and revision of existing OCS Orders and the develop¬ ment of new OCS Orders. Proposed new and revised Orders are to be published in the Federal Register for public comment prior to their adoption. Standardization of Pollution Report Form The Pacific Area has reviewed the Gulf of Mexico Area proposed form and has submitted suggestions and comments. Safety and Advisory Committees The industry has established a committee on OCS Safety in both the Pacific and Gulf of Mexico Areas. The Area offices have designated person¬ nel to form systems analysis review committees tc meet on a regular basis. These committees have had their initial meetings and will continue meeting monthly to review prior accidents and accident reports and discuss implementation of safety programs. IV-70 The Review Committee on Safety of Outer Continen¬ tal Shelf Petroleum Operations, under the auspices of the Marine Board, National Academy of Engineers, was established in July 1973 to serve as a third- party audit of the OCS procedures and operations and to review state-of-the-art technologies. This committee established at the request of the Geological Survey, composed of experts not regularly employed by industry or the Government, has issued four reports to the Geological Survey. In its First Report to the United States Geological Survey (USGS), issued in March 1974, the Review Committee addressed five areas: (1) standards and specifications; (2) applicability of systems anal¬ yses techniques to offshore gas and oil operations; (3) the safety alert system of the USGS; (4) a proposed revision to OCS Order No. 8 (Approval Procedure for Installation and Operation of Plat¬ forms, Fixed and Mobile Structures, and Artificial Islands) to include caisson-like structures; and (5) a preliminary look at environmental baselines in support of offshore oil and gas operations. The Second Report, issued in June, 1974), focused on three issues: (1) policy and program planning by the USGS for the assurance of safety and pollu¬ tion control in OCS petroleum operations; (2) implementation actions and priorities established IV-71 UBRARV U- OF /_ URBAA£A CiiAMPA!GH by the USGS on the basis of safety study recommendations; and (3) application of systems analysis techniques to offshore oil and gas oper¬ ations . The Third Report, issued in March 1975, addressed three topics: (1) standards developed for OCS operations; (2) inspection strategies for use in the OCS; and (3) methods for determining the condition of existing pipelines. The Fourth Report, issued in August 1975, concerns three areas: (1) industry influence in the pro¬ cess by which the USGS establishes new and revised regulations; (2) expansion of USGS procedures for the development of new and revised standards for OCS operations; and, (3) a problem oriented method of conducting impact studies to ensure the pro¬ tection of the environment in areas of offshore petroleum operations. Members of the Review Committee have been selected on the basis of their experience and expertise in technologies important to the study of safe OCS petroleum operations. Review Committee members are listed below. MEMBERSHIP George F. Mechlin, Chairman Vice-President, Research § Development Westinghouse Electric Corporation IV-72 Kermit E. Brown Head § Halliburton Professor Petroleum Engineering Department The University of Tulsa Kenneth 0. Emery Marine Geologist and Senior Scientist Woods Hole Oceanographic Institution Ben Cliffod Gerwick, Jr. Professor of Civil Engineering University of California Murray F. Hawkins, Jr. Head, Petroleum Engineering Department Louisiana State University B. J. Livesay Director, Ocean Mining Laboratory Kennecott Exploration, Inc. Robert J. Menzies Professor of Oceanography Florida State University W. F. Searle, Jr. President Searle Consultants Dale M. Straughan Assistant Professor of Biology University of Southern California Elmer P. Wheaton Vice-President § General Manager, ret. Lockheed Missiles § Space Company See Appendices IV-2 and IV-3 for a discussion of additional recommendations adopted from the various recent studies (recommendations 16, 17, 18, and 19). h. PCS Technology Assessment Group Stud y - University of Oklahoma A comprehensive report on a technology assessment of oil and gas operations on the U. S. Outer Continental Shelf was published by an inter-disciplinary research team from the Science and Public Policy IV-73 Program at the University of Oklahoma. 1 The independent analysis, funded by the National Science Foundation, was conducted over a 20-month period beginning in September 1971. The principal conclusions of the study are: (1) that existing OCS technolo¬ gies are adequate for continued oil and gas operations; (2) that more sharply defined concerns for safety and environmental protection continue to pose a challenge to OCS management even though technologies responsive to these new concerns are gradually evolving; (3) that in the past, participation in the management of OCS oil and gas operations was limited to the Department of the Interior and the petroleum industry and that this relatively closed manage¬ ment system was initially unable to sense and respond quickly to a changing social climate. Interested groups and Federal agencies representing con¬ cerns such as environmental conservation are now participating in the manage¬ ment system primarily through the impact statement process required by NEPA. These new participants are demanding changes from past patterns of operations and (4) most of the new demands being made on OCS technologies are well within state-of-the-art. The necessary information modifications in the physical technologies required by a changing social climate can be met. Although the application of stringent environmental and safety criteria pose problems, the industry has or can develop the required physical technologies and procedures. "Supplement No. 1, dated May 1974, to the Report of the Work Group on OCS Safety and Pollution Control, May 1973, U. S. Geological Survey", was Iphe Technology Assessment Group, Science and Public Policy Program, University of Oklahoma, Energy Under the Oceans: A Technology Assessment of Outer Continental Shelf Oil and Gas Operations, University of Oklahoma Press, September 1973. IV-74 prepared in order to consider and discuss the recommendations in this new Oklahoma study. The Oklahoma report is compatible with the three previous reports and many of the respective recommendations are the same or similar, but the Oklahoma report goes much further than any of the other three. In- depth considerations of Government management and jurisdiction are unique to the Oklahoma study as is its plan for OCS development. Supplement No. 1, including an appendix to the Geological Survey Work Group report, responds to the recommendations of this Oklahoma report. c • Supplement No, 1 to the Geological Survey Work Group Report The entire Supplemental No. 1 Report is reproduced and presented in appendix IV-2 at the end of this section. d - Council on Environmental Quality OCS Oil and Gas Operations Environmental Report for the Atlantic OCS and the Gulf of Alaska - April 197 T --- The Council on Environmental Quality (CEQ) performed a study and prepared a report for the President of the United States on the environmental impacts of oil and gas operations on the Atlantic OCS and the Gulf of Alaska. Numerous agencies contributed to this report, including the Environmental Protection Agency and Geological Survey. The Department of the Interior is presently considering the CEQ recommenda¬ tions in this report. Many of the recommendations are identical or similar to those that resulted from the previously discussed studies and reports. Therefore, certain CEQ recommendations are already at various stages of implementation. The Geological Survey has prepared a work group report dated November 4, 1974, titled Supplement No. 2 to the Work Group on OCS Safety and Pollution Control. This report is a response to the pertinent recommendations of the report to the President by CEQ. IV-75 e. Supplement No. 2 to the Report of the Work Group on PCS Safety and Pollution Control The entire Supplement No. 2 Report is reproduced and presented in appendix IV-3 at the end of this section. IV-76 f ‘ General Accounting Office (GAO) Study and Report In addition to the above studies and reports, the General Accounting Office issued a report at the request of the Conservation and Natural Resources Subcommittee of the Committee on Government Operations, House of Representatives.* This study, like those mentioned above, presents a critical review of OCS regulatory and inspection procedures and includes recommendations designed to achieve more effective capability and procedures. In a letter dated August 3, 1973, from Secretary Morton to Mr. Henry S. Reuss, Chairman of the Conservation and Natural Resources Subcommittee, it is pointed out that the recommendations contained in the GAO report which have not already been implemented are being implemented as part of the Work Group's recommendations as a result of the NASA, Marine Board, National Academy of Engineers, and other studies. As noted in the GAO report itself, most of the deficiencies identified by GAO have already been recognized by the Geological Survey through its own studies and studies undertaken on its behalf by NASA and others, and steps have already been taken or are underway to remedy them. Many of the recommendations contained in the GAO report were also made in the studies discussed above. Nevertheless, the following actions specifically respond to the GAO report: • Inspectors are instructed to apply prescribed enforcement actions for violations of OCS Orders unless deviations have been authorized and properly documented for each case by the Chief, Conservation Division, Geological Survey. • The inspection staff is to be increased and the number of inspections, both scheduled and unannounced, have been increased. This applies mostly to the Gulf of Mexico Area for GAO reported that it was the Gulf of Mexico Area that needed to increase inspection frequency. General Accounting Office, "Improved Inspection and Regulation Could Reduce the Possibility of Oil Spills on the Outer Continental Shelf", Report No. B-146333, June 29, 1973. IV-77 UBRARlf IS. OF i. UflElAHA -CHAMFAi BM. • Inspections include workover and remedial operations as well as drilling, producing, and abandonment operations. • Work groups have been formed to study the feasibility of requiring operators to submit a preventive maintenance schedule and to perform scheduled inspections and report results in a specified format. • Geological Survey is working with industry and with the API in an attempt to set standards and requirements for training personnel. Geological Survey personnel would participate in this training. n the meantime, Conservation Managers have been instructed to initiate formalized training in inspection procedures. • Plans are being adopted to limit the conditions under which multiple operations may be conducted for a single platform. Several speakers at the Public Hearing on the Santa Ynez Unit Plan of Operations Draft Environmental Statement, made reference to the portion of this GAO report, that indicated the U. S. Geological Survey had discovered 76 violations in connection with Santa Barbara Channel operations in fiscal year 1972. These were violations listed in the two U. S. Geological Survey semi-annual inspec¬ tion reports for the five OCS Santa Barbara Channel platforms. The GAO analysis of U. S. Geological Survey records showed that the lessees took more than seven days to correct 19 of these violations and that the remaining 57 violations were corrected in less than seven days. As a result of the GAO recommendations, renewed emphasis has been put on requiring that violations be corrected within seven days. The Geological Survey has stated that if a violation is of the type which creates an imme¬ diate threat to the environment, the involved well or wells will be shut-in. In order to keep the 76 violations in proper perspective, one must consider two things: (1) the majority of these violations involved minor technical matters which would have no bearing on the safety of operations in relation to potential immediate harm to the environment, and (2) the U. S. Geological Survey Santa Barbara District conducted rigorous inspection programs which involved checking and testing literally thousands of items. IV-78 GAO pointed out that the 76 violations included 12 instances in which sub¬ surface safety devices leaked during tests and that subsurface safety devices play an important role in environmental protection. However, the GAO report did not explain a very important aspect of U. S. Geological Survey subsurface device test procedure policy. The Geological Survey issued the operators written warnings if a subsurface device was not bubble tight during testing. Therefore, the 12 subsurface device violations listed in the inspec¬ tion reports does not indicate that the tests detected serious leaks. A sub¬ surface device that does not prove to be bubble tight is not considered a serious condition and does not represent an immediate hazard to the environ¬ ment. The 76 violations are remarkably few, considering their nature and that thousands of items were checked and tested under the U. S. Geological Survey inspection program. g. Bureau of Land Management Study Groups Because of the wide variation in scientific opinions on the effects of oil spills and because of a general lack of concrete evidence for either damage or lack of damage, the Department of Interior has author¬ ized the Bureau of Land Management to evaluate, on a continuing basis, the effects of oil spills from offshore oil and gas exploration and production in OCS waters. These studies will be conducted by teams of about 20 people including marine biologists, oceanographers, pipeline engineers and other personnel with specialized expertise. They will initiate studies and com¬ pile data concerning the short and long term impact of oil spills on marine biota, as well as the environmental effects of produced waste water dis¬ charge, drill cuttings, drilling mud and pipeline construction. These IV-79 U1BRJVRV U. OF /. UfiESSi yyyj CHAMPA1 CM study groups are assembled in the Gulf Coast, East and West Coast, and the Gulf of Alaska areas. 9. Memoranda of Understanding Several of the recent OCS management reports, including the CEQ Report, have made recommendations that call for the Geological Survey to develop memoranda of understanding on OCS safety and pollution control with the Department of Labor (in accordance with the Occupational Safety and Health Act--OSHA) on inspection and enforcement; with the Bureau of Land Management and the Office of Pipeline Safety on pipelines; and with the Environmental Protection Agency on discharge standards. IV-80 Steps have been taken by the Geological Survey toward the development of the above-mentioned memoranda of understanding. ig a t _ing Factors Related to the Detrime ntal Effects of Oil Spills in the Santa Barbara Channel ~ ~ The possibility of a major oil spill resulting from further development of the Santa Barbara Channel certainly cannot be categorically ruled out. It should be noted that oil and gas operations had been conducted in the Santa Barbara Channel for 77 years before the first major oil pollution incident (the Platform A spill). a. Long-Term Impact Certain recent studies suggest the long-term impact may be minor in many cases. Published conclusions of investigations express varying opinions; however, all are in agreement that the extent of impacts, both short-term and long-term, depends upon the circumstances of the spill. Certain studies made after the Santa Barbara oil spill concluded that damage to the biota was not widespread, that the number of species affected was limited and that the area was recovering. b - Effect of Different Types of Oil Most of the crude oil that would be produced would probably be a low- gravity viscous type and certain studies suggest that this type crude oil would be less damaging to the environment than, for example. No. 6 fuel oils and middle distillates (No. 2 oils and diesel fuel oil). Although there are conflicting opinions, many authorities believe crude oil from the Santa Barbara Channel in general, would be easier to contain and recover than higher gravity crude oils, and therefore, in the event of a spill, less detrimental to the environment. IV-81 c. Animals with Tolerance to Oil Studies have suggested that the animals that are native to the Santa Barbara Channel region, because of their exposure to natural oil seepage over hundreds of years,have developed a greater tolerance than similar species in other areas. (See Straughan,1970, p. 411 for one pre¬ sentation of this hypothesis). d. Natural Assimilation of Crude Oil Studies have indicated that oil-oxidizing bacteria are most abundant where seep oil is present. Because of natural oil seeps in the Santa Barbara Channel, natural assimilation of crude oil may take place more rapidly than in areas where natural oil seeps do not occur. B. Mitigations Related to the Specific Phases and Components of Potential Activities Many of the mitigating factors related to specific components and phases associated with potential activities are covered in section I, and the regulations, inspection, and enforcement procedures have been discussed in the general mitigation portion of this section. 1. Specific Proposals Require Geological Survey Approval Geological Survey approval would be required prior to the installation and operation of all individual facilities. Prior to acting on such applications, each proposal would be carefully reviewed in light of this channel-wide statement supplemented by site specific information and any subsequent technological advances, experience from current operations, and additional data collection. If deemed necessary the Geological Survey would under its existing regulations proceed with a full environmental analysis of the specific proposal and thereon base a determination as to the need for an additional environmental impact statement. IV-82 Secretarial Order No. 2974 dated April 30, 1975, concerning inter-bureau coordination in the OCS minerals program, enables the Geological Survey to obtain expert advice from Fish and Wildlife Service and the Bureau of Land Management relating to OCS oil and gas operations with respect to environ¬ mental protection. This order requires the Geological Survey to consult with and receive recommendations from these agencies prior toi • issuance of draft OCS Order, approval of exploratory drilling plans, and plans of development, • granting the right to use or easements to lessees to construct and maintain platforms, fixed structures, artificial islands and pipelines on areas of the OCS, and • approval of installation of platforms, fixed structures, artificial islands and pipelines. The Geological Survey's Area Oil and Gas Supervisor, Los Angeles, plans to issue Notices to Lessees and Operators spelling out the minimum require¬ ments for protecting archeological and biological resources, relating to OCS oil and gas operations. The Supervisor has sent letters to various Federal and State agencies (October 1975) requesting recommendations and suggestions as to minimum requirements for conducting archeological and biological sur¬ veys. A draft of these Notices to Lessees and Operators should be in the Federal Register by June 1976 for public comment. IV-83 LIBRARY If- OF /_ URBA, A.VJ CHAMPAl B 2. Well-Control Training Programs for Operating Personnel^ Uncontrolled well flow would be further mitigated by personnel training and operating practices. Daily functional tests would be conducted on the blowout preventers and weekly pressure tests would be made. Blowout preventer drills, which familiarize crews with proper procedures and make sure they respond properly, would be conducted daily until the crews are proficient. After that, weekly drills would be conducted. If a slow response were found, more frequent drills would be conducted until the response was satisfactory. In addition, key supervisory personnel of both operator and the drilling contractor would receive extensive well-control training at special facili¬ ties such as the Saticoy Well Control Training Facility located in the Saticoy Field near Ventura, California. This mile-deep practice well is equipped with storage tanks, a pump, control manifold, and a full array of pressure gages and controls, modeling the diverse equipment that is used on actual wells to prevent a blowout. These training facilities would be utilized to provide actual practice in controlling a simulated "well kick". Training sessions would also include classroom instruction in the detection and handling of abnormal well conditions. Through August of 1973, approxi¬ mately 250 men from eight different oil companies and drilling firms active in the Santa Barbara Channel area had used the Saticoy facility. 3. Platform Beautification Studies Studies have been conducted to develop platform beautification techniques. These range from camouflage of the structure to techniques that accentuate the platform but in a modified form which may be more pleasing to the viewer. Screening may be accomplished by the use of panels and configurations to change the shape or clarity of the structure's IV-84 silhouette. Another method uses sea water sprayed from the upper levels of the structure. Natural light from behind the platform causes the spray to appear as a white screen on bright days and to reflect the natural sky color in more typical hazy weather. Under certain light conditions the screened platform becomes less visible and tends to disappear from view. Work is continuing on the development of practical and effective platform beautification techniques. However, the U. S. Coast Guard has expressed concern that camouflaging techniques could increase the hazard to navigation and this would have to be a prime consideration in platform beautification studies. 4. Platform Removal Platforms are designed for removal after their operational life. Following the depletion of all producing zones developed from a platform, wells would be plugged and abandoned. Well conductors would be cut below the mudline and removed; drilling and production equipment would be dis¬ mantled and removed; and the deck units would be removed. All piling would be cut below the mudline, and the jacket legs and buoyancy tanks would be deballasted until the jacket floated. The jacket would then be removed and the site restored in accordance with permit requirements. 5 - Non-Use of Polychlorinated Biphenyl (PCB) Liquids Review of Gulf Coast OCS lease sale environmental impact state¬ ments expressed a great deal of concern about polychlorinated biphenyl liquids inasmuch as any PCB's escaping into the environment would constitute a serious hazard. PCB’s are not used on any of the existing Santa Barbara Channel OCS platforms nor would any future platforms use them. IV-85 UBRARV U- OF I. VflBAMJi-CHAMPAl&H. 6. Sub surface Safety Valves All Santa Barbara Channel subsurface safety valves would be the surface-controlled type as required by the Pacific Area OCS Orders of 1, 1971. Excessive sand production, detrimental to these valves, is not expected to be a serious problem in Santa Barbara Channel potential field areas. For these reasons the Geological Survey places increased reliance on the performance of Santa Barbara Channel subsurface safety valves. It is recognized that certain Gulf Coast incidents reflect a poor subsurface valve performance record. However, these were the old-type velocity actuated valves and were in an area known for excessive sand production problems. A few velocity actuated subsurface valves that were in the Santa Barbara Channel were replaced with the surface controlled valves several years ago. (See sections I.D.6.d. and IV.B.6. for further discussion on subsurface safety valves.) 7. Subsidence a. Subsidence Potential Subsidence of the ground surface can occur when oil and gas are withdrawn from their reservoirs. (See section II.B.7.h.) Subsidence has been recognized over a number of producing oil and gas fields through¬ out the country, and although the conditions in each are different, the greatest amounts of subsidence seem to be associated with fields where pro¬ duction is from stratigraphic zones containing compactable strata -- strata susceptible to compaction when pore fluid pressures are reduced. The conse¬ quences of this compaction include: 1) lowering of surface elevations, 2) centripetally directed horizontal displacement of surface points, and 3) faulting (Yerkes and Castle, 1969). The faulting may break the ground IV-86 surface or be entirely subsurface, and at least two unequivocal examples of seismicity associated with faulting of this origin have been documented (Yerkes and Castle, 1975). The best known example of subsidence in California occurs over the Wilming¬ ton oil field, where the chief hazard from subsidence was the threat to onshore areas, including commercial and military installations, from inunda¬ tion by the sea. By 1958, the situation was no longer amenable to control by the expensive remedial works of the sort undertaken since 1941, and the California Legislature passed the Subsidence Control Act for the purpose of arresting land subsidence through repressuring by water injection (Huey, 1964). The subsequent water injection program was successful in reducing the rates of subsidence, and by 1974 the State Oil and Gas Supervisor could report that: "...from August 1973 to August 1974 general rebound conditions (were indicated), although slight subsidence occurred over the central har¬ bor area in Long Beach." (State Oil and Gas Supervisor, 1975). This sug¬ gests that maintainence of reservoir pressures through fluid injection can provide an effective countermeasure to the surface displacements. Fluid injection, however, has a potential for triggering seismic events (Raleigh, Healy, and Bredehoeft, 1972) under some conditions, and should be under¬ taken only with great care and forethought (McCulloh, 1969, p. 45, 46; see also section II.B.7.h. of this report). General lowering of surface elevation, such as would be noticed by a rise in water level on platform legs, would probably not pose a significant hazard to a platform unless the amount of subsidence were so large as to threaten inundation. The seismic events so far recorded in association with both fluid withdrawal IV-87 and injection in oil-field areas have been relatively small (generally less than magnitude 4), and the associated seismic shaking probably poses little hazard to well-designed and well-built structures. In general, subsidence and its associated effects probably present little direct environmental hazard to OCS production that cannot be readily de¬ tected at an early stage and countered by prompt remedial action. b. Subsidence Detection Program Some of the Pliocene reservoir strata of the Dos Cuadras and Carpinteria fields probably include compactable beds. As the degree to which these beds may compact is not now established, three present OCS platforms (A, B, and Hillhouse) are instrumented and monitored to measure any subsidence that might occur. Although the instruments have been in operation since 1971, no change in relative elevations has been recorded. In other parts of the Channel, the greatest production potential now known is in the Santa Ynez Unit, where the reservoir rocks consist of older (Miocene), better compacted strata, and the porosity from which hydrocarbon production is expected to be greatest consists largely of fractures in silicious shale, chert, and dolomite. The potential for subsidence over such a field appears relatively slight, however, as there has been little direct measurement over fields having this type of dominant porosity, it seems only prudent to recommend that a systematic subsidence-detection program should accompany production. The present detection program in the Dos Cuadras OCS field reflects Geologi¬ cal Survey policy that it is best to anticipate possible subsidence so that, if it does occur, early detection will permit a remedial course of action to stop or minimize any potential for hazard. To measure differential IV-88 subsidence at any one platform, benchmarks were established on each corner of the three platforms in the Dos Cuadras field. Any tilting of the plat¬ form would be measured by periodic resurvey of the benchmarks. To determine changes in elevation of an entire platform, recording tide gages were installed at each. (According to Lewis and Lewis Offshore, Inc., offshore surveyors of Ventura, a 60-day study can provide an accuracy of ±0.1 foot and a one-year study could provide an accuracy of ±0.05 foot, when compared with a suitable standard station.) Although the U. S. Coast and Geodetic Survey tide station on Rincon Island may be of questionable value as an absolute standard, because it lies atop another producing oil field and may be subject to subsidence from those operations, any relative change of elevation among the instrumented platforms would be readily recognized and measured to within small tolerances. As a check on computed results, several tidal datum planes can be computed from the data recorded by the tide gages: 1) daily highs and lows, 2) mean high water, 3) mean low water, 4) mean higher high water, 5) mean lower low water, 6) mean tide level, 7) diurnal high water inequality, and 8) diurnal low water inequality. The tide gages have been in operation since October 1, 1971, during which time there has been no measurable change in relative elevation of the three platforms. If deemed necessary, the Geological Survey could require this same type of subsidence detection program for any future platforms. 8• Dos Cuadras Field Seismometer Array The Geological Survey installed an array of seven seismographs on the sea floor in the vicinity of the Dos Cuadras field. The spacing and location of the instruments is designed to locate and identify the foci of small, shallow earthquakes in the vicinity of the producing reservoir, that might occur in association with fluid injection operations, and IV-89 distinguish those from the regional tectonic seismic activity. The instal¬ lation of this small seismometer array over the Dos Cuadras field was com¬ pleted in December 1975 and, therefore, has been in operation only a brief time. This may be the first and only sea floor array now operating in the world. 9. Archeological and Historic The identification and evaluation of potential cultural re¬ sources and artifacts will be by qualified professionals. The opinion of the State Historic Preservation Officer and the Secretary of the Interior will be sought in determination of eligibility for inclusion in the National Register of Historic Places. All resources determined to be eligible for inclusion in the National Register of Historic Places are protected by the Historic Preservation Act of 1966 (Public Law 89-665, 80 Stat. 915) and are subject to Section 106 of this act. The procedures set forth in Title 36 CFR 800 should be followed and documented in these cases. OCS operations must be conducted so as to protect archeological resources in accordance with the Historical Preservation Act and Executive Order 11593 (Protection and Enhancement of the Cultural Environment). The Geological Survey Office in Los Angeles is presently preparing a Notice to Lessees and Operators that will specify certain requirements for the conducting of archeological surveys. The Geological Survey, Los Angeles Office, requested comments and recommendations as to reasonable and practi¬ cal requirements for the conducting of such archeological surveys, by letter dated October 29, 1975, sent to: The Bureau of Land Management, U. S. Fish and Wildlife Service, the Office of Archeology and Historic Preservation, National Park Service, Interagency Archeological Services, IV-90 and to the Directors of the State Parks of California, Washington and Oregon. As of January 1976, the Geological Survey has not received all responses. A draft Notice to Lessees should be in the Federal Register by June 1976 for public comment. 10. Platform Seismic Design Criteria Existing and presently proposed platforms on Federal leases in the Santa Barbara Channel have all been designed in accordance with the best technology for seismic design and structural analysis available, at the time of their initiation. In view of the continuing developments in the fields of earthquake seismology and seismic design, and the need to establish platform criteria in other areas and concern, the USGS has recon¬ sidered its earlier intent to establish a multi-disciplinary panel of experts to review the seismic design of platforms. The needs as presently seen go far beyond seismic design. As a result the Geological Survey is in an advanced stage of negotiations and arrangements for the first steps in establishing a system of third-party certification of platform design and for the development of various design criteria for OCS platforms and other facilities. In essence, the system is expected to be somewhat similar to the present British system now employed for the North Sea development. A con¬ sulting firm will develop an overall plan for the certification of platform design, and will, among other requirements, identify design criteria and practices for OCS developments, related to differing regional conditions. IV-91 11. Programs of Research Aimed at Reducing the Potential for Adverse Impact from Certain Geologic Events Section II.B.7 of this report summarizes the geologic conditions and events that have a potential for hazard to oilfield development and production facilities, and a consequent potential for hazard to the environment of the channel region. Programs of research aimed at reducing the potential for adverse impact from particular geologic events could accompany development and production of petroleum resources, and should have the same general objectives as those enumerated by Alfors and others (1973) in their recommendations for reducing geologic hazards losses in California: 1. Avoid or prevent damage (adverse impact) from future events by assessing the nature and location of probable events, taking steps to control those events, and guiding human activities away from hazardous areas in which it is not feasible to correct the hazards. 2. Minimize unavoidable or unpreventable losses (adverse impact) by requiring thorough analysis of the geologic environment prior to design, then provide safe design, construction, and maintenance practices by adequate codes and ordinances. 3. Take emergency action to save lives and property (and prevent adverse impact) during or immediately following any particular disastrous event. 4. Take longer-range recovery action following a particular event to study its lessons, reestablish normal life, and rebuild. To meet these objectives in the Santa Barbara Channel region, ongoing research programs should continue; some need to be expanded or accelerated, and others should be initiated. For the purpose of reducing earthquake hazards and concomittant adverse environmental impact, a continuing, coordinated research program should accompany petroleum exploration, development, and production. As an example, a comprehensive program to delineate the active faults in the Santa Barbara Channel could provide a more detailed seismic risk zoning IV-92 and, perhaps, a capability to predict the location and timing of specific large earthquakes. Such a program would require augmentation of the present seismograph network, onshore and offshore geological and geo¬ physical investigations, and geodetic measurements, much like the following 1) Installation and operation of a denser seismograph network 100 stations spaced about 5 miles -8 km- apart). 2) Controlled seismic explosions to investigate the crustal structure. 3) Detailed acoustic profiles (tracks spaced 0.2 miles -0.3 km- apart), and field geologic mapping on land. 4) Geodetic strain measurements. 5) In-situ stress measurements. Because detailed geologic and seismologic data can only be accumulated over many years, and for maximum benefit, such a program should take advantage of the considerable "lead time" following any decision to pro¬ ceed with development plans, and should be implemented no later than the time of that decision. Detailed seismic monitoring of oilfield produc¬ tion, as initiated for the Dos Cuadras field, is also necessary to avoid triggering small earthquakes which may cause oil spills (as dis¬ cussed in section II.B.6.h.). The cost of such programs would be a very small percentage of the potential value of the petroleum reserves, and could be largely or completely amortized if it prevented only one major oil spill. 12. Other Environmental Research # Ecological Baseline and Monitoring Studies In October 1972 NOAA sponsored a workshop at the Santa Catalina Marine Biological Laboratory of the University of Southern Cali¬ fornia to develop strategies for a national program in marine pollution mon¬ itoring. In May 1974 the National Bureau of Standards held a second work¬ shop in marine pollution monitoring in Gaithersburg, Maryland. This second workshop developed the monitoring program as a pilot project of the Inte¬ grated Global Oceanic Station System (IGOSS) under the United Nations. This program proposes a global network of marine pollution measurements from ships, coastal stations, and various other platforms by scientists of many nations. The objective of the program would be long term, large scale monitoring of various forms, primarily hydrocarbons, of marine pollution. In 1974, in response to Senate National Ocean Policy Study hearings, a committee was formed to coordinate baseline studies which pertain to oil and gas development on the Outer Continental Shelves. Participants were the Bureau of Land Management, the National Oceanic and Atmospheric Administration, the Environmental Protection Agency, the U. S. Geological Survey, the Fish and Wildlife Service, and the National Ocean Policy Study. Department of the Interior baseline studies involve three sequential levels of effort: (1) an inventory and analysis of existing environmental and socioeconomic data; (2) special field studies to fill short-term non-recurring data gaps pointed out in the first phase; and (3) continuing ecological baseline and monitoring studies in existing fields and pipeline corridors. Studies of southern California have been described by the Department of the Interior OCS Lease Sale 35, FES, Vol. I, p. 21-24. IV-94 Also in 1974, the Assembly Select Committee on Coastal Zone Resources of the California Legislature held hearings regarding offshore drilling, includ¬ ing environmental baseline data required to permit an accurate assessment and measurement of any changes which may occur in the environment as a result of OCS oil and gas development activities. One committee recommendation was: "State and Federal governments should cooperate in the conduct of environmental baseline studies in any offshore area for which de¬ velopment leases are being sought before such leases are issued. The studies should be conducted by a governmental agency with expertise in marine sciences, such as the National Oceanic and Atmospheric Administration, and should be subjected to independent review. Such studies should be carried out on a continuing basis after oil and gas development proceeds in order to enhance the ac¬ curacy and usefulness of the information for application in future offshore oil and gas management decision." (California Legislature, 1974, Report on Hearings) Environmental studies relating to offshore petroleum operations were reviewed by the National Research Council, assembly of Engineering, Marine Board.^ "The review Committee concludes that regulatory agencies can more efficiently apply their resources in a combined effort of monitor¬ ing? field assessment, and research and development so that the most pertinent data can be collected and evaluated and can be used in a predictive capacity for determining the potential effect of future petroleum development on the environment. "The Review Committee examined the responsibility of regulatory agencies for controlling offshore industrial development and estab¬ lishing the necessary restraints to protect the environment from significant adverse effects or permanent damage resulting from petroleum operations in offshore and related areas. The Review Committee also examined the application of resources by regulatory agencies in conducting environmental impact studies. ...A problem-oriented approach to the collection and assessment of the environmental data by regulatory agencies... challenges the current practice by regulatory agencies of conducting widespread, lengthy, and sometimes duplicative studies prior to offshore oil operations, for the purpose of gaining a dynamic understanding of August 1975, in fourth report of the review committee on safety of Outer Continental Shelf petroleum operations to the United States Geological Survey: work supported by Contract N00014-67-A0244-002 between the Office of Naval Research and the National Academy of Sciences. IV-95 the entire marine ecosystem. Unless such far-reaching studies are indicated by a singular type of facility or by special environ¬ mental problems at a particular location where petroleum will be extracted, they fall more appropriately within the responsibility of other government agencies assigned to the function of basic research or directly involved with the study of the marine environ ment." Baseline studies and monitoring programs have been suggested by several agencies. The Sale 35 FES, and a variety of recent documents, presentations, and testimony of various Bureau of Land Management and Department of Interior officials before Congressional Committees demonstrates clearly a commitment to follow baseline data collection programs and studies m new frontier OCS areas with monitoring programs continuing through exploration and develop¬ ment activities. • Bureau of Sport Fisheries and Wildlife Research is being conducted on the status (populations, immediate problems) of the California condor, light-footed clapper rail, California least tern, the black rail, and (in cooperation with the California Department of Fish and Game) the California brown pelican. All species are either endangered or thought to be threatened. Goleta Slough, Carpinteria Marsh and Mugu Lagoon are among the mainland study locations for water-associated birds. • National Marine Fisheries Service The agency is cooperating in the California Cooperative Oceanic Fisheries Investigation in 1) performing bioassays of anchovy food supply, and 2) performing studies of anchovy larvae stock and recruitment. Independ¬ ent work is conducted at San Miguel Island on marine mammals, primarily population and breeding studies on fur seals and sea lions. IV-96 • California Department of Fish and Game The Department, in addition to specific studies, participates in the California Cooperative Oceanographic Fisheries Investigations (CalCOFI). Other participants in the CalCOFI program include Scripps Institution of Oceanography (SIO), which performs oceanographic data collection and analysis, and National Marine Fisheries Service, listed separately. The primary CalCOFI role of the Department is in assessing fish populations and distri¬ butions. The Department also participates or is delegated responsibility in a variety of governmental studies, programs, and regulatory functions. • Southe rn California Coastal Water Research Project (SCGVRP) The Project is chartered to comprehensive studies of the Southern California Bight, which includes the Santa Barbara Channel. A three-year comprehensive report was published in 1973. Other technical studies and reports are m progress. Originally and presently funded by five local government agencies, additional Environmental Protection Agency grants have been awarded. The 25 scientists are organized into the divisions of biology, chemistry, and engineering. Two of numerous studies under way are: 1) "Quantitative Response Characteristics of Demersal Fish and Benthic Invertebrate Communities," and 2) "A Synoptic Survey of Chlorinated Hydro¬ carbon Inputs to the Southern California Bight." # Universities, Colleges and Academic Institutions The University of California system and the University of South¬ ern California are among the many academic institutions utilizing the resources of the entire Santa Barbara Channel area for research and instruction. Research results appear in journals, technical reports and thesis format. Studies are too numerous and varied to list. Those related IV-97 LIBRARY U- CSF /_ UflByiMA-CHAAtt* to oil production include tolerance of organisms to oil pollution, effects of oil and detergents on survival of species and recolonization of inter¬ tidal substrates, thermal effects of oil pollution in the upper intertidal zone, and long-term and sublethal effects of exposure to oil. • Ocean Dischargers Dischargers (municipal, industrial) are required to monitor their operations (sample and analyze—physical, chemical, bacteriological). Data is submitted to appropriate regulatory agencies. This data of voluminous proportions enables compliance with regulations, but is usually not pub- lished. The USGS has contacted various State and Federal agencies as to their requirements for minimum requirements for biological surveys to determine impacts of oil and gas operations. The agencies contacted (including U. S. Fish and Wildlife Service, U. S. National Marine Fisheries Service, Cali¬ fornia Department of Fish and Game, and Oregon Department of Fish and Wild¬ life) specified various surveys. Also, EPA has performed and contracted produced waste water impact studies. • Study of Oil? Tar, and Gas Seeps^ The California State Lands Commission has contracted with University of Southern California scientists to conduct a 14-month study of oil, gas, and tar seeps in the Santa Barbara Channel. The scope of work includes location of seeps, determination of causes, and an attempt to find means of sealing or minimizing the seepage. The study period is July 1974 through August 1975. IV-98 13. Air Quality Impacts a. Marine Tanker Loading Terminal Air Emissions Measures to mitigate air emisssions from tanker loading activity will be taken wherever possible. Methods of decreasing combustion products generated would include minimization of unnecessary operation of ships borders and auxiliaries during loading. Also, consumption of low sulphur fuel oil will decrease impacts from combustion products. Loading procedures can also significantly affect generation of ullage vapor emissions. Fill pipe locations close (within several inches) to the bottom of tanks decrease turbulance of incoming fluids and resultant generation of volatile hydrocarbon gases. Avoidance where possible or safe, of topping off hold tanks will also decrease vapor discharge to the air because the most hydro¬ carbon rich portion of generated vapors tends to be within a few feet of the fluid surface and are the last to be displaced when filling. b. Onshore Treating Facilities Emissions Mitigation of air emissions from onshore processing facilities will occur by a variety of means. All processes will be closed to the atmosphere and no emissions other than disposal by sweet gas flare incineration of certain waste tail gases and occasional emergency flare burning will occur. The relatively small quantities of combustion gases and their composition and minimization are reviewed in the Onshore Facilities Air Impacts discussion. IV-99 LIBRARY U. OF /. URBAJ\fSl CHAMPAi KM APPENDIX IV-1 Form 3380—1 (February l q 66) (formerly 4—1255) UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT OIL AND GAS LEASE OF SUBMERGED LANDS UNDER THE OUTER CONT INENTA L SHE LF LANDS ACT Office Serial Number Cash Bonus Rental Rate Minimum Royalty Rate Royalty Rate This indenture of lease entered into and effective as of ’ ^ an( ^ between 1 United States of America, hereinafter called the Lessor, by the Director, Bureau of Land Management, and hereinafter called the Lessee, under, pursuant, and subject to the terms and provisions of the Outer Continental Sh« Lands Act of August 7, 1953 (67 Stat. 462; 43 U.S.C., Sec. 1331, et sec,.), hereinafter referred to as the Act and to . lawful and reasonable regulations of the Secretary of the Interior (hereinafter referred to as the Secretary) when not consistent with any express and specific provisions herein, which are made a part hereof. WITNESSETH: Sec 1 Rights of Lessee. That the Lessor, in consideration of a cash bonus and of the rents and royalties be paid, and the conditions and covenants to be observed as herein set forth, does hereby grant and lease to Lessee the exclusive right and privilege to drill for, mine, extract, remove and dispose of all oil and gas deposit < cept helium gas in or under the following-described area of the Outer Continental Shelf (as that term is defin the Act): containing acres, more or less (hereinafter referred to as the leased area), together with. (a) the nonexclusive right to conduct within the leased area geological and geophysical explorations which are not unduly harmful to aquatic life; (b) the right to drill water wells within the leased area and use free of cost, and to dispose of, water produced from such wells; and (c) the right to construct or erect and to maintain within the leased area all artificial islands, platforms, fixed or floating structures, sea walls, docks, dredged channels and spaces, buildings, plants, telegraph or telephone lines and cables, pipelines, reservoirs, tanks, pumping stations, and other works and structures necessary or convenient to the full enjoyment of the rights granted by this lease, for a period of 5 years and as long thereafter as oil or gas may be produced from the leased area in paying quantities, or drilling or well reworking operations, as approved by the Secretary, are conducted thereon; subject to any unit¬ ization or pooling agreement heretofore or hereafter approved by the Secretary which affects the leased area or any part thereof, the provisions of such agree¬ ments to govern the leased area or part thereof subj thereto where inconsistent with the terms of t lease. Sec. 2. Obligations of Lessee. In consideration the foregoing, the Lessee agrees: (a) Rentals and royalties. (1) To pay r'ntals royalties as follows: Rentals. To pay the Lessor on or before first day of each lease year commencing prior to a < covery of oil or gas on the leased area, a renta per acre or fraction thereof. Minimum royalty. To pay the Lessor in of rental at the expiration of each lease year c mencing after discovery a minimum royalty of per acre or fraction thereof or, if there is product; the difference between the actual royalty paid dui the year and the prescribed minimum royalty, if actual royalty paid is less than the minimum roya Royalty on production. To pay the Lessc royalty of percent in amount or value of produc IV-100 saved, removed, or sold from leased area. Gas of all kinds (except helium and gas used for purposes of pro¬ duction from and operations upon the leased area or un¬ avoidably lost) is subject to royalty. (2) It is expressly agreed that the Secretary may establish reasonable minimum values for purposes of computing royalty on products obtained from this lease, due consideration being given to the highest price paid for a part or for a majority of production of like quality in the same field, or area, to the price received by the Lessee, to posted prices, and to other relevant matters. Each such determination shall be made only after due notice to the Lessee and a reasonable opportunity has been afforded the Lessee to be heard. (3) When paid in value, such royalties on production shall be due and payable monthly on the last day of the month next following the month in which the production is obtained. When paid in production, such royalties shall be delivered at pipeline connections or in tanks provided by the Lessee. Such deliveries shall be made at reasonable times and intervals and, at the Lessee’s option, shall be effected either (i) on or immediately adjacent to the leased area, without cost to the Lessor, or (ii) at a more convenient point closer to shore or on shore, in which event the Lessee shall be entitled to reimbursement for the reasonable cost of transporting the royalty substance to such delivery point. The Lessee shall not be required to provide storage for royalty taken in kind in excess of tankage required when royalty is paid in value. When payments are made in production the Lessee shall not be held liable for the loss or destruction of royalty oil or other liquid products in storage from causes over which the Lessee has no control. (4) Rentals or minimum royalties may be re¬ duced and royalties on the entire leasehold or any deposit, tract, or portion thereof segregated for royalty purposes may be reduced if the Secretary finds that, for the purpose of increasing the ultimate recovery of oil or gas and in the interest of conservation of natural re¬ sources, it is necessary, in his judgment, to do so in order to promote development, or because the lease can¬ not be successfully operated under the terms fixed herein. (b) Bonds. To maintain at all times the bond re¬ quired prior to the issuance of this lease and to furnish such additional security as may be required by the Lessor if, after operations or production have begun, the Lessor deems such additional security to be necessary. (c) Cooperative or unit plan. Within 30 days after demand, to subscribe to and to operate under such rea¬ sonable cooperative or unit plan for the development and operation of the area, field, or pool, or part thereof, embracing lands included herein as the Secretary may determine to be practicable and necessary or advisable in the interest of conservation which plan shall ade¬ quately protect the rights of all parties in interest, including the United States. ) Leases of sulfur and other mineral. The right to grant sulfur leases and leases of any mineral other than oil, gas, and sulfur within the leased area or any part thereof, subject to the provisions of Section 8(c), 8fd). and 8(e) of the Act and all lawful and reasonable regulations prescribed by the Secretary thereunder; Provided, That no such sulfur lease or lease of other mineral shall authorize or permit the Lessee thereunder unreasonably to interfere with or endanger operations under this lease. (c) Purchase of production. In time of war, or when the President of the United States shall so prescribe, the right of first refusal to purchase at the market price all or any portion of the oil or gas produced from the leased area, as provided in Section 12 (b) of the Act. id) Taking of royalties. All rights, pursuant to clause (3) of Section 8(b) of the Act, to take royalties in the amount or value of production. (e) b issionablc materials. All uranium, thorium, and all other materials determined pursuant to paragraph (1) of subsection (b) of Section 5 of the Atomic Energy Act of 1946, as amended, to be peculiarly essential to the production of fissionable materials, contained, in whatever concentration, in deposits in the subsoil or seabed of the leased area or any part thereof, as pro¬ vided in Section \2(e) of the Act. (f) Helium. Pursuant to Section 12 (f) of the Act, the ownership and the right to extract helium from all gas produced under this lease, subject to such rules and regulations as shall be prescribed by the Secretary. (g) S us pension of operations during u.ar or national emergency. Upon recommendation of the Secretary of Defense, during a state of war or national emergency declared by the Congress or President of the United States after August 7, 1953, the authority of the Secretary to suspend any or all operations under this lease, as provided in Section 12(c) of the Act: Provided, That just compensation shall be paid by the Lessor to the Lessee. the progress achieved In correcting weaknesses. This review should centime until the Indentl^lcatlon system previously recommended Is operational. The physical technologies with weaknesses fiall Into three categories: need to be developed, need to be improved and need to be deployed. [Chapter VI) IV-113 LIBRARY U- OF /. URBAN A. CIIAJAPM K fl Concerning R&D, the thrust of the Work Group s Recommendation No. A (May 1973 report) was to encourage industry to conduct the necessary R&D because of its operational responsibility for safety and pollution prevention. Accordingly, the approach was to establish an API-USGS R&D Committee to encourage industry in this activity. A list of pertinent R&D projects in progress is being completed together with a list of those needs that require new or improved development. Nevertheless, the USGS should have capability for R&D development. Therefore, the Work Group further recommended that in those cases where industry does not respond to R&D needs, the USGS will contract for the ronm' rpd work. The Work Group agrees with the second part of OU's Recommendation No. 31—to contract for R&D with organizations outside the petroleum industry to insure effective communications with other technological communities and responds to this proposal in its revised Recommendation No. A given below. With respect to OU’s Recommendation No. 39, implementation of the Work Group Recommendations Nos. 1, 2c, 3, A, and 6 (May 1973 report) will provide a basis for compiling a list of inadequate components as well as promotion of R&D for corrective actions. The Work Group did not in its earlier recommendations address the desirability of publishing an annual summary review of progress being made towards correcting the weaknesses. It agrees, however, that this should be done. Accordingly, to respond to OU’s Recommendations Nos. 31 and 39 the Work Group revises its Recommendation No. A (May 1973 report) as follows (additions and changes are underlined): WORK GROUP RECOMMENDATION NO. A ( Revised ) a. The USGS, in cooperation with the API or other appropriate organizations , should establish a program to encourage and promote research and development in safety and anti-pollution equipment and systems. Current and completed research and develop¬ ment should be taken into account in the determination of specific needs. Such needs should be communicated to industry IV-114 through API o r other appropria te organizations , and issued by USGS as an annua] summary r e port . For those needs where there is no response from industry, or the response is unsatisfactory, the USGS should contract for the required wor k> utilizing, when appropr late, orga nizations outside the usual petroleum industry R&D establishments to perform such research . (See also Recommendation No. 8a.) With specific reference to the NAE recommenda¬ tions, the Work Group recommends: (1) The promotion of industry consensus standards should be effected through a cooperative arrangement with API (see Work Group Recommendation No. 5). (2) Requests should be made to NOAA, USCG, and EPA to sponsor programs to study the effects of various amounts of crude oil intrusion into the marine, environment, taking into account site variables. (3) The recommendation to undertake quantitative studies of the effective¬ ness of methods for cleaning up oil from the marine environment should be referred to the U. S. Coast Guard. (4) The development and testing of damage- limiting and fail-safe systems in the area of damage control, fire-fighting, and well control should be an item for follow-up under cooperative arrange¬ ments with API, or other appropriate organizations. IMPLEMENTATION ACTION REQUIRED The Conservation Division should identify those physical technologies and operational IV-115 USRARV II- OF /. e/OOA/VA-CHA&tPAIGH methods in need of R&D, which have a significant impact on safety and pollution control, and for which industry R&D efforts are considered inadequate or lacking. As these are identified, the Division should prepare a plan for contracting with organi¬ zations outside the petroleum industry, but giving consideration to R&D work which could be carried out by the Government itself. The plan should include recommendations for the funding of such R&D work. The Conservation Division should also establish which organizations, other than API, could be considered for assistance in the R&D efforts of the USGS, and their participation utilized when appropriate. OU 32. PeAionneZ StandoAd*. USGS should develop unthoAi n 6tandaAd* ancT~EzmiicaUon a equiAwent* ioA Pf**°™** wko peA^osw Inspection and test hanctcons. (CkapteA OU 33. PeAsonnet T Aaining . USGS should develop a pAogAam to establish. ZmpAoved and standaAdized tAainung and pAo ceduAes ioA opeAating personnel. This pAogAam should utilize the expeAtise oh oAganizations and ^ndxvsduals such 06 behavioAal scientists toko specieLeze a. n tAaining. (ChapteA l/I) • Work Group Recommendation No. 9 (May 1973 report) does not preclude the development of standards and requirements for personnel who perform inspection and test functions. However, Recommendation No. 9 should be amended to identi y this specific need. Likewise, the desirability o utilizing training specialists should be addressed. Accordingly, Work Group Recommendation No. 9 (May 1973 report) is changed as follows (additions and changes are underlined): WORK GROUP RECOMMENDATION NO. 9 ( Revised ) a. The USGS, working with industry through API should set standards and requirements for training of personnel, to include, but not be limited to, the following: (1) A requirement that all operator or third party personnel, who perform IV-116 j.nspec tion and test functions related to safety and pollution control ,~be formally trained and qualified . (2) A requirement for minimum training in safety and pollution prevention and control for all company and contractor personnel, including identification and proper use of safety equipment, emergency procedures, and first aid. (3) A requirement that appropriate company and contractor field personnel be on USGS regulations and orders. b. Standards and requirements for such training should be specified in OCS Orders and a certification, by the operator , of compliance should become a prerequisite for inspect ing. t_e sting, and for certain permits and opera¬ tional work. A system for updating and aud iting such training should be developed . Appropriate credit should be given for pertinent experience. c * Hie expertise of organizations and individuals gho specialize in training should be utilized in the develo pment of stand ards anH ments for training . d. USGS field supervisory and inspection personnel should be required to participate in training courses appropriate to their responsibilities. (The third party" inspectors referred to in a.(l) above could be someone in the employ of the operator who is not responsible for the operations he is inspecting and who reports directly to management, or someone who is an employee of an outside firm with which the operator or group of operators contract for inspection services.) IMPLEMENTATION ACTION REQUIRED Arrangements have been made with API for a joint effort to develop the necessary standards and specifications for training of industry personnel. The Conservation Division should pursue this effort and revise OCS Orders accordingly. IV-117 Requirements for appropriate training of USGS personnel should be included in the Division Manual. The Conservation Division should arrange for briefing programs on USGS regulations and orders. XV. NEW RECOMMENDATIONS The final category of OU recommendations include three (Nos. 17, 22, and 38) that are essentially different from those considered by the Work Group. These are discussed in the text that follows. on 17. USGS Management. With limited exceptions^, post-lease sale management ob OCS oil and gas operations should be concentrated m USGS. Tlie objective ob tht 6 concentration ob management is to eliminate _ naps and overlaps and establish clear-cut responsi¬ bility. Suck concentration mil also assure that management decision* conform to the development plan laid out in the hierachy ob impact statements. Any impact statements triggered by post-lease A cute activities should be the responsibilityob USGS and be AubAidiary to the lease A ale Atatement. Where necessary, transber ob operational responsibility to USGS Akould be accomplished by inter-agency agreements. In Aummary, then, the USGS Ahould continue to administer all ob its present post-lease activities plus the hollowing: (Chapter IX) • The Work Group agrees that the USGS should continue to administer all of its present post-lease activities. Comments on OU Recommenda¬ tions 17a. through 17d. follow. OU 17a. OSHA. By agreement between Labor and Interior, OCS TCesponsibillties asAigned to the Department ob Labor by the Occupational Sabety and Health Act [OSHA) Ahould be administered by USGS. The standards themselves should be developed by Labor ulth the advice ob USGS and the Department ob Health, Education, and Welbare [HEW). Such an arrangement will increase the et^ec £ive day-to-day administration ob the OSHA standards since USGS is already equipped to inspect OCS tfacXXo ties. Further, these sabety IV-118 and kzatt.li concerns are Intimately teed to equlp- mznt design and operational procedure6 that aAe alAeadij a LISGS tier pom lb lltty . As a fiinal ad¬ vantage, this approach relieves Industry oan additional layer ofi Inspectors. • The Work Group agrees. A draft of a Memorandum of Understanding was completed in March 1974 but questions of statutory authority and re¬ sponsibility are as yet unresolved. WORK GROUP RECOMMENDATION NO. 16 A Memorandum of Understanding between the USGS and OSHA should continue to be sought. IMPLEMENTATION ACTION REQUIRED The Conservation Division should continue to take the lead in negotiating a Memorandum of Understanding between OSHA and the USGS. /See section IV.A.9. "Memoranda of Understanding"/ ou 17b * Environmental Administration , USGS should be responsible fior enforcing all environmental quality standards applicable to OCS oil and gas operations . Where necessary, agency responsi¬ bilities should be clearly defined in inter-agency agreements between Intenor, Transportation, and ErA . • Enforcement authorities are usually assigned by statutes. However, various inspection and monitoring activities upon which enforcement actions are based can sometimes be shared or delegated. Accordingly, current efforts towards finalizing various Memoranda of Under¬ standing to clearly define the respective functions, scope of activities and responsi- among the agencies involved in various aspects of environmental protection on the OCS should be expedited, and the results publicized for the guidance of all concerned. The Work Group addresses specific items in this regard in its Recommendations Nos. 13 (Revised), 16, and 17 of this report. IV-119 LIBRARY U. OF /. UfiBA NA - CHAM PAJ H H on 17c Rlahti-o(,-Way. By (,onrnal agaeement beluieen BLM and —BLMilwuld Uiue /Ughti-o(,-uiay (,oa common cavileA pipeline* only upon necommendatxon ofi tha USGS. This t ultl assure that coordination exists between common carrier lines and the gathering lines patently regulated by USGS. Such authority will allow USGS to insure that pipeline development conionmA to the plan* developed in the impact Atatments. Vn.ej.ent responsibility ion. pipeline* i* in.agme.nted and 4 ome agencies are incapable oi meeting their /legulatory responsibilities. ou 17d. Pipeline*. By iomal agAeemoyt between the OU-cce Oi Pipeline Saiety (OPS) and Interior, USGS should be designated as responsible ion. enion.cj.ng design and peAionmance standards ion. onshore pipelines which are now under OVS jurisdiction. The standards, however, should be jointly formulated by OPS and USGS. USGS presently exercises such authority over gathering lines. • Activities for the development of Memoranda of Understanding between USGS, BLM, arid OPS in accordance with the intent of OU Recommendations 17c. and d. have been underway for some time. The principal delaying factors have been the need for reviews of the respective pipeline administering activities, including legal re¬ views, to clarify the statutory authorities and responsibilities of USGS, BLM, and OPS. Current draft proposals of Memoranda of Under¬ standing between USGS and BLM provide for USGS review, prior to final action by BLM, of all rights-of-way applications to install common carrier type pipelines pursuant to 43 CFR 2883. The reviews by USGS would focus on the technical aspects of OCS pipeline design, installation, maintenance and operation in accordance with appropriate regulations and standards designed for safety and environmental protection, and to avoid undue interference with other uses of the OCS and its superjacent waters. The USGS, in cooperation with BLM, will continue efforts to formulate an agreement with OPS whereby OPS safety standards developed for OCS pipelines may be enforced by the USGS. IV-120 WORK GROUP RECOMMENDATION NO. 17 a. A Memorandum of Understanding between USGS nad BLM should be developed whereby BLM approval of pipeline rights-of-way applications will require a determination by USGS of the adequacy of the application with respect to design, installation, maintenance and operation. b. A Memorandum of Understanding between USGS, BLM, and OPS should be formulated whereby the USGS will enforce OPS safety standards, jointly developed by OPS and USGS, for OCS pipelines. IMPLEMENTATION ACTION REQUIRED The Conservation Division should continue efforts to formulate a Memorandum of Understanding between the USGS and BLM concerning pipeline rights-of-way and a Memorandum of Understanding between USGS, BLM, and OPS for the enforcement of safety standards for pipelines. _/See section IV.A.9 "Memoranda of Understanding"/ OU 17e. Gat Reteryet . By hohrnat agreement between the Federal Power Committion (FPC) and I nterior, USGS 6h.ou.ld 6e required to provide ettimatet oh recoverable ga6 retervet to be. terved by propoted new ga 5 tenet. Attached to the ettimatet thould be an attettment oh how the tine will hit into the development plan et tab tithed in the impact ttatementt . Additionally, USGS 6hould be available to FPC contultation on all quettiont concerning linet. The purpote it to attitt FPC in approving new pipelines 60 that they condom to the develop¬ ment plan e6 tab tithed in the impact t totem entt . • Estimates of recoverable gas reserves to be served by proposed new gas lines are the responsibility of FPC, but the USGS has cooperated with the FPC when requested and is available for assistance and consultation. 22. Apply FWPCA to PCS . The FUPCA Amendmentt oh 1972 thould be amended tpeclhically to apply ditcharge provitiont to the OCS. Under thit arrangement, IV-121 LIBRARY U. OF /_ UftBANA-CHAMPA1EH. EPA Mould establish the AtandaAdt, but a* Aecowtn ended eaAloeA, USGS Mould have, enforce¬ ment AetponAlbUUy. TkeAe l* no apparent reaton Mky the. geneAal principle of a separate agency to & that the Vepantment o& dike. Interior establish minimum Federal standards Ion critical OCS operator personnel and certlhy on provide ^on appropriate accreditation oh the tnalnlng programs. (See Work Group Recommendation No. 9). Rapid, accurate measurement oh downhole. pressure appears Impontant In Improving the. ability to maintain well contnol and to reduce the possibility oft blowoutA. The Council necommendA that the Vepantment oh the Intenlon determine which technologies could Improve the meaAunement oh the honmatlon pressure neon the dnlll bit and Inconponate them Into the OCS ondenA. (See Work Group Recommendation No. 4, Revised. This will be one of several items included in the list of items for Research and Development.). The Council necommendA that the Vepantment oh the I nterior, In coordination with the Environmental Vnotectlon Agency, develop mone detailed guidelines hon the dlspoAal oh drilling muds, dnlll cuttings, and other materials, considering h^ily the nesults oh the Bureau oh Land Management monitoring studies oh ocean disposal oh these materials In new OCS areas. (See Work Group Recommendation No. 18). The Council recommends that subsea production equipment be used In new OCS areas where It would provide a higher degree oh environmental protection and reduce conhllct between oil and gas operations and competing uses oh the ocean. (See Work Group Recommendation No. 19). The Council recommends that the Vepantment oh the Interior develop detailed perhonmance requirements h 0/i surhace-actuated subsunhace sahety valves and require their use on all production wells In new OCS areas where technically heaslble. The Vepantment should encourage the development oh such valves with higher pressure ratings and with Improved reliability oh operation over the llh e oh the devices. (See Work Group Recommendation No. 5, revised in Chapter II of this supplement). IV-139 LIBRARY U. OF /. URBANA CHAMPA !UH CEQ 9. In undeveloped areab like the Atlantic and Gulf of Alaska. OCS, environmental loadingb of oil and other materialb should be kept at the. lowest levelb pobbible at Zeabt until environmental babeline btudieb buch at thob e recently initiated by the, bureau of Land Management determine the, environmental ribk from Mich materialb. The, Council recommendb that the, Department of the. Interior and the, Environmental Protection Age-nay, Zn cooperation, ebtablith effluent btandardb for wabte water dibcharge from OCS dAZZZtng, production, and abbo dated operatic nb. Strong conbideration bhould be given to requiring inbtallation of the but commercially available contAoZ teehnoZogy for1 oil-water beparation In new OCS areab. (See Work Group Recommendation No. 18). CEQ 12. The CounetZ recommendb that the Departments of the Interior and Transportation develop detatZed performance /lequirements for OCS ptpeZtne protection and undertake the development of pipeline integrity monitorb to detect incipient failures in OCS pipelines . (See Work Group Recommendation No. 17). CEQ 13. The Council recommendb that the Department of the Interior, in cooperation with other TederaZ agencies and the a^ected Statu, undertake advanced planning for pipeline corridor biting ab boon ab the location of potentially producing OCS areab ib known and debig note corridorb which avoid or minimize, to the maximum extent pobbible, intrubion into environmentally benbitive areab in the marine and cocibtal regionb of new OCS areab . (See Work Group Recommendation No. 17). CEQ 16. The Council recommendb that the TederaZ Government and industry continue efforts to improve oil bpill containment and cleanup. The Council recommendb further that the Department of the Interior and Commerce and the Environmental Protection Agency cooperatively conbideA the identification of critical environmental regionb in new OCS areab and the incorporation of appropriate meabureb into the National Oil and Hazardous Subbtanceb Pollution Contingency Plan. (See Work Group Recommenda¬ tion No. 4. The lead responsibility for improving oil spill containment and cleanup technology rests with agencies other than the USGS. The USGS does, however, participate in the identification of critical environ¬ mental areas [see Work Group response to CEQ Recommen¬ dations Nos. 4, 6, and 15] and will continue to participate in the interagency development of Pollution Contingency Plans.). IV-140 CEQ 25. The Council recommends that, in order to deter violations °i OCS orders rather than simply shortening the time that operators take to correct, noncompliance, the Secretary of the Interior propose sanctions requiring fixed shutin periods and administrative fines as enforcement measures. (See Work Group Recommendation No. 12 revised in Chapter II of this supplement.). Additionally, the following CEQ recommendations have already been implemented: CEQ 17. The Council recommends that States affected by new OCS development strengthen their coastal zone management programs by developing special technical expertise on all phases of OCS development and its onshore and offshore impacts. Such augmented State coastal zone management agencies should attempt to ensure that State interests and regulatory authorities are fully coordinated voith Tederal OCS technical and management activities. Tederal agencies should make every effort to cooperate voith State coastal zone management agencies on an ongoing basis and at all stages of the management process. (It is an established policy to cooperate with coastal State organizations wherever possible.). CEQ 23. The Council recommends that the department of the Interior in consultation voith other appropriate Tederal agencies, determine the kinds of information and analyses necessary for adequate assessment of environmental factors at all stages of leasing and development. The department should take, measures to obtain such information, including acqui¬ sition and analysis of high-resolution, near-surface seismic reflection data for the purpose of determining the nature and magnitude of geologic hazards prior to tract Selection. (The Department of the Interior sponsors an interagency OCS Research Management Advisory Board to oversee the program of pre-operational benchmark data collections on the OCS necessary for an adequate assessment of environmental factors. The acquisition and analysis of high-resolution, near-surface seismic reflection data for the purpose of determining the nature and magnitude of geologic hazards prior to tract selection has been established as a standard procedure.). 11 • RECOMMENDATIONS CALLING FOR MODIFICATION OF EARLIER RESPONSES This Chapter includes those CEQ recommendations which have prompted the Work Group to modify some of its earlier recommendations. The CEQ recom¬ mendations are shown in italics, followed by a brief discussion and a revision of the pertinent Work Group recommendation. The changes in the recommendation are underlined. Implementation actions, additional to those m the May 1973 report and Supplement No. 1, May 1974, are also given. IV-141 LIBRARY U. OF /. URBANA-CHAMPA1 Gfl 4. Serious (lonsideratlon must be given to postponing teasing in an OCS region where oit cannot be safely produced and safety transported to markets because a is significant threats of earthquakes, tsunamis, and severe storms. The Council recommends thatthe departments of the Interior and Transportation coordi- ncte thetr evaluation and approval procedures for drilling platfo.rms for new OCS areas. They should, prepare detailed performance requirements for such platforms, considering fully the natural hazards in these areas. 6. The Council recommends that the department of the Interior develop and incorporate in OCS orders de¬ tailed performance requirements for production plat¬ forms and associated equipment to be used in new OCS areas, with full consideration of natural hazards. The department should develop in-house capability, or should contract with a qualified independent firm, to evaluate the adequacy of the proposed designs to guarantee structural integrity subject to natural and manmade forces. 15. decisions on offshore oil storage in the Atlantic and Gulf of Alaska OCS must fully consider the potential impacts of severe storm and seismic conditions. The Council recommends that the departments of the Interior and Transportation develop detailed performance standards for offshore storage facilities and incorporate them into OCS orders for the new areas. General requirements for the design submission and approval of fixed and mobile platforms are given in OCS Order No. 8. This Order does not, however, give detailed performance requirements specific to different OCS areas. Environmental studies to identify hazards are now a part of the OCS leasing program. Agencies, such as the USGS, NOAA, EPA, and BLM, contribute to these studies. Hazards identified by these studies, by Environmental Impact Statements, and by the inter¬ agency OCS Research Advisory Board should be taken into account when specifying requirements in OCS Orders. Accordingly, Work Group Recommendation No. 13, Revised (May 1973 report and Supple¬ ment No. 1, May 1974) is further revised as follows: WORK GROUP RECOMMENDATION NO. 13 (Second Revision) a. Formalized procedures of the type outlined in the NASA recommendation should be established for development and revision of OCS Orders. b. In general, OCS Orders should specify the objectives to be achieved, with standards for achievement included by reference. IV-142 c. The Work Group agrees with the NAE recommendations that (1) there should be continuation and refinement of the current practice of requiring submission of plans of applicants in terms of equipment and including personnel qualifications and training procedures; and (2) that regulations should take into account on a continuing basis the results of the analysis of information resulting from accident evaluation, as well as consideration of natural environmental hazards. d. All memoranda of understanding and interagency agreements concerning management of OCS petroleum activities should be made available in a single document, and appropriate references made in OCS Orders. e. The Conservation Division should adopt the following procedures for the development of new and revised OCS Orders: (1) Announce in the Federal Register its intention to prepare a new or revised Order and solicit comments and recommendations. (2) Prepare a draft of the Order and publish it in the Federal Register for comment. Steps (1) and (2) may in some cases be concurrent. (3) After receipt of comments, Division personnel may meet with interested organizations or consult with individual experts on the various requirements of the Order. (4) Revise the draft Order, if appropriate, to take into account the information developed from steps (2) and (3). (5) If the revision is extensive or significant, republish the Order in the Federal Register as a redraft for further comment. Otherwise, publish it in the Federal Register as a final Order with an effective date. f• The USGS, in coordination with DOT and other Federal agencies having pertinent expertise or .jurisdiction, should develop detailed performance requirements for fixed and mobile platforms and fixed and mobile offshore storage facilities , taking into account specific environmenta l hazards and problems that are characteristic of different regions of the OCS. IV-143 IMPLEMENTATION ACTION REQUIRED (additional to those in the May 1973 report and in Sup¬ plement No. 1, May 1974) The Division should strengthen its in-house and contract capability for the development of platform performance requirements and design review, and coordinate as appro¬ priate with DOT and other Federal agencies having pertinent expertise or jurisdiction. The Division should also coordinate its evaluation and approval procedures for such platforms and storage facilities with DOT. CEQ 10. The Council Ae.comine.ndy!) that the VepaAtment o ^ the InteAaoA develop detailed peA^oAmance AequlAement* &oa *a^ety pAactlce* ^oa well woAkoveA and *eAvlclng operation* on pAoductlon plat&oAm* and IncoApoAate them tn OCS oAdeA* ^oa the new aAea*. The VepaAtment should con*ldeA Aegu- latlon* encouAaglng the u*e ofi tmpAoved technology to minimize the thAeat oi blowout* duAlng woAkoveA and *eAvlce opeAatlon*. 9 A similar recommendation for specific attention to well work- over and completion operations was made in the NAE report, but the Work Group limited its Recommendation No. 5 to equipment. Additionally, in the development of OCS Orders for different areas, attention should be directed to environ¬ mental hazards and problems that are characteristic of the specific OCS area. The Work Group believes that the USGS should adopt new procedures that would formalize the participation of all interested parties in the development of standards. This would broaden Work Group Recommendation No. 5 which was made in response to the recommendations of the NASA study team and the panel of the Marine Board, NAE, which called for the USGS to work with API in the development of standards. This does not preclude the continuation of work on the part of API for the development of "industry consensus standards." Accordingly, Work Group Recommendation No. 5 (May 1973 report) is revised as follows: WORK GROUP RECOMMENDATION NO. 5 (Revised) The USGS should identify needs for additional or more specific standards for safety and antipollution equipment and for hazardous operations such as well workovers, servicing, and IV-144 2 . c ompletions . The standards should include performance °P eraC1 °-^ »d for the^perational ll'irq oh is equipment in the marine environment. The USGS should establish the 1n-hn„«» capability to deveTT^T standgrds_buriirould make, use organizations such tMc r «o MF rni ml ° naara ^- ihg_°E£o rtunity to a ssist in the preparatio n, to review ^Td ^--^^£^Sj ^findardsbefore~~thev Z aro~ ^a^f7a~~^ problems that are 6 h S ' pecific enviro n mental hazards and £ oblems that are characTTK j tic of differe nt areas of th„ Tn ' tn oc; Oid!i^ a e 7 0 lnl:0 | aC - ^°-^ " hen lncor Porat ing standards I^d 13 Revised . i 6 S ° Gr ° UP ^“•"endatiors Nos. 4 IMPLEMENTATION ACTION REQUIRED (Additional to those in the May 1973 report) for th^development^f "^standards ; ad ° Pt: ^ f0ll0Klng PP ° Ced — 1. Identify needs for new or modified standards, and establish priorities. Publish a notice in the Federal Register of intent to prepare specific standards, requesting input and assistance. 8 Prepare drafts of new, updated, or revised standards by one or a combination of the following methods: o By use of input derived from step 2 above. o By use of available in-house expertise. o By arrangement with ANSI, ASME, ASTM, API or other organizations who prepare standards. 4. Publish draft standards in the Federal Register for comments. B ei or 5. Consider the comments received, publish the final standards in the Federal Register, and incorporate them in an appropriate OCS Order by reference. P it public and other participation, and publish a notification of these arrangements in the Federal Register n IV-145 3. LIBRARY U. OF /. URBANA - CHATAPA1 G14 rvn ii Thp CounctZ A &cottitti(iYidA that the. Vc-pcPitrri£./it6 oi th. d Results of accident investigations, in addition to being made available to the public, should be provided to the Review Committee for possible further analyses. p. The USGS ac cident report in g system should be modified .la_ T'milunrH-n FT>A t° insure compatible format s 7n that statistical anal y ses of composite figure s_may_be performed . IV-146 IMPLEMENTATION ACTION REQUIRED (additional to those in May 1973 report) wh^ S ° n a S f° Uld - be establlshed wi th the DOT and EPA to determine t modifications to the systems used by the agencies will be analyses^ Pr ° Vide 3 COmprehensive bas i* for adequate CEQ 26. The Council recommends that the department o{ the Interior th and the 4 cole. o{s OCS developmentIn voAtocu Meglont. Statu agencte* tkoald Tw t0 f l aA ^ cJj P^ ^ Mua inspection eUofits. In addition, the. Vepantment should eAtabtak a lonmal tA.aana.ng pAogAam tfoA the. inspection stafifi. Work Group Recommendation No. 12 (May 1973 report) takes into Work U Grou nSPeCti ° n strat ^. aad Policy. While the should he P k 3Sr d eS th3t personnel requirements for inspectors this f °° inspection strategies, it did not address this point specifically in its earlier response. The Solicitor has informally advised the USGS that personnel from a State agency cannot assume the responsibility of the A L era Th overnment for assuring compliance with the OCS Lands Act. The Work Group agrees, however, that in the absence of egal constraints it would be desirable to include representa¬ tives from coastal States in certain inspections. Mav k lQ 74 i P Recom " endati ° n No. 9, Revised (Supplement No. 1, inspection^taff^ ^ ^ ^ 3 p ^am *>* bb e Accordingly, in response to CEQ Recommendation No. 26 Work Group Recommendation No. 12 (May 1973 report) is revised as follows: WORK GROUP RECOMMENDATION NO. 12 (Revised) a. The USGS should incorporate into its inspection program all of the NASA recommendations (a. through e. above) and LMS recommendations 1, 2, 3, and 5 above. Punitive fixed- period shutins (LMS recommendation No. 4 above) are not permissible under existing legislation, nor are they considered advisable. IV-147 LIBRARY U. OF /. UfiBANA CHAMPAl £ g OCS Orders should include requirements for lessees to conduct inspections on a scheduled basis and report the results in a specified format to the USGS. The USGS should explore the feasibility of inspections as an alternative or supplement to lessee inspections. The USGS ghnnl d invite representatives from interested ag encies to become f am iliar _w i t h Federal inspec nr ocedures. USGS shoul d also request an opinion from t __ M.vnnr on the extent of possib le participation _b£ in OCS inspections , a nd respond according _i with invitations to the States to parti cipate, as appropriate . The PINC system of inspection should be periodically reviewed to determine how it should be modified an improved. The USGS should formalize inspection strategies and policies, including optimum frequencies of inspections, and emphasize improvement of methods for evaluating inspection results. These results should be used in determining the number of inspe ct ors require __. The USGS should continue to evaluate procedures for inspection and enforcement to insure the application of rigorous and uniform practices in light of new require mp.nts and past experiences. IMPLEMENTATION ACTION REQUIRED (additional to those in May 1973 report) A Solicitor’s opinion on the extent of State participation in OCS inspections should be requested. IV-148 Statement of Principles^ for Choosing areas to lease and in administering environmentally safe offshore operations * ™? 1 1 ° ra ‘^°V nd devel °P nlent °£ the OCS must take place under a P icy which puts very high priority on environmental protection. The location and phasing of OCS leasing should be designed to ^ni 1 ::: L^™L:r^: bJectIves of the ieasing program at * must be used *• • Regulatory authorities available to Federal agencies must be enviL™Lt:rri S \:in r :::^Ta n "as s “ ictly enforced to minimize and subsequent State and local community action The g? declsl ° ns inevitable a , hat P lannln S ca n precede and channel the integrated 1 ^1“' P ressures - Experience must be continuously xuLegraced into the management process. y and i * lterested public must be given the opportunity to participate - gr0, ”l he report to the President by the Council on Environmental Ap U rU ^ 7 r titled "° CS 0U and GaS " An E -ironmental Assessment, ft IV-149 LIBRARY U- OF /. UfiBANA CHAMPAi BHI REFERENCES n n T -I Q 7 t Pineline design to reduce anchor and fishing board Brown, R. J., 19/3, Pipeline uesxgu ^ 199-210. damage: Transportation Engineering Journal of ASCE, 99. T _ a \ h nmuin October 1970, a Solution to ground sub- ESS casing stings Vd-nAe^s: AIME, 45th Annual Meeting. California Department of Fish and Game, 1972, Listing of California's endangered and rare fish and wildlife. _ p cup-t 1964 Artificial habitat in the r^o^; ^California and Game, Fish Bulletin, 124, 93 p. Conservation Coronittee of California Oil Producers, 1972, Annual review of California oil and gas production 1971. ^rafa^es^e^TrlpS^to^he^pitsfdln; b^the'co'ncfl^n'EnvTron-" mental Quality. Domenico, P. A., and others, 1965, Water from low-permeability sediments and land subsidence: Water Resources Research, V. 1, No. . Federal Regulations, Code of. Title 30, Part 250. Federal Water Pollution Control Act, Amendments of 1972 (P.L. 92-500; 86 Stat. 816). Kaffir ■*” 1971b, Evaluation of impact on the marine environ- — . .. _i 4.-4„ ooKio and baree loading 1971b, evaluation ui . ment of proposed submaTi ne pipelines, electric cable, and barge loadtng facility near Corral Canyon, California, 23 p. facility near Corral Canyon, California Kurenkov, 0. V., 1970, Subsidence of the earth's surface as related to oil and gas fields, 1970. Lofgren, B. E., 1968, Analysis of stresses causing land subsidence: U. S. Geological Survey Professional Paper 600-B. „ dc n i (Clausing 1969, Land subsidence due to ground- water'withdrawal^Tulare-Wasco California: U. S. Geological Survey Professional Paper 437-B. National Academy of Engineering, Marine Board, 1972. ^er Continental^lf resources development safety, a revie . f petroleum products, systematic minimization of environmental intrusion from petroleum P IV-150 contract Gullitf™" “ d SpaCe "■^•‘ration. 1971, Applicability 0 f NASA contract quality management and failure mode effect anaivci. j WAA the USGS Outer Continental Shelf oil ,„j „ , ect anal y sls procedures to untinentai snelf oil and gas lease management program. m 0 eif:r6u^"conti t Ln1;i^^ 7 eif^ n n g Ld n gL r ^rSs. * technol °^ — Outer Continental Shelf Lands Act (43 USC, sec. 1331-1343). Barbara^l^iirigeg-^Tf^ol^^ 0 '^ 08 ^ 1 " 3 ! 1 SUrVey ° f the Santa of Southern California. * Hancock Foundation, University J:;;"";'*•««■ S^'g: 1S7! - s, "“' °< ss«£ 1972, Outer Continental Shelf lease management .roup on OCS Safety and Pollutio^ContTOl.^’ 1 t0 ^ reP ° rt ° f th ® Work June 1974, Notice to lessees and operators of *» the Outer Continental Shelf,°Pacifi<; S Region jevelopment^"and seismicity'o^the'Sant^B^bar^Channel^region^Cali forni sr • S ' Geological Survey Professional Paper 679. g ’ tallfornia - deferences added since initial manuscript preparation dl^rilling^Assembly Select^ Rep0rt on Hear ings Regarding Offshore imng. Assembly Select Committee on Coastal Zone Resources. nd S ihe e Co!sial°Zone er 93d 4 Co° Uter Co "“" ental shelf Gil and Gas Development or the use of the rA™, « C ° ngrasS ’ 2d Session Committee Print, prepared cean Policy Study, 2™p! °" ^ persuant t0 s - Res. 222, National IV-151 LIBRARY U - OF A UR BA NA - CUAMPA1 G fi i 1 ft* «• Hfl ' :i* ■ ■ t V. UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS Unavoidable adverse effects that might result from oil and gas activi¬ ties on Federal OCS lands in the Santa Barbara Channel are as follows: A - Oil Pollution Effects on Marine Environment Information presented in section III shows that small intermittent or continuous oil discharges (normally less than 25 ppm oil in produced waste water discharge) and small inadvertent recurrent oil spills probably would occur, and occasional major spills might occur from such activities. Research on long-term effects of oil spills on the marine environment is underway and studies of the effects of oil spills in the Santa Barbara Channel and elsewhere have been summarized in several reports. However, the studies have varied in procedure, the extent and composition of the products spilled have differed, and the natural and physical conditions have varied. The magnitude of impact of a spill is directly related to the volume and duration of pollution and the physical conditions under which it occurs. The severity of impact also depends upon the types and quantities of vulnerable wildlife present. The effects of oil spills on the environment, some of which are discussed in section III of this statement, although controversial among experts, seem to indicate that damage to the natural system from spills of crude oil has been less severe than that resulting from spills of more highly refined fuels. Regardless of the nature of the oil, however, the normal "health" of the ecosystems is disrupted and some balance is lost during the period of recovery. 1 * Marine and Marine-Associated Birds and Mammals In the event of an oil spill, the severity of the impact on Wildlife is dependent upon the quantity and type of oil, the abundance and species present, migratory patterns, stage of breeding and rearing of young. V-l LIBRARY ii. OF L URBANA-CHAMP A1GH seasonal factors, meteorological and oceanographic conditions, and other variables. Many birds and mammals of the open ocean avoid oil to some degree. During the 1969 Santa Barbara oil spill they were observed moving away from the slick itself. a. Birds Aquatic-related bird species in the Santa Barbara Channel region that were most affected in the 1969 oil spill were those that swim at the surface, such as cormorants, loons and grebes. An estimated 3,600 to 6,800 birds, mainly loons and grebes, died as a result of the 1969 spill from Platform A. At that time techniques for treating the affected birds were inadequate and the survival rate was low. Since then survival rates of 41 to 50 percent have been recorded in 1973 (section III.L.6.). This increase was directly related to improved techniques. The bird population around Santa Barbara has recovered from the effects of the 1969 spill. Rare and endangered species in the Channel area include the California least tern (Sterna albifrons brown!), which uses the beach areas for nesting; and the resident California brown pelican (Pelecanus occidentalis californicus). The brown pelican uses the offshore waters for feeding and nests on Anacapa and Santa Cruz Islands. b. Mammals Marine-associated mammals of the Channel include whales, dolphins, sea lions, and elephant seals. Sea lion and elephant seal rooker- ies on the Santa Barbara Channel Islands would be susceptible to severe impact should a major spill reach the rookeries before pups were weaned, a V-2 period when there would be a greater possibility of oil ingestion. Reports on the impact of the 1969 Santa Barbara Channel spill generally do not attribute the death of marine mammals to the oil spill, but the direct and indirect effects of oil have not been completely investigated. 2. Benthic Organi sms Patterns of crude oil dispersion offshore are similar regardless of the source (see section III.L.1.) In the Santa Barbara Channel, benthic organisms of the intertidal zone would be most affected if oil were washed upon the shore. Tide-pool animals would be affected to a lesser degree. Benthic organisms of the subtidal and bathyal zones would be least affected. No rare or endangered benthic species should be affected. Due to the miti¬ gating measures for the operational phase (see section IV), the potential for major impacts on benthic organisms is minor. 3. Bottom Sediments The major potential impact on bottom sediments would be the formation of tarballs (a mixture of higher density oil components and sedi¬ ments). These generally are formed and deposited at some distance from the site of the spill. Unlike natural tar seeps on land, spilled oil would not cover or blanket the bottom sediments, or bear resemblance to the vents of natural tar seeps offshore. A cumulative effect on bottom sediments would be an increase m tarballs which have been found on beaches, in deep basins, and floating in the open ocean. 4. Beaches and Shoreline Recreation The most serious impact on beaches and shoreline recreation ould be the remote possibility of an uncontained minor or major oil spill reaching the nearshore and beach areas. The magnitude of the impact, until V-3 LIBRARY U. OF L URBANA CBAMPA1BH cleanup is completed, could range from "objectionable" to "severe recreatron- a i loss," the latter costing several thousand dollars in recreation lost and operator cleanup. If pollution incidents occurred during periods of heavy visitor use, loss of recreational enjoyment and use and the loss in economic benefit to the vicinity could be substantial. Spilled oil would have a direct adverse impact on local inhabitants, because it fouls boats, temporarily pollutes recreation areas, and curtails the tourist industry. Water sports, such as surfing, swimming, diving, spear¬ fishing, underwater photography, fishing, boating, and water skiing would be directly affected by an oil spill. Other marine-related activities such as beachcombing, shell hunting, seascape painting, shoreline nature study, camping, and sunbathing would be unattractive during cleanup operations. B. Construction and Operation Effects Construction of platforms, submerged production systems, and the pipelines necessary to move produced oil and gas from the offshore produc¬ tion facilities to storage and treatment facilities, and the disposal of washed cuttings during drilling operations would have a minor and short- lived adverse impact on nearby flora and fauna. 1 . Wildlife Along Pipeline Routes and Near Qnsho rg^ Facilitie s^ Pipeline and utility installation would temporarily disrupt the natural habitat; however, it should recover within a short period of time. Onshore facilities would represent a longer term land commitment; eventuall) however, the land would be returned as nearly possible to its natural statu! or to a higher land use. Not all species are affected to the same degree by human activity. V-4 Oil and brine spills, potential but unlikely, could disturb the nearby wild¬ life population; however, eventual recovery would be expected. 2. Benthic Organisms During the constructional phase, any platform, pipeline, near¬ shore loading terminal, offshore storage terminal, or submerged production system should have a short-term impact, ranging from negligible to moderate, on the benthic organisms. The duration of this impact is estimated to range from 2 months to several years depending on specific community composition. The most significant of these operations could be burial of pipeline portions by blasting, jetting, or covering with rip-rap along a narrow corridor from the intertidal zone to the outer edge of a kelp bed if present. The benthic environment would return to a condition similar to that before construction. An artificial habitat would be constructed. 3. Bottom Sediments The effects of the possible levels of development on bottom sed¬ iments alone are anticipated to be minimal. During the construction phase, (for example, platform, pipeline, nearshore loading terminal, and/or offshore storage and loading system), the microrelief of the ocean floor would be changed. Turbidity would be increased temporarily. Rip-rap could have a local effect on sediment transport dependent upon water depth. A few square yards of sediment could be covered if a single leg mooring system were built. Drill cuttings and displaced sediment would have neither beneficial nor detrimental effects. Compared to naturally occurring onshore-offshore and longshore sediment transport volume, the sediment displacement would be minimal. During the post-operational phase, temporary minor disturbance would occur if V-5 LIBRARY Ii_ OF L UOOAKA-CHAAiPAlBH bottom and sub-bottom components were long-term effects on sediments. removed. There would be no significant 4. Beaches and Shoreline Recreation a. Construction Phase The beaches or coastline in the Channel region would be impacted upon on an intermittent and temporary basis during the construction phase of the facilities. During this time, a pipeline may be buried near¬ shore (to 200 feet water depth) and onshore at the beach. Increased water turbidity would result. Increased noise and exhaust vapors would be pro¬ duced. An onshore construction site would produce increased background noise, fumes or exhaust vapors, and possibly increased siltation during and shortly after construction. See section III.LL.l.b. for construction air impacts. b. Operation Phase Offshore marine loading terminals, platforms, and associate* vessel movements would be partly visible to beach visitors, some of whom might find them aesthetically objectionable. C. Compatibility of Commercial Fishing All offshore structures interfere to a degree with commercial fishin This conflict is most intense in shallow areas. The structures themselves would occupy a minor area of ocean bottom, but trawling gear could be en¬ tangled if trawlers approached too closely to them. If several structures were clustered moderately close to each other, they could render the entire area within the cluster unusable for trawling, although this is not likely. Commercial fishing is carried on in the Santa Barbara Channel with a steady V-6 volume of trawler activity. Methods of commercial fishing other than trawl¬ ing are largely unaffected by offshore structures or pipelines. Otter boards, weighing from 500 to 800 pounds each, have rounded edges designed to allow the boards (and net) to "hop" or slide over smooth under¬ water obstacles. Most trawling is done in deep water although a sea-bottom pipeline connection at the 300-foot water depth could possibly snag nets. The location of pipeline connectors would be public knowledge, and this information could be plotted on marine charts and the area could be avoided by local trawlermen. Damage, in the form of fraying or minor tears, might result if nets should contact barnacles growing on the pipelines, although this is expected to be no more serious than present net contacts with barnacles on rocks. Pipelines could serve as traps for trawling equipment if gaps or scoured areas opened under them. Under these conditions, otter boards could ride under pipes and wedge firmly, instead of smoothly sliding across them. If this occurred, a net might be severely damaged or lost, especially if tow- lines between the trawler and the net failed. Most fishermen indicated that such a loss could normally be avoided by reversing power and "backing the net off the pipeline,” but it was generally conceded that adverse weather conditions, or other unforeseen factors, could make this course of action difficult. D - Relationship to Shipping Traffic Very little, if any, interference would occur between platforms and ships that are utilizing established shipping lanes. The possibility of a major seagoing vessel colliding with a platform is considered remote as most offshore facilities would be located several miles from the shipping V-7 lanes and the platforms would be equipped in accordance with Coast Guard regulations. E. Effect on Truck Traffic Truck traffic on local highways would be increased with the increased chance of accidents, some additional noise, and slightly increased air pollu¬ tion. See section III.LL.l.b. for construction traffic air impacts. F. Archeological and Cultural Resources Adverse effects on historic and archeological resources will occur if ground-disturbing construction or drilling cannot be designed to avoid cultural resources identified by previous surveys. If such relocation cannot be accomplished, then destruction of sites constitutes an adverse effect to the extent that scientific salvage, or salvage excavation, destroys the context, making the context unavailable for future study. Study may be accomplished prior to salvage excavation. G. Debris Adverse impacts of debris from various sources can be summarized as follows: • Metal objects may be lost off platforms, barges, and boats and sink to the bottom causing damage to commercial fishing trawling nets. Side-scan sonar records indicate that a variety of sunken objects is present on the floor of the Santa Barbara Channel. The net increase in sunken debris due to the proposed activities should have little additional impact. • Small boats can be damaged by collision with large, heavy, floating materials, and a small percentage increase might be V-8 expected from petroleum-related activities. Also, floating rope and sheeting could foul the screws of motor vessels and boats. • All floating debris, including litter, constitutes an aesthetic impact, especially when floating in nearshore areas or stranded on beaches. H. On-Land Impacts Construction of onshore facilities would change the local topography and would have a small, but long-lasting, effect on runoff of surface water. Natural slopes might be changed by cutting and filling; stream channels could possibly be confined to buried conduits. Increased industrial activi¬ ties might enter rural areas, thus occupying a small amount of land poten¬ tially suitable for other uses. I. Air Pollution Volatile hydrocarbons and other gases would be generated and released to the atmosphere from the following activities: development of wells, treatment of produced fluids, transportation to market of produced minerals, and exhaust gas generation from internal combustion engines on drill rigs, construction equipment, service boats, and motor vehicles. The overall impact of the planned development on air quality should be small. However, an OCS oil spill or a well blowing out of control, ignited or unignited, could contribute air pollution in varying degrees. See section m*LL. for air quality impacts. d• Water Pollution Offshore facility activity would result in the introduction of pollutants into the marine realm such as treated sewage, minor amounts of trash and garbage, drilling mud, produced waste water, and potential small V-9 LIBRARY U. OF L URBANA CHAMPA !HN recurrent oil spills. Moderate to severe degradation would occur in the event of an accidental oil spill. A major oil spill would result in several impacts on the water qual¬ ity of the Santa Barbara Channel. These include: (1) a reduction of sun¬ light; (2) a decrease in the concentration of dissolved oxygen of the surface waters under the oil spill; and (3) an increase of hydrocarbon concentrations in water adjacent to the spilled oil. K. Impact on Humans Two unavoidable adverse impacts would affect some people m the vicinity of a proposed project. One stems from the visual impact of the platforms and other marine facilities; the other, which is closely related, stems from the overall increase in industrial activity. Some people would object to the very presence of the platforms and other facilities because they decrease their aesthetic enjoyment of an uncluttered marine vista. Some would object to the increase in truck and car traffic, the increase m noise levels, and other nuisances attendant to the industrial facilities. Potential threat to human safety would, for the most part, be limited to the workers either on the platforms or at the onshore treating and storage facil ities. The impact on social services and increased demand placed on local govern¬ ment agencies would be small. (See section III.N. ’’Socioeconomic Impacts”) V-10 VI. RELATIONSHIPS BETWEEN LOCAL SHORT-TERM USE AN D MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY The principle short-term use of the Santa Barbara Channel OCS would be for extraction of oil and gas from those leases that have proven reserves of oil and gas, and exploration for additional reserves on other leases. This mineral extraction would diminish the oil and gas reserves of the Santa Barbara Channel. The long-term effects of oil spillage cannot be assessed until reliable data become available which will permit the analysis of overall biologic effects caused by a gradual buildup of oil-derived pollutants in the marine environ¬ ment. The additional stress from any form of pollution which the ecosystem can absorb is finite, but at present the bounds of these limitations are not known, and their possible effect on long-term marine productivity cannot be completely projected. Among pollutants derived from petroleum breakdown are aromatic compounds such as toluene and benzene that are toxic on contact. Other aromatic compounds, including those with carcinogenic properties, are potentially dangerous if ingested, although some organisms are able to purge themselves rapidly or metabolize the compounds into nontoxic substances and excrete them. It has been hypothesized that these might be concentrated through the marine food web, but evidence is not conclusive (see section III). However, these lighter more toxic fractions are more quickly dispersed and evaporated, and the heavy fractions that remain longer, such as tar, are less toxic and in certain instances are physiologically inert. The regula¬ tions under which further development would occur are the most stringent ever promulgated. With strict enforcement of these regulations and their further development, the possibility of adverse effects from the proposed action should be less than from similar actions in the past. At present, offshore oil production accounts for two percent of oil pollution to oceans. VI-1 LIBRARY U. OF i. i/KBAMA-CHAMPAIGH The cumulative effect of structures on multiple uses in offshore areas where more and more structures are required as OCS production increases is also one of concern. The cumulative nature of structures as obstacles to commercial shipping and commercial fishing activities represents a use conflict that can be controlled through proper planning and coordination with appropriate Federal and State agencies and private industry. Some leveling out in the number of platforms and the number and total length of pipelines would be expected as more and more areas go out of production, gome platforms would be removed and some additional capacity would become available in existing pipelines to carry products from new areas. The intrusion of man-made structures into areas where few or none exists is another matter of environmental concern. However, individual developments would have a relatively short life (about 30 to 40 years) and would be re¬ moved when mineral extraction was completed. The extraction of oil and gas would create additional wealth that eventually would be distributed in various proportions among the workers, the unit operators, the Federal Government, and local governments. How this wealth were used would have both a short-term anc a long-term effect on the environment of the Santa Barbara region. No long-term, direct adverse impact, such as scarred terrain, would remain except possibly in the area of the treatment facilities, and these areas could be landscaped and re-seeded witn native plants and snruos. Destruction of archeological and historical remains that cannot be avoided or retrieved in project design constitutes a cumulative adverse effect. Cumulative effect of this destruction is increased by the loss of such resources for study in future years when techniques of archeological study are improved. Recovery of submerged remains, if present in impacted areas. VI-2 may offset in part the long-term destructive effects of the sea; the relative importance of such effects is not known since there has not been intensive and systematic study of submerged historic and archeological remains. Short-term effects would result in the event of minor or major oil spills. The local short-term use of the marine and shore environments for oil and gas production should have little adverse effect on other uses, either for the short or long term. VI-3 ^ isn • irreversible and irretrievable commitment of resources The purpose of this section is to set forth those resources that would be consumed and those that would be altered irreversibly and irretrievably by additional development of oil and gas resources in the Santa Barbara Channel OCS. Further development of the Santa Barbara Channel OCS could involve commit¬ ment of a significant part of the area’s oil and gas resources. Minor amounts of water supply, air, other mineral resources, and wildlife including fish probably would be committed (lost). The natural appearance of very small amounts of land area would be altered to some degree by onshore facilities. An irretrievable commitment of some construction materials would result: presumably mainly subocean-floor casing, cement, and chemicals. Some con¬ struction materials, mainly steel, might have salvage value and be retrieved after production is completed. The extent of these commitments and an assess¬ ment of their environmental impacts have been previously discussed. A. Mineral Resources Further development would permit extraction of producible oil, gas, and associated materials, including sulfur. This development could result m production estimated to range from 1 to 2 billion barrels of oil and 530 to 970 billion cubic feet of gas. B - Fish and Wildlife Resources An irreversible or irretrievable commitment of fish, fowl and other wildlife resources and habitats would occur in the area of a massive °il spill. Recurrent low levels of oil pollution may result in a degree of harm to some biota. At present, offshore drilling and production operations account for two percent of oil pollution to oceans. The full significance VII-1 of such low level oil pollution cannot be assessed because of the presence of numerous natural oil and gas seeps, the total amount of such pollution cannot be foreseen, and the long-term effect on most species is not presently known. C. Archeological and Historical Resources Destruction of archeological and historical resources, should it occur, constitutes an irretrievable adverse effect. These remains whether onshore or offshore are a non-renewable resource, and the primary source of information for analyzing them is their context - the relationships between artifacts, their surrounding deposits, and the original environment. VIII. ALTERNATIVES TO THE FURTHER DEVELOPMENT OF OIL AND HAS RF^nnornc nr- TO Tocs PORTIONS of t he SANTA BARBARA chammf. RESOURCES OF The preceding sections of this statement describe the methods that could be utilized for exploration and development of oil and gas resources thought to be in the Channel area. Future OCS oil and gas production within the Santa Barbara Channel may be accomplished by implementation of any of the various levels of development activity as described in the preface and section I, or a combination of the various levels. The estimated levels of oil and gas production and related facility requirements are given in section I, tables 1-1 and 1-2. The potential impacts associated with the various related implementing activities are identified and evaluated in section III. The major physical impacts that may result from offshore oil and gas opera¬ tions are those resulting from (a) large discrete oil spill incidents, such as the Platform A blowout of 1969, and (b) small, but vastly more numerous, chronic additions of hydrocarbons to the marine environment. The latter may occur not only from the OCS petroleum industry operations directly, but much IS also contributed from onshore discharge of airborne and liquid effluents including municipal sewerage, shipping and pleasure craft operations, and from the many natural oil and gas seeps from the Channel floor and shoreline areas Which have been known throughout the recorded history of the region. Sections III.K. 1 through 3 have discussed and documented the known oil spill history of offshore activities, and take note of the applicability and reliability of the data presented. It is not possible to relate the data there presented to potential spills and impacts resulting from OCS activities l " thS Santa Barbara Channel, due to a lack of reasonable comparability of conditions at the time and place the specified incidents occurred and the VIII-1 LIBRARY U. OF L UflBANA-CHAMPA J6M present or future conditions and activities that may take place in the Channel area. The data from section III.K. 1 through 4 are useful and instructive only in the most general sense. Thus, in the following discussions the probability of either large or chronic small spill occurrences cannot be usefully discussed at each appropriate point in the text. Clearly, the greater the intensity of activity, and the more wide spread oil and gas activity becomes in the Channel, the greater the possi¬ bility for major spills, and the larger the increment of small chronic pollution must become. The magnitude and importance of such increased possibility and increment, however, is speculative. (See section In summary , the several possible future levels of OCS oil and gas development are: Proceed with development and production on existing producing leaseholds Carpinteria Offshore - Dos Cuadras Offshore Development of existing leaseholds with discoveries, not presently developed VIII-2 - Pitas Point Unit Potential Field Area - Hueneme Offshore Potential Field Area - Santa Clara Unit Potential Field Area - (development of the Santa Ynez Unit, Hondo Potential Field Area was authorized on August 16, 1974) • Exploration of leaseholds, without discoveries, and subsequent development in the event economically recoverable reserves are proven • Offering additional lands for lease, exploration, and development The Administration’s proposal for the establishment of a National Energy Reserve encompassed the Federal Ecological Preserve and the Federal Buffer Zone established in 1969. The Secretary has not revoked the orders establishing these two areas at this writing (January, 1976), thus their withdrawn status continues. The remaining lands proposed for inclusion in the National Energy Reserve returned to their pre-proposal status when the 93d Congress adjourned without passage thereof. Thus, the following discussions of Alternatives C, D, and E, exclude the Preserve and Buffer Zone but do encompass other areas of the once proposed National Energy Reserve as appropriate. A. No Action The viability of this general alternative, and its potential impacts differs considerably with respect to the various Federal actions related to the identified possible levels of future development in the Channel, includ¬ ing the one specific proposal for Federal approval action now pending. The alternative of "no action" as it relates to the various potential levels of future or further development is discussed below in the context of each such level. VIII-3 B. Operational Alternatives In the course of further development of oil and gas production in the Santa Barbara Channel, the receipt of a variety of proposed plans of development and individual proposed permitting actions on existing leases must be anticipated by the Geological Survey. In considering such proposals, it will be necessary for the Survey to consider all possible technologic or operational alternatives; for example, the installation of fixed-leg plat¬ forms versus seafloor completion systems; onshore treating and storage facilities versus offshore treating and storage facilities; crude oil transport by onshore pipeline versus marine barge or tanker transport; and many others. This environmental statement has discussed and examined all such major aspects of possible oil and gas operations. The Geologic Survey will fully examine and assess all proposals on a case-by-case basis to assure of the art in mind. The regulations of the Geological Survey and Department of the Interior provide for full analysis of potential environ¬ mental effects of proposed actions, and for the determination as to the need for preparation of further environmental impact statements under the pro¬ visions of the National Environmental Policy Act. C. Authorize Full Development on Existing Produc ing Leases 1. No Action Pursuant to implied covenants of both the OCS Lands Act and the existing lease agreements, the Secretary is obligated to respond to a legitimate application to conduct operations on a valid lease providing all terms and conditions thereunder have been met. His response may be approved as proposed, rejection on various legitimate grounds, approval in part and rejection in part, approval subject to such additional conditions and VIII-4 requirements as he may impose under the law, or deferral of decision based on proper grounds as described below. Accordingly, the alternative of "no action" by the Secretary is not tenable with respect to legitimate operations Which may be proposed in the future on leases existing at this writing "No action" would equate to maintaining the status quo, and the constraints and impacts would be the same as stated in below. 2. Defer Action The Secretary may defer final action on a proposal with proper grounds. These could include but not be limited to the need and time required for: a. Modification of the proposal to correct administrative or technologic deficiencies, b. re-design to reduce or avoid environmental impact c. acquisition of additional data to provide an improved basis for technical or environmental evaluation d. further evaluation of the proposal and/or alternatives The principal effect of deferring action on a proposal would be a comparatively short-term delay in the imposition of all related impacts of the proposal- both adverse and beneficial as previously described in section III of this Statement. 3 - Prevent Fu rther Development of Existing Producing Leases The only alternatives to allowing full development of existing producing leases are preventing such development or imposing additional conditions and restrictions on the operations. The several apparent means Of preventing full development are discussed below. If prevention of further and full development of producing leases were accomplished, substantial quantities of oil and gas, known to be present, VIII-5 LIBRARY U. OF l. URBAN A -CHAMPAiGH would be left in place and not recovered for use, because maximum potential recovery cannot be effected from existing production facilities. Following shut-down of present operations when economic and technologic limits of recovery are reached, there will be a redistribution of resources m response to conditions then existing within the reservoirs now being produced. Such redistribution could effectively reduce the quantities ultimately recoverable from the fields at some future time, should such an effort be made, compared to the quantities recoverable under present reservoi conditions and production. TO replace the resources foregone by this alternative course of action, other comparable quantities of energy would be required to meet national needs. The development of other energy sources, and the related impacts, are discussed on later pages a. Suspension of Operations The full development of existing producing leases could be delayed by suspension of operations. If such action were taken, there would be no additional increment of environmental impact on the Channel area and it would continue in its present condition, as further modified by natural processes and the continuation of all existing activity and uses. The authority of the Secretary of the Interior to suspend operations on existing leases has already been utilized and future suspensions for reason periods, with proper grounds, could be imposed. However, the Secretary doe: not possess authority under present circumstances to suspend operations to the extent that a d e facto cancellation of a lease would result. The matte has been sufficiently tested in the Federal Courts to clearly establish sue a course of action {de facto cancellation) as not viable, hence unworthy of VIII-6 further consideration as a reasonable alternative for the Secretary. b * M^_to_ Approve Future Applications for Developmental Refusal by the Secretary of the Interior to approve future applications to conduct various oil and gas activities on existing leases would have no additional increment of environmental impact on the Channel area, and it would continue m its present condition, as further modified by natural processes and the continuation of all existing activity and uses. The Secretary may reject and refuse to approve any individual proposed activity if it does not meet the prescriptions of applicable law and regulations under his authority, including the potential for environmental impact that could be reduced or avoided by adoption of a significantly different designed course of action by the lessee (operator). However, the Secretary does not possess authority under the present circumstances to refuse approval of such applications on the leases to the extent that a de facto cancellation of the leases would result. Should the Secretary nonetheless initiate such a course of action, litigation by one or more of the lessees would likely ensue, and the impacts would be similar to those described under the following sub¬ sections. As a reasonable alternative course of action by the Secretary this option is not sufficiently viable to warrant further analysis. c. Cancel the Leases The Secretary does not possess authority under the present circumstances to unilaterally cancel the leases except on the grounds defined therein (Appendix IV-1; Section 7 of the lease terms~"Remedies in case of default"}. The authority to cancel on other grounds would likely require Congressional authorization for such action as well as for the requisite funds for compensation of the lessees as may be necessary. Since withdrawal VIII-7 of support for proposed legislation in 1973, the Administration has not re-entered a request for such legislation and the Congress has not re¬ initiated or considered such action. The possibility of such actions is a matter for further consideration by the Administration and the Congress in the light of this environmental statement and myriad other relevant non- environmental concerns. Such legislative proposals have been initiated by the Administration and/or the Congress in recent years in several other in¬ stances, but such legislation has never reached the voting stage. Should such legislation be proposed, it could encompass all or some of the presently producing leases. Should such cancellation be legislated on other than the prescribed grounds, under present circumstances it would appear certain that litigation by one or more of the present lessees would follow. The ultimate effects would be several, and would relate directly to the litigatory actions taken, the decision thereof, and the time required for resolution. Present production could be interrupted temporarily or terminated completely, as could further exploration and full development of producing leases. To the extent that oil and gas from existing producing leases was curtailed or halted, alternative sources of energy would be required and these are discussed on later pages. The time required to replace the energy source foregone could range from scant to a number of years, depending on the specific altemative(s) selected and their state of production. The direct monetary cost of such litigation to all parties involved could rans from comparatively modest sums to billions of dollars. Indirect costs to producer, government, and consumer occasioned by contract abrogation, delay in replacement or substitution, displacement of employees, VIII-8 loss of governmental taxes and royalties, loss of employment income, etc would be substantial in the aggregate. Environmental effects on the Channel area could range from accelerated removal of all sources of physical and aesthetic impacts and significant adverse socio-economic impact resulting from termination of OCS activity, to increased adverse impacts on the physical environmental and aesthetic considerations, and altered socio-economic effects, by court-directed authorization of full development of existing producing leases. In the event that Congressional authorization to cancel all or some of the existing producing leases should issue, the possibility of court-directed authorizations for full enjoyment of lease-rights would presumably be remote. d. Federal Acquisition of the Lease s The outstanding leasehold interests could be acquired by the Secretary. The ability to acquire the leasehold interests is not granted under existing relevant statutes and would require Congressional authori¬ zation for such action as well as for the requisite funds for compensation of the lessees. To date the Administration has not requested such action of, and the Congress has not initiated or considered such legislation and the possibility thereof is thus moot. The major effects of such Congressional authorization would be quite similar to those of unilateral cancellation of the leases by the Secretary as previously discussed. 4. Allow Full Development of Selected Producing Areas The implementation of this alternative would require full VIII-9 LIBRARY U. OF L LfRBANA CiiAZiPAl fi ti development of selected areas of producing leaseholds, based upon a balancing of non-environmental concerns against the anticipated adverse environmental consequences. Further development would be allowed only on those producing leaseholds, or portions thereof, with the lowest anticipated adverse environmental consequences and the greatest net benefits to accrue therefrom. Adoption of this alternative would result in minimizing adverse effects through a reduction of area in which impacting activities could take place. This alternative constitutes a selective application of the alternative "Prevent Further Development of Existing Producing Leases," and the previous discussion pertaining to that alternative concerning possible litigation and the need for authorizing legislation is relevant to the consideration of thi: alternative. In addition, the development of leaseholds or parts thereof, selected solely on the basis of lowest potential adverse environmental effects could readily result in development that would not permit maximum recovery of oil or gas resources. This would be contrary to the enhance¬ ment of long-term productivity and the principles of conservation embodied in the legislation authorizing the leasing of these lands for the purposes described. 5 . Impose Additional Special Terms and Conditions to Furt her Mitigate Environmental Damage This alternative constitutes the only practical method by which the adverse environmental impact of oil and gas operations on existing leases could be further minimized when and if any future applications are offered for approval, and simultaneously maximize the conservation and full development of the resources. The terms and conditions of the existing producing leases and those attendant to issuance of subsequent permits and VIII-10 authorizations required under existing regulations, and the Federal supervision which will be imposed thereunder, are discussed in section IV under the heading "Mitigating Measures" and other portions of this statement. To the extent that environmental evaluation demonstrated the need, additional terms and conditions of approval would be written to further protect the environment on a case-by-case basis for each future application. D - Authorize Full Development on Existing Leases Not Presently Developed ' —— - 1. No Action Pursuant to implied covenants of both the OCS Lands Act and the existing lease agreements, the Secretary is obligated to respond to a legitimate application to conduct operations on a valid lease providing all terms and conditions thereunder have been met. His response may be approval as proposed, rejection on various legitimate grounds, approval in part and rejection in part, approval subject to such additional conditions and requirements as he may impose under the law, or deferral of decision, based on proper grounds, as described below. Accordingly, and as previously discussed, the alternative of "no action" by the Secretary is not tenable with respect to legitimate operations which may be proposed in the future on leases existing at this writing. "No action" would equate to maintaining the status quo, and the constraints and impacts would be the same as stated in "D.3.", below. 2. Defer Action The Secretary may defer final action on a proposal with proper grounds. These could include but not be limited to the need and time required for: a. Modification of the proposal to correct administrative or technologic deficiencies. VIII-11 b. re-design to reduce or avoid environmental impact c. acquisition of additional data to provide an improved basis for technical or environmental evaluation d. further evaluation of the proposal and/or alternatives The principal effect of deferring action on a proposal would be a comparatively short-term delay in the imposition of all related impacts of the proposal both adverse and beneficial, as previously described in section III of this statement. 3 . Prevent Further Development of Existing Leases The only alternatives to allowing full development of existing leases are preventing such development or imposing additional conditions and restrictions on the operations. The several apparent means of preventing full development are discussed below. If prevention of exploration and full development of existing but not pro¬ ducing leases were accomplished, substantial quantities of oil and gas, thought to be present, would be left in place and not recovered for use. To replace the resources foregone by this alternative course of action, other comparable quantities of energy would be required to meet national needs. The development of other energy sources, and the related impacts, are discussed on later pages. a. Suspension of Operations The exploration and full development of existing, but not producing, leases could be delayed by suspension of operations. If such action were taken, there would be no additional increment of environmental impact on the Channel area, and it would continue in its present condition, as further modifed by natural processes and the continuation of all existing activity and uses. VIII-12 The authority of the Secretary of the Interior to suspend operations on existing leases has already been utilized and future suspensions for reasonable periods, with proper grounds, could be imposed. However, the Secretary does not possess authority under present circumstances to suspend operations to the extent that a de facto cancellation of a lease would result. The Secretary may reject and refuse to approve any individual proposed activity if it does not meet the prescriptions of applicable law and regulations under his authority, including the potential for environ¬ mental impact that could be reduced or avoided by adoption of a significantly different designed course of action by the lessee (operator). b * Refuse to Approve Future Applications for Exp loration and/or Developmental Actions " Refusal by the Secretary of the Interior to approve future applications to conduct various oil and gas activities on existing leases would have no additional increment of environmental impact on the Channel area, and it would continue in its present condition, modified by the continuation of other existing activity and uses. The Secretary may reject and refuse to approve any individual proposed activity if it does not meet the prescriptions of applicable law and regulations under his authority, including the potential for environmental impact that could be reduced or avoided by adoption of a significantly different designed course of action by the lessee (operator). However, the Secretary does not possess authority under the present circumstances to refuse approval of such applications on the leases to the extent that a de facto cancellation of the leases would result. Should the Secretary nonetheless initiate such a course of action, litigation by one or more of the lessees would likely ensue and the impacts would be similar to those described under the following subsection. As a reasonable alternative course of action by the Secretary, this option is not sufficiently viable to warrant further analysis. c. Cancel the Leases The Secretary does not possess authority under the present circumstances to unilaterally cancel the leases except on the grounds defined VIII-13 therein (Appendix IV-lj Section 7 of the lease terms-"Remedies in case of default"). The authority to cancel on other grounds would likely require Congressional authorization for such action as well as for the requisite funds for compensation of the lessees as may be necessary. Since withdrawal of support for proposed legislation in 1973, the Administration has not re¬ entered a request for such legislation and the Congress has not re-initiated or considered such action. The possibility of such actions is a matter for further consideration by the Administration and the Congress in the light of this environmental statement and myriad other relevant non-environmental concerns. Such legislative proposals have been initiated by the Administra¬ tion and/or the Congress in recent years in several other instances, but sue! legislation has never reached the voting stage. Should such legislation be 6 developed proposed, it could encompass all or some of the existing but not/ leases. However, should such cancellation be legislated, under present circumstances it would appear certain that litigation by one or more of the present lessee: would follow. The ultimate effects would be several, and would relate directly to the litigatory actions taken, the decision thereof, and the time required for resolution. Exploration and potential production could be interrupted temporarily or terminated completely. To the extent that development and production of oil and gas from existing leases is possible and could be curtailed by lease cancellation, alternative sources of energy would be required and these are discussed on later pages. The time required to replace the energy source foregone could range from scant to a number of years, depending on the specific alternative(s) select* and their state of production. VIII-14 The direct monetary cost of such action to all parties involved could range from comparatively modest sums to many millions of dollars. Indirect costs to producer, government, and consumer occasioned by contract abrogation, delay in replacement or substitution, displacement of employees, loss of governmental taxes and royalties, loss of employment income, etc., would be substantial in the aggregate. Environmental effects on the Channel area could range from limiting of all sources of physical and aesthetic impacts to present production facilities and significant adverse socio-economic impact resulting from a leveling off of OCS activity, to increased adverse impacts on the physical environmental and aesthetic considerations and likely altered socio-economic effects by court-directed authorization of full development of existing leases. In the event that Congressional authorization to cancel all or some of the existing but undeveloped leases, the possibility of court-directed authori¬ zations for full enjoyment of lease-rights would presumably be remote. d - Federal Acquisition of the Leases The outstanding leasehold interests could be acquired by the Secretary. The ability to acquire the leasehold interests is not granted under existing relevant statutes and would require Congressional authori¬ zation for such action as well as for the requisite funds for compensation of the lessees. To date the Administration has not requested such action of, and the Congress has not initiated or considered such Channel-wide legislation, and the possibility thereof is conjectural. The major effects VIII-15 LIBRARY U. OF /. URBANA-CHAvAPAIBH. of such Congressional authorization would be quite similar to those of unilateral cancellation of the leases by the Secretary as previously dis cussed. 4 . Allow Exploration and Development of Selec ted Areas Now under Lease The implementation of this alternative would require exploration and full development of selected areas of existing leaseholds, based upon a balancing of non- environmental concerns against the anticipated adverse environmental consequences. Such activities would be allowed only on those leaseholds, or portions thereof, with the lowest anticipated adverse environ¬ mental consequences and the greatest net benefits to accrue therefrom. Adoption of this alternative would result in minimizing adverse effects through a reduction of area in which impacting activities could take place. This alternative constitutes a selective application of the alternative "Prevent Further Development of Existing Producing Leases," and the previous discussion pertaining to that alternative concerning possible litigation and the need for authorizing legislation is relevant to the consideration of thi: alternative. In addition, the development of leaseholds, or part thereof, selected solely on the basis of lowest potential adverse environmental effects could readily result in development that would not permit maximum recovery of oil or gas resources. This would be contrary to the enhancement of long-term productivity and the principles of conservation embodied m the legislation authorizing the leasing of these lands for the purposes describe 5. Impose Addition al Special Terms and Conditions to Further Mitigate Environmental Damage This alternative constitutes the only practical method by whic the adverse environmental impact of oil and gas operations on existing lease could be further minimized when and if any future applications are offered f VIII-16 approval, and simultaneously maximizing the conservation and full develop¬ ment of the resources. The terms and conditions of the existing leases and those attendant to issuance of subsequent permits and authorizations required under existing regulations, and the Federal supervision which will be imposed thereunder, are discussed in section IV under the heading "Mitigating Measures" and other portions of this statement. Environmental analyses would be made of all such future applications, and such analyses and possible subsequent environmental impact statements would consider and identify the need for additional conditions of approval that would further mitigate potential adverse impact of the action proposed. E * Lg. as e > Explore and Develop Presently Unleased Areas 1. No Action Under existing law, any action to offer additional OCS lands m the Channel for leasing is a matter of the Secretary's discretion. If no further offerings are made, the existing and established impacts of OCS oil and gas operations in the Channel would continue through the life of existing approved operations, and they would be increased incrementally as described herein to the extent that further exploration, development and production operations on now existing leases were proposed and approved. As of January 31, 1976, the Department of Interior Proposed OCS Planning Schedule of possible lease sales through Calendar 1978, does not include the Santa Barbara Channel. (Final Environmental Statement, General Lease Sale, Offshore Southern California, 8/75, p. 10, Vol. 4) VIII-17 LIBRARY U. OF I. URBANA-CHAMPAIBH. 2 . Hold Future Lease Sales of Presently Unrestricted Areas of the Channel PCS Should the Secretary determine that the potential oil and gas resources of presently unleased areas of the Santa Barbara Channel OCS are such that, on balance of all appropriate considerations, they may warrant leasing and development, the established preleasing and lease sale activities of the Department would be initiated. These activities are well documented in formal regulations (43 CFR 3300) and in previous Environmental Statements covering various lease sale activities (for example see Section I, DOI FES 5-68, Lease Sale No. 35, General Lease Sale Offshore Southern California, dated August, 1975). Briefly, the Departmental activities are as follows: 1. Study of available data by USGS and BLM resulting in delineation of general areas likely to be productive. 2. Issuance of a formal call for nominations from industry for specific tracts to be offered within the area of the proposed sale, and nominations of tracts or areas to be excluded from the sale by any interested party. Geophysical and/or Geological exploration by industry. VIII-18 3. Receipt of nominations, study, and tract selection. 4. Preparation and issuance of EIS on proposed lease sale by BLM. 5. Public Sale of leases of designated tracts by sealed bid. 6. Receipt and action by DOI on various applications for exploration and development by lessees. Excluding the unleased Federal Buffer Zone (34,000 acres), and the Federal -cological Preserve (21,000 acres), the present document has indicated (tables 1-1 and 1-2) that it is likely that most of the significant oil and gas resources in the Channel OCS, from known producing lorizons of the region, have already been found; that some exploration for leeper producing horizons is underway, demonstrating to a degree some .ndustry confidence that such sources may be found; and that future explora- :ion and technology will likely permit sale and utilization of tracts in ncreasingly deeper-water areas. If leased, explored, and developed, these ands may yield 40-150 million barrels of oil, and could require the following •dditional facilities and their proportional contribution to the impacts on he Channel: The maximum future additional activities are estimated to include table 1-1) : 1-3 Platforms 0-3 Submerged seafloor systems 5-20 Miles of pipeline to shore 0-1 Treating and Storage facilities onshore 15-20 Exploratory Wells 20-80 Development wells VIII-19 Specific potential impacts of each such facility has been identified previously in section III of this document. Should the Secretary decide to hold further lease sales, the established leasing procedure will include comprehensive environmental analysis and determination of the need for additional environmental impact statements prior to holding such sales. That process would also include the develop¬ ment and analysis of specific alternatives to each notential sale, much as those in the Department's environmental statement, FES-75-65, Lease Sale 35 off Southern California. 3 . The Federal Buffer Zone The Buffer Zone to the Federal Ecological Preserve was established on March 21, 1969 by the Secretary of the Interior (Plate 1). This area, contiguous to and seaward of the Federal Ecological Preserve, consists of several tracts (34,000 acres) for which no bids were received during the Santa Rarbara Channel leaseeSalCoOf^february^^l^S^Thi potential the buffer zone area is though . . Secretary as an adjunct These lands were ordered withheld from leasing by the Secretary Federal Ecological Preserve (34 F.R. 5655-5656, March 26, 1969). All persons were called upon to conduct their activities in the area in a manner that would help to protect and preserve the values of the area for scientific study, recreation, and other similar uses for the benefit and enjoyment of all. The Secretary has several apparent courses of future action with resnect to the Federal Buffer Zone: • Take No Action • Rescind the 1969 order and make the lands again available for leasing. to VI11- 20 a. No Action If no action were taken by the Secretary to evacuate the order establishing the Federal Buffer Zone, the Zone would continue in its present condition for the purposes already stated, as the Zone may be affected by all authored usage and by activities in other Channel areas. b - Re scin d the Order and Make the Lands Again Available for Teasing -- The authority of the Secretary to promulgate such an order for withdrawal specifically includes the authority to subsequently rescind or otherwise nullify such an order (Executive Order 10355, May 26, 1952, section 1 (a)). There presently is no proposal, either from the Department of the Interior, or any other party, to rescind the existing with¬ drawal and cancel the action establishing the Buffer Zone. However, should the Secretary ultimately determine that the potential oil and 8 as resources within the present Buffer Zone are such that, on balance of all appropriate considerations, they warrant leasing and development, the established preleasing and lease sale of the activities of the Department would be initiated as defined by regulations (43 CFP. 3300). The environ¬ mental impacts resulting from such an action would be related to the amount of exploration and development activity that subsequently occurred. Such activities could result in additional production of oil and gas and require additional oil and gas facilities such as platforms, pipelines ana onshore treating and storage facilities. VIII-21 LIBRARY ti- OF I. URBANA-CHATAPMStH. Specific potential impacts of each such facility has been identified previously in section III of this document. Such action would allow OCS oil and gas activities to proceed in closer proximity to the shoreline, thus increasing the chance of spilled oil to reach shore, should a spill occur. In addition to generating a proportional increment of physical and socioeconomic impacts, the opening of the Buffer Zone to leasing and subsequent exploration and possible development would almost certainly generate a significant adverse aesthetic impact on some segment of the residents and public, and substantial opposition and controversy locally. 4 . The Federal Ecological Preserve The Federal Ecological Preserve was established July 27, 1967 by the Secretary of the Interior prior to the 1968 Santa Barbara Channel OCS lease sale (Plate 1). This area of some 21,000 acres consists of lands of the OCS extending approximately 2 miles seaward of the Santa Barbara Oil Sanctuary, which was established by the California State Legislature in December 1955 (section 6871.2, California Public Resources Code). The Secretary's action (34 FR 5655-5656, March 26, 1969) withdrew these OCS lands from all forms of disposition, including mineral leasing, and reserved their use for scientific, recreational, and other similar uses as an ecological preserve. A part of this area is along a trend of existing producing horizons and has a high oil and gas resource potential. VIII-22 The present document (section I, Table 1-1 footnote] has indicated that the Federal Ecological Preserve possibly contains a significant proportion of potential resources of the unleased area yet undiscovered from known producing horizons in the Santa Barbara Channel OCS. The Secretary has several apparent courses of future action with respect to the Federal Ecological Preserve: • Take No Action • Rescind the 1969 Order and make these lands agai available for leasing. n a. N o Ac tion If no action were taken by the Secretary to evacuate the order establishing the Federal Ecological Preserve, the Preserve would continue in its present condition for the purposes already stated, as the Preserve may be affected by all authorized usage and by activities in other Channel areas. b. .Rescijid jthe_j^rdcr and Make the Lands — AvajJ,ahf or teasing ~ The authority of the Secretary to promulgate such an order for withdraws! specificaliy includes the authority to subsequently rescind or otherwise nullify such an order (Executive Order 10SSS, May 26, :9S2 ' S6Cti0n 1(a)h There Presently is no proposal, either from the Apartment of the Interior, or any other party, to rescind the existing with- 'rawal and canccl the action establishing th# Fct , eral Fcological however, should the Secretary ultimately determine that the potential oil and as resources within the nresent Federal Ecological Preserve are such that, ” balanCe ° f 311 a PPr°Pri«e considerations, they warrant leasing and VIII-23 LIBRARY U. OF /. 1/KBANA-CHAMPAIGM development, the established preleasing and lease sale of the activities of the Department would be initiated as defined by regulations (43 CFP. 3300). The environmental impacts resulting from such an action would be related to the amount of exploration and development activity that subsequently occurred. Such activities could result in an estimated 40 to 150 million barrels of oil and from 20 to 70 billion cu/ft of gas (table 1-2 footnote). Attendant facilities could include an estimated (table 1-1 footnote): 1-3 Platforms 0-1 Onshore facilities 0-3 Submerged production systems 5-20 Miles of pipeline to shore 5-20 Exploratory wells 20-80 Development wells Specific potential impacts of each such facility has been identified previously in section III of this document. Such action would allow OCS oil and gas activities to proceed in closer proximity to the shoreline, thus increasing the chance of spilled oil to reach shore, should a spill occur. In addition to generating a proportional increment of physical and socio-economic impacts, the opening of the Federal Ecological Preserve to leasing and subsequent exploration and possible development would almost certainly generate a significant adverse aesthetic impact on some segment of the residents and public and substantial opposition and controversy locally. A further potential series of impacts could subsequently result from the State allowing oil and gas operations to take place in the Santa Rarbara VIII-24 OH Sanctuary, in the interest of protecting potential State oil and pas resources in the Sanctuary from drainage by possible discoveries and subsequent development on the adjacent Federal lands. The activities in State waters that might ensue are not presently quantifiable with any degree of realism due to the lack of modern, or even old (pre-1955) exploratory data in the area. However, any such exploration and develop¬ ment would result in the same kinds of activity, with the same kinds and magnitudes of impact generally, inasmuch as State regulatory requirements are quite similar to those of the Federal agencies concerned. F. Establi shment of a Fed eral Energy Reserve Portions of the leased areas with discoveries, leased areas without discoveries and unleased areas of the Santa Barbara Channel OCR, including the Federal Ecological Preserve and Buffer Zone, were within the National Energy Reserve proposed by the Administration but not enacted into egislation by the 93rd Congress (Plate I). (s. 1951 and H. R. 7500.) This egislation is presented as appendix VIII-1 at the end of this section, lowever, most of the known discovery areas as of February 1976, are com- detely outside of the proposed National Energy Reserve. he 93rd Congress adjourned without taking action on any of the legislation reposed (pages ii-16-ii-l7; section I, pp.ll-14).As indicated in the Preface f this document the Administration withdrew support of all such proposed egislation and requested that no Congressional action be taken until the resent environmental statement had been prepared. No proposal for establish- mt ° f 3 '"' lational En ®rgy Reserve" in the Santa Barbara Cl.annel presently ists before Congress, and the possibility that Congress would itiate and pass such legislation is speculative at best. The history previous proposals and resulting litigation is summarized in VIII-25 LIBRARY li. DF L IfJRBANA-CHAMP AlfaH. section I, as noted above. The status of the 33 existing leases proposed for inclusion in the proposed Reserve, and on which all operations had been ordered susnended by the Secretary, as of duly 8, 1974, reverted to that of any other valid existing oil and gas lease on the Federal OCS, as a result of litigation entitled Gulf Oil Corporation, et al. v. Rogers, C. F, Morton, et al., Civil Number 71-1669-FCN as consolidated with Mobil Oil Corporation, et al. v. Rogers C. B. Morton, et al., Civil Number 73-1302-FCK, U.S.D.C., C. D. Calif., decided on May 8, 1974. That is, the 35 leases are no longer under valid suspension orders and are subject to exnloration and development under the terms of the contract (lease). Although the pronosed legislation was not passed, the status of the Federal Ecological Preserve and the Federal Buffer Zone remains unchanged, and their designation as remains in effect. The oroposed legislation included these two areas, but the Secretary has not revoked the establishing order of March 21, 1969. Unleased areas within the previously proposed National Energy Reserve (Plate I), excepting unleased areas within the Federal Buffer Zone and the Federal Ecological Preserve, are technically as available for leasing as any other tracts on the Channel OCS. Existing leases within the previously proposed National Energy Reserve encompassing known discoveries (Plate I) are subject to further exploration and development, subject only to the same requirements as any other existing valid lease. With respect to these lands, within the previously proposed National Energy Reserve, the Secretary has several possible courses of action: • Take no further action • Resubmit proposed legislation to the VI11- 26 Congress, unchanged. • Submit a new proposal for establishment of a National Energy Reserve but with a new mix and/or selection of lands to be included. 1. No Action There being no existing legal requirement for the same, the Secretary may, at his discretion, take no further formal action to initiate establishment of a "National Energy Reserve" on the Santa Barbara Channel OCS. Should he elect to take no further action, the following activities and related environmental impacts could ensue: • Applications for exploration of all existing leases in the National Energy Reserve area, must be anticipated, some of which may result in discoveries of oil and gas, and subsequent applications for development and production facilities. Such facility requirements could include part of the following estimates for all leased areas without discoveries (Tables 1-1, 1-2) 1-4 Platforms 0-1 Onshore treating and storage facility 0-4 Submerged production facilities 0-1 Pipelines to shore (5 to 30 miles) 15-60 Exploratory Wells 20-100 Development Wells »eal a w 1 >h ty r ai ] d reserve estinatcs presented here are those for the leased Pita! P n h U . dlSC ° Ver i eS (taMeS I ' 1 an< ’ ^ l'°"'ever, a portion of the Reserve. lscover y area is within the formerly proposed National Energy VIII-27 LIBRARY U. OF 1. URBAN A - CHAMPM S M Potential production could be all or part of an estimated 40-200 million barrels of oil and 20-100 billion cu/ft natural gas. Of the 36 leased areas of the OCS, without discoveries, and on which no exploratory wells have been • in the* previously proposed National Energy drilled, 22 leases were included m tne previously i . Reserve. (Fig* l - 2 an< ^ Elate I). • The single valid lease with an existing discovery (Pitas Point Unit, Plate I) will require additional Exploration before development and production can be contemplated. This potential field could involve two platforms, supporting submerged production facilities. • ^i f i 1 1 nos * (ind treating and storage facility. • The several unleased tracts of the previously proposed National Energy Reserve are available Tor leasing under this alternative (Plate I). To the extent that they constitute part of the unleased area considered as viable leasing area (Tables 1-1 and 1-2), a proportional part of the estimated facilities which could be required for exploration and development, and related potential impacts, must be considered likely to follow if the areas are leased. 2. R esubmit Proposed Legislation, Unchanged^ to the Co ngress for Consideration Should the Secretary decide to resubmit his proposed legislation (see Appendix VIII-1 at the end of this section), in view of recent court decisions it is assumed that simultaneous action to halt all operations on the 35 existing leases would not take place. Subsequent to VIII -28 those decisions in 1974, the Geological Survey has te™inated the suspension of operations and approved the initial plan of operations for exploration drilling on the Oak Ridge Unit which was included in the 35 leases formerly proposed for inclusion in a National Energy Reserve. The initial plan includes the drilling of two exploratory wells to evaluate the geologic structure in the Unit area. The Geological Survey has approved an application to drill and the Unit Operator plans to cogence drilling in March 1976. Passage of the legislation (if resubmitted) would have the following environmental effects; • It would substantially reduce the potential for impacts of OCS oil and gas operations to the existing environmental and recreational qualities of a large segment of the Channel and the four Channel Islands. Such legislation would offer further protection of the Santa Barbara coastal area from spills occurring on the Channel OCS, by substantially enlarging the area in which Federal oil and gas development is precluded. • It would open Naval Petroleum Reserve No. 4, on the Arctic North Slope of Alaska, to exploration under Federal auspices, with all attendant environmental impacts in a totally different but possibly more fragile environment than the Channel OCS. VIII-29 LIBRARY IJ. DF /. URBAN A -CffAAf PA16H . It would preclude develop.»ent and utilization o£ a known discovery of oil and gas (the Pitas Point Unit), and it would preclude discovery, development, and utilization of potential resources in a significant part of the Channel OCS. Alternative sources of energy would have be found and developed, with attendant environmental impacts which may be greater or lesser than those anticipate. in further Channel development. . It would preclude the environmental impacts which could result from allowing exploration, development and production activities in the Channel area. Should the Congress not pass the legislation, the various tracts of area one, «„« to ,0,1, P„„« .«*“• on „d „« .o.lvltlo, oo .0... «„o„. - ,*'•>*<■ ”* d not be repeated here. The Secretary could propose legislation for establishme a National Energy Reserve in the Channel which encompassed a different selection of tracts from those proposed to the 93rd Congress. The basis *»> a new selection would flow from a different basic rationale for proposing such a Reserve; it could range from reasons much more specific than the original, to something much more general. The possible combinations of tracts to be included could conceivably range from a single tract, to only the Federal Ecological Preserve, to the entire OCS of the Channel. VIII-30 The legal and operational status of various segments of the Channel OCS, their general potential for oil and gas development, the kinds and estimated amounts of impacting activities involved in each such level of development, and the magnitude of environmental impacts of each such activity, have been previously identified in this document. The possible combinations of rationale and tract selection that might be encompassed in a new Energy leserve in the Channel are too numerous and speculative to warrant further rttempt at specificity here as to possible environmental consequences of each. ■he Secretary's decision in the matter of a National Energy Reserve in the ;anta Barbara Channel is now speculative in any event. His decisions in the uture will involve a balancing of the environmental consequences as escribed herein as well as a number of other factors including, but not imited to, national energy need and security, balance of trade, national nergy self-sufficiency, and national and local economy. VIII-31 LIBRARY U. OF 1. UR BAN A CiiAMPAl £ H G. Alternat ive Sources of E ne ggy_ ' should”further oil and gas development of the Santa Barbara Channel be prevented in whole or in part, a notential source of domestic energy would be lost and according to the National Energy Policy Act, alternative energy sources should be considered. The extent of alternative sources of energy which would be needed to replace the potential sources from the Santa Barbara Channel is dependent upon both the type of administrative decision and the results of exploration and development, if permitted. Complete information can be gained only by these operation In light of the present energy situation and the United States ciency goals, it is questionable whether substitution of any one energy alternative is a viable alternative to any environmentally acceptable opera¬ tion that would result in increased energy from a domestic source. In the President's message to the Congress transmitting the budget for Fiscal Year 1975 February 4, 1974), he stated: "The 1975 budaet reflects a comprehensive national energy polieu to deal with current shortages and provides funds to initiate the Federal position of Project Independence, an accelerated private and governmental effort to reestablish our capability for self-sufficiency in energy by 1980." VIII-32 In order to attain this goal, usage of all environmentally acceptable domestically-produced energy forms is required. In compliance with the National Environmental Policy Act of 1969, and to insure complete¬ ness of this statement, energy alternatives have been both incorporated by reference as described below and also discussed in the text. A full consideration of the impact which would result from development of alternative sources or a reduction of energy consumption is found in the United States Department of the Interior's "Energy Alternatives and Their Related Impacts." All of the discussion contained therein concerning the environmental impact of the development of alternative sources which would help meet national energy demands is specifically incorporated herein by reference. Copies of that document may be obtained from the Assistant Director of Minerals Management, Bureau of Land Management, 18th and C Streets, N.W., Washington, D. C. 20240. Reading copies are available in the Bureau of Land Management Office, 7663 Federal Building, 300 North Los Angeles Street, Los Angeles, California 30012. An expanded version is in preparation by the University of Oklahoma under contract from the Council on Environmental Quality with funding sup¬ port by the Bureau of Land Management (BLM), Environmental Protection Agency, Federal Power Commission, and Federal Energy Administration. Its title will 3 * " Methodol °gy and Documentation for Consistent Analysis of Energy Alter¬ atives for Environmental Impact Statements." It is slated for completion Ln spring 1975. 'ho U. S. Department of Interior's "Energy Alternatives and Their Related "•Pacts" is a complete detailed study of long-term optional energy sources nd of energy conservation. As a supplement to this incorporated by reference VIII-53 LIBRARY li. DF 1. URBANA-CUAMPM&H. alternative study, a brief discussion appear to have the most potential in of the optional energy sources that the relatively near future is included within the text of this statement. Modifications have been made to render the discussion Santa Barbara Channel OCS and to the potential levels the Channel area. Also, a nuclear energy alternative and minor editorial and technical changes were made. applicable to the of development within section has been added Table VIII-1 following provides units and energy source conversions for the various potential oil and gas development levels considered for the Channel. Definitions of the various levels of development appear in table 1-2. The following is a list of energy sources or actions which might be employed as substitutes to OCS oil and gas should further Santa Barbara Channel potential development be. prevented or severely limited: 1. Energy conservation 2. Conventional oil and gas supplies 3. Coal 4. Synthetic sources of oil and gas 5. Hydroelectric power 6 . Nuclear power 7. Solar energy 8 . Energy imports 9. Other energy sources 10. Combination of alternatives Each of the items is discussed briefly in the pages that follow VI11-34 Oil equivalents in millions of barrels oo 00 LO • LO • 300 27 327 o o to 116 vO rH 3- 200 • r- rH • t"~ i-H CNJ 150 (N rH CN 43 i-H r-H rH to to to to to to to to to to to to v O vO • vO • 200 18 218 780 70 o in co 40 • to • to 3- 40 to to n- •H O r-H 0 E P o G P 0 4-1 rH G G > o •H «H 3 P cr o o •rH *H 3 P cr o 0 3 ”3 rH O •H P O Oh G P o H •rH o rH 6 P o c ,p 0) 4-1 rH G G > O • rH »H 3 P cr o O •H -H 3 P cr o CD 3 'G rH o •H p O Oh G p o H •H O rH CD CD O G G G i-H Rj OhX o •H *H 3 P cr o 0 3 "d rH O •H p O Oh CO G 00 rH 0 0 O G Rj G i-H G OhX 0 O P 0 O X p p G p o H 0 0 O G rt g r-H G OhX 0 U P 0 O X p p f —s X* v—/ /-V G '_/ ✓—\ V-/ /—\ /H v*—' v—✓ Csl to i-H 0 > rH 0 i> X rH 0 % 0 X X co G oo r-H 0 0 a G G G rH G OhX 0 u ^ 0 O X p p to E cn g cn E P o P O P o G P G P G P 0 4h 0 4h 0 4h rH G G rH G G rH G G > o •rH *iH > o • H *H > o • H *H 3 P 3 P 3 P O' O O' o 0 3 0 3 0 3 TJ rH O rn'B *3 i-H O • H p •H P •H p O Gh O Gh O Gh G P O E- CN VIII-36 to to CM o o o o o LO o LO vO * r-H p—4 00 •> r-H to r* c- vO o o o o o X X X X X CM CM tO CtJ to to to cj to E ti ° G >h O 4m to T3 o T3 to o to cj cj f-l C3 CJ3 P-. cj a o r —\ /—\ Cj XI Cj V_' '_ ' w r-H to •H Cj O bO r—( cH i—t r-H cj o a> a) a> Cj X o c O c X o cj C cj G o f- i-h cj <-* cj H ax ax a> o O u fn O X o x X X X X to E to E to s +-> o X o X o C $h G fn G U O 4m 4) 4m O 4m r-H r-H r-H cj C cj G cj C > o > O > O •H -H •H -H •H *H 3 X 3 x 3 X a 4 u cr o cr u a> p a> 3 « 3 T3 to o to 13 X> to o cj U cj *m cj Jh u a a a CJ Oi /—\ /—N r-\ X ' _ t a5 V_/ v—✓ CM to rH r-H 0 ) a> LO cr> • • • • • <3 O o o r-H to rH to o • • • • 03 (N| r-H of to r>- of f—i of LO o O O o p P P p vO t-- rH oo • o • 43 • to • Cl r-H LO CM t"- CM CM o o • • O Of tO o to CM o o P P o o • • O 43 CM to CM ,h •H o -h c a, g < u X h u o p p x p G P E C O P p -h 4h 03 > G •H o 3 -H cr +j p o 3 -H T3 03 O O P U Cl, 03 to P > p to ot3 tO P rH o p G c -H G O-i G 4) x o u o p P X P to p E G O <1) P -h 4-1 ct3 > G •H O G p o E- P rH o p G G rH G Oi G P x O U O P P X P to p E G O 0) p rH 4-1 Ct3 > G o P X to G to G O p p rH 4-1 G > G 3 *H 3 -H • 1 3 *H cr p cr p cr +j P o P G I t r- P G rH rH G P > G •H 03 P 03 3 f-H u c to G P P G 4h O G P O •H O to ct3 G O P P rH 4 h G > G •H o 3 -H cr p G •H O S-‘ H cr p p o 3 rH T3 G O O p U O, to P 3 O -G to p p G •H o tu o G •H 3 G cr p •H G rH G P O G •H P P rH P G O > P •H rH 3 w cr p /—\ rH G V - ' G O •H rH P P rH O p P > rH p w X E o G O •H P O 3 03 O B. to (U co 3 03 G CN • cn • 00 • LO • CM rH r—i to \0 to CM rH 00 LO o o o o • • • • CD r^. CN r- Ht vO f-H LO O) •» rH o o o o p p p p pH ti- iH • • • • r- t"- CN O) r- o> LO LO 00 ccJ c u CCJ X 0) 0) •H CO X cj DO C/> P P u 3 P C _ CD E L0 p •H g yj o 3 P p P S- P 3 1 p O o O cr p ip *3 CD 4h cp 0) cp *3 p rH P p CD cd r-H rH rH C CD Q Cti ctf ccS o •rH p p

P* v— / ' _ / W pH v—' /^N •H /-\ •H • H ccS J v _✓ v —/ '—/ CD CD O ccS CD CN to VI11- 40 (b) Electrical equivalents to replace gas production from the Channel v £5 CN vO • • • • 4-> 4 -» O i-H • • • • to CM o rf r\i to 00 vO oo vO • • • • to oo 00 o 1—1 1—4 «—( i-H o o o o 4-> ■M ■m 4-1 o i— i • • • • ctf 0) o3 O o o •H G a> w rH a> (/) *H •H E V) u 3 4-> 3 O 3 4-> Eh 'TO G O a> rH CP Ih O <4H TJ G O 0) rH o *4—1 <2 r-t G fl) a» rH rH »H Rj O O *H Eh Eh 03 4-> Rj 4_> <2 o <4H •H 4-) Eh O +-> 3 <2 o <4H O H O E- / — \ U XI /— \ / — \ •H a> o •H •H •rH 1-4 f-t •H •rH v_ / v_y W 0h N—/ •rH VIII-41 LIBRARY U. OF /. UHBAtiA-CHAulPMStl o LO 00 • l n • cr. cn to CM 00 r-H to r-H CN r-H to to to o> 00 • • (N r- (NI o ?-h r-H 03 o 00 o OC • • • ' LO (N LO cr Tl- 00 to o tO 00 o * * rH U 00 LO r- o vj O o 4-1 O 4-1

o \ •H • H •—t P • H V_✓ '_/ tu £l, v—' o o c3 oo vO VI11-42 o o o o o • • • • • o o X LO X X 00 LO to rj- O) LO to o * #1 X to O o o o o P +-> P p p O o o o o • • • • • O o 00 Tj- 00 co cn rr i-H CN CO to to CN CN * to CN 'tt rH V) •H rt 0 bo 0 G 0 c U O o o rt •H rt •H P P P ip i-H p G< O rt Oh 0 o3 0 c P 0 G P h G o P G 0 rt G rt G o x p •H tp X O 0 > P •H tp T) O CL> O tp 3 G i-H 3 c rH O' G 0 0 O P o o o LO • • • • LO oo 00 to 00 o 00 to LO •rt- o o o o p p p p o o o • • • • LO rH o CM i-H X fp rH •s CN G O •H ip to P •H rt rt O bo P V 0 G 0 G o O o o 3 •rH rt bO i-H ip P rp Oh 0 rt Oh i—t 0 G P 0 rt P G a) p o 03 G rp •H O X 0 o a> P P U bO P c P c O to 4) ip to o3 0 P X rt P X ip G P a G U 0 CD p o > P tp •H tp T3 0 •H tp -3 3 G Ip 3 3 rH cr c 0 0 cr c 0 03 0 ) o 0 o P •rt P p •H p O E P O o E P o E-> 3 y «P tp 3 O tp •H 3 •H 3 G n3 ! -1 c xi 0} O f —\ •H rt O P P •H •H P P •H 33 Oh v_ ' '—H 33 Oh V-/ r —\ •H t —\ ✓—\ •H v_/ rt X V_ / tO H 0 > 0 — 1 VIII-43 to LO to • • • ■rt- LO CN LO t"- X o Hi Ip X o o o p p p CT> CT> • • • o CN rH rH ip tn CN rH (a) Uranium equivalents to replace oil in CM CM 01 in CM vO o o O p p P Ol Ol • • • o in CM rH rH CM m f— l to to to to to to o o cn 01 01 • • Ol • • in vO CM • to rj- CM o r- o 1-0 CT1 to CM •V to to in •» •V m m. to in to 1/1 rt P X o e u 01 • H o l/l P <—• 6 3 P a o O > ,p T3 CD •H CP c rH 3 CD o cr c 0 o P •H o o 6 P «P 4-1 3 o •H 3 3 *3 r —v • H ccj O •H •rH P P v_' v—^ P< 0 0 V) 0 CD CD VHI-44 p> CQ 4> 4) X *4-4 3 4-> CQ O © CM io oo y O t''- *r4 » . fi H H 3 II II o Ci o 44 o O 3 4-> *44 to 3 B O C< •p4 o CO *44 to •p4 X *44 bO >4 o\° 4) LO 3 • 4) CO Ci 3 V X 3 4-» o o (X 3 *4-4 *8 0) tO 4-* 3 3 X U 3 C O CQ -p4 to to to pH 3 cr> Ci 4) pH bC O 4) > •H —< > 4) O pH 3 i-4 3 X O pH Cl o pH y 3 CM 3 Cl 44 • pH •H u 3 pH 0j 44 3 3 o 3 X II «H 4) *44 44 44 O pH 4) o 1 V Cl cc 1 o 44 3 O co : *0 *0 © + 3 3 ph a bo bo XvO Kh H 3 oo 4) . to L0 3 o rt 3 cni ph Jh X 3 to C 0 p u PS *44 H 0 II c c 3 4J 4-» un 3 3 3 II CM *4-1 4) X •H 4) £ ^ PIP x Cl O 3 4J c CD CD •H - 3 O X +-» -H O CQ *4-1 •H *4-4 f-4 « C *1 fj » X > ~ p4 3 J 44 *4-1 PH || 0 O -H O pH 4> 44 CD O O *44 O o o o u *44 *44 pH *44 u y 4) o ^ h c 3 3 CD o y o x +j ii X 4-» bo Ci 3 •H 3 '-•OX W x 4-> *+4 p a O 4-> *H CD U 3 J P COO 3 pH O O *H pH CL, 4* c 4) bO 3 •p4 +4 cD 4) X to cD b0 TD 3 al •H o tO cD X o 3 tO CO CD bO *3 3 cD •H O * 4 H O 4) CO 3 *3 3 4) < 4 H O X O o\o 3 O 4) oo •H U * 4 H •p4 O *44 o\° O TJ- 0) X o +j XJ bO •r4 y •H C. 44 u 4> pH 4> o\° CO CO 4) X o 44 T3 O B 3 to CO 3 to 3 5 3 O 3 is s bo X 44 •H U •p4 C. 44 O -a *44 Cl pH r-i 4) to pH 1 > 3 to o *—1 3 O o 3 O pH pH *44 c o\° LO 44 *44 *44 X X 3 O o 3 44 3 3 pH X X Cl, o o O 3 3 c 44 O 3 4) 4) U T3 03 •H O •r4 o 4> 4) C •H •H *44 *0 3 *44 *44 4) 3 *44 *44 OS 03 W Ui si CO Tf LO VIII-45 LIBRARY U. Of /. fi»»M£4.CfiMa»/UfiM 1. 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 alone can reduce energy demand growth by. 0.7 to 1.2 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 comnercial sectors of the economy are often character¬ ized as inefficient energy consumers. In the next 30 years, their share of total energy use is expected to increase from 32 to 39 percent in the State of California alone. Inadequate insulation, inefficient heating and coolin; systems, poorly designed appliances, and excessive lighting are often no¬ ticed 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 anc minimum thermal standards for new homes and offices. Excessive consumption is also evident in the industrial sector where energ; 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 convnonplace. Estimated energy savings of be¬ tween 10 and 30 percent may be available in this sector of the eco y Transportation of people and goods accounts for approximately 25 percent o nationwide energy use and nearly 35 percent in California. Energy ineffi¬ ciency in the transportation sector varies directly with automobile usage. VIII-46 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 eduction, lower speed limits, rate and service improvements on public transit and rail freight transit, energy savings of 15-25 percent might be possible. For example, the Cali¬ fornia Department of Transportation has estimated that a three percent reduction in fuel consumption in 1974 resulted from the lower speed limit on California highways. Other policies to encourage fuel conservation in transportation could in¬ clude standards for more efficient new autos and incentives to reduce miles traveled. An important new development in the fuel economy area could be the modification of the standard internal combustion engine. Although such an engine is now in the advanced stages of development, further study by automotive engineers, industry, and concerned Federal agencies is necessary before an acceptable engine may be approved. Significant energy savings are clearly possible through accelerated conser¬ vation efforts. The Project Independence Report estimates that conservation alone could result in a 2.2 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. California Coastal Zone Conservation Commission Energy Conservation Policy The California Coastal Zone Commission has recommended a number of energy conservation policies in its preliminary Coastal Plan. They are presented below by policy number. VIII-47 LIBRARY U. Ci /_ URBANA-CHASAPMSM. nt t l i tv Rates to Enc ourage Conservation . Utility rates 121. Restructure Utilit y Kates iu -£- Th. California Public U.i.l.U. «—!"■ «*«> , prtricitv The State Energy and transmission of a customer’s gas and electric y . 4 -ucv rpnr in the revisions as soon as it is able Commission should assist the CPUC m the rev do so. (E-p2) a. 122 . Reduce_^nergy__Consum£tion__Statewide_and_in_Coastal__Develo£ments_. Non-essential consumption of energy should be reduced statewide, thereby reducing the adverse environmental impact of energy supply facilities o coastal zone. (E-p4) cmtowide Energy r ™«»™t.ion Measures Recommended. The energy con¬ servation standards contained in Policies 123 through 126 below clearly should be applied statewide and are therefore recommended to the State Energy Resources Conservation and Development Commission ("State Energy Commission”) for its consideration in developing state¬ wide energy conservation measures in fulfillment of its legislative tti o n d O f P b . coastal Energy Conservation Stan dards May Also be Applied. If, for any reason, a significant energy conservation program is not m effect statewide by January 1, 1977, then the standards set forth in Policies 123 through 126 below, or any improvement upon them recom¬ mended or enacted by the Energy Commission, shall be applied by the coastal agency to all development proposed within the agency's juris¬ diction. Until that time, the application of such standards should b. required to the maximum extent feasible in any development as a VIII-48 ribution to energy efficiency and resource conservation. (E-p4) 123< ^ duce Consumption of Electricity for Unnecessary light¬ ing in new or substantially remodeled residential, commercial, institutional or industrial development shall be reduced through State Energy Commission action (or by the coastal agency within its jurisdiction-see Policy 122) in the following ways. (E-p5) a- jjggniate Lighting Levels. Lighting shall not exceed 2.3 watts (2.5 volt-amperes) per square foot except in instances where higher levels are shown to be necessary for high visual acuity tasks and public health and safety. b ' ~- ° W Only Efficient Lamps and Luminaries . Only efficient lamps and luminaries, as defined in the proposed Standard 90-F of the American Society of Heating, Ventilating, Refrigeration, and Air Conditioning Engineers (ASHRAE), shall be allowed. C ’ — V - lde f ° r Selective On-Off L ight Switching . In large office buildings, light switches shall be provided so that portions of the building, including portions of each floor, receiving adequate natural light, or not in use, can be switched off selectively. d - UsjL HPS Street Lighting New street and highway lighting lumin¬ aries shall be of the high pressure sodium (HPS) type, or an approved alternative type equal in energy efficiency, unless there are environ¬ mental, aesthetic, or public safety reasons for utilizing a different type of light source. (E-pS) Consideration should be given to establishment of a capital improvement fund, by passage of a State bond issue or by other appropriate State funding, for the conversion VIII-49 LIBRAR Y U. C. 1. UREA [4A -Ci iAMPAl £M f. of existing State, county, and municipal incandescent or mercury vapor type street and highway lighting to high pressure sodium (HPS) type or equivalent. Conversion should take place as quickly as possible given the financial resources available and manufacturing and installation.capacity. Funds expended could be repaid from energy cost savings resulting from the conversion. (E- P 9d) Other appropriate energy-conserving devices (e.g., astronomical clocks that eliminate lighting during daylight) and designs shall also be incorpc rated in all new public lighting systems. (E-pS) Ran ,.i ghted Advertising or Omamenta ljigis- Pr0 P 0Sed new advertisin or ornamental signs, whether on business sites or off, shall not be electrically lighted, except that businesses shall be allowed on-site lighted identification signs containing only the name, address, and major project or service of the business, and these signs shall be illuminated during darkness only when the business is open to the public. (Incorporation of such standards in local sign ordmanc as prescribed in Policy 58, should be considered.) Minimize Building and Facade Lighting . Building and facade lighting exclusive of signs, shall be no greater than 1,000 watts or 2 percen of the total interior lighting load of the building, whichever is greater. On-site signs and facade lighting shall be included in the project’s energy budget. (E-p5) L 24 . Reduce Consumption of Electricity for H eating and Cooli ng.. Unnecessary use of electricity for heating, cooling, and ventilating in n< or substantially remodeled residential, commercial, institutional, or industrial developments shall be reduced through State Energy Commission VII1-50 c. action (or by the coastal agency within its jurisdiction-see Policy 122) in the following ways. (E-p6) Restrict Electric Resistance Heating . No electric resistance heating (water or space) shall be allowed unless: (1) an effective solar delivery system and/or natural gas service are not available or ade¬ quate for meeting energy requirements; (2) electrical heating is needed for medical, health, or public safety reasons; (3) some other unusually high requirement for clean heat exists; or (4) a back-up system for solar heating and cooling systems is required. b ' Build to Reduce Air Co ndi tioning Needs . Air conditioning needs shall be reduced by: ( 1 ) incorporating either mature planting, exterior architectural shading projections, or reflecting and/or insulating glass or exterior solar screens to shade or protect windows receiving direct sunlight in warm climates; (2) incorporating operable sash and vents in all exterior rooms for which ventilation is required by the local building code, and making such sash and vents weather-tight by use of weather-stripping; and (3) having variable thermostats for areas with different air conditioning requirements. Use Best Available Ai r C onditioning Technology . An air conditioning design using the best practical available technology with low-level or no electricity consumption shall be required. New conventional compressive refrigeration air conditioning shall be permitted only if an applicant can demonstrate that the life cycle costs of the conven¬ tional system are substantially less than the lowest cost alternative system available. The demonstration shall include a comparison of the conventional and potential alternative schemes, including electric VIII-51 LIBRARY U. OF l. UP.BAUA-CtiA^mm energy consumption, cooling output, and life cycle cost, together with outline specifications and sketch plans to scale for conventional and alternative systems. The comparison shall be sub¬ mitted and signed by a California registered engineer. (Alternatives may include cooling systems based on evaporative cooling, solar cool¬ ing, nocturnal radiation, absorption refrigeration, heat pumps, rock bed regenerators, and coolness storage, among others.) (E-p6) (See the section on Alternative Energy Sources.) 125. Reduce Wasteful Consumption of Natu ra l Gas in Pilot Lights and Ga s Flames . Wasteful use of natural gas in new or substantially remodeled residential, commercial, institutional, or industrial developments shall be reduced through State Energy Commission action (or by the coastal agency within its jurisdiction-see Policy 122) in the following ways. (E-p7) a. Use Intermittent Electrical Igni tion Systems or Other Means. Intermittent electric ignition systems or other acceptable means shall be used in lieu of gas pilot lights in all residential, commercial, or industrial equipment (with the exception of water heater gas pilots) installed in proposed new construction or additions to exist¬ ing structures unless it can be conclusively demonstrated that the gas pilot device: (1) has a substantially lower life cycle cost than an electric ignition or other alternative system, computed at prime interest rates; (2) that for particular equipment, the gas pilot light is more energy efficient than available alternatives; or (3) that public health or safety necessitates the use of pilots. b. Ban Open Gas Flames. Open gas flames for advertising, promotional, or decorative purposes shall not be allowed in proposed new industria VIII-52 commercial, or residential construction or additions. This applies to both exterior and interior installations. (E-p7) 126 ' f0r New Developments. An energy budget code should be formulated, to be applied statewide by the Energy Commission to substantially remodeled residential, commercial, institutional, and industrial developments. (E-p 8 ) 3 - t£° P° sed Energy Budget Code Criteria . The code should set re¬ quired energy budget performance levels for a range of building types, sizes, occupancies, projected levels of intensity of use, and locations. The energy budget shall state the energy inputs and outputs of the proposed building or other development in BTU's per cubic foot or in watts per square foot; and shall give the extreme mean heat loss/gain of all buildings in peak heating and cooling seasons. All proposals for enclosed developments shall include outline specifications for the following: microclimate description of the building site; microclimate modifiers such as planting; total building exterior cladding material; building insulation; building thermal inertia and energy storage capa¬ bility; major building energy using and controlling equipment such as for lighting, heating, ventilating, and air conditioning. b. Pro jects Requiring Energy Bu dget Analysis . An energy budget, including outline specifications, shall be required for residential developments of four or more dwelling units, or commercial or industrial projects of 5,000 square feet of floor area or more. It shall be signed by a California registered engineer or certi¬ fied architect. Proposed light commercial structures of less VIII -53 LIBRAR Y U. C. L UREA14 A - CHAMPM fiM than 2,700 square feet may be exempted from the specific standards without submitting an energy system analysis, provided a California registered engineer or certified architect states in writing that the specific proposed design would be expected to meet or have a lower annual energy consumption than the minimum established per¬ formance for the project type. Consideration should also be given to developing an exemption procedure for single family homes that would permit administration of energy conservation measures throug local building codes without necessitating undue cost in the prep- aration of energy budgets. c. Projects Meetinp Budget Stan dard Exempt from Specification Requirements A proposed building or development that meets the required energy budget performance level set in the energy budget code, as shown through an energy system analysis, shall be exempt from snecification criteria as those described in Policies 123 through 125. (E-p8) d . Research and Training Needed . To facilitate development and implementation of an energy budget code statewide, detailed re search should be undertaken to define energy code standards, and a State-financed program of in-service training for building in¬ spectors to administer the energy budget should be instituted. (E-p9) e. Interim Budget Code for Coastal Dev elopments. If the Energy Commission has not made substantial progress toward development of an energy budget code by January 1, 1977, the coastal agency shall consider adoption of an interim budget code, to be applied VI11-54 to all development proposed within the agency's jurisdiction. Such an interim code might be submitted by a responsible profes¬ sional organization to the coastal agency for public hearing and possible adoption. If adopted, the energy budget code would be implemented through the coastal permit process in the same manner set forth above. Until January 1, 1977 , the development and ap¬ plication of energy budgets should be encouraged as a contribution to energy efficiency and resource conservation. (E-p8) 127, l ament Other Energy C onservation Measures Statewide . The State Energy Commission and the State Legislature should, as part of a comprehen¬ sive statewide energy conservation program, implement certain other conser- vation measures statewide, as follows: a ‘ I ^ . Heavier, Less-Effic ient Autos . Tax legislation should be enacted that encourages the use of lighter automobiles with smaller engines and increased energy efficiencies. (E-p9b) b " Dlscou rage Ineffi ci ent Appliances . Legislation should be enacted requiring that (1) all appliances sold in California meet speci¬ fied energy efficiency standards, and (2) all appliances be clearly labeled with energy efficiency or energy consumption information. (E-p9c) C ‘ *EP TOved En P . r gy Us e St andards of Existing Buildings . A long-range phased program for improving the energy use standards of existing buildings in California, including replacing energy inefficient equipment, should be devised and implemented. Special loans and/or tax incentives should be considered to assist in upgrading insula¬ tion, and incorporating low or non-fuel-using technologies that VIII -55 involve higher capital costs. (E-p9a) E nvironmental Impacts The environmental impacts o£ a vigorous energy conservation program will be primarily beneficial in terms of fuel/energy consumed. The exact nature and magnitude of these impacts will depend on whether there is a net reduction in energy use or whether the reduction is accomplished through technological change and substitutions. For the former, the net impacts will simply be that there are fewer pollutants of all kinds unleashed. As an example, the 2.2 million bbl/day savings by 1985 mentioned above would result in a diminishment of various pollutants by the following amounts. 1 CO - 4 lbs/1,000 gals = 189 tons/day Hydrocarbons - 3 lbs/1,000 gals = 142 tons/day Particulates - 23 lbs/1,000 gals = 1,088 tons/day N0 X - 60 lbs/1,000 gals = 2,838 tons/day S0 2 - 157 lbs/1,000 gals = 7,426 tons/day If however, energy conservation is achieved by technological change or sub- stituion, the net reductions will be those above, less the incremental pollu tants from other sources, as well as any new pollutants which might arise from these other sources. 1 HUD Contract #H2026R - "Research Evaluation of a System of Natural Air Conditioning." VIII-56 2 * Conventional Oil and Gas Supplies Large quantities of oil still remain in the United States. The U.S. Geological Survey estimates that undiscovered recoverable resources of 135-270 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 (Jan. 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 25 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 produc¬ tion is almost certain to continue its decline from the peak production rate attained in 1970. All of the 12 oil production forecasts discussed in the Project Independence Blueprint 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, regulation, and environmental constraints. Much of the domestic oil reserve is recoverable through secondary and ter¬ tiary extraction techniques. However, the oil that is attainable in this manner is in many cases "old" and hence subject to price controls. These controls have diminished the incentive for using these sophisticated and expensive recovery methods. TO substitute directly for the potential development for the Santa Barbara annel, onshore oil production would have to provide an additional 1,060 illion to 1,950 million barrels and onshore gas production would have to provide additionally 530 billion to 970 billion cubic feet. This substi¬ tution would entail environmental impacts such as land subsidence, soil sterilization, and disruption to existing land use patterns. Equipment ailure, human error, and blowouts may also impair environmental quality. rever, poor well construction and oil spills can result in ground and surface water pollution. VIII-57 LIBRARY U. CF i. URBANA-CiiAiAPAlBH a. Deregulation of the Wel lhca^rice_of__ Natural Ga s 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 could have an inflationary impact though it would encourage 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 he accessible. The DCS is believed to be one of the most prospective areas for natural gas development. b. Nuclear Stimulation of Gas For mations Nuclear stimulation, an experimental method of fracturing low permeability gas reservoirs otherwise incanable of sustaining commercial production, has the potential to add materially to U.S. recoverable gas reserves. The Atomic Energy Commission is conducting research and develop¬ ment of nuclear explosives and techniques for utilizing the effects of multiple 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. Federal Power Commission, April 1973 for the Technical Advisory Committee Federal Power Commission, p. II-7. Natural Gas Technology Task Force of the Natural Gas Survey by the VI11 -58 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 environ¬ mental impacts of nuclear stimulation of a single well or several wells in small geographic areas have been evaluated by the AEC, for example, for the Rio Blanco and Wagon Wheel Projects. Extrapolation to more extensive develop¬ ment relates to 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. 3. 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 12S times the energy consumed in 1970 . VIII-59 LIBRARY U. GF L MBANA-CGAMPMBH To replace the energy from the potential development of the Santa Barbara Channel 279.8 million to 514.0 million tons of coal would be necessary. Though domestic reserves could easily provide this quantity, serious limitations to coal development exist. In many uses, coal is an imperfect substitute for oil or natural gas. In many other 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 electricity generated from coal. Coal production is also threatened by the unique set of labor problems associated with mining and new strict standards for coal mine safety. Although U.S. coal resources are very large, there is some geographic dislocation. Most of our coal is found west of the Mississippi River far from the concentrated industrial areas of the east and far west. Also, mucl of the western coal is in arid or semi-arid areas where scarcity of water could constrain development. The portion of the demonstrated reserve base that is available for use depends on whether the coal deposit can legally be mined, and if it can, whether it is suited for underground or surface mining. Surface mines may recover up to 90% of the coal in a given mine; underground mines 50 to 60% using room and pillar methods. 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 miners. This Act has also increased the costs of underground coal mining - an important side effect VI11-60 since most of the nation's coal reserves can be recovered only by underground mining. Additionally, the Mining Health and Safety Act has given strip mining a competitive advantage over underground lining because strip mining is far less hazardous than underground mining and is subject to fewer of the provisions and regulations of the Act. The advent of new, strict air quality regulations has diminished the attractive- ness 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. 4 - 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 necessi- tate rapid development of this fossil fuel. Oil Shale can be processed after its extraction using a surface technique, °r, in place (m-situ) processing can be conducted. As with coal, oil shale be extracted using underground mines or surface techniques (i.e, strip nining). Hie Green River Formation covering parts of Colorado, Utah, and Wyoming •ontains the most abundant concentration of oil shale in the nation. ■Pproximately 600 billion barrels of oil are believed to be deposited in VIII-61 WSfW vmo-VNVBsn i jo n /avuan 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 environmental hazards but disturbance of underground aquifers and contamination of ground waters are side-effects of both development techniqu Commercial development of the Green River Formation would require significan quantities of water. However, the Colorado-Utah-Wyoming area is low on wate 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 exist!, land uses and thus have social and economic repercussions in an area traditionally devoid of large scale industry. Because 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 th area’s streams. Disposing.of the huge 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. VIII-62 b - Synthetic N atural Ga s and Oil Liquifying and gasifying coal in commercial quantities is another target of current energy research. Synthetic natural oil is the end product of coal liquefaction while gasification produces synthetic natural gas. Of the two methods, researchers have devoted more effort to gasifica¬ tion because of the high costs encountered in producing synthetic natural 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 are major problems because coal is the raw material for both processes. Moreover, these processes cause water, air, and noise pollution. According to Dr. Thomas A. Henri (Bureau of Mines, USDI), a typical coal [asification plant will produce 250 million cf/d of pipeline gas, consume 1X t0 10 milllon tons of coal annually, use about 6,000 gallons of water ,Cr minUte ’ 3nd have capital costs (including coal mine development) of over llion. Synthetic oil and natural gas would have to supply 6,602 rillion to 12,320 trillion BTU's in order to substitute for the oil and s from potential Santa Barbara Channel development. If the substitution VIII-63 library u. of /. u/mm-cHAiiPMSH involved synthetic oil only would have to be produced. then 1,155.2 million to 2,123.3 million barrels Complete substitution by coal gasification would require 6,468 billion to 11,920 billion cubic feet assuming approximate BTU heating value equivalence for natural and synthetic fuels. Complete substitution by coal gasification would require 4 to 7 250-billion BID'S per day coal gasification plants assuming a 20 year production period for the Channel, and would require 400 to 700 million tons of coal. At an estimated *250 million tor each gasification plant, tnese plants would cost „ 0 billion to *1.75 billion (because of the present lack of a commercial synthetic gas industry and the uncertainty of the related economics technology, SNG production projections are uncertain.) The gross comparison involved in the above analysis is somewhat misleading because perfect substitutability between synthetic gas and oil production and DCS production is not possible. The difference in longevity between a producing OCS field and a coal gasification plant requires consideration. Total Channel production of 6,692 trillion to 12,320 trillion Bill's would be spread over about a 20-year period while economic life of coal gasification plants proposed as alternatives may be as long as 75 to 100 years. Environmental impacts associated with coal conversion processes would largcl be those which are associated with the required mining of coal. In addition plant construction would require about 200 acres per plant. Large qua of water for the conversion would be needed and large quantities of devolatized coal, called char, would be burned or gasified. Sulfur and nitrogen oxides, bottom ash and fly-ash emissions would result. Water quail would be affected and waste solids disposal could cause surface water contamination problems. Noise will occur but would not likely be a problem VIII-64 beyond the plant property lines. 5. Hydroelectr ic Power The energy captured from falling water is termed hydropower. falling water, regulated and controlled by human technology, is used to drive turbines and thus produce electrical energy. The engineering problems in converting hydropower to electrical energy were mastered early and many of the major hydroelectric sites operating today were developed m the early 1950'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. Theoretically, increased domestic reliance on hydropower is currently possible. The undeveloped potential for hydroelectric generation in the lower 48 States alone is about 93,000 MW (FPC, 1972). If that potential were developed fully then hydropower could supply nearly 8% of the current domestic energy demand, CFPC, 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: • The sites with the greatest productive capacity and the lowest development costs have already been exploited. • Hydroelectric power imposes substantial land use conflicts and environmental side-effects. • The dams and reservoirs required by hydropower development have very high capital costs. • The amount of energy that can be produced via hydropower varies with the seasons. VIII-65 LIBRARY 11 . Cf L UHBANA-CHASSetm. » Manipulation of reservoir storage capacity is constrained bv water use and flood control considerations. In consequence of the above factors, an important future application of hydropower in California, and across the entire Nation, 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 through a generating unit to the lower reservoir thus producing the electricity required during the period of elevated demand. Pumped storage has at least 2 advantages: 1. It optionally 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. The quantity of hydroelectric energy needed to substitute for the oil and gas from the potential OCS development in the Channel depends on whether th( oil and gas is used directly for purposes such as heating or if it is burnec to produce electricity, an indirect use. Since direct use is more efficieni substitution in this instance would require a larger quantity of hydro¬ electric energy versus the case where oil and gas were burned to produce electricity. To substitute for end uses, 1,277.7 million megawatt hours to 2,324.8 milli' megawatt hours of hydroelectric energy would be needed. To substitute for the electricity which could be generated by the oil and gas, 786.4 million megawatt hours to 1,447.4 million megawatt hours would be needed. VIII-66 Several constraints limit future hydropower development and its feasibility as an alternative to fossil fuels. Hydropower cannot be substituted for oil and gas in transportation uses or in industrial uses that depend on the unique properties of oil and gas. Land use priorities may inhibit develop¬ ment of the few potential hydro sites east of the Mountain states. Furthermore, few dams are built solely for hydroelectric power generation. Irrigation, navigation, municipal and industrial uses, and flood control are frequently more important than and not fully compatible with nower production needs. Since hydropower is most often used to service peak loads, other energy sources must be relied on for base nower loads. Construction of a hydroelectric dam represents an irreversible commitment of the land resources beneath the dam and lake. Flooding eliminates wildlife 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 downstream, adversely affecting indigenous fish. Fluctuating reservoir releases during peak load operation may also adversely affect fisheries and downstream recreation. Fish may die if exposed to nitrogen supersaturated water. Nitrogen supersaturation results at a dam when excess water escapes from the draining reservoir. High nitrogen levels in the Columbia and Snake River pose a threat to the salmon and steelhead resources of these rivers. VI11-67 library U. DF l imBANA-CHAMPM6& 6. Nuclear Power The predominant nuclear system used in the IJ.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 electrical power capacity now under construction is nuclear powered. Nuclear power development has encountered delays m 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 activity will be necessary. The nuclear capacity required to generate electricity to substitute for potential Santa Barbara Channel OCS Development is shown below for two cases • all of the potential Channel development of OCS oil and gas used to generate electricity • all of the potential Channel development of OCS oil and gas devoted directly to end uses such as oil and gas heating. Nuclear capacity required to substitute for the electricity which could be generated by oil and gas from the potential OCS Channel development would VIII-68 be 6 to 10 1,000-MW plants. Capacity required to substitute for end uses would be 9 to 17 1,000-MW plants.1.2 The required amounts Qf nuclear fuel for end use and electrical generation are shown below. For End Use E lectrical Generation ^ rom To From To Short tons of slightly enriched uranium fuel necessary to sub¬ stitute for oil and gas production from the Santa Barbara Channel. 5 Short tons of slightly enriched uranium fuel in the first core - first year only Short tons of slightly enriched uranium fuel required for annual reloading of cores.^ Acres of land required for nuclear power plant sites. 5 5,735.9 11,758.5 3,533.9 6,495.2 780.0 1,600.0 482.0 884.0 260.0 534.0 160.0 295.0 13,500 25,500 9,000 15,000 Assuming 80 percent plant factor. 2 l!^- tati0 ? ° f * his com P arls °n should be noted. By asserting that a OCB ri" n ™ b ® r °f nuclear generators are required to replace potential Channel development, perfect substitutability between a fixed plant base U is e assumed rat Th S ’ ^ a . de P letable resource, the OCS hydrocarbon e ’ is assumed. The comparison is therefore not nprfhnt , oran^cl'^Cr,^^^ 1 ^ the di *«°r»"S TetTj the fe lx c a cy 6 of an OCS oil field (about 20 years) versus the longer average lifetime of a nuclear generator which is about 40 years. lifetime 3 l S n i IoAmiL FiSS T °L„ the sli shtly enriched uranium fuel yielding 1.2 x 10 BTU/lb., and a 33% efficiency factor for a nuclear generation ^ Plant as compared to a 40% efficiency for fossil fuel electri^ generation. 4 lold d UP ° n annUal C ° re reloads paling about 1/3 of the initial core Assuming 1,500 acres per 1,000-MW unit using cooling ponds. VIII-69 released to the environ- Some airborne and liquid radioactive materials are ment during normal operation. The amounts released are very small and potential exposure has been shown to be less than the average level of natural radiation exposure. The plants are designed and operated in such a way that the probability of harmful radioactivity releases from accidents is very low. 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 sited fossil-fuel plants. The effects of thermal discharges may be beneficial in some cases. Adverse effects can be mitigated by use of cooling ponds. Low level radioactive wastes from normal operation of a nuclear plant must be collected, placed in protective containers, and shipped to an AF.C storage site and buried. High level wastes created within the fuel elements remain there until the fuel is spent. They are then isolated in a fuel reprocessin plant and stored in liquid or solid form at AEC facilities. 7. 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 generated considerable business in California and Florida. Commercially VIII-70 installed solar heating and cooling in homes may be in wider use in many parts of the nation by 1985 but will not be common until later and possibly much later. Intensifying current research and development could hasten these dates (Morrow, 1973). Solar energy may eventually supply 35 to 50 percent of the nearly 20 percent of the nation's 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 S60 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 competitive. The typical solar heating system for a home costs $5,000-$6,000 (ncluding costs of a standby conventional furnace) compared to $1,000-82,000 for a conventional fossil-fuel home heating unit. However, the rising cost Df the gas and oil needed h r the conventional heaters means that the initial ifference in fixed costs will quickly be overshadowed by the solar systems' Lack of fuel costs. Therefore, though more costly at first, the solar units ippear to be the economical alternative over time. he full potential of solar energy can be realized only after large-scale .eneration of electricity using solar energy becomes technically and conomically feasible. In this regard the Ford Administration has requested 33 million for solar electric programs in fiscal 1975 - almost 826 million ore than the fiscal 1974 appropriation. A number of technical and engineering VIII-71 LIBRARY U. OF I. MBANA-CHMiPMBH problems now prevent commercialization of solar steam-electric plants though pilot projects are well underway. It is estimated that solar electricity could be available on increased scale in 10-15 years. (As a comparison, peak production from potential Channel development might occur in six to eight years.) 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. The accelerating real costs of fossil-fuel will continue to increase the attractiveness of the solar energy option. In addition, the environmental impacts of solar energy are relatively less severe than those imnosed by the traditional energy sources. Solar energy cannot substitute for petroleum in all uses, transportation and petrochemicals being the most evident examples. However, as solar energ is used with increasing frequency for heating and electricity generation, oil and gas supplies previously devoted to heating and electricity will be channelled to the petrochemical and transportation industries and other exclusive uses of oil and gas. 8. Energy Imports a. Oil Increasing U.S. reliance on foreign energy supplies is another alternative to the proposed offshore California sale. U.S. imports of petroleum in 1973 amounted to 2.264 billion barrels. If oil from foreip i. sources were to replace the hydrocarbons expected from the potential OCS Channel development, then an additional 1,155.2 million to 2,123.5 million barrels would have to be imported during the life of Channel production. A VIII-72 1974 world oil prices, this would entail a $ 12 , to . M2.1 to $22.4 billion increase in our oil import bill. Studies conducted by the Department of the Interior show that oil produced on the DCS of the United States is much cheaper than the foreign alternative. Extraction plus transportation costs for nrs costs tor OCS oil are anywhere from $6.50 to $ 8.00 per barrel less than the world oil price. The Project Independence study concluded that oil import levels will rise or actions the U.S. tabes. Projected oil imports under the different strategies studied are shown below. 1985 U.S. Oil Imports * ase case w/ and w/o emergency programs accelerated supply World Oil Price *7 (MMBD) 12.4 8.5 $11 (MMBD) 3.3 'onservation 0 ccelerated supply plus 9.8 1.2 conservation 5. 6 0 —v.1. ax i.uurg/ Aammi November 1974, p. 34 . 5r ' 6 b3Se CaS6 ’ t0tal 1985 0il imp0rts at * 7 —Id Oil prices are estimated - 12.4 million b/d. Of these, 6.8 million would be susceptible to disruption 11 world oil prices, 1985 imports for the base case are estimated at lion barrels a day, of which 1.2 million would be subject to disruption. -da, the second largest supplier of U.S. crude imports, has adopted a llCy ° f gradUal PhaSing 0Ut 0f a11 ^ exports to the U.S., possibly by 3 ' ^ ° f 1975 ’ the level allowable exports to the U.S. was VI 11-73 LIBRARY U. OF L URBAMA-CiOIMmm towered to BOO,000 b/d, nd C.n.de t» coo>lderln t ■ further reductron. U.S. oil imports fro. On.d. ...bed « .boot 1.2 million b/d in 1022, »»d r.« fro. .bout 200.000 to 0 . 0,000 b/d in 1... 102*. M.u.l erode erpert. to the ».S. the 1... three month, of »2, — >«• «■* Total U.S. crude oil imports, on a four week average for December 1974, were slightly over 4 million b/d, compared with 3.04 million b/d for a comparable period in 1973. Oil imports have contributed to U.S. balance of payments problems. Among the adverse environmental impacts of importing oil are possible spills from tankers carrying imported oil. Spills can result from intentional discharges, accidental discharges, tanker casualties, and tanker collisions. A study of oil pollution in domestic waters during 1969-70 showed that , , . nilt of the pollutine oil. Results from that tankers accounted for about 28o ot me pui study are presented in Table VIII-2. b. Natural Has 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. Canada’ intention to gradually phase out all crude oil exnorts to the U.S. creates uncertainty regarding future natural gas exports 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 facility for receiving base load shipments. Several LNG projects are now under consideration on the Pacific, Atlantic, and Gulf coasts. However, the Midd VIII-74 TABLE VIII-2 ESTIMATED ANNUAL OIL POLLUTION OF THE OCEANS 5 marine operations Tankers LOT tank cleaning operations Non-LOT tank cleaning operations Discharge due to bilge pumping, leaks and bunkering spills Vessel casualties Terminal operations Tank Barges Discharge due to leaks Barge casualties Terminal operations All Other Vessels Discharge due to bilge pumping, leaks and bunkering spills Vessel casualties Offshore Operations NON-MARINE OPERATIONS Refineries and Petrochemical plants Industrial Machinery Highway Motor Vehicles TOTAL METRIC TONS PERCENT 265,000 702,000 100,000 250,000 70,000 20,000 32,000 18,000 600,000 250,000 300,000 750,000 1,440,000 5.41 14.34 0.41 0.65 0.38 12.25 5.11 6.12 15.31 29.41 4,897,000 100.0 3 f?"* 1 l 0ta u < ! 0es not include oil contributed by recrea¬ tional boats, hydrocarbon fallout, and natural seepage. Source: Ind k Fn Sand the ?' S ' Energy Situation - an Economic and VirgilT? n Ke a ith nalySiS - J ° Seph D ' Porricelli VIII-75 LIBRARY 11. OF I. URBARlA-CHAMPAlBti East oil cutback has raised questions concerning the security o* 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 contracts, 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. Natural gas imports of 6,468 billion to 11,920 billion cubic feet would be required to replace the total energy expected from potential Channel develop- ment. In view of Canadian policy of phasing out crude exports and limiting future energy exports in order to meet anticipated increases in domestic demand, it is doubtful that any more gas would be available for import by pipeline. ENG 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 regasification 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. Receiving and regasification facilities will require 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 capit and the country (U.S. or foreign) in which equipment is purchased and LNG VIII-76 tankers are built. 9 * 2L h _££_^^££>^^urces The high cost., and rapidly shrinking reseryes Qf the energy fueis have encouraged research into new and different sources for al energy. As the traditional fuels continue to exhibit accelerating rates of cost growth, demand for and eventual substitution of alternate —- — - - ———. :: l.c,„ b„, M(h p „ vratiJ rtjir widespread use. Environmental impacts of these alternatives are sometimes difficult to assess, especially if a great amount of research and development remains to ae completed before operational scale systems can he d» , /brems can be developed, tested, and evaluated. « U, M th , d ,« OTluMllty >in ubsidized research, and the probability of encounter!„„ • 7 or encountering insurmountable ngineering and technical problems. Thus some of these energy sources could a installed within a decade, while others may prove never to be feasible. Possible significant energy contribution before 198S» L e !£f_form£ Primary Limitation, •othermal energy r sands lar Resources Resources Technology Secondary Limitations Economics Economics Economics ^ f ter: New Energy Forms Task Crouo 1971-1oaq n Council Committee on U.S. hnergy Outlook, 1972! etr ° leim VIII-77 LIBRARY U. Dt L iffiBAMA-CiWAPMM improbable significant contributions before 1385 Energy Forms Hydrogen Primary Limit a t. io ns Economics Secondary Limit_ations Technology Biological (agri¬ cultural $ wastes) Tidal Wind Economics Resources Resources Resources Economics Economics Fne rpv Conversion Devices Technology Fuel cells Thermionics Thermoelectric Technology Technology Economics Economics Economics Magnetohydro¬ dynamics Technology Economics Federal energy research and development funding has expanded significantly in the last few years. President Nixon announced in his Energy Message of January 23, 1974, that Federal commitment for direct energy rese ... , p incr eased to SI.8 billion in FY 75. Table VIII-3 shows development will be increased the funds for different areas of research and the agencies involved. 10. Combination of Alternatives The future U.S. energy source mix will deoend on a multinlici of factors, among them the identification of resources, research and develo ment efforts, development of technology, rate of economic growth, the economic climate, changes in life style and priorities, capital investment decisions, energy prices, world oil prices, environmental quality orioritie government policies, and availability of imports. VIII-78 TABLE VIII-3 federal energy r§d funding ($ million) Direct progra ms Conservation f. Other transportation Oil, gas, and shale a * Production b. Resource assessment c. Oil shale d. Related programs Coal e. Mining Mining, health, § safety Direct combustion Liquefaction Gasification (high BTU)** Gasification (low BTU) Synthetic fuels pioneer prog. Resource assessment Other (incl. common technology) environmental control • Near term SO • Advanced S0 X X • Other fossil fuel pollutants (incl. N0 X , particulates) • Thermal pollution • Automotive emissions FY74 65.0 End use (residential 6 commercial) Improved efficiency (transmission) Improved efficiency (conversion) Improved efficiency (storage) Automotive 13.0 19.1 FY75 128.6 Agency* 22.0 41.8 DOI, other AEC, DOI, NSF AEC, DOI, NSF AEC, NSF AEC,EPA,NSF,DOT, dod,nasa DOT, DOC DOI DOI, NSF DOI AEC, DOI 164.4 415.5 7.5 55.0 DOI 27.0 27.7 DOI 15.9 36.2 DOI, NSF 45.5 108.5 DOI, NSF 33.0 65.3 DOI, NSF 21.3 50.7 DOI, NSF 42.1 DOI 1/ 1.2 1.9 DOI 11.7 28.1 DOI 65.5 178.5 39.9 82.0 EPA, DOI 4.0 12.0 EPA 13.1 57.0 EPA 1.5 18.5 EPA, AEC 7.0 9.0 EPA f 11115 re£ * uest was later reduced by $27.0 million. VIII-79 LIBRARY U. OF L UfiBANA-CHAMPAlGiH TABLE VIII-3 (Continued) FEDERAL ENERGY R$D FUNDING ($ million) Direct Programs Nuclear fission a LMFBR b. Other breeders (GCFBR £ MSBR) c. HTGR d. LWBR e. Reactor safety research f. Waste management g. Unanium enrichment h. Resource assessment i. Other (incl. advanced tech.) Nuclear fusion a. CTR b. Laser Other *** a. Solar b. Geothermal c. Systems studies d. Misc. Support programs Environmental effects research a. b. c. d. e. f. Pollutant characterization, measurement, and monitoring Transport of pollutants Health effects Ecological effects Social and welfare effects Environmental assessment and policy formulation FY74 FY75 Agency__ 530.5 724.7 AEC 1/ 357.3 473.4 4.0 11.0 13.8 41.0 29.0 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 AEC 57.0 102.3 44.1 66.3 53.5 157.5 13.8 10.9 17.3 50.0 44.7 30.0 AEC, NSF AEC, DOI, NSF AEC, DOI, NSF, Treasury, FPC, other 11.5 32.8 NSF, DOI 169.7 303.4 AEC, EPA, NSF 16.3 37.4 26.6 55.6 72.6 112.5 27.3 65.0 17.5 19.8 9.4 13.1 1/ The AEC research budget was later increased by $40 million. VIII-80 TABLE VIII-3 (Continued) ($ million) Support Programs FY74 FY7^ Basic research 94.5 4 I/O 174.6 a. Materials 2 b. Chemical, physical, engineering 30 's c. Biological ACi \ d. Plasmas 40 ' 3 e. Mathematical 7 ’^ 32.9 58.1 60.5 8.2 14.9 Manpower development 6.3 8.5 Total (direct energy R§D) 999.1 1,815.5 Total (support programs) 270.5 486.5 Total (direct and support) 1,269.6 2,302.0 Agency AEC, NSF AEC, NSF Agency AEC DOC DOD DO I DOT EPA FEA FPC NASA NSF codes: - Atomic Energy Commission ~ Department of Commerce Department of Defense - Department of the Interior - Department of Transportation - Environmental Protection Agency Federal Energy Administration Federal Power Commission -National Aeronautics and Space Administration National Science Foundation ** *** dc^not ^include ^sfp^Zts" ^ ““ ° f C ° al b ^et Includes amounts for laser fusion directed toward military applica- VII1-81 UBRARV B. DF I. URBANA-CUAMPtlM The Project Independence Report 1 estimated U.S. energy supply for four cases. These data are shown below. demand and domestic U.S. Energy Demand and Domestic Supply, 1985 World Oil Price $7 per Demand barrel Domestic $11 per Demand barrel Domestic • (quads) Supply (quads) (quads) Supply (quads)* Base case w/ and w/o emergency 109.1 84.2 102.9 96.3 programs 104.2 Accelerated supply 109.6 92.6 104.2 Conservation 99.2 79.6 94.2 91.8 Accelerated supply plus 99 7 88.5 96.3 96.3 conservation ♦Quad - a quadrillion BTU’s. The tabulation below shows the breakdown of total domestic fuel supplies the base case and the accelerated supply case Domestic Fuel Consumption by Source, 1985 (in quads) Coal Oil Gas Hydro and Geo Nuclear Synthetics Imports Total 1972 Actual $7 world Base Case oil Acc Supply $11 world oil Base Acc Case Supply 12.5 22.4 22.1 2.9 0.6 19.9 23.1 23.9 4.8 12.5 17.7 30.5 24.7 4.8 14.7 22.9 31.3 24.8 4.8 12.5 20.7 38.0 25.5 4.8 14.7 0.4 * 11.7 24.8 17.1 6 .5 0 72.1 109.1 109.6 102.9 104.2 The increases in domestic supply under the accelerated supply case are due largely to the following. 1 The data cited in this section are taken from: Federal Energy Admmistra tion, Project Independence Report, November 197 . VIII-82 cap^citTm™ i9Ss! XPedited UCenSing t0 inCreaSe "- 1 - eX P loration and development of the Pacific, Gulf of Alaska, and Atlantic OCS. Additional oil and gas pipelines from Alaska to the lower 48. shal^production! leaSi " S ^ aCU ° nS t0 all ° W addltio " al oil Opening Naval Petroleum Reserves #1 and #4 to full scale commercial development. critical " aadat °7 a g°cation or other actions to assure levels 1 erlalS and equipment to meet expected production For the base case, the Project Independence Report envisions the role of alternative energy sources as the following: Petroleum production is severely constrained in the short run Rpfo gre ?Q 77 a f fected world oil prices in the long run. duction from^ 61 *?- 15 Uttle that can Prevent domestic pro¬ duction from declining or at best remaining constant. by a lack 0 of C market! n f Crease significantly, but is limited by lack of markets. Increases are limited by rate of mental'restrictions? r6aSing " UClear Cap3City ’ a " d envir °n- Potential increases in natural gas production are limited. Nuclear power is expected to grow from 4 . 5 % to 30% of total electric power generation. 198S heUC fUClS WiU n0t Play 3 maj ° r role between now and Shale oil could reach 250,000 B/D by 1985 at $11 world oil prices, but would be lower if $7 prices prevail. Geothermal, solar, and other advanced technologies are large potential sources, but will not contribute to our energy ' supplies until after 1985. ^ In the interest of clarity of presentation, the previous sections have discussed separately each potential alternative form of energy as a nossible substitute potential further Santa Barbara Channel oil and gas development. VI11-83 LIBRARY U. OF l l/RBAfJA CHAMPMh However, it is unlikely that there will ever be a single definitive choice between energy sources or that development of one source will preclude development of others. Different energy sources will differ in their rate of development and the extent of their contribution to U.S. energy supplies. Understanding of the extent to which they may replace or complement offshore oil and gas requires reference to the total national energy picture. Relevant factors are: • Historical relationships indicate that energy requirements will grow at approximately the same rate as gross national product. • 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 m their implementation - they include rationing, altered transportation modes, and major changes in living conditions and life styles. Even severe constraints on energy use can be expected to only slow, not halt, the growth in energy require¬ ments within the time frame of this statement. • 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 VIII-84 in the longer run and generally involves choices in energy- consuming capital goods. The principal competitive interface between fuels is in electric powerplants. Moreover, the full range of flexibility m energy use is limited by environmental considerations. • 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 imnortant roles in supplying future energy requirements, though their future competitive relationship is not yet ore* dictable. • 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. VIII-85 library u. Ct /. URBANA-CHAMPHNA • 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. VIII-86 Appendix VIII -1 93i> CONGRESS 1st Session* IN Til 15 HOUSE 0U KMUIiESENTATIVES May o, 1U78 Mr. SAYI.OK ( for liimwlf. Mr. Don 11. ( '..mm n. j.ii.I .Mr. Tk.u.vk of C’nlifoi nia ) mtro(l"f W | Im Inlovra.* bill; wl.irl, was nUVrmt to tJio Con,mitt,■« „ , Interior and lnsulur Allans A BILL lo terminate mid to direct the Secreimy of ilie Interior mid the Secretary of the Navy to lake action with respect to cer¬ tain leases issued pursuant, to (he Outer Continental Shelf Lands Act in the !Santa Barbara Ciiaunel, odsliore of the, .Slate of California; to explore naval petroleum reserve ntiniheiccl 4, ami lor other purposes. 1 Be it enacted bf/ the Senate and Jlon.se of Re.presenta- 2 tires of the United States of Avieriea in Compress assembled. 3 That effective on the date of enact mem; of this A ct all of 4 tllc foIlowi "« <1<,s eril>od leases, and all rights thereunder is- 0 sued pursuant to the Outer Continental .Shelf Lands Act in ° lll< ‘ ,Sll " la Jhirhtini Channel, offshore of the State of Cali- VIII-87 LIBRARY U. DF l. URBANA-amm&k 1 fornin, shall terminate mid the United Stales shall be vested 2 with all of the right, tilh‘, mid inl(‘iu*st in said leases: p-oi7» P-0170 P-0178 P-0175 P-0177 P-017! P-o I7:i P-0.170 P-0172 P-011>8 P-0171 P-l) Kill P-o 10.7 P-O ID!) P-01 OS P-020S p.0202 P-0‘207 P-02:) 1 P-0220 P0)220 P-0222 1 *-0200* P-0220 P-0221 P-0210 P-0201 1 *-0228 P-02.’ll P-0227 P-0210 P-021 1 P-0220 P-0212 P-0200 3 Si:c. 2. (a) The holder of any lease terminated pursit- 4 ant to this Act shall he entitled as the sole method for the 5 recovery of just compensation lor the lease or leases so tciini- 6 nated to bring an action against the United States in the 7 United States District Court for the Central District of Cal- 8 ifomia within one year after the date of enactment of this 9 Act. Said court is expressly vested with jurisdiction of any 10 action so brought without regard to the amount ol the claim 11 therein. Trial of any such action shall he to the court, without 12 a jury. 13 (b) The amount of any judgment in any such action or 14 of any compromise settlement of such action and any int< ust 15 accruing thereon shall he certified to the Secretary of the lu- 1G terior bv the Department of Justice. 17 Sec. i». (a) There is hereby created iu the Treasury ol 18 the United States a special account which shall he known as 19 the petroleum reserve account from which payments shall 20 be made in accordance with the provisions of this Act. In 21 order to provide the funds for the petroleum reserve account, VIII-88 3 1 the Secretary of ll,c Navy is directed to offer for sale on the 2 open market, under mvh competitive bidding procedures as 8 1,0 Cstill,]ish ’ '•'o Hlntc* share of the oil and gas 4 extracted from Naval Petroleum lieserve Numbered 1 pur- 5 mmt to the provisions of this Act and to pay the funds G realized from such sale into the United States Treasury. In 7 each year, sales proceeds e«|ual to the Government’s receipts 8 from Naval Pelroleum lieserve Numbered I during ,| lc 9 twelve calendar months immediately preceding enactment 10 of this Act shall he credited to the general fund and the ro¬ ll maining sales proceeds shall he credited to the petroleum 12 reserve account. Any sums remaining in the petroleum re- 13 serve account after the payments authorized by subsection U (l,) ,mV ° 1,0011 ™< h transferred to miscellaneous 15 rUC ' < ' II,tS ' ° f tllC Tl ' 0flsu, y> ail(1 lliereafter the funds realized 10 U1K,0r this Mll,S0, ' ,ioi ‘ 1>« ImW into miscellaneous receipts of the Treasury. 18 (h) There is hereby authorized to he appropriated out 19 of the petroleum reserve account to the Secretary of the 20 Interior, the Secretary of the Navy, the Secretary of the 21 iteasury, and the Attorney General, to remain available 22 until expended when so authorized in appropriation Acts, 23 such sums as may be necessary to— 21 (l> 1,10 Secretary of the Interior to pay VIII-89 LIBRARY U. 0. I. UKBAl^A-CHAUPMM •1 1 2 3 •1 5 (> 7 8 9 .10 11 .12 13 14 15 10 17 18 19 20 21 22 21 *> O judgments, compromise settlements, mid inteicst tlien- on, ns certified l>y tlie Attorney General under section hereof; ( 2 ) ennhle the Secretary of the Navy to carry out. petroleum exploration on Naval l’elioleum Nunihered 4, Arctic North Slope, Alaska; (;>) reinihurse. the general funds of the Treasury for nnv lost, royalties, as determined hy the Secretary • * of the Interior, resulting from a reduction ol existing production ..'xisting oil and gas leases on Federal hinds caused hy ].rodnelion of oil and gas from Naval Petroleum Peserve. Nunihered 1 under the provisions of this Act; and (4) carry out the functions and responsibilities re¬ quired of the Secretary of the Interior, the Secretary of the Navy, and the Attorney General under the pro- visions of this A cl. (r) lit the event tin* funds in the petroleum reserve . m) p| me not siuTieiciil. to pay any amount, so appropriated ,cre is authorized to he appropriated to the Secretary f the Treasury for advance to tin' petroleum reserve ae- omit out of any money in the. Treasury not otherwise ap- .printed, such ..Is as may he necessary fur such pn.v- I|( .„| S . The Secretary uf the Treasury shall he relmhumed VIII-90 1 lor sudi jxlv 2 'Umts irom hinds paid into the pH roll! mu it kitnt account in accordance with this Act, with interest llicicon, at sucli rates as may he. determined from time to 4 lime by the Secretary ot the Treasury. 5 lSli<4 - Wiilif.ut regard to (ho provisions of chapter (HI, G til, Code, (l,o Secretary of (l,o Xavy is * • ' 7 mil homed mid direeled (o produee hy win,lover menus Ik- 8 ..ns necessary sufiieienl oil from Xaval Petroleum Jieservo 9 Numbered I lo fulfill (ho n'lpiiremonts of section 3 hereof. 30 Tiu ' ‘ S, ' n ' c,fir >’ of I lie Xavy is also authorial to renegotiate 11 a '" 1 """ llly cxis,i ‘.v crealed a national energy reserve on the Outer Coniine,dal Shelf in the Santa, liarhara Chau- 1( > rnd, offshore of the Stale of California, under the jurisdie- 17 ""‘ 1 of ■Sccrelnry of the Interior. The said 18 .. r " M ' rv «’ '-lade up of the land subjeet 19 ,h, ‘ l,,i,S< ' S .. . Mils Hcl, plus (],(> hand t0 W,h '° ,J ll ' i,so mid the following described land as show,, on the ofliehd Ouler Continental Shelf Leasing “ M, ‘'” 1 2 3 CALIFORNIA Official Leasing Map, Channel Islands Area Map Numbered (> 1 > I.lock 50 north 00 west 50 north 07 west- 51 north 05 west- 51 north 00 west- 51 north 07 west- 51 north OS west- 51 north 00 west- 51 north 70 west— 52 north 04 west — 52 north 05 west — 52 north 00 west — 52 north 07 we.-4 — 52 north 08 west— 52 north 00 west— 52 north TO west... I >i>sc*rlpt ion _All. All. Northwest <|M:i.rtcr of the northwest quarter. ____ All. _All. _All. _All. Fast. lmlf and east half west half. All federal portion thereof. All Federal portion thereof. All Federal portion thereof. All Federal portion thereof. All Federal portion thereof. AH Federal portion thereof. All Federal portion of east half and east hal f west ha.l f. 4 48 north 00 west. 47 north (V0 west. 4G north GO west. 47 north 08 west . 4G north G8 west 47 north G7 west 4G north 04 west All. All Federal portion thereof. All Federal portion thereof. All. All Federal portion thereof. All. A11 Federal port ion thereof. The national energy reserve skill lx- available for lease, only as determined by Urn President, ainl under sm-.li !<• rins and 6 conditions ns he may |>r< •scribe. in accordance with existing 7 law VIII-92 SECTIONAL ANALYSIS OF PRDPn<;Ai rfthr^on^il tMS Pr0P ,° Sed biU t0 the S P eaker to the appropriate committeeforcons deraUoTLl'th't ^ U be referred Transmitted with this original hin n + at that 11 be enacted, as S. 1951 and H. R 75001 was th-VJ? lntroduced to the 93d Congress posal. 5 ° 0) W3S the f °H°»ing sectional analysis of the pro- in C t t hr U nit t eTst:t t e e s S . SeVeral named leaSCS ’ a11 to which are vested STSTu? rDl^ric^C^lofth^TT 7 f°t lea seholders, via an action Department of Justice shall certify the Dlstrict of California. The of the Interior for parent. X 3UdgnlentS awarded to the Secretary whlcf^tT^tYb*: made' ii^accord 3 R “”™ ac “ be funded by the sale of U S ni l a i Wlth the act * The accoun t will Reserve Numbered 1. In addition to 1 ^ extract ed from Naval Petroleum section 2 of the act this account ^pensating leaseholders pursuant to Flotation of Naval Prtroleua Reserve Numbered 4'^rc? 7 T FT 1 ”* ““ to reimburse the general funds for Insect ■ jN C Nortb Slope, Alaska; existing oil and gas production on r, sse soccasioned by any reduction in Naval Petroleum Reserve Numbered l- and""^ Caased by P rod uction from cies involved in the act to carrv o-.f tw e " able .the various Federal agen- Rese h r°ve Z a e ccoun e t! eCretary ° f th ° -Se'^eTto thTp'roUum VIII-93 UBRARV U. G} l uWAW-CfiAMPAlfiH REFERENCES u. S. Department of the Interior energy alternatives and their related impacts. _ * * Tnt prior Bureau of Land Management, 1975, Draft u. S. Department of the Interi , osed 1975 OCS oil and gas gen environmental statement (DES tor P r0 P°= e No 35 lease sale, offshore southern California, OCS sale No. 3b. genera VIII-94 IX * CONSULTATION AND COORDINATION WITH OTHERS in the preparation of this statement, data and information were obtained from the agencies and organizations listed below. Federal Department of Commerce National Oceanic and Atmospheric Administration National Marine Fisheries Service Environmental Data Service Department of Defense Naval Oceanographic Office Naval Undersea Center Department of Interior Bureau of Land Management Bureau of Outdoor Recreation Bureau of Sport Fisheries and Wildlife National Park Service Environmental Protection Agency State California Coastal Zone Conservation Commission South Central Region South Coast Region Resources Agency Water Resources Control Board Regional Water Quality Control Board Central Coastal Region South Coast Region Air Resources Board Department of Fish and Game Department of Water Resources Department of Conservation Division of Oil and Gas Other Southern California Coastal Water Research Project University of California, Santa Barbara University of California, Los Angeles Chambers of Commerce Santa Barbara Ventura Santa Barbara Historical Society Santa Barbara Museum of Natural History IX-1 LIBRARY II. OF 1. lOmm-CiiAMPAlBH The Draft Statement was made available to the Council on Environmental Quality and the public on June 6, 1975. We express our appreciation to those Federal mented on the Draft Statement. The National agencies who reviewed and com- Oceanic and Atmospheric Adminis tration. Western National Marine Fisheries Service, Bureau of Land Management, and Archeological Center of the National Park Service were most helpful with their assistance in preparing both the Draft and Final Statement. The various agencies of the Department of the Interior also provided valuable input in the areas of outdoor recreation and tourism, biology, mineral op erations. legal advice and comprehensive review. Appreciation is expressed for all comments, data information, opinions and letters. All were noted and much of the information was helpful in preparing the Final Statement. IX-2 A * Summary of Public Hearing Testimony and Responses Public Hearings Oral statements at public hearings on the draft environmental impact state¬ ment were invited by the Department of the Interior News Releases of June 11, and July 2, 1975, and the Federal Register notices of June 13, and July 7, 1975. The Department of the Interior hearings were held August 25 through August 27, 1975, in the City of Santa Barbara for the purpose of receiving comments and suggestions concerning the subject draft statement. Presiding over the hearing was Administrative Law Judge Franklin P. Michels, Office of Hearings and Appeals, Department of the Interior. The hearing panel consisted of Frank J. Kelley, Deputy Assistant Secretary Land and Water Resources; Herbert G. Stewart, Special Assistant for Environmental Analysis, Office of the Director, U. S. Geological Survey; and Dr. Russell G. Nayland, Chief, Conservation Division, U. S. Geological Survey. The members of the technical advisory panel were: Peter L. Tweedt, Staff Assistant to the Secretary of the Interior; Fred J. Schambeck, Pacific Area Oil and Gas Supervisor, Conservation Division, U. S. Geological Survey; Bill R. LaVelle, Petroleum Engineer, Conservation Division, U. S. Geological Survey; Edward G. Kreppert, Environmental Specialist, Office of the Assistant Division Chief for Programs, Environmental Analysis Section; Andrew T. Clifton, Environmental Engineer, Conservation Division, U. S. Geological Survey; Russell H. Campbell, Geologist, Geologic Division, U. S. Geological Survey; Robert D. Conover, Acting Field Solicitor, U. S. Department of the Interior, Dr. F. J. Watson, Coastal Ecosystem Activities Leader, U. S. Fish and Wildlife Service; Merline I. Carter, Pacific OCS Office, Bureau of Land Management ; Dr. Orien R. Gossett, Pacific OCS Office; and James J. Slawson, Marine Biologist, Environmental Assessment Group, National Marine Fisheries service. IX-3 UBRARV ii- OF L UP.8ANA-£iiAM?M&a Hearing testimony was reported by: Valley Reporters, 555 Capital Mall, Suite 415, Sacramento, CA 95814. Over one hundred persons submitted oral testimony for the hearing record; supplemental written text to oral testimony was incorporated as a part of the hearing record. Transcripts of the hearing (five volumes, 855 pages) and supplemental written text (498 pages) are on file and available for inspection at the U. S. Geological Survey National Headquarters, Reston, VA. and the Pacific Area Office, Los Angeles, CA. Speakers at the August 25 through 27, 1975 hearing are listed below Philip L. Fradkin William F. Northrop Mary Overbee Naomi L. Schwartz Robert J. Lagomarsino Bill Thuman Jim Barroca Dave L. Schmidt Thomas N. Banks C. N. Sweeney A. Barry Cappello Dr. Robert Mullen David Schiffman James J. Carroll Assistant to the Secretary of the State Resources Agency (Claire T. Dedrick) Executive Officer, State Lands Commission Administrative Assistant to State Senator Omar L. Rains Member of South Central Regional Coastal Commission (for self) State Congressman Ventura County Air Pollution Control District Ventura Chamber of Commerce California Chamber of Commerce Southern California Gas Company Southern California Edison Company Attorney for the City of Santa Barbara (on behalf of the City Council and City of Santa Barbara) Chairman, Environmental Quality Board Mayor of the City of Santa Barbara California Council for Environmental and Economic Balance IX-4 Self Henry F. Berg Self Albert F. Reynolds Environmental Quality Coordinator of Santa Barbara County Marvin Levine County and City of Santa Barbara Task Force Albert F. Reynolds County and City of Santa Barbara Task Force Frank J. Frost County and City of Santa Barbara Task Force John E. English County and City of Santa Barbara Task Force Dr. Robert Mullen County and City of Santa Barbara Task Force Lee Waian County and City of Santa Barbara Task Force R. C. Sharp County and City of Santa Barbara Task Force Dr. Alan Eschenroeder County and City of Santa Barbara Task Force Laurence Brundall County and City of Santa Barbara Task Force Joe Green County and City of Santa Barbara Task Force Michael D. Saddler County and City of Santa Barbara Task Force David Bagnard Fred Huntsinger, Vetco Offshore Industries, Ventura John Jostes Self Murray Lewis Los Padres Chapter, Sierra Club Walter Relies Santa Barbara Group, Sierra Club Catherine McCammon League of Women Voters of Santa Barbara Thomas L. Phillips Global Marine, Inc. Lois S. Sidenberg Carpinteria Valley Association Francis Sarguis Get Oil Out William Gesner Get Oil Out Penny Knowles Get Oil Out Roger Amebergh Self Robert E. Burt California Manufacturers Association Jack H. Willson Butte County Rice Growers Association William I. DuBois California Farm Bureau Federation IX-5 library a. cr i. mm-cHAMPAim Dr. John Burke Self Jimmy Jones Self John Cushing Self and Wife Michael D. Bergen Self Mr. Jacobs Self Tom Escobbie Self Paul Randolph Self Patrick Kelly Self Peter Dane Self Rosario Coulette Self James Roden State Assemblyman Gary Hart Philip Verleger Western Oil and Gas Association E. J. Cahill Western Oil and Gas Association John Silcox Western Oil and Gas Association E. J. Dickinson Western Oil and Gas Association Leonard Gearin Western Oil and Gas Association Paul Jennings Western Oil and Gas Association C. W. Waage Clean Seas, Inc. G. Allan Smalley Western Oil and Gas Association Fred Weiss Western Oil and Gas Association Henry Lippett, 2nd California Gas Producers Association Goldie Joseph Orange County Council Environment - Employment Economy - Development Orrin K. Earl Pasadena Chamber of Commerce Don Deining American Institute of Professional Geologists Jack S. Russell Mobil Oil Corporation Martin Kellogg Isla Vista Municipal Advisory Council Mickey M. Gutierrez Self IX-6 Edward Bruce California Wildlife Federation Ted Broman Self Lanny Kimmett Self Lee Staman Society of American Florists and Flower Growers Harry Brant Self Evelyn McDonald Goleta Valley Branch, American Association of University Women Pamela Bradley Self Penny Knowles Santa Barbara Coalition against Oil Pollution Scott Stewart San Francisco Chamber of Commerce Samuel B. Frisk Gulf Oil Company James A. Bottoms Self T. L. Campbell Self Jackie Johns Los Angeles Chamber of Commerce Loron J. Hodge Bakersfield Chamber of Commerce Stark Fox Independent Oil and Gas Producers Association Rosalind Conley Self (American Association of University Women Santa Barbara) * Coleen Putnam Self C. C. Albright Long Beach Area Chamber of Commerce H. Douglas Lemons Long Beach Area Chamber of Commerce Fred Johnson Long Beach Area Chamber of Commerce Michael Chapman Long Beach Area Chamber of Commerce Bob Willard Long Beach Area Chamber of Commerce Don Lloyd Long Beach Area Chamber of Commerce Carter Boswell Long Beach Area Chamber of Commerce Gene Bowman Long Beach Area Chamber of Commerce Phillip Jimbrecey Self Mr* Randolph Self IX-7 LIBRARY U. Gf L L7:SAi0 at new locations, such as obscure canyons, would retire zonin g changes ln 3U Pr0babmty ’ accompanied b y a multiplicity of inherent problems, income received from potential OCS development in the form of local taxes paid and the cost incurred by the public for increased government s have not been quantified. A cost revenue analysis for each level of OCS development should be prepared. Disruptions due to OfS farii-i+in ities maintenance and replacement have not been addressed. • Recommendations have been made in many studies, but most have still not been implemented, e.g., that the USGS undertake immediate and concerted action to develop and promulgate a basic program plan for the assurance of safety and pollution control in OCS operations. The Department of Interior T t or has not implemented the CEQ recommendation that DOI establish minimum standards for critical OCS operator personnel through certification and appropriate accreditation training programs. Concern was expressed that if the Federal Ecological Preserve and Buffer e withdrawn from protected status and were leased by the Federal Government resultant production in Federal waters would force the State to allow development in the Santa Barbara Sanctuary. Concern was expressed that the USGS and other Federal agencies were not assuring that maximum effort and capabilities are being applied to OCS operations to assure environmental protection and safety. E.g., pipe- line design for seismic areas. More specific information is required before air quality impacts can be assessed, it is not reasonable to conclude there will be very minor air Reality impacts. Discrepancies in possible long-range adverse effects of OCS operations °n Pinnipeds (seals, sea lions, sea elephants) and their rookeries have IX-15 not been resolved. • • j pi o-r» wore not acknowledged 26 . The California Coastal Zone Commission and Plan in DES 75-35. 27 It was stated that offshore oil and gas operations had not been sub.ecte t0 a severe earthquake and that ability to withstand a severe earthquake was unknown. In reponse, testify was presented that there was orl development during the Santa Barbara earth q uakes of 192S and 19S0 ; how¬ ever, this was on State lands including platforms on piers. There was also considerable discussion as to Channel seismic history 28. and marine structure seismic design criteria. „ nffice and the County Counsel’s Office for Santa The City Attorney's Oftice ana Barbara County made a Joint revest on behalf of the Task force review¬ ing the Draft EIS for information obtained from exploratory drilling and other information-gathering activities to determine the geological make-up of the Channel and size of the oil and gas supplies in the Channel. A copy of the letter request is to be made part of this 29 30 31 record. The above officials also stated that the Draft EIS is so inadequate t it must be rewritten and recirculated in draft form and hearings must not be terminated until the public has had the opportunity to review and comment on that data. Mitigations should include requiring an assumption of absolute liabil: for all damages, including tax losses which result from an oil spill- it was stated that the hazards of deep water drilling and potential tanker collision have been analyzed and presented to the Department o the interior, but the pertinent information was not mentioned in the DES. (Specific sources or references were not named). IX-16 32. An apparent inconsistency was noted on draft pages I„- 179 and m _ 206 regarding the percentage of local labor for the exploratory phase would be a small or large percentage. 53. DES 75-35 treats the subject of oil spill containment and cleanup on the open seas in an inadequate manner i e a , H manner, i.e., deployment of equipment in an emergency, whether response will be mado V ° made to an emergency, and the capacity of equipment. 4. Plate 1 inaccurately indicates an oil field on the Mesa area; The City of Santa Barbara does not permit oil drilling within city limits. 5. Economic impacts of an oil spill are nnt A + spin are out of date and the statement refers the reader to DES 75-35 D t TT ia 7 a ^ p. 111-167 and p. III-182 for an "adequate" discussion that does not exist. The County of Santa Barbara was not consulted by the IlSfq ■ a the USG S m preparation of the draft. Petroleum conservation was not addressed in meaningful depth in terms of reducing demand and resource exhaustion. Petroleum conservation should be evaluated in terms of national needs and should relate the Santa Barbara OCS to those needs. ■ Hazards of drilling from floating vessels were inadequately covered "Worst case analysis', was not presented for an oil spill C e.g.. a well being drilled at 10,000 feet in 1,000 feet of water from a floating vessel). USGS regulations on crew training on operation of rop s uperarion of BOP equipment should be more stringent and comprehensive. quality monitoring network should be set up both for onshore and offshore in the Channel area. More detailed consideration and attention were suggested for the areas of: *£3 IX-17 43. . disposal of produced waste water DES 75-35, - drilling inspection and surveillance procedures and inspection personnel training. _un, Of drilling -ud di,d»„.d „„„« for exploratory «.l. ■»< ~ ** wells. .• 1 nil and gas reserve estimates seem on the low side. The potential oil and gas i oci-aH for City of Santa Barbara statistics Inclusion in the FES was requested for City .no ritv of Santa Barbara from the 1969 spill, on loss of revenue to the City of Santa d IX-18 Responses to Public Hearing Testimony 1. Response to this comment is provided in the revised and greatly expanded Socioeconomics Baseline and Impacts discussion in the FES. See sections H.F., Resources, and III.N., Socioeconomics Impacts. 2. If a final Coastal Plan is adopted by the California Legislature and approved by the U. S. Department of Commerce pursuant to the Coastal Zone Management Act of 1972, the activities of the Department of Interior or of Federal oil and gas lessees directly affecting the Coastal Zone shall, to the maximum extent practicable, be conducted in a manner consistent with the approved coastal zone management program. The discussion of the Coastal Zone Plan has been updated and expanded in this final state- and IV.A.1.h.). ment (see section I.F.2.a. Also refer to hearing response No. 26 and response No. 38 to the State Resources Agency (Coastal Commission portion) • The summary statement of Mr. A. F. Reynolds cites "Significant short¬ comings" in the DES 75-35 treatment of geologic and seismic hazards; how¬ ever, the detailed geologic comments within the Santa Barbara/Task'Force report appear to be critical of the general state-of-the-art of geologic andseismologic information in the Channel region. None of the detailed comments challenges the DES as an accurate and up-to-date summary review of current geologic and geophysical information for the region; nor do they offer significant additions, revisions, or corrections to the data reported. The County report does not cite or otherwise refer to any Other report or reports that provide a more complete, more accurate, or Otherwise more "adequate" review of the geology and seismology of the Channel region, the present status of information, and the future needs for additional information if commercial development proceeds. Regarding the requests for: A) "basic raw data used in the preparation of DES 75-35", and B) oil companies' proprietary data", the related formal correspondence between the County Counsel and the Geological Survey and the Department of Interior is presented in the written commeni response portion of this section. Mr. Coudray comments that: "Specific mitigation measures that are technologically feasible and economically realistic need to be spelled out that win or will not preclude the chance of major oil spill (s) from a seismic or geologic hazard." It is, of course, impossible to write specifications covering all possible contingencies, in the absence of knowledge of the kind of installation or the specific site location; and, similarly, no list of specifications can guarantee performance to the absolute point that all chances of major oil spill are completely "precluded." However, current sound engineering practice calls for careful investigation of conditions in and around the potential site of any structure to determine those factors that might pose a hazard, and for consideration of those hazards in designing the structure to per¬ form in such a way as to resist the kinds and severity of damage that might pose a hazard to safety or potential for adverse environmental impact. Mr. Brundall is quite candid in his recognition that his comments relat to his judgment concerning the . . incomplete state-of-the-art at this point in time.” rather than to any failure of the DES to report that state-of-the-art fully and fairly. He further recognizes that the DES recommends acquisition of more and more-detailed geologic and seis mologic information, both for the region as a whole and for site-specif purposes. IX-20 In his criticism of plate 4 (DES 75-35), Brundall ignores the context of its title, which states that its purpose is to illustrate the "method of interpretation from acoustic profiles". The principal conclusion about recency of faulting intended to be illustrated by plate 4, is that faults of different probable ages are shown on the geologic map (plate 2) with the same symbol. Only detailed examination at specific sites along the faults, such as those points shown on MF-585 by the "Geologic Control Symbols", can discriminate between different ages of faulting. The DES statement that research could accompany development and produc¬ tion provides the additional consideration that research related to potential for adverse environmental impact should continue throughout the entire period of production. No oil and gas operations or facilities will be located within a certain distance of the established shipping lanes. The Geological Survey and Coast Guard work together in establishing such shipping lane safety zones. The present agreement for the Santa Barbara Channel OCS requires that all oil and gas platforms and drilling vessels must be at least % mile from the shipping lanes. The number of support vessels required for the possible levels of Channel development would depend on many variables. The crews are trans¬ ported by boat and helicopter. The crews sometime live on the location and sometimes are transported to and from shore each 8-hour shift. Also, the frequency of supply vessel trips varies considerably. The possible levels of Channel development would likely require approximately 15 to 40 support vessel round trips daily from shore to drilling vessels and platforms. XI m ’■‘M wu) $5 Qg IX-21 This amount and type of increased traffic in the Channel should result in only minimal negative impact on pleasure boating. Both the support and pleasure boats possess a relatively high degree of maneuverability and must adhere to Coast Guard regulations. The support vessels perform numerous rescue and assist operations in the Channel each year. This is one positive aspect of such appropriately equipped and well manned vessels traversing the Channel daily. 7. The OCS Lands Act (43 U.S.C. 1331-1343; 67 Stat. 462), provides that Section 8 leases are to be maintained under regulations m existence at the time the lease is issued. The leases in the Santa Barbara Channel were issued in 1968. Should a future proposal be received for a leased area within six nautical miles of an area of biological concern, thor- ough consideration would be given to environmental concerns. Appropriat State and Federal agencies would be consulted. The action to repurchase leases or portions of leases would require legislative action. We concur with respect to baseline data. Studies being conducted by the Bureau of Land Management on future potential lease sale areas are intended to provide baseline data for assessing impacts on any future development. During the past decade, there has been intensive study of long-term and recurrent major and minor oil discharges, as reflected in the references following section IV. Although baseline data may be lacking or incomplete, "control" areas (those similar to the area im¬ pacted) have provided a basis for comparison. 8. Decision as to the need for site-specific environmental impact statement will be made on a case-by-case basis in accordance with established NEP£ procedures of the Department of the Interior and the Geological Survey. 9. Refer to the Preface and section I.A. for a discussion of the reason foi initiating this statement and the basic purpose. The primary objective is to consider the impacts that would occur as a result of the four possible levels of Santa Barbara Channel OCS development. 10. A detailed discussion of national energy needs and plans (short-term anc long-term) is considered beyond the scope of this Santa Barbara Channel IX-22 statement. The Project Independence Report is cited as the most recent and comprehensive attempt to define national energy requirements now and in the future, as well as methods for meeting our energy needs domestically or from secure foreign sources. A Rand Corporation report prepared for the State of California is cited as one source for a de¬ scription of the California energy situation. See section III.N. for a complete reference to both of these reports. The Department of the Interior is committed to baseline studies in new frontier OCS areas (proposed OCS lease sale areas) followed by monitor- mg programs through exploration and development activities. The Southern California OCS Sale 3S FES, and a variety of recent documents, presentations, and testimony of various Bureau of Land Management and Department of the Interior officials before Congressional Committees demonstrates clearly this commitment to baseline and monitoring pro¬ grams an frontier areas. This commitment is further demonstrated by the Bureau of Land Management's commencement of such programs for cer¬ tain frontier areas, i.e., the Southern California OCS Sale 35 area. Presently (January 1976) no area-wide, coordinated baseline and monitor¬ ing programs have been initiated for leased areas with existing oil and gas operations. In the Santa Barbara Channel OCS leased area, some site-specific monitoring and biological and archeological studies are conducted by the operators, in accordance with agency requirements and guidelines, or by the agency itself. Examples are: • Seismic monitoring (USGS)- - Iv _ B _g_ • Subsidence detection (operator)-section IV. B. 7. • Biological and archeological surveys to insure protection of these resources (operator)_ sections IV.B.l. and 9. Site-specific waste-water discharge monitoring and analysis (operator)- sections IV.A.l.c. and g., "OCS Order No. 8.(5)” For a discussion of multi-agency, university, and industry involvement and recommendations as to baseline and monitoring programs, see section IV.B.12. 12. See expanded coverage in section III.N.10. 13. Marine traffic and safety considerations for the Santa Barbara Channel are addressed in considerable detail in the DBS section III.J.l. Present and likely future vessel traffic as a function of possible increased production in the Channel are quantified appropriately therein. Safety regulations for vessel traffic and the likely impact thereon of increasec levels of production are also noted in the revised safety portion of FES section III.J.l. The impact of LNG transport in the Channel cannot be meaningfully deter¬ mined at this time due to the large uncertainty of its occurrence, timing, or magnitude. However, refer to section I.F.3. for other activ¬ ities in the Channel that might affect marine traffic there (including LNG transport). 14. Estimated fresh water needs for a single onshore facility are provided in section III.E.2.d. Total fresh water supply needs would be a function of the level of development of the Channel, which cannot be IX-24 determined at this time. However, as noted in table 1-1, the range of numbers of onshore facilities for the various possible levels of develop- ment is from 1 to 5, hence total water needs for onshore facilities could be estimated from as little as 20 acre feet per year to as much as 100 acre feet per year. . These statements are noted. Please see the responses to items 16, and 17. As noted elsewhere, while the statement addresses the possibility of leasing, it is not a lease sale statement (which would be prepared by the Bureau of Land Management should leasing be considered). The "principles of conservation," as legislatively defined, refer to the conservation of oil and gas resources, OCS orders and Departmental policy, as well as State and local agency policies, do reflect serious concern for the conservation of natural resources other than oil and gas. Please see the discussions on Areas of Special Biological Significance, Conservation Considerations and Concerns, California Coastal Zone Conservation Commission discussion and Mitigations, as examples. Without site-specific proposals, it is not possible to evaluate onshore impacts m great and specific detail. In the FEIS, the discussions of generalized onshore impacts have been expanded. Specific onshore sites would presumably receive full environmental consideration under various state and local laws as a minimum in the event of a site-specific proposal. IX-25 17. These statements are acknowledged and we concur with the possibilities. Further, the California Coastal Zone Conservation Commission Plan, when adopted, will provide policies relating to consolidation of onshore pro¬ cessing facilities and descriptions of the types of areas where develop¬ ment may occur among many additional guidelines. (Policy 83c, 83f in section IV.A.i.n.) (bee also response 16) This subject is addressed in the revised and greatly expanded Socio¬ economics Baseline and Impacts discussion in the FES. See sections II.F., Resources, and III.N., Socioeconomic Impacts. 18. Response to this comment is provided in the revised and greatly expandec Socioeconomics Baseline and Impacts discussion in the FES. See sections II.F., Resources, and III.N., Socioeconomics Impacts. 19. The maintenance of subsea production systems would require the presence of a surface vessel. A subsea production system is frequently suggestec as means of totally eliminating the aesthetic impact of a surface facility. However, normally a nearby surface facility is required durn the production phase and a surface vessel is required for drilling and maintenance. The maintenance of platforms, onshore facilities and drilling vessels would be a part of the routine operations and daily operational impacts. Mechanics, electricians, etc. are considered in section III.N. "Socioeconomics Impacts." (See table I II-8) 20. The status of implementing recommendations made in several studies of OCS operations has been updated in this final/fstcfionhv.A.S.). There have been many of these studies, as shown in section IV.A.8., and several are presently ongoing. As new studies are completed, the need revise and expand certain original recommendations and add new ones, becomes apparent. See section IV.A.8. and appendices IV-2 and IV 3 f° IX-26 examples of the revising of adopted recommendations prior to the completion of implementation. „ any of these complex recommendations considerable planning, manpower and money and cannot otherwise be meaningfully implemented. The Review Committee on Safety of Outer Continental Shelf Petroleum Operations, under the auspices of the Marine Board, National Academy of Engineers was established in duly 1973 , to serve as a third-party audit of the OCS procedures and operations and to review state-of-the- art technologies. This Committee established at the request of the Geological Survey, composed of experts not regularly employed by industry or the Government, has issued four reports to the Geological Survey. The fourth and latest report, issued in August 1 975 , and the three previous ones are discussed in i-n,-. r- , iscussed in this final statement; Committee membership is also presented (see section IV.A.S.a.). Prl0r t0 thS CEQ implementation of a similar training recommenda- tl0n ; reSUltlng fr ° m an earlier stud T> «s already in progress. See section IV.A.8. for the status o-F i plementmg the recommendations from Various studies as to OCS operations and management. F "*“ 1 P ™“" “ p «— z „„„, „ S '*” s "'* **»”■ »u s—".n. ln th , lnt „ ldl . :lIon 00 Page 11,10, sectlon I.E.4. and section VIII.E.3. and 4. It is acknowledged in the statement that the possibility of drainage from merged lands within the State Sanctuary would exist should this adjacent restricted Pederal area become available for leasing. However " "" th6re " S - or by the Secretary of atenor to make the Federal Ecological Preserve and Federal Buffer Zone SB S3 S3 § OT/’fM sjj IX-27 UBRAR/ 23, 24 25 available for leasing. Discussion of the subject in this EIS was and is included for the purposes of looking at the full range of "possible.. OCS development in the Channel. The level and extent of USGS efforts to protect the environment is de scribed in great detail in section IV.. Mitigation Measures. fl The identification and quantification of potential air pollution emis¬ sions and their impacts from the possible levels of Channel development have been addressed in detail in the greatly enlarged Air Quality and TT r 1 and III., and III.LL. Air Impacts sections II.G.1•, ana The long-term effects of crude oil on marine mammals in their natural habitat are not well known. As may be seen from the many cited expert references, even the immediate impacts of crude oil spills are yet open t0 some question. Research is continuing in many private and govern¬ mental circles, world-wide on both the short-term and chronic effects of petroleum products on the marine environment, as well as, improve¬ ments for the techniques of spill prevention and clean-up. The decisio, have to be made only after weighing the potential environmental conse¬ quences of not only oil spills, but also the factors of human encroach- ment, as they are known at that time, 26 „ _ , rnn^prvation Commission and the Plan-in- The California Coastal Zone Conservation ^ Iv . A .l.h. ,. sections I.F.2.a./The U. S. Geological Preparation were discussed in sectio Survey is acknowledged on page 17 of the California Coastal Plan as om of the Federal Agencies having provided assistance and cooperation in r; nlan The draft statement was issued June 6, the preparation of the plan. , , lpt M Tt -i Brief- Preliminary Coastal Plan". 1975 prior to the pamphlet in Brier. Final Plan dated December 1, 1975 was received by the USGS in mid- December. As noted in the transmittal letter of the plan "the workloa IX-28 for us (the commission) has been enormous." Nonetheless, in our informal telephone contacts with individual conmissioners, they provided useful and helpful information for the draft EIS preparation. The 162 policies and 44 recommendations (not yet acted on by the California Legislature) the valuable descriptive text and very informative color- coded, annotated map series in the 443-page volume are too numerous to abstract, however, certain of the petroleum-related policies and recom¬ mendations have been listed in section IV.A.l.h. Copies of the Cali¬ fornia Coastal Zone Conservation Plan may be purchased from: Documents and Publications Branch, P. 0. Box 20191, Sacramento, California 92520 The plan definitely will be consulted and considered in the event of any site-specific proposal. The following is in response to Dr. Paul C. Jennings'helpful hearing testimony on "earthquake engineering features of the draft statement." We believe a portion of Dr. Jennings' comments stem from misreading or misinterpretation (perhaps due in part to unclear wording in the DES text), and confusion between "expectable ground motion parameters", "design criteria", and "design specifications". DES 75-35 describes ground motions of the sort expected to be measured by seismometers and accelerographs on the ground surface at sites lacking the influence of Structures or extreme contrasts in the elastic properties within the local geologic section. As such, ground motion does not relate to the nature or importance of the structure being designed. Tbe capability of a structure to resist specified ground motions without collapse can only be evaluated in the context of the entire spectrum of design con¬ siderations. DES 75-35 deals only with the ground motions. In recog¬ nition of the potential for misinterpretation, we have revised and expanded the discussion on p. 11-129, 130 (DES 75-35). See section H.B.6. g. A 93 QS IX-29 Jennings’ final general comment consists of urging that the authors of the various sections of DES 75-35 be identified because he sees the effec as "dilution of responsibility through anonymity". Such lack of indenti- fication is not based on any reluctance of the individual contributors to be so identified, but reflects the practice of DOI, USGS. Both the draft and final statements are institutional documents carrying the Director’s signature indicating both approval and agency responsibility for its contents, as the NEPA has assigned that responsibility. Following are responses to Dr. Jennings' additional substantive hearing comments: (1) Jennings asserts that "...the 0.2Sg and O.SOg design spectra, combined with the other portions of the recommended design criteria fin, the Santa Ynez platform...have produced a platform which has the calcu] capacity to resist without danger of collapse ground motions with peak values equal to those which they recommend." This serves to support t! statement of Coulter (DES 75-35, p. XI-129. 130 ), that proposed Platform "C" could resist very large acceleration even though the nominal design coefficient was 0.15g. (2) Jennings comments that peak acceleration values are not di Y related to the amplitude of response of structures with the natural frequencies of offshore drilling platforms. This is, of course, correc however, as Trifunac and Brady (1975, p. 43) point out: "...one of tl simplest methods of scaling the strong ground motion is to use the pe: IX-30 acceleration recorded in the hopviiv ck ^ the heavily shaken area. Though one such P " *™ ™ the „e„n spectral u„. d , ptna , nt „ f „ u ^ ^ reasons, as well as sinvnl ir‘i -t-v .i*. plicity, it appears that such scaling may remain in engineering and seismological nractir^ gicai practice for some time.” Furthermore the estimates of peak velocity and displacement give information on the low frequency components of ground motion which are more relevant for offshore drilling platforms. .Jennings also asserts that the ground motion characteristics recommended " ° ES 75 ‘ 35 3re " inC ° mPlete f ° r the P-P- of specifying the design values of the maximum credible earthquake." Design specifications are beyond the scope of the Seismology Section of the Impact Statement The intent of the Impact Statement was to characterize the ground motion. Peak horizontal acceleration, velocity and displacement were recommended. Given these values, methods exist (e.g. Newmark and Hall) for constructing response spectra for design purposes . 1 g asserts " The values given by the USGS arg higher than those thought appropriate by most other experts in this field " This assertion must be questioned in the context of the recent paper by Trifunac and Brady (1975), who estimate maximum acceleration associated WUh 3 magnitUde 7 ' 5 6arth ^ ake a "-ft” site at the causative fault to be as much as 4.5*. and that the average peak accelerations at the . be 1 ' 75g - Trifunac and Brady conclude (1975, p. 49 ) : " We ark > N. M., and Hall W I iqao c • reactor facilities: Fifth’wor^'r^i 5 " 110 deSlgn criteria for nuclear Santiago, Chile, 1967, Proc., v. Z^p^y-so 0 " Earthquake Engineering, ass CS3 gu £3 3 If 5*. ca 13 IX-31 t »„d ,h. amplitudes »f .»»« „„d,e,.d by dlft "" C " “ “ Pl,1 “ by ,b, seti.u, Let »< d.,a («.« M - » «“ ”* »' arbitrary ...»«d. f« tu.a.d, source in most previous studies." Jennings also asserts that "...no recommendations are given...concern¬ ing the attenuation of motion with distance from the causative fault." He is referred to the discussion and figure on P- (DBS 75-35) Which specifically treats attenuation of ground motion *# distance from a causative fault; and to p. n-113-121, which points o,r that the most modern solutions of epicenter locations in the channel h. a relative error of as much as 5 km which, when combined with the observation that many of the faults have dips that may deviate appreo from the vertical, and when combined with the data of Plate 2 -which s . f th „ channel for which there is good information that for the parts of the Channel fault distribution it is difficult to find a site as much as 5 hm fro, mapped fault-lead to the concluding statement on p. TI ' 141 (DES 75 which states; "Because no part of the Channel is far from one or ano of the major faults, and because of the seismicity of individual faul cannot be resolved from among the many nearby faults by the present seismograph net, the hazard should probably be considered to be unifc distributed throughout the region, even though the instrumental reco, of small earthquakes indicates a greater frequency on the north-cent, east-central, and southeastern parts of the channel... IX-32 >8 !9 . The reader is referred to responses tn n ponses to the Dames and Moore review sub- mitted as part of WOGA written counts, and to Texaco written counts relating to Channel seismic activity and seismic design criteria. All correspondence related to this subject is included in the section on written comments to the Director (section IX.B.). The requirements Tor circulation of the Statement in Draft form prior to preparation of the Final Statement have been fully met per section 1500 of the Council on Environmental Quality Guidelines, titled -Preparing draft environmental statements; public hearings." The matter of data availability is addressed in the USGS response letter request noted in the previous comment. The Department and the Survey do not contemplate further nuhlir • runner public hearings on this statement at the time of filing the FES. Parts (a), (b) and (c) of OCS Order No. 7 clearly state that the lessee “ responsible for the cost of clean-up of any spills. The lessee's lability to third parties would be determined according to applicable law. Regarding the prevention of waste and conservation of the natural resources of the Outer Continental Shelf, regulations have been promul¬ gated establishing bonding requirements for lessees, 43 CFR 3304.1, 3304.2, and liability for oil spills resulting from operations, 30 CFR 250.43. several of the comments received by the Department have IX-33 suggested that the amount of the required bonds should be increased and that absolute liability for oil spills resulting from operations Should be extended to include damages suffered by state and local governments and third parties as a result of such spills. Furthermore, some counters said that a mechanism should be created whereby third party damages could be assessed and collected expeditiously from the party causing the spill. The bonding regulation is intended to implement the statutory require¬ ment that the successful bidder be one who is responsible and qualified. 43 U.S.C. § 1337(a). The bond is conditioned upon compliance with all the terms of the lease. For an individual lease the bond must be in the amount of $50,000 or the lessee may furnish a $300,000 bond to cover all the leases he may hold within a given geographical area specified in the regulation. The right is reserved to the United State: to require additional security in the form of a supplemental bond or bonds or to increase the coverage of an existing bond if, after oper¬ ations or production have begun, need for such additional security becomes apparent. No limitation on the amount of bonds is set by the OCS Act. The lessee is required to bear the expense for the control and total removal of pollutants proximately resulting from drilling or productio, operations conducted by or on his behalf. 30 CFR S 250.43(b). The absolute liability for the costs of cleaning up a spill does not exten IX-34 to damages suffered by third parties as a result of the spill, which constitutes a separate and different suite of legal concerns. The regulation provides that the lessee's liability to third parties is governed by applicable law. Adjacent state civil and criminal laws effective as of August 7, 1953, the date of enactment of the OCS Act, or other Federal laws and regulations of the Secretary apply to oper- ations on the Outer Continental Shelf. The administration is presently supporting legislation which would establish a mechanism to assess and collect third party damages expedi tiously from the party causing the spill. Deep water drilling and potential tanker collision has been discussed m this statement. As drilling progresses into deeper water, new technical problems will have to be resolved and OCS Orders will be prepared to respond accordingly. (See section IX.B. responses Nos. 1 and 5 to EPA comments on deep water drilling) Response to these comments have been made in the greatly revised and expanded Socioeconomics Baseline and Impacts discussion in the FES. See sections II.F., Resources, and III.N., Socioeconomics Impacts. Refer to the updated inventory list of Clean Seas Inc., clean-up and containment equipment (section IV.A.4. and 5.). See response to ERA and Resource Agency of California comments on spill clean-up and containment capabilities. The Bottom-Tension Boom has contained seep eight-foot seas with its full containment capabilities as yet undetermined. This sea state covers about 94 percent of Santa Barbara Channel sea conditions. As stated in the text of this statement IX-35 34 35 36 37 subsequent to the 1969 Platform A spill, continuing improvements have been made in spill containment and clean-up procedures and equipment. However, to date, no system or equipment has been developed which is completely effective in controlling and removing all spilled oil under all weather and sea conditions (section IV.A.5.). It is acknowledged that the Mesa Oil Field near Santa Barbara as shown on plate 1 is abandoned. Response to these comments was made in the greatly revised and expanded Socioeconomics Baseline and Impacts discussion in the FES. See sections II.F., Resources, and III.N., Socioeconomics Impacts. While the Counties of Santa Barbara and Ventura were not formally consulted, published information from agencies and organizations of both counties were used in draft preparation, and the process adhered to NEPA guidelines. The CEQ specifically intended for such input of State-local agencies to take place during the draft review period. The distribution of approximately 1,000 copies of the statement in draft form, holding of public hearings for oral comments, receiving written comments and responding to such comments are the means by which all interested parties contribute input to the final statement. Approxi mately 600 copies of the draft statement were mailed to parties the Department believed may have an interest, the remaining 400 were mailed on request. The availability of the draft statement was announced in the Federal Register and in a Department News Release. Conservation is addressed in expanded detail in the revised and enlarge section VIII.G.l., Alternative Sources of Energy, (Energy Conservatio IX-36 38. Whether drilling is conducted on land, a platform, or from a floating vessel, many of the procedures, and requirements are similar. Drilling from a floating vessel, however, requires certain modifications in procedures and in some cases equipment modifications. Five areas of major differences in procedures for floating drilling are identified and described in section I.0.3.a. The impacts of drilling from a floating vessel and from a platform are discussed in section III. It is apparent that weather conditions and sea state are more of a factor in floating drilling than in platform drilling. 39. Possible spill volumes for various types of spills are discussed in section III. See table HI-17; also see the added discussion in this final statement as to maximum credible spill amount estimates (section III.K.4.). The drilling depth of the well and water depth are not necessarily major factors as to the ability to abate the source of the spill or contain the spill and prevent oil from reaching relatively more sensitive areas. o. See our earlier responses nos. 20 and 21 to a similar hearing comment on implementation of certain training recommendations. Several studies on DCS operations and management have resulted in training recommendations. Refer to section IV.A.8. and appendices IV-2 and IV-3 for the status of implementing the recommendations that have resulted from various studies. As to specific training for blowout preventer operations, OCS Order No. 2 does presently require testing of the preventers at various specified times, and that a blowout prevention drill be conducted weekly for each m !?a i 3 $3 r 1 £0 3 IX-37 drilling crew to insure that crews are properly trained to carry out emergency duties. All blowout preventer tests and crew drills must be recorded on the driller s log. 41. The subject of air quality monitoring data is addressed in the greatly enlarged Baseline Air Quality and Impacts sections in the FES. See sections II.G.l. and III.LL. 42. Disposal of produced waste water is discussed in considerable detail throughout the statement in appropriate sections. Portions of the produced waste water discussion has been updated in the final to more closely reflect the present status as to produced waste water disposal and regulation. Produced waste water di scussion references. Section I.D.8.a.(2) Section II.G.2.C. and d. Section III.E.2.e. and Section IV.A.l.c. and d Section III.C.2 .b.(1)(c) Santa Barbara Channel OCS inspection frequency and procedures are described in detail in section IV.A.2. 43. It is agreed that the estimate, of the average amount of drilling mud spilled into the sea, may be too high for platform development drilling. 44. The opinion that these reserve estimates are conservative is acknowledge As stated in the text the reserve estimates given m table 1-2 are preliminary and subject to possible drastic revision as more information becomes available and more detailed reservoir studies and reserve analys are performed. IX- 38 45, Loss statistics from the 1969 oil spill to the City of Santa Barbara, as estimated and provided by the Mayor's office, are presented below. The City lost more fhan^lOO^OOrfn^enJa! of^City 0 ™^“°"' SSOO t OoS e - Pr h P r ty ‘ ^ l0St fr ° m ' 69 to '73 more than $500,000 m bed taxes and $3 million in sales taxes The lty suffered a diminution in the fair market value’of its ocean-front property and a loss of use of the City's ocean front property from 1969 in effect until the present To ^he -tely $3 a mUli B :n bara thiS ^ additional l°ss of ^proxi- I! s rrc: s- l°ss by /c " y crr^b-r^rk^ 1 :^- citizens!" wlthout reducing services for all of its as ‘O Q£ IX-39 g. W ritten Comments rm the draft environmental statement, as invited by Written comments on the arait the aforementioned (section IX.A.) news releases and Federal Register notices are reproduced in the following portion of this section. As appropriate, response to specific comments are made. For easy reference, responses to each comment have been numbered and the appropriate section of the comment letter has been bracketed and numbered. The letter precedes the response, correspondence duplicating hearing testimony is included with the hearing records. Appreciation is expressed for all letters, data, information, and opinions The following written comments were received: IX-40 Federal Bureau of Land Management Bureau of Mines Bureau of Outdoor Recreation Department of the Army Department of Commerce Environmental Protection Agency Federal Energy Administration Fish and Wildlife Service National Park Service Office of the Secretary, Ocean Mining Administration U. S. Coast Guard U. S. Energy Research and Development Administration August 5, 1975 August 5, 1975 July 24, 1975 July 30, 1975 September 2, § 16, 1975 October 2, 1975 July 31, 1975 August 11, 1975 July 22, 1975 July 31, 1975 August 4, 1975 August 7, 1975 on State State Lands Commission Resources Agency of California and California Coastal Zone Conservation Commission (submitted together) Other Governmental Santa Barbara, Office of City Attorney City of Tehachapi August 20, 1975 November 19, 1975 August 8, 1975, Sept. 25, 1975 § August 29, 1975 August 28, 1975 IX-41 Private Organizations and Individuals Air Transportation Association August 13, 1975 Bekins Company August 1, 1975 B’nai B’rith Messenger July 31, 1975 F. P. Lathrop Construction Company July 8, 1975 J. Ray McDermott and Company, Inc. August 29, 1975 Le Roy Jeffries and Associates August 22, 1975 Kaiser Steel September 2, 1975 Modern Plastic Company August 20, 1975 Parr and Associates (Russ Campbell and Solicitor) August 27, 1975 Pioneer Division, The Flintkote Company July 25, 1975 Red Triangle Oil Company July 16, 1975 Sidney R. Frank Group August 21, 1975 Sport Fishing Institute September 9, 1975 Standard Oil Company August 29, 1975 Texaco, Inc. August 26, 1975 Union Oil Company of California August 21, 1975 Valley Nitrogen Producers, Inc. August 27, 1975 Western Oil and Gas Company August 27, 1975 Mrs. William Aggeler August 29, 1975 Malcolm Archbald August 31, 1975 Mrs. Malcolm Archbald August 30, 1975 Richard H. Bigelow August 26, 1975 W. E. Bisgaard July 30, 1975 W. E. Bruse August 28, 1975 IX-42 Private Organ izat-i nr. g Mrs. Bryan Burk Jacki Bergen and Brad L. Clements Edward N. Dodson Phyllis Dodson Albert Dorskind Mrs. W. M. Fridell Mickey M. Gutierrez William P. Hoopes Ernest J. Loebbecke Ferdinand Mendenhall Howard Morf Gene E. Steed John V. Vaughn Mrs. Carol A. Waters August 4, 1975 No date August 27, 1975 August 29, 1975 August 4, 1975 August 4, 1975 August 29, 1975 August 1, 1975 July 31, 1975 August 5, 1975 August 7, 1975 August 5, 1975 August 4, 1975 July 31, 1975 ■W zsa -:‘4 s 8s O "s' sa OC QO Z3 IX-43 IN REPLY United States Department of the Interior bureau of land management WASHINGTON, D-C. 20240 1792 ( AUG 5 1975 Memorandum To: From: Subject: Director, Geological Survey Director, Bureau of Land Management _ . j ra f t environmental statement. Oil and Gas S^enf ln the Santa Barbara Channel Outer Continental Shelf off California DES-75/35 1 of no have reviewed the above subject. We find In response to your reque h ^ Section VII i on Alternatives to the weakest section of the dra wording on the bottom of page Further Development. For examp e, con fusing. We would suggest VIII - 3 on the N^ctisa Alter^slnted on the ^Action that a much more comprehensi etails on what the legal and environ- ssrss-ss.^ £ =.£“ .srrs;.™ each of the operational alternatives The following detailed comments are provided for your use, A..*& fk Assistant Enclosure ^ 76 -^ IX-44 Detailed Comments: ii. The Preface and Introduction of thp nFTQ the history of OCS development in California 8 / 6 excellent summary of summary of development in the Santa ^ 3 parti cularly good however, to expand the Santa Barbara R 1 3 hanne1- lt; ma y he appropriate, (PP. ii-13 to 11-15) and d^cuss l^morn: an d th° e 11 d SPi11 ° f 1969 Sectlo "> L969 Blowout, and the clean im - not - 0 i, • , 1 the daTna 8 G caused by the :he reader to page III-183. ic resulted thereof, or to refer >eing conducted but do^orgivIVpfoifctiT^f ° f aCtlvities currently :t may be useful to protect a ranee „f , ° f expected future activities, action in the FEIS. 8 Probable future activity in this olume I ection I.D.1,2 - page 15-23 age 1-22, 3rd paragraph, last sentence- Wh*t- -?o ndicated water base muds are not hatful TLrine^ !b1erco I ;pie« OT 'technology“°?he S great m detairi Ve Platform and rt ° f SUbS6a ^chnology is treated is especiaUy wln^repL^^h 6 ^ ^ ;ad^..^f; 9 ; ep ^ e : f I -“^ t ^), fines 4 thru 8. - Change to : 10 feet in the fairways. Corns of requlres a "ULnimum pipeline burial minimum pipeline burial of 10 fp Pt - * ne ^ rs ln Galveston, Texas, requires uchorage areas." 6et ln the fairwa y s ’ and 16 1/2 feet in the quired by OCS order No!^^" 1311 2 * Corrosion prevention measures are Peline^idto d^te’was^TlO Para ? raph to d °cument the deepest underwater alian state-^fco^pany, m t l’ 1 , 8 " "T ° f Water by a " p y, (.Oil and Gas Journal, October 28, 1974). 2e 1-124, paragraph 2, line 5. — Change to read- "Th 0 t ats in OCS Order No. 9 apply to all OCS^pipelines." P ? ^ reqUlre ~ :e Code/' P " a8 “ ph 2 > llne ~ Change "Uniform Fire Code to "National 3)1 ( •13 :tion II-A, II-l No comment d a^eader't^believe^that 51 ” paragraph > last sentence. This sentence may believe that more geological and geophysical investigation IX-45 LIoR/itt 4 l»m Om i. ~Lsiii will be completed prior to oil of"further" 3 seismic 3 investigations prior to any oil production activities. . yv.pt are the ground accelerations the other r p a ge 11-129, last sentence. ^What are tne g OCS platforms could withstand. Section II-C Meteorology No comment 8 Section II-D - . Oceanograph y sentence : It is doubtful that only in tl Page 11-179. 2nd paragraph, beach with little modifica- area of Point Conception can waves strike reasonable that tion resulting. With waves from the northwest. It " 2“^ energ , they will be diffracted around Point Conception, ^dissrefracted at along the shore south of Point Conception. area of the submaii Point Conception, the wave energy will c °^rg ^ statement is true, a s&r^ To clarif: this statement the Army Corps of Engineers could be consulted. L , 'x-t-a cont-prirp The statement should be. the amplitude and a decrease m wave length.) Volume II Page 11-217 - It should be indicated that the area from Mugu Lagoon to Latigo Point is designated as an ASBS. 10 Page 11-218 — When referring to the rare and endangered / particular area, it would be more meaningful and more scientxfically^^ accurate to distinguish ^ich subspecies ^ Ac J ding t0 the Such is the case on page 11-218 with t VV TOStr ± s ) i s endangered DES, the entire clapper rail species ia are endanger* This is incorrect. Only the three subspecies - ^aUfornxa is and only the light-footed clapper ral1 - ■ t ? lnklng ~7ii^~i^lies t found in the subject area being described. Thithinking «ls n the peregrine falcon which should be listed as the American p falcon (Falco pe regrlnus anaturo ) . bro-’nil ^bieh also occui The~Califomia least tern (S^^na §i^ £ ^^ r own pelican included in things together. 8 h 1 extr emely helpful for tying would be helpfZforTfuller und^stL™ 1381 ?" 5 ° f kllOWn faCtS Whlch the acorn barnacle (Cthalamus f„«„d h .„ n ? r ° f th ? coramunit y- F °r example. This species was one~of the veTTf^T? omitted from Table 11-20. "S occur 3 in°the^a further south in the Severn >ase 11-259, 261 - Fay (1971) should be changed to Fay et al. (1972) f -s. Fish and Wildlife Ser^icf^ It^s^istVi*?» endan8ered b F the f the United States" 1973 Edition. 1 C d ±U the Thre atened Wildlife fiction II—F. —— Papp TT-im ational Monument and is not ^rZdZlZd^wLt’- Island is a ••• Anacapa is ripe with development opporZiUes. " S meant by the P braaa . -thods total 98%, not 100% 4 --~why? 6 Percenta8es for different fishing ‘ese^igurerfrrfive'yearroirand 6 eStlmateS should be included here. ie relationship ZZnlZing^ “^^^ed^siderabiy jomplete'descriptio^of^the 3 terrestrial^minp - f^ 8 ” thlS SeCti °" ^es -sent or potential offshore mineral -r eral resourc es, no areas of s no offshore mineral deposits -ft ^ mentione d. If there lld get a better feeling of the of/V^ be . lndicated » so that the reader ; Present, that may be fcono^cal to e “ vir °nment. If mineral deposits ng mined at this time it ZZ t ““ in the future * but a re not time, it should be indicated in the text. able on existing tanker^ooriZUcilitill Z•3 i 3 A .. 4 <4 -A •a « ca 33 28 29H page XU-16 - paragraph 4, sentence 3 - Information on dilution would help to describe the dispersion effect. Paragraph 5 ~ What is the source of this information. 30 page III-29 --(a) Blowout and Caprock J^/guf f iUen^depth sentence "Care sould be taken that '“^ B “™ f ^ S £eper tones!" prevent formation damage by exposure to pressures rr This particular item is quite significant f^^Yo^ch^nt was the cause of the original big show what actual requiremeti s--s\53-“ etc. 31 . ttt r 3 n-M Spill Estimates page III 35 - Tbe data in leum in the Marine Environment" by the National Academy^ ^ ^ Washington, D.C./ 1975, disagrees wi offshore production refers to McCaslin, 1972, and show the 1971 ^ ^ EIS 618 million barrels per year or • ^ minor spills from U. S. off- SSe“^Sr- 1^500 barrels per year or 63,000 gallons, rather t the 662,203 gallons you indicate. All this data, however, 18 ver *i!h i!is Yd S piil ratios have litl to justify in the context in ^ich it loused, ^ ^ majorl , meaning in the Santa Barbara Mexico with its many wells and mucl ££ conditions. Mso, why pick da, 5 years old, when more recent data is available. A major spill will completely change the data natural seepage going to consider small spills, it souia De tieu 32 33 page Hl-73 - Pipeline trenching 5 i^recommende^that^reseeding l prior to construction, and that planting of native shruDS “ "“".SS “i£: £5 mounds! *o^other*techniques"^ used to prevent erosion and salt . intrusion? 34 slope stabilization could be enhanced by requiring use of Y ti ftcati Set^^th^ = r bf d^irt^^hore construction . be presented. IX-50 ItTu ll\l £ 1,16 sta — is -• would be spilled. This should be explained iT iTb^ ° f S f° red 011 of baffles in a sinol^ - P d * ls xt because of some type small storage containers, etc? C ° ntainer » or wil1 th ere be several tL\\ n ^ S 0 t i 1 te :p e il t i a durin e R b d r 8 v n r n ^ 0f the S6C0nd P a ^raph indicates modest, local adverse enviroLental effects^ Experf 117 ° nly that a major spill has never been readilv % an d^d" SeemS t0 indicate conflicts with the next statement nf -\ ^ ndled ' • Also, this statement spill occurs in wet^eathlr 2SSk passive pollution if the same anffor'^hatleriod^fttoer^af l ?" 1 " 6 habitat area would be removed, pollutants would be emitted from the^^h 3 ™* approxlmate quantities of ities? emitted from the onshore storage and treatment facil- . ;.1 TTT.L. 3 . Impact of Spill on Air quallt; The section is too brief and does not ad ^ge aid s^Ill else spiU ^th example, what impact would occur ™ 1 f ^re would be an over- the discharge lasting -er * s veral ^ZZ leidded to during the next night accumulation of pofl ^ , t->o 1 1 ntion be for a day. Also, what would the ^“^"^j^that SO me modeling be done to establish jTllutantImount durations, and onshore areas which would be impacted. Page III-120 — Reference 29 is not complete. 40 Page III-133 - The Baker (1971a) and 1971b) references are not listed i the bibliography. Recovery of marsh plants is dependent upon Aether or not oil penetrates Tnto thl sediment surrounding the root system of the plant. To cite the Nelson-Smith (1973) summary of Baker's work: . Penetration of oil into the substratum has direct effects by spreading around root systems ^reducing norma bacterial activity content. Jhis^indr: pass by smothering the shoots p H971f) demonstra oxygen into the soil via ^eir roots Baker (19 If) demo^ ^ a great reduction in this oxygen diffusion wnen t nainted with oil and pointed out that the roots of healthy frTtina are surrounded by brown, oxidized mud whereas after Vparuna are n i ants this becomes blackened and rePe vobic° Bacterid degradation of oil is largely aerobic an under such reduced conditions, may be very much slowed down. <*,„ «a not ,.,.tt thn, the,. ». v.t, “““ “““l on rocky surfaces as indicated on p. m-VX. g significant to the mussel community, but Chan in , re efs in the area, decrease in marine life after the oil spill onother reels in Most severely affected were acorn barnacles, limpets, and striped crabs (Chan, 1972). Page III-165 - The DBS indicates that, carbons, but eventually depurate them. The ha i„ and the consequent inc concentration of hydrocarbons in t e oo temporary conci danger of carcinogens or toxicity as the result of this temp tration should be indicated. IX-52 Section III.H. — Table III-9 on p. 111-176 should perhaps be updated to £roiert t h a T dema ? d forecasts now being anticipated! (Source - FEA 1— Project Independence Blueprint) "SowceTofMrol 178 ^ mi ? labaled s °™ewhat. Perhaps a caption such as Petroleum supply of petroleum consumed..." may be more appropriate Section III.0.2 Summary - Impacts on Air Qaulitv result 11 "" 21 ^ 11 ” 6 1 f tat ? S " Very min ° r irapact:s on al r quality would result... In case of a large case spill or another volume spill lastine will'b! a yS ’ r no longer be true. In addition tLrl - expanded for 8 morracc^a!yf r0m ° nSh ° re ° Perations ' Tha “«ion should be discussed! 21 ' line 11 ' The SUbjeCt 0f 1oK level chr °nic spills is not Page III-222: line 1 - What types of impacts are to be expected, amounts of pollutants are decreas^g each ^The" generatedbpollutants! 311 ' 6 ' ^ ““ ° nSh ° re offsho - !r bII - 222: . llne 4 “ Fumes fro ”> fires and the volitization of spills do T [“r ln 3 raf>id fashion - i®Pact would result. Some discussion .woSSd hS e thr g e SL e te^. the m ° St Pr ° bable ° nSh0re 3reaS “ here the 'Section III.0.3. p. III-222. This section should be expanded There are Mny potentially adverse effects (possible concentratio^of fish at p-tential - S TvuTltlf - that ShOU S d S e diSCU£Sed - N ° of L“- lerence with drifting seme fishermen. Section HI.0.4. p. III-224. The statement - "habitat impact for i-enthir be 8 a n sUght°Lditi m0S ^ *1? W ° Uld bS P ° Sitlve debatable. There would ... . 8 C addltlon to the sessile epifauna habitat, and therefore the the^natural apaPaunal individuals, but also a consequential decrease in Undi^duHs. 3nd reSUltlng decrease of the normal infaunal Cofst^ulrd 2 ^^ 61 ” paragraph 1 ’ line 3 - Change to read: "The U. S. oileof'lea lane^boundaries. permanenC pladP °™ a not be within one-quarter ^y t i° n i975 A aid a ocq P o f- 2 H “ fo°a ld alS ° include 0CS °rder No. 11 dcted / > l 9/5 and OCS Order No. 12 dated December 1, 1974. Section IV.A.1. g. Pacific Area OCS Orders — p. IV.-11. There are 1? this section ^Thel^r' ^ app j; 0prlate information should be included in December 1974 " I , 1 ' 8 sen tence OCS Order, No. 12 will likely be effective 1974 does not seem applicable on July, 1975. IX-53 •a Section IV.A.4.a. Organization Formed by Companies for Spill Containment a and Removal — P. IV-33 49 The U S Coast Guard National Strike Force, Pacific Team, commanded by LCDR Wiechert, represents a significant capability that can be on si tithin 2 hours, "ibis should he ^included along^th^thei^equipment. ? hours This should be included aiong wuu r - - Additionally, there is a significant Navy clean up crew at the Construe ion L Battalion Base in Pt. Hueneme that was not included. T The P.I.C.E. cooperative group noted has changed tneir name to Clean bu |_ Coastal Waters". Section IV.A.4.b. Clean Seas, Incorporated — p. IV-35. 51 Clean Seas has a published inventory last dated April 1, 1975, which represents a significant increase in equipment over the January 1974 last noted This also invalidates the list on p. IV-39, (2) Equipment and Materials to be Purchased by late 1974. It gives the impression that ^fone tos paid much attention to this section for at least a year and therefore ought to be brought up to date. Section IV.A.6. Mitigating Factors Involving the Relationships of Potenti; Activities to Shipping — P. iv.-pu. 52 The one-half mile boundary from sea lanes was correct at the time hte paragraph was written, however, the U. S. Coast Guard is now in process of getting 1 Ik mile approved. 53 Section IV.0.5. p. III-225, 2nd paragraph, . 3r ^ S ™ te "“’ : J™s uglily*’ it is found that during the Santa Barbara incident, oil silks usually penetrated a short distance into suspended sediment plumesshownin Figure 2, page 345). This indicates that f '""“er bottom sedii: out are not dispersed with sea water, and cou p J 54 Section V.A.l and 2. This is a somewhat optimistic outlook as many of the impacts, unavoidable or otherwise, are somewhat speculative. p V 5 — The statement that the duration of the P «- benthos'will last up to 2 years, apparently does not consider the^ime^ required for a destroyed population to reach reproductive ag . is unknown for most species, but for a community “‘otalthemember X™re are a significant number of other species requiring a similar time to reach reproductive age. *Kolpack, R.L. 1971. Biological and Oceanographical survey ^he Santa^ Barbara Channel oil spill. Allan Hancock Foundation. Volume I , p. and 345. IX-54 r: h : f in T f r nce with — result of Increased boat traffic The °u an „ oil spi11 and as a fishing, other than trawl-ino * i , ement that methods of commercial *- or pipfiines" is ^o t correct! U " affected ^ offhore structures Section V.I. page V-9 Unavoidable Adverse Impacts - Air Quality C “t belted 1 throu^ P e q uip m ent d controi m etc! S ° f P ° llutants that wil1 C Section VII.B. p-VII-1. Considerably more detail is needed. “‘^ l ‘ cSS,d -to the California legislature. ° r C ° nServation Policies being recommended References used for Biological Comments: A StUdy ° f the effects of the San Francisco oil spill M^rSr 78p? r8aniSnS ‘ Kentfleld > California, College of ^Southern cllif ^ ^ th±C macrofauna of the mainland shelf of southern California Allan Hancock Foundation, Monogr. Mar. Biol. Nelson- N.Y^abOpf* 19?3 ' 011 P ° llution and mar ’i ne ecology. Plenum Press, IX-55 response to bureau of land management in our view, a single treatment o£ the alternative to encompass all possible aspects of future development would be inappropriate, complex, and unnecessarily confusing to the reader. As stated in the referenced passage, it was discussed on subsequent pages in the context of separabl, categories of possible actions. The passage has been revised in the final statement to reflect post- draft receipt of proposals for Federal actions. 2. The reader has been referred to the appropriate portions of section III 3. Section I.E.S. and 6. (tables 1-1 and 1-2) contain estimates for the number of facilities, exploratory and development wells and potential production for each of the four possible levels of Santa Barbara Channe development. Tables III-7 and III-8 give a hypothetical 40-year time frame for the possible levels of Channel development. 4. Normally, sea water is used as drilling fluid for this type of shallow coring. Occasionally, small amounts of clay (bentonite) are added for viscosity. Discharge of small amounts of this sea water-clay mud waul, likely result in only very brief local turbidity. The evidence is indirect, e.g., recolonization of the ocean bottom within 8 months (section III 0 C.2 0 b.(1)(b))° 5. These suggested changes have been made where appropriate. 6 . Various geological and geophysical studies by private concerns as well as the Geological Survey will continue to be performed m the Channe IX-56 for many years concurrent with present production activities and possible future oil and gas activities. 7. This entire page has been rewritten to more clearly present the present situation as to earthquake design criteria. 8. Recommendations accepted and text modified to reflect suggestions. 9. Please see section II.G.2.b.(2) for ASBS discussion. .0. The subspecies involved is indicated by use of the trinomial in the scientific name in tde F£S. 1. The text has been modified as appropriate. 2. The difference was due to rounding off. 5. Sections H.F.9.a. and b. have been expanded considerably. 1. other than information on kelp harvesting, no data on potential mari- culture in the Channel area exists. A discussion of Santa Barbara Channel potential mineral resources other than oil and gas has been included in section II.F.13. Presently, no minerals other than oil and gas are extracted in paying quantities from the Santa Barbara Channel, however, it is possible in the future that gravel, phosphorite, manganese and other minerals will be extracted from the Santa Barbara Channel ocean floor in paying quantities (also refer to the response to the Bureau of Mines). 16. Table 11-66 and figure 11-46 list and locate the existing tanker mooring facilities in the Santa Barbara Channel. 17. Platform Harry was abandoned and removed in July 1974. 18. This error has been corrected in the revised Air Quality Baseline section II.G.l. 19. Suggested revision has been incorporated into the text where noted. 20. Produced waste water discharged at a depth below the ocean surface doe: not guarantee that some degree of very local osmotic shock or high sail concentration gradients do not occur right at the discharge point. However, the rate of produced waste water discharge is small in compar son to the net current flow through past the platform. Hence, normal sea water diffusion kenetics along with the constant renewal of the receiving water volume, result in very low constituent concentration just a few meters away from discharge points. Table 11-68 presents typical produced waste water characteristics from a Santa Barbara Channel lease. Produced waste water in the Channel is essentially similar in makeup and concentration to sea water thus its impact on the receiving water volume is very slight even with minimal dilution. Also section III.C.2.b. (1)(c)(i) of the DES discussed a monitoring study made on produced waste water dischage effects from Continental Oil Company activity in the Channel. 21. The Hillhouse discharge permit issued by the U„ S. Geological Survey may be reviewed at the USGS Pacific Area office in Los Angeles. It IX-58 was not reproduced in the DES since appropriate discussion of it was provided in section II.G.2.d.(3) of the DES text. The Geological Sur- vey does agree that receiving water quality does give some indication the effectiveness of effluent quality control and regulation. See sections II.G.2.C. and d. , and IV A 1 c anH a -p , CDA . 1 * c- and d. for updated discussion on EPA permits and regulations. 22. The 1974 date was correct and discharge has essentially been eliminated in favor of subsurface injection into platform wells. 23. We concur. Additional data is presented in section II.F. 9 .a., Commercial Fishing. Intensity of fishing is an important factor. 24. Negative aspects of platform structures are addressed in the DES in a manner which was felt to be adequate and appropriate. 5. The purpose of including municipal discharge of chromium into the Channel in this section was not to justify additional, much smaller amounts of its discharge by oil operations, but rather, to merely put such additional discharges into proper perspective. >• Ferrochrome lignosulfonate (Q-Broxin) has recently been used in some Santa Barbara Channel mud systems. The weight given is the weight of the mud components added to the sea water, not the weight of the sea water plus the other mud components. • dilution and dispersion of discharged drilling muds would be a function of mud type, and discharge rate, concentration of constituents, sea water characteristics, discharge regime, water column exchange rate. Hence, generalization on drilling mud dispersion would not be useful. sc 3 IX-59 29 Reference is at end of paragraph. 30. The reader is referred to the OCS Order casing requirements in section IV.A.l.g. 31. The comment is acknowledged and estimates of spillage have been re¬ assessed. The difficulty of making accurate predictions of spill rati, using data, much of which is from a number of years past and from Gulf of Mexico OCS operations, is known. 32. The recommendations are noted. Pipeline routing would be regulated by appropriate State, Federal, and local entities which would likely rest' in the avoidance of marshes or other unique habitat to the extent feas sible. in any event, environmental considerations would be taken intc account for a site-specific proposal. t n 7 a for construction methods for pipelines and 33. Refer to section I.D./ 0 a. roi III.D.l. for impacts from same 34. See table III-17 for acreage estimation of onshore facilities 35. Frequently, there is more than one storage tank and also, normally, there are several treating and separating facilities that would conta a portion of the oil. 36. This paragraph simply indicates that a major onshore spill resulting from landsliding and flooding during wet weather would be more diffu to contain and, depending on the facility location, oil could possib reach the near shore marine environment. Normally, during dry weath the impact of an onshore spill is relatively local as compared to an offshore spills IX-60 37, See table HI-17 for acreage estimation of onshore facilities. The estimated figure of 30 acres minimum would be the amount of native habitat removed and would be for the life of the facility, about 40 to 50 years. See the revised and much expanded air quality impacts section III.LL.l.b for onshore facility air emissions. >8. Refer to the revised and expanded section III„LL.l.d. which addres the air pollution impacts of oil spills. ses 9. Page ni-120. We concur, however, this is a direct reproduction of CEQ publication. Page III-133. Please see revised references, section III. 0. The text has been revised for consistency with these observations. The text has been changed also to include the National Academy of Sciences (1975) finding that there is no evidence for food web magnification in the case of hydrocarbons in the marine environment. reac ^ er is referred to several more recent forecasts, '* The table has been deleted. Refer to the revised and much expanded sections on Oil Spill Air Pollution Impacts, section III.LL.l.d. and Onshore Facilities Air Pollution Impacts, section III.LL.l.b. Refer to the greatly revised and expanded Baseline Air Quality and Air Quality Impacts sections II.G.l., and III.LL. respectively. JQI 5a . ..1 . .• * . ■<» a via aa IX-61 45. This is a summary section. For added detail see section II.F.9.a. ar b., Commercial and Sport Fishing. 46 The statement has been deleted, 47. One mile has been changed to 1/2 mile. 48. OCS Orders 11 and 12 have been included, also, the status of other existing OCS Order revisions has been updated. 49. The Coast Guard and Navy are indicated in section IV.A.4.b. as agenc that have clean-up equipment and capabilities. 50. This name change has been made. 51. The Clean Seas inventory of clean-up equipment has been updated. 52. It is noted that the Coast Guard is presently considering a one-foui mile boundary from sea lanes. 53. We recognize Kolpack-s observation that oil slicks in 1969 followin, the Platform A spill penetrated a short distance into suspended sed ment plumes and refer to this observation at the bottom of page III Due to mixture of the oil with sediments and formation of tar balls is unlikely that oil would cover bottom sediments over any signific area. 54. The text has been modified. 55. Reader is referred to other portions of text which go into detail c all these aspects. 56. Refer to the greatly revised and expanded Baseline Air Quality an IX-62 Quality Impacts sections II.G.l., and III.LL. respectively. 57. Refer to section II for cataloging natural for impacts. resources and section III 58. Refer to the revised and expanded section VIII.G. on the alternative ot energy conservation provided in the FES. ■?*« -■« ■as* LIBRAS t United States Department of the bureau of mines 2401 E STREET, NW. WASHINGTON, D.C. 20241 Interior August 5, 1975 DES 75-35 Memorandum To: Director, Geological Survey From: Subject: Director, Bureau of Mines Shelf Off California Personnel in our Western Field^gaf development in OCS lands lying this draft statement for oil and gas ^ ngltude 119°, and east of generaUy north of ^ u f ’ t the 0CS in the Santa Barbara Channe. the Federal Government to date. 1 A wealth of information has been provided^ phases of offshore drilling. is adequate. However, no offsho oil and gas are discussed. The statement page H-383, Jo^of* their^ajo/sand and gravel resource populated areas face depletion gravel deposit can be set in'the next three decades unless a ^ contain p as natural resource zones for fut and the bot tom sediment the Nation’s future sand and gra where sand and sr££2 js: s . “s ........ - - future needs. Also the statement would ben ®^ t resource^other than oil and pageSlS.^the^areas"surroundin^hardware^nstallations, platforms, au 2 must he restricted S from P any 1 type of^eve^opment^^hifs^atement^DES^fas . zrjtsz?:; :^ s jZr:^ s : lthdrawn — sr&JZZ? l t the e fo i ur a vol^ e t s°of Sh t i he b dr t Ift n s tat ‘T ° f £hiS Statement Outer Continental Shelf and £ ^ ^ OCS Sale No. 35, it should be noted. Page 1-20 1»=? California, statement recognizes the "Prnnnco^ t? ^ * ast P ara 8 r aph, of this Geophysical Exploration in the Outer “* ZSLZfZSZTZ DES ^30 “? —^ - -e^^t-s 30 ^ 0 ™^ .. c ? ,, „ / p fl DES 75 ' 30 * For instance, on page 1-22 Part r Shallow Coring and Soil Sampling " and Part ttt_a 7 \i o ut* rt C ’ w P °S ii q iES : r .r^rfto such^equirements ^f^ wel^done? ^ P ° lntS ralsed above, we believe your statement is a job TJS* • - ^ J’J '<3 A 5 ‘ '*» A ;. “• A Q 'ca ■*£ Qfl CD Z3 RESPONSE TO BUREAU OF MINES Presently no minerals other than oil and gas are extracted from the Santa Barbara Channel OCS. However, in the future it is possible that sand, gravel, phosphorite, manganese and other minerals could be recovered from the ocean floor in paying quantities. Mining of such minerals could be accomplished with minimal conflict with existing oil and gas operations. At present, offshore mining technology for the retrieval of authigenic and terrigenous mineral resources is in its infancy. At such time as proposals for commercial extraction of thes< i • cita HpEttigcI cond.itions and stipula submerged minerals and techniques are defined, tions to further minimize possible conflict can be prepared. (See section II.F.13) 2 . See section I.F. 3 .a. for a discussion of the relationship of possible levels of oil and gas development considered in this statatement to those resulting from OCS lease sale 35. IX-66 or jjg PLY REFER TO: E3035 ES 75-35) United States Department of the Interior BUREAU OF OUTDOOR RECREATION WASHINGTON, D.C. 20240 JUL 2 41975 Memorandum To: From I^jLrector, Geological Survey * /^ >Director ' Bureau of Outdoor Recreation Subject: Review of Draft Environmental Statement, Oil and Gas evelopment m Santa Barbara Channel Outer Continental Shelf off California (DES 75-35) continental environmental statement, submitted by your S fflS fcrSe - “-tion “ r*”"» long as they remin contaminated wi?h ^ he^ S ? means are emnlov^D in i ' nurtner, if mechanical loaders and other earth movin^em"^ op ^ ations (bulldozers, front end Santa Barbara ana a -t S. ^Quipment) as was done following the "ay be unset by bei50'eTOval Pll FT inCi ^ entS ’ then shoreline equilibrium can lead to erL-innui ^val. Excessive removal of beach materials example, are avaiSl P S blem ? ml \ SS enough sand 311(1 gravel, for * , are available to replace the removed beach materials. A IX-67 2 Director, Geological Survey loss of sandy beaches for recreation ndgh Aesriactfc^jeopardlzfpossible inclusion into the afore- mentioned types of reserve status. Although the DEIS indicates tot the P-sence^ of^re^oil structures will enhance the recreational fishg. ta ke advantage of that only a very small user grou? will be ^® s Ss are allowed (or this opportunity, andthencnlyi to the drilling structures. In addition, it has been stated by the ^ ^ S portsfish (DES 75-8, OCS Sale No 35 tna £ q£ ^ catch following the Santa Bar P Therefore any statements catch during comparable six-month periods- te S £ questionable, regarding potential net gain re | e nt oil incursion could result gs-^s ■js.-arss ^ ..— in the final EIS. «,il, « .g~ that potential «P*f' » “™*““ SuSET impacts most likely to occur, f 1 ^ofar asis possible, historic losses in recreation opportunities phases rf £ SOU rce the final EIS should quantify impacts dur g P length 0 f tine development. Areas needing clariixa during pipeline construction, that recreation beadies clean-up time and nearshore waters made turbi § reflect’the fact that clean-up costs. Further, the fmal EIS shou steajn my be more detri- tiseaTifetoTeaving the sifcstrate untouched or mechanically cleaned only. On page III-199, in the last sentence, the term "would” should be changed to "could." 'XSfsSttX §sfif I* “ p,ci£ic Southwest Regional Office can furnish this information. The final EIS should mention that ev ®^ ^jj^L^^^e'entry^nto the pollutants is expected to occur (section III L 3), tne enrry IX-68 Director, Geological Survey atmosphere of large amounts of volatilized or combusted hydrocarbons sulfur oxides, and oxides of nitrogen may not only adversely affect ’ human health, but may also fatally damage forest treef Tech^iSf KS S„“ a ™ 5 «« ETiJSSL « California Air Resources Board, and the Southern California Association of Governments (SCAG--Air Oualitv particularly fetation of such in^ac^^b^ p rticularly inportant m view of Los Padres National Forest’s n,™t ™WQ le ~^% Plan Whl S h giV6S P riorit y to protection of watershed values, maintenance of aesthetic quality, and enhancement of recrea- t^r 1 ?P portunitl( r s » and also because the National Forest is expected .Si 'SXS/EXT ° PP ° rt “ , " S » replace the. 1«, a? Thanlc you for the opportunity to comment on this project. BUREAU OF OUTDOOR RECREATION 1. The information presented is appreciated. Section III has been modified to note this information where appropriate. The Sport Fishing Institute has expressed, in the letter reproduced elsewhere in this section, its opinion on the use of platforms for sport fishing. You state that the final EIS should reflect the fact that cleanup operations, especially with detergents and steam, may be more detri¬ mental to sea life than leaving the substrate untouched or mechanically cleaned only. According to the California State Oil Spill Contingency Plan, the use of any such substances "shall be supervised and enforced by the Depart ment of Fish and Game.” That should help prevent any significant dam¬ age to the marine environment which might result from the cleanup itself. 2 . For the purposes of this statement, the county breakdown was considered sufficient. However, your informative input as to the breakdown coastal LSWCF-funded projects separate from the county groupings is appreciated and is provided to the reader, following this response. IX-70 Project 138 134 258 19 5 338 133 372 294 151 359 95 299 145 237 385 306 305 170 34 245 298 246 238 236 311 210 119 273 378 379 422 314 351 309 274 256 111 115 350 283 213 415 6 7 C iifornia Coastal Land and Water Conservation Fund-funded projects (Data received from Bureau of Outdoor Recreation, December 1975 ) Number Project Title Aquatic Park Acquisition Aquatic Park Development Berkeley Fishing Pier Marine Park Alameda Creek - Coyote Hills Par San Leandro Shoreline Pk Dev. Point Richmond Shoreline Park Dev Martinez Fishing Pier Point Pinole Clifford Kamph Memorial Park Fort Ross State Historic Park Acquis Mouth of Mad River Fishing Acces Abalone Cove Beach Acq. Nicholas Canyon Beach Acquisition Torrance - Redondo Beach Acquis Beach Acquisition Long Beach Marina + Park Dev Long Beach Marina + Park Acquis Beach Lot Acquisition San Pedro Public Fishing Pier Will Rogers State Beach Dev. Dockweiler Beach Development Cabrillo Beach Development Redondo Beach Park Santa Monica-South Bay Bicycle Trail Upper Tomales Bay Wildlife Area McNear’s Beach Park Bay Front Park North Bay Front Park Richardson Bay Lineal Park Dev Richardson Bay Lineal Park Acquis Russian Gulch State Park Noyo River Fishing Access Manchester State Beach No. 2 Manchester State Beach Addition Del Monte Dunes Bolsa Chica State Beach Sunset Beach Parking Bolsa Chica State Beach Addition Huntington Beach Addition Main Beach Park Acquis-Phase II Main Beach Park Dev Crescent Bay Point Acquisition San Clemente Beach Acquisition San Clemente Beach Development Total Obligation 24633.00 154581.00 43082.76 100000.00 819996.64 93743.00 249900.00 67848.50 773911.00 20298.00 371535.00 39592.28 1428000.00 1486650.00 202470.00 140250.00 188777.00 127500.00 158545.00 372233.40 449055.00 325380.00 111479.66 189465.00 626918.00 153218.87 166199.82 267750.00 344811.00 22950.00 0.00 130560.00 49573.00 178500.00 100470.00 759504.00 393214.00 489064.50 1938000.00 649984.00 174420.00 318240.00 280500.00 280925.00 8319.00 IX-71 California Coastal Land and Water Conservation Fund-funded projects (Data r ® ceiv ® Bureau of Outdoor Recreation, December J ('Continued') Project Number 341 249 304 269 343 268 404 97 11 27 10 226 407 375 253 243 175 174 301 289 9 8 13 14 420 386 131 93 141 247 266 130 109 296 Project Title Total Obligation . Doheny Beach Acq. Mission Point Development Cardiff State Beach Addition San Onofre State Beach Project Batiquitos Lagoon Beach Access Carlsbad State Beach Addition "j" Street Beach Access Buena Vista Lagoon Wildlife Area Mission Beach Aquatic Park Ocean Beach Park Mission Beach Acquatic Park Harbor Drive Bicycle Path Dev.. Ocean Frontage Access Acquisition Warmwater Cove Public.Acess Dev Pismo State Beach Addition Foster City Regional Park North Montara Beach Pacifica Fishing Pier Ellv/ood Pier Project Leadbetter Beach Restroom Shoreline Park Shoreline Park Shoreline Park Shoreline Park . .. . Castle Rock State Park Acquisition Moran Lake Park Acquisition Santa Cruz Pier Twin Lakes State Beach Add Stillwater Cove Park Acquisition Gualala Point Park Development Point Mugu State Park Expansion Emma R. Wood State Beach Acq. Hollywood Beach Park Mandalay Beach Acquisition 313869.00 197217.00 825500.00 173400.00 50524.00 331500.00 56100.00 127500.00 127990.69 74190.53 7800.00 166260.00 85935.00 32706.00 388933.65 331500.00 313650.00 563151.00 61200.00 28050.00 100000.00 325000.00 1175000.00 25000.00 19890.00 51000.00 117292.81 131325.00 99450.00 108936.00 2149650.00 691050.00 28050.00 994500.00 The identification and quantification of potential air pollution emissions and their impacts from the possible levels of Channel dev, ment have been addressed in full detail in the greatly enl g quality and air impacts sections H.G.l. and III.LL. Also the las three lines reflect a "worst case" condition, and assume the Los Pa IX-72 IX-73 SPLED-E DEPARTMENT OF THE ARMY LOS AN<5 eues o.stk.ct, cohps op engineers LOS ANGELES! CALIFORNIA 90053 30 July 1975 ~Mr. Henry W. Coulter Acting Director U.S. Geological Survey U.S. Department of the Interior Reston, Virginia 22092 Dear Mr. Coulter: o t-n vmir letter of 10 June 1975 in which you This is m response to your let environmental impact TtSft Toirri 2 Development. in the Santa Barbara Channel Outer Continental Shelf off California. The proposed action is not expected to interfere with Santa Barbara Channel navigation. The draft EIS indicates that drilling may thafthelisks onirs“^e r =;duej:/^^ e rifr sthetic SLSvf :f C riS%r e th°e u S se of large tankers which conic 1 represen a bigger threat of oil spill than does an onshore dri ?his impact should he discussed in the draft EIS. Thank you for the opportunity to review and comment on this draft nhnhompnt' . Sincerely yours. IX-74 Mr. Henry W.Coulter Acting Director Geological Survey United States Department of the Interior Reston, Virginia 22092 Dear Mr. Coulter: We have now received additional comments from the National Oc e anic_ancl Atmospheric Administration on the draft environ- mental tmpact statement on "Oil and Gas Development in the nta Barbara Channel Outer Continental Shelf Off California These additional comments will, therefore, supplement our letter of September 2, 1975, on this subject. General Comments: silrfarhar! ru ° U and g3S devel °P™ent in the Santa Earbara Channel, area can probably be predicted with some degree of accuracy. The impact of this development var^aM ? r t0 predict beca use of the large number of relat:Ln S to potential catastrophic events (i e fan « S ^° nS a/ arthq !f k6S ’ blowouts . etc.) The statement address the dm P acb of a number of such catastrophic occurring slmult aneously or in close proximity to events°wh^ r h ^ ?1 S °, fails t0 assign any probability to events which are likely to occur. is b ?ter much le f "u th . tke draft environmental impact statement is nn? information on the marine environment a S , current enough to allow valid environmental impact assessments to be made. The statement should include which ^ commendati °ns for future biological studies are outd U J d aUSment th ° Se portions of the data base which '^ 6 - 191 * IX- 75 2 . Specific Commentsj_ VOLUME 2 . IX. Description of the Environment Biology Marine Biology Barbara Channel Region Marine Organisms of the banra naru Sublittoral Zone (to approximately ) E. 2 . a. (5) p.r. r ph_a, ^“•rx I '! 5 £ S”,s; 3 ‘ l> rs;«, b, Ulp Sd. around the offahor. Island, SpfaLSr’^d^a Sid Sd^dToSC, mob L referenced figure. Table 11-21 Page 271. The total percentage of classified communities has been - incorrectly added. This should be corrected. r (b) (i) Pelagic Environment Nekton Neritic Nekton , 7Q Snpr ies list. The tabular list of species includes ling cod and the table should be separated on that basi . (8) Marine Mammals Table 11-25 Page 288 Additional occasional or limited seasonal visitors to the"cTaifornia inshore waters include the ^° w ^' aenop t Pacific Right Whale ( Balaena glacia ■-— » whale (Physeter borealis). Finback whale (B. physalu ,) P H w Pnroois' assy. ^ sp*»»».«.ssss 1 * “,S" ( FLuv caudon), Pygmy “"* ; c : ai;;l b:ir5 -hal«. (FamiLy 7 inhiidae) mciuae: dcuiu o — "- '--—- . , Hubb’s Beached Whale m^nplodon carlhubbsi), and Cuvre Beaked Whale ( Ziphius Cavrrostrrs). IX-76 3. rable 11-28 Page 289 . The Totals in years 1969 and 1970 are incorrect. 7. Fishing i. Commercial Cable 11-43- and 11-44 345-348 - Several of the total pounds and total value figures presented in these tables have been added incorrectly ind should be refigured. $. Mariculture u Kelp } ^ ge 357, paragr aph 1. The annual dollar value of kelp larvested in the Channel area should be provided if ivailable. b Air and Water Quality •• Water Quality >. Water Quality Objectives 2) Areas of Special (Biological) Significance ag.e 405 paragraph 3. Areas of special biological significance ■eed to be more explicitly defined. "Waters surrounding the anta Barbara Channel Islands" does not provide enough inform- tion to determine the exact extent of the area under consideration. . Waste Discharge Related to Oil Production 4) Produced waste water from State and Federal Santa Barbara hannel platform b) Federal Platforms 421, Figure 11-47, . The column indicating the concentration settable solids" has been mislabeledo 11 • Env ironmental Impact of Santa Barbara Channel Oil and as Development. Impact of Drilling and Production Platform • Construction Phase IX-77 ^ l •*« g *•' a g 1 I** - * & i** 4 . 10 Pa£» IX-79 DEPARTMENT OF COMMERCE (September 16, 1975) One must recognize the remote possibility of a number of catastrophic events occurring simultaneously. However, it is impossible to assign probabilities to a situation that may never have occurred during the history of oil and gas operations. Refer to section III.K.l.b. for a discussion of the problems involved in assigning probability to poll ment in the Santa Barbara Channel. For general spill probability discussion see the excerpt from the "Council on Environmental Quality 1974 Report--Statistics on OCS Accident, Oil Spill, and Chronic Discha: (section III.K.3.) • Also see section III.K.4.; this section on Santa Barbara Channel spill probabilities has been added to the final state* 2 . AS noted, there are deficiencies in the available data base. Specific recommendations for future biological studies are properly within the charter of the academic co-unity, research institutions, and local, State, and other Federal agencies-in addition to the U.S.G.S. Continued biological studies are being sponsored by BLM. Hopefully these will augment the data base. Please see response to hearing com no. 11. (section IX.A.) (pertaining to pages 2 through 5) The specific comments are useful, and the text has been changed accor 3. The arithmetic ic has been recalculated and changed in the text 4. Please see added note on table 11-21. Addition was incorrect m the original source IX-80 5. The text reflects these changes. 6. These figures have been corrected. 7. Refer to expanded kelp harvest discussion in section II.F.10. 8. See section II.G.2.b.(2). 9. The figure has been corrected as necessary. 10. Sentence deleted. Tables 1-1 and III-17 in the DEIS indicates the total number of platforms expected will be between 10 and 21 and the increase in tanker traffic will be insignificant. The determination of platform siting will consider environmental factors such as effects upon marine mammal mitigation. Therefore, the impact on endangered cetaceans should be negligible. 1. The statement is noted. The data presented is that available. 2. OCS sewage production would be several acre feet per year per platform. 3. Without a site-specific proposed plan of development, it is impossible at this time to obtain site-specific information. Future consideration however^iH be given to pipeline routes, case-by-case at the appropri- Section III.L.l. has been revised for clarification and substantiation. figure III-9. Spillage from U. S. offshore operations in 1970 was 13,285 tons metric, less than 1/3 of 1% of the total from all sources. Worldwide offshore operations contribute 100,000 metric tons or 2% of the sources of oil pollution. These figures do not include natural seepage. of ocean In section III there are several presentations of percentages pollution from various sources (e.g., tanker spills compared to spills all other offshore oil and gas operations). IX-82 tJI 1 a ED STATES DEp ARTMEI\IT OF COMMERCE Washington, D C. t 202°3 C o retarV f ° r Science and*Techn*^ogy September 2, 1975 Mr. Henry W. Coulter Acting Director Geological Survey United States Department of the Interior Reston, Virginia 22092 Dear Mr. Coulter: The draft environmental impact statement "Oil and Gas SSJT £ "c,H, e S “ C \ B \ rblra CcJlLtal June 10 1975 hH ’ WhlCh accom P^^d your letter of June 10, 1975, has been received by the Department of reviewed and IhTTo 1 i" d . COmnent ' The statement has been consideration " 8 comments are offered for your S S2d enV ItT ental f atement is carefully prepared should 1 y/ Passional job, and the editor should be commended for his work. One section in Volume 2, pp IH-122 to III-124 is deficient presented on Md ocean °*™Phic d *ta leasehold PP ' 53 throu § h 11-175, and the prospective estimati a ^ as as niapped on Plate I, a much better job of prob“n n p 0 iits P oi ential r 0il S Z il1 drift trajectories and have been P done The mPaCt -? n - h ° re and lsland beaches could spill d!? , The compilation of drilling platform oil employ^ contained in pp. III-100 through III-109, when be ised t^est^T^r WUh the above infc ™ion, should under at least ® 31:63 ° f potential im Pact with time the cnltnl" • ? fOUr “J” seasons of the year, and for areas 2 ?“ extremes of wind and sea. These affected facto h ld be . IMpped and a brief discussion of the physical in the S srr iUn8 , at aach location should also be treated . section on Contingency Plans, pp. IV-32 to IV-50 -mrtatrons of oil spill recovery techniques caused by »lso in the W r at i 6r 3nd S6a conditions should be addressed S0 m the Contingency Plan section. dOtUT/O* m - 6-l9l IX-83 2 . There should be more ta^environ- ment ^'particular" at ten tion 3 ^ should be paid to the impact on any coastal wetlands. Chronic oil spUU S,S"S « Z V^Z’to’JZl “f 1 .^ S-w o£ detecting the., .held not automatically, the p more efficient methods be ignored. Further res th e effects of of detection as well a continued In any area where these chronic « « Chronic Uaks -HI cans. .Ignlflc It 1. determined that such c consld „,ti„„ should be g environmental disruptions, bei. .1 3rp?) to curtailment of operations in that particular area. The seismic condition, of th^.re. “”^1. research^establishment of an adequate seismic disturbance researen, escu f,, vt -her development of sturdier plattc detection system and furthe J . , hazardous areas whe There should be no development in highly hazardous adequate protection can not be provide . The detailed discussion of technology and practices through, the draft environmental feguards against adverse'effects on the environment ^ pertaining to undersea pipeline^(PP; ^ also seem to provide goo p leaks that occur, with early detection and rapid remedy for leaks tna Zi “ui/S’r^Lei fern dL.l.p rf , sl: z zXZ 1 ztzsssn ^ Thus, the environmental impact seems f" matter, the If more information could be developed on this environmental impact statement woul IX-84 Thank you for giving us an opportunity to provide these comments, which we hope will be of assistance to you We would appreciate receiving eight copies of the final statement. Sincerely, ->J£u Sidney R. Gafller Deputy Assistant Secretary for Environmental Affairs IX-85 UBKiUii iim L» /. nF.PARTMENT OF COMMERCE (September 2, 1975) 1. Estimates of oil spill trajectories for several locations and conditions are addressed in the expanded section IH.L.l. on Oil Spill Trajectories 2. Limitations of spill recovery equipment and techniques are included in sections IV.A.4. and IV.A.S. on Contingency Plans and Status of Oil Spi] Containment and Cleanup Technology, respectively. 3. The discussion has been expanded in section III.M.l. With the very limited amount of wetlands (estuarine, lagoon and marsh) extant in the area under consideration, it is inconceivable that construction of shore treatment facilities would even be contemplated in these areas. The possibility becomes even more remote with the issuance of the final California Coastal Plan (see III-168 of the Plan) Your recommendations are acknowledged. The special considerations give to "Areas of Special Biological Significance" and to cultural resources protection accomplishes to a considerable degree your recommendation or curtailment or restriction of operations in particular areas. All research results will be considered as they become available, and environmental aspects will be carefully considered. 5. Refer to section I.E. and table 1-2 for the estimated potential oil an gas production from the possible levels of oil and gas development. IX-86 ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OCT 2 1975 Office of the Administrator Dr. Vincent E. McKelvey Director U.S. Geological Survey Department of the Interior Reston, Virginia 22092 Dear Dr. McKelvey: The Envircmmental Protection Agency in accordance with it- ^ti't e i atlon of a fifth developmental level which'would 1 defer all Urther leasing or development of deepwater or high risk tracts n 3ur ^comm^ndatlonTr'consld^at 1 ^of CTifth d de “ onstrated - aaximiJ efficTen^^ WhUe acMeV “g ; “«"**>*1 ft*" »hteh, T w h he S „“’mp'lTSM'f Soe“Xv h ,, *oSs , "? , ;'H* , ' =c ** or «.d«ie d..X5;„r ction be tak n tn f . actlvlties ’ We recommend no ecessarv nia • f0i3ter add itional development until the icourage theTonfinn a , ccom P lished - ^ addition, we would iploration'or development^in tl^ar^ ^ ^ f ° r “ Sed A ■4 ■“Mi ■A3 - rm . 3 ■ -r+» •«» IX-87 a cAli In summary, we would have ^^^."“^^in^additional about selection of options thr * uture leases . Our specific exploratory activity on exist g strengthened, and focus on comments detail areas that could be^stren^^d impact s. The the analysis of anticipated deepwater technology issues, remainder of our comments deal with deepv focu3 Qf the the proposed National Energy Reserve, ana environmental impact statement. we thank you for the opportunity to hument lonV forward to receiving the fmal btatemem Sincerely yours, * x> f y / i * p C^Pi O' V 4i Sheldon Meyers * * Director . Office of Federal Activities If Enclosure i IX-88 Environmental Protection Agency Comments on Draft Environmental Impact Statement for Oil and Gas Development in the Santa Barbara Channel Introduction The proposed Federal action under consideration involves selecting one of four different levels of development for oil and gas resources m the Santa Barbara Channel. The possible levels of development are: (1) continue production from existing leases; (2) develop new production from existing leases on which oil and gas capable of being produced in paying quantities has been discovered; (3) explore and subsequently develop existing leases on which no discoveries have been made in the Santa Barbara Channel; or (4) lease, explore, and develop presently unleased acreage in the Outer Continental Shelf (OCS) of the Santa Barbara Channel. This action is most significant in that it contemplates a vastly increased commitment to development and production of oil and gas in the area. The Santa Barbara Channel is adjacent to the major metropolitan complex on the West Coast; it is an area renowned for water oriented recreational resources, ind an area of known geologic hazard. EPA commends the Department of the Interior for preparation of a grammatic environmental impact statement encompassing the entire >anta Barbara Channel and for the concept of the four-level analysis. PA believes that this programmatic environmental impact statement & a necessar T and important input to the significant actions being ; ontemplated. IX-89 UBKAKs it, l utsiSHi'ui-isiiteHit However, as the comments which follow indicate, we encourage preparation of environmental impact statements for any subsequent site specific decision on exploration, development or production activities. The exploration, development, and production activities which follow leasing of OCS lands involve widely varying impacts depending on the extent of reserves discovered and the rate and timing of development factors which are presently unknown and must be assumed. Our comments focus upon six principal areas of concern: (1) the environmental risks of deep ocean drilling requiring radically new deepwater technologies; (2) potential conflicts regarding the Proposed National Energy Reserve; (3) onshore impacts; (4) mitigation through intergovernmental cooperation; (5) offshore development and associated impacts; and (6) time focus of the EIS. Environmental Risks of Deep Ocean Drilling — The draft statement contemplates oil and gas development in water depths considerably greater than have been attempted in other United States OCS areas. The costs and the technological difficulty of ocean drilling, platform and pipeline construction, and facility opera¬ tion and maintenance increase exponentially as water depth increases. New and as yet untested technology, including subsea production systerr will be required to develop oil and gas resources in these waters. The risks of deepwater OCS development are compounded by the acknowledged geologic instability of the Santa Barbara Channel. On page 445, Volume 2 of the draft environmental impact statement (DEIS, for Lease Sale Number 35, the Bureau of Land Management noted. IX-90 "The capability of a subsea production system to withstand an earthquake, slumping, sliding, or other potential geologic hazard is unknown at this time. » In the absence of proven fail-safe technology, EPA believes that subsea completions cannot be considered as a viable alternative. Furthermore, because of the lack of technological information and empirical evidence on which to base a reasonable judgment that development of deepwater tracts can be accomplished without unacceptable environmental damage, EPA has environmental reservations about proposed actions that would result in offering tracts requiring the use of untested technology. EPA strongly recommends consideration in the final statement of a fifth level of development of the Santa Barbara Channel. This level would propose postponing the sale or development of tracts with the greatest risk or which are in the deepest water while continuing exploration on existing leases for the purpose of confirming the levelopment possibilities of known potential oil fields. Once the levelopment potential of the existing fields had been confirmed, evelopment of those discoveries could proceed in shallower waters 'ith the least environmental risk. An economic benefit could accrue y reducing the requirement for the more sophisticated and costly reduction techniques needed for high risk or deepwater tracts. As evelopment proceeded into deeper waters, there would be oppor- WltleS *° U3e P roven technology and to test and demonstrate new rototype deep water technology. IX-91 Since the Santa Ynez Unit involves a platform for water depth much greater than that of existing Channel production platforms, EPA recommends that if all approvals are granted, new deepwater technology employed in the installation and operation of this platform be closely monitored. We suggest all monitored information be m ade available to the public and the rest of the industry so that future leasing decisions might include consideration of experience with these techniques. In this manner, development might proceed in an orderly fashion into deeper waters with a minimization of risk to platform workers and to the marine environment. In this connection, we also recommend consideration be given to a special provision for the implementation and testing of subsea production facilities in the Hondo Field to provide more experience with this type of technology as well. Further, if this fifth developmental option were implemented in the Santa Barbara Channel, consideration might first be given to the proposed platform on Lease V-P0202. This action might then be followed by further exploration of the unnamed potential field in the Santa Clara Unit on Lease I-P-0215 and the unnamed potential field in the Pitas Point Unit. When information on new technology for the above areas had been analyzed and after new deepwater techniques had been demonstrated in the Hondo Offshore Field, the Sacate Offshore Field might be considered. IX-92 In view of the potential risk of deepwater operations employing new technology in a seismically active area, EPA believes it is essential that OCS leases include language which informs bidders of investment risk. In the event that subsequent research or experience determines that development of certain leases or development with certain tech¬ nologies is environmentally unsatisfactory, it is important that the Department of the Interior have appropriate language in the leases which would retain the maximum legal options that are available within the existing authority. This would permit the Department the utmost flexibility to modify (and perhaps to deny) operating permits, and to provide an opportunity for public involvement. d Potential Conflicts A ssociated with Proposed National Energy Reserve ' "* 1 Approximately 85 percent of the total California State lands offshore, including the Santa Barbara Oil Sanctuary, are held in petroleum resource sanctuaries that are legislatively excluded from any petroleum drilling. Large areas of potential Federal offshore leases and the proposed National Energy Reserve are adjacent to either State leases or State petroleum resource sanctuaries. Production on the Federal leases could deplete State reservoirs and prompt the State to accelerate its own production. If Federal production threatens to deplete reservoirs within California's Petroleum resource sanctuaries, the State is bound by the sanctuary legislation to begin drilling and production within the sanctuary. The final environmental impact statement (FEIS) should clearly Identify the extent of this potential conflict, and assess the environmental impact of any induced or accelerated State activity lue to accelerated activities on the Federal leases. IX-93 EPA is especially concerned about the leasing of tracts within the proposed National Energy Reserve which lie adjacent to the three mile limit bordering the Santa Barbara Oil Sanctuary or the nearly pristine Channel Islands (including Anacapa Island which has been designated by the State of California as an Area of Special Biological Significance). EPA is also concerned about the leasing of tracts within the proposed National Energy Reserve which lie within the shipping lanes, require deep ocean drilling and/or may lie atop geologically hazardous areas. The complexity of assembling a new boundary for the National Energy Reserve is appreciated. However, EPA believes the final statement should provide a full discussion of the range of options and impacts of the proposed National Energy Reserve. Onshore Impacts The development of the Santa Barbara Channel OCS will result in secondary onshore impacts. Onshore activities and facilities which are required to service the construction of and production from OCS oil and gas facilities include oil platform fabrication sites, boat docks, storage yards, pipeline corridors, pumping stations, tank farms, intermodal transfer facilities and onshore pipelines. Oil refineries, petrochemical processing facilities and electrical generating plants are among the activities and facilities which will seek locations in the coastal zone in order to take advantag of the availablity of OCS oil and gas produced either as a raw material or as a source of energy. In turn, these facilities and activities will induce incremental additions to community facilities such as roads, sewers, schools, housing and transit facilities and other public IX-94 services. The product of this complex matrix of change is of particular concern to EPA because of serious potential conflicts of coastal land use and resource management with the ability of State and local governments to provide the necessary urban infra¬ structure, and with the ability to control the generation of waste ■esiduals in the form of wastewater discharges, air pollutant missions, and toxic materials. It is clear that secondary effects ■f OCS leasing and subsequent production, as they are manifest over ime* will be equally as important While the DEIS generally does as the direct and primary effects, a commendable job of disclosing 16 dir6Ct and primary effects and mitigative actions for OCS etivity in the Santa Barbara Channel, the discussion of secondary ■fects and mitigation measures could be improved in the following tstances: Socio-Economic Impacts The discussion of socio-economic impacts in Section III is edicated upon population and employment projections for the State California prepared by the State Chamber of Commerce. No stification is provided for using the Chamber of Commerce projec¬ ts versus the official projections of OBERS or those published by 5 State Depart ^^t of Finance. The projections used in the DEIS ' ° nly exceed the current offici al Dioo series baseline values, but ^ alS ° eXC6ed the upper limit Panning estimate of the D150 series. In g he employment benefits of OCS development, the DEIS cites Chamber of Commerce estimate of 170, 000 new jobs needed annually ‘ewide through 1980. There is no explanation as to why these figures preferred over those of the State Department of Finance. IX-95 b The secondary pricing effects throughout the economy, pubUc revenue impacts, and equilibrium effects of the proposed action are not adequately analyzed. The DEIS omits opportunity costs relating either to the four levels of OCS development in the Channel or alternative energy sources. Thus, for example, the discusston of energy requirement impacts on page III-186 states that OCS development will provtde critically needed energy supplies but onuts a discussion of the net or balance concept of energy products. There should be consideration of the net energy products from the Santa Barbara OCS, particularly in deep water, versus alternattve energy sources, including for example, the alternative of increased conservation and "storage and shut-in capacity" discussed m IBS, gnergy_Poll£y: Alternativ£3_^or_Security i _^££2Hl£S^2il-^2_^li^i^- c . Ultimately, (in 20-30 years, but with peak production expected eight years after discovery) the economic activity associated with development of nonrenewable OCS resources may end. The social and economic costs of adjustment to this potential outcome must be considered in assessing regional economic and environmental impacts the post production period the sponsors of significant OCS employm and capital investment will have to discover new economic purposes, possibly in the face of smaller energy supplies. Irreversible commitments of land to urban uses induced by OCS related activities will make it difficult, if not impossible (see page III-3), to continue to rely upon the current agricultural and tourism economies of Santa IX-96 3arbara and Ventura Counties. In addition as noted on page III- 13 , 'Disturbance to commercial fishing operations. .. . could vary from ninimal to significant. " With the aerospace industry. Southern California has already seen the long-term difficulties which resulted rom rapid and intensive growth of one facet of the economic base nd the impacts following the demise of that economic sector. To ae extent feasible, the final environmental impact statement should onsider this major long-term consequence of the proposed development ivels, the Federal responsibility and opportunities for mitigation, nd the alternative of a balanced (mix of energy sources) energy evelopment program on the economic well-being of the area. d. The DEIS (page III-181) states that over an eight year period •e peak labor force required in Santa Barbara and Ventura Counties ■r OCS development in the Channel will be about 3, 500 employees. rom this, it is concluded that "any aggregate socio-economic ipacts within the Santa Barbara Channel area are expected to be mimal. The basis for these projections are unstated, and it pears that these projections consider only employment in primary CS fieW devel °Pment activities, thus possibly understating the real pacts on population, shifts in economic markets, and public services. 16 ° EIS em P hasize s the economic benefits of OCS development, but Is to analyze the economic benefits of developing alternative sources en ergy, thereby leaving the impression that the benefits are unique OCS activities. On page III-117 the DEIS speaks to the issue of the relationship 3CS Channel development and California's self-sufficiency in oil by i0 - The implied significance of this discussion is misleading since IX-97 X Sft t r if? California, as a State, does not represent the sole market for OCS oil and gas and since evaluation of other energy alternatives, such as increased conservation and storage and shut in capacity are not examined in the same context. f. The discussion of probable impacts upon the recreation industry appears incomplete. For example, on pages III-183-185, a summary by Mead and Sorenson of the costs of the 1969 Platform A oil spill is Cited. This summary, which is not in 1975 dollars, lists the property value loss as $1, 197, 000, yet attendant note (5) indicates that $4. 5 million has been fully recovered by property owners in a class action suit. These estimates of loss are for a single event and do not represent the impact of greatly expanded oil development and transport being considered for the Channel. Nor does the summary consider the unknown risks of deep ocean operations. Similarly, on page III-199 it is indicated that 'Development activities could cause increased turbidity of that water in localized areas, making swimming undesirable; conditions would return to normal with no lasting effects. " But on page III-180, it is indicated that the development phase could last fifteen years, and again the long term cumulative impact is not analyzed. g. The discussion of impacts of not developing OCS resources (III 186-189) proceeds from an assumption that a growing energy demand must be satisfied, thereby discounting conservation. From this assumption of a critical need for energy, the DEIS singles out one sector, environmental protection and pollution control, to illustrate the essential nature of the demand. The analysis consider the very small relative contribution to energy demand of IX-98 Pollution control versus such other sources of demand as private iuto usage, which in 1973 represented 38 percent of nationwide ■nergy demand. mpacts of Oil Support Facilities on Water Quality Since Los Angeles is expected to be the major staging area for ICS activity, and production operations are expected to concentrate i Los Angeles/Long Beach, it would be highly appropriate to provide baseline inventory of existing oil support facilities. The DEIS ownplays onshore impacts by virtue of the existing industrial lfrastructure. However, to say an area is already industrialized lys nothing about its ability to sustain more industrialization rapidly, he degree of onshore impact depends on the availability of existing cilities and the rate of offshore development. The DEIS treats the onshore environmental impacts of the opot>ed program primarily in the aggregate, while the most gnificant impacts could in fact be localized in areas such as )s Angeles/Long Beach Harbor, and coastal areas of Santa irbara and Ventura Counties where pipelines come ashore or 3ra ge and refining complexes are developed. NPDES records indicate that presently, the refinery capacity thin California is approximately 1. 6 million bbls/day. The DEIS hcates that there may be as much as 2 billion bbls. of oil in ' ° CS lease tracts in the Channel. There are additional reserves the Southern California Borderland area as well as in State terS ' The FEIS should estimate the need for additional refinery city and the corresponding need for any public investment in Cities to handle the wastes from such development. IX-99 nui * iff* 10 11 Although existing sources are now under NPDES permits and abatement schedules, the longer range implications for petroleum related facilities development may be to increase the mass burden of industrial wastewaters discharged to the ocean. The FEIS should demonstrate that every effort will be made to minimize and abate any further stress. The DEIS does not discuss the total quantity of solid and liquid wastes (including toxics) that will be generated by onshore activities and the availability of disposal sites over a 40 year production phase. Refineries, for example, may generate large amounts of either solid or dissolved salts. A study conducted by A. D. Little for the Council on Environmental Quality has estimated that a 100, 000 barrel/day refinery with no water discharges of pollutants will generate 10, 000 tons of solid wastes per year. Ancillary petrochemical complexes would result in an additional 19, 000 tons of solid wastes per year. The disposal of oil from oil spills, which must be anticipated in such operations, poses additional problems. Other environmental impacts of refineries include the need for offsite water resources. Cooling water may be ocean or fres depending on the location of the refinery. The March 1975 Preliminary Coastal Plan of the California Coastal Zone Conservation Commission contains a number of policies which will tend to limit the immediate coastal zone as a location for new or expanded refineries. Therefore, much of this water demand may have to be filled by inland water sources. The lowest estimate of water used by an oil refinery which uses water cooling is 25 gallons of water per barrel of oil, though most existing refineries use hundreds of gallons of water per barrel. IX-100 Therefore, a 250, 000 barrel per day refinery would require at a _ minimum 6, 250, 000 gallons of water per day. The DEIS inadequately examines the impact of onshore support facilities and related increased population on fresh water supplies. The hydrology discussion for the DEIS clearly indicates that onshore areas bordering the Channel are water short, that groundwater resources are being overdrafted, and that there is a serious threat of salt water intrusion. While the DEIS considers the effect of the 20 acre feet (page III-80) per year of water used by a single onshore treatment facility, it does not consider the cumulative consumptive requirements of all support facilities and increased population that will accompany full development of the Channel’s oil and gas resources Neither does the DEIS consider the impact of this demand for water on such consumptive uses as agriculture and municipal growth. Impact of Oil Support Facilities on Air Quality In the Southern California area, air pollution has reached critical proportions. State and Federal efforts to abate the pollution to attain the National Ambient Air Quality Standards (NAAQS) have led to the adoption of many control strategies which affect the Federal OCS leasing program in the Channel. The siting of refineries and associated petrochemical industries in the Southern California area may be severely restricted due to air pollution considerations. In addition, it is not possible to dismiss casually the relation¬ ship between petroleum consumption and air quality, particularly m the South Coast Air Basin. The DEIS discusses only beneficial air quality aspects of increased oil and gas production. Plentiful supplies of these fuels may in microcosm reduce pollution. IX-101 as is asserted, but the principal use of most petroleum produced and refined in California is for transportation within the state. The South Coast Air Basin has the most serious oxidant problem in the nation. In addition, ambient concentrations in excess of NAAQS for nitrogen oxide, particulates and carbon monoxide are common throughout the area, and high sulfur dioxide levels have been recorded. Increased refinery activity in an area presently violating the NAAQS could substantially interfere with the attainment of each of these standards, both directly and as a result of associated petrochemical industries. The air quality will be further exacer¬ bated not only by accelerated leasing and production of large quantities of oil in the OCS area south of Ventura, but also by the shipment of Alaskan crude oil to the area for refining. Refineries and petrochemical facilities in particular will be carefully regulated; any new expansion will be required to utilize equipment to meet new source performance standards (NSPS) and must secure a permit from the Air Pollution Control District (or EPA) prior to construction. Due to the existing severe oxidant problem in the South Coast Air Basin, emissions of hydrocarbons will be very closely scrutinized, and any aggregate increase in total mass emissions of hydrocarbons may be the basis for a permit denial. The very limited land in the presently industrialized area of the South Coast Basin suitable for major new refineries indicates that capacity increases will occur by replacing obsolete units with I new units capable of meeting NSPS. To the extent that the new units I have improved emission characteristics, overall air quality standard may be maintained. Although the environmental impact statement is intended to be IX-102 programmatic EIS, the following items are appropriate for discussion of air impacts in the final environmental impact statement since the total level of activity on the Santa Barbara Channel OCS leases may be significantly affected. a. The ability to process and refine Southern California OCS and imported oil consistent with all applicable air pollution regulations in the South Coast Air Basin, including de-sulfurization capacity. b. The estimated or probable sulfur content of the Santa Barbara Channel OCS oil and the air pollution aspects of utilizing OCS oil for electrical power generation in the Southern California service area. c. The estimated or probable emissions of volatile gases and reactive hydrocarbons that may be derived from drilling and trans¬ shipping operations in the Federal OCS and the impact that meteorological transport of these gases into the Air Basin will iave on air quality. d. Alternative locations for onshore petroleum activities within Southern California that minimize air quality impacts such as fringe >reas of the South Coast Air Basin, areas outside the South Coast hr BaS “’ and inland ref ineries using dry cooling towers and served ’ y Plpeline from th e Channel and Los Angeles/Long Beach Harbor. e. A quantitative estimate of the contribution of Santa Barbara >CS development to the cumulative air quality impact of all Southern alifornia OCS oil and imported oil. The estimate should consider impact resulting from routine onshore operations and of signifi- oil spills, suc h as those that might accompany seismic activity l °ng the coast or a large tanker accident in the Los Angeles/Long each Harbor (page 11-80-81). IX-103 ,5 0 , #v;\ i ie* «K*’ Mitigation of Onshore Im pacts The FEIS Should address the overlapping Federal, State, and local jurisdictions and the appropriate roles for each in mitigating the extremely serious onshore environmental impacts associated with the proposed action in the Santa Barbara Channel. November, 1972, the California Coastal Zone Conservation Act was enacted to provide long-term planning for coastal resources now widely recognized as irreplaceable. The California Coastal Zone Conservation Plan will be submitted to the California State Legislature for adoption on December 31, 1975. The inherently large scope and impact of offshore oil development activities could preempt areas of concern in the plan. The award of leases prior to completion and adoption of the Plan would mean subsequent drilling, production, transportation, and refining ativities which could conflict with both onshore and offshore plan elements now being refined after extensive public hearings. The potential conflict with the Coastal Zone Management Plan assumes even greater importance since the jurisdiction of the Coastal Commissions includes not only the immediate coastal zone but also the Channel Islands. Federal development of the California OCS will require pipelines, onshore storage tanks, and related production facilities. These developments will require the approval of the Coastal Commissions, and if any facilities are located on submerged State lands, the State Lands Commission. Coordination between these becomes increasingly important as efforts accelerate to exploit the offshore oil and gas resources. IX-104 EPA recommends the Department of the Interior direct special attention in the final statement to delaying exploration and/or development (as described in the third and fourth levels of possible activity in the Channel area) until onshore impacts of OCS develop¬ ment, including cumulative environmental impacts, have been defined sufficiently to enable formulation and implementation of long-term mitigation commensurate with the scope and timing of the impacts. In the Santa Barbara Channel this would mean the postponement of further development of new fields or new leases until legislative adoption of the Preliminary Coastal Plan (no later than December 1977). While the proposed coastal plan provides, by far, the best effort to date to mitigate the adverse impacts of OCS development and plan wisely for its benefits, efforts are underway to refine and improve further the ability of State and local government to manage their environment. The National Oceanic and Atmospheric Administra¬ tion has allocated $300, 000 to the California Coastal Zone Conservation Commission to improve State capabilities to plan for and manage the projected or potential onshore impacts induced by Federal OCS IX-105 actions. Among the specific uses of these funds are establishment of siting criteria for OCS support facilities, identification of appro¬ priate and inappropriate sites and conditions, formulation of controls on siting and operation, and analyses of impacts and timing of additional induced growth at various levels of OCS development. In addition, the Federal Energy Administration and the Department of Housing and Urban Development have joined with the State Lands Commission, State Energy Commission, State Office of Oil and Gas, Air Resources Board, State Water Resources Control Board and other State agencies to determine onshore OCS impacts in Southern Californi and the adequacy of State management capabilities by July, 1976. Offshore Activities and Associated Impacts OCS Discharges : The discussion on discharge of produced waste water (page III 20) generally implies that brines are relatively harmless. This conclusioi is made in the absence of any supporting data except for a single sample taken from a platform that no longer operates. As mentioned in the draft EIS for OCS Lease Sale 35, there is little data that relates to the impact of continuous discharges of brine waste containu heavy metals, oil, and other toxic substances such as ammonia and phenols on the marine ecology of the area. Dos Cuadras, Carpinteria and Hueneme Fields : Pages 111-38-40 discuss further development of the Dos Cuadras and Carpinteria Offshore Fields and Hueneme Offshore Potential Fiel The final environmental impact statement would be improved by an estimate of how many wells and how many platforms are necessary IX-106 for the development of a single oil field. For instance, is the purpose of proposed Platforms C and Henry in the Dos Cuadras and Carpinteria Offshore Fields to recover the oil resources in a more timely manner _ or are they necessary to recover all the available oil in the fields 7 . Transport of Oil ; EPA has received the results of its contract with Booz, Allen and Hamilton. Inc. entitled A Risk and Cost Analysis of So uthern California Outer Continental gh-if The alternative transport modes considered are tankers or barges and pipelines While none of the three oil fields evaluated were in the Santa Barbara Channel, one considered transport from the Santa Rosa Cortes (North) Field to Ventura. Pipelines were found to be the least costly alternative for all three sites evaluated, with the cost decreasing as distance to shore lessened. Furthermore, the estimates of total volume of oil spilled over the life of each field indicated that pipelines are safer by a factor of 5 to 7. Earthquake risk was not found to be a significant factor in estimating the volume of oil spilled by an offshore pipeline over the life of an oil field. Based upon the results of the above study and factors cited in our comments on the DEIS for Eease Sale No. 35, EPA believes that tanker Wd barge operations from this area are inferior to pipelines. EPA further concurs with the DEIS and CEQ conclusions that oil transport V Pipelines has less environmental risk than transport by tanker or * r§e ‘ EPA encou -g es consideration of lease stipulations which would that the safer mode of transport to be used so that potential udders could plan accordingly. The final environmental statement h °uld also discuss the environmental impacts of the several IX-107 LBftliiu v* l uteiiivrbtitii* lor , pipeline .0 r.Iinerle. in .to U» pos Beach area. Oil Spills : While it i. true that there i. no oonclu.iv. evid.nee the, . m„or 0,1 spill result, in long-.,™ topee, on the «*» «*—' ,h, res.on it i. true 1. hee.u.e little is known ebon, the long-tern, topee, of Oil pollution. Therefore. . »— «“ * h "* is no long tern, top.ot he. no sci.ntiiie be.is. The DEIS .re... the environment.! topee.. 0 , oil iron, the proposed OCS Channel development activities primarily in the aggregate, while the most significant impacts could in fact be localized. Thus, for example. Figure in- 9 "Sources of Oil Pollu¬ tion to the oceans 1969-1970, " is not particularly meaningful for estimating the pollution contribution of shipping and offshore production in the Santa Barbara Channel because of the concentration Of OCS activity and shipping (including Alaskan crude oil transport). The aggregate level of oil spills must be put in the perspective of number, magnitude, location and recurre nce for meaningful impact analysis to be performed. Oil Spill Cleanup Regarding rte technology of oil spill cleanup and control, the section entilted Status of Oil S p ill Containment, and Cleanup Te chnology (Pg. IV-48) may be misleading. This section states that "... the oi industry has developed safety equipment and procedures that . • • provide for effective cleanup in the event of a spill. The material which is presented to substantiate the quoted statement consists of a IX-108 listing of the equipment owned by or available to Clean Seas, Inc., (the cooperative which would most likely clean up a spill in the Santa Barbara Channel), a report that the Exxon Bottom tension boom . . . contained natural seep oil in six-to-eight foot seas, " and a brief description of the USCG High Seas Boom. However, testing of oil spill control equipment at the EPA OHMSETT facility, under controlled conditions, has revealed that both inland and especially offshore equipment for spill control has a great deal of development effort yet to be performed before we can confidently state that the technology of cleanup is "effective". While the DEIS seems to make clear the probability of a major spill from a platform, the actual nature and consequences of a cleanup operation are not presented. Mitigatory Actions for Offshore Impacts The environmental impact statement should fully discuss overall coordination of Federal and State offshore production as well as cooperative planning among the relevant agencies and oil companies in order to minimize the impacts of development. The discussion should include consideration of the following topics: IX-109 a. In regard to coordination, BLM should consider the require¬ ment of a lessee's submittal of a 5 and 10 year plan of development for the use of the local governmental units. Such a plan would outline the schedules of offshore development in relation to the construction of onshore support facilities. This plan could serve as a vehicle for planning coordination and act as an early warning device for possible conflicts. b. in the past, the location of pipelines and support facilities serving the OCS has been determined by industry initiative and economic incentive. To minimize construction in offshore and onshore areas, every effort should be made to unitize (share by more than one company) pipeline rights-of-way, marine terminals, and storage and separation facilities. In addition, wherever possible, unitization with oil operations in the State submerged lands should be accomplished. c. The areas around the existing ocean outfalls are known to contain highly organic substrate and high concentrations of heavy metals and DDT. Pipeline routing should completely avoid these areas in order to prevent resuspension of these deleterious materials. d. All pipelines and/or channel dredging in existing harbors where high concentration of heavy metals in the sediment are known, should be carefully performed (i. e. no jetting) to minimize resuspension. Serious consideration should be given to land disposal of all polluted spoil with clean fill imported to backfill over pipelines. e. Pipelines should be completed and in operation prior to the commencement of production in order to avoid the use of barges with their known high spill characteristics. IX-110 Time Focus of the EIS : The EIS would be improved by focusing on phases and cumulative effects. The DEIS attempts to identify the time frame for various separate activities expected to occur during exploration, development and production phases. However, the discussion of timing is fragmentec throughout the statement. As a consequence, the statement does not take into account the cumulative effects of OCS activities in the Santa Barbara Channel on the marine and the onshore environment. The cumulative effects of oil and gas extraction activity in the Santa Barbara Channel cannot be viewed in iso i ation from the addmve impacts of other proposed or likely development, including increased scs activities elsewhere in the Southern California Bight, increased anker traffic due to crude oil imported from Alaska, LNG tanker and erminal operations, and deepwater port proposals. EPA appreciates he difficulties of forecasting cumulative impacts over time. However, a the absence of such considerations, the actual impact upon the ocial, economic and environmental condition of Southern California ould be seriously underestimated particularly with respect to onshore npacts. For example, before California will have significant new Tshore production, "imported" oil will already be arriving via ^er from Alaska. And even with successful OCS development in e Santa Barbara Channel, it is likely that Alaskan oil would continue come into California for trans-shipment and eventual pipeline Moport to the Gulf of Mexico refining and distribution centers. WS ’ deSPUe the conclu si°n in the DEIS that OCS development may esent fewer environmental hazards than continued reliance on lk6r imP ° rted 0il ' California will probably have significant Atonal tanker traffic with or without offshore development. IX-111 EPA believes that the FEIS should catalog the other major energy related developments that will be occurring at the same time as the Santa Barbara OCS development and attempt to project at a macro level a range of cumulative impacts over time. IX-112 1. Deep water development is actually a part of three of the four possible levels of development presented. Prior to approval of any deep water proposal the state of the art will be assessed. For example, the Exxon Submerged Production System is presently being tested in the Gulf of Mexico (see section I.D.6.d.(2J) for several years prior to being con¬ sidered for installation at greater water depths such as in the Santa Vnez Unit Santa Barbara Channel. Prior to acting on a request for such a deep water installation, the Geological Survey would take into con¬ sideration the results of all testing, including several years of off¬ shore subsea field operations and also diver depths capabilities. (See section I.D.6.b.(2) for an updated discussion of the rapid advance¬ ment of deep water diving capabilities) As drilling progresses into deeper waters technology must evolve to resolve certain problems and the Geological Survey must assess the technical capabilities and past drilling performance in progressively deeper waters prior to acting on specific deep water drilling proposals. The OCS Orders must be revised (primarily OCS Order No. 2) as the need arises in order to insure proper regulation of such deep water operations. The recommendation to defer further leasing or development of deep water tracts is acknowledged. Variations of this type alternative are discussed in section VIII.C.D. and E. The recommendation to await the completion, approval and adoption of the State Coastal Plan is acknowledged. If a final Coastal Plan is opted by the California Legislature and approved by the U. S. Depart¬ ment of Commerce pursuant to the Coastal Zone Management Act of 1972, IX-113 . Tni'p'rioT or of Federal oil 3.nd g&s the activities of the Department of Interior lessees directly affecting the Coastal Zone shall, to the maximum ex¬ tent practicable, be conducted in a manner consistent with the approvec coastal zone management program. Tbe discussion of the Coastal Zone Plan has been updated and expanded in this final statement. (See sections I.F.Z.a., and IV.A.l.h., the hearing comment No. 26, and response No. 38 to the Resources Agency of Caliiornia (*h. Coastal Zon, . _ , , or p o nart of these comments.)) Commission comments were a pa . Decisions as to the need for site-specific statements will be made on a case-by-case basis in accordance with NEPA procedure. in light of the first sentence of the introduction to the specific comments, the following clarifying comment is made. The Federal Gove: ment is not proposing the four levels of development (they are E£ssib) levels of development); nor does the statement suggest the "action under consideration involves the selection of one of the four possibb different levels of development." The purpose of this statement is t consider impacts that may occur as a result of these possible levels of development. (See the Preface and section I.A. for further explan tion as to the purpose of this statement) Neither do we consider tin to be a "programatic” EIS. Only additional leasing would constitute imder a well-established program. Departmental program initiative, under The concerns relating to deep water drilling are acknowledged. (See the response No. 1 above to this concern expressed in EPA's letter transmitting these specific comments) The status of subsea production systems has been updated m this fm IX-114 statement. The various systems are described and the status of the Gulf of Mexico field testing of three of the subsea systems is dis¬ cussed (see section I.D.6.d.). The testing of these three prototype systems has thus far been satisfactory. These Gulf of Mexico tests are contributing significantly toward the evolution of deep water systems of the future. A new subsection has been added to this final section I.D.6.d.(7) "Industry Assessment of the Current Status of Technology in Subsea Well Completion Techniques and Subsea Production Systems." Comments as to subsea production system status from indus¬ try in response to a Department of Interior Federal Register Notice request, are summarized in this new subsection. The recommendation that consideration be given to special provision for the implementation and testing of subsea production facilities in the Santa Ynez Unit Hondo Field is acknowledged. (See section I.D.b.d. ( 2 )) 5. In section I.D.6.b.(2) two recent (June 1975) dives to below 1,000 fe< described. One of these dives to a water depth of 1,069 feet in¬ volved recovering a blowout preventer stack. This dive was performed from the drilling vessel Handrill, Offshore Labrador Canada for a consortium headed by British Petroleum Canada. The ranges of options and impacts relating to the area that was once proposed as a National Energy Reserve is presented in section VIII.F. Your concern as to the possibility of leasing within the Federal Ecolo, ical Preserve and Federal Buffer Zone (which are adjacent to the State Santa Barbara Oil Sanctuary) is acknowledged. This is discussed in section VIII.E.3. and 4. should this restricted area adjacent to the IX-115 Santa Barbara Oil Sanctuary become available for leasing, the possi bility of drainage from submerged lands within the State Sanctuary would exist. However, contrary to your expression, the text did not intend to indicate that any consideration is being given to the possi¬ bility of making the Federal Ecological Preserve and Federal Buffer Zone available for leasing. The intent was to explore the fullest possible range of possible future activity. The Federal Ecological Preserve and Federal Buffer Zone is discussed in the introduction page ii.10., section I.E.S. and section VIII.E.3. and 4. Response to these comments is provided in the expanded Socioeconomics baseline and impacts discussions in the final statement. (See sec¬ tions II. F, Resources and III.N., Socioeconomics Impacts) On page 11 of the EPA comments the figure of private auto usage is 38 percent of the nationwide energy demand in 1973. October 1975 statis¬ tics indicate private automobiles account for 13 percent of the uses of energy and 28 percent of the uses of petroleu m (7 percent of the latter which is for all urban commuting). (Source: Automobile Club of Southern California, October 1975, Auto Club News Pictorial, p. 2) We believe that the differences in statistics cited are significant. 8. Most activity related to the possible future levels of Santa Barbara Channel Development appears likely to be concentrated in the Ventura area rather than Los Angeles. Any refining capacity requirement on the Los Angeles area would be a result of market demand and woul likely result only in a substitution of domestic for foreign crude stocks. IX-116 The socioeconomic, ecological, and aesthetic impacts are addressed in the revised sections on those subjects. (See sections III.N. and III. L.) 9. As noted in response No. 8 above, any additional Santa Barbara Channel production would likely be substituted for foreign crude feed stocks in existing refineries. If this should be the actual case, addition¬ al refinery capacity would not be necessary. Refinery capacity is developed to meet market demand, not crude oil supply. 10. Waste water discharge regulations are discussed in sections II.G.2.d., IV. A.l.c, d., and g. of the FES. Those sections concern -Regulation of Waste Water Discharged into the Santa Barbara Channel OCS Waters," and the "Pacific Area OCS Orders No. 7 and 8." 1. See response No. 8 above. The concentration, makeup, and quantity of produced waste water is a function of the formation of origin, state of reservoir development, and recovery techniques. Therefore, to exactly predict the quantity and quality of produced wastes is not possible for the potential levels of development of the Channel. Refer to section II.G.2.d. for results from existing Channel production. For an estimated range of the quantity of produced waste water that might result from the possible levels of Channel development, see table III-17. !• An expanded discussion of water demand, consumption, and waste water treatment has been provided in the enlarged Socioeconomics Baseline section II.F. on Resources. IX-117 13. *:- L - “ iM ““ “ d * lr quality ....... - ,n ^' ““ tl «l, (bd.l, greatly U «-> —«**>• ™ "““” d I number “ d each po.aH.. lev. •< *»■<*“' “ ^ ‘ „ d ,. 2) . Table 111-17 quantitative "« impacts. Rationale to, d.,l«i"g q, ,b. table. Tab,., .1.-7 - U- .« • W"”" 1 "' frame ter .be possible ...,» of *»»■•»-“• *t.i. » of a summary of unavoidable adverse effects that would result from OCS oil and gas activities related to the four possible levels of develop- ment ' 7 T.ve effects, we would not predict significant cornu- Concerning cumulativ > f h the biological communities, as a resu lative impacts, on the biologic . ,, indicated throughout this state possible levels of developmen . P , nt nroceed without unforeseen mishaps when exploration and development proceed ,i.. short duration. Keco accidents, impacts are minor and generally i -fvnTtt outside the sm3.ll of destroyed organisms is largely supp i impacted. impacts are significant when accidents resulting in oil spill* occur Th e impact of chronic oil spill pollution is discussed . to ^ extent it is presently known, in section HU- Accor g rpsnect to time and loc large spills would occur unpredictive y n q riiscussion of cumulative ation and too infrequently for meaningful discuss effects. IX-124 FEDERAL ENERGY ADMINISTRATION ' REGION IX 111 PINE STREET SAN FRANCISCO, CALIFORNIA 94111 HAWAII <7 JUL 3 1 1975 irector, U. S, Geological Survey apartment of the Interior -ston, Virginia 22092 iar Sir: oVaTgas^ 7 ° raft ““1 2sss*s Dort -Q fn " w ® st 1 Loa ? t lf we are to reduce our needs for foreign oil out in the EIS chapters dealing with the overall energy picture. have the following specific comments: ita S Barbara a channef 5 eCt i ° n refiner y rapacity of different levels of 3 ecessarv t0 wp h « Stat ® me " t that burial of subsea pipelines appears cautions’to prevent oineV r" d ® talled ex P la nation be included of wlers dravinHw - P P 5 UptUres due to lar ge ships, other than » ggmg their anchors over uncovered pipelines. IX-125 - 2 - JUL 31 1976 Section IIT.0.2.. Impacts on Air Quality o?! Depending upon the type of air poll the on-shore treatment and storage oil and gas may not be "very minor as in ica e te significant amounts of treatment plants, and tank farms may inc i ul ie completely enclosed- hydrocarbons to the atmosphere unless th^ ^ should be vapor recovery systems for all on-shore facilities. pointed out. Section IV.A.5 c-oi-hq nf Oil Spill Containment and Cleanup Technol oj Although comment is made reg **; d ^ g ^ V eg er no 1 mention P is made of capabil tension booms in six- to probability of contai f p^SL^spiU would be available, if probability of sea-state conditions during various seasons were given. Sincerely, / -v. -v ^.v v ( U EUGENE W. STANDLEY Energy 0 Resource Development Programs Division o atfS! (C C IX-126 response to fe deral energy administration . Refinery capacity is developed to meet market demand, not crude oil supply. Since the United States is reliant on substantial imports of foreign oil, the overall effect of possible OCS Santa Barbara Channel development would be to displace an equivalent amount of imported oil, thus decreasing the degree of dependence on imports. Only an increase in consumer demand on the West Coast exceeding present refinery capacity would result in the need to expand that capacity. Should market demand require increased West Coast refinery capacity, the specific locations of proposed refinery expansion and installation by the industry would be controlled to a large degree by the Coastal Zone Commission and the State Air Resources Board. (California Petroleum Refinery Capacity table II-54c has been updated in tnis final statement) The possibility of a pipeline rupture due to anchors dragging is considered in the statement. Table ttt i • j- II-l indicates one major spill as a result of anchor dragging. This Gulf of Mexico incident occurred in 1967. The 160,000-barrel spill volume is attributed to the lack of adequate pipeline leak detection at that time. Pipeline deak detection and Shut-in systems in operation today serve to minimize spill volumes in the unlikely event such a pipeline break should occur. Our records no major pipeline oil spills have occurred offshore California in State or Federal OCS waters. The historical record does not indicate justification for pipeline burial in a P P me burial m deep waters except in certain unique cases. It was suggested in the SYU-FES (74-20) that Pipelines totally buried may not withstand earthquakes as effectively Pipelines with portions remaining on the surface so that more independent flexibility relative to the surface can be maintained. IX-127 3. The identification and edification of potential air pollution emissions and their impacts from the possible levels of Channel deve ; , . r q detail in the greatly enlarged Air m ent have been addressed m full detail tt r 1 and section IIIoLL. Quality and Air Impacts sections II.G.l. _ fn rleanup and containment capabilities 4o All available information as to cle P tv a 4 and 5 The Clean Seas Inc. inventory c presented in section IV.A.4. and . onui nment has been updated in this final statement Please see table waves of various -6, Monthly percentage frequency of occurrence dghts and periods in the Santa Barbara Channel. IX-128 HT rck y United States Department of the Interior fish and wildlife service WASHINGTON, D.C. 20240 address only the director FISH AND WILDLIFE SERVICE ’ In Reply Refer To: FWS/OBS AUG 1 1 1975 Memorandum Director, Geological Survey Acting Deputy Associate Director, Fish and Wildlife Service E ^™ental Statement, Oil and Gas Development in tne Santa Barbara Channel Outer Continental Shelf off California (DES-75/35) ^„^, reVieWed bhe sabject statement in accordance with Acting Director Coulter s memorandum of June 10, 1975, and provide the following comments. It has not been possible for us to exhaustively review your statement nor examine a majority of the literature cited; however! we have noted a a!e Hs!fd S a Ctl T th3t re<5Uire addltions and ' or changes. Our comments sted according to sections and/or pages of the statement. The draft environmental statement provides an overview of the natural !he°!!!r S °U t !‘ e Sanba Barbara Channel. However, as a general comment, l3CkS balance - Engineering and geological aspects are presented m great detail but there is only minimal discussion of the possible impacts upon the flora and the fauna of the Santa Barbara Channel. San!! f a T d ( L 122) , that an oi l llne or lines could be routed from the M ar ara anneb north to either a proposed deepwater terminal at I/ ? ay ° r Montare 5'- The statement should include a physical description of these areas and their natural resources and the possible impact(s) of ocs development studied in this draft EIS. ® ecti0 ” concerning marine mammals (II.E.2.a.(8)) should reflect total Cha P°P ulatl °ns as well as the numbers found in the Santa Barbara " ™ area - This would allow a more meaningful quantification of the e impacts of OCS development upon marine mammals. For example, CONSERVE ^AMERICA’S |1 energy IX-129 t * f * - 2 - it should be noted that^the .-tin-ated^world^Pulatxon^of 363 ^° n ^6 0 h OOO C anf2iri f^3CT5~^pectively (National Marine LTsheresTerfi^VoM Fed. Reg. 39(122) =23903-23905) . , /ttt r ? a fl)) that disturbance to commercial fishing It is stated Cy-C-2.a.(l)) vary from minimal to significant de¬ operations by the platforms cou y sou „ ht ...weather, and currents pending upon factors SUC Statistics exist for the Santa Barbara Channel Since commercial fishery statl ^^ a f a p proach is possible. Analyses it would appear that a more an y existing platforms have in- should be conducted to determine if the . fluenced commercial fishing operations and/or harves V (ttt n 1 a } mav lead to the resuspension !?seK‘« rs‘■»£ pollutants^t^the^ediments^informat ion should be provided indicating _their distribution in the Santa Barbara Channel. Section III.L.G. states that the Bureau of Sport Fi concluded that if brant had been in the P q£ ^ space cou ld are during migration, almost the ent P P conment;s should be more have been exposed to exterminat . Bure au of Sport Fisherie specifically referenced. and wildlife Service, and Wildlife has been changed to the U.S. nsn an . tit „i 0 /'ttt T 7 d.) should include the The Summary of Impacts on Marine amm northern fur seals: conclusions reached by Kenyon , _ flir opals are found on migration they In most open sea areas where Detro i e um products. However, infrequently come in contamination may be when they enter busy shipping lanes, significant. Oil contaminated seals apparently do not survive to return to the breeding grounds. 1/ Kenyon, Karl W. 1971. The effect fsub™^ ■ ^;i B =rt f - Washington 98115. 9 pp. mimeo. IX-130 -3- 3. Since fur seals usually occur well offshore and the bodv is „f - would^arely^be^ound'on beaches^’ **** anll " alS W ° Uld S±nk and thus The statement should discuss in Hpha-i 1 j--l u • • result from the selection of a c ? Change ln lmpact which woul o I'P'Yi" Via.*? been modified accordingly• 3. The comment is well taken and the text has been mo Commercial catch and landing data for the general area in which the existing platforms are located have been included in the FES. Conclu¬ sive studies on the influence (if any) of those platforms on commercia fishing would have to be site specific. We are aware of no baseline studies conducted at the site prior to platform placement; therefore, information taken from studies which might be conducted now would be of limited comparative value. The comments regarding offshore pipeline construction are noted and will be considered in the event of a site-specific proposal. ,. This section has been rewritten for clarity as the Brandt cormora been confused with the black brant or sea goose and the United States Fish and Wildlife Service quotation, therefore, is not applica IX-132 The suggested literature citation is incorporated, although more recent publications (National Academy of Sciences, 1975; Kolpack et al., 1975 ) do not include these conclusions. Please see section I.A.I., Purpose of the Environmental Impact State- Estimated facilities, activities and production for each of the possible levels of development are presented in tables I-l and 1 - 2 . IX-133 or IN REPLY REFER TO: L7619 (WR)PSE United States Department of the Interior NATIONAL PARK SERVICE WASHINGTON. D.C. 20240 JUL 2 2 1975 Memorandum To: Director, U.S. Geological Survey , . . __ cprretarv for Fish and Wildlife and Parks Through: Assistant Secretary j-ul Fromj.c Associate Director, Park System Management Sub ject: ^” p ^ n fifthe V Sanw e Barbara a ch^nel ^Continental Shelf off California (DES 75-35) We have reviewed the draft environmental statement and offer the following comments for your consideration. COMMENTS ON THE PROPOSAL Is alloweHo take place within the proposed lease areas. ^tforms s : p^rxr £££ “^i — st to the surrounding natural beauty of the area. transport n where°large C quantities "hannellsiandsM ) 1 and^the^ighboring tsUnds^ich are presently effect°upon^endangered^species 1 habitat and recreational activity. ^IN IX-134 Considering the potentially adverse impacts to Channel Islands National Monument and the general Santa Barbara Channel area we cannot support any further development in this area. ’ COMMENTS ON THE STATEMENT There are two actions considered which mav i These are the construction of one or .ore »i« 1 t resources. the possible construction of onshore delivery pipelines^^a ’ref • center such as Los Angeles (page 1-3). Y P P to a refining All areas where onshore surface disturhancp ,• e i-i •, professional archeoloeist An v ye Q oy a be evaluated for their National Z g l st er TolZTA ^ criteria outlined in Title 36 CFR 800 lfi P t-h u' meet the to the National Register of historic piac^s " ^ be^de^vailabl^t^tbrNltionarp’ ^ ludin8 recommendations, shoulc L. the interest of promoting safe navigation and reducing t e po ® n * artnien of life and property at sea, OCS leases should be issued by the Departmen the Interior subject to the following conditions: "(i) Pprman ent platforms maY^gt_be_lpcated_wit hin on e' sea lane_boundariesT~^This stipulation is justified on v f organization gompliance with the Intei-governmental Maritime Consultative Organi IX-138 that enables vessel! to^^ig^^ith™^! 626 ? 3113663 3 navi S ation system siting sea lanes. Provision must be made fo/th! If 6 accurac ^ when tran- vessel up to one-quarter mile outside of an ° peratin S Ws navigation equipment tells him that hp i<= - f u. Wished sea lane whose boundaries. Second, the !ne-m er "d! Tf/" the charted sea lana ensure that servicing vessels^nd tarll d . ff ? r Z ° ne wil1 be necessary to kept outside of charged s^a lanL; ® at tendant to offshore platforms are -Vessels may nnf engage in rlr*-i1 1 • • i au^terjulguof^y^ transit, vessels jr?-- 2 ] ahQve » anii p koe p. t_foi^vessels in ,1 i if-the_District Commander has l» n „ inrd T^ tu*! Ual s ~-- e expre s s permiss i n’n District Commander direct control over the nn h aase P rov r s ion will give the In the_sea_lanes to ensure that these v!Iseird er ^ position of work vessels :o navigation; essels do not create unacceptable hazards -Subje ct to p rnviginn ( i 'd /oh „i J3i_E.ermanen t _gla tforms_will3e7p^^itted — within^the^se^^ation^z^ ~ --- ue . ^ eyara tion zones ; and l!iSS-may_hay e_no cabl!!! d a^ ^| Se y!n!!hr.ll t ~ aQ£ha ~ S -- SataMe - sf the SM ga-lanes^at^ epth of ]essTi^ ^l^?^'^ S£ ~ a§a ^^^ lB ^ ,lt ln thp ». "VI"? Tr“ to ° n "»» J »» Mress the concerns of the Coast Guard. 1031 Statement > however, should " opportunity to review this draft statement is appreciated. Sincerely, i « J. RILg/ /j Captain, S. Coast Giiard “"3 By direction of the Commandant IX-139 UUiintw The term "On-Scene-Commander" has been deleted. „ TntPTior acknowledges the District Commander's positi, The Department of Interior acKnowie g that OCS leases should be issued subject to certain conditions as liste In the event of a future Santa Barbara Channel OCS lease sale, the Depar men t of interior will confer with the Coast Guard in considering these recommended conditions, as well as an y other lease stipulations the Coast Guard recommends. IX-140 . UNITED STATES ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION WASHINGTON, D.C. 20545 AUG 1 1975 Mr. William E. Grant, Manager Bureau of Land Management Pacific OCS Office U.S, Department of the Interior 7663 Federal Building 300 North Los Angeles Street Los Angeles, California 90012 Dear Mr. Grant: Continental Sheif o« ^ ^ B “*“* Channel °“ t “ Energy Research and Develop.ent^ini^rati^^ ^ffindt Statement contains a * 7 ^ . We find the dwl1 , n „ . " 7 a great deal of information about offshore “,F : “E s A specific comment is that the first paragraph on pane VTTT S7 ® 1 !!* f e * rroneous impression that the measures takfn to prevent harmful releases of radioactive material from light water realtor nuclear power plants are of questionable effectiveness It is uggested that the paragraph be revised to read: "Some airborne and liquid radioactive materials are released to the environment during normal operation The beeT ho™ tT: d r Sma11 ^ P ° t6ntial -po^ure hL een shown to be less than the average level of natural radiation exposure. The plants are designed and operated in such a way that the probability of harmful radioactivity releases from accidents is very low." activity We appreciate the opportunity to review this Statement. r m J pvt'CUaff'th (W. H. Pennington Assessments and Coordination Officer Division of Biomedical and Environmental Research IX-141 1 . r - Your suggestion to remove the information about offshore drilling tech¬ niques not directly related to the Santa Barbara Channel area was considered. However, it was decided not to delete the general descrip¬ tion of drilling and development operations and techniques m the interest of making available to the reader an overall concept of pos¬ sible future oil and gas operations. Most of this general material is in Appendices 1-2 and 1-3 at the end of section I, and, therefore, does not disrupt the presentation of the more pertinent information. 2. The suggested paragraph revision has been incorporated. wkz": GK CX: IX-142 ORNIA MDS COMMISSION FFICE ector S. Geological Survey 108, National Center ton, VA 22092 'C- ^ x £$%/ W2mi CftW August 20 , 1975 1807 13TH STREET SACRAMENTO, CALIFORNIA 95814 USGS DES 75-55 Comments r Sir: *ct Statement a f or“potential 6 Oil V and ? f ‘n* "? raft Envi ™nmental ja Barbara Channel OCS Of? California " 5 in the lequate in that it fails to examine all ? lnd the statemen t - could result from unsnerif alE environmental impacts facilities in the Channel. P ° entlal Petroleum operations t be expected'i^the^'channel Trll “ S e “™l«ation as to what Miens/and is Semple tel ?toil nf a regardln S offshore extractive or analysis. t ' ompleteI > r V0ld of any site-specific discussion pending for OCS activities^in th^S™ 6 ? n ° a PP lica tions no specific actions k the Santa Barb ara Channel, and radictory, however, are pag^l! 0 ? ^of^i ln ^ report - a Mobil Oil Cornoratinn P ?Q7a 12 N? of . Volume U which state form on OCS Leas^ P-0202 is 7 he?n£ t ? ® reCt a dril ling Letion of this DES? g held ln abe X a noe pending >«.v=™, ro S°S,p t S h , r s?" “** 0ES ,S - 3S nation of additional for future actions without : or full public review and flc ^environmental impact state- opment. If such iV d dlscusslon o£ each proposed ssr«rr *«•««. •“.^"■ssrS £ “Lroi"% ,re *- ■ “ mpie ”' able for review f n d ^oii^enr a" mUS * b ® prepared and made do abundantly C l“r inTh? Pi A commitment to do so should tty clear m the Final Environmental Impact Statement □ IX-143 Director U.S. Geological Survey - 2 - August 20, 1975 Additionally, as has J^n^occasions? th^decision for Department of the In ^ ££ °rentiated from the exploration and the development (as di - continental shelf resources evaluation phases) of the oute national energy policy should be made in concert with a viaoi affected !uch policy must ^ developed n partners p^ ^ ^ earl i est adjacent states. ™is Partners P^^ ^ entire program. planning stages an j pve i 0D and implement a viable energy Further, in order to develop ana if exploration of the policy, Government should conduct t P q£ the petroleum OCS for definition of the location an^ bene£its and environmen resources as well as eva upvelonment and production operati risks which would ch exploration must be shared with Information garnered from such _ affected agencies on a cooperai As you are imminently awareiature^n 1 ^™^ Any Fede is to be submitted to the Sta e grated with this Plan. The .unit OCS development s ^ 0 p ^ t££n e should not be made the unwilling ' $ unreasoned 1 Federal S OCS development policy. Specific detailed comments on the technical aspects DES 75-35 are attached. Thank you for the opportunity to review and comment this critical subject. Attachment ds Comm. IX-144 UIFORNIA ANDS COMMISSION OFFICE 1807 13TH STREE1 SACRAMENTO, CALIFORNIA 95814 COMMENTS ON DEPARTMENT OF INTERIOR DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR POTENTIAL OIL AND GAS DEVELOPMENT IN THE SANTA BARBARA CHANNEL OUTER CONTINENTAL SHELF OFF CALIFORNIA (DES 75-35) sneral: Conspicuously absent from the Draft is an Executive Summary. The >sence of such summary hampers review and makes it very difficult to opsrly assess the report without exhaustive review of the entire •cument. Additionally, the Division was unable to identify any section which •cussed growth inducing and cumulative effects of OCS oil operations in arbara Channel. Inasmuch as these are required by CEQA and CEQ, • Division feels that it would be appropriate to incorporate these sections :o the final EIS. ‘S-ikili. This section, discussing the Santa Barbara Channel blowout spill resulting from the drilling of the fifth development well atform A is incomplete and misleading in its description of the V0Ut ‘ The rep0rt 8tates " Flo « the well was promptly controlled by IX-145 activating blowout prevention equipment; but because of usual geological conditions, this caused fluids fr<*n deeper reservoirs to reach the ocean floor through fractures in shallow strata.” The description contained with: McCulloch, U. S. Geological Survey Professional Paper 679-C and Appendix A, _ Geological Survey Professional Paper, would be more complete. Pag , q.23. L.9; The permit program for shallow coring to 500 feet and t 750 feet under certain conditions should be modified such that drilling wit out any blowout prevention control should be restricted to no more than 10C feet. We feel that drilling to such depths without proper well control is an unnecessary environmental risk. 8 T-.18. Subparagraph (a) and rape T-40, Subparagraph (dji These sections refer to B.O.P. installations on the conductor casing, set and cemented after drilling to depth of 300- to 500- below ocean floor. No mention is made of any B.O.P. installed Error to reaching that depth. Bot State Lands Division -'Procedures” for drilling operations and the U. S. Geological Survey CCS Order No. 2 specify that the Drive or Structural Casing (Called Conductor casing in State "Procedures”) which is set at a depth of about 100' below ocean floor shall have at least "one remotely controlled annular type blowout preventer and related equipment. installed prior to drilling below that depth. This is an important cmiss Furthermore, the statement beginning on L.6, Page 1-39, which reads "The blowout preventer assembly and riser systems are then installed and the actual drilling proceeds", implies that a complete blowout pre IX-146 is Installed on the conductor casing. This is not so as both the existing and proposed revised OCS Order No. 2 requires only one annular preventer and a diverter system to be installed on the conductor casing, and allows drilling to proceed to a maximum of 1500- below the ocean floor. The State Lands Division has commented several times during the revision of OCS Order No. 2 that this blowout preventer requirement is inadequate for exploratory in ning from vessels , and, has recommended that at least one annular preventer, one set of drill pipe rams and one set of blind-shear rams be . installed on the conductor casing. 1-41 and 1-42, Subparagraphs (1), ( 2 ). (1) rah Thef)e section8 relate to important design criteria and procedures for the conduct of drilling operations from vessels which presumably are established by Geological Survey OCS Orders. It is apparent that the writers of the DBS did not review the existing and proposed revised OCS Order No. 2 as these important requirements are not included. During the period that OCS Order No. 2 was being revised, the State Lands Division sent written comments to both the Chief, Conservation Division, U.S.G.S. in Reston, Virginia, and the Oil and Gas Supervisor, Pacific Area, recording that the scope of the drilling procedures be oaden to include specific and detailed requirements for drilling from vessel, similar to those identified in the DES. The State Lands Division firmly believes that the proposed revised OCS Order No. 2 is completely inadequate with regard to the conduct of drilling operation, from vessels, inless adequate drilling procedures are established to assure that this •yP* of operation will be conducted safely, drilling from vessels should mitted in the Santa Barbara Channel or on any other OCS lands. ‘ i* recommended that the proposed OCS Order No. 2 now being processed by be revised to provide specific requirements for drilling from esaels. IX-147 inn P T . T-AV L. 1 and Page 1-54, L. U These sections deal with B.O.P.E Drilling Fluid for well control purposes, but drilling personnel ^ualific for well control purposes are not mentioned, although drilling crew with trol drills is (p. 55). CCS Order Ho. 2, specifies that company and cont drilling supervisors shall have coveted a well-control school or semin* within the previous year and shall have passed a proficiency test; also , well-control training for drillers, other than the retired weekly blowo, vention drills, shall be required. In addition, it is suggested that co, L ation be given to formalised training for all drilling and production pe p nt .e 1-53. L 1.: This section implies that drilling fluids, liquid w water, and drill cuttings, once freed of oil contamination, may be disch into the ocean. However, as noted elsewhere in the report, regulations regarding the disposal of waste water and other materials into the ocear Lare currently under revision whereby such disposal may not be permitted, 11 P. r T.82. 1. 28.: It ia abated "Wellhead equipment is specifically designed for hydrogen sulfide service and maximum wellhead pressure". > wish to point out that this generally is not true. Only if the hydroge sulfide problem is known to be present will wellhead equipment be so de The EIS is totally lacking in an adequate discussion of the special han and greater potential environmental risks Involved in the production of sour crude oil* 12 Pave 1-83 and 84; The lengthy discussion of velocity-actuated safe, devices is irrelevant as these device, are not permissible in current extractive operations. IX-148 - £ C 1-92 ■ The Ungthy dl3CU8Sion ° f Proprietary equipment for ocean floor completions does not take into consideration proven operating .Imitations of the equipment to the water depths encountered in the Channel. Me ' 1 ' 121 ' L,9,i " Pre8ent c *P* b ^tiee I" Offshore Pipeline Construction". The pipelines described are at depths considerably less than would be en¬ countered in the Santa Brabara Channel, with the exception of the Strait of Messina line. At the present time equipment is being designed or constructed with a predicted capability of laying pipelines in depths of 3,000-, and an experimental line has been laid (and retrieved) in 1,005 feet of water. However, there appears to be no assurance based on experience that production pipelines can be safely installed and utilised in certain areas of the Channel. £^. 1-123, Section (c): "Operation and Maintenance". This section should include a statement about inspection for internal corrosion in Pipelines by means of an electronic surveillance or other approved methods, fhe State Lands Commission requires periodic internal inspections for --orrosion in pipelines located on State tide and submerged lands. m 1-128 - -i- The EIS does not address Itself sufficiently to the -ossible hydrogen sulfide problems involved with oil production in this ar.a. Consideration should also be given to planning for ffshore pipeline corridors. Development of the Santa Barbara Channel oil " d *“ reS ° UrCeS C ° Uld “P *<> «• hundred eleven miles of additional ffshore pipelines (Pg. X-164). A reduction in the number of miles of Ipeline needed (given pipeline corridor planning) would lessen the potential ,r environmental degradation. IX-149 The EIS states that "...OCS oil and gas operations 18 Pa ge IV-1, would comply with applicable regulations of County, State and Federal agencies including....the State Lands Commission and the Division of Oil and Gas....". This statement is misleading because neither the State Lands Commission or Department of Oil and Gas have jurisdiction over OCS operations beyond the three-mile limit. 19 I - Page IV-12,; OCS Order No. 2, "DRILLING PROCEDURES" is presently being revised. We wish to point out here that this Division's comments on propc revisions of OCS Order No. 2 have not been incorporated into subsequent revisions thereof. We wish also to reiterate that in view of the great public concern in regard to offshore drilling and the inherent hazards associated therewith, you include these proposed revisions prior to final adoption of your PROCEDURES. Further, continued approval of drilling operations from floating vessels for which regulations have not been adopted is a serious matter, and such procedure should be discontinued until appropriate regulations have been approved. 20 r Pave IV-32 to IV-48: This section sufficiently defines the oil spill contingency plans and equipment available for use in the Santa Barbara Channel. The statement should contain detailed discussion on the actual field testing of this equipment. Further the U.S.G.S. should require OCS operators to submit for approval a "Critical Operations and Curtail®. Plan". Criteria should take into account weather conditions, the effecti ness and availability of oil-spill containment and recovery equipment, ar other factors relating to safety of operations. Critical well operation' would be required to be curtailed. It should be noted that Union Oil Company has been unable to control or contain the five barrel a day seep L at Platform A. IX-150 Lands Commission 1 t age IV-48, L. 24.; Refers to the adoption by the State of a staff report indicating that the oil industry has developed safety equipment and procedures that minimire the possibility of a major spill occurring and provision for effective clean-up In the event of a spill. It should be pointed out that this report refers to leases operating under stringent State regulations and to wells drilled in State waters at much -shallower depths. Page IV-55 et seq.; These sections show that the USGS has not Imple¬ mented recommendations made as the result of special studies of OCS operations. The descriptions of actions taken on the 15 original re- emendations are too nebulous to be of any value. It Is recommended that the Final Environmental Statement describe definitive actions taken so that these can be analyzed for sufficiency. The Final Environmental Statement should be delayed until such definitive actions can be described. Examples of the nebulous statements which are considered Inadequate are (underscroes added): •t IX-151 art easi OS ■"STf ec css: IV-57 L.ll. "It is anticipated that an information dissemination syst will be designed.. .I*. Pace IV-57 U19 "Research and Development" ~ "ft cooperative commit tee on off shore safety and anti-pollution research has been formed.. . . ^! P„ r IV-58 L.2. "Standard, and Specifications" a cooperative commit tee on Offshore safety and anti-pollution standards has been fo rmed..." Pass IV-58 L. 11. "Draft copies of these standards have been made avallab s~ — ~ and comment. The final copies of these standards will be pu bli later in 1974". a- r - i->* and IV-60 L. 27._: "...and« e continuing to w o^c with the U. S. Geological Survey i^Rlng meaningful, a.^ffectlv^n^nj^ operations." Pave IV-60 L. 6.: 'These studies are currently being evaluated with .... p t TV-59 L. 26 and IV-60 L. 27.: ".. .and are continuing to Jgrk with tl U. S. Geological Survey f maklna meanlngful_and effective chan.es In . j££ operations." Pave IV-60 La 6.: "These studies are currently being evaluated with .... P.ye TV-60 L. 15.: "The study looked in detail at the offshore productic facilities, the pipelines to shore, and the alternate offshore storage ar terminal system from the viewpoint of safety to personnel and oil in wat, pollution'*. Pa r IV-60 L. 71.: "...28 wer e in need of additional analysis..^ Pa r TV-60 L. 16-: "... the p a rticular items recommended for docum ents! are not specifically addressed.^ Pave TV-61 L. 19.: -However, the Pacific Area will review the Gulf of Mexico revised OCS Order No. 8 when completed, for consideration and possible adaptation to the Pacific Area. IX-152 Area Pa g e IV-62 L. 2.: 'The Pacific Area will review the Gulf of Mexico XS Order No. 8 , when completed, for adaptation of the erosion control section to the Pacific Area." Page IV-62 L. 7.: "a committee has been formed.» Pa S e . Ay-62 L » 15 •.. .have plans for developing a training course in PCS orders and regulations for presentation to the industry. 'The Pacific Area has made a study.....". Page IV-63 L. 4.: 'The API and oil industry are taking the lead in developing a motivation program." P a g e IV 763 L. 7.: "Additional personnel have been hired for the Pacific Area and Gulf of Mexico Area OCS offices. The areas of responsibilities and goals of the individual organizational units are being developed. jiao under development, is a system for incorporating reports from other program areas into an annual review." Page IV-64 L. 4.: 'The Geological Survey is currently developing formalized procedures..." Page IV-64 L. 7.: "Proposed new and revised Orders are to be published ... ^age IV-64 L. 11.: "....is reviewing other OCS Orders for revision." 3 jge _ I V - 64 L. 13.: "Standardization of Pollution Report Form - The Pacific *ea has reviewed the Gulf of Mexico Area proposed form and has submitted suggestions and comments. ag e IV-64 L. 18: States that oil and gas operations had been conducted n the Santa Barbara Channel for 77 years before the first major oil •ollution incident (the Platform A Spill). However, oil and gas production Perations had been conducted on OCS lands for only seven years prior to he Platform A Spill. - gc ^ It I® our opinion that a formal training and certi- 1 cations program should be established for all offshore drilling and roduction personnel. IX-153 aei em, pe't 4 9 ’S' 1 ". «'14 t.; *! 1“ "sri"- erwjjSI gii : '^v Kv*,* 1 * & ' « • "* IK Ot£' wet £ 24 25 Page IV-83 et geq.; This section (12) speaks of baseline and monltorii studies found in response to Senate National Ocean Policy Study hearinj Such studies pertain to outer continental shelf oil and gas develops and are ongoing. It would appear very difficult to properly assess po tential damage to the environment without knowledge derived from the completed studies. Pape V-9 L. 18.: It appears that insufficient data exists to conclude the “the overall impact of the planned development on air quality shou be small.” For such conclusion detailed site-specific data must be . available. ■ P-> VTTI-l et seo.; Alternatives of delaying further leasing until the need for production is proven and until technology is improved is not adequately discussed. IX-154 2 . RESPONSE TO THE STATE LANDS COMMISSION The statement is primarily for the purpose of considering the impacts that would result from ponible future levels of development. Therefore by necessity the statement is, for the most part, void of site-specific discussion. Exceptions to this are the discussions of the three possible platforms C, (lease OCS-P 0241), Henry (lease OCS-P 0240) and the Mobil platform for lease OCS-P 0202 (see sections I.B. and III.C.3.). It is explained in the statement that Mobil has submitted a preliminary notice of intent to install a platform on lease OCS-P 0202 and that this tentative proposal, indefinite and lacking in detail, is not recognized as a formal application suitable for commencing serious evaluation and consideration. Action by the Survey on this preliminary notice is being held in abeyance pending submission of additional more definite and detailed information, and the completion of this statement. The operator has stated that the economic feasibility of this possible platform is dependent on further evaluation drilling. (See sections I.B., I.B.2. and III.C.3.b.) The statement in the draft that no development applications are pending for the Santa Barbara Channel DCS has been qualified in this final state¬ ment. This was a valid statement at the time the draft was published. However, subsequent to publication, an application to install Platform Henry on lease OCS-P 0240 was received by the U. S. Geological Survey (see sections I.B. and III.C.3.a.). Decisions as to the need for site-specific statements will be made on a by case basis in accordance with established NEPA procedures of the Survey and the Interior Department, 4. AS the Commission is aware, the OCS regulations (CFR 250.34) are revised so as to require the OCS operators to submit development plans to the State prior to Department of Interior approval. The proposed modified regulations were published in the Federal Register (Vol. 40, No. 179, September 15, 1975) for comments and the final adopted modified regulations were published in the Federal Register, November 4, 1975 (Vol. 40, No. 213). The objective of the modification is to provide affected States with early information and an opportunity for early review and comment on development associated with OCS oil and gas. Sue! information will allow the State to assess and plan for possible onshor« impacts from specific proposed OCS operations at the earliest possible date. If a final Coastal Plan is adopted by the California Legislature and approved by the U. S. Department of Commerce pursuant to the Coastal Zone Management Act of 1972, the activities of the Department of the Interior or of Federal oil and gas lessees directly affecting the coastal zone shall, to the maximum extent practicable, be conducted in a manner consistent with the approval coastal zone management program. The discussion of the Coastal Zone Plan has been updated and expanded in this final statement. (See sections I.F.2.a. and IV.A.l.h) 5. Response to this comment is provided in the greatly expanded Socio¬ economics Baseline and Impacts sections in the FES. (See sections H.1 Resources, and III.N., Socioeconomics Impacts) 6. For this statement the discussion of the Platform A blowout is conside adequate. For further detail the reader is referred to USGS Professio IX-156 Paper 679. '• The su ®8 ested shallow coring depth limitation "without blowout pre- vention control" is acknowledged. The Geological Survey personnel in Los Angeles, presently revising OCS Order No. 2, have been given these recommendations for consideration. Recommendations are being incorporated wherever appropriate. (See section IV.A.l.g. for the revision status of OCS Order No. 2 ) . The introductory sentence to the design criteria and procedures list in the draft was incorrect and has been reworded in the final. Your recommendations on drilling from vessels and training of all drilling and production personnel is presently being considered by the Geological Survey. The waste water disposal discussion in this final statement has been up¬ dated to include information about EPA OCS discharge permits and EPA OCS discharge regulations and requirements (see sections II.G.2.C. and d., and IV.A.l.c. and d.). Presently drill cuttings and produced waste water are discharged to the OCS waters and this practice will likely continue for at least several years (per telephone discussion with EPA represen- tatives). OCS Order No. 2, presently being revised, has been expanded to include hydrogen sulfide detection and control requirements. During the interim while OCS Order No. 2 is being revised, an OCS "Notice to Lessees” has been issued by the Geological Survey, spelling out in detail hydrogen sulfide detection and control requirements. A discussion of the revised OCS Order No. 2 and hydrogen sulfide Notice to Lessees, have been included m this final statement. (See section IV) IX-157 12. This discussion of velocity-activated sub-surface safety devices is considered relevant in presenting the reasons for placing greater reliance on surface controlled subsurface safety devices now used n the Channel as compared to those velocity-activated types that have performed well, in recent operations in the Gulf of Mexico. 13. Operating limitations of subsea completion systems are discussed m section I.D.6. That section has been updated and expanded m the f including a status report on Gulf of Mexico field tests of three su production systems. I 14. It is recognized that certain portions of the Santa Barbara Channel water basin are beyond the present pipeline installation state of t art. 15. Recommendation for internal corrosion inspection is acknowledged. 16. See response to item 11 above on hydrogen sulfide problems. 17. Planning which would minimize facility numbers is stressed in the statement (see section I.E.). 18. Federal OCS operators would have to comply with applicable regulat of the County and State including the State Lands Commission and Division of Oil and Gas concerning certain aspects of activities extending into State waters and onshore (e.g. pipelines and subsur injection into onshore wells of OCS produced waste water from onsb facilities). Therefore, we do not agree that the referenced state is misleading. 19. As stated above, the Geological Survey is presently considering recommen dations of the Commission on revision of USGS OCS Order No. 2, 20. Field testing of equipment is discussed and problems involving the conducting of a "representative" field test using actual oil is recog¬ nized. It appears that additional coordination between OCS operators, EPA, Navy, Coast Guard and the Geological Survey and possibly others in conducting and assessing such tests would be essential. The uncontrolled five barrel a day Platform A seepage is noted in the Introduction to this statement. :l. It is acknowledged that the State Lands Commission staff report refers to leases operating under State regulations in shallower State water. 2. The status of implementing recommendations made as a result of special studies of OCS operations has been updated (section IV.A.8.). There have been many of these studies, as shown in section IV.A.8., and appendices IV-2 and IV-3, and several are presently ongoing. As new Studies are completed, the need to revise and expand certain original recommendations, and add new ones becomes apparent. Many of these complex recommendations involve considerable planning, manpower and money and cannot be meaningfully implemented overnight. The Review Committee on Safety of Outer Continental Shelf Petroleum Operations, under the auspices of the Marine Board, National Academy of Engineers, was established in July 1973, as a third-party audit of the OCS procedures and operations and to review state-of-the-art technologies. The Committee established at the request of the Geolog¬ ical Survey, composed of experts not regularly employed by industry or IX-159 as) «USS> O-, r. 2:^ y acg 1 **■*», 2) *■*2* "«S ssc the Government, has issued four reports to the Geological Survey, The fourth and latest report, issued in August 1975, and the three previou ones, are discussed in this final statement; committee membership is also presented (see section IV.A.8.a,)* 23 . The problems related to meaningful baseline and monitoring studies ar< recognized. An expanded discussion on this matter is contained in thi final statement. In regards to the comment reference to completed studies, it must be recognized that at least the monitoring phase in many cases would be ongoing for the life of the oil and gas activitie Also see our response No. 11 to hearing transcript baseline studies and section IV.B.12. comments related t< 24. The identification and quantification of potential air pollution emissions and their impacts from the possible levels of Channel devel ment have been addressed in full detail in the greatly expanded Air Quality sections. (See section III.LL., for Air Quality Impacts. Baseline Air Quality, Meteorology, and Air Impacts Mitigation are a) addressed in the revised sections II.G.l., II.C. and IV.B.13., respectively) 25. The alternatives, of delaying further leasing until the need for pro. tion is proven and until technology is improved would be factors in future consideration to hold further lease sales in the Santa Barbar Channel or elsewhere. IX-160 Joniarvoti on : i»h and Gama 4ovigetion and pm«nt 5 ork* and Recreation fater Resources EDMUND G. BROWN JR. GOVERNOR OF CALIFORNIA THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA OFFICE OF THE SECRk./V RESOURCES BUILDING 1416 NINTH STREET 95814 (916) 445-5656 Air Resources Board Colorado River Board Son Fronci.co Boy Conservation and Development Commission Solid Waste Monogement Board State Lands Commission State Reclamation Board State Water Resources Control Board Regional Water Quality Control Boon NOV 19 1975 Dr. Vincent E. McKelvey Director U. S. Geological Survey Department of the Interior National Center Reston, Virginia 22092 Dear Dr. McKelvey: °5 California has reviewed Volumes 1 , 2 and 3 for Continental Shelf th£ Santa Barbara Channel Outer ires 7* 1 Shalf p f f California, Draft Environmental Statement ’ fitted to the Office of Planning and Research with t part e TT i nf h ?h Se rl ln the Govern °r's Office, in accordance Circular a^QB• ° ff |° e ° f Mana S eme nt and Budget circular A -95 and the National Policy Act of 1969. This review was coordinated with the Departments of Water Resources, Pood and Agriculture, Transportation, Health Conser and Recreation nd thrstate V wf? ti0 S &nd ° Cean Develo P me nt’ and Parks *7creaiion^ the State Water Resources Control Board- thp Waste Men Bay c ° naervati °n and Development Commission; the Solid Co^i e s ^on Se and thfofiifnrnf r n ReS ? U r eS B0ard > the ^ate l^nds j the California Coastal Zone Conservation Commission. Commlssion°^aff S a?e a^Lchef ^full?**^ 1 Z ° ne Conservation GENERAL COMMENTS ronmental ?SJL** nu f b ! :r of serious concerns with the draft envi- onmentai impact statement for potential oil and gas dev^ionm^nt e l anta ,^ arS Channel °°S off California that it hopes IX-161 Dr. Vincent E. McKelvey -2- Cm * CUSS' 2331 •Cl *S!!t vr.i '*■ 1 ** vt « •»3 3*1 v* M ««c os Decision Making; Process As with the proposed lease sale Number 35 off ^^ for SJ there is no process for joint federal-state decision making. Tl procedure for development outlined in this EIS and the U. S. Geological Survey’s proposed modification of leasing regulations show this absence of consideration for the governmental entities at the state and local level who have to live with the problems incurred by outside jurisdictions. The regulations and procedu: outlined for this area attempt to structure development plans 11 such a way as to evade the provisions of both the Coastal Zone Management Act (CZMA) and the National Environmental Policy Act (NEPA). It should be made clear that the consistency provision of the CZMA and the requirements of NEPA for a supplements environmental statement are applicable to development plans. Meeting these requests is absolutely necessary because in no ot! way can the onshore impacts be gauged and regulated by the p P state and local agencies in a way that balances the need for domestic energy supplies with keeping the ^ a S °° fabrics of a predominately rural, recreational-oriented area intact. To be more specific, the consistency clause of the C makes it imperative for the development plans to be matche against the coastal plan. That plan has been put in final, form and will be submitted to the Legislature for:its ^option next year. The draft EIS is vague on whether site specif:ic^impact statements will be executed for individual developments wit ^" the leasehold area. The final EIS should state the tional impact statements will be prepared, as was done for the . Santa Ynez unit. Deficiencies The statement does not address the cumulative impact of all ene developments proposed for the Santa Barbara area shoreline. T include possible additional oil and gas activity on stat,e-owne lands, increased tanker traffic from Alaska, a liquefied nature gas terminal at Pt. Conception, a possible nuclear power pi , and additional activity from lease sale Number 35. The EIS also deficient in its discussion of onshore impacts and 1 ^ particular does not discuss what such development might balance presently existing between limited channel oil 1°P and the present residential-recreational-light commercia activity in the area. There is little discussion in the EIS on how the goal of cons ■ dation of sites and activities might be accomplished although there is a brief mention of the possibility of concentrating IX-162 r. Vincent C. McKelvey -3- ishore facilities in two or three are*., IJhal - , ill discussion of the leeai . eas ’ What is needed is a >lved in requiring consolW^tfon of 1 f. environmental issues in- i termination, if fndeed? 1 ^^ dLi^^^e^Is^^ itire lease area should makp 4 e> ine • EIS f or the desirable, rather than the site^D^no^tion if consolidation t address this overall question mhf f± ? statemen ts which will ere the produced oil will be refined whi ^ D ° ?* scusslon of estion of onshore oioelii lnffn d which would settle the affic. Pipeline location versus barge or tanker e draft statement is inadequate in -i +-0 +- , on°has f to h be P given e to°the a potentiai a ^ 1 '' More^coL^dera! 1 ?elopment° UndS associated with varioufposs°ibl°e llv^of 0 " 8 “ d gulations 'lSicafsu^efare^ending^^en^hf regulablons b y the U. S. ’tions of the regulations shouid^^' a are ado P ted * pertinent it in the Santa Barbara Channel b ® m ade applicable to develop- ieves that the Secretary of T Sh P ? : ^ticular, the State ■ponsibility for approval of development clans a« fvZ * ? Gas Supervisor Sf^ t , 5 P ower is given to the Area Oil nsferre^ /slaluL^^f^T^fwScr^uW^ro^bif 1011 fchiS yeal< ( Cha P b - mtiL la for t°h ^ any . 011 ° r 8^ PiPeline P or S asso t c°iat2d Str ' UCt ' submerged lands within°thepermit area°of S the fr0m an offshore area Project meets certain requirement! ^ C ° aStal ZOne ’ unless you for the opportunity to review and comment on this project. Sincerely,, CLAIRE T. DEDRICK Secretary for Resou £U>U, chments IX-163 SPECIFIC COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT FOR THE OIL AND GAS DEVELOPMENT IN THE SANTA BARBARA CHANNEL OUTER CONTINENTAL SHELF OFF CALIFORNIA 38.1 asi ““'LSI 1 , t ittgr*' v-jL w J) n.< esc OIL AND GAS DEVELOPMENT p affe i_! States that a total of 197 wells have been drilled on theOCS Fa.g e 1 —. , r . ^ r _* „ fields This figure does not includi leases of Dos Cuadras and Carpintena tieias. inxt. u 6 exploratory holes drilled within these leases. p ___ ii-2 Platform "Harry", Conception Offshore field, should be removed USTthTniap The productive area near shore for Coal Oil Point is not nroductive and should be removed. The proposed national energy reserve, a S"!;, not only includes the 35 leased parcels but also 14 pare within the ecological preserve and buffer zone. Page ii-3. Add municipal leases to state and federal leases of California from which the combined production was produced. Ps( , p ii-4 naragraph 2. Implies that state regulation of oil and gas deve y s —£ -?—rfri —State regulation started with the passage of the Crea “‘^^“estaWishing «SL, that is now the Division of Oil and C In 1921, the first statutes governing the leasing of state-owne ti e an were passed. Page ii-13. States that surface flow from the well was controlled by act] r,: a ocean floor because of unusual geologic conditions as stated, but a so because of insufficient casing tie-down. Pa „ p ii-15. line 7. States tnat the spill was brought under control in lO^days. ^This s hould be changed to indicate that it was the subsurface f. from the well that was brought under control. Page ii-17. The number of wells drilled on federal lands is discussed STS?: fr^L/^tr^di! 7 h^ have b|n abou 3,300 wells drilled within the onshore coastal zone of the channe . Page ii-18 . The section on State Government Action existing sta Lands Commission imposed a moratorium on all new ri | f sb tideland leases. The moratorium did not apply to wellsJ 1 and sites or to tidelands granted to the cities, and that du 8 SummerlaI December 1974, drilling programs were approved £° r ^arpint , S Belmont, Rincon, and South Elwood fields. It should also ^stated more than 200 wells have been drilled from SgLlature territorial boundaries since the blowout and that the State Lg ^ added 1,216,000 acres of state land to sanctuaries where 8 is not allowed unless drainage is occurring. IX-164 Page_I_15. Add abandonment to list of potential activities. Page 1-23 . The limit of shallow coring is stated tn ho snn c *- r tion, or 750 feet if not more than 50 feet of compefenf foJaTi encountered. In the ES for proposed OCS exploration reg^ione" deep stratigraphic drilling is described as penetrations of more than’sO feet of 750^eet^llowable^ppears^to^e'in^confliet'witl^OCS Orders^wh'"*h^ " • floor ? mentln8 ° f C ° nduCtor at a de P th b ^ween 300 to 500 ffft”bfLw^hHfean we^ht~materialf iSCUSS i° n ° f drlU1 ”« fluid ’ b ™^ - -tinned as a P ag e 1-46 . States that mud logging equipment is required by OCS Order No 7 for development wells. This order M y uraer jno. Z logging equipment. /1/?1) requlres mud monitoring, not mud prafenfef' P fifff r f Ph 2 ' t0 the l0Wer pipe rams as a " annular type preventer. This term, as used in blowout-prevention literature refers^o the bag-type valve at the top of the stack. ' reters to f f fjoo? : In thiS diasram ' the choke and kill lines should be connected at 3 e rmit~ed * dumpin S of waste materials and debris is not emitted, This should be changed to indicate that treated waste materia ihe^oceanf ttln8S ' bl0l ° 8ical Wastes > aad Produced water, may be dJfpefiftf’ fhe W dffnff 8 K nd dr f 11S are required but some provisions should rills to be evaluated and approved by the USGS. Casing is required to be cut at least 5 feet below the mud line of hf casing removal should be limited in order to facilitate reenffv r handling possible subsequent problems. ^ SiHir^a u tat u S that auxillar y electrical power is normally installed, f auxiliary ^wef? 8 ^ ^ lndiCate that 0CS orders require the installation ^ 77 ' States that subsurface safety valves are used in flowing wells. f flnwf at f° n r be changed to require valves in wells that are capable lowing to the ocean floor and not to the elevation of the platform. piii26. In this discussion of onshore treating and storage facilities Jplicable 6 S !; ated that within the territorial boundaries of the State, all >piicable state statutes and regulations shall apply. ’ Indicates that "at the meeting of December 11 , 1973, the State SoftffTTT ad ° P£ed neW regulations". This should be changed tf leal Lofs It P ^ C6dures covering drilling and production operations and restric- ^ £beSe cPcrations". Then add that "the State Division of Oil and * adopted regulations (Title 14, Chapter 4, SubchapterYHf the IX-165 asi California Administrative Code) governing the drilling, production, mainte naJcf and abandonment of offshore wells within the territorial boundaries of the State, which were certified by the California Secretary of State and became eftective on May 22, 1974." Page 1-191 . Source: Change California "Department" to "Division" of Oil and Gas. Page 1-193. States that some of these wells have been deflected as much as 70 degrees from the vertical. Change this to 80 degrees. Page 11-32. "Middle Miocene strata have not yielded significant production . Middle Mi ocene production has been established at South Elwood Offshore fiel in state waters^here a few wells have been recompleted m the Monterey Shale and several more are planned. In addition, Middle Miocene strata have been tested and found to be productive in the Santa Clara-Santa Ynez U Pages 11-41. Section h . Fischer mapped fan channels for his dissertation at U.S.C. Page 11-72. "Miocene age have also been productive of oil and gas, P a tticu- larly^i nthe area west of the Elwood field". Vaqueros and Sespe Production occurs along the zone north of the Red Mountain fault (p. 11-50, par. 1) Summerland on the east to Alegria on the west. T t_oa flnd 85 Section b and Table II-l . R-F intensities at Santa Barbara are'shown for most earthquakes. Note that the City of Santa Bar ara ^y be particularly susceptible to high R-F intensities because it is on alluvium. Page 11-139. Section a . Needs explanation of sources of pressure and method used to control pressure while drilling. Page TT-143. Section d . Note that tsunamis are not hazardous to platforms. Page 11-385. The map of oil fields on this page is dated 1958. An up-to date map should be used, one that includes offshore fields. Page 11-386. The cumulative production for Santa Barbara County is incorrec and shoul d""be changed to 1,029,046,263 barrels of oil and 1,459,476,980 Met of natural gas as of December 31, 1972. Page III-28. Add to the causes of blowouts, the improper or inadequate response by personnel at the well site. The second paragraph implies that if casings ar y Required to hi ing well, a major blowout could occur. All flowing w ^ fhl subsurface safety valves installed below the ocean floor. Therefore, thi valve or the production packer would have to fail before a blowout occurred Page III-49. One additional impact from the development of theHuenemeOf £ shore fie ld which should be discussed is the possibility of drainage fr state-owned lands and subsequent state development. IX-166 s P houL I be’e«endfd 1 th-;ouS e i974! lla,:i0n ° f ° ilS SPlUS fr ° m 1957 through 1972 Pa ^ e IV-10 . States that the California Division of Oil ^ r proposals for underground water disposal. Section 1748 ? a ^ * ev * ews ter 1.1, Chapter 4, Title 14 of thp fni-if • AJ . . 8,2 » Article 3, Subchap- that all subsurface injectionprMecta Admlnistrative Code states of Oil and Gas. The California Divisin 9 f I?.. prl ° r approval of the Division operation, maintenance, and abandonment''of oil and ^ r ®f alates a11 drilling, torial boundaries of the State so 833 WellS within the terri- life, health, property and neural res° 38 far 33 P° sslbla > damage to gas deposits, loss of oils gas and ama S e to underground oil and ground and surface waters ofdo^t^JSpS ~ The discussion on alternate sources of energy should include WATER QUALITY CONTROL PLAN f'series^of‘"areas^along thetastlf cSf Contro1 B ° a rd established ,f California ral Water qU3lity standard s for the ocean waters •eratnreV 0 ?^ ad ° Pte ? the " Water Q ualit y C °ntrol ^an for Control of Tem- t October"^" W71 Per m Ur ? Pla "> anfadopteff reviser vr*r -"•Cffssi’s sirirs'jL s-susr* aintenance C °f e Wa ^ ers tD be a Sufficlent distance from ASBS to assure thf P “ 3 ™ —d alifomia"°?Ocean d °^ ed 1 the 7^1 QUal “ y C ° ntro1 Plan for 0cea " Waters of ta ZirtoZ ^ n) ,° n Uly 6 i 1972 ‘ 1116 0cean Plan includes a provi- detallod 8 C the location of waste discharges must be determined after J assure thar SS r nt i ° ° Ceanogra P hic characteristics and current patterns Signaled as beinc r of Wat6r ? U f ^ y con ditions are not altered in areas -nv-fri +.1, bein § °f a special biological significance. The plan also ‘sure maintenance eS f Eha f 1 dlscharged a sufficient distance from ASBS to re maintenance of natural water quality conditions in such areas. »tIl°ProterM P1 “ and the ° Cean Plan were accepted by the Federal Environ- “ugust l8?1 9 72 y " Pa “ ° f the state - feda ral water quality standards IX-167 Th P crimarv purpose of designating ASBS is to guide the State and Regional Boards in Visions relating to*. control of -ste <'-^rges^coast^ =; g e 0 r^;trr^^:dT^ St^Ltrol^t 1 " and^it^ 1 Amendments of 19^2 (Section 402, PL 92-500). Generally the Regional Boards would prohibit the direct discharge of waste into an I^BS or its immediate vicinity. Dischargers some distance away are Required to have a monitoring program to demonstrate that the discharge cou not be detected inside the ASBS. Wastes presently being discharged into AS are phased out. Existing discharges which influence water quality in ASBS are either phased out or must comply with requirements which forbid y detectable waste substances within ASBS. Tne Ocean Plan is not applicable to vessel wastes, the control of dredging, or the disposal of dredging spoil. Therefore, the discharge of wastes fro* boats and dredging activities in ASBS would not be affected by such designation. "Areas of special biological significance" (ASBS) are those areas contain!* biological communities of such extraordinary, even tnough unquantifiable value! that no acceptable risk of change in their environments as a result man’s activities can be entertained. ASBS in Southern California are: San Miguel, Santa Rosa, and Santa Cruz Islands San Nicolas Island and Begg Rock Santa Barbara and Anacapa Islands San Clemente Island Santa Catalina Island, including the following subareas: Subarea #1 Isthmus Cove . Subarea #2 North end of Little Harbor to Ben Weston Point Subarea #3 Farnsworth Bank Subarea #4 Binnacle Rock to Jewfish Point Mugu Lagoon to Latigo Point Heisler Park Ecological Preserve Newport Beach Marine Life Refuge Irvine Coast Marine Life Refuge San Diego-La Jolla Ecological Reserve .San Diego Marine Life Refuge Discharges of sewage, drilling debris, oil, and formation" at “ °f'a platforms, as well as oil spills entering ASBS in detectable quant ’ an subject to regulation whether or not the discharges origina The DES for OCS Lease Sale 35 (DES 75-8), prepared for the of the Interior by the Bureau of Land Management , recognizes the establi^ ment of ASBS and suggests prohibition of oil development activ six miles of such areas as a possible mitigation measure. The ^scubsI ASBS in Section II.G.2.B.(2) should be rewritten to conform with th p IX-168 :is“ ^ U ®t s °f °cean dischargers in Tables 11-63 (page 11-408) and 11-64 page 11-409) require updating. Table 11-63 should note that the City of an Buenaventura Seaside Plant (4A-56-001) is no longer in operation In able II 64, the only one of the four industrial dischargers under the iuris- iction of the Regional Water Quality Control Board, Los Angeles Region which lant'cNu^erlig * 1 * * * )/ 116 C ° ntinental 011 Grubb Lease Seawater Processing age 11-13 . Attribution of leaks from the Platform A blowout to "unusual J ^h?CV° nd a-s° nS 1S evaslve< We understand that construction standards t that time did not require special measures to meet existent geologic atrted°t S ’th J- Cti ° n Standards for f uture offshore wells should be page IV 481 that ° nS s SC ° Vered dUrlng drlllin S- The DES claims techniques wm reduce p^n- T ^ le n II ” 6 * a again errone °usly lists these dischargers. No oil rea „ d ^ C d- r8 h t0 the ° cean from an y °f the companies listed in Zl 'r , 17 daschar § e 1S fro “ the previously mentioned Continental Oil S00- n barreT(?26 S O O n aCi n t ^ ^ iS 3 peri ° dia “fl ,000 barrel (126,000-gallon) capacity flocculation tank. The discharge ntams aluminum hydroxide floe and insoluble material removed from the lfluent seawater stream. !S. es 11-423 and IU-26 . It may not be feasible to reinject all produced stewater into subsurface formations. Some operators who have tried this e requesting to discontinue because it is adversely affecting their produc- •on. Apparently, successful reinjection depends on the viscosity of it in injection strata. y tane^r treabment and dilution strategies for wastewater should receive tailed discussion. ||_ill^l. It seems probable that there would be improvements in design atform. pdatfo ™ s huilt in 1969. Any designs that would make future atrorms safer should be incorporated. 111 If a break in tbe pipeline occurs between shore and the 300-foot- P h contour, the DES should indicate what effective measures will prevent 1 in the line below the break irom eventually leaking into the ocean. 3TECTI0N OF WATER RESOURCES !u OUl ^ lndlcate what effective preventive measures will be taken sourrp t-w f? ore . and of fshore and the surface and subsurface water leaks or l u the 3-111116 limit fr ° m P° ssible contamination in case teaks or rupture of the pipeline systems. IX-169 AIR QUALITY Shore Treatment Installations. The DES states that, depending on level o development of the oil fields, from one to five shore treatment installat w pp]_ he required. These installations will involve, at the minimum, oil- separators, oil storage depots with off-loading facilities, and gas desul izing units. The oil-brine separators will emit hydrocarbons and probably oxides of nitrogen. The oil storage facilities, even when equipped with the most e cient floating roofs on the tanks, are sources of hydrocarbon emissions. The loading of ships barges to transport the crude oil to the refineries be a major source of hydrocarbon emissions. The gas desulfurizing units, when equipped with three-stage Claus units and Stretford or other efficie tail gas scrubbers, will emit appreciable quantities of S0 2 and some oxid nitrogen. Because the locations of existing and potential oil fields are known, it should be possible to make a reasonable estimate of the probable locatior capacity of the onshore installations for various levels of development a quantify the probable emissions of pollutants for each level. There are two EIS’s for onshore installations which could serve as guides prepared by Dames and Moore for ARCO's proposed increase in production fi Platform Holly and one prepared by Exxon for its proposed installation ir Flores Canyon. There are also EPA emission factors available for ship lc operations. Therefore, we recommend that the total emissions should be calculated foi several levels of development and, by application of appropriate models, estimates should be made of ambient air quality for comparison with state federal air quality standards. Shipping and Unloading Crude Oil. It appears from the DES that the crude will be shipped by barge or tanker to existing refineries in the Los Ange Long Beach area or to the San Francisco Bay area. Estimates should be me of the quantities destined for each area at the various levels of develo] and the emissions in transit and in loading should be calculated. There: appropriate models should also be used to determine the additive effect ' these emissions at the unloading areas. Preliminary calculations indicate a definite possibility of substantial < emissions of hydrocarbons, oxides of nitrogen, and sulfur dioxides at th< installations and of hydrocarbons at the delivery points at tank loading facilities and in transit. Therefore, further analysis as indicated abo _ should be instigated and incorporated in the final EIS. VESSEL TRAFFIC Page 111-34. Areas within the shipping lanes should not be used for the opment of oil or gas. Here the report states that the United States Cos Guard does not permit structures within one mile of shipping lanes, but IX-170 tance requlre^rshlul^be^ndlcaterbera^^th 8 1/2 mUe - 1,16 corre ct dis- _ to this situation. Seated because the report makes reference twice There is no information on the in^rpaco ,• would affect pleasure boating in the area ^fwee/T ^ traffiC and how “ cause more problems with recreational nds ’ any in c^ase would support traffic activity should be includedl^ a " alySls ° f the commercial 6 vessel“traf f ic ofthfs^\f Structures and increased concerned. The final ES should address £het ? rate for the areas V for boating accidents can be recognized and mitigated?° ^ ^ potential WASTE DISPOSAL We recommend that the disposal of solid 0 „a i• ... operation of the proposed project be a^vln^a slm aLnario^esentefinlhe^^^^nsi^LbL' 11 ^t^ 9 ’ ^ ° n the oil ^■^ssiassg si- 1 oi f i° s 1 piS n a^f' evaluate the impact of the disposal oflhese lsS laro ^- ^ report <*°»ld disposal facilities in Santa Barbara and Vent^a c ou ^«es? S ° lld raste thesf™stes 1 in°an 1 environ^entariy^ound C m Uae measUTes for the disposal of potential disposal sites and include nrovi^l” 61 '’*- 11118 Plan shoul(1 identify planning activities of Santa Barbara and *7 0 °? rdinatl °n with those for solid waste management. 8 r ^ and Ventura Unties* agencies responsible r ISH AND WILDLIFE ^ impaot ° n fish - d leasures in the document and ^Tr^s conveyance facUitierfhall^ofbe^oca'tefirexist 6 ° U St ° rage and - s :c:io 6 gic:r“se^? auticai -- tte 1 °L t te d of 1 &H 8 fomL 1 tha S t e the a aonli m 0 n t trate t0 the sat i sf ^tion of oil spill containments and recover “saMmiesT" 71^7 depl °y able o prevent spill damage to ASBS marine ]ifp fs n su ^ lcien ' t quantities reserves. ’ marine life refuges, and ecological ^feg^t Tands??^ 61106 -' 11,6 statement should read "one" of the few IX-171 esi nu« paragraph 2 . Kelp cutting is limited to four feet by the Department of Fish and Game. 24 « » . cac§ »r *21? **«»* Page 111-13 . The discussion on the^isual^impact^of ^°™® n tf^ SO ciate ( 25 gy§?s„ r» —xi:rjs b f»S.”a r documentation or deleted. 26 Vi p Available data show that oil spills can have lo gyftiitssiji rSi—. »*. »• “ - “ 27 L Page IV- 35 . ^ °° 0rd ^foverprevioufconWngencrpSns ! 11 Nevertheless, have been greatly impr „ ]_i s ted containment and recovery equipment^re^lmost* entirely hypothetical and should he stated as such. 28 , - n ,tfornia brown pelican nests in the project are Pa ge V- 2 . The endangered California or y resident, as reported ZeZlZ^ ^lealTte™ a^so nests along the shore in these areas. 29 r Pages 1-41 & I-U2 . The DSS d ^^ ea ^ m ^ e ' a s eis y that t ^e S e!LbUsSd°by US I for conduct of drilling operati^ f covering drilling procedures reve OCS Orders. A review of OCS O^er covered. The State believes tha that only four of the 7 i Order No. 2 be revised to include all it is absolutely necessary that OCS order no. these items in the regulations. SSi IX-172 CAUFORN'A COASTAL ZONE CONSERVATION COMMISSION 5sO Market Street, San Francisco'94102 — (415) 557-lCQi Corcaants of California Coastal Zona conservation CornuLssion Staff on Draft Environmental Impact Statement for f Oil and Gas Development in the Santa Barbara Channel Outer Continental Shelf Off California” oUcving c °™snts represent the work of Coas+ai *» addressed 5l Consents a to to Address Potential Curative Effe ct o> S anta 3arta~ nw—n - ^—Ps the most significant i anr-e -f-u iieet is to determine whether oil and is?aot ^^aneat f 8 l8 f- throrcghout the Santa Ba^bSa ** *«“»* sis th tceritalirre^r^^h^^ SeT ^^ 31 ?* »** f*“* uses. It does not, however, a^esi?^ th . 8 ?"“■“» of . ‘ v between limited Channel oil dev=lo-—A ttl8 =si -- cs •j recreational, fish±r» asrierfH-n^i a ^ *C 0pClwit ~ d ohs r 23 ^ential, natural environment co'lAAAtAt ^JT ^ 00 da P e “ tBnfc ® the .sun-related activities^ develop. 7 * d ° uM “* ° r trt P^ of The Environmental impact Statement should cc-sirt-- Fnsnt activities the Santa Barbara Channel withi^h 011 «? e * energy-related activities n^esen+lv ■ • . oonp^eue context er to accurately rIfl! presently being considered for the sare = uS not adequately considered are: “ the pcssici fc) AAAA 0i r 23,1 gas ootirities on State-owned ''ar-‘s- b; “creased tanker traffic, involving tank-rTofthf L associated with Alaskan oil development’and ptjpo’sed - Szz8 ’ a deepwater port in the Los Angeles/Long Bea^h %l£ the proposed liquefied natural gas maril 1 p. Conception (Cojo Bay); errr - au ^ • e’bTr^' 6 *^ 331 f0r 8 rruclear Power nlant or. the 575 -=,,--=, " ° f Po ~“ Conception owed by Southern’ California' Sii-ArT — '-'-.t— <— j-*j— out LO; d gas r^Tt - , T* 4 * U ^ ■ 1 OUw c) d) of am si ^7 • IX-173 CUES' me?? ^3 C.X* n,,Zr '** M** *X| u »^*# Oi SI £5 SI 3- , . , , ._ 5 .t ot ^-,o Tprrtnrials and. Onshore F.ic: . ' -■■ " g —^ — t!arL ^-—--- 32 T _ .. vrs D 1 - 143 . under the heading 'Itinisizatiai! In Volume I of the Oraio > -wtiiafc. ”... an alternative to the. of the Number of Facilities , ;? th^ coordinated development of all oil traditional piecemeal deve-opm - „ r s i 3 a brief discussion of production in the Santa two or three areas that are possibly concentrating a -1 onsh ~ environmental impacts. Sready industrially developed, an this possible After that brief mention, howave . — > nQ discrd3Sian 33 to how the goal "mitigating measure" altogeth-r. ™~ - ao tua01y be effected. Hot, of consolidation 0? s f 83 ^ t t lincie^iutei-rene to require consolidatic for example, might Federal or S^a ^ economic, and environmental ££ “■S’USI.'■S^STSTp^-l. - .-»»• Furthermore, the Draft EXS £?£ SSS£ necessary to measure ^ lease owners, unit operators, and (a) a comprehensive listcn^o,oixS Qr placn3d ^ Fed eral or State all petroleum f c^gel^d (b) a baseline inventory of exdstrn leases in the Santa Baroara Cnmnex, aaag other things, marine terminals ■ end on ° =rsh±p- ggree of present use of the facility, company facility and the facility and state of its i. . v- r> ^bout ^ar ir,yj CCS-Relate d Onshore fl.ctivi.ui3 3 TnaHpnnate Iniormaxicn jujouw -— r 33 . _ T ^ Qr .^ nlform construction is liksly tc The Draft EES is vague^as to^wn-^pl- „ Caasfcrccbim of each put* occur, saying only, ior “ ipTerminal Island or elsewhere..." The 1 would involve fabrication, )jnder discussion here may involve indicates that the prosp.cti^ - - document should give a 21 new platforms, and m view ^ ^ggiiTites including a listing of the fuller discussion ox SnfoAia olatforms and the California shxpy construction si„es of existan, ^ cou id fea3 ibiy occur, or other facilities whers such constru—on coui 34 , . oa .pr-t-i2l considerations as The Draft EES "fSyTenters, offshore- staging areas for oifshore ^ d ^ loansntj construction layd erm related light industrial an^cocme; — ^ sh£TOld bs discussion oJ areas, heliports and helicopter traf • ±t to handle Increased snch facilities presently exist, —^ cap-ci.^/ [_activity, and the livelihood of need for new dsvelcnaent. 35 The Draft document P-yt S ^discussion of STfo likely to go for refining, orrefinery location by Analysis should be made.of l.ase own = ^ ^ ' 3arbara channel oil. How company, and tha.rostoncn ... tQ b3 sent nor *h to the. San Frsr. cf the Channel oil, Ior exi-, _ ^ ef^ct determinations of the r Bay area for refining? Thus m.o ..at_,^,. 7 traffic the Channel for marine terminals, the acro^n. 0 ' f th » proposed alternative of ard in San Francisco Bay, and the rabidity o, tn. propo a land pipeline to the Los Angeles area. IX-174 aadecruats Di-cunsin~i nr C i _ .' - ~ Sa fet^S ^a. ^ I or Subsea Squir-mf Operation, rpu /-i rv— M it* i_ ~t •»» i—* 11 ■ The Draft ELS's treatment of vessel t-rpf^in • three respects: (a) it dees not fully dsv^J ^7= SfOrient in at xtons based on Alaskan oil flows, Lffi wh, 1 T2S3sl tra ^ic 1 oil and gas development; (b) it ~-~Zli T cna Sariua Barbara by various recent Depantneni of the^^feu^Sof \° r-to as to the standard regulation pro-dr”' +-r n f 1, ^apact (see appended list of eight dif^.v^LSi. 0 " 1 , I ^f i9r8s ta shipjna; ec®t interior publications) • and ?cfth=^St‘“° 0i ,' /h i? :acdard ’ culled ts no discussion of what imroveral^s su”~ --f a ° n ’ nI ^ tl f? t --S nsasures" storing systems, night conceivably'b-’aa^aT^ ***?««* collision. 7 a?r -—~ >-3 reduce the risks of foas^lf 2009 tto3 «" 8 «S. £^s±T. P gf ^'aif d^ l0= d ’? Bb tha eduction acSmy^°1S’;i h f^4 ? ? 17 to + sweral ^pects^of'OcHa^ «rr.or and the legislated, 1 ^4^ “ d S3nt to ^ eat merit in the Draft EIS. ° a ^ ! - s that it 13 not given 1 ■ 5 r aa >• “« ; c ?«=8l petroleun development.* 1 ^.affect Santa of P 1 ^ 33 agricultural lards ,,1°j-l'L.,- Policies relating to at the availability of onshore 7??, 01 ^ ^^lity, which lc'es rplb+in^ 4. J ,. e P-C^wooXTU, iacilltles in Von-f-i^a p 01TT .w^ -.^-ws relating to consolidation of oil a—' era- ,7V:? V ou ^7; •shnant of qth nae- n — -1-Ho °~*~ 3 s_w03 and xacilitiss* -• —simas on the apoearanca ar^ n- i*x- ; -* the types Of areas where dWe 3 — =nt^tv facilities, standards recreational uses. asve_.„.mt shou_d occur, and standards to pr w5 r £ 1 III. -I"'* ,3 t wS ■KSl K i-ro** 0*4 p2 . , 0 rrn 00 rvoft EC3 should give a fuller discussion of the PS 52 i-65, paragrapc 2: th. Er. El it eight be c on s u la r ^X^^nfX^yU Z thT project; the capability of. facilitia S£ri ! «E of joining tcgsthsr the P- viill the joining process ta Possme -viron^al exxects if «*• £~L . -A^ ^ Cssi 39 possible en 7 ircnieuuu-L 7 - Tslunda? _ place la the coastal permit zone oil the Gha^nJ. loian . r , . m- a single sentence identifying "the Saj Page 1-65, 0 f h-^industrial activity" as "a probable prewar. r STt’ fl Sl«o^3'*’i7an unacceptably brief consideration ox an in; si.e for platiorau “ £hou j_ d analysis of where exLsti’ Dlanmng issu_. Hscus3i constructed; where there a piitfo^s ■££> platform fahricat: shipyards or Outer ^a r." , far platform fabrication i night occur, and “ • Mrahl= tin- period: and where, if net i lik=iy to be vatnm the appiLcaci- “- P'-J i iiTinr fw Trrr-'i,^ tih , n ~c= 33 ary platforms wiii ba constructed, gi-.-^ -t. cSSSltil to S^dlor piatfoms that could nataria^a U a r accelerated offshore leasing proposals on the 7 ' » coasts. 40 , _ ^T=?ci23S‘ion of siibsea compleiicn ana. prochieuicn, s/st’ Pages X —77 to 1 111- 7”, 4.-+.;.^ nf i_r^or~ P tion as to vtiat vraler c r would be enhanced by presentation of x-u^-u o B w and economic considerations dirta^_t. u=e ^ ^ tha safe , be useful to have izncmaT.10n r.giu—. 41 be useful ao nave mcna^ ^ shallower waters alon record of the numerous s f ttbl'c—ai Comments, above, t Santa Barbara Channel, is noted in th^L-n--- , > , - 1 A t- a substantial discussion oi hurf couo -5 '-Ps~ D - — ai cn 1 ^stins:* Enomtcrring p’xiblem of regulation of suosea system design, --sti^, -o. — _ maintenance, other than cn a case-oy-case oasio. Pag r 1 ok~n■ T^e Draft EI 3 presents all of two paragraphs discussi.-^, til¬ es I-12o-7: i oc =tion of, onshore treating and storage f, for, and the possibl- g at scms of the existing onshore Federal CCS prediction , might to accommodate future production, ..,dep-n fu^gfhanical cc there is no further information Wnichthat ^k^e^siXs. With better information as to gchl-ical condition, cc r>^oc a rt d.0£TSS 01 Uo2j ^ 1 , on ern^ a-.u. ^ gtc• 7 there is no way to rn^sur ownership, excess a/a_^.ciblw - t 7 n onshore seps accuracy of the * 31 » P ™3 -ti f that 1-5 edi^^^ dc .-j facilities nay oe r~qui_— . - , h . At the very least, the EES couU.preserrt such onshore treating and storage facn^Oxies i-- t— Carp t- 42 which handle thl pris^t Federal offshore production. ft (morSk <♦) 'TP- / dL IX -176 - 5 - 136: The Draft EIS notes that at present there ere terminals in the Channel area then ? seven nearshore loading in Channel production would reouire the 3 ^ ^ Say ’ " A 3i £ nificant increase or the modification of existing ones " Sush^ae^ 10 ? °h addinS n6W te ™inaT: essential issue preclude" anal veto ’ tb facile treatment of such an impact of additional Chanel oil and gas'd^ 1 the overa11 identify the location " gas development. The EIS should facilities; those with the bes+ potential^' ^ exlstlns use of ’ the existing duction; and the degree to which w servln S new Federal pre¬ construction of an overland otoel 1+ + d lltieS might be ^placed by an overland pipeline to the Los tageles/Long Beach area. tion of Marine .j S - ade quate Discussion of Consolida- potential tor consolidation through coordtolif^ \ dlseussion of the should also be included among possible "Mitigating ^° Pment "'isysSuh«« *. .» *—» result from such Platforms!" No ^nfo^aSoris 15 ™ * 1 ^ 11 “ ight this projection: how much oil night h„ * * given, however, to support of the two existing facilities?‘is there tor^ What ±S ^ Capaoit F .:s:; sr probiems that -IkilZTllly , 2 natto!„tofanfLSdwLf°ofmototo dto n SSi ° n • ° f LTLrb2aX e ^ef£n!i e n rr?f lnS: and the - California Borderlands leases planne! q to”e S in°DeSe"?^?' ^ S ° Uther: 46, top paragraph, continued from page 1-1ts* c. mn paragraph 1 (above). P 8 Same comment as for Page 1-145, 46 to 1-152: The Draft EIS could nresent r,m„ about Planned or underway operations !!th! m ° re ourrent information sheet of information from Se Oil “rt vara ° us ^its. See attached section makes no ^^0 ^^ g _a|J£H£gal of July 7, 1975. This areas of the Channel, P-0176, P-OI99 a!d :To21 "i 1 ! 6 ^ separated if Oil company ownershio ’ P-0212. It would be helpful each unit discus™! lnterests were deluded in the information on At two places on this page the Dr^tt ftq 0 -l _l ,, KS toSor“ ^ 0ffSh °- P ^ d "".™e fr0m new onshore tre!tin! easting treating and storage facility or to a between Port Hueneme and !^tor!" ^It^LuldV' 0 '* 1 ' 1 probably be located fuller, more informational Sshofafto to! 6 i P ° S ! lble b ° present a Potential for expansion of existing r S Z 1 ®. the lo oation, capacity, and Production that would necessity g faci J ltles ’* ^ amount of offshore land use conflicts that might affe^T facill ^ y; the environmental and County, including policies relating tn anning f ° r a new facility in Ventura and the fefsLility of fining a San f it ™ agrlcultural Centura County. g Ian afall for the oil other than in IX-177 - 6 - Page 1-151 - 1-152= -re - 1 " SrS’-Sefof L^S involved, of the reasons for the low estimac = por exa mple, the tracts number of facilities -hat mig depth it is hard to know froi might be broken down according^ ^ nQt nominated previously for le the discussion wliethe of unfavorable geological findings, because of water depths o toward deepwater technology, the El With industry advancing so rap: L ^L/of how quickly some of these trac should present Anther consideration of how quic y ^ petroleum p^ranrr^s^^d^op for leasing of these L tracts. 46 n o Q „+.t #7 above) The EIS should present a fulle 3age x-165: (See "General of the Coastal Plan, at least " discussion of the structure might have an identifying the policies developed :m the KLan^ha 0 and gag develc effect on the manner m which Santa Barbara ^ ^ gpU1 hazard , air is carried out, including pole ime agricultural lands, siting quality protection ; ^VUilities related to offshore petroleum prodi of offshore and onshore facili ^ional opport unities, developme) marine and land transportati , c tal P i an . Ideally, preparatic ss on OCS development of the Coastal Plan. 47 * VOLUME II Page 11 - 387 , Table 11-53= This table could be significantly improved by upda 48 [Attached to these comments is a more recent listing. p age 11-390, 11-391= On ^ese pages the Draft EIS purports^^give^ descri,: of "Marine Transportation and Oil ana . , . An-a-in thi: ^pef/of the Santa Barbara Channel TpZ* document simply fails to P ve Santa Barba: the degree of development tnat must occ , f enviro nmental: Channel oil and gas developmen , an suooort offshore petrol- Which of the harbors, for example, presently support oilsno y ^ activities? What kind ofociate^traffi^ and with what effect on coi of offshore petroleum-associated trailic, a oaDacit y of the Sh marine vessel uses? As to pipelines, w Reach area? What is t Oil Company pipelines to the Los Angeles/ s a i on g the Shell ri present excess capacity? Is there any extra ^ roved by way for expansion? Table 11-54 on page H -392 could be imp figures as to present levels of use. Some anafytrcal lang^ge f ^ the potential of any of the existing pipelines to handl y production would be useful. 49 IX-178 -^3, Table II 66: This table would be improved by the inclusion of rinformation regarding present levels of u-e of +L T ! ° f vessel traffic at each f af >ilitv i • .• 1 he moorin S facilities, can be accommodated (tonnage and draft^ ^ ? 1ZG ° f Vessel that the potential of each oTthe extt } ' ?° me analytical treatment of pipelines and onshore f JTittTs) ZZTZ facUiUes ( and Re¬ production, or conversely, to be phased ou “ CreaSeQ y olu,nes fl '° m new -useful. P iased out- of use altogether, would be * * Eli - and due to thef Lkff spef f c taowS^of^^ad^itio^ oiT^T be required." While this statement may b» partiailv t™e + ^ b ® is known about where oil - P true, certainly enough is knowable about existing^ f. fnZlt °fl?lTZ 7 ’Z* ZTZZlZZZ ZZVT * 1 —f n alternatives, and Spaces and lo Tnd t deVel °™ requirements, of "mitigating measures" ’ The =t h UC some area-specific evaluations California Office of Placing and he prea ^ bein S conducted by the ’ An EIS that does less than this win 1S attem P tln S just such analyses. already known ZlZfTZrTZZeZLlZ Ut ? 6 to What is amount to a critical missed Tee ? T davelo P ment generally, and will potential for developin' of-sfoT f 7 , Raring fully into the environmental disruption. * P ® " r ° leUm ln a maImer Rat minimises 'ZZZZsZZnZeaZZZ ^ ROt necess -ily the "natural be reclaimed for other' priority ufes ^ Z th&t onshore sites should or recreation, when their life jq on’ ? G + ^ PG ancludln S coastal open space historically it is infreouent thqf mpdeted - A principal concern is that allowed to occur is returned to nonf fuf rlf tsif deVelopment i£ by a vessel (withT^latforia^is flikeff 101 ! ^ Draft EIS states "Collision tional equipment on lll pa Ts „g sZsZZl ° f ° b nava S a - St:rX“a1 - T -d axLugh^ge^ “3,' if in the Gulf of Meiico off'Vf f " ith “ offshore drilling platform substantial ofde of fm Tf™’ Te fl Whi ° h resulted in laa ^ include discussion of +L % 4- several death s. Discussion also might the Channel the decree V ° Un ^ ary . nature of tha shipping lanes through Lanes, ^anyL m ■+ ^ exlstln S traffic adheres to the shipping aeration in the Channel ^rea^^ ^ dlrectlve °P erat ions currently in ! tatement s S in t various I, nen C °t Cer + °I Gr the . several apparently conflicting distance between shippin/lanpo ° H Ipt ^ pi0r documents as to the required 5 , above. sh iPPmg lanes and platforms, see "General Comments" IX-179 - 8 - JRSS US* 1 VI #; mtj** !^3 «S3 5*3 B-= •"Si ^V-/ jJ . UM-yi^J A? fc*^ <4 *rVA*~ (L // '/',// V -• ^ Lx^vU j / -,tAl*-^L• DOI's manner of per a ting and history make it appear that if 4- o^peccr mat it seeks to circumvent he procedures and examination that NEPA and the public demand." 2 _ Th ® ° nly Ume that the P« bllc has been able to give any Sal ^ nput lnto tjls decision-making process has been at the wrings; " DOI's chosen arena is within the Executive Branch -ling with the public only at hearings...'" when by la W 3 thl • !bUC Sh ° Uld be involved to a greater degree in this process. honestly question the impact that we, the public, have at these IX-425 LIBRARY u. of L URBANA-CHAMPM S H hearings; "...the draft environmental impact statement issued by the Department of the Interior is merely a pro forma doc¬ ument..." 4 implies that the decision has already been made and the hearings and draft DID are nothing more than procedural tech localities. That, then is my first criticism of the Draft IS; the public did not have sufficient, if at all any, input mi,o tne creation of this docume t, that ■ states it ".. .is to serve as one of the bases for future decisions by the Secretary of the Interi and the U.S. Geological Survey regarding future OCS oil and gas 5 operations in the Channel;" A second critisim of the Draft DS is.that it comes across as a very subjectively written document, its bias leaning sig¬ nificantly towards advocating the leasing and developing of the SB channel OCS. The best way to'illustrate my contention is review certain passages that are found in the Draft Do. The effect of minor oil spills on the marine environment of the Santa Barbara Channel can be compared to that of the natural oil seeps of the area. (111-1210 The impression that is given from this statement is that minor (however many gallons or barrels that "minor" is) oil spills are similar to "natural seeps" therefore there is no need to worry, however, the reader is not told what the impact of na¬ tural seeps are and what the impact of natural and man-made oil spills put together, are. The impact on the physical environment.during opera¬ tions of offshore treatment and storage terminals would e minor,except for the possible effects of minor recurrent oil spills or major oil spills. (III-86) No where throughout the entire Draft ES does the draft a uately- cover a major oil spill or the cumulative effect of several minor spills; therefore, the reader of the above state¬ ment cannot in all truthful ness comprehend the impact of re- IX-426 current oil spills and a major oil spill. The point that I „ a ,.t o .et acioss noro is that for an official federal document that su^pood io analyse^ certain proposed action, it does so in a very uncritical and A objective manner. Some more phrases: an energy shortage of substantial proportions (i-i) IS possible but not likely (III-io) d "1eSK ScKr• 1 that there is not as much petroleum and gas as ^neric would, want, hut as I ’wave aim': pointed out, the o.J. with respect to energy. : e :ovcr-v' r , jjra. 1 . c , ndustri <-■ . ■cwizl- toll u. sufficienI v-t 0 - : -aspect to on or ' n 1 -i «-> - _:_L l , cA ' l'cary nf v;e don 1 1 becomo se 1 f- n.o.m. v 1 j we mil lose our e^o.mnic security, (2) our standard of livin~ v n * 11 ~ ■" * U-/ —*• - —•- f --Op, (J ) f ov; v. r j 1 3 t ''0 ” 1 -n- nf n ~ A X 1 1 ' - e ,,aicle a^s balance of pay ments. -i r\ 2. mod 1 p•? o i ■ V elv yn ^ jr e £ovor:i;neiit 2:?enc:Lve a ^ Gw. affiliatcs . Q ts ci C- 0 J.J. a^ 1 Cl a .q nn -1- * •’• 1 • r- ('• *"*-i O- - .0 so 1 - 4t, -- ' _ .p 4,7 • 0-. one OTi V*i r , rv"-iov'!-»-1 i• i , .. 0 . i:ar - a xt d00s - is the tactic and strat- c u i i - 1 -rr e sp o c t i ve e '-r tUp-j- 7 -, ^ DGjl and • o:l 1 acd jas in dust] p o - - Wo 1 ^ ••• -o>w r -'.ployed. Tic -caX answer, : 0 ;ipv«r» -* ■ ^- 9 -- ri o . ,r> • i _ tO f 1 r' n r [ t on^l -- unuJ. ; nfi a *• i probl si:! and then. ha.~’ a vr -pi o •? -- — ' ^ l( j.i sol-v';io‘ - : S ^ j .'.st one— cV . 0 . 1.0 jy oia ..... y ox two lb clan- r -~\ r\ r *' * — ^'i UOu ( .1. 1. i-iy cra'ci cme -v- , :-> 0 _ _ ^ - 's -.o — (/ .uaj as not loci -£»-l- in L J- 1. I •'• •or' r- r* "! “| '> ~TC\ ’■> « 4« T , - —^ u i aavo * H T “■ (O ‘ ' td -1 r nn - ~. i ~ J O U i r'- 1 o\ • recoa v;ou? r 1 v .o • i • x.ia g .;oi^ o -yr -r*,* ^ r . . . - ^ i ' l v - - -*• ^ ESTABLISH as a working* rmiinv t 4 . TOrKln S Policy, I repeat, a working policy, tfte process of communicating and sharing all data with state, county, local governments and private individuals, agencies, etc., when ’ formulating an fENVIEOI’JMENTAL IMPACT STATEMENT. IX-429 LIBRARY u. of l urbana-champ**** RESPONSE TO MICKEY GUTIERREZ !. The assumptions are unwarranted. Refer to the Preface and section I.A. for the stated purpose of this environmental impact statement. • * n „ i non ronies of the statement in draft 2. The distribution of approximately , P form, holding of public hearings for oral comments, receiving written comments and responding to such comments are the means by which all interested parties contribute input to the final statement. Approxi¬ mately 600 copies of the draft statement were mailed to parties the Department believed may have an interest, the remaining 400 were mailed upon request. The availability of the draft statement was announced in the Federal Register and in a Department News Release. 3. This is noted in the abstract of the Public Hearings along with a range of quite different reactions and contentions. The position of the USGS is nonadvocacy„ 4. Quantification, to the extent of available data, appears in III.L.l. Section III.L. assesses the impacts of oil spills regardless of source, and notes the fact that the fate of oil in the marine environment and the impacts of ongoing research are subjects of ongoing research by many investigators. Some of the published conclusions and data are conflicting. Additionally, there is a paucity of data in some areas, including the subject of cumulative impacts of natural seeps and man- made seeps. Both the National Academy of Sciences, 1975: Petroleum in the Marine IX-430 Environment, and Kolpack et al 1973 Fa t-„ n-n • /i. Fate of Oil m a Water Environ- ment--A Review and Evaluation of T -<- he Literature, are comprehensive references on the state of knowledge. TO quote the preface of National Academy of Sciences, 1975 (see sectio, III references): "In the future, the uncertainty regarding petroleum in the marine environment can only be narrowed by the accumulation of more firm information. Until then we must be content with figures of less than complete certainty . . . Divergences of viewpoints were discussed and mostly reconciled without rancor, despite the importance of many questions and the difficulty of obtaining reliable data." The University of Southern California Environmental Geology Program notes (Kolpack et al., 1973, see section III references): "The litera¬ ture indicates that there has been an unbalanced treatment of the various questions related to the i • oil m the water environment." The California Coastal Plant fl 975 n zn Uy/b, p. 34-35) prepared by the California Coastal Zone Commission recognizes that: • The long-term and sub-lethal effects of spilled oil are not completely known. There have been few research projects on these effects and conclusions so far have been equivocal. . Studies on the effects of spilled oil along the coast are complicated by the presence of natural oil and gas seeps that regularly emit petroleum, with unknown effects on the marine environment. See our response to your comment No. 3 above IX-431 LIBRARY u. of /. URBANA - CHAMP A1 6 H 6. The DES is not a lease sale statement (see section I.A.). 7. Socioeconomic impact considerations have been greatly expanded in the final statement. It is repeatedly stated that the onshore facilities would have to be in accordance with all applicable County and State regulations. Refer to our responses to EPA, The Resources Agency of California and the California Coastal Zone Conservation Commission in regard to the Coastal Zone Plan. See sections I.F.Z.a. and IV.A.l.h. for an updated and expanded discussion of the Coastal Zone Plan. 8. In the draft statement, energy conservation was the first alternative considered in the energy alternatives section. This discussion has been expanded in this final statement (refer to section VIII.G.10- 9. Refer to the Preface and section I.A. for a discussion as to the reasons for initiating this statement, and for the basic stated purpose. This statement identifies and assesses the impacts that would result from possible future Channel development. Three of the four possible levels of development involve areas that were leased prior to 1969. 10 Refer to response number 4 of the State Lands Commission. IX—432 /TPS/#?.. &^&is j&t«zJ^xJ, i//? ZA &rC-2 /tl^lX^ X^Lzx^x^^- y4x^ r j4c4tz^4Ls /AlZstj y &&?'L&ts y£XU / / y<4?/ f ;>1 /C/L£ jd^Z ^ S7 - . t^Z^X’ jXtHxTfX , ,. /,—^w - ^ v_— -y/ - , c 7 ^-^ jXfZ'Z^^ixzx^X'TZxx'c *?? /^X^XZ^nx y^/ /V'Zft X'C^ fj .&'7 / c-x> &<'<-d? ^ X/^f^zX f ^w^, XsCt^ ^ ^■OC^ V^zm*, t6te/&*4& ^ ^ IX-433 LIBRARY u. OF L URBAN a -CHAMPA* s m ERNEST J. LOEBBECKE 433 SOUTH SPRING STREET LOS ANGELES, CALIFORNIA 90013 July 31, 1975 Director U. S. Geological Survey Mail Stop 108 National Center Reston, Virginia 22092 Dear Sir: I would appreciate your entering this letter in the files of the August 25-27 hearings in Santa Barbara, representing my opinion as a private and interested citizen. As a resident of Southern California for the past forty-five years and one who has used its beaches and oceans for recreational purposes, I have some knowledge of the effects of the oil production which has occurred off-shore during that time. The so-called Santa Barbara Channel spill was an unfortunate incidence, but the drilling companies immediately responded to the problem and any damage must, in the long view, be considered as extremely minimum. I am informed that since that time the oil industry has developed a containment capability which would greatly reduce, if not entirely eliminate any effects in the unlikely event that another spill should occur. I am further informed, and I consider the source reliable, that some 18 or 19 thousand wells have been drilled on the Outer Continental Shel and that only 4 spills of any consequence have occurred. In light of this nation’s desperate need for oil it seems to me that such a record in itself would dictate that the development of off-shore drilling should be approved and encouraged, particularly in light of current levels of technical competence and supervision of the drilling companies. Here in Southern California there is a more pressing need for the IX-434 m Director U. S. Geological Survey - page 2 July 31, 1975 rrtr sr r;“r n r - wmi“r,* h rr„rr 1 r* »srr r “ course of the next two or three" 1 years' 3 ^ Calif ° rnia in the another reason for the continued a ^ ’ 14 seems to me, is Channei area. mUed devel °Pment of the Santa Barbara It is my view that the course is ■, T further exploration and production in that d y ° U t0 encoura ge leases to qualified and interested producers^ ^ additional Very truly yours, 1 -'-' ^ Ernest J. Loebbecke IX-435 UBRARV V- OF L URBANA-CttAMPNM* FERDINAND MENDENttALL Director U.S. Geological Survey Mail Stop 108 National Center Reston, Virginia 22092 5 August 75 Dear sir: to attend the hear- the question of Unfortunately, I will not be able ings scheduled by the U.S.G.S. on economics of Southern California, and tb. nation, stJs-.Si.’KiS 23 tion Also, Please give serious consideratron to recommending the offering of additional leases in that area. The nation has seen, during the past eighteen months, the terrible effects of the lack of domestic crude oil a^d natural gas on the economy, on the consumers and business in general, and ^ employment. The part about all of this is that it is unnecessary if the Alaska pipeline had been approved four years eLu- than it was, as it should have been we would have an additional two million barrels a day avail able domestically. When the argument about Alaskan pipeline was going on, people were saying now that there can be further delay in developing the Outer Continental Shelf, including the Santi Barbara Channel, because if it is developed the oil will not be available until the late '70s. In the first place, some of this oil would be available very promptly because the explor.t^nd^lace, ment phases have been completed. . In * he n , ?o ; the oil will certainly be needed in the lat and in the 1980s. This remains true even * °"® get full production from Alaska and from Elk Hill The problem of natural gas is slightly different. W simply cannot afford to meet all new requirements for IX-436 Director U.S. Geological Survey Page 2 that possibility!^ tL^TsT^ ' , ^ ^ in conjunction with thl natural gas to be found the Santa Ba^PcPPP tPr naPuraPP a 0il ±B right here!-withPP h r PPlY ±n S ° Uthern California- are not found and made available!" 231 S “ " eW Supplies 3 P ppp%PrPtLPd t ! i Pr:: s pp e --e t Pi n s rp h B3rb3 - h::r:pePeP e fi n °pL spil1 -- mind that th 1 „ ! area; and when one bears in and clean-upcapabilitv"fI “ providi ^ containment ""it’?; 1 :;!*,;:",;"** 1 - 1 ; .„;*r able circumstances 9 be3CheS Under an ^ -onceiv- Sincerely yours. g x _y yuurs , ^ \sivr»4**i V-\^cO<^LilC> FERDINAND MENDENHALL IX-437 LIBRARY B- BF / URBANA-Fit* HOWARD MORF INVESTOR 1770 EAST VALLEY ROAD SANTA BARBARA. CALIFORNIA 83108 August 7, 1975 United States Department of the Interior Geological Survey 7744 Federal Bldg. Dear Sire: r, a 3 ft- i 11 I have completely overlooked the expiration date to requ« time to express an opinion on your hearing, August 25, 26 and In my opinion, it is a most unfortunate situation when a misguided segment of our population Is really confused as to the American economic mechanism. How, more than ever, we need oil. It is an Important factor In solving our balance of payments and In gaining nor* respect for our dollar throughout the world. Obviously, curtailing our Imports will help to control flatIon. This is important to the majority of our population who must also he considered. I lived at the beach for five years, from 1945 to 1950, at Fernald Point, here In Santa Barbara. Then, as now, we dl find some tar on the beach, oeeaslon&lly. There is no Justification for the delays. z*. a 3 ft- i 11 IX-438 5401 Lennox Apt. 80E Bakersfield, Ca. 93309 August 5, 1975 Director D. S. Geological Survey tfS 108 y National Center *eston, Va. 22092 Re: ear Sir: • „ , , ^ ■ Lj11 v j-xunmental the S s S G a q em r t prepared b y for Public comment on developing oil and gas reserves in the Santa Barbara, Culiforma Channel ike to S go n on n rlcord e f s C favorina f t^ h % United States ' 1 «°uld ' irbara Ca lif° rn ia channel for^ifLf gL^dnc^on " 6 ^ )reign sourcls^f ^il'and e g as lte we S h ateS ' beSn de P ende nt upon 16 inmediate development of oir o^n oU and'gaTre^rves'? wironment, but the^ee^for ®°” e adverse eff ects upon the verse effects. 1 d gas far outweigh the some adverse h effects' S that n s uch d althou 5 h there will feet on the environment haVe a significant e economic effects are to .understand the Federal law, verse environmental effects. 91VSn egual weight with the lision !^ 6 that the laW wil1 be followed in making your :omplished for^ear^L^th^Guff^f been successf ully uring the environment At the^^ Maxico without seriously ivity has been of tre^endou^ l? V 1 ”?' this e oonomic ire United States. lue tC> that are a and to the shore oil 1 and°gas a resources lt and a i i It t0 develo P ment °f the elopment. and 1 strongly advocate such Very truly yours. Gene E. Steed LIBRARY u. of l urban A -Chabspai 6 H Jdhn V. Vaughn 555 South Flower Street Los Angeles, California 90071 August 4, 1975 Director U. S. Geological Survey Mail Stop 108 National Center Reston, Virginia 22092 Dear Sir: t win not be able to attend the hearings in August on in f.hP files of the hearings. domestifoirand nati’al^^businesfl^geneMl^d o^“employment. We must develop our energy ^ so ^^ or Sro/tfone^o^urwirfcauL^ff^rrfrea^ I urge you to support the development °f 011 “ d & P nd that in the Santa Barbara Channel Continental Shelf additional leases in the area be offere . JW: dvr IX-440 CAROL ARTH WATERS 1842% North Normand,e Avenue, Los Anceees, C,uforn,a 90027 July 31, 1975 The Director U. S. Geological Survey Mail Stop 108 National Center Reston, Virginia 22092 Dear Sir: I am aware that hearings will ho h Q i j • 0 August 25-27, on the draft enviro Santa Barbara 5 California ofe 1 011 and ~ development, "santa that you enter this^etter into^he'^record? 3 ^’ 1 W ° Uld re< i uest Channel"^ (^further olUnd T woman and as the owner of Sant,* R*r-h * 1 d ° S ° as a busi ness- As a Southern Californian for 46 years'" ? r ° perty with my husba nd. by the lack of domestic crude oU and^ura^gL!" ^ People who occupy positions of leadership a, posed to lead us in tough times as well L ’ therefore < sup- one foot and then the other and said "yes '“no ^ St °° d ° n we have urged that they get on with thl ’k Z’ and “^be" while velopment of our domestic reserves puts us chat^h^rttt b^d' better tharatyone^ltr^Iltding^he^nT' dldn,t Uke “ an > vinced that the companies will otetate with P3nl63 ‘ ” e are con ' SPUI occur, that they will thoroughly and c^LTta^’c" 3 ed. We do noriLrany^ote time°to tT 828 „ eServes are not develo in our own interest. rgue# Decisions must be made Sincerely Mrs. Carol A. Waters IX-441 VERNMENT PRINTING OFFTCE: 1976 . 685 . 100/37 Region fc _ ^ , ' UNITED STATES DEPARTMENT OF THE INTERIOR FINAL ENVIRONMENTAL STATEMENT OIL AND GAS DEVELOPMENT IN THE SANTA BARBARA CHANNEL OUTER CONTINENTAL SHELF OFF CALIFORNIA PLATES 1 THROUGH 7 PREPARED BY THE UNITED STATES GEOLOGICAL SURVEY DEPARTMENT OF THE INTERIOR b. t. (Director) 0 LIBRARY UNIVERSITY OF ILLINOIS AJ URRANA-CHAMPAIGN Unnamed PLATE 1 EXPLANATION Ashland Oil and Refining Co. Colorado Oil and Gas Corp. J. M. Huber Corp. A. Boundary of unit areas LEASE HOLDER Proposed National Energy Reserve /RINCON V- J B8-PRC 3403 SAN MIGUELITO VENTURA VENTURA □ Leased State parcels P-0215 Federal lease number PRC-3403 State lease number Terminated leases LION MOUNTAIN OAKVIEW TIP TOP, CANADA LARGA & C?" WELDON CANYON o Oil field Potential oil field <0 Gas field a HOLLY Drilling and production platform □ Proposed drilling and production platform • Oil and (or) gas seep X Brea and (or) oil sand deposit Three-mile limit Leased Federal parcels UNITED STATES DEPARTMENT OF THE INTERIOR GEOLOGICAL SURVEY 120°30' Gaviota ALEGRIA C b, XXX REFUGIO COVE (abandoned) CAPITAN CONCEPTION OFFSHORE POINT CONCEPTION .OFFSHORE Capitan CUARTA OFFSHORE ^-LAS VARAS (abandoned) ^GOLETA (abandoned) ^n ALEGR iA CjfY YFFSHORE •apitati Beach NAPLES • OFFSHORE •<»' HARR) ELWOOD Ci-nnon DD-PRC-2879 SHORE •SUMMERLAND (abandoned) LION MOUNTAIN- SANTA BARBARA Montecito E-PRC 3120 f I X $ -[ Goleta P oint . COAL OIL POINT OFFSHORE | '^-H-PRC-309 SANTA MESA- UNIT AREA Unnsnu-d Carpinteria •0189 iOAKVIEW i TIP TOP a SUMMERLAND ' OFFSHORE^' CANADA LARGAx. HILDA Rincon Mountain HAZEL f>-P-0187 .-Point P-PRC- 3133 # - ~^)B-PRC- „ - ^ 1466 "^-= Ririctin Beach, RINCON' — "N ISLAND R-P-0194 SOUTH ELWO( OFFSHORE -WELDON CANYON :-4031 \j l-PRC-3150 CARPINTERIA ^ OFFSHORE-^. •RINCON SAN •MIGUELITO ■) HENRvFqJ". houghin' 7 - "HEIDI' J-P-01-66. VENTURA hillHouse N— >w\\\s Unnamed VENTURA POINT WEST MONTALVO yY-PRC-3314 Unnamed li-P-Ai>17 , r 4.-- ODFF CLARA SANTA Unnamed h R-P;b?08' Unnamed SAN MIGUEL Devils Peak Carrington Point ISLAND NTERI0R —GEOLOGICAL SURVEY. RESTON Shoreline from U S Geological Survey Maps Nl 10-6.9 (Santa Maria) and Nl 11-4 (Los Angeles) Bathymetry from U S Coast and Geodetic Survey Maps 1206N-15. 1306N-19. 1306N-20 Revised May, 1974 15 NAUTICAL MILES 15 STATUTE MILES APPROXIMATE M t AN DECLINATION. 1974 15 KILOMETERS 120 ° 00 ' 119° 30' BATHYMETRIC CONTOUR INTERVAL 50 METERS MAP SHOWING OIL AND GAS FIELDS, LEASED AREAS, AND SEEPS IN THE SANTA BARBARA CHANNEL REGION PLATE 1 EXPLANATION o Oil field Potential oil field U.S. GOVERNMENT PRINTING OFFICE: 1975-0-690-036/28 ■v CD C CD CD O C O CD cn O - O O Ui CD C k_ CD CD O CL O CL jD O CL ZD r o r JL U— I CD * h- CD o a> cd cd > "O CD Nl • •■■■• “5 . o 34 ° 00 3 4 ° 00 ' Plate 6. Complete Bouguer gravity anomalies, Santa Barbara Channel region, California (Anomalies west of longitude I20°00' and south of 34°00' from von Huene, 1969 , and anomalies east of longitude 120°00' from Hanna and others, in preparation. Contour interval, !0 mi/liga/s.) u. S. GOVERNMBTT HIKTING OFFICE: 1975-0-690-036/28 e^oiAen P*?*" s-v 7 SIGNIFICANCE FOR GEOLOGIC RECENCY OF FAULTING TIME GEOLOGIC EVIDENCE CONTF SYMBC c 03 Ph Minimum limit on time of latest faulting Actual time of latest faulting Maximum limit on time of latest faulting present F | past '"Oldest preserved unfaulted rock or < sediment deposited across or intruded ^along fault C Youngest preserved faulted rock or sediment C < or Youngest preserved fault-produced geomorphic feature < Figure 1.--Basis for determining recency of faulting: available geo limits on time of latest faulting, and symbols used to show that i on map. Stratigraphic relations are the chief source of in¬ formation for bracketing the age of latest faulting. Relations between a fault and adjacent rock or sediment units ideally can define maximum and minimum limits within which the latest faulting occurred (fig. 2A) : the latest faulting must postdate the youngest faulted rock or sediment and must predate the oldest unfaulted rock or sediment unit that is deposited across or in¬ truded into the fault. How closely the time of latest movement can be assessed depends on the closeness in age of the bracketing stratigraphic units. In areas of surficial deposits, stratigraphic and structural relations may be inferred from discontinuities in the flow or level of ground water in the deposits. For instance, the presence of groundwater barriers, imped¬ iments, or cascades within water-bearing Pleistocene valley fill may indicate faulting of at least the lower part of that material. Certain geomorphic features can supplement strati¬ graphy as a means of determining the age of latest faulting (fig. 2B). Displacement of the ground sur¬ face by faulting commonly produces features such as scarps, closed depressions, or offset stream courses. These features are short-lived parts of the landscape, and their presence indicates relatively recent fault movement. The age of such geomorphic features thus determines the maximum limit on the age of latest faulting, because the faulting can be no older than the age of the fault-produced feature. Criteria can be selected whereby different geomorphic features suggest different ages of the most recent ground dis¬ placement (see footnotes to age-range chart in map explanation). Such age inferences, however, are particularly uncertain because the rate at which fault-produced surface features are destroyed depends on such variables as material hardness, climate, and the activities of man. The time range of latest movement can be most close-