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                   ACKNOWLEDGEMENTS AND DISCLAIMER
      This report has been reviewed and approved for publication by the U.S. Environmental
Protection Agency, Standards and Applied Science Division, Office of Science and Technology,
Office of Water. This report was prepared with the support of Avanti Corporation (EPA contract
no. 68-C5-0035) under the direction and review of the Office of Science and Technology,
Standards and Applied Science Division.  Portions of this report were prepared by Hagler Bailly
Consulting, Inc. (Section 5.2.2 and Section 8) under EPA contract no. 64-C4-0060.

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                                                                                          ES-1
                                  EXECUTIVE SUMMARY
A.    Background
      This Water Quality Benefits Analysis (WQBA) evaluates some of the effects of current discharges
and projected benefits of the final effluent limitations guidelines and standards for the coastal
subcategory of the oil and gas extraction industry point source category.  The WQBA considers two
separate geographic areas: coastal areas of Louisiana and Texas adjacent to the Gulf of Mexico and
Cook Inlet, Alaska.  The WQBA examines potential impacts from produced water discharges in both
geographic areas, and potential impacts from drilling fluids and drill cuttings discharges in Cook Inlet.
Drilling fluids and drill cuttings discharges are not assessed for Gulf of Mexico coastal operations
because they are currently prohibited by state authorities and by existing National Pollutant Discharge
Elimination System (NPDES) permits.  Benefits outside of Cook Inlet, Louisiana, and Texas are not
discussed in this WQBA either because currently operating coastal facilities are already practicing zero
discharge of produced water, drilling fluids,  and drill cuttings or because there are no currently existing
coastal facilities.                >
      Three types of benefits are analyzed: quantified and non-monetized benefits, quantified and
monetized benefits, and non-quantified and non-monetized benefits.  However, these benefits are
analyzed for only a small number of the pollutants discharged in produced water. Of the 49 pollutants
identified in produced water discharges in Louisiana and Texas and 46 pollutants identified in produced
water discharges in Cook Inlet, Alaska, only 11 of these 49 pollutants in Louisiana and Texas have
water quality standards, and only 12 of the 46 pollutants in Alaska have state water quality standards.
In addition, the quantification of water quality benefits was conducted for only 11 of the pollutants
found in produced water in Texas and Louisiana, and for only 12 of the pollutants found in produced
water in Alaska.  Monetization of human health benefits is based upon only one pollutant — Ra226 and
Ra228. Thus, the overall benefits determined in this analysis are based on a limited number of pollutants
and are expected to be understated.

      The coastal waters that the final guidelines cover maintain diverse ecosystems. These ecosystems
serve as spawning grounds, nurseries, and habitat for important estuarine and marine finfish and
shellfish species. Many commercial and recreational species depend on coastal ecosystems for portions
of their life cycle. For example^ the commercial fisheries in Louisiana and Texas (finfish, shrimp,

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ES-2
crabs, and oysters) were valued at $543 million in 1994; 99% and 96% of the landings in these two
states, respectively, consist of species that spend a significant portion of their life cycle in estuaries and
bays. In addition, these coastal waters  serve as habitats for numerous federally-designated endangered
and threatened species, including 32 species in coastal areas of Louisiana and Texas. Cook Inlet
supports commercial and recreational fisheries with a combined value of $79 million ($51 million for
commercial fisheries and $28 million for recreational fisheries; 1995 dollars).

      The regulatory options considered for produced water and evaluated in the WQBA are:

      •   Option 1: Option  1 prohibits  all coastal oil and gas facilities from discharging produced
         water except:  1) facilities discharging produced water derived from the offshore subcategory
         of the oil and gas extraction industry into a major deltaic pass of the Mississippi River;  and
         2) all facilities in Cook Inlet,  Alaska.  Exempted facilities are required to comply with new
         Best Available Technology Economically Achievable (BAT) effluent limitations for oil and
         grease at 29 mg/1 monthly average, and 42 mg/1 daily maximum based on improved operating
         performance of gas flotation (IGF) treatment technology.

      •   Option 2 [the selected option]: Option 2 prohibits all coastal  oil and gas facilities from
         discharging produced water with the exception of coastal facilities in Cook Inlet, Alaska.  In
         Cook Inlet, facilities are required to comply with BAT effluent limitations for oil and grease
         at 29 mg/1 monthly average, and 42 mg/1 daily maximum based on improved operating
         performance of gas flotation.  (This option would require facilities  in the Gulf currently not
         covered by the NPDES general permit to meet zero discharge.)

      •   Option 3:  Option 3 prohibits  all discharges of produced water.  The technology basis for
         compliance with zero discharge is injection of produced water.  (This option would require
         facilities in the Gulf currently not covered by the NPDES general permit to meet zero
         discharge.)

      The options considered for drilling fluids and drill cuttings and evaluated in the WQBA are:
         Option 1 [the selected option]: Zero Discharge All, except Offshore Limits for Cook Inlet
         Facilities.  In Cook Inlet, Option 1 allows the discharge of drill cuttings and drilling fluid

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                                                                                           ES-3
         with limitations requiring toxicity of no less than 30,000 ppm (SPP), no discharge of free oil
         or diesel, and no more than 1 mg/1 mercury and 3 mg/1 cadmium in the stock barite. This
         option requires no additional regulatory requirements beyond those already in place.

      •   Option 2: Zero Discharge All.  This option requires all operators to achieve a zero discharge
         standard, including Cook Inlet operations. The two control technology bases for compliance
         with the zero-discharge option considered for drilling wastes in Cook Inlet are: (1) waste
         minimization via closed-loop solids control followed by transportation of drilling wastes to
         shore for disposal; and (2) grinding followed by subsurface injection at the platform.

      Two baseline scenarios are developed for this document. The current requirements baseline is
composed of Louisiana major deltaic pass dischargers and Cook Inlet dischargers. The alternative
baseline is composed of current requirements baseline dischargers plus two additional groups of
dischargers: open bay facilities in Louisiana and potential dischargers represented by operators seeking
individual permits hi Texas.

      Although all the above options were evaluated, this Executive Summary presents findings
developed for the two evaluated baselines and the selected options only.  For produced water, the
selected option is Option 2  (Zero Discharge; Cook Inlet Gas Flotation). For drilling fluids and
cuttings, the selected option is Option 1  (Zero Discharge, except Cook Inlet).  Results for other
considered options are presented in the main body of the report.

B.    Quantified, Non-Monetized Benefits, Produced Water
1.    Review of Case Studies, Gulf of Mexico

      To identify the type and extent of potential impacts due to produced water discharges from oil
and gas facilities covered under this final rule, EPA has compiled the results of a series of field studies.
These field studies describe or assess the chemical transport and fate or the biological effects of
produced water discharges at a variety of coastal case study sites. A total of 30 case study sites (17
sites in Louisiana and 13 sites in Texas) are summarized, representing 8 sites studied under Federal
agency sponsorship, 8 sites studied under state agency sponsorship, and 14 sites studied under industry
or trade association sponsorship.

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 ES-4
      Of these 30 study sites, 17 sites are in relatively low energy locations (marshes, canals) and 13
 sites are in relatively high energy areas (bayous, river distributaries, open bays/lakes). Also, 17
 wetlands locations were included in the 30 study sites; 8 saltmarsh sites, and 9 fresh or brackish marsh
 sites. Water depth is reported for 21 study sites; 17 sites are located in water depths less than 3 meters;
 4 sites are located in waters greater than 3 meters.

      Documented impacts show frequently elevated hydrocarbons in the water column: among 8 sites
 where water column hydrocarbons were examined, 3 showed only low level effects (e.g., 1,000-fold
 dilution within 15 meters of the discharge), while 3 sites showed elevated hydrocarbons at <250
 meters to <500 meters, and 2 sites showed increased hydrocarbons at 800 meters to < 1,800 meters.
 Salinity effects were examined at 21 sites: at 7 sites no salinity plume was observed; at 7  sites salinity
 effects were noted, but not quantified with respect to extent, had high seasonal variability, or had a low
 salinity effluent; 1 site exhibited a salinity plume to 100 meters;  at 5 sites the plume extended 230
 meters to 350 meters; and a salinity plume was noted to 800 meters at one dead-end canal site.

      Sediment hydrocarbon impacts were detected to  < 100 meters at 4 sites; impacts were detected at
 200 meters to 364 meters from the discharge at 5 sites; impacts were detected at 500 meters to 600
 meters from the discharge at 8 sites; and impacts were detected at 1,000 meters to 1,300 meters from
 the discharge at 2 sites. A study of two open bays in Louisiana indicates that polyaromatic hydro-
 carbons (PAH) and metals in sediments exceed sediment quality criteria as described by Long et al.
 (1990 and  1995).  At these sites, metals exceed the Effects Range Low (ERL; or minimal effects range)
 at 1,000  meters and PAH exceeds the ERL  at 300 meters.  PAH also exceeds the  Effects  Range
 Median (ERM) or possible effect range at the discharge.
      Biological effects were examined at 24 sites.  Depressed benthic communities were noted at
< 100 meters from produced water outfalls at 6 sites; effects were noted at > 100 meters to 455 meters
at 5 sites; effects were noted at 800 meters at 2 sites; and effects were noted at 1,000 meters and 1,030
meters at 2 sites. No benthic biological effects were noted at 3 sites; while benthic community effects
were noted but variable at 2 sites.  At the remaining 4 sites, hydrocarbon bioaccumulation was noted
for caged oysters at 3 of the 4 sites. A whole effluent toxicity risk assessment (based on projected
plume dispersion and produced water toxicity tests) for 69 outfalls in Louisiana indicates 23 % of
effluents exceed the acute LC50 value for mysids and sheepshead minnows at the edge of a 50-foot
mixing zone. At the edge of a 200-foot mixing zone, 18% exceed acute LC50 values, whereas 57%

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                                                                                           ES-5
and 56%, respectively, exceed the chronic no observable effect level (NOEL) for survival and growth-
inhibition.

      Radiochemical impacts are variable, but generally of limited spatial scale. Indigenous biota,
including fish, crustaceans, bivalves, and plants, are generally found to have detectable levels of Ra-
226 and Ra-228.  Background levels in these studies are generally not known and not easily estimated.
No pre- versus post-discharge sampling has been conducted to establish temporal relationships between
the discharge of produced water radium and sediment or biotic accumulations.  Spatial data are
ambiguous and not easily interpreted in terms of establishing background levels in sediments or biota.
However, caged organisms deployed for  14 days near produced water discharges in coastal Louisiana
have been shown to bioaccumulate radium as far as 350 meters from a produced water discharge.

2.    Water Quality Benefits

      In the WQBA, surface water quality modeling is used to assess compliance of produced water
discharges with state water quality standards in Louisiana,  Texas, and Alaska.

Current Requirements Baseline Dischargers
      In-stream pollutant concentrations are projected for 49 pollutants for the major deltaic pass
dischargers.  Among these 49 pollutants, 2 are conventional pollutants,  13 are toxic pollutants, and 34
are nonconventional pollutants. Louisiana has 12 state water quality standards (aquatic acute, aquatic
chronic, and human health) covering 11 of these 49 pollutants (10 toxic pollutants and 1 noncon-
ventional pollutant).1  These standards are used to derive both daily average and daily maximum
limitations for each of the three types of water quality standards.  For the purpose of providing
information for this final rule, the Agency is primarily using the daily average limitations because
comparisons of these limitations to state water quality standards are deemed the most meaningful for
assessing projected compliance of produced water discharges.  For Cook Inlet, in-stream concentrations
are projected for 46 pollutants. Among these 46 pollutants, 2 are conventional pollutants, 15 are toxic
pollutants, and 29 are nonconventional pollutants.  Alaska has 12 state water quality standards (aquatic
acute, aquatic chronic, or human health) covering 12 of the 46 produced water pollutants (all of which
      1   Louisiana has separate standards for trivalent and hexavalent chromium, whereas the produced water
         analyte is total chromium.

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ES-6
are toxic pollutants), and drinking water standards, with which Alaska also requires compliance, for 16
of these 46 pollutants (9 of which do not have water quality standards).  Site-specific water quality
modeling is performed for each outfall/facility included in the current requirements baseline.

Alternative Baseline Dischargers

      In-stream pollutant concentrations are projected for 49 pollutants (the same as those identified for
major deltaic pass dischargers) for 69 outfalls identified as discharging produced water to Louisiana
open bays and 82 dischargers identified as potentially discharging produced water as Texas individual
permit applicants. Louisiana has 12 state water quality standards for 11 of these 49 pollutants (10 toxic
pollutants and 1 nonconventional pollutant); Texas has 10 state water quality standards covering 11 of
the 49 produced water pollutants (8 toxic pollutants and 3 nonconventional pollutants).2  For both
states, these standards are used to derive daily average and daily maximum limitations for each of the
three types of water quality standards.

      The alternative baseline dischargers assessment does not perform individual, site-specific water
quality modeling for each open bay or individual permit applicant discharger because of the large
number of facilities included in this baseline. Instead, the assessment uses model scenarios based on
typical ambient and operational characteristics, including flow-weighted water depths of 1.73 meters
for Louisiana discharges and 1.66 meters for Texas discharges.  Also, for these two groups of
dischargers, three produced water discharge rates are used for this water quality compliance
assessment. These three discharge rate scenarios are: the mean discharge rate by outfall or permit; the
median discharge rate by outfall or permit (i.e.,  50%  of produced water outfalls discharge at a rate
greater or less than the median rate); and the median discharge rate by volume (i.e., 50% of the total
produced water volume is discharged at a greater or lesser rate than the median rate by volume).

      Assessment of compliance with state water quality standards was conducted hi accordance with
state implementation guidance of both Texas and Louisiana.  For the purpose of providing information
for the final rule, the Agency is primarily using mean discharge rates and the daily average limitations
because comparisons of these limitations to state water quality standards is deemed the most meaningful
for assessing projected compliance of produced water discharges.  However, analyses also have been
         Texas has one standard for cresols, vraereas the produced water analytes are ortho- and para-cresols.

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                                                                                           ES-7
conducted at two types of median discharge rates - the median discharge rate by outfall and the median
discharge rate vy volume.  Results of water quality compliance assessments for these discharge rate
scenarios are presented in the text of the WQBA in Section 3.

a.    Current Requirements Baseline

Major Deltaic Pass Dischargers, Louisiana

      The current technology level of treatment for major deltaic pass dischargers is evaluated for
exceedances of Louisiana water quality standards.  The five operators (dischargers) evaluated for this
assessment comprise seven outfalls (one operator has three outfalls) in major deltaic passes; lack of
adequate ambient  or operational data prevented modeling the eighth outfall and sixth operator. (For the
purpose of this assessment, the projected water quality exceedances for the operator maintaining three
outfalls are combined and presented as one discharge.)  All five dischargers (six outfalls) are projected
to have exceedances of state water quality standards.

       For daily average limitations,  all 5 dischargers exceed the human health standard for benzene (6
 outfalls) and the copper marine acute standard (5 outfalls); one discharger exceeds the marine chronic
 standards for copper and nickel (1 outfall); and 1 discharger exceeds the toluene marine acute standard
 (1  outfall).  For daily maximum limitations, 5 dischargers (5 outfalls) exceed the human health standard
 for benzene; 2 dischargers (2 outfalls) exceed the copper marine acute standard; and 1 discharger (1
 outfall) exceeds the copper marine chronic standard.  There is a combined total of 22 daily average and
 daily maximum exceedances of state water quality standards (for 4 pollutants:  benzene, copper, nickel,
 and toluene) among these five operators.  The selected BAT option requires all facilities in the coastal
 subcategory of states adjacent to the Gulf of Mexico to meet zero discharge of produced water.  Under
 this option all state water quality standards would be met due to cessation of discharges.

       Current technology effluent discharges also are projected to exceed five Louisiana oil and gas
 rule effluent performance standards, required as end of pipe limitations. Benzene, toluene, radium, oil
 and grease, and TSS concentrations reported for characteristic current requirements baseline discharges
 exceed these oil and gas rule limitations. The selected BAT option (zero discharge) requires all
 facilities in the coastal subcategory of states adjacent to the Gulf of Mexico to meet zero discharge of

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  ES-8
  produced water.  Under this option, all oil and gas rule effluent performance standards would be met
  due to cessation of discharges.

       In addition to the quantified state water quality benefits projected for major deltaic pass
  dischargers in Louisiana as a result of selecting the zero discharge option, the final rule also provides
  for significant, but nonqualified, water quality benefits.  These nonquantified benefits result from
  EPA's regulation of produced water pollutants other than the 11 pollutants in Louisiana for which state
  water quality standards have been adopted. Of the total annual pollutant loading of 1.493 billion
 pounds from major deltaic pass dischargers, pollutants other than chlorides (for which major deltaic
 pass operators are projected to exceed the state water quality standard by a factor of 35 to 69)
 amounted to 87,764,126 pounds.  The 11 pollutants covered by Louisiana standards account for only
 2.3% of this latter amount.  By adopting zero discharge as BAT, EPA not only eliminates water quality
 exceedances for the 11 pollutants that have standards adopted, but EPA also eliminates any potential
 water quality/water body impairment due to the 2 conventional, 3 toxic, and 33 nonconventional
 pollutants (representing 97.7% of the produced water pollutant load, excluding chloride) for which
 Louisiana has no water quality standards.

 Cook Inlet, Alaska Dischargers

      Because Alaska state standards do not specify mixing zones for enforcement of the numeric water
 quality and drinking water standards, results of the Alaska state water quality analysis are assessed as
 the distance from the point of each facility's discharge to the point where all state standards are met.
 For current technology effluent, this distance for the eight facilities evaluated ranges from within 100
 meters to 3.5 kilometers. For improved gas flotation effluent (the selected option for Cook Inlet) this
 distance is reduced to a range of within 100 meters to  1.0 kilometer.

 b.    Alternative Baseline Dischargers

 Open Bay Dischargers, Louisiana

     The current technology level of treatment for open bay dischargers is evaluated for exceedances
of Louisiana water quality standards.  At the mean discharge rate (4,780 bpd), exceedances of state
water quality standards are projected for 5 pollutants.  Discharge rates at 18 of the 69 open bay outfalls

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                                                                                           ES-9
(representing 79% of the total daily'flow of open bay discharges) equal or exceed the mean discharge
rate and, therefore, are projected to have exceedances of state water quality standards.  A total of 7
daily average limitation exceedances of state water quality standards for 5 pollutants is projected at
each of these 18 outfalls: benzene human health standard; copper marine  acute and chronic standards;
lead marine chronic standard; nickel marine chronic standard; and toluene marine acute and chronic
standards.  A total of 4 daily maximum limitation exceedances of state water quality standards for 3
pollutants also is projected at each of these 18 outfalls: benzene human health standard; copper marine
acute and chronic standards; and lead marine chronic standard.

      The selected BAT option (zero discharge) requires all dischargers in the coastal subcategory of
states adjacent to the Gulf of Mexico to meet zero discharge of produced  water.  Under this option all
state water quality standards would be met due  to cessation of discharges.

      Similar to major deltaic pass discharges,  selecting the zero discharge option for the final rule also
provides for significant, but nonqualified, water quality benefits in addition to the quantified state
water quality benefits projected for open bay dischargers.  These benefits result from EPA's regulation
of produced water pollutants other than the 11 pollutants in Louisiana for which state water quality
standards have been adopted. In the case of the 69 open bay  dischargers in Louisiana, an estimated
total annual pollutant loading of 2.579 billion pounds is projected.  For pollutants other than chlorides
(for which open bay dischargers are projected to exceed the state water quality standard by a factor of
35 to 69), the loading amounts to 156,859,881  pounds. Pollutants from open bay dischargers covered
by Louisiana standards account for only 4.8% of this amount. By adopting zero discharge as BAT,
EPA not only eliminates water quality exceedances for the 11 pollutants that have standards adopted,
but EPA also eliminates any potential water quality/water body impairment due to the 2 conventional, 3
toxic, and 33 nonconventional pollutants (representing 95.2% of the produced water pollutant load,
excluding chlorides) for which Louisiana has no water quality standards.

Individual Permit Applicants, Texas

      The current technology level of treatment for individual permit applicant dischargers is evaluated
for exceedances of Texas water quality standards.  At the mean discharge rate (827 bpd), one daily
average limitation of the  state water quality standard for one  pollutant (silver marine acute) is projected
to be exceeded.  Discharges of produced water at the mean rate or higher are expected to occur at 18

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 ES-10
 of 82 individual permit applicant dischargers (representing 84% of the total daily produced water flow
 from this group of dischargers), and thus are projected to exceed the state water quality standard.
 These 18 dischargers are projected to exceed one daily average limitation: the silver marine acute
 standard. These 18 dischargers are not projected to exceed any daily maximum limitations.

      The selected BAT option (zero discharge) requires all dischargers in the coastal subcategory of
 states adjacent to the Gulf of Mexico to meet zero discharge of produced water. Under this option all
 state water quality standards would be met due to cessation of discharges.

      Also similar to major deltaic pass dischargers and open bay dischargers in Louisiana, selecting
 the zero discharge option, for the final rule,  hi addition to quantified water quality benefits, also
 provides for significant, but nonqualified, water quality benefits.  These nonqualified benefits result
 from EPA's regulation of produced water pollutants other than the 11 pollutants in Texas for which
 state water quality standards have been adopted.  Thus, of the total pollutant loading of 530 million
 pounds discharged by individual permit applicants, pollutants other than chlorides amounted to
 32,228,590 pounds. The 11 pollutants covered by Texas standards account for only 0.2% of this latter
 amount. By adopting zero discharge as BAT, EPA not only eliminates water quality exceedances for
 the 11 pollutants that have standards  adopted, but EPA also eliminates any potential water quality/water
 body impairment due to the 2 conventional, 5 toxic,  and 31 nonconventional pollutants (representing
 99.8% of the produced water pollutant load,  excluding chlorides) for which Texas has no water quality
 standards.

3.    Pollutant Loadings and Removals by the Selected BAT Option
      Pollutant loadings and removals for produced water have been estimated for both the current
requirements baseline and the alternative baseline dischargers. The total loading and removal estimates
presented throughout this WQBA for produced water exclude well treatment, workover, and
completion fluids.

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                                                                                         ES- 11
a.    Current Requirements Baseline

Major Deltaic Pass Dischargers, Louisiana

      For all eight major deltaic pass outfalls (6 operators), the total annual current technology
pollutant loading (based on 49 pollutants) for produced water is 1,492,600,175 pounds (Ibs). This total
annual loading consists of 1,855,319 Ibs of conventionals; 108,018 Ibs of priority organics; 33,877 Ibs
of priority metals; and 1,490,602,961  Ibs of non-conventionals.  For the selected option (zero
discharge, BAT Option 2) this loading is completely eliminated. Thus, for the selected option (zero
discharge, BAT Option 2) the annual pollutant removal will be equal to the pollutant loadings listed
above.

Cook Inlet, Alaska

      The total annual Cook Inlet pollutant loading (based on 46 pollutants) for produced water at the
current technology level of treatment is  1,056,542,206 Ibs.  This total annual loading consists of
1,781,074 Ibs of conventionals; 120,587 Ibs of priority organics; 51,089 Ibs of priority metals; and
1,054,589,456 Ibs of non-conventionals. The total annual Cook Inlet pollutant loading (46 pollutants)
for produced water using IGF treatment technology, which is the selected option (BAT Option 2), is
1,055,042,019 Ibs. This total annual  loading consists of 926,020 Ibs of conventionals; 50,220 Ibs of
priority organics; 36,334 Ibs  of priority metals; and 1,054,029,445 Ibs of non-conventionals. This
selected option (IGF, BAT Option 2) results in the total annual pollutant removal of 1,500,187 Ibs.
This removal consists of 855,054 Ibs of conventionals; 70,367 Ibs of priority organics;  14,755 Ibs of
priority metals; and 560,011  Ibs of non-conventionals.
 Total Current Requirements Baseline Pollutant Loadings

      For the current requirements baseline (assuming compliance with the existing NPDES permits
 requiring zero discharge of coastal operators in Louisiana and Texas), the total annual pollutant loading
 for produced water at the current technology level of treatment is 2,549,142,381 Ibs.  This total annual
 loading consists of 3,636,393 Ibs of conventionals; 228,605 Ibs of priority organics; 84,966 Ibs of

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 ES-12
priority metals; and 2,545,192,417 Ibs of non-conventionals.  For the selected option (BAT Option 2:
zero discharge for major deltaic pass dischargers and IGF level of treatment for Cook Inlet), the annual
pollutant loading for produced water totals 1,055,042,019 Ibs.  This total annual loading consists of
926,020 Ibs of conventionals; 50,220 Ibs of priority organics; 36,334 Ibs of priority metals; and
1,054,029,445 Ibs of non-conventionals. For the selected option (BAT Option 2: zero discharge for
major deltaic pass dischargers and IGF for Cook Inlet), the total annual pollutant removal is
1,494,100,362 Ibs. This removal consists of 2,710,373 Ibs of conventionals; 178,385 Ibs of priority
organics; 48,632 Ibs of priority metals; and 1,491,162,972 Ibs of non-conventionals.

b.    Alternative Baseline Dischargers

Open Bay Dischargers, Louisiana

      For the 69 open bay outfalls, the total annual pollutant loading (49 pollutants) for produced water
at the current technology level of treatment is 2,578,995,458 Ibs. This total annual loading consists of
7,072,298 Ibs of conventionals; 450,458 Ibs of priority organics; 90,535 Ibs of priority metals; and
2,571,382,167  Ibs of non-conventionals. The selected option reduces this loading to zero. Thus, for
the selected option (zero discharge, BAT Option 2) the annual pollutant removal will be equal to the
pollutant loading listed above.

Individual Permit Applicants, Texas
      For the 82 individual permit applicants, the total annual pollutant loading (49 pollutants) for
produced water at the current technology level of treatment is 529,883,014 Ibs. This total annual
loading consists of 1,453,081 Ibs of conventionals; 92,551  Ibs of priority organics; 18,602 Ibs of
priority metals; and 528,318,780 Ibs of non-conventionals. The selected option (zero discharge, BAT
Option 2) completely eliminates this loading.  Thus, for the selected option (zero discharge, BAT
Option 2) the annual pollutant removal will be equal to the pollutant loadings listed above.

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                                                                                        ES-13
Total Alternative Baseline Dischargers

     For all alternative baseline dischargers (major deltaic pass, Cook Inlet, open bay, and individual
permit applicant dischargers), the total annual current technology pollutant loading for produced water
is 5,658,020,853 Ibs.  This total annual loading consists of 12,161,772 Ibs of conventionals;
671,614 Ibs of priority organics;  194,103 Ibs of priority metals; and 5,644,893,364 Ibs of non-
conventionals.  For the selected option (BAT Option 2: zero discharge for major deltaic pass
discharges, Louisiana open bay dischargers, and Texas individual permit applicants; IGF level of
treatment for Cook Inlet), the total annual pollutant loadings are 1,055,042,019 Ibs. This total loading
consists of 926,020 Ibs of conventionals; 50,220 Ibs of priority organics; 36,334 Ibs of priority metals;
and 1,054,029,445 Ibs of non-conventionals. For the selected option (BAT Option 2:  zero discharge
for major deltaic pass dischargers, Louisiana open bay dischargers, and Texas individual permit
applicants; IGF level of treatmentfor Cook Inlet) the total annual pollutant removal is 4,602,978,834
Ibs.  This removal consists of 11,235,752 Ibs of conventionals; 721,394 Ibs of priority organics;
157,769 Ibs of priority metals; and 4,590,863,919 Ibs of non-conventionals.

C.  Quantified and Monetized Benefits, Produced Water

1.   Projected Cancer Risk Reduction Benefits

     A first order assessment of ithe potential human health impacts from ingestion of seafood
contaminated with radium from coastal subcategory produced water discharges is presented. This
assessment is based on plume dispersion modeling to estimate water column concentrations of Ra226 and
Ra228 and target organism-specific BCFs to estimate edible tissue radium levels in seafood.  As per EPA
methodology (EPA, 1989a; 1993b), an exposure duration of 30 years for average-rate consumers (15
grams per day seafood consumption), an exposure duration of 70 years for high-rate consumers (147.3
g/d seafood consumption), and carcinogenicity potency factors for radium 226 (1.2 x 10'10) and radium
228 (l.OxlO-10) are used.
      Resulting individual carcinogenic risks from all seafood categories are adjusted, also as per EPA
methodology (EPA, 1989b), by factors of 0.20 and 0.75, to account for ingestion of seafood from
various locations, some of which are not contaminated by produced water discharges. This
methodology does not consider potential human exposure from consumption of seafood where the

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ES-14
Ra226*228 burden results from exposure of consumed species either to radium in sediments or to the
ingestion of radium-contaminated prey.  The applicability of this methodology and/or availability of
required data is discussed for each group of dischargers in each baseline.

a.    Current Requirements Baseline Dischargers

MajorDeltaic Pass Dischargers

      For major deltaic pass dischargers, site-specific water quality modeling is used to project
available dilutions for produced water, using the average dilution at 50 and 200 feet.  Using the
methodology summarized above, individual excess lifetime cancer risks were derived based on the
ingestion of seafood contaminated at levels resulting from water column exposure to produced water
discharges.  The projected individual excess lifetime cancer risk for average-rate consumers (15  g/d)
ranges from 1.0 x 10'6 to 2.8  x 10'5; and for high-rate consumers (147.3 g/d) ranges from 2.4 x  10"5 to
6.3 x 10"4. However, because of uncertainty and difficulty in describing the potential population at risk
of exposure from just major deltaic pass dischargers, total cancer cases avoided by the selected option
(zero discharge, BAT Option 2) could not be performed for this WQBA.  For the zero discharge option
(BAT Option 2), these risks will be eliminated.
Cook Inlet, Alaska

      Because of the minimal concentration of radium detected in produced water discharges in Cook
Inlet and uncertainty over the level of fishing near oil and gas structures and proportion of dietary
intake that such catch might represent, no radium risk assessment is conducted for Cook Inlet
dischargers in this WQBA.

b.    Alternative Baseline Dischargers

      For alternative baseline dischargers, the risk assessment methodology is similar to the approach
for current requirements baseline dischargers, except site-specific ambient and operational data are
replaced with characteristic values of the two groups. For the alternative baseline dischargers,
produced water dilutions are estimated from water quality modeling using flow-weighted depths (see

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                                                                                          ES-15
Section 3 of this WQBA), mean discharge rates, and the average dilutions available at 50-foot and 200-
foot mixing zones.

Open Bay Dischargers, Louisiana

      For the average-rate seafood consumer (15 g/d), the estimated increased lifetime cancer risk from
produced water Ra226 and Ra228 ranges from 1.3 x 10'5 to 4.8 x 10'5.  Estimated increased lifetime
cancer risk from produced water Ra226 and Ra228 for the high-rate consumer (147.3 g/d) ranges from
2.9 x 10'4 to 1.1 x 10'3. For the average-rate seafood consumers in Louisiana, there are 7.1 to 26
excess lifetime cancer cases projected.  For the high-rate seafood consumers in Louisiana, there are 18
to 67 excess lifetime cancer cases projected. Thus, there are totals of 25 and 93 lifetime excess cancer
cases projected for Louisiana for combined average- and high-rate seafood consumer populations.
There will be an increase of 0.25 to 0.96 cancer cases per year for high-rate seafood consumers.  For
average-rate consumers, there will be an excess of 0.10 to 0.38 cancer cases per year.  For the total
population of recreational anglers and their household members (high- and average-rate consumers),
there will be an increase of 0.35 to 1.3 cancer cases per year in Louisiana due to produced water Ra226
and Ra228 contamination.  Using the lifetime cost of each cancer case range of $2.5 million to
$13.4 million, the annual monetized benefits (in 1995 dollars) of cancer case avoidance due to zero
discharge of produced water for high-rate consumers in Louisiana range from $0.6 million to $13
million; the average-rate seafood consumer benefits are valued at $0.3 million to $5.1 million. The
total annual monetized benefits (in 1995 dollars) for cancer case avoidance in Louisiana is $0.9 million
to $18 million, with a range of midpoint values from $2.8 million to $11 million.
Individual Permit Applicants, Texas

      For the average-rate seafood; consumer (15 g/d), the estimated increased lifetime cancer risk from
produced water Ra226 and Ra228 ranges from 1.6 x 10'6 to 6.1 x 10'6.  Estimated increased lifetime
cancer risk due to Ra226 and Ra228 for the high-rate consumer (147.3 g/d) ranges from 3.7 x 10'5 to 1.4
x 10'4.  For the average-rate seafood consumers, there are 1.6 to 6.2 excess lifetime cancer cases
projected.  For the high-rate seafood consumers, there are 4.2 to 16 excess lifetime cancer cases
projected.  Thus, there is a total of 5.8 to 22 lifetime excess cancer cases projected for Texas for
combined average- and high-rate seafood consumer populations. There will be an increase of 0.06 to
0.23 cancer cases per year for high-rate seafood consumers. For average-rate consumers, there will be

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 ES-16
 an excess of 0.02 to 0.09 cancer cases per year.  For the total population of recreational anglers and
 their household members (high- and average-rate consumers), there will be an increase of 0.08 to 0.32
 cancer cases per year in Texas due to produced water Ra226 and Ra228 contamination. Using the lifetime
 cost of each cancer case range of $2.5 million to $13.4 million, the annual monetized benefits (in 1995
 dollars) of cancer case avoidance due to zero discharge of produced water for high-rate consumers in
 Texas range from $0.15 million to $3.1 million;  the average-rate seafood consumer benefits are valued
 at $0.05 million to $1.2 million.  The total annual monetized benefits (in 1995 dollars) for cancer case
 avoidance in Texas is $0.20 million to $4.3 million, with a range of midpoint values from $0.64
 million to $2.6 million.
 Total Monetized Human Health Risk Reduction Benefits

      For the average-rate seafood consumers, there are 9 to 32 excess lifetime cancer cases projected
 for Louisiana and Texas combined.  For high-rate seafood consumers, there are 22 to 83 excess
 lifetime cancer cases projected for Louisiana and Texas combined.  Thus, there is a total of 31 to 115
 lifetime excess cancer cases projected for combined average- and high-rate seafood consumer
 populations.  There will be an increase of 0.31 to 1.19 cancer cases per year for high-rate seafood
 consumers. For average-rate consumers, there will be an excess of 0.12  to 0.47 cancer cases per year.
 For the total population of recreational anglers and their household members (high- and average-rate
 consumers), there will be an increase of 0.43 to 1.66 cancer cases per year in Louisiana and Texas due
 to produced water Ra226 and Ra228 contamination. Using the lifetime cost of each cancer case range of
 $2.5 million to $13.4 million, the total annual monetized benefits (in 1995 dollars) of cancer case
 avoidance due to zero discharge of produced water for high-rate consumers in Louisiana and Texas
 combined range from $0.75 million to $16.0 million; the average-rate seafood consumer benefits are
 valued at $0.35 million to $6.3 million. The total annual monetized benefits (in 1995 dollars) for
 cancer case avoidance in Louisiana and Texas combined is $1.1 million to $22.3 million, with a range
 of midpoint values from $3.4 million to $13.3 million.

      The temporal dynamics of both impacts and benefits assessments is  relevant to the human health
 risk assessment. For the assessments of cancer reduction benefits, the methodology is consistent with
estimating costs for the rule, using a one-year, "snap-shot" approach.  Allocating the full value of
annual benefits within one year following cessation of produced water discharges may appear to over-
estimate potential annual benefits in  cases where incomplete recovery has occurred.  However, in such

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                                                                                         ES-17
cases where impacts are incompletely recovered, a consideration of total impact would need to include
any impacts expected to occur beyond that year.  This analysis does not attempt to identify or allocate
benefits on a year-by-year basis, but merely averages total benefits so that monetized benefits may be
compared to costs that are developed using the same approach.

2.    Projected Ecological Benefits
      To assist in characterizing the benefits of the final coastal oil and gas effluent guideline, the
WQBA assesses projected ecological impacts resulting from current technology discharges for two
groups of alternative baseline dischargers — Louisiana open bay dischargers and Texas individual
permit applicant dischargers. Projections of impacts are based on a study conducted in a shallow
coastal embayment in Texas. As such, the results of this study are not applicable to either of the two
current requirements baseline discharger groups (i.e., major deltaic pass dischargers to the Mississippi
River or facilities in Cook Inlet, Alaska). The results of this study, however, are applicable to
assessing potential ecological impacts for two groups of alternative baseline dischargers — Louisiana
open bay dischargers and Texas individual permit applicants.

      A potential ecological benefit of zero discharge of produced water in Texas and Louisiana coastal
areas is projected from a Trinity Bay, Texas case study. Assuming that zero discharge of produced
water would result in a recovery of ecosystems around platforms, a monetary value could be assigned
to the estimated acreage impacted around the study platform currently affected by produced water
discharges. A case study of a produced water  outfall to a coastal embayment is used to develop
estimates of ecological impact associated with this outfall.  Sediment benthic community analyses and
sediment total naphthalene analyses were performed monthly for 21 months.  The sieve size used for
benthic infaunal sorting was changed during the course of the  study, so two sets of analyses are
performed, one for each sieve size.

      For 0.50 mm mesh size data, benthic abundance and species richness are respectively reduced
23% and 21%  within a 3,963-meter impact radius, amounting to 2,817 and 2,501 equivalent acres
affected.  For 0.25 mm mesh size data, species richness was reduced 7% within a 3,963-meter impact
radius for 814  equivalent acres affected; benthic abundance was reduced 9% within a 1,677-meter
impact radius for 200 equivalent acres  affected.

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ES-18
      To project receiving water-wide benefits, the approach scaled the data available for the Trinity
Bay case study assuming a linear relationship among all parameters (i.e., flow, environmental impact,
and costs), adjusted for the improvement in effluent quality between the Trinity Bay effluent and both
current technology and IGF treatment technology effluent.  For the 69 Louisiana outfalls, the total
current technology flow for open bay dischargers is projected at 329,814 bpd.  The total current
technology flow for the 82 permit applicants in Texas is projected at 67,774 bpd.

      For Louisiana open bay dischargers, assuming the full range of wetland values ($57 to $940/acre
in 1990 dollars; median ecological value estimate of $410/acre) and the full range of ecological  impact
areas affected (i.e., using the 5,739- to 80,828-acre estimates from the adjusted current technology
effluent/Trinity Bay study as the basis for the Louisiana assessment), ecological benefits of the zero
discharge option under the alternative baseline analysis range from $0.3 million to $76.0 million, with
a midpoint of $38.2 million in 1990 dollars; $0.4 million to $88.6 million with a midpoint of $44.5
million in 1995 dollars. Assuming the midpoint impact area estimate of 43,298 equivalent acres and
the full range of ecological valuations per acre (i.e., the $57 to $940/acre estimates), ecological
benefits of the zero discharge option range from $2.5 million to $40.7 million, with a midpoint of
S17.8 million in 1990 dollars; $2.9 million to $47.4 million with a midpoint of $20.8 million in  1995
dollars.

      For Texas individual permit applicants, assuming the full range of wetland values ($57 to
$940/acre in 1990 dollars; median ecological value estimate of $410/acre) and the full range of
ecological impact areas affected (i.e., using the 1,179- to 16,610-acre estimates from the adjusted
current technology effluent/Trinity Bay study as  the basis for the Texas assessment), ecological benefits
of the zero discharge option range from $0.07 million to $15.6 million, with a midpoint of $7.8  million
in 1990 dollars; $0.08 million to $18.2 million with a midpoint of $9.1 million in 1995 dollars.
Assuming the midpoint impact area estimate of 8,897 equivalent acres and the full range of ecological
valuations per acre (i.e., the $57 to $940/acre estimates), ecological benefits of the zero discharge
option range from $0.5 million to $8.4 million, with a midpoint of $3.7 million in 1990 dollars;  $0.6
million to $9.8 million with a midpoint of $4.3 million in 1995 dollars.
      The total ecological benefits of the zero discharge option for Louisiana open bay dischargers and
Texas individual permit applicants, assuming the full range of wetland values ($57 to $940/acre in 1990
dollars; median ecological value estimate of $410/acre) and the full range of ecological impact areas

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                                                                                         ES-19
affected, range from $0.48 million to $106.8 million, with a midpoint of $53.6 million in 1995 dollars.
Assuming the midpoint impact area estimates and the full range of ecological valuations per acre (i.e.,
the $57 to $940/acre estimates), ecological benefits of the zero discharge option range from $3.5
million to $52.9 million, with a midpoint of $25.1 million in 1995 dollars.

D.   Non-Quantified Benefits

      The WQBA attempts to quantify, and whenever appropriate, to monetize specific environmental
benefits that may result from the coastal effluent guidelines. However, some of the potential benefits
could not be quantified or monetized because of a lack of data or insufficient information to define
causal relationships between coastal oil and gas production activities and environmental effects. This
WQBA includes:  (1) an assessment of potential health risks to Alaska's Native Populations from
consumption of Cook Inlet's fish and shellfish and a potential link between coastal oil and gas
discharges and fish consumed by;native populations; (2) effects on threatened or endangered  species
and migratory waterfowl; (3) potential water body benefits of the effluent guidelines on ecosystem
health primarily for coastal areas of the Gulf of Mexico,  and to a limited degree for Cook Inlet; and (4)
pollutants for which insufficient health effects data exist to  quantify potential human health benefits
from reductions in consumed seafood pollutant concentrations.

1.   An Assessment of Health Risks to Cook Inlet's Native Populations
      EPA attempted to assess the potential health risks due to high subsistence use of Cook Inlet by
 native populations. Although sufficient information on Cook Inlet's native population subsistence
 patterns exists, there are little fish tissue data with which to assess the risks from consumption of fish
 and shellfish from Cook Inlet. Two available studies provide some mussels tissue data, but they
 provide no data on fish or other shellfish.  The mussel data may provide an upper bound of
 contaminant concentrations likely to be found in other shellfish. However, the data are insufficient to
 assess risk from consumption of fish because mussels have much higher bioaccumulation rates.

      Mussels, and shellfish in general, represent only a small portion (i.e., two to eight percent) of the
 fish and shellfish subsistence harvest for three of Cook Inlet's native villages (Tyonek, Nanwalek, and
 Port Graham).  Finfish represent  74% to 80% of the harvest (with salmon representing 57% to 97% of
 the fmfish harvest).  The finfish harvest data indicate consumption levels could be as high as 211 g/d,

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            ES-20
            238 g/d, and 298 g/d (with salmon consumption levels of 121 g/d, 232 g/d, and 180 g/d) in Port
            Graham, Tyonek, and Nanwalek, respectively. The shellfish harvest data indicate consumption levels
            of 6 g/d, 20 g/d, and 29 g/d hi Tyonek, Port Graham, and Nanwalek, respectively.  However,  lacking
            the data on the concentration of pollutants in fish tissue, which represent up to 80% of the Cook Inlet's
            native population fish and shellfish intake rates, it is difficult to assess the human health risks from fish
            consumption, and to reasonably establish the link between coastal oil and gas discharges and human
            health effects from the discharges in Cook Inlet.

            2.    Threatened and Endangered Species

                 The final regulation may also have beneficial effects on 32 threatened and endangered species in
            coastal areas of Texas and Louisiana.  Because of the number and geographically broad extent of
            produced water discharges hi coastal Louisiana and Texas, exposure of these species to produced water
            pollutants is a concern.  Zero discharge of produced water would eliminate these concerns of potential
            impacts from discharges on these species or their habitats. In the Cook Inlet region, 13 species are
            identified as species of concern (i.e., listed as threatened, endangered, or candidates for listing). Most
            of the species are migratory (whales and birds) and do not spend significant amounts of time within the
            Cook Inlet area. These  species would not be likely to be affected by current discharges and would be
            less likely to be affected under the selected regulatory options (IGF for produced water and offshore
            limits for drilling fluids).

           3.    Potential Water Body Improvements

                 As described previously hi this Executive Summary, nonquantified benefits may result from this
           rule due to the elimination or reduction in pollutant loading from produced water pollutants for which
           no state water quality standards have been adopted. These nonquantified benefits primarily will accrue
           in the coastal Gulf of Mexico, but also may be of limited benefit in Cook Inlet. This consideration is
           important because of three factors.  First, the number of pollutants in produced water for which state
           standards do not exist is  high  (37 of 49 pollutants  hi produced water from operations in Louisiana; 38
           of 49 pollutants hi Texas; 34 of 46 pollutants in produced water from Cook Inlet operations).

                 Second, the relative contribution to pollutant loading from pollutants with no state standards in
           produced water discharges is very high. For major deltaic pass dischargers, Louisiana open bay
_

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                                                                                          ES-21
dischargers, and Texas individual permit applicants, the loading from pollutants for which no state
standard exist respectively represent 97.7%, 95.2%, and 99.8% of total produced water loadings.
Third, ambient and effluent characteristics in coastal areas of the Gulf of Mexico are favorable for
sediment/discharge plume interactions. Because of generally shallow water bodies, restricted
circulation and flushing, and the high densities of produced water (causing discharges to sink rapidly),
the projected improvement is not restricted to water quality impacts.  Produced water has demonstrably
greater benthic impacts than water column impacts.  Thus, the nonquantified benefits of eliminating or
reducing pollutants for which no state water quality standards have been adopted will improve not only
water quality but also sediment quality (perhaps, even more so).

4.    Additional Human Health Benefits

      In addition to nonquantified water body benefits, there are similar nonquantified human health
benefits that may result from this final rule.  These nonquantified human health benefits result from two
causes: (1) pollutants in produced water for which insufficient health effects data exist to quantify
potential benefits,  or (2) health benefits from pollutants in produced water that have not been quantified
due to time constraints.  Examples of the former type of benefits are potential cancer risk reduction
benefits from eliminating or reducing discharges of: cadmium (limited evidence of human
carcinogenicity) and lead (an animal carcinogen with inadequate or no evidence in humans). Examples
of the latter type of nonquantified benefits are: carcinogenic effects of benzene, for which a cancer
potency factor is available, and noncarcinogenic human health effects for pollutants with RfDs (e.g.,
lead and cadmium).  These produced water pollutants do or may present potential human health risks
that have not been quantified for this final rule. However, by selecting the zero discharge option for
coastal operations  in Louisiana and Texas and IGF treatment technology for Cook Inlet operation, the
discharge of these pollutants is eliminated or reduced, even though no quantified benefits have been
projected.

E.   Drilling Fluids and Cuttings
      The selected option for drilling fluids and cuttings (Option 1) imposes BAT limitations that are
achieved under current BPT practice. Because there are no technology-based pollutant reductions,
there are no quantified or non-quantified benefits that are attributed to these regulations.

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                               TABLE OF CONTENTS
                                                                                    Page

EXECUTIVE SUMMARY	ES - 1

1.  INTRODUCTION
    1.1   Background	1-1
    1.2   Purpose	1-1
    1.3   Baseline Populations	1-2
    1.4   Geographic Scope .	1 " 3
    1.5   Waste Streams	1-3
         1.5.1  Gulf of Mexico Operations	1-3
         1.5.2  Cook Inlet, Alaska Operations	1-4
    1.6   Treatment Technologies	1-4
    1.7   Terminology	  . 1 - 5
    1.8   BAT Regulatory Options 	1-6
         1.8.1  Produced Water 	1-6
         1.8.2  Drilling Wastes	1-7

2. PRODUCED WATER CHARACTERIZATIONS
    2.1   Industry Profile and Discharge Volumes 	2-1
    2.2   Produced Water Discharge Volume Characterization	2-4
         2.2.1  Current Requirements Baseline Dischargers	2-4
                2.2.1.1  Major Deltaic Pass Dischargers, Louisiana  	2-4
                2.2.1.2 Cook Inlet, Alaska	2-6
         2.2.2  Alternative Baseline Dischargers 	2-6
                2.2.2.1  Open Bay Dischargers, Louisiana 	2-6
                2.2.2.2 Individual Permit Applicants, Texas	2-8
    2.3   Produced Water Pollutant Characterization	2-17
         2.3.1  Current Requirements Baseline Dischargers	2-17
                2.3.1.1  Major Deltaic Pass Dischargers, Louisiana  	2-17
                2.3.1.2 Cook Inlet, Alaska	2-17
         2.3.2  Alternative Baseline Dischargers 	2-17
                2.3.2.1 Open Bay Dischargers, Louisiana 	2-17
                2.3.2.2 Individual Permit Applicants, Texas	2-22
    2.4   Produced Water Toxicity Characterization	2-22
          2.4.1  Current Requirements Baseline Dischargers	2-22
                2.4.1.1 Major Deltaic Pass Dischargers, Louisiana  	2-22
                2.4.1.2 Cook Inlet, Alaska	2-22
          2.4.2 Alternative Baseline Dischargers 	2-24
                2.4.2.1 Operi Bay Dischargers, Louisiana 	2-24
                2.4.2.2 Individual Permit Applicant, Texas  	2-25
    2.5   Produced Water Pollutant Loadings and Removals by the Selected BAT Option . ...  2-25
          2.5.1  Current Requirements Baseline  	2-25
                2.5.1.1 Major Deltaic Pass Dischargers, Louisiana  	2-25
                2.5.1.2 Cook Inlet, Alaska		2-25

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 H
                2.5.1.3  Total Current Requirements Baseline Pollutant Loadings and
                        Removals by the Selected BAT Option	2-27
          2.5.2  Alternative Baseline Dischargers  	2-27
                2.5.2.1  Open Bay Dischargers, Louisiana  	2-27
                2.5.2.2  Individual Permit Applicants, Texas	2-28
                2.5.2.3  Total Alternative Baseline Dischargers Pollutant Loadings and
                        Removals by the Selected BAT Option	2-28

3. WATER QUALITY COMPLIANCE ASSESSMENTS FOR PRODUCED WATER
    3.1   Surface Water Modeling Methodology  	3-1
          3.1.1  Current Requirements Baseline Dischargers	3-1
                3.1.1.1  Major Deltaic Pass Dischargers, Louisiana  	3-1
                3.1.1.2  Cook Inlet, Alaska	3-4
          3.1.2  Alternative Baseline Dischargers  	3-4
                3.1.2.1  Open Bay Dischargers, Louisiana  	3-4
                3.1.2.2  Individual Permit Applicants, Texas	3-7
    3.2   State Water Quality Standards	3-12
          3.2.1  Current Requirements Baseline Dischargers	3-12
                3.2.1.1  Major Deltaic Pass Dischargers, Louisiana  	3-12
                3.2.1.2  Cook Inlet, Alaska	3-16
          3.2.2  Alternative Baseline Dischargers  	3-16
                3.2.2.1  Open Bay Dischargers, Louisiana  	3-16
                3.2.2.2  Individual Permit Applicants, Texas	3-18
    3.3   Summary of Surface Water Quality Modeling	3-20
          3.3.1  Current Requirements Baseline Dischargers	3-20
                3.3.1.1  Major Deltaic Pass Dischargers, Louisiana  	3-20
                3.3.1.2  Cook Inlet, Alaska	3-24
          3.3.2  Alternative Baseline Dischargers  	3-24
                3.3.2.1  Open Bay Dischargers, Louisiana  	3-24
                3.3.2.2  Individual Permit Applicants, Texas	3-30
    3.4   Nonqualified Surface Water Quality Benefits	3-34
          3.4.1  Current Requirements Baseline Dischargers	3-34
                3.4.1.1  Major Deltaic Pass Dischargers, Louisiana  	3-34
          3.4.2  Alternative Baseline Dischargers  	3-35
                3.4.2.1  Open Bay Dischargers, Louisiana   	3-35
                3.4.2.2  Individual Permit Applicants, Texas	3-35

4. WATER QUALITY COMPLIANCE ASSESSMENTS FOR COOK INLET DRILLING
    WASTE
    4.1    Characterization of Drilling Discharges	4-1
    4.2   Dilution Modeling	4-1
    4.3    Water Quality Analysis, Cook Inlet Drilling Discharges  	4-3

5. POPULATIONS AND RESOURCES EXPOSED TO COASTAL PRODUCED WATER
    DISCHARGES
    5.1    Recreational Anglers	5-1
          5.1.1  Louisiana	5-2
          5.1.2  Texas	5-5

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                                                                                      Ill
    5.2   Seafood Consumption Rates and Patterns	5-5
         5.2.1  Gulf of Mexico Recreational Fishing	5-5
                5.2.1.1  Louisiana	5-6
                5.2.1.2  Texas	5-6
         5.2.2  Cook Inlet, Alaska Subsistence Fishing	5-6
                5.2.2.1  Finfisheries	5-7
                5.2.2.2  Shellfisheries	5-7
                5.2.2.3  Seafood Consumption	5-9
    5.3   Commercial Fisheries, Louisiana and Texas	5-9
    5.4   Endangered and Threatened Species	5-11
         5.4.1  Gulf of Mexico Endangered and Threatened Species  	5-11
         5.4.2  Cook Inlet, Alaska Endangered and Threatened Species 	5-11

6. RADIUM RISK ASSESSMENT AND MONETIZATION OF POTENTIAL HUMAN
    HEALTH BENEFITS
    6.1   Methodology	,	6-1
         6.1.1  Current Requirements Baseline Dischargers	6-2
                6.1.1.1  Major Deltaic Pass Dischargers	6-2
                6.1.1.2  Cook Inlet, Alaska	6-3
         6.1.2  Alternative Baseline Dischargers 	6-3
                6.1.2.1  Open Bay Dischargers, Louisiana 	6-3
                6.1.2.2  Individual Permit Applicants, Texas	6-3
    6.2   Results	'.	6-4
         6.2.1  Current Requirements Baseline Dischargers	6-4
                6.2.1.1  Major Deltaic Pass Dischargers	6-4
         6.2.2  Alternative Requirements Baseline Dischargers	6-4
                6.2.2.1  Open Bay Dischargers, Louisiana 	6-4
                6.2.2.2  Individual Permit Applicants, Texas	6-17
         6.2.3  Total Monetized Benefits for Louisiana Open Bay Dischargers and Texas
                Individual Permit Applicants	6-21
    6.3   Evaluation of the Assessment	6-24

7. ECOLOGICAL IMPACT ASSESSMENT AND MONETIZED BENEFITS
    7.1   Description of the Trinity Bay Study	7-2
    7.2   Case Study Approach . ;	7-5
         7.2.1  Ecological Impact Assessment	7-5
         7.2.2  Ecological Resource Valuation	7-15
                7.2.2.1  Review of Coastal Wetland Values	7-15
                7.2.2.2  Recreational Fisheries, Galveston Bay  	7-23
                7.2.2.3  Nonconsumptive and Other Recreational Values, Galveston Bay  . .  7-24
                7.2.2.4  Total Recreational Value, Galveston Bay . .	7-24
    7.3   Trinity Bay, Texas Case Study Assessment	7-25
         7.3.1  Current Requirements Baseline Dischargers	7-27
                7.3.1.1  Major Deltaic Pass Dischargers, Louisiana  	7-27
                7.3.1.2  Cook Inlet, Alaska	7-28
         7.3.2  Alternative Baseline Dischargers  	7-28
                7.3.2.1  Open Bay Dischargers, Louisiana 	7-28
                7.3.2.2  Individual Permit Applicants, Texas	7-28

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IV
    7.4   Trinity Bay-Based Ecological Benefit Monetization Estimates for the Selected
         BAT Option	7-28
         7.4.1  Current Requirements Baseline Dischargers	7-31
               7.4.1.1  Major Deltaic Pass Dischargers, Louisiana  	7-31
               7.4.1.2  Cook Met, Alaska	7-31
         7.4.2  Alternative Baseline Dischargers  	7-31
               7.4.2.1  Open Bay Dischargers, Louisiana  	7-31
               7.4.2.2  Individual Permit Applicants, Texas	7-31
    7.5   Evaluation of the Assessment	7-32

8. QUANTIFIED, NONMONETIZED WATER QUALITY BENEFITS, COOK INLET,
    ALASKA
    8.1   Pollutants of Concern and Levels in Fish Tissue  	8-1
    8.2   Contaminants of Concern	8-2
    8.3   Tissue Contaminant Concentrations  	8-2
    8.4   Assessment of Risk from Seafood Consumption  	8-6

9. PRODUCED WATER LITERATURE REVIEW
    9.1   Summary of the Produced Water Literature Review	9-1
    9.2   Summary of Coastal Studies Cited 	9-13

10. REFERENCES  	  10-1

APPENDIX A
APPENDIX B
APPENDIX C

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                                  LIST OF EXHIBITS
                                                                                      Page
Exhibit 2-1.   Major Deltaic Pass Dischargers, Louisiana Produced Water Outfalls	2-5
Exhibit 2-2.   Cook Inlet, Alaska Produced Water Outfalls  	2-7
Exhibit 2-3.   Louisiana Open Bay Produced Water Outfalls	2-9
Exhibit 2-4.   Texas Permit Applicants Produced Water Outfalls	2-13
Exhibit 2-5.   Produced Water Pollutant Concentrations for Gulf of Mexico Analyses	2-18
Exhibit 2-6.   Produced Water Pollutant Concentrations for Cook Inlet, Alaska Analyses	2-20
Exhibit 2-7.   Louisiana Coastal Produced Water Toxicity Data  	2-23
Exhibit 2-8.   Cook Inlet Produced Water Toxicity Data	2-24
Exhibit 2-9.   Texas Coastal Produced Water Toxicity Data	2-26

Exhibit 3-1.   Site-Specific Input Parameters for CORMIX Modeling—Major Deltaic Pass
             Dischargers, Louisiana  	3-2
Exhibit 3-2.   Derivation of Produced Water Densities for Major Deltaic Pass Dischargers	3-3
Exhibit 3-3.   Summary of CORMIX Modeling Results—Major Deltaic Pass Dischargers: Available
             Dilutions at Specified Mixing Zones	3-4
Exhibit 3-4.   Site-Specific Input Parameters for CORMIX Modeling—Cook Inlet, Alaska	3-5
Exhibit 3-5.   Input Parameters for CORMIX Modeling - Open Bays, Louisiana   	3-8
Exhibit 3-6.   Summary of CORMIX Modeling Results—Open Bay Dischargers, Louisiana:
             Available Dilutions at Specified Mixing Zones	3-9
Exhibit 3-7.   Input Parameters for CORMIX Modeling—Individual Permit Applicants, Texas  . 3-11
Exhibit 3-8.   Summary of CORMIX Modeling Results—Individual Permit Applicants, Texas:
             Available Dilutions at Specified Mixing Zones	3-12
Exhibit 3-9.   Louisiana Water Quality Standards	3-13
Exhibit 3-10. Calculation of the Fraction of Dissolved Metal for Setting State Water Quality
             Effluent Limitations, Louisiana	3-15
Exhibit 3-11. Alaska Water Quality  Standards	3-17
Exhibit 3-12. Calculation of the Fraction of Dissolved Metal for Setting State Water Quality
             Effluent Limitations, Texas	3-19
Exhibit 3-13. Texas Water Quality Standards	3-19
Exhibit 3-14. Louisiana Major Deltaic Pass Dischargers Summary of Daily Average Water
             Quality Exceedance Ratios	3-21
Exhibit 3-15. Louisiana Major Deltaic Pass Dischargers Summary of Daily Maximum Water
             Quality Exceedance Ratios	3-22
Exhibit 3-16. Results of CORMIX Modeling for Alaska Produced Water Discharges: Distance
             to Achieve Compliance with Alaska Standards	3-25
Exhibit 3-17. Open Bay Dischargers, Louisiana Summary of Daily Average Water Quality
             Exceedance Ratios	3-26
Exhibit 3-18. Open Bay Dischargers, Louisiana Summary of Daily Maximum Water Quality
             Exceedance Ratios  .;	• • • •	3-27
Exhibit 3-19. Individual Permit Applicants, Texas Summary of Daily Average Water Quality
             Exceedance Ratios	3-31
Exhibit 3-20. Individual Permit Applicants, Texas Summary of Daily Maximum Water Quality
             Exceedance Ratios	3-32

Exhibit 4-1.  Pollutant Concentrations in  Drilling Fluid Effluent 	4-2

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VI
Exhibit 4-2.  Summary of OOC Model Results from Region 10 Permit Development	4-3

Exhibit 5-1.  Demographics for Texas and Louisiana Coastal Counties and Parishes	5-3
Exhibit 5-2.  Recreational Angler Characterization for Louisiana	5-4
Exhibit 5-3.  Recreational Angler Characterization for Texas  	5-4
Exhibit 5-4.  Cook Inlet, Alaska, Native Village Subsistence Finfishery Harvest	5-8
Exhibit 5-5.  Cook Inlet, Alaska, Native Village Subsistence Shellfishery Harvest	5-8
Exhibit 5-6.  Fish Consumption Surveys of Alaska Subsistence Fishermen	5-10
Exhibit 5-7.  Threatened and Endangered Species of the Gulf of Mexico	5-12
Exhibit 5-8.  Endangered, Threatened, or Candidates for Listing in Cook Inlet, Alaska  	5-14

Exhibit 6-1.  Summary of Major Deltaic Pass Discharger Maximum Individual Lifetime
             Cancer Risks	'	6-5
Exhibit 6-2.  Flores and Rucks Estimated Increased Lifetime Cancer Risk	6-6
Exhibit 6-3.  Chevron Pipeline Estimated Increased Lifetime Cancer Risk	6-7
Exhibit 6-4.  Amoco Estimated Increased Lifetime Cancer Risk	6-8
Exhibit 6-5.  North Central-001 Estimated Increased Lifetime Cancer  Risk  	6-9
Exhibit 6-6.  North Central-002 Estimated Increased Lifetime Cancer  Risk  	6-10
Exhibit 6-7.  North Central-003 Estimated Increased Lifetime Cancer  Risk  	6-11
Exhibit 6-8.  Warren Petroleum Estimated Increased Lifetime Cancer  Risk  	6-12
Exhibit 6-9.  Estimated Increased Lifetime Cancer Risk, Open Bay Dischargers, Louisiana ...  6-13
Exhibit 6-10. Projected Excess Cancers, Louisiana  	6-15
Exhibit 6-11. Estimated Lifetime Excess Cancer for Louisiana Recreational Anglers and
             Their Households	6-16
Exhibit 6-12. Estimated Annual Monetized Benefits of Cancer Case Avoidance for Louisiana
             Recreational Anglers and Their Households	6-16
Exhibit 6-13. Estimated Increased Lifetime Cancer Risk, Individual Permit Applicants, Texas  .6-18
Exhibit 6-14. Projected Excess Cancers, Texas	6-19
Exhibit 6-15. Estimated Lifetime Excess Cancer for Texas Recreational Anglers
             and Their Households  	6-20
Exhibit 6-16. Estimated Annual Monetized Benefits of Cancer Case Avoidance for
             Texas Recreational Anglers and Their Households3	6-20
Exhibit 6-17. Total Projected Excess Cancers; Combined Louisiana and Texas  	6-22
Exhibit 6-18. Estimated Total Lifetime Excess Cancer for Louisiana and Texas
             Recreational Anglers and Their Households	6-23
Exhibit 6-19. Estimated Annual Monetized Benefits of Cancer Case Avoidance for Louisiana
             and Texas Recreational Anglers and Their Households	6-24

Exhibit 7-1.  Map of Trinity Bay Showing Location of C-2 Separator Platform and Extent of
             Transects	7-3
Exhibit 7-2.  Scatter  Plot:  Sediment Naphthalene vs. Distance from Outfall, All Samples,
             20°C/72hr Extraction  	7-4
Exhibit 7-3.  Mean Sediment Naphthalene vs. Distance from Outfall, Distance-Averaged	7-6
Exhibit 7-4.  Log Mean Sediment Naphthalene vs. Log Distance from Outfall,
             Distance-Averaged	7-7
Exhibit 7-5.  Fractional Benthic Abundance and Species  Richness vs. Sediment Naphthalenes  .  . 7 - 8
Exhibit 7-6.  Trinity  Bay, Texas Produced Water Outfall Fractional Abundance and Species
             Richness Data	7-9

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                                                                                         Vll
Exhibit 7-7.   Fractional Abundance/Species Richness vs. Distance, 0.50 mm Mesh Sieve Size .  7-10
Exhibit 7-8.   Fractional Abundance/Species Richness vs. Distance, 0.25 mm Mesh Sieve Size .  7-11
Exhibit 7-9.   Fractional Abundance vs. Distance, 0.25 mm and 0.50 mm Mesh Sieve Size  ...  7-12
Exhibit 7-10.  Fractional Species Richness vs. Distance, 0.25 mm and 0.50 mm Mesh Sieve
             Size	7-14
Exhibit 7-11.  Summary of Literature Review of Wetlands Values	7-18
Exhibit 7-12.  Summary of Galveston Bay Recreational Values	7-25
Exhibit 7-13.  Total Abundance and Species Richness for 0.25 mm and 0.50 mm Mesh Size
             Data and Equivalent Acres Affected	7-27
Exhibit 7-14.  Estimated Receiving Water Impacts and Monetized Benefits, Open Bay
             Dischargers, Louisiana   	7-29
Exhibit 7-15.  Estimated Receiving Water Impacts and Monetized Benefits, Individual
             Permit Applicant Dischargers, Texas	7-30

Exhibit 8-1.   Pollutants of Concern in Drilling and Production Discharges	8-3
Exhibit 8-2.   Human Toxicity Potential of the Contaminants of Concern	8-5
Exhibit 8-3.   Tissue Contaminant Concentrations in Mussel Samples from Cook Inlet	8-6

Exhibit 9-1.   Summary of Organics and Metals Impacts Found in Studies of Coastal
             Subcategory Discharges of Produced Water	9-3
Exhibit 9-2.   Summary of Radiochemical Impacts Found in Studies of Coastal Subcategory
             Discharges of Produced Water 	9-9

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                                                                                           1-1
                                    1. INTRODUCTION

1.1   Background

      This water quality benefits analysis (WQBA) is part of the U.S. Environmental Protection
Agency's (EPA) rulemaking package for final effluent guidelines for the coastal subcategory of the oil
and gas extraction industry (coastal Guidelines).  EPA developed the Guidelines (60 FR 9428; February
17, 1995) based on a variety of data collected and analyzed by the Agency, including a Request for
Comments (54 FR 46919; November 8, 1989); an Information Collection Request (ICR) conducted by
the Agency during July of 1993; information collected in response to a public meeting on this
rulemaking held on July 19, 1994 in New Orleans, Louisiana; and the comments received and
additional information collected after publication of the proposed rule.  As part of the rulemaking
package, EPA seeks to describe and assess the potential ecological and human health impacts associated
with discharges from coastal oil and gas operations and the benefits associated with the regulatory
options under consideration and selected for final coastal guidelines.

1.2   Purpose

      The purpose of this WQBA is to quantify and to monetize, wherever possible, the benefits that
are projected to accrue from the regulatory options under consideration in the final rule.  The WQBA
presents several types of characterizations and assessments for this purpose:

      •  Waste stream characterizations of produced water discharge volumes, pollutant composition,
         toxicity, and pollutant loadings (Section 2)
      •  Water quality compliance assessments for produced water discharges to receiving waters in
         Louisiana, Texas, and Cook Inlet, Alaska comparing receiving water pollutant concentrations
         projected from surface water dispersion modeling for state mixing zones to state numeric
         water quality standards (Section 3)

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1-2
      •  Water quality compliance assessments for drilling fluids and cuttings discharged to Cook Inlet
         that compare receiving water pollutant concentrations projected from surface water dispersion
         modeling to state numeric water quality standards (Section 4)

      •  Analyses of populations and resources exposed to produced water pollutants (Section 5)

      •  A carcinogenic risk assessment for produced water radionuclides for average-rate and high-
         rate seafood consumption, based on seafood radionuclide contamination levels projected from
         modeling (Section 6)

      •  An analysis of projected, monetized ecological benefits for the alternative baseline (See
         Section 1.3 below) resulting from a zero discharge limitation for produced water, based on a
         field study in Trinity Bay, Texas and valuations of resources at risk in the Gulf of Mexico,
         including recreational fishing,  commercial fisheries, and non-consumptive and other
         recreational uses (Section 7)

      *  Quantified, non-monetized, water quality benefits developed for subsistence populations
         around Cook Inlet, Alaska (Section 8)

      •  A literature review of field studies of produced water impacts in coastal Louisiana and Texas
         (Section 9).

1.3   Baseline Populations
      In the development of the final rule, two baseline scenarios were developed and evaluated. The
first is the current requirements baseline, and is composed of Louisiana major deltaic pass dischargers
and Cook Inlet, Alaska dischargers.  This baseline represents both the Gulf of Mexico facilities that are
expected to be discharging after January 1, 1997, which are discharges excluded under the existing
Best Available Technology Economically Achievable/Best Professional Judgement (BAT/BPJ) National
Pollutant Discharge Elimination System (NPDES) general permits, and the facilities discharging in
Cook Inlet, Alaska.

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                                                                                           1-3
      In addition, an alternative baseline has been developed for the purpose of analysis during the
development of this final rule.  The alternative baseline, in addition to dischargers covered under the
current requirements baseline,  includes two additional groups of dischargers.  The first group is
composed of open bay facilities in Louisiana that are currently required to meet zero discharge by
January 1, 1997 under Louisiana state law.  The second group is composed of potential dischargers
represented by operators seeking individual NPDES permits in Texas. Both of these baseline scenarios
have been evaluated in this WQBA for the final rule based on their separate engineering and economic
considerations.

1.4  Geographic Scope

      The WQBA considers operations and impacts in two geographic areas: coastal areas adjacent to
the Gulf of Mexico (primarily  analyses for Louisiana and Texas) and Cook Inlet, Alaska.  The WQBA
does not consider any environmental impacts associated with coastal oil and gas operations in
Mississippi, Alabama, Florida, California, or North Slope of Alaska because these facilities are
currently  controlled under state regulations  that require zero discharge for both drilling and production
wastes.

1.5  Waste Streams
 1.5.1 Gulf of Mexico Operations

      Drilling fluids and cuttings associated with Gulf of Mexico coastal operations are currently
 prohibited from discharge by state authorities and existing NPDES permits.  Therefore, drilling wastes
 are not considered for Gulf of Mexico operations in this WQBA. The only waste stream considered in
 this WQBA for Gulf of Mexico operations is produced water. Produced water volumes and pollutant
 concentrations for operators in coastal areas adjacent to the Gulf of Mexico are supplied by EPA's
 Engineering and Analysis Division (BAD); their derivation is explained in detail in the Development
 Document for the final  rule (EPA, 1996a).

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 1-4
      Produced water volumes are based on individual outfall and permit data including compliance
 schedules for attaining zero discharge limitations under existing Louisiana permits and individual
 permit applications hi Texas.  Produced water pollutant concentrations for the settling tank treatment
 (considered as current technology) are average values for seven Louisiana and Texas facilities whose
 effluent quality met Best Practicable Treatment (BPT) limitations based on an EPA sampling and
 analysis survey of ten coastal facilities.  Produced water pollutant concentrations for improved gas
 flotation are based on pollutant levels in produced water effluent from this treatment technology based
 on facilities in the offshore subcategory of this industry.  Produced water toxicity for Gulf of Mexico
 operations is based on data obtained from effluent studies conducted for coastal facilities in both
 Louisiana and Texas.

 1.5.2 Cook Inlet, Alaska Operations

      Similar to Gulf of Mexico operations, discharge volumes and pollutant concentrations for
 produced water and drilling fluids and cuttings discharges from Cook Inlet operations are supplied by
 EPA's Engineering and Analysis Division (BAD); their derivation is explained in detail in the
 Development  Document for the final rule (EPA, 1996a).

 1.6  Treatment Technologies
      Historical treatment of produced water discharges has developed on the basis of treatment tech-
nologies for oil and grease.  This endpoint has developed into two types of treatment technologies.  The
predominate technology in current practice is settling tank treatment. This technology, which hereafter
is referred to in this WQBA as current technology, is the prevalent technology used by industry and is
adequate to meet limitations of 48 mg/1 oil and grease as a monthly average and 72 mg/1 oil and grease
as a daily maximum.  The second type of treatment technology is improved gas flotation (IGF), which
can achieve effluent limitations of 29 mg/1 oil and grease as a monthly average and 42 mg/1 oil and
grease as a daily maximum (and which is the current requirement for offshore discharges).  For the
purpose of this final rulemaking, both current technology and IGF treatment were considered but not
chosen as the selected technology for the Gulf of Mexico region. The selected technology option for
the Gulf of Mexico region for produced water is injection of produced water into subsurface forma-

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                                                                                            1-5
tions, resulting in an effluent limitation of zero discharge.  For Cook Inlet facilities, IGF treatment is
the selected technology.

      Effluent pollutant concentration data for current technology and IGF technology are presented in
this WQBA; thek derivation is presented in greater detail in the Development Document for the final
rule (EPA,  1996a). Separate pollutant data are provided for Gulf of Mexico facilities and Cook Inlet
facilities.

1.7  Terminology
      Potential confusion may arise in this WQBA over the use of the term "baseline" as it applies to
 the regulatory baseline versus the technology baseline. The regulatory baseline (e.g., current require-
 ments baseline or alternative baseline) is used to define the initial population of dischargers covered by
 these coastal guidelines. The technology baseline is the most prevalent treatment technology currently
 hi use (and its resultant effluent quality), against which new pollution control treatments are compared
 and incremental improvements are calculated. In this document the technology baseline is referred to
 as the "current technology."

      Dischargers included hi the current requirements baseline population are treating their produced
 water using two levels of treatment technology.  Most current requirements baseline dischargers treat
 their produced water using settling tanks capable of producing an effluent that will meet current BPT
 limitations (i.e., 48/72 milligrams oil and grease per liter as a monthly average/daily maximum).
 However, one discharger currently treats its produced water using improved gas flotation, a technology
 considered by EPA for the final rule as a BAT-level treatment.  Thus, for current requirements
 baseline, the  major deltaic pass dischargers current technology baseline is a mixture of BPT (settling
 tank) and BAT (unproved gas flotation) treatment technologies; all Cook Inlet dischargers are known to
 be at the BPT level of treatment. The two additional groups of dischargers  that are included in the
• alternative baseline (Louisiana open bay and Texas permit applicant dischargers) are assumed to be at
 the BPT (settling tank) level of treatment because of the higher cost of IGF treatment.

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1-6
1.8   BAT Regulatory Options

      BAT regulatory options considered for the final rule for produced water and drilling fluids and
cuttings are presented below.  EPA assessed and evaluated all options considered for development of
the final rule.

1.8.1    Produced Water

      EPA considered three BAT options for regulating produced water in the development of this final
rule.  These options are the following:

      •  Option 1: Option 1 prohibits all coastal oil and gas facilities from discharging produced
         water except: 1) facilities discharging produced water derived from the Offshore Subcategory
         into a major deltaic pass of the Mississippi River; and 2) all facilities in Cook Inlet, Alaska.
         Exempted facilities are required to comply with new BAT effluent limitations for oil and
         grease at 29 mg/1 monthly average, and 42 mg/1 daily maximum based on improved operating
         performance of gas flotation.

      •  Option 2 [the selected option]:  Option 2 prohibits all coastal oil and gas facilities from
         discharging produced water with the exception of coastal facilities in Cook Inlet, Alaska.  In
         Cook Inlet, facilities are required to comply with new BAT effluent limitations for oil and
         grease at 29 mg/1 monthly average, and 42 mg/1 daily maximum based on improved operating
         performance of gas flotation. (This option would require facilities in the Gulf currently not
         covered by the NPDES general permit to meet zero discharge.)
         Option 3:  Option 3 prohibits all discharges of produced water. The technology basis for
         compliance with zero discharge is injection of produced water. (This option would require
         facilities in the Gulf currently not covered by the NPDES general permit to meet zero
         discharge.)

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                                                                                            1-7
1.8.2    Drilling Wastes

      EPA considered two options for regulating drilling wastes in the development of this final rule.
These options considered are:

        •  Option 1 [the selected option]: Zero Discharge All, except Offshore Limits for Cook Inlet
          Facilities.  Option 1 allows the discharge of drill cuttings and drilling fluid with limitations
          requiring toxicity of no less than 30,000 ppm (SPP), no discharge of free oil or diesel, and
          no more than 1 mg/1 mercury and 3 mg/1 cadmium in the stock barite. This option requires
          no additional regulatory requirements beyond those already in place.
        • Option 2: Zero Discharge All.  This option requires all operators to achieve a zero
          discharge standard, including Cook Inlet operations.  The two control technology bases for
                               i
          compliance with the zero-discharge option considered for drilling wastes in Cook Inlet are:
          (1) waste minimization via closed-loop solids control, followed by transportation of drilling
          wastes to shore for disposal; and (2) grinding followed by subsurface injection at the
          platform.

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                                                                                         2-1
                   2.  PRODUCED WATER CHARACTERIZATIONS
2.1      Industry Profile and Discharge Volumes

         The discharge volumes and pollutant concentration data used in this WQBA for the final
coastal oil and gas effluent guidelines are derived from state and NPDES permit data and from data
collected and analyzed by BAD of EPA's Office of Science and Technology.  Discharge volumes and
pollutant concentration data are presented in summary form in this WQBA. The specifics of their
collection, derivation, and analyses are presented in detail in the Development Document for this final
rule (EPA, 1996a).  The volume, pollutant, and toxicity data summarized and presented in this chapter
are used for all of the analyses that are conducted and presented in this WQBA.

         The  industry profile for coastal oil and gas facilities operating in the Gulf of Mexico region
has been revised to reflect changes in the regulatory  environment since proposal development.  For
details, citations, and references for the revisions to the industry profile data described below, please
refer to the Development Document (EPA, 1996a).  For the final rule, Gulf of Mexico  costs and
pollutant removals for produced water hi this document are based on full implementation of Region VI
NPDES general permits. At the time proposed coastal guidelines were being developed, no general
permit was in place regulating discharges from these facilities. On January 9, 1995, EPA Region VI
published final NPDES general permits (hereafter "general permits") regulating discharges of produced
water and produced sand derived from oil and gas point source facilities (60 PR 2387; January 9, 1995;
LAG290000 and TXG290000).  In the absence of promulgated effluent guidelines, these general
permits represent the Region's Best Professional Judgment (BPJ) of limitations that would represent
effluent guidelines of the BAT level of control.  Due to the late publication date of these general
permits relative to the proposed Coastal Subcategory effluent limitations guidelines, the proposed
rulemaking presented costs and pollutant loadings as if the general permits were not final.

          These BAT/BPJ general permits are comprehensive in that they require all coastal facilities in
 Region VI (with a few exclusions, as noted below) to comply with zero discharge for produced water.
 At the same time, Region VI issued an Administrative Order along with these general permits allowing

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 2-2
 discharge until January 1, 1997.  Certain Texas Stripper Subcategory wells are excluded from the
 provisions of the general permit for Texas. Because these Texas Stripper wells are not in the coastal
 subcategory, their exclusion does not affect the Coastal Subcategory industry profile or list of
 dischargers. Thus, no Texas facilities are projected to incur any incremental compliance costs as a
 result of the guidelines rulemaking.

         Another exclusion, however, does affect the Coastal Subcategory inventory of dischargers:
 The general permit for Louisiana excludes from coverage discharges of produced water derived from
 Offshore Subcategory wells or from Stripper Subcategory wells to the major deltaic passes1 of the
 Mississippi River or to the Atchafalaya River below Morgan City including Wax Lake Outlet (hereafter
 referred to as "major deltaic pass dischargers.")  It should be noted that produced water derived from
 Coastal Subcategory wells is not excluded from coverage under the zero discharge requirement of the
 general permits (See 60 FR 2387; January 9, 1995). EPA has sought to identify any and all oil and gas
 production facilities near the Mississippi and Atchafalaya River deltas of Louisiana that might be
 excluded from coverage under the terms of the general permit.

         EPA Region VI, Louisiana's Department of Environmental Quality (LDEQ), and commentors
 assisted in identifying facilities that might fit the terms of the general permit exclusion.  No facilities
 could be identified as discharging produced water derived from the Stripper or Offshore Subcategories
 into the Atchafalaya River. However, six companies with eight outfalls were ultimately verified as
 discharging offshore-derived produced water into major deltaic passes.

         Produced water discharge rates for these eight outfalls were determined from LDEQ
 Discharge Monitoring Reports (DMRs) dated 1993 through 1995, and supplemented with written and
 electronic industry confirmation. When the proportion of offshore-derived versus coastal-derived
produced water could not be determined, it was assumed that all produced water at that facility is
derived offshore. Thus, maximum compliance costs are estimated.
      1   Major deltaic passes are defined by the Louisiana Department of Environmental Quality (LDEQ) as
         those receiving 0.5% of the main river flow.

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                                                                                            2-3
         Coastal production facilities in Mississippi, Alabama, Florida, California, and the North
Slope of Alaska inject all of their produced water either for disposal or for waterflooding. There are
no incremental compliance costs or pollutant removals associated with these facilities. Coastal facilities
in Cook Inlet, Alaska, are described separately.

         In addition to major deltaic pass dischargers in Louisiana and Cook Inlet, Alaska dischargers,
a third group of dischargers also was subject to consideration in the development of these guidelines-
Louisiana "open bay dischargers." LDEQ issues state permits for discharges of oil and gas production
wastes in state waters.  With the exception of discharges to major deltaic passes of the Mississippi and
Atchafalaya Rivers, these state permits implement state regulations which require that produced water
discharges be phased out.  The state has grouped permits by receiving water type and has identified a
series of termination dates by which the cessation of discharges must occur. Fresh water areas were
phased out earliest and brackish/saline water areas are to be phased out last.  Nearly all discharges
must cease by 1997, with only th
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 2-4
 WQBA (see Section 2.2.2.1).2 Because the outcome of LDEQ's deliberations on the zero discharge
 rule is uncertain, EPA chose to assess this population'of dischargers as part of this effluent guidelines
 development.

          Lastly, a fourth group of dischargers was considered in the development of these coastal
 guidelines: individual permit applicants in Texas.  The Railroad Commission of Texas identified a
 number of operators who are applying for coverage under NPDES individual permits instead of cover-
 age under the Region VIBAT/BPJ general permit for Texas.  Operator and discharge volume data used
 in this WQBA were obtained from the Railroad Commission's log of individual permit applications
 received by May 15, 1996 under the general permit.  As of May 15,  1996, the Railroad Commission of
 Texas had logged 100 individual permit applicants. Eighty-two of these  100 individual permit
 applicants reported discharge rates and these are used for analysis hi the  WQBA (see Section 2.2.2.2).3

 2.2      Produced Water Discharge Volume Characterization

 2.2.1    Current Requirements Baseline Dischargers

 2.2.1.1   Major Deltaic Pass Dischargers, Louisiana

          With the assistance of LDEQ and industry representatives, EPA identified a total of six
 operators with eight outfalls which would be affected  by the final rule. Discharge data for this
 rulemaking were collected from state files, verified by EPA teleconferences, and compiled for analysis.
 The final list of operators and discharge rates used hi  this WQBA are  supplied by EPA and are
 presented in Exhibit 2-1.
      2These outfalls represent the same universe of Louisiana dischargers utilized in engineering and cost
analyses, except that those analyses aggregate outfalls at the permit level (37 permits). The WQBA bases its
analyses on disaggregated, outfall-level data because using discharge-level data is a more appropriate approach for
the assessment of environmental effects.
      3These permit applicants represent the same universe of Texas dischargers utilized hi engineering and cost
analyses, except that those analyses aggregate applicants at the permit level (91 permits). The WQBA bases its
analyses on disaggregated permit data.

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          For the Gulf of Mexico coastal subcategory, there exists a mixture of treatment technologies
 in use among major deltaic pass dischargers for the current requirements baseline scenario.  There are
 a total of eight produced water outfalls owned by six operators currently discharging produced water
 effluent in the deltaic region of the Mississippi River. Among these eight outfalls, seven are
 discharging produced water at settling tank effluent quality. These seven outfalls represent a total
 discharge of 36,825 barrels  per day (bpd) or 13.4 million barrels per year (bpy).  Their discharge rates
 range from 291 bpd to 18,920 bpd with a mean discharge rate of 6,138 bpd. The remaining outfall is
 currently using IGF treatment technology with a total discharge of 153,895 bpd, or 56.4 million bpy.
 Thus, for all major deltaic pass dischargers, there is a combined discharge of 191,292 bpd, or 69.8
 million bpy;  the discharge rates range from 291 bpd to  153,895 bpd, with a mean discharge rate of
 23,912 bpd.

 2.2.1.2   Cook Inlet, Alaska

          Discharges of produced water to Cook Inlet are covered by an NPDES general permit issued
 by EPA Region X (EPA, Region X,  1986).  Individual  facility discharge volumes and rates are  used to
 assess loadings and water quality impacts for individual outfalls similar to  the major deltaic pass
 discharges used for Gulf of Mexico analyses. The discharge rates of the eight outfalls located in Cook
 Inlet are presented in Exhibit 2-2.

          All eight outfalls discharging into Cook Inlet are discharging BPT-level produced water
 effluent, and average 16,911 bpd, with a total discharge volume of 135,285  bpd, or 49.4 million bpy.
 Discharge rates range from 30 bpd to 127,468 bpd for these eight outfalls.  These discharge rates are
 used for Cook Inlet operations in analyses for all options considered that include discharge of treated
 effluent (Options 1 and 2).

2.2.2     Alternative Baseline Dischargers
2.2.2.1  Open Bay Dischargers, Louisiana

         LDEQ issues state water discharge permits for discharges of oil and gas production wastes in
state waters.  Nearly all discharges must cease by 1997, with only the few facilities discharging to

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                                                                                         2-7
Exhibit 2-2. Cook Inlet, Alaska Produced Water Outfalls
Operator
Unocal
Shell Western
Unocal
Unocal
Unocal
Phillips
Unocal
Unocal
Facility
Trading Bay
East Foreland
Dillon
Anna
Granite Point
NCIU Tyonek A
Bruce
Baker
Discharge Distance
from Shore
(miles)
1.9
0.15
3.7
2.5
1.9
5.5
1.5
7.5
Discharge
Volume
(bpd)
127,468
1,700
3,116
919
929
30
199
924
Outfall Count 8
Total Cook Inlet Volume (bpd) 135,285
Total Cook Inlet Volume (bpy) 49,379,025
Mean Cook Inlet Discharge Rate (bpd) 16,91 1
               Source: EPA, 1996a.
 major deltaic passes of the Mississippi and Atchafalaya Rivers permitted to continue discharging.
 Variances from compliance dates have been issued through January 1, 1997 to a number of facilities
 discharging to open bays and located more than 1 mile from any shoreline.  Permits for the operators
 who indicated that they would continue discharging if given variances by LDEQ were listed by USDOE
 in a risk assessment of produced water discharges in open bays of Louisiana (USDOE, 1996).
 Discharge data were collected from state files and reported by USDOE (1996). This discharge
 information, compiled by USDOE, !is used in this WQBA for characterization of Louisiana open bay
 dischargers.

         For IGF treatment technology evaluation, small dischargers (defined for Louisiana as dischar-
 ges of less than 70.5 bpd) are assumed by EPA to haul their waste to commercial disposal facilities

-------
2-8
rather than improve their treatment systems to IGF, and are not included in the IGF treatment technol-
ogy analyses performed in this WQBA. Additionally, all sites that reported zero discharge, intermittent
discharge, or omitted discharges are not used in either current technology or IGF technology analyses.

         A list of 69 outfalls located hi Louisiana open bays is presented in Exhibit 2-3. These 69
outfalls that are assumed to be using settling tank treatment and current technology are currently
discharging a total discharge of 329,814 bpd, or 120.4 million bpy produced water. Discharge rates
range from 1 bpd to 37,113 bpd, with a mean discharge rate of 4,780 bpd; 18  outfalls discharge at a
flow greater than the mean, with a combined flow of 260,266 bpd (79% of total daily flow). The
median current technology discharge rate by outfall (i.e., the discharge rate above and below which
50% of the outfalls discharge) is 1,680 bpd; 35 outfalls totaling 96.3% (317,492 bpd) of the total daily
flow discharge above the median flow by outfall.  The median current technology discharge rate by
volume (i.e., the discharge rate above and below which 50% of all produced water is discharged) is
13,351 bpd; 8 outfalls discharge at a flow greater than the median flow by volume.

         For IGF treatment technology evaluation, there are 56 outfalls identified as discharging at
greater than the 70.5 bpd minimum discharge threshold, with a total discharge of 329,567 bpd, or
120.3 million bpy. Discharge rates range from 117 bpd to 37,113 bpd, with a mean discharge rate of
5,885 bpd; 16 outfalls with a combined flow of 76% of the total daily flow (249,998 bpd) discharge at
a rate greater than the mean discharge rate.  The median IGF treatment technology discharge rate by
outfall is 2,955 bpd; 28 outfalls totaling 91.6%  (301,725 bpd) of the total daily flow discharge above
the median flow by outfall.  The IGF treatment technology median discharge rate by volume is 13,375
bpd; 8 outfalls discharge at a flow greater than the median flow by volume.
2.2.2.2  Individual Permit Applicants, Texas

         With issuance of the Region VIBAT/BPJ general permit, the Railroad Commission of Texas
has been receiving correspondence from individual facility operators who are filing for exemptions
from zero discharge requirements under the general permit and submitting applications for individual
NPDES permits.  The log of this correspondence file is used to characterize Texas coastal dischargers.

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Exhibit 2-3.  Louisiana Open Bay Produced Water Outfalls
                                                                                        2-9
Permit Number
1856
1866
1870
1901
1901
1901
1934
2072
2072
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2084
2134
2142
2273
2479
Location
Quarantine Bay
Breton Sound
Chandeleur Sound
\ Black Bay
Black Bay
Black Bay
Breton Sound
Breton Sound
Breton Sound
Terrebonne Bay
Terrebonne Bay
Terrebonne Bay
Timbalier Bay
i
Timbalier Bay
Timbalier Bay
Timbalier Bay
Terrebonne Bay
Timbalier Bay
Terrebonne Bay
Terrebonne Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
Chandeleur Sound
N Black Bay
Chandeleur Sound
Timbalier Bay
Discharge Rate
(bpd)
15,000
4,621
49
20,077
11,500
10,123
15,675
20,250
17,500
3,720
3,017
2,484
2,126
2,065
1,201
802
701
586
41
0
0
0
0
0
0
23,333
12,076
4,621
10
Water Depth3
(m)
1.8
3.1
2.0
0.6
0.6
0.6
3.1
3.1
3.1
1.5
1.5
1.5
1.0
1.0
1.0
1.0
1.5
1.0
1.5
1.5
1.0
1.0
1.0
1.0
1.0
2.0
0.6
2.0
1.0

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2-10
Exhibit 2-3.  Louisiana Open Bay Produced Water Outfalls (Continued)
Permit Number
2504
2523
2523
2618
2672
2704
2816
2816
2816
2816
2816
2816
2816
2816
2816
2816
2816
2825
2827
2856
2857
2857
2859
2860
2881
2881
2881
2881
2881
2898
2898
Location
W Cote Blanche Bay
W Cote Blanche Bay
W Cote Blanche Bay
Breton Sound
Black Bay
Terrebonne Bay
Jacko Bay
Jacko Bay
Lake Barre/Jacko Bay
Jacko Bay
Terrebonne Bay
Jacko Bay
Jacko Bay
Terrebonne Bay
Timbalier Bay
Jacko Bay
Jacko Bay
Atchafalaya Bay
incomplete permit data
Breton Sound
Breton Sound
Breton Sound
E Black Bay
Black Bay
Lake Pelto
Lake Pelto
Lake Pelto
Lake Pelto
Terrebonne Bay
Terrebonne Bay
Terrebonne Bay
Discharge Rate
(bp%)
37,113
5,364
0
22,500
8,366
524
614
600
510
220
140
117
30
30
10
0
0
2,910
1
3
10
10
10,807
6,800
2,485
1,103
729
489
204
3,000
617
Water Depth"
(m) v
1.8
1.8
1.8
3.1
0.6
1.5
1.1
1.1
1.5
1.1
1.5
1.1
1.1
1.5
1.0
1.1
1.1
2.3
1.7
3.1
3.1
3.1
0.6
0.6
1.4
1.4
1.4
1.4
1.5
1.5
1.5

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                                                                                                       2-11
Exhibit 2-3.  Louisiana Open Bay Produced Water Outfalls (Continued)
Permit Number
2898
2898
2901
2901
2915
2952
2995
3002
3014
3023
3032
3032
3072
3063
3320
3320
3320
3320
3320
4206
Location
Timbalier Bay
Terrebonne Bay
Breton Sound
i
Breton Sound
Chandeleur Sound
Breton Sound
Salt Bay
Barataria Bay
Breton Sound
Chandeleur Sound
Chandeleur Sound
Chandeleur Sound
E Cote Blanche Bay
:Black Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
Timbalier Bay
incomplete permit data

Outfall Count (discharging)
Total Louisiana Open Bay Volume (bpd)
Total Louisiana Open Bay Volume (bpy)
Mean Louisiana Open Bay Discharge Rate (bpd)c
Median Discharge Rate (by outfall)
Median Discharge Rate (by volume)
Discharge Rate (bpd)
0
0
876
200
130
223
4,621
2,017
4,621
3
25
25
1,489
11,500
7,368
4,914
4,744
3,873
1,680
4,621
Current Technology
69
329,814
120,382,111
4,780
1,680
13,351
Flow-weighted Average Louisiana Open Bay Water Depth (m)c
Water Deptha (m)
1.0
1.5
3.1
3.1
2.0
3.1
0.2
1.5
3.1
2.0
2.0
2.0
1.8
0.6
1.0
1.0
1.0
1.0
1.0
1.7
IGF Treatment
Technology11
56
329,567
120,291,955
5,885
2,955
13,375
1.73
a. Average depth for receiving water indicated on permits listed in U.S. DOE (1996).
b. Outfalls discharging greater than 70.5 bpd.
c. Flow-weight average = sum of receiving water average depth x individual discharge rate, then divided by total discharge

-------
2-12
         For current technology (settling tank treatment) analyses in this WQBA, Texas facilities
include those current discharges listed on the individual permit application intake log.  For IGF treat-
ment technology analysis, small dischargers (defined for Texas as discharges of less than 76.5 barrels
of produced water per day) are assumed by EPA to haul their produced water to commercial disposal
facilities rather than investing hi improved (IGF) technology. These small dischargers are not included
in the IGF treatment technology analyses hi this WQBA. Additionally, all sites on the permit applica-
tion list that reported zero discharge are not used for either current technology nor IGF treatment tech-
nology analyses hi the WQBA. The list of Texas individual permit applicants and discharge volumes
for both current technology and the IGF treatment technology option are presented in Exhibit 2-4.

         There are 82 individual permit applicants identified in coastal Texas that are assumed to be
discharging at the current technology level of treatment, with a total discharge of 67,764 bpd, or
24.7 million bpy. Discharge rates range from 1 bpd to 9,316 bpd with a mean discharge rate of
827 bpd; 18 facilities discharge at greater than the mean discharge rate, with a combined volume of
56,616 bpd (84% of the total daily flow).  The median current technology discharge rate by facility is
163 bpd; 41 facilities discharge 97% of the total daily flow (65,575 bpd) at greater than the median
discharge rate by facility. The median current technology discharge rate by volume is 3,714 bpd; 6
facilities discharge at a rate greater than the median discharge rate by volume.
         For the IGF treatment technology analysis, there are 53 facilities identified as discharging at
greater than the 76.5 bpd minimum discharge threshold, with a total discharge of 67,010 bpd, or
24.5 million bpy.  Discharge rates range from 86 bpd to 9,316 bpd with a mean discharge rate of 1,265
bpd; 16 facilities discharge at a rate greater than the mean IGF treatment technology discharge rate,
and total 54,436 bpd (81 %) of the total daily flow.  The median IGF treatment technology discharge
rate by facility is 443 bpd; 26 facilities discharge 91%  of the total daily flow (61,323 bpd), at greater
than the median discharge rate by facility. The median IGF treatment technology discharge rate by
volume is 3,749 bpd; 6 facilities discharge at a rate greater than the median discharge rate by volume.

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                                                                                       2-13
Exhibit 2-4.  Texas Permit Applicants Produced Water Outfalls
Permit Number
04CCC
na
na
na
na
1
13
14
18
20
37
41
45
60
68A
68B
68C
68D
68E
71
77
80
81
85
90
104
105A
105B
Location
Corpus Christi Bay
Aransas Bay
Black Duck Bay
Matagorda Bay
E Matagorda Bay
Carancahua Bay
Kellers Bay
San Antonio Bay
Carancahua Bay
San Antonio Bay
San Antonio Bay
Cox Bay
Carancahua Bay
Galveston
' Cow Bayou
Cow Bayou
Cow Bayou
Cow Bayou
' Cow Bayou
Tabbs Bay
Tabbs Bay
Trinity Bay
Trinity Bay
! Tres Palacios
Star Bayou
Goose Creek
Cow Bayou
Cow Bayou
Discharge Rate
(bpd)
0
7
93
115
1,500
0
5
0
0
1,151
15
40
1,400
685
50
55
315
1,765
0
3
3,552
1,492
3,090
1,379
1,800
49
0
160
Water Depth"
(m)
3.2
2.8
0.6
2.7
1.3
1.0
1.0
1.7
1.0
1.7
1.7
1.2
1.0
1.9
1.0
1.0
1.0
1.0
1.0
0.8
0.8
2.0
2.0
1.4
1.0
1-9
1.0
1.0

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2-14
Exhibit 2-4. Texas Permit Applicants Produced Water Outfalls (Continued)
Permit Number
105C
105D
105E
105F
113
119
124A
124B
127
164-001
164-003
164-004
164-005
166
167
174
199
202
214
215
217
233
236
238
242
264
282
284
Location
Cow Bayou
Cow Bayou
Cow Bayou
Cow Bayou
Star Bayou
Goose Creek
East Bay Bayou
East Bay Bayou
Tabbs Bay
Galveston Bay
Galveston Bay
Galveston Bay
Galveston Bay
Gum Bayou
Gum Bayou
Galveston Bay
Mustang Island
Red Fish Bay
Corpus Christi Bay
Corpus Christi Bay
Point Comfort
Aransas Bay
Mustang Island
Corpus Christi Bay
Petronilla Creek
Copano Bay
Corpus Christi Bay
Corpus Christi Bay
Discharge Rate
(bpd)
230
0
0
260
5,127
2
255
200
0
0
443
3,918
2
1,029
690
384
40
153
16
0
0
1
44
515
104
114
1
22
Water Depth3
(m)
1.0
1.0
1.0
1.0
1.0
1.9
3.7
3.7
0.8
1.9
1.9
1.9
1.9
1.0
1.0
1.9
0.9
1.7
3.2
3.2
1.0
2.8
0.9
3.2
1.0
1.2
3.2
3.2

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                                                                                        2- 15
Exhibit 2-4.  Texas Permit Applicants Produced Water Outfalls (Continued)
Permit Number
552
582
595
605
619
628
637
663
666
674
675
679
684
690
693
694
710
711
723
747
752
813
822
825
903
904
905
919
Location
N. Piper Lake
Laguna Madre
Trinity Bay
Laguna Madre
Galveston Bay
Copano Bay
Trinity Bay
Cedar Lake
Trinity Bay
Tabbs Bay
Tabbs Bay
Black Duck Bay
Tabbs Bay
Aransas Bay
Aransas Bay
Trinity Bay
Trinity Bay
Aransas Bay
Matagorda Bay
San Antonio Bay
Sabine River (Adams Bayou)
Espirito Santo Bay
High Island
Cedar Lake
Tabbs Bay
Tabbs Bay
Goose Creek
Matagorda Bay
Discharge Rate
(bpd)
140
75
0
150
536
24
200
10
628
0
92
454
165
1
10
185
358
0
1
0
29
4,893
200
0
0
1,360
86
60
Water Depth3
(m)
1.0
0.9
2.0
0.9
1.9
1.2
2.0
0.6
2.0
0.8
0.8
0.6
0.8
2.8
2.8
2.0
2.0
2.8
2.7
1.7
2.1
2.0
1.0
0.6
0.8
0.8
1.9
2.7

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2-16
Exhibit 2-4.  Texas Permit Applicants Produced Water Outfalls (Continued)
Permit Number
921
922
924
925
926
927
937
939
952
953
954
967
968
969
970
972
Location
Matagorda Bay
Matagorda Bay
Matagorda Bay
Matagorda Bay
Matagorda Bay
Matagorda Bay
Black Duck Bay
Tabbs Bay
Trinity Bay
Trinity Bay
Trinity Bay
*pending, incomplete permit data
*pending, incomplete permit data
*pending, incomplete permit data
*pending, incomplete permit data
Aransas Bay

Facilities Count
Total Texas Permit Applicants Volume (bpd)
Total Texas Permit Applicants Volume (bpy)
Mean Texas Permit Applicants Discharge Rate (bpd)
Median Discharge Rate (by outfall)
Median Discharge Rate (by volume)
Discharge Rate
(bpd)
410
143
31
69
48
95
659
43
4,980
9,316
7,384
397
540
1,480
250
1
Current
Technology
82
67,764
24,733,860
827
163
3,714
Water Depth2
(m)
2.7
2.7
2.7
2.7
2.7
2.7
0.6
0.8
2.0
2.0
2.0
1.6
1.6
1.6
1.6
2.8
IGF Treatment
Technology15
53
67,010
24,458,650
1,265
443
3,749
Flow-weighted Average Texas Permit Applicants Outfall Depth (m)c 1.66
a. Average depth for receiving water indicated on permit applicant list.
b. Facilities discharging greater than 76.5 bpd.
c. Flow-weighted average = sum of receiving water depths x individual discharge rate, then divided by total state discharge
  rate (See Section 3.1.2.2).

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                                                                                         2-17
2.3
Produced Water Pollutant Characterization
2.3.1    Current Requirements Baseline Dischargers

2.3.1.1  Major Deltaic Pass Dischargers, Louisiana

         Pollutant data for current technology level of treatment are provided in EPA's Development
Document for this final rule (EPA, 1996a) based on sampling conducted on coastal facilities in
Louisiana and Texas.  IGF treatment technology (BAT Option 1) effluent concentrations also are
provided by EPA based on sampling of offshore produced water discharges (EPA, 1993a).  The
concentrations of the 49 pollutants in produced water discharges from oil and gas facilities located in
coastal areas adjacent to the Gulf of Mexico, for current technology and IGF technology (BAT Option
1), are presented in Exhibit 2-5. The derivation of these pollutant values is presented in detail in the
Development Document (EPA, 1996a).

2.3.1.2  Cook Inlet, Alaska

         Pollutant concentration data for the 46 pollutants identified in produced water discharges from
Cook Inlet facilities are provided by EPA. Current technology pollutant concentrations and IGF
treatment technology (BAT Options 1 and 2) pollutant concentrations are based on data in the Offshore
Development Document (EPA, 1993a). The derivation of all pollutant  concentrations developed by
BAD are explained in detail in the Development Document for this rule (EPA, 1996a).  Current
technology and IGF pollutant concentration data are presented in Exhibit 2-6.
                               i

2.3.2    Alternative Baseline Dischargers
2.3.2.1  Open Bay Dischargers, Louisiana

         The current technology and IGF effluent pollutant characterizations (Exhibit 2-5) used for
major deltaic pass dischargers are also used to characterize open bay dischargers' current technology
and IGF effluent streams (see above; Section 2.3.1.1).

-------
2-18
Exhibit 2-5. Produced Water Pollutant Concentrations for Gulf of Mexico Analyses
Pollutant
2-Hexanone
2-Methylnaphthalene
2,4-Dimethylphenol
Aluminum
Ammonia
Barium
Benzene
Benzoic Acid
Boron
Cadmium
Calcium
Chlorides
Chromium
Cobalt
Copper
Ethylbenzene
Hexanoic Acid
Iron
Lead
Lead 210
pCi/1
Magnesium
Manganese
Molybdenum
m-Xylene
Naphthalene
n-Decane
n-Dodecane
n-Eicosane
Pollutant
Category
Nonconventional
Nonconventional
Priority organic
Nonconventional
Nonconventional
Nonconventional
Priority organic
Nonconventional
Nonconventional
Priority metal
Nonconventional
Nonconventional
Priority metal
Nonconventional
Priority metal
Priority organic
Nonconventional
Nonconventional
Priority metal
Radionuclide

Nonconventional
Nonconventional
Nonconventional
Nonconventional
Priority organic
Nonconventional
Nonconventional
Nonconventional
Mean Concentration G^g/l)
Current
Technology
34.5
77.7
148
1,410
41,900
52,800
5,200
5,360
22,800
31.5
2,490,000
57,400,000
180
117
236
110
1,110
17,000
726
0.000000549
38.1
601,000
1,680
121
147
184
152
288
78.8
Improved
Gas Flotation
34.5
77.7
148
49.93
41,900
35,560.83
1,225.91
5,360
16,473.76
14.47
2,490,000
57,400,000
180
117
236
62.18
1,110
3,416.15
124.86
0.000000549
38.1
601,000
1,680
121
147
121
152
228
78.8

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                                                                                      2-19
Exhibit 2-5.  Produced Water Pollutant Concentrations for Gulf of Mexico Analyses (Continued)
Pollutant
n-Hexadecane
Nickel
n-Octadecane '
n-Tetradecane
o-Cresol
Oil and Grease
o+p-Xylene
p-Cresol
Phenol .
Radium 226
pCi/1
Radium 228
pCi/1
Silver
Strontium
Sulfur
Tin :
Titanium
Toluene
Total Suspended Solids
Vanadium
Yttrium
Zinc
Pollutant
Category
Nonconventional
Priority metal
Nonconventional
Nonconventional
Nonconventional
Conventional
Nonconventional
Nonconventional
Priority organic
Radionuclide

Radionuclide

Priority metal
Nonconventional
Nonconventional
Nonconventional
Nonconventional
Priority organic
Conventional
Nonconventional
Nonconventional
Priority metal
Mean Concentration C"g/l)
Current
Technology
316
151
78.8
119
152
26,600
110
164
723
0.000191
189.1
0.000000977
264
359
287,000
12,200
430
43.8
4,310
141,000
135
35.3
462
Improved
Gas Flotation
316
151
78.8
119
152
23,500
110
164
536
0.000191
189.1
0.000000977
264
359
287,000
12,200
430
4.48
827.8
30,000
135
35.3
133.85
                 Source:  EPA 1996a.

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2-20
Exhibit 2-6. Produced Water Pollutant Concentrations for Cook Inlet, Alaska Analyses
Pollutant
2-Hexanone
2-Methylnaphthalene
2,4-Dimethylphenol
Aluminum
Ammonia
Anthracene
Barium
Benzene
Benzoic Acid
Benzo(a)pyrene
Boron
Cadmium
Calcium
Chlorides
Chromium
Cobalt
Copper
Ethylbenzene
Hexanoic Acid
Iron
Lead
Magnesium
Manganese
Molybdenum
n-Alkanes
Naphthalene
Nickel
o-Cresol
Oil and Grease
p-Cresol
Phenol
Pollutant
Category
Nonconventional
Nonconventional
Priority organic
Nonconventional
Nonconventional
Priority organic
Nonconventional
Priority organic
Nonconventional
Priority organic
Nonconventional
Priority metal
Nonconventional
Nonconventional
Priority metal
Nonconventional
Priority metal
Priority organic
Nonconventional
Nonconventional
Priority metal
Nonconventional
Nonconventional
Nonconventional
Nonconventional
Priority organic
Priority metal
Nonconventional
Conventional
Nonconventional
Priority organic
Mean Concentration (/ug/1)
Current
Technology
34.5
77.7
514.7
78.01
41,900
25.3
55,563.8
3,386.1
5,360
10.6
25,740.3
22.6
2,490,000
57,400,000
180
117
444.7
157.7
1,110
4,915.9
195.1
601,000
115.9
121
1,941.5
933.5
1,705.5
152
26,600
164
431.5
Improved Gas
Flotation
34.5
77.7
250.0
49.91
41,900
7.40
35,560.8
1,225.9
5,360
4.65
16,47.8
14.5
2,490,000
57,400,000
180
117
284.6
62.2
1,110
3,146.2
124.9
601,000
74.2
121
656.6
92.0
1,091.5
152
23,500
164
431.5

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                                                                                       2-21
Exhibit 2-6.  Produced Water Pollutant Concentrations for Cook Inlet, Alaska Analyses (Continued)
Pollutant
Radium-226
pCi/1
Radium-228
pCi/1
Silver j
Steranes
Strontium
Sulfur
Tin
Titanium ;
Toluene
Total Suspended Solids
Total Xylenes
Triterpanes
Vanadium
Yttrium
Zinc
Pollutant
Category
Radionuclide

Radionuclide

Priority metal
Nonconventional
Nonconventional
Nonconventional
Nonconventional
Nonconventional
Priority organic
Conventional
Nonconventional
Nonconventional
Nonconventional
Nonconventional
Priority metal
Mean Concentration (/ug/1)
Current
Technology
0.000000265
2.62
0.000000003
8.11
359
77.5
2878,000
12,200
430
7.00
1,507.4
141,000
542.5
78.0
135
35.3
44.8
Improved Gas
Flotation
0.000000265
2.62
0.000000003
8.11
359
31.0
287,000
12,200
430
4.48
827.8
30,000
378.0
31.2
135
35.3
44.8
                   Source: EPA,:i996a.

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2-22
2.3.2.2  Individual Permit Applicants, Texas

         The current technology and IGF effluent pollutant characterizations (Exhibit 2-5) used for
major deltaic pass dischargers are also used to characterize Texas individual permit applicant
discharges (see above; Section 2.3.1.1).

2.4      Produced Water Toxicity Characterization

2.4.1    Current Requirements Baseline Dischargers
2.4.1.1  Major Deltaic Pass Dischargers, Louisiana

         LDEQ coastal discharge permits require that operators conduct acute and chronic toxicity
tests using mysids and sheepshead minnows and submit the results within six months of initiating
produced water discharges.  These toxicity data for coastal outfalls were compiled from the LDEQ
permit files and are summarized for 222 outfalls in Exhibit 2-7.

         Louisiana produced water toxicity tests report an average acute toxicity (96-hour LC50) of
12.4% effluent for mysids (range of 0.048% to 100% effluent) and 27.4% effluent for sheepshead
minnows (range of 1.17% to 100% effluent). The average chronic EC50 values range from 4.69%  to
6.23% effluent for mysids and 8.25% to 8.54% effluent for sheepshead minnows.

         Whole effluent toxicity testing is used to characterize the sum total toxicity of an effluent's
chemical composition.  Whole effluent toxicity has been used to address the "no toxic pollutants in
toxic amounts" portion of state water quality regulations.  Whole effluent toxicity data may be used
either end-of-pipe or mixing zone analyses.  The information below describes the whole effluent
toxicity of produced water for  both Gulf of Mexico and Cook Inlet operations.

2.4.1.2   Cook Met, Alaska

          As part of a study conducted for Alaska oil and gas companies and EPA (Ebasco Environ-
mental, 1990), six production facilities were sampled in winter and summer.  The toxicity data are
in

-------
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2-24
presented in Exhibit 2-8. The mean seasonal 96-hour LC50s range from 0.91 % effluent to 63.39%
effluent, with an overall mean of 23.6% effluent for the six facilities.

 2.4.2   Alternative Baseline Dischargers
2.4.2.1  Open Bay Dischargers, Louisiana

         The produced water toxicity characteristics of major deltaic pass dischargers are also
applicable to open bay dischargers in Louisiana (see above; Section 2.4.1.1).

Exhibit 2-8.  Cook Inlet Produced Water Toxicity Data
Facility
Amoco Platform Bruce
Winter
Summer
Marathon Granite Point
Winter
Summer
Marathon Trading Bay
Winter
Summer
Shell East Forelands
Winter
Summer
Amoco Platform Baker
Winter
Summer
Winter
Summer
Phillips Platform A
Winter
Summer
Mean 96-hour LC50
for Mysidopsis bahia
(% Effluent)
1.5
0.3
8.5
18.5
12.1
23.9
13.9
29.4
20.5
29.3
32.4
13.8
78.2
49.2
Annual Mean LC50
(% Effluent)
0.91
13.5
18.0
21.66
23.99
63.69
Source:  Ebasco Environmental, 1990.

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                                                                                          2-25
2.4.2.2  Individual Permit Applicants, Texas

         The Railroad Commission of Texas produced water discharge permits do not require toxicity
testing. Therefore, whole effluent toxicity data for Texas coastal outfalls were obtained from literature
sources.  These limited toxicity data identified for Texas are summarized in Exhibit 2-9.

         Texas lethal toxicity values range from 2.7% to 80% effluent (48-hr LC50s) for silverside
minnows and grass shrimp, respectively.  The mean 48-hour LC50 value for all species is 22.7%
effluent for 10 reported values. The mean 96-hour LC50 is 42% effluent for 7 reported values.
Chronic values (ECSOs) range  fronr <2.7% to 27.2% effluent for 3 reported tests.

2.5      Produced Water Pollutant Loadings and Removals by the Selected BAT Option

2.5.1    Current Requirements Baseline

2.5.1.1  Major Deltaic Pass Dischargers, Louisiana

         For all eight major deltaic pass outfalls (six operators), the total annual current technology
pollutant loading (based on 49  pollutants) for produced water is 1,492,600,175 pounds (Ibs).  This total
loading includes:   1,855,319 Ibs of conventionals; 108,018 Ibs of priority organics; 33,877 Ibs of
priority metals; and 1,490,602,961 Ibs of non-conventionals.  For IGF treatment technology (BAT
Option 1), the pollutant loading for these same 49 pollutants totals 1,491,819,056 Ibs.  This total
loading includes:   1,309,386 Ibs of conventionals; 70,778 Ibs of priority organics; 29,349 Ibs of
priority metals; and 1,490,409,543 Ibs of non-conventionals.  These loadings, and all of the following
produced water loadings and removal estimates in the WQBA, exclude well treatment, workover, and
completion fluids.
2.5.1.2  Cook Inlet, Alaska

         The total Cook Inlet current technology pollutant loading (46 pollutants) for produced water
is 1,056,542,206 Ibs. This total loading includes:  1,781,074 Ibs of conventionals; 120,587 Ibs of

-------
2-26
Exhibit 2-9.  Texas Coastal Produced Water Toxicity Data
Species
Sheepshead minnow
Pinfish
Atlantic croaker
White mullet
Brown shrimp
White shrimp
Microtox
Mysids
Sea urchin
Brown shrimp
White shrimp
Crab megalops
Grass shrimp
Silverside minnows
Fathead minnows
Ceriodaphnia
Pin perch
Test Endpoint
96-hour LC50
EC50
N/A
EC50
(fertilization)
EC50
(normal development)
48-hour LC50
48-hour LC50
24-hour LC50
48-hour LC50
Produced Water
Concentration
52% (with seawater)
35% (with DI water)
51%
46%
37%
37%
36%
15%
3% -30%
<2.7% - 17.7%
7.3% -27.2%
24.5% -26.5%
18% -21.5%
26% -30%
13.5%
21%
15%
80%
2.7%
10%
17% (1-day old
sample)
35% (2-day old
sample)
8% (1-day old sample)
11% (2-day old
sample)
11.5%
Reference
Andreason and
Spears, 1983
Cain, undated
Caudle, 1993
Chapman, undated
Heffernan, 1971
Mackin and Conte,
1971
Saueretal., 1992
Spears, 1960

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                                                                                           2-27
priority organics; 51,089 Ibs of priority metals; and 1,054,589,456 Ibs of non-conventionals.  The total
Cook Inlet IGF treatment technology (BAT Options 1 and 2) pollutant loading for the same 46
pollutants is 1,055,042,019 Ibs.  This total loading includes:  926,020 Ibs of conventionals; 50,220 Ibs
of priority organics; 36,334 Ibs of priority metals; and 1,054,029,445 Ibs of non-conventionals.

2.5.1.3   Total Current Requirements Baseline Pollutant Loadings and Removals by the Selected
          BAT Option

          For the current requirements baseline, the total current technology pollutant loading for
produced water is 2,549,142,381 Ibs.  This total loading includes:  3,636,393 Ibs of conventionals;
228,605 Ibs of priority organics; 84,966 Ibs of priority metals; and 2,545,192,417 Ibs of non-
conventionals.  For the selected option (BAT Option 2:  IGF for Cook Inlet and zero discharge for
major deltaic pass dischargers), the pollutant loading for produced water totals 1,055,042,019 Ibs.
This total loading consists of 926,020 Ibs of conventionals; 50,220 Ibs of priority organics; 36,334 Ibs
of priority metals; and 1,054,029,445 Ibs of non-conventionals. For the selected option (BAT
Option 2: zero discharge for major deltaic pass dischargers and IGF  for Cook Inlet), the total pollutant
removal is 1,494,100,362 Ibs. This removal consists of 2,710,373 Ibs of conventionals; 178,385  Ibs of
priority organics; 48,632 Ibs of priority metals; and 1,491,162,972 Ibs of non-conventionals.

2.5.2     Alternative Baseline Dischargers
2.5.2.1   Open Bay Dischargers, Louisiana

          For the 69 discharging open bay outfalls, the total open bay current technology effluent
pollutant loading (49 pollutants) for produced water is 2,578,995,458 Ibs.  This total loading includes:
7,072,298 Ibs of conventionals; 450,458 Ibs of priority organics; 90,535 Ibs of priority metals; and
2,571,382,167 Ibs of non-conventionals. For IGF treatment technology, the total pollutant loading for
the 56 dischargers with discharge rates above 70.5 bpd,  for these same 49 pollutants is 2,572,106,557
Ibs. This total loading includes: ;2,257,566 Ibs of conventionals; 122,031 Ibs of priority organics;
50,604 Ibs of priority metals; and 2,569,676,356 Ibs of non-conventionals.

-------
2-28
2.5.2.2   Individual Permit Applicants, Texas

          For the 82 individual permit applicants, the total current technology pollutant loading (49
pollutants) for produced water is 529,883,014 Ibs. This total loading includes:  1,453,081 Ibs of
conventionals; 92,551 Ibs of priority organics; 18,602 Ibs of priority metals; and 528,318,780 Ibs of
non-conventionals. IGF treatment technology total pollutant loading (for the same 49 pollutants) for the
53 permit applicants with discharge rates above 76.5 bpd is 528,467,618 Ibs.  This total loading
includes:  463,842 Ibs of conventionals; 25,073 Ibs of priority organics; 10,397 Ibs of priority metals;
and 528,467,613 Ibs of non-conventionals.
2.5.2.3   Total Alternative Baseline Dischargers Pollutant Loadings and Removals by the Selected
          BAT Option

          For all four discharge groups in the alternative baseline, the total current technology effluent
pollutant loading for produced water is 5,658,020,853 Ibs. This total loading includes: 12,161,772 Ibs
of,conventionals; 671,614 Ibs of priority organics;  194,103 Ibs of priority metals; and 5,644,893,364
Ibs of non-conventionals.  For the selected option (BAT Option 2: zero discharge for major deltaic
pass discharges, Louisiana open bay dischargers, and Texas individual permit applicants; IGF for Cook
Inlet), the total pollutant loadings are 1,055,042,019 Ibs. This total loadings consists of 926,020 Ibs of
conventionals; 50,220 Ibs of priority organics; 36,334 Ibs of priority metals;  and 1,054,029,445 Ibs of
non-conventionals.  For the selected option (BAT Option 2: zero discharge for major deltaic pass
dischargers, Louisiana open bay dischargers, and Texas individual permit applicants; IGF for Cook
Inlet) the total pollutant removal is 4,602,978,834 Ibs.  This removal consists of 11,235,752 Ibs of
conventionals; 721,394 Ibs of priority organics; 157,769 Ibs of priority metals; and 4,590,863,919 Ibs
of non-conventionals.

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                                                                                         3- 1
  3.  WATER QUALITY COMPLIANCE ASSESSMENTS FOR PRODUCED WATER

3.1      Surface Water Modeling Methodology

3.1.1    Current Requirements Baseline Dischargers

         Compliance of facilities covered by this guideline with the water quality standards of
Louisiana and Alaska is assessed using the current technology and IGF effluent pollutant concentrations
and effluent plume dispersion modeling for produced water.  For Louisiana, state water quality
implementation guidance documents are followed in applying waste load allocation models to calculate
appropriate daily average and daily maximum limitations. Alaska does not require application of a
waste load allocation model; surface water quality modeling is used to project the extent of mixing
zones required to achieve compliance with Alaska water quality standards.

         Water quality assessments are conducted separately for Louisiana major deltaic pass
dischargers and Cook Inlet, Alaska dischargers.  Plume dispersion modeling was performed using the
CORMIX expert system (Version 2.10; Doneker and Jirka,  1993). For main deltaic pass dischargers,
outfall-specific flows are modeled for seven of the eight outfalls (five operators) currently discharging
into the deltaic region of the Mississippi River; insufficient operational and ambient data precluded
analyses for one operator's outfall.  For Cook Inlet operations, outfall-specific flows are modeled for
all eight outfalls currently discharging into Cook Inlet.

3.1.1.1  Major Deltaic Pass Dischargers, Louisiana
         Site-specific ambient and operational model input parameters for major deltaic pass dischar-
gers are presented in Exhibit 3-1. Ambient modeling input parameters for major deltaic pass dischar-
gers are based on site-specific data from discharge locations.  Ambient current speeds, ranging from
0.13 nvVsec to 933.53 nrVsec, are based on major deltaic pass flows and channel geometry.  Major
deltaic pass flows were provided by LDEQ (Hale, 1996).  Ambient depths, ranging from 1 meter to
10 meters, and pass descriptions were provided by BAD.  Ambient density is provided by CORMIX
based on water temperature (John Macauley, EPA, personal communication, May 1996).  Discharge

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configurations simulated for major deltaic pass discharger outfalls are also based on site-specific data
for each outfall provided by BAD.  Effluent flow rates, ranging from 572 bpd to 153,895 bpd, are
presented in Exhibit 2-1.

         For major deltaic pass dischargers, site-specific modeling input included facility-specific
effluent densities.  Effluent densities for each major deltaic pass outfall are based on produced water
densities and salinities obtained for two major deltaic pass facilities from LDEQ permit file DMRs.
Produced water densities for the remaining outfalls are estimated based on their salinity (also obtained
from LDEQ DMRs) and the regression line of effluent density on effluent salinity for the two facilities
mentioned previously (Exhibit 3-2).

Exhibit 3-2. Derivation of Produced Water Densities for Major Deltaic Pass Dischargers
Facility
Outfall
Pass Location
Chloride
(ppm)
Salinity
(ppt)
Density
(kg/m3)
Reported Produced Water Effluent Density
Warren, 1992
Chevron
NA
NA \
Xante Phine
Tante Phine
192,145
97,200
347
176
1,363
1,184
Calculated Values Derived From: Density = (Chlorides - 97,200) * 0.001885 + 1,184
Chevron
Flores & Rucks
North Central
Amoco
Warren, 1995
3229-1-3
2071-004-1
2184-1
3407-001-6 ;
2963-006
North
Southwest
Southwest
Emiline
Tante Phine
84,206
54,335
48,200
47,682
37,200
152
98
87
86
67
1,160
1,103
1,092
1,091
1,071
Source: Welsch, 1996.
         A summary of resulting available dilutions at the edge of 50-foot and 200-foot mixing zones,
based on CORMIX modeling runs for major deltaic pass dischargers and used throughout this WQBA,
                                 t
is presented in Exhibit 3-3. The 50+foot and 200-foot mixing zones are specified in Louisiana state
standards for assessing compliance with marine acute and marine chronic/human health standards,
respectively.

-------
3-4
 Exhibit 3-3.    Summary of CORMIX Modeling Results—Major Deltaic Pass
                Dischargers: Available Dilutions at Specified Mixing Zones
Operator-Outfall
Flores & Rucks
Chevron
Amoco
North Central— 001
-002
—003
Warren
Mixing Zone Dimension
50-foot
15
7
104
307
144
60
84
200-foot
21
112
124
464
188
72
169
3.1.1.2  Alaska Cook Inlet

         Site-specific ambient and operational model input parameters for Cook Inlet dischargers are
presented in Exhibit 3-4. Ambient modeling input parameters for Cook Inlet are based on site-specific
data from Cook Met discharge locations. An ambient density of 1,025 kg/m3 is used,  with ambient
velocities ranging from 2.8 m/sec to 4.0 m/sec.  These data are supplied by a Region X modeling study
for the same outfalls (Schurr, 1986).  Discharge configurations simulated for Cook Inlet outfalls are
also based on site-specific data for each outfall.  Effluent flow rates, ranging from 30 bpd to 126,072
bpd, and outfall configurations are also found in Schurr, 1986.

         Modeling is conducted for each outfall to determine the distance at which Alaska state
standards are achieved.  This distance is used to assess potential impacts.  These results are presented
in Section 3.3.1.2.

3.1.2    Alternative Baseline Dischargers

3.1.2.1  Open Bay Dischargers, Louisiana
         For open bay outfalls (69 using current technology and 56 using IGF), three discharge rate
scenarios are modeled: mean discharge rate by outfall; median discharge rate by outfall (i.e., the

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 3-6	
 discharge rate at which 50% of all outfalls report discharge rates greater or lesses than the median
 discharge rate by outfall); and median discharge rate by volume (i.e., 50% of the total produced water
 volume is discharged at greater or lesser rates than the median discharge rate by volume). The mean
 and both median discharge rates were presented in Exhibit 2-3. The median rate by outfall is useful in
 assessing the proportion or number of outfalls or facilities complying with water quality standards,
 whereas the median rate by volume is useful for assessing the proportion or amount of produced water
 being discharged that is complying with state standards.  The effluent pollutant concentrations used hi
 all of these analyses are those presented previously in Section 2, Exhibit 2-5.

         Input values to CORMIX are derived from published literature and state permit data, except
 for ambient water density, water depth,  and effluent density values. The ambient current speed used is
 5 cm/sec, an average determined from published literature for the Gulf of Mexico (Texas A&M, 1991).
 The discharge configuration simulated for modeling assumes a 5-inch diameter pipe discharging at the
 surface.  These two configuration parameters were determined by responses to the Section 308
 questionnaire  submitted to EPA by coastal operators.

         Open bay ambient density data also are derived from temperature and salinity data in
 published literature (Temple et al., 1977).  A density of 1,005 kg/m3, which is  the same as was used
 for the proposed rule, is used for the  final rule.  The water column is assumed to be uniformly mixed
 because of shallow water depths.

         For  open bay dischargers, produced water effluent density used in the final rule is the same
 as was used for the proposed rule.  The effluent density was determined from temperature and
 chlorides data submitted on state permit DMRs.  The resulting effluent density is 1,020 kg/m3.  As
 noted above, the typical open bay discharger will discharge at the surface.  However, CORMIX
 requires that the discharge port be located in the lower third of the water column and produced waters
 are negatively buoyant.  Therefore, the modeling scenario for modeling is inverted.  The effluent
 density modeled for open bay dischargers is 990 kg/m3, discharged at the bottom.  This resulted in a
positively buoyant discharge stream entering the receiving water from the bottom with the same density
differential as  a negatively buoyant stream at the surface.  Characteristic discharge rates (mean, median
by outfall, and median by volume) used for CORMIX input have been previously discussed.

-------
^	3-7
         Comments on the approach used for the proposed rulemaking indicate that arbitrarily
assigning water depths (e.g., at 1 and 3 meters as was used for proposal) may not accurately portray
the depths for these dischargers.  Because there are only sporadic reliable data on facility-specific
discharge depths, an approach using flow-weighted, average receiving water depths is used for the final
rule.  The flow-weighted depth is determined by identifying receiving waters, then locating oil field
structures and/or respective receiving water depths on NO A A navigational charts.

         Receiving waters are identified from the DOE study of open bay dischargers (USDOE,
1996).  An average depth is then determined for each receiving water that has been identified in the
discharge permit.  The depth assigned to each outfall, based on the receiving water average depth, is
multiplied by the reported outfall flow, and the resultant products summed. This sum is divided by the
                                  I
total flow reported by each state to give a state-wide, flow-weighted depth.  The flow-weighted depth is
determined to be 1.73 meters for Louisiana.  Discharge rates and receiving water depths used for these
flow-weighted depth determinations; were presented in Exhibit 2-3. The input values used for
CORMIX modeling for Louisiana open bay dischargers are summarized in Exhibit 3-5.

         A summary of the resulting available dilutions at the edge of 50-foot and 200-foot mixing
zones for the CORMIX modeling runs for the 69 open bay outfalls in Louisiana is presented in
Exhibit 3-6.  The 50-foot and 200-foot mixing zones are specified in Louisiana state standards for
assessing compliance with marine acute and marine chronic/human health standards, respectively.

3.1.2.2  Individual Permit Applicants,  Texas

          Similar to open bay dischargers in Louisiana, for the individual permit applicants (82 using
current technology and 53 using IGF), three discharge rate scenarios are modeled:  mean discharge rate
by outfall; median discharge rate by outfall; and median discharge rate by volume. The mean and both
median discharge  rates were presented in Exhibit 2-4.  The median rate by outfall is useful in assessing
the proportion or number of outfalls or facilities complying with water quality standards, whereas the
median rate by volume is useful for assessing the proportion or amount of produced water  being
discharged that is  complying with state standards. The effluent pollutant concentrations used in all of
these analyses were presented previously in Section 2, Exhibit 2-5.

-------
                        3-8


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-------
                                                                                           3-9
Exhibit 3-6.    Summary of CORMIX Modeling Results—Open Bay Dischargers,
               Louisiana: Available Dilutions at Specified Mixing Zones

Median, by outfall
Mean
Median, by volume
Mixing Zone Dimension
50-foot
Current
Technology
38a
8.7
6.7
IGF
18"
7.1
6.7
200-foot
Current
Technology
52a
12
8.2
IGF
25b
9.6
8.2
a Available dilutions for 69 current technology effluent outfalls
b Available dilutions for 56 IGF treatment technology effluent outfalls
         Input values to CORMIX are derived from published literature and state permit data.  The
ambient current speed used is 5 cm/sec, an average determined from published literature for the Gulf of
Mexico (Texas A&M, 1991).  The discharge configuration simulated for modeling assumes a surface
discharge from a 5-inch diameter pipe. These two configuration parameters were determined by
responses to the Section 308 questionnaire submitted to EPA by coastal operators.

         Ambient density data used for Texas individual permit  applicants also are derived from
temperature and salinity data in published literature (Temple et al., 1977).  For the proposed
rulemaking, Texas water quality modeling was conducted based on an average of results using both
ambient summer density (1,000 kg/m3) and ambient winter density (1,004 kg/m3) scenarios. These
results and additional modeling for the final rule indicate that no  more than a 3.7%  difference occurs
between the mean and either summer or winter ambient density modeling.  As a result,  only the winter
ambient density was used for the final rulemaking.  The water column is assumed to be uniformly
mixed because of shallow water depths.
         For Texas individual permit applicant dischargers, the produced water effluent density used
in the final rule is the same as was used for the proposed rule. The effluent density was determined
from temperature and chlorides data submitted on state permit DMRs.  However, for Texas, only
chlorides data were available, so the Louisiana temperature data were used.  The resulting effluent
density is 1,031 kg/m3.  Because CORMIX assumes the discharge port is located on the bottom,

-------
3-10	
whereas the typical operational discharge is located at the surface, the density scenario is inverted.  The
effluent density modeled for the permit applicants was 977 kg/m3. This resulted in a positively buoyant
discharge stream entering the receiving water from the bottom, a mirror image of the operational case.
Characteristic statistical flow rates (mean, median by outfall, and median by volume) used for
CORMIX input have been previously discussed.

         Comments on the approach used for the proposed rulemaking indicate that arbitrarily
assigning water depths (e.g., at 1  and 3 meters as was used for proposal)  may not accurately portray
the depths for these dischargers.  Because there are only sporadic reliable data on facility-specific
discharge depths, an approach using flow-weighted, average receiving water depths is used for the final
rule.  The flow-weighted depth is determined by identifying receiving waters, then locating oil field
structures and/or respective receiving water depths on NOAA navigational charts.

         Receiving waters for the 82 discharging permit applicants are identified from the Railroad
Commission of Texas individual permit application intake log.  An average depth is then determined
for each receiving water that has been identified in the permit application. The depth assigned to each
outfall, based on the receiving water  average depth,  is multiplied by the reported outfall flow, and the
resultant products summed.  This sum is divided by the  total flow reported by each state to give a state-
wide, flow-weighted depth.  The flow-weighted depth was determined to  be 1.66 meters for Texas.
Discharge rates and receiving water depths used for these flow-weighted depth determinations were
presented hi Exhibit 2-4. The input values used for CORMIX modeling for Texas individual permit
applicant dischargers are summarized in Exhibit 3-7.

         A summary  of the  resulting available dilutions at the edge of 50-foot, 200-foot, and 400-foot
mixing zones for the CORMIX modeling runs for individual permit applicants in Texas is presented in
Exhibit 3-8.  These dilutions are used throughout this WQBA. The 50-foot, 200-foot, and 400-foot
mixing zones used in this water quality modeling are specified by Texas state standards for marine
acute, marine chronic, and human health standards respectively.

-------
            3-11
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-------
3-12
Exhibit 3-8.
Summary of CORMIX Modeling Results—Individual Permit
Applicants, Texas:  Available Dilutions at Specified Mixing Zones

Median, by outfall
Mean
Median, by volume
Mixing Zone Dimension
50-foot
Current
Technology
457a
67
16
IGF
115b
46
16
200-foot
Current
Technology
680a
94
21
IGF
170"
64
20
400-foot
Current
Technology
1,153"
151
29
IGF
296b
97
28
*  Available dilutions for 82 current technology effluent outfalls,
b  Available dilutions for 53 IGF treatment technology effluent outfalls.
3.2     State Water Quality Standards
3.2.1    Current Requirements Baseline Dischargers
3.2.1.1  Major Deltaic Pass Dischargers, Louisiana
         For major deltaic pass dischargers in Louisiana, waste load allocations and soluble metal
transformations are applied at 50 feet (the acute standard mixing zone) and at 200 feet (the chronic and
human health standards mixing zone). The waste load allocation model uses predicted dilutions and
published state standards to calculate allowable end-of-pipe limitations. Produced water pollutant
concentrations are compared to these end-of-pipe limitations to assess  compliance with state standards.
The state standards used to calculate Louisiana's water quality-based, end-of-pipe limitations are
presented in Exhibit 3-9.  These standards are marine water quality standards. EPA recognizes many
receiving waters covered by this rule are not marine, and marine standards may not protect fresh,
intermediate, or brackish waters. However, the water quality assessment generally uses conservative
assumptions (e.g., choosing certain input for plume dispersion modeling).  Thus, the use of marine
standards, in the larger context, still results in an appropriately balanced water quality compliance
assessment. In addition to water quality standards, Louisiana has performance standards for oil and gas
facilities (see Exhibit 3-9). These performance-based standards must be met prior to any dilution of the
effluent.

-------
                                                                                                        3- 13
Exhibit 3-9. Louisiana Water Quality Standards
Parameter
Benzene
Cadmium
Chromium (tri)°
Chromium (hex)c
Copper
Ethylbenzene
Lead
Nickel
Phenol
Toluene
Zinc
Radium
Chlorides
Oil and grease
TOC
TSS
Surface Water Quality Standards (ag/l)a
Marine Acute
2,700
45.62
515
1,100
4.37
8,760
220
75
580
950
95

Marine Chronic
1,350
10.0
103
50
4.37
4,380
8.5
8.3
290
475
86

Human Health
12.5




8,100


50
46,200


Range of 835-1,600 mg/1 for estuarine water bodies









Oil and Gas
Standards (ug/l)b
12.5




4,380



475

60 pCi/1
10-fold dilution
15 mg/1
50 mg/1
45 mg/1
Source:  Louisiana DEQ, 1996.
a.  To be achieved at the edge of applicable mixing zone.
b.  End-of-pipe performance standard.
c.  Although Louisiana has separate standards for trivalent and hexavalent chromium, the produced water analyte is total
   chromium.  Thus, Louisiana's 12 surface water quality standards cover only 11 of the 49 identified produced water
   pollutants.

-------
3-14	
         In-stream pollutant concentrations are projected for 49 pollutants for the major deltaic pass
dischargers.  Among these 49 pollutants, 2 are conventional pollutants, 13 are toxic pollutants, and 34
are nonconventional pollutants. Louisiana has 12 state water quality standards (aquatic acute, aquatic
chronic, or human health) covering 11 (see footnote c, Exhibit 3-9) of these 49 pollutants (10 toxic
pollutants and 1 nonconventional pollutant).  In addition to state water quality standards, Louisiana has
performance-based effluent standards for oil and gas exploration and production facilities. These
standards are also presented in Exhibit 3-9.  These performance-based standards represent effluent
limitations that must be met prior to any dilution of the effluent.

         In accordance with the Louisiana implementation guidance, the waste load allocation was
calculated in the following manner (LDEQ, 1993). First, as part of the state waste load allocation
model, three metals (copper, lead, and zinc) require calculation of a dissolved fraction to determine the
amount that may be present in the water column.  The calculation of these dissolved fractions is
presented in Exhibit 3-10.  For all other metals and organic pollutants, the dissolved fraction is
assumed to be 1 for the calculations. To calculate the waste load allocation (WLA), each state standard
is divided by the fractional percentage of effluent at the edge of the prescribed mixing zone (1/number
of dilutions predicted by the model) and multiplied by the dissolved fraction appropriate to each
specific pollutant.

         This waste load allocation is then used to calculate the long-term average (LTA) limitations
for each pollutant (1.31 x WLA for acute limits, 0.53 x WLA for chronic limits, and 1.0 x WLA for
human health limits). From these LTA limitations, daily average and daily maximum limitations are
calculated for acute, chronic, and human health standards (1.31 x LTA for acute limits; 3.11 x LTA for
chronic limitations, and 1.0 x LTA for human health daily average and 2.38 x LTA for human health
daily maximum limitations). Thus, for any one pollutant, compliance with as many as six limitations
may apply; both daily average and daily maximum limitations for acute, for chronic, and for human
health standards.  For water quality compliance analyses, daily average and daily maximum limitations
are assessed as end-of-pipe limitations. These limitations are compared to produced water pollutant
concentrations  for both current technology and IGF treatment technology  to assess compliance with
state water quality standards.

-------
                                                                                        3- 15
Exhibit 3-10.  Calculation of the Fraction of Dissolved Metal for Setting State Water Quality Effluent
              Limitations, Louisiana


Metal


Copper
Lead
Zinc


Slope
(m)


-0.72
-0.85
; -0.52
Louisiana Linear Partition
Coefficients


Intercept
(b)
4.86
6.06
5.36

K a
D
13,804
162,181
69,183
  KD = 10" x TSSm, where TSS - 10 mg/1
                       Fraction of Dissolved Metal =
1
                                                                 (KDxTSSxlO-6)
Metal
Copper
Lead
Zinc
Dissolved Fraction
Louisiana
0.878
0.381
0.591
Source: LDEQ, 1993.

-------
3-16	
3.2.1.2  Cook Inlet, Alaska

         Water quality assessments for Cook Inlet are conducted according to state standards for
Alaska (ADEC, 1989; 1994).  The Alaska marine water quality standards for toxics and other harmful
organic and inorganic substances in discharges to waters used for growth and propagation of fish,
shellfish, aquatic life, and wildlife require compliance with EPA water quality criteria or Alaska
drinking water standards, whichever are more stringent.  The water quality standards used for this
analysis are presented in Exhibit 3-11.

         For Cook Inlet, in-stream concentrations are projected for 46 pollutants.  Among these 46
pollutants, 2 are conventional pollutants,  15 are toxic pollutants, and 29 are nonconventional pollutants.
Alaska has state water quality standards (aquatic acute, aquatic chronic or human health) for 12
produced water pollutants (all of which are toxic pollutants), and drinking water standards, with which
Alaska also requires compliance, for 16 of these 46 pollutants (9 of which do not have water quality
standards).

         The approach to assess compliance with state standards for Alaska  fundamentally differs from
that of Louisiana and Texas.  Alaska regulations do not specify spatially-defined mixing zones. Rather,
the extent of the mixing zone needed to achieve compliance with water quality standards is determined
and evaluated for reasonableness. This analysis (i.e., the spatial extent of mixing zones needed for
each outfall to meet all of Alaska's state standards) is provided in this WQBA.

3.2.2    Alternative Baseline Dischargers

3.2.2.1  Open Bay Dischargers, Louisiana

         State water quality standards and the waste load allocation methodology for deriving daily
average and daily maximum limitations for open bay dischargers in Louisiana are the same as those
presented for major deltaic pass dischargers (see Section 3.2.1.1).

-------
Exhibit 3-11.  Alaska Water Quality Standards3
                                                                                                          3-17
Parameter
Aluminum
Anthracene
Antimony
Arsenic
Barium
Benzene
Benzo(a)pyrene
Beryllium
Cadmium
Chlorobenzene
Chromium
Copper
Di-n-butylphthalate
Ethylbenzene
Iron
Lead
Manganese
Mercury
Naphthalene
Nickel
Phenol
Radium-226 and -228
Selenium
Silver
Thallium
Toluene
Xylenes (total)
Zinc
Drinking Water
Standards (/wg/1)
200
; -
6.0
50
2,000
'• 5.0
-
4.0
5.0
,
100
1,000
-
700
300
-
50
100
-
100
-
5 pCi/1 (total)
(5E-6 Mg/1)
50
100
2.0
1,000
10,000
5,000
Federal Water Quality Criteria (tig/1)
Acute
-
-
-
-
-
5,100
-
-
43
-
-
2.9
-
430
-
220
-
-
2,350
75
5,800
-
-
-
-
6,300
-
95
Chronic
-
-
-
-
-
700
-
-
9.3
-
-
-
-
-
-
5.6
-
-
-
8.3
-
-
-
-
-
5,000
-
86
Human Health
-
0.0311
-
1.4
-
710
0.311
-
-
21,000
-
-
12,000
29,000
-
-
-
-
-
100
-
-
-
-
-
424,000
-
-
a.  Alaska state water quality standards for marine waters—growth and propagation of fish, shellfish, aquatic life, and
   wildlife—require that toxic and other deleterious organic and inorganic substances not exceed criteria cited in EPA Quality
   Criteria for Water or Alaska Drinking Water Standards (18 AAC 70.020).

-------
3-18	
3.2.2.2  Individual Permit Applicants, Texas

         For Texas individual permit applicants, waste load allocations and soluble metal trans-
formations, which are similar to those derived for Louisiana, are applied in the analysis of water
quality at 50  feet (the acute standard mixing zone), at 200 feet (the chronic standard mixing zone), and
at 400 feet (the human health standard mixing zone). The methodology for soluble metal trans-
formations is shown in. Exhibit 3-12. The Texas standards used to calculate state water quality
limitations are presented in Exhibit 3-13.

         In-stream pollutant concentrations are projected for 49 pollutants (the same as those identified
for major deltaic pass dischargers) for 82 dischargers identified as potentially discharging produced
water as Texas individual permit applicants.  Texas has 10 state water quality standards covering 11 of
the 49 produced water pollutants (8 toxic pollutants and 3 nonconventional pollutants); the additional
pollutant results from one state standard for cresols while produced water analyses identify both ortho-
and para-cresol.

         In addition to copper, lead, and zinc for which dissolved fractions are calculated for
Louisiana, Texas standards require the calculation of the dissolved fraction of silver.  The waste load
allocation (WLA) is calculated the same as for Louisiana.  The long term average (LTA) limitations are
calculated in  the same manner as Louisiana, but with different multipliers (0.32 x WLA for acute;
0.61 x WLA for chronic; and 0.93 x WLA for human health). The daily average and daily maximum
limitations also are calculated similar to Louisiana, but with different multipliers (1.47 x LTA for daily
average limitations and 3.11 x LTA for daily maximum limitations).  Thus, similar to the case for
Louisiana discharges, for any one pollutant compliance with as many as six limitations may apply (two
limitations, daily average and daily maximum, for  each state standard that, i.e., acute, chronic, or
human health, has been adopted).

-------
	;	3-19

Exhibit 3-12.  Calculation of the Fraction of Dissolved Metal for Setting State Water Quality Effluent
              Limitations, Texas
Metal
Copper
Lead
Zinc
Silver
Slope
(m)
-0.72
I -0.85
-0.52
-0.74
Texas Linear Partition
Coefficients
Partition
Coefficient (Kpo)
70,000
1,150,000
230,000
720,000
V
13,330
162,000
69,500
131,000
  Kp  = Kp0 x TSSm, where TSS = 10 mg/1; as recommended for bays in the Texas Implementation
  Guidance (TNRCC, 1996b).
                             Fraction of Dissolved Metal =   	1	
                                                          1 + (KpXTSSx lO'6)
Metal
Copper
Lead
Zinc
Silver
Dissolved Fraction
Texas
0.882
0.382
0.590
0.433
Exhibit 3-13.   Texas Water Quality Standards
Parameter
Benzene
Cadmium
Chromium (hex)
Copper
Cresols
Lead
Nickel
Silver
Zinc
Chlorides
Water Quality Standards (^g/l)
Marine Acute

45.62
1,100
16.27
i
140
119
2.3
98
Marine Chronic

10.02
50
4.37

5.6
13.2

89
Human Health
208



31,111
3.85



determined per specified stream segments
                       Source:  Texas Water Commission, 1996a.

-------
3-20	
3.3      Summary of Surface Water Quality Modeling

3.3.1    Current Requirements Baseline Dischargers

5.3.1.1  Major Deltaic Pass Dischargers, Louisiana

         The projected dilutions at the edge of the mixing zones for each of the major deltaic pass
outfalls are used as input in the Louisiana waste load allocation model. The results of these outfall-
specific waste load allocation calculations are used to derive the long term average limitations that are
then transformed into daily average and daily maximum limitations and compared to produced water
pollutant concentrations.  A summary of the water quality compliance assessment for daily average
water quality effluent limitations for both current technology effluent and IGF treatment technology
effluent from the seven (of eight) outfalls discharging to Mississippi River major deltaic passes is
presented in Exhibit 3-14. A summary of the water quality compliance assessment for daily maximum
water quality effluent limitations for both current technology and IGF treatment technology effluents
from these outfalls is presented in Exhibit 3-15.

         Results are expressed as water quality exceedance ratios.  These ratios compare the produced
water effluent pollutant concentration to the calculated Louisiana water quality limitations.  (Thus, a
water quality exceedance ratio of "N" indicates the produced water pollutant exceeds the limitation by
a factor of "N.") Only ratios for those concentrations that exceed limitations are indicated.  Detailed
calculations of current technology and IGF treatment technology water quality compliance for these
major deltaic pass  dischargers are presented hi Appendix A for daily average and daily maximum
limitations.

Current Technology

         The current technology level of treatment for major deltaic pass dischargers is evaluated for
exceedances of Louisiana water quality standards.  The five operators (dischargers) evaluated for this
assessment comprise seven outfalls (one operator has three outfalls) in major deltaic passes; lack of
adequate ambient or operational data prevented modeling the eighth outfall and sixth operator.  (For the
purpose of this assessment, the projected water quality exceedances for the operator maintaining three
outfalls are combined and presented as one discharge.) All 5 dischargers (6 outfalls) are projected to

-------
3-21



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    3-22
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                                                                   	3-23
have exceedances of state water quality standards.   For daily average limitations, all 5 dischargers
exceed the human health standard for benzene (6 outfalls) and the copper marine acute standard (5
outfalls); 1 discharger exceeds the marine chronic standards for copper and nickel (1 outfall); and 1 dis-
charger exceeds the toluene marine acute standard (1 outfall).  For daily maximum  limitations, 5
dischargers (5 outfalls) exceed the human health standard for benzene; 2 dischargers (2 outfalls) exceed
the copper marine acute standard; and  1 discharger  (1 outfall) exceeds the copper marine chronic
standard.  Among the 5 dischargers combined, a total of 22 daily average and daily maximum
exceedances are observed for 4 pollutants (benzene, copper, nickel, and toluene).

Improved Gas Flotation Treatment Technology (BAT Option 1)

         Improved gas flotation treatment technology also  was evaluated for exceedances of Louisiana
water quality standards.  For the 5 dischargers (7 outfalls) evaluated, 5 dischargers (5 outfalls) are
projected to exceed state water quality standards for 3 pollutants. For daily average limitations; 2
dischargers (2 outfalls) exceed the human health standard for benzene;  5 dischargers (5 outfalls) exceed
the copper marine acute standard; 1 discharger (1 outfall) exceeds the copper marine chronic standard;
and 1 discharger (1 outfall) exceeds;the nickel marine chronic standard. For daily  maximum
limitations, 1  discharger (1 outfall) exceeds the human health standard for benzene; 2 dischargers (2
outfalls) exceed the copper marine acute standard; 1 discharger (1 outfall) exceeds  the copper marine
chronic standard; and  1 discharger (1 outfall) exceeds the nickel marine chronic standard.  Thus,
among the 5 discharges combined,  a total of 14 daily  average and daily maximum exceedances are
projected.

Zero Discharge (BAT Option 2); the Selected Option

          The selected BAT option requires all dischargers in the coastal subcategory of states adjacent
to the Gulf of Mexico to meet  zero discharge of produced water. Under this option all state water
quality standards would be met due to cessation of discharges.

-------
 3-24	^	
 3.3.1.2  Cook Inlet, Alaska

          Because Alaska state standards do not specify mixing zones for enforcement of the numerical
 standards, results of the Alaska state water quality analyses are presented in Exhibit 3-16 as the distance
 from each facility's discharge point to the point where all of the standards are met.  This distance, for
 the eight outfalls in Cook Inlet, ranges from within 100 meters to 3.5 km for current technology
 effluent and from within 100 meters to 1.0 km for improved gas flotation technology (BAT Option 1),
 the selected BAT option for Cook Inlet.

 3.3.2     Alternative Baseline Dischargers

 3.3.2.1   Open Bay Dischargers, Louisiana

         The projected dilution at the edge of the mixing zone for each of the three modeling scenarios
 (mean discharge rate, median discharge rate by outfall, and median discharge by volume) is used as
 input in the Louisiana waste load allocation model.  The results of these three discharge scenario waste
 load allocations are used to derive the long term average limitations that are then transformed into daily
 average and daily maximum limitations and compared to produced water pollutant concentrations. A
 summary of the water quality compliance assessment for daily average water quality effluent limitations
 for both current technology and IGF treatment technology effluents from Louisiana open bay
 dischargers is presented in Exhibit 3-17. A summary of the water quality compliance assessment for
 daily maximum water quality effluent limitations for both current technology effluent and IGF
 treatment technology effluent from these facilities is presented in Exhibit 3-18.

         Results  are expressed as water quality exceedance ratios. These  ratios compare produced
water effluent pollutant concentration to their daily average and daily maximum water quality effluent
limitations.  Detailed calculations of water  quality compliance for  current technology effluent and IGF
treatment technology effluent for these open bay dischargers are presented in Appendix B, for both
daily average and daily maximum limitations.

-------
                                                                                      3-25
Exhibit 3-16.   Results of CORMIX Modeling for Alaska Produced Water Discharges: Distance to
              Achieve Compliance with Alaska Standards
Operator
Marathon
Amoco
Shell Western
Marathon
Unocal
Unocal
Unocal
Phillips

Marathon
Amoco
Shell Western
Marathon
Unocal
Unocal
Unocal
Phillips
Facility
Trading Bay
Dillon
East Foreland
Granite Point
Baker
Anna
Bruce
Tyonek

Trading Bay
Dillon
East Foreland
Granite Point
Baker
Anna
Bruce
Tyonek
Discharge
Rate (bpd)
129,468
3,116
. 1,700
929
924
919
199
30

129,468
3,116
, 1,700
929
924
919
199
30
Current Technology Effluent
Distance to Compliance (m)
Drinking
Water
< 2,900
<100
<400
<500
<100
<100
<100
<100
Acute
<800
<100
<400
<400
<100
<100
<100
<100
Chronic
<900
<100
<400
<400
<100
<100
<100
<100
Human
Health
<3,500
<100
<400
<500
<100
<100
<100
<100
IGF Treatment Technology Effluent
Distance to Compliance (m)
BAT Option 2, the Selected Option
Drinking
Water
< 1,000
<100
<400
<400
<100
<100
<100
<100
Acute
<700
<100
<400
<400
<100
<100
<100
<100
Chronic
<700
<100
<400
<400
<100
<100
<100
<100
Human
Health
<900
<100
<400
<400
<100
<100
<100
<100

-------
3-26	

Exhibit 3-17.   Open Bay Dischargers, Louisiana Summary of Daily Average Water Quality
                 Exceedance Ratios60
Pollutant

Mean Discharge Rate,
Flow-Wtd depth
Acute Chronic
Current Technolog
Benzene
Cadmium
Chloridesw
Chromium (3+)
Chromium (6+)
Copper
Ethylbenzene
Lead
Nickel
Phenol
Toluene
Zinc
Subtotals
:
i



13.0




1.2


IGF Treatn
Benzene
Cadmium
Chlorides*'
Chromium (3+)
Chromium (6+)
Copper
Ethylbenzene
Lead
Nickel
Phenol
Toluene
Zinc
Subtotals





16.0











5.7

3.9
2.2

1.1


ent Techn





7.1


2.7




Human
Health
Median Discharge Rate
by Outfall,
Flow-Wtd depth
Acute
y Level of Treatm
34.7











7





3.0







ology Level of Tre
10.2








1.1


5





6.3







Chronic
ent vs Dai





1.3







atment vs





2.7


1.0




Human
Health
Median Discharge Rate by
Volume,
Flow-Wtd depth
Acute
y Average Limitati
8.0











3





16.9




1.6
1.0

Chronic
»ns





8.3

5.7
3.2

1.6


Daily Average Limitations
3.9











4





16.9












8.3


3.2




Human
Health

50.7








1.8


9

12.0








1.3


5
 8 Water quality exceedance ratio = effluent concentration/daily average (or maximum) limitation, as derived from LA WQ standards
  and waste load allocations.
 b The current technology and IGF treatment technology chlorides concentration (57,400 mg/1) exceeds the acceptable range of
  chlorides by a factor of 35 to 69.

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                                                                                                        3-27
Exhibit 3-18.   Open Bay Dischargers, Louisiana Summary of Daily Maximum Water Quality
                 Exceedance Ratios00
Pollutant

Mean Discharge Rate,
Fl-Wtd depth
Acute
Current
Benzene
Cadmium
Chlorides**
Chromium (3+)
Chromium (6+)
Copper
Ethylbenzene
Lead
Nickel
Phenol
Toluene
Zinc
Subtotals





5.5







IGF Treatm
Benzene
Cadmium
Chlorides*'
Chromium (3+)
Chromium (6+)
Copper
Ethylbenzene
Lead
Nickel
Phenol
Toluene
Zinc
Subtotals





6.7







Chronic
Technology





2.4

1.6

;



ent Techno
'




3.0
;

1.1




Human
Health
Median Discharge Rate
by Outfall
Fl-Wtd depth
Acute
' Level of Treatme
14.6











4





1.3







logy Level of Trea
4.3











. 4





2.7







Chronic
nt vs Daily













tment vs Ds





1.2







Human
Health
Median Discharge Rate by
Volume,
Fl-Wtd depth
Acute
Maximum Limitat
3.4











2





7.1





1.0

ily Maximum Lin
1.6











3





7.1







Chronic
ions





3.5

2.4
1.3




u'tations





3.5


1.3




Human
Health

21.3











6

5.0











4
a Water quality exceedance ratio = effluent concentration/daily average (or maximum) limitation, as derived from LA WQ standards
  and waste load allocations.             '
b The current technology and IGF treatment technology chlorides concentration (57,400 mg/1) exceeds the acceptable range of
  chlorides by a factor of 35 to 69.

-------
3-28	
Current Technology

         The current technology level of treatment is evaluated for exceedances of Louisiana water
quality standards.  At the mean discharge rate (4,780 bpd), a combined total of 11 daily average and
daily maximum exceedances of state water quality standards for 5 pollutants is projected.  Discharges
of produced water at 18 of the 69 outfalls equal or exceed the mean discharge rate, and thus are
projected to equal or exceed the water quality exceedances projected at the mean discharge rate.  For
daily average limitations each of these 18 outfalls are projected to exceed 7 limitations; the human
health standard for benzene; the copper marine acute standard;  copper marine chronic standard; lead
marine chronic standard; nickel marine chronic standard; the toluene marine acute standard; and the
toluene marine chronic standard.  For daily maximum limitations, each of these 18 outfalls are
projected to exceed 4 limitations; the human health standard for benzene; the copper marine acute
standard; the copper marine chronic standard;  and the lead marine chronic standard.

         For the median discharge rate (1,680 bpd) by outfall (i.e., the rate at which half of the
outfalls discharge at a lower rate and half at a higher rate) 35 of the 69 outfalls  are projected to exceed
state standards with a total of 5 daily average and daily maximum exceedances for 2 pollutants.  For
daily average limitations, each of these 35 outfalls are projected to exceed 3 limitations; the human
health standard for benzene; the copper marine acute standard;  and copper marine chronic standard.
For daily maximum limitations, each of these 35 outfalls are projected to exceed 2 limitations; the
human health standard for benzene and the copper marine acute standard.

         For the median discharge rate (13,351 bpd) by volume (i.e, the rate above and below which
half of the total open bay discharge volume of produced water is discharged), 8 of the 69 outfalls are
projected to exceed state standards with a total of 15 daily average and daily maximum exceedances for
7 pollutants. For daily average limitations each of these 8 outfalls are projected to exceed 9 limitations;
theihuman health standard for benzene; the copper marine acute standard; copper marine chronic
standard; lead marine chronic standard; nickel marine chronic standard; the toluene marine acute
Standard; toluene marine chronic standard; the human health standard for phenol; and the zinc marine
acute standard.  For daily maximum limitations each of these 8 outfalls are projected to exceed 6
limitations;  the human health standard for benzene; the copper  marine acute standard; the copper
marine chronic standard; lead marine chronic standard; nickel marine chronic standard; and the zinc
marine acute standard.

-------
                                                                                          3-29
IGF Treatment Technology (BAT Option 1)

         Improved gas flotation treatment technology was also a considered but not selected for this
final rule. This level of treatment is also evaluated for exceedances of Louisiana water quality
standards. At the mean discharge rate (5,885 bpd), a combined total of 9 daily average and daily
maximum exceedances of state water quality standards for 4 pollutants is projected. Discharges of
produced water at 16 of the 56 outfalls are projected to equal or exceed  the mean discharge rate. For
daily average limitations, each of these 16 outfalls are projected to exceed 5 limitations; the human
health standard for benzene; the copper marine acute standard; copper marine chronic standard; nickel
marine chronic standard; and phenol human health standard.  For daily maximum limitations, each of
these 16 outfalls are projected to exceed 4 limitations; the human health standard for benzene; the
copper marine acute standard; the copper marine chronic standard; and nickel marine chronic standard.

         For the median discharge rate (2,955 bpd) by outfall, 28 of the 56 outfalls are projected to
exceed state water quality standards with a combined total of 7 daily average and daily  maximum
exceedances for  3 pollutants. For daily average limitations, each of these 28 outfalls are projected to
exceed 4 limitations; the human health standard for benzene; the copper marine acute standard; copper
marine chronic standard; and nickel marine chronic standard.  For daily maximum limitations each of
these 28 outfalls are projected to exceed 3 limitations; the human health standard for benzene; copper
marine acute standard; and copper marine chronic standard.
         For the median discharge rate (13,375 bpd) by volume, 8 of the 56 outfalls are projected to
exceed state water quality standards with a combined total of 9 daily average and daily maximum
exceedances for 4 pollutants. For daily average limitations, each of these 8 outfalls are projected to
exceed 5 limitations; human health standards for benzene and for phenol; copper marine acute and
marine chronic standards; and nickel marine chronic standard.  For daily maximum limitations, each of
these 8 outfalls are projected to exceed 4 limitations; the human health standard for benzene; copper
marine acute standard; copper marine chronic standard; and nickel marine chronic standard.

-------
3-30	
Zero Discharge (BAT Option 2); the Selected Option

         The selected BAT option (zero discharge) requires all facilities in the coastal subcategory of
states adjacent to the Gulf of Mexico to meet zero discharge of produced water.  Under this option all
state water quality standards would be met due to cessation of discharges.

3.3.2.2  Individual Permit Applicants, Texas

         The projected dilutions at the edge of the mixing zones for each of the three modeling
scenarios (mean discharge rate, median discharge rate by permit applicant,  and mean discharge by
volume) is used as input in the Texas waste load allocation model. The results of these discharge
scenario waste load allocations are used to derive the long term average limitations that are then trans-
formed into daily average and daily maximum limitations and compared to produced water pollutant
concentrations. A summary of the water quality compliance assessment for daily average water quality
effluent limitations for both current technology and IGF treatment technology effluents from 82 Texas
individual permit applicant dischargers is presented in Exhibit 3-19.  A summary of the water quality
compliance assessment for daily maximum water quality effluent limitations for both current technology
effluent and IGF treatment technology effluent from these facilities is presented in Exhibit  3-20.

         Results are expressed as water quality exceedance ratios.  These ratios compare the produced
water effluent pollutant concentration to the water quality effluent limitation.  Detailed calculations of
water quality compliance for daily average and daily maximum limitations,  for both current technology
effluent and IGF treatment technology effluent, are presented in Appendix C for these Texas individual
permit applicant dischargers.

Current Technology

         The current technology level of treatment for Texas individual permit applicant dischargers is
evaluated for exceedances of state water quality standards. At the mean discharge rate (827 bpd), 18 of
the 82 dischargers are projected to exceed one state water quality standard for one daily average
limitation:  the silver marine acute standard. For daily maximum limitations, no exceedances  are
projected.

-------
                                                                                                3-31
Exhibit 3-19.   Individual Permit Applicants, Texas Summary of Daily Average Water Quality
                Exceedance Ratios(a>
Pollutant

Mean Discharge Rate,
Flow-Wtd depth
Acute
Currei
Benzene
Cadmium
Chromium
Copper
Cresols
Lead
Nickel
Silver
Zinc
Subtotals







2.1


IGF Treat
Benzene
Cadmium
Chromium
Copper
Cresols
Lead
Nickel
Silver
Zinc
Subtotals







7.2


Chronic
it Technolog






r



ment Techn


•


1



>
Human
Health
Median Discharge Rate
by Applicant,
Flow-Wtd depth
Acute
•y Level of Treatm









1










ology Level of Tres









1







2.9


Chronic
ent vs Daily










itment vs D










Human
Health
Median Discharge Rate,
by Volume,
Flow-Wtd depth
Acute
Average Limitati









0



1.7



9.0


ally Average Limi









1



1.7



21


Chronic
ons



2.5

2.6




tations



2.6






Human
Health






1.8



5










3
  Water quality exceedance ratio = effluent concentration/daily average (or maximum) limitation, as derived from Texas
  standards and waste load allocations.

-------
3-32
Exhibit 3-20.   Individual Permit Applicants, Texas Summary of Daily Maximum Water Quality
                Exceedance Ratios00
Pollutant
Mean Discharge Rate,
Flow-Wtd depth
Acute
Current
Benzene
Cadmium
Chromium
Copper
Cresols
Lead
Nickel
Silver
Zinc
Subtotals










IGF Treatn
Benzene
Cadmium
Chromium
Copper
Cresols
Lead
Nickel
Silver
Zinc
Subtotals







3.4


Chronic
Technolog;










nent Techno










Human
Health
Median Discharge Rate
by Applicant,
Flow-Wtd depth
Acute
r Level of Treatme









0










logy Level of Trea









1







1.4


Chronic
nt vs Daily










tment vs Da










Human
Health
Median Discharge Rate
by Volume
Flow-Wtd depth
Acute
Maximum Limitat









0







4.2


ily Maximum Lira









1







9.7


Chronic
ions



1.2

1.2




litations



1.3






Human
Health










3










2
  Water quality exceedance ratio = effluent concentration/daily average (or maximum) limitation, as derived from Texas
  standards and waste load allocations.

-------
	3-33
         For the median discharge rate (163 bpd) by individual permit applicant outfalls, there are no
exceedances projected for the 82 dischargers for the 11 pollutants for which Texas has adopted
standards.

         For the median discharge rate (3,714 bpd) by volume, 6 of the 82 dischargers are projected
to exceed state water quality standards with a combined total of 8 daily average and daily maximum
exceedances for 3 pollutants. For daily average limitations, each of these 6 dischargers are projected to
exceed 5 limitations; the copper marine acute standard; copper marine chronic standard; lead marine
chronic standard; lead human health standard; and silver marine acute standard.  For daily maximum
limitations, each of these 6 dischargers are projected to exceed 3 limitations; the copper marine chronic
standard; lead marine chronic standard; and silver marine acute standard.

Improved Gas Flotation, (BAT Option 1)

         Improved gas flotation treatment technology is also evaluated for exceedances of Texas water
quality standards.  At the mean discharge rate (1,265 bpd), a combined total of 2 daily average and
daily maximum exceedances of state water quality standards for 1  pollutant is projected.  Discharge of
produced water at 16 of the 53 dischargers is projected to equal or exceed the mean discharge rate.
For daily average limitations, each of these 16 dischargers are projected to exceed 1  limitation; the
silver marine acute standard.  For daily maximum limitations each of these 16 dischargers are projected
to exceed 1  limitation; the silver marine acute standard.

         For the median discharge rate (443 bpd) by individual permit applicant, 26 of the 53
dischargers are projected to exceed state water quality standards with a combined total of 2 daily
average and daily maximum exceedances for 1 pollutant.  For daily average limitations, each of these
26 dischargers are projected to exceed 1 limitation; the silver marine acute standard. For daily
maximum limitations, each of these 16 dischargers are projected to exceed 1 limitation; also the silver
marine acute standard.

         For the median discharge rate (3,749 bpd) by volume, 6 of the 53 dischargers are projected
to exceed state water quality standards with a combined total of 5 daily average and daily maximum
exceedances for  2 pollutants.  For daily average limitations, each of these 6 dischargers are projected to
exceed 3 limitations; the copper marine  acute standard; copper marine chronic standard;  and silver

-------
3-34	
marine acute standard. For daily maximum limitations, each of these 6 dischargers are projected to
exceed 2 limitations; the copper marine chronic standard; and silver marine acute standard.

Zero Discharge (BAT Option 2); the Selected Option

         The selected BAT option (zero discharge) requires all facilities in the coastal subcategory of
states adjacent to the Gulf of Mexico to meet zero discharge of produced water.  Under this option all
state water quality standards would be met due to cessation of discharges.

3.4     Nonqualified Surface Water Quality Benefits

3.4.1    Current Requirements Baseline Dischargers

3,4.1.1  Major Deltaic Pass Dischargers, Louisiana

         In addition to the quantified state water quality benefits projected for major deltaic pass
dischargers in Louisiana as a  result of selecting the zero discharge option, EPA's selection of the zero
discharge option for the final rule also provides for significant, but nonquantified, water quality
benefits. These nonquantified benefits result from EPA's regulation of produced water pollutants other
than the 11 pollutants in Louisiana for which state water quality standards have been adopted.  Of the
total annual pollutant loading of 1.493 billion pounds from major deltaic pass dischargers, pollutants
other than chlorides (for which major deltaic pass operators are projected to exceed the state water
quality standard by a factor of 35 to 69) amounted to 87,764,126 pounds.  The 11 pollutants covered
by Louisiana standards account for only 2.3 % of this latter amount.  By adopting zero discharge as
BAT, EPA not only eliminates water quality exceedances for the 11  pollutants that have standards
adopted, but EPA also eliminates any potential water quality/water body impairment due to the 2
conventional, 3 toxic, and 33 nonconventional pollutants (representing 97.7% of the produced water
pollutant load,  excluding chloride) for which Louisiana has no water quality standards.

-------
 	I	3-35
 3.4.2     Alternative Requirements Baseline Dischargers

 3.4.2.1   Open Bay Dischargers, Louisiana

          Similar to major deltaic pass discharges, selecting the zero discharge option for the final rule
 also provides for significant, but nonqualified, water quality benefits in addition to the quantified state
 water quality benefits projected for open bay dischargers.  These benefits result from EPA's regulation
 of produced water pollutants other than the 11 pollutants in Louisiana for which state water quality
 standards have been adopted. In the case of the 69 open bay dischargers in Louisiana, an estimated
 total annual pollutant loading of 2.579 billion pounds is projected.  For pollutants other than chlorides
 (for which open bay dischargers are projected to exceed the state water quality standard by a factor of
 35 to 69), the loading amounts to 156,859,881 pounds.  Pollutants from open bay dischargers covered
 by Louisiana standards account for only 4.8% of this amount.  By adopting zero discharge as BAT,
 EPA not only eliminates water quality  exceedances for the 11 pollutants that have standards adopted,
 but EPA also eliminates any potential water quality/water body impairment due to the 2 conventional, 3
 toxic, and 33 nonconventional pollutants  (representing 95.2% of the produced water pollutant load,
 excluding chlorides) for which Louisiana has no water quality standards.

 3.4.2.2   Individual Permit Applicants, Texas
         Also similar to major deltaic pass dischargers and open bay dischargers in Louisiana, in
addition to quantified state water quality benefits, selecting the zero discharge option for the final rule
also provides for significant, but nbnquantified, water quality benefits. These nonquantified benefits
result from EPA's regulation of produced water pollutants other than the 11 pollutants in Texas for
which state water quality standards have been adopted.  Thus, of the total pollutant loading of 530
million pounds discharged by individual permit applicants, pollutants other than chlorides amounted to
32,228,590 pounds.  The 11 pollutants covered by Texas standards account for only 0.2% of this latter
amount.  By adopting zero discharge as BAT, EPA not only eliminates water quality exceedances for
the 11 pollutants that have standards adopted, but EPA also eliminates any potential water quality/water
body impairment due to the 2 conventional, 5 toxic, and 31 nonconventional pollutants (representing
99.8% of the produced water pollutant load, excluding chlorides) for which Texas has no water quality
                                i
standards.

-------

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                                                                                         4- 1
                 4. WATER QUALITY COMPLIANCE ASSESSMENTS
                         FOR COOK INLET DRILLING WASTE
         Cook Inlet, Alaska is the:only coastal area in which the discharge of drilling fluids and drill
cuttings are currently authorized. For the final effluent guidelines, EPA developed two options for
consideration: the selected Option 1 (BPT; the current technology), and Option 2 (zero discharge;  not
selected for Cook Inlet). This WQBA has included the following water quality assessment for drilling
fluids and cuttings discharges in Cook Inlet.

4.1      Characterization of Drilling Discharges

         The pollutant concentrations for drilling fluids and drill cuttings, the most significant waste
stream from drilling operations,  are provided by EPA and are presented in Exhibit 4-1.  These
concentration data are presented and discussed in detail in the Development Document for this final
rule (EPA, 1996a).  Based on this chemical characterization, the total Cook Inlet current technology
pollutant loading for drilling fluids is 172,383,892 Ibs. This total  loading includes 164,211,822 Ibs of
conventionals; 34.1 Ibs of priority organics;  29,603.7 Ibs of priority metals; and 8,142,433 Ibs of non-
conventionals (EPA, 1996a).

4.2     Dilution Modeling
         Modeling of drilling fluid discharges was not conducted as part of this WQBA. The
modeling results used for this water quality assessment of Cook Inlet discharges are from dilution
modeling conducted for EPA Region X for the issuance of an NPDES general permit for Cook Inlet
operations.  The modeling was conducted as part of the Ocean Discharge Criteria Evaluation
(TetraTech, 1994) using the Offshore Operator's Committee  (OOC) Mud Discharge Model (version
1.0; Brandsma et al., 1983). The results of the modeling are summarized in Exhibit 4-2.

-------
4-2
 Exhibit 4-1.  Pollutant Concentrations in Drilling Fluid Effluent
Pollutant
Metals
Cadmium
Mercury
Aluminum
Antimony
Arsenic
Barium
Beryllium
Chromium
Copper
Iron
Lead
Nickel
Selenium
Silver
Thallium
Tin
Titanium
Zinc
Organics
Naphthalene
Fluorene
Phenanthrene
Alkylated benzenes
Alkylated naphthalenes
Alkylated fluorenes
Alkylated phenenthrenes
Total biphenyls
Total dibenzothiophenes
Average Concentration in
Drilling Waste
dbs/MM Ibs dry mud)
1.1
0.1
9,069.9
5.7
7.1
120,000
0.7
240
18.7
15,344.3
35.1
13.5
1.1
0.7
1.2
14.6
87.5
200.5
nbs/bbl mud)
0.0000035
0.0000563
0.0000084
0.0021017
0.0000344
0.0001218
0.0000143
0.0001360
0.0000004
Average Concentration n
Drilling Effluent
(mg/I)"

0.35
0.03
2,920
1.84
2.29
38,632
0.23
77.26
6.02
4,940
I 1 .30
4.35
0.35
0.23
0.39
4.70
28.17
64.55

0.010
0.161
0.024
6.00
0.098
0.348
0.041
0.388
0.001
a.  Metals calculated as: Cone./1,000,000 Ib dry wgt. * 454,000 Cmg/Ib) * 0.7091 flb dry mud/I)
    Organic pollutants calculated as:  Cone.  * 454,000 fmg/lb)/I59 fl/bbl)
Source: EPA, 1996a.

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                                                                                        4-3
Exhibit 4-2. Summary of OOC Model Results from Region 10 Permit Development
Current
Speed
(cm/sec)
2
10
30
100
150
Number of Dilutions at Edge of 100-m Mixing Zone
1, 000 bph/40m depth
Solids
2,516
1,039
3,957
3,995
4,025
Dissolved
1,600
1,012
886
6,024
6,601
750 bph/20 m depth
Solids
—
1,329
1,252
4,810
—
Dissolved
—
747
700
7,143
—
500 bph/10 m depth
Solids
—
3,323
2,126
—
—
Dissolved
—
420
269
—
—
Source: TetraTech, 1994.
         Because drilling fluid dispersion had been found to be dependent to a large degree on water
                              I
depth, modeling was conducted for three depth ranges. These ranges are;  40 to 300 meters; 20 to 40
meters; and 10 to 20 meters.  For the 40 to 300 meter water depth range, discharge rates of 1,000
barrels per hour (bph; the maximum allowable rate under the Region X permit for this depth) and 500
bph were modeled for current speeds from 2 to 150 cm/sec. For the 20 to 40 meter water depth range,
discharge rates of 750 bph (the maximum allowable rate under the Region X permit for this depth) and
500 bph were modeled for current speeds from 10 to 150 cm/sec.  For the 10 to 20 meter water depth
range, discharge rates of 500 bph (the maximum allowable rate under the Region X permit for this
depth) and 250 bph were modeled for current speeds  from 2 to 30 cm/sec. Discharges are prohibited
in waters between the shore and the 5 meter isobath.

4.3      Water Quality Analysis, Cook Inlet Drilling Discharges
         Alaska water quality standards do not specify spatially-defined mixing zones.  However, in
the development of the general NPDES permit for Cook Inlet, Region X performed a Clean Water Act
Section 403 Ocean Discharge Criteria Evaluation (ODCE).  Region X's approach for the general
permit, therefore, uses modeling to predict the dilutions of drilling fluids discharges at the edge of the

-------
4-4	
 100-meter mixing zone specified under Section 403 for a discharge of 1  hour duration. Eight modeling
scenarios were used to assess compliance with marine water quality criteria.

          The list of drilling  fluids pollutants and their concentrations used in this Region X water
quality analysis are not the same as those used for the final coastal rule.  Region X used a list of eight
priority pollutant metals (arsenic, barium, cadmium, chromium, copper, lead, mercury, and zinc).
Pollutant concentrations used by Region  X are provided in Table 2-1 of the ODCE (TetraTech,  1994).
An assessment of the potential for organic compounds to exceed water quality criteria was not possible
with the exception of naphthalene due to a  lack of data on such compounds in drilling fluids and lack of
water quality criteria for chemicals that were detected in drilling fluids.  Naphthalene was shown to
have little potential to exceed acute water quality criteria.

          Results of this modeling indicated that among the eight priority pollutant metals examined, all
except copper and zinc were projected to be below acute water quality criteria at the  edge of the mixing
zone; chromium exceeded its criterion in two of the eight modeling scenarios. (Region X did not
assess  chronic water quality criteria because drilling  fluid discharges are intermittent  and generally
brief in duration, i.e., on  the order of hours.)

          Region X's review of this ODCE assessment resulted in the determination that drilling fluids
discharges will not cause exceedances of marine water quality criteria at the edge of the mixing  zone.
This determination is based on the conservative nature of the analyses, primarily based on the method
used to measure drilling fluid pollutant concentrations versus those that should be used for water quality
compliance assessments.  Whereas total recoverable metals is the recommended analytical methodology
(UFA,  1992b; the Toxic Rule, 57 FR 60865: as cited in TetraTech, 1994) for determining effluent
pollutant levels for water quality assessments, the method used to analyze for drilling fluids metals was
a total  methods protocol.  Total metals analyses use a more rigorous sample digestion procedure and
will result in higher measured pollutant concentrations than a total recoverable metals procedure.

          In view of the uncertainties of this analyses, the Region X ODCE anticipated the requirement
for total and total recoverable metal analyses and that the compliance of metals with water quality
.standards will  be a subject of review during permit reissuance.

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	,	      4-5
         The selected option for drilling fluids and cuttings (Option 1) imposes BAT limitations that
are achieved under current BPT practice.  Because there are no technology-based pollutant reductions,
there are no quantified benefits that are attibuted to these regulations.

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                                                                                        5- 1
            5. POPULATIONS AND RESOURCES EXPOSED TO COASTAL
                           PRODUCED WATER DISCHARGES
      Analyses of populations potentially exposed to produced water discharges from coastal oil and
gas facilities were performed to conduct exposure assessments to support the risk assessment presented
in Section 6 of this WQBA. Methodology to conduct environmental health risk assessments includes
exposure from ingestion of contaminated foods.  Because produced water outfalls are located in areas
that are important fishing areas, exposure by ingestion of contaminated seafood is of concern.  To
assess these potential risks, information on populations at risk as well as consumption rates must be
determined. Work performed by UtS. Fish and Wildlife Service (USFWS), Galveston Bay National
Estuary Program (GBNEP; Brooks et al., 1992) and USDOE (Steimle and Associates,  1995) provide
the population data and consumption rates for this risk assessment. The GBNEP study also determined
cumulative risk potentials at each of four Galveston Bay sampling sites, which demonstrated
contamination by several metals and PAHs found in coastal oil and gas-derived produced water.
                                [
5.1   Recreational Anglers

      Demographic data from the USFWS are used to identify the total population of recreational,
licensed fishermen in coastal Gulf of Mexico (USFWS 1993a; 1993b).  The GBNEP study indicated the
high-rate seafood consumer is estimated to be at the 95th percentile of all recreational fishermen.  For
this WQBA, the high-rate consumer population is estimated as the 95th percentile ± 5%, or 10% of the
total licensed recreational anglers. Therefore, the average-rate consumer population is estimated at
90% of the total recreational, licensed anglers.
     The population of anglers used in the exposure assessment is based on the total number of
licensed anglers adjusted by two factors, one of which resulted in response to late comments received
from the Department of Energy (USDOE) and the Office of Management and Budget (OMB). These
adjustment factors include one for the percentage of saltwater anglers who only fish in marine (i.e.,
offshore) waters; the second factor adjusts for the percentage of the population living in coastal
counties. To adjust the total population of anglers for saltwater anglers who only fish offshore, the
WQBA used data presented in Steimle and Associates (1995), who reported that 60% of the licensed
recreational anglers in  Louisiana and 48% of the licensed recreational anglers in Texas fished in coastal

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5-2	
(inshore) waters of the Gulf of Mexico. Additional data used in the WQBA from Steimle and
Associates (1995) are the average numbers of seafood consumers in fishermen's households which are
3.3 and 2.9 for Louisiana and Texas respectively.

      In response to USDOE and OMB, the WQBA also adjusts the total population of anglers by the
percentage of the state population that resides in coastal counties.  Coastal counties are defined as those
counties within 65 miles of the shoreline.  This fraction of the state population is also applied to the
total number of licensed anglers to determine the subset of coastal anglers.  The Louisiana parishes and
Texas counties and their populations used for this analysis are presented in Exhibit 5-1.

      These estimates of seafood consumer populations and percent coastal anglers are used in this
WQBA to better quantify the exposed population from the recreational fishery by first dividing the total
population into two consumer groups (high-rate consumers and average-rate consumers) by multiplying
the total population of recreational licensed fishermen by the respective population percentages (10%
and 90%). The next step determines the number of coastal fishermen by multiplying each consumer
group portion by the respective state percentage of inshore fishermen and the fraction of the state
population located in coastal counties. The estimated total population at risk for each consumer group
in each state is then determined by multiplying this number of coastal fishermen by the number of
seafood consumers per household in the respective states (Exhibits 5-2 and 5-3).

5.1.1 Louisiana

      The USFWS data indicate  there is a total of 768,900 recreational licensed anglers in the state  of
Louisiana. There are 76,890 recreational anglers  in Louisiana who are described as high-rate
consumers (10%  of all recreational anglers in Louisiana; USFWS, 1993a).  These recreational
fishermen, and members of their households, are assumed to consume much of their catch. For the
risk assessment presented hi Section 6, these individuals are assumed to consume seafood products at
the high-rate consumption level of 147.3 g/d (see Section 5.2.1).  There are 692,010 recreational
anglers in Louisiana who are described as average-rate consumers (90% of all recreational anglers in
Louisiana; USFWS, 1993a).  For the risk assessment presented in Section 6, these individuals are
assumed to consume seafood products at the average-rate consumption level of 15 g/day (see
Section 5.2.1).

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                                                                                      5-3
Exhibit 5-1.  Demographics for Texas and Louisiana Coastal Counties and Parishes
Texas
Aransas
Bee
Brazoria
Brooks
Calhoun
Cameron
Chambers
Colorado
Dewitt
Duval
Ft. Bend
Galveston
Goliad
Hardin
Harris
Hidalgo
Jackson
Jefferson
Jim Hogg
Jim Wells
Kenedy
Kleberg
Lavaca
Liberty
Live Oak
Matagorda
Montgomery
Newton
Nueces
Orange
Polk
Refugio
San Jacinto
San Patricio
Starr
Tyler
Victoria
Wharton
Willacy
County Population
19,054
24,907
: 211,171
7,844
19,395
282,561
i 20,930
18,084
17,975
12,685
j 268,396
232,373
6,154
43,749
3,044,569
424,009
12,613
247,457
5,010
38,125
: 422
29,407
18,752
55,162
9,974
38,461
209,856
13,417
303,979
83,525
33,737
7,538
17,548
60,249
45,444
17,196
77,494
39,626
; 18,043
Total Coastal , 6,036,891
Total State ,17,950,285
Percent Coastal 34%
Louisiana
Acadia
Allen
Ascension
Assumption
Beauregard
Calcasieu
Cameron
Iberia
Iberville
Jefferson Davis
Lafayette
LaFourche
Livingston
Plaquemines
Pointe Coupee
St. Bernard
St. Charles
St. James
St. John Baptist
St. Landry
St. Martin
St. Mary
St. Tammany
Tangipahoa
Terrebonne
Vermilion
Washington
W. Baton Rouge
Parish Population
56,579
21,485
61,878
22,681
31,393
173,191
9,146
70,503
31,096
30,972
176,266
87,045
74,606
25,569
22,534
67,090
45,066
20,700
41,675
80,275
44,574
57,686
160,331
87,778
101,535
50,321
42,320
19,772
Total Coastal 1,714,067
Total State 4,298,689
Percent Coastal 40%
 Source: CACI, 1993.

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5-4	
Exhibit 5-2. Recreational Angler Characterization for Louisiana
Consumer
High-rate Consumers
Average-rate Consumers
Entire State
Recreational Anglers
Number"
76,890
692,010
768,900
% of State
Anglers
10%
90%

% Coastal
Residents'"
40%
40%

% Inshore
Anglers0
60%
60%

Average
Persons per
Household11
3.3
3.3

Estimated
Exposed
Population11
60,897
548,072
608,969
• Source: USFWS, 1993a.
b Source: CACI, 1993.
c Steimle and Associates, 1995.
d Recreational anglers and household seafood consumers.
Exhibit 5-3. Recreational Angler Characterization for Texas
Consumer
High-rate Consumers
Average-rate Consumers
Entire State
Recreational Anglers
Number1
238,470
2,146,230
2,384,700
% of State
Anglers
10%
90%

% Coastal
Residents'1
34%
34%

% Inshore
Anglers"
48%
48%

Average
Persons per
Household11
2.9
2.9

Estimated
Exposed
Population11
112,863
1,015,768
1,128,631
1  Source:  USFWS, 1993b.
b  Source: CACI, 1993.
e  Source:  Steimle and Associates, 1995.
d  Recreational anglers and household seafood consumers.
      In Louisiana, 24% (40% x 60%) of the total recreational angler population are assumed to be
coastal (inshore) anglers, with an average of 3.3 consumers per household.  Thus, the total population
of inshore recreational anglers and their household members is estimated at 608,969 people.  The
population of high-rate consuming coastal, inshore recreational anglers and their households in
Louisiana is estimated at 60,897. The estimated population of average-rate consuming coastal, inshore
recreational anglers and their households is 548,072.  These population estimates are used in the

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	5-5
produced water radium risk assessment and for the monetization of human health benefits presented in
Section 6 of this document.
                                I
5.1.2 Texas

     The USFWS data indicate there are 2.38 million recreational licensed anglers in the state of
Texas; 238,470 of these recreational anglers are considered high-rate consumers (10% of all
recreational anglers in Texas; USFWS, 1993b). There are 2,146,230 recreational anglers in Texas
who are considered average-rate consumers (90%  of all recreational anglers in Texas; USFWS,
1993b). The high-rate (147.3 g/d) and average-rate (15 g/d) consumption of seafood is the same as for
Louisiana.

     In Texas, 16%  (34% x 48%) of the total recreational angler population are assumed to be coastal
                                i
(inshore) anglers, with an average of 2.9 consumers per household.  Thus, the total population of
coastal, inshore recreational anglers and their household members is estimated at 1,128,631 people.
The population of high-rate consuming coastal, inshore recreational anglers and their households  in
Texas is estimated at  112,863.  The estimated population of average-rate coastal, inshore recreational
anglers and their households is  I,0i5,768. These  population estimates are used in the radium risk
assessment and the monetization of human health benefits presented in Section 6 of this document.

5.2  Seafood Consumption Rates and Patterns

5.2.1 Gulf of Mexico Recreational Fishing

     The GBNEP and Steimle and Associates studies are used to determine the seafood consumption
estimates used in this WQBA. The GBNEP study  (Brooks et al., 1992) estimates that the average con-
sumer of Galveston Bay seafood eats 15 g/d, while the high-rate consumer (defined  as the 95th percen-
tile of the seafood consuming population) consumes 147.3 g/d.  These amounts of seafood consumed
are an aggregate of finfish, oyster, and crab consumption estimates.  Although Steimle and Associates
(1995) did not report on the amount of seafood eaten, the report did indicate the  type of recreational
fishing undertaken by fishermen. These types of fishing were finfishing, shrimping, crabbing, and
oystering.  Because the GBNEP report did not include shrimp consumption patterns, and because
shrimp are not generally caught around oil and gas structures, EPA has excluded shrimp as a source of

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S-6	
possible contaminated seafood in the risk assessment in this WQBA. To determine individual daily
consumption of each of the three exposed and consumed types of seafood included in the WQBA risk
analysis (i.e., finfish, oysters, and crabs), the high-rate and average-rate consumption (i.e., 147.3 g/d
and 15 g/d) were multiplied by the percentages listed below in Sections 5.2.1.1 and 5.2.1.2, for finfish,
oysters, and crabs only.

5.2.1.1 Louisiana

      Steimle and Associates (1995) reported percent frequency for types of fishing conducted.  This
report indicated 94.7% of Louisiana recreational fishermen preferred finfishing, while 2.5% crabbed,
2.4% shrimped, and 0.4% oystered.  Although shrimp has been excluded as a possible source of
contaminated seafood, it is a part of the recreational fisherman's diet and has been included in the total
seafood consumption budget.  The average-rate consumer, therefore, is estimated to consume 14.2 g/d
of finfish, 0.38 g/d of crabs, 0.36 g/d of shrimp, and 0.06 g/d of oysters, totaling 15.0 g/d of seafood.
The high-rate consumer consumes 139.5 g/d of finfish, 3.7 g/d of crabs, 3.5 g/d of shrimp, and 0.6 g/d
of oysters, totaling 147.3 g/d of seafood.

5.2.1.2 Texas

      Steimle and Associates (1995) reported percent frequency for types of fishing conducted.  In
Texas, 96.6% of recreational fishermen finfished, 1.8% crabbed,  1.3% shrimped, and 0.3% oystered.
Similar to the analysis for Louisiana, shrimp has been excluded as a possible source of contaminated
seafood. It is a part of the recreational fisherman's diet and has been included in the total  seafood
consumption budget. The average-rate consumer, therefore, consumes 14.5 g/d of  finfish, 0.27 g/d of
crabs, 0.20 g/d of shrimp, and 0.05 g/d of oysters, totaling 15 g/d of seafood.  The high-rate consumer
consumes 142.3 g/d of finfish, 2.7 g/d of crabs, 1.9 g/d of shrimp, and 0.4 g/d of oysters, totaling
147.3 g/d of seafood.

5.2.2 Cook Inlet, Alaska Subsistence Fishing

      Alaska has a unique property rights structure in which hunting and fishing rights are prioritized
by law, and subsistence harvesters are given priority over both sport and commercial harvesters
(Brown and Burch,  1992).  Cook Inlet was designated as a "nonsubsistence area" in 1992  by the
Alaska Board of Fisheries.  However, exceptions were provided to three Alaska Native villages. Cook

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	5-7
Inlet provides subsistence fishery resources the Alaska Native villages of Tyonek, Port Graham, and
Nanwalek (previously English Bay; Nelson, 1994). Tyonek is located on the northwestern shore of
Cook Inlet and has a population of 154 (Alaska Department of Labor, 1991). The villages of Port
Graham and Nanwalek, with populations of 141 and 175 respectively, are located near the mouth of
Cook Inlet on Kachemak Bay (ADFG, 1995).

5.2.2.1 Finfisheries

      Data on the finfish harvests of the three Cook Inlet subsistence fisheries from the most recent
harvest survey available are presented in Exhibit 5-4. Finfish make up 74%, 79%, and 80% of the
total subsistence harvests for Tyonek, Nanwalek, and Port Graham, respectively.  Salmon are 97%,
62%, and 57% of the finfish harvest for Tyonek, Nanwalek, and Port Graham,  respectively. In 1983,
the Tyonek fisheries harvested about 3,300 salmon yielding about 51,000 useable pounds (ADFG,
1995). Chinook salmon were the most frequently harvested species.  In 1993, the Nanwalek and Port
Graham fisheries harvested about 7,000 and 4,500 salmon, respectively, yielding about 21,000 and
17,000 useable pounds, respectively (ADFG,  1995).  Pink salmon were the most frequently harvested
species for both villages.

5.2.2.2 Shellfisheri.es

      Tyonek, Nanwalek, and Port Graham also have subsistence shellfisheries  (see Exhibit 5-5). The
Tyonek people utilize clamming beds south of their village on the western shore of Cook Inlet.  Tyonek
clamming parties harvest about 1,000 edible pounds of clams (approximately 3,000 clams) annually,
with razor clams making up about 90% of the harvest (Stanek et al., 1982; AFDG, 1995). Nanwalek
and Port Graham villagers have traditionally harvested shellfish from  areas near the mouth of
Kachemak Bay. However, following the Exxon Valdez oil spill, residents of these villages began
utilizing areas further into Kachemak Bay and razor clam beaches across Kachemak Bay and the inlet
(Stanek, 1994).  Shellfish resources harvested at Nanwalek and Port Graham include clams, chiton,
cockles, mussels, crabs, shrimp, octopus; snails with clams and chitons being the most important
(Stanek et al., 1982; Stanek,  1994; AFDG, 1995). As shown in Section 5.2.2.3 below, shellfish are a
much smaller portion of the total subsistence harvest than finfish for all three villages.

      The finfish consumption estimates are also supported by the harvest data.  That is,  the finfish
harvest data indicate consumption levels of 211 g/d, 238 g/d, and 298 g/d in Port Graham, Tyonek,

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5-8         	



Exhibit 5-4.    Cook Inlet, Alaska, Native Village Subsistence Finfishery Harvest

Survey Year
Population in Survey Year
Tyonek
1983/84
273
Nanwalek
1993/94
141
Port Graham
1993/94
175
Useable Pounds Harvested
Salmon
Other Finfish
Total Finfish
Total All Resources
50,950
1,369
52,319
70,962
21,109
12,731
33,840
43,068
17,006
12,692
29,699
37,044
Percent of Total Subsistence Harvest
Salmon
Other Finfish
Total Finfish
72%
2%
74%
49%
30%
79%
46%
34%
80%
Note: Detail may not add to total due to independent rounding.
Source: ADFG, 1995.
Exhibit 5-5.    Cook Inlet, Alaska, Native Village Subsistence Shellfishery Harvest

Survey Year
Population in Survey Year
Tyonek
1983/84
273
Nanwalek
1993/94
141
Port Graham
1993/94
175
Useable Pounds Harvested
Clams
Other Shellfish
Total Shellfish
Total All Resources
1,230
0
1,230
70,962
1,681
1,615
3,296
43,068
1,180
1,607
2,786
37,044
Percent of Total Subsistence Harvest
Clams
Other Shellfish
Total Shellfish
2%
0%
2%
4%
4%
8%
3%
4%
8%
Note: Detail may not add to total due to independent rounding.
Source: ADFG, 1995.

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	5-9
and Nanwalek, respectively, and salmon consumption levels of 121 g/d, 186 g/d, and 232 g/d for Port
Graham, Nanwalek, and Tyonek, respectively.

5.2.2.3 Seafood Consumption

      Exhibit 5-6 provides a summary of available estimates of the consumption offish and shellfish by
Alaska Natives. These studies indicate a level of consumption of fish and shellfish that is much higher
than has been estimated for some Native American populations in the contiguous United States
(see CRITFC, 1994; EPA,  1992), but is similar to the levels found in tribal spearers in the Great Lakes
Basin (GLIFWC, 1994).

      Because the seafood consumption estimate by Nobmann et al. (1992) does not distinguish
between fish and shellfish, low (10 g/d),  medium (21 g/d), and high (27 g/d) estimates of shellfish
consumption are used for the risk assessment based on the Chenaga Bay and Kodiak Island studies
(Exhibit 5-6).  These estimates are substantiated by the subsistence harvest data described in Sections
5.2.2.1  and 5.2.2.2 above.  That is, the shellfish harvest data indicate consumption levels of 6 g/d, 20
g/d, and 29 g/d in Tyonek,  Port Graham, and Nanwalek, respectively (calculated by dividing useable
pounds harvested by population and days per year).

5.3   Commercial Fisheries, Louisiana and Texas
                               I
      Most commercial fishery species spend a significant portion of their life cycle in bays and
estuaries.  Of 57 commercial species caught in Louisiana (NOAA, 1985; NMFS, 1995), 39 species
spend a significant portion of their life cycle in the estuary (estuarine related species).  These 39 species
made up 99% of the total weight landed in Louisiana in 1994.  Similarly, of 35 commercial species
caught in Texas (NOAA, 1985; NMFS, 1995), 21 species are  estuarine related and spend a significant
portion of their life cycle in the estuary.  These 21 species made up 96% of the total weight of
commercial landings in Texas in 1994. Therefore, the water and sediment quality of coastal
subcategory waters may affect the early life stages of the important commercial species, and affect both
coastal and offshore fisheries.

      The commercial fisheries in Louisiana and Texas were valued together at $543 million;
($523.9 million in estuarine related species) in 1994 (ex-vessel value; NMFS, 1995).  This value
represents 62% of the entire value of the Gulf of Mexico fishery.  Louisiana's commercial fishery was

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5-10	

Exhibit 5-6.    Fish Consumption Surveys of Alaska Subsistence Fishermen
               Study
             Description
   Estimated Mean Daily
 Intake (grains/person/day)
  Nobmann, etal., 1992
Survey collected seasonal dietary intakes
of 351 Alaska Native adults from 11
communities from 1987-1988.  A total
of 995 24-hour recalls were collected
from the survey participants.	
109 (fish and shellfish)
  Alaska Department of Fish and
  Game, Division of Subsistence (as
  cited in CFSAN, 1990)
Survey of fish consumption patterns for
the village of Chenaga Bay on Evans
Island, Prince William Sound, between
1984 and 1986.
141 (fish):
89 (salmon)
52 (all other fish)1

21 (shellfish):
2 (bivalve mollusks)2
8 (crabs)
11 (shrimp)	
  Kodiak Island Native Association,
  1983 (as cited in CFSAN, 1990)
Survey of food consumption on Kodiak
Island hi 1983.
Most isolated population:
369 (fish)
27 (butter clams)

Less isolated population:
124 (fish)3
10 (butter clams)
1 Includes halibut, herring, herring roe, cod, rockfish, smelt, shark, eel, Dolly Varden, and trout.
2 Includes razor and other clam species, cockles, and mussels.
3 Mostly salmon.


valued at $336.3 million ($320 million in estuarine related species), while the Texas commercial

fisheries brought in $206.7 million ($203.9 million in estuarine related species; NMFS, 1995). It is not

possible to reliably quantify the benefits of these coastal oil and gas regulations to these fisheries.
      Numerous other natural and anthropogenic factors significantly affect commercial fisheries,
ranging from annual water temperature to the market price of catch.  Not only are these factors
numerous, but the significance of then- impact and interactions are largely unknown.  However, many
commercially important specises spend a significant portion of their life cycle hi estuary systems
adjacent to the Gulf of Mexico. A reasonable line of reasoning is that eliminating the discharge of
produced water pollutants through selection of the zero discharge option as BAT will provide some
improvement water quality and sediment quality in receiving waters important to commercial species,
even if this improvement cannot be accurately quantified at present.

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                                                                                         5-11
5.4  Endangered and Threatened Species

5.4.1 Gulf of Mexico Endangered and Threatened Species

     There are 51 endangered or threatened species within coastal areas of the Gulf of Mexico
(Carmody, 1993; Stevens, 1993; Francesco, 1994; USFWS, 1992).  Thirty-two threatened or
endangered species occur in Louisiana and Texas.  These 32 species include:

        •  12 endangered and 1 threatened species of birds
        •  3 endangered and 4 threatened species of reptiles
        •  4 endangered and 1 threatened species of mammals
        •  1 endangered and 1 threatened species of fish
        •  1 endangered and 1 threatened species of mollusks
        •  3 endangered species of plants.

      Exhibit 5-7 presents a complete list of the threatened and endangered species that occur in the
coastal areas of the Gulf of Mexico.
5.4.2 Cook Inlet, Alaska Endangered and Threatened Species

      There are 13 species listed as endangered, threatened, or as candidates for listing in the Cook
Inlet region.  These species are presented in Exhibit 5-8.

      Region X has determined,  in issuance of the NPDES general permit for Cook Inlet, that these
species would not be adversely affected (i.e., their continued existence would not be jeopardized) by
the oil and gas activities covered. The basis for this determination is presented in the fact sheet for the
proposed general permit at VLB (EPA Region X, 1995). The regulatory options that have been
selected for the guidelines rule will require additional pollution control measures (IGF for produced
water and offshore limits for drilling fluids).

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5-12
Exhibit 5-7.  Threatened and Endangered Species of the Gulf of Mexico
Listed Species
BIRDS
Brown Pelican
Arctic Peregrine Falcon
Bald Eagle
Piping Plover
Interior Least Tern
Attwater's Prairie Chicken
Ivory-billed Woodpecker
Red-cockaded Woodpecker
Black-capped Vireo
Aploraado Falcon
Eskimo Curlew
Bachman's Warbler
Whooping Crane
Wood Stork
Roseate Tern
Cape Sable Sparrow
REPTILES
Green Sea Turtle
Hawskbille Sea Turtle
Leatherback Sea Turtle
Loggerhead Sea Turtle
Kemp's (Atlantic) Ridley Sea Turtle
Ringed Sawback Turtle
American Alligator
MAMMALS
Jaguarundi
Ocelot
Louisiana Black Bear
Florida

—
T
E
T
—
—
—
—
—
—
—
—
—
E
T
E, CH

E
E
E
T
E
—
E, CH

—
—
—
Alabama

E
T
E
T
—
—
—
—
—
—
—
—
—
E
—
—

T
E
E
T
E
—
—

—
—
—
Mississippi

—
T
E
T
—
—
—
—
—
—
—
—
—
—
—
—

T
E
—
T
E
—
—

—
—
—
Louisiana

E
T
E
T
E
—
E
E
E
E
E
E
—
—
—
—

T
E
E
T
E
T
'j'*

—
—
T
Texas

E
E
E
T
E
E
—
—
—
—
—
—
E
—
—
—

T
E
E
T
E
—


E
E
—

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                                                                                       5-13
Exhibit 5-7.  Threatened and Endangered Species of the Gulf of Mexico (Continued)
Listed Species
MAMMALS (Continued)
Florida Panther
Red Wolf
Key Deer
Florida Salt Marsh Bole
St. Andrew Beach Mouse
Santa Rose Beach Mouse
Choctawhatchee Beach Mouse
Perdido Key Beach Mouse
Alabama Beach Mouse
Key Largo Cotton Mouse
Key Largo Woodrat '.
Lower Keys Rabbit
Florida Manatee
FISH
Gulf Sturgeon
Pallid Sturgeon '
MOLLUSKS
Louisiana Pearlshell Mussel
Pink Mucket Mussel
Stock Island Tree Snail
INSECTS
Schaus' Swallowtail Butterfly
PLANTS
Texas Prairie Dawn
Slender Rush-pea
Louisiana Quillwort
Key Tree Cactus
Garber's Spurge
Florida

E
—
E
E
C
C
E, CH
E
—
E
E
E
E, CH

T
—

—
—
T

T

—
—
—
E
T
Alabama

E
—
—
—
—
—
—
E, CH
E, CH
—
—
—
E

T
—

—
—
—

—

—
—
—
—
—
Mississippi

E
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—
—
—
—
—
—
—
—
—
—
—

T
—

—
—
—

—

—
—
—
—
—
Louisiana

E
E
—
—
^~
—
—
—
—
—
—
—
—

T
E

T
E
—

-—

—
—
E
—
—
Texas

—
—
—
—
.—
—
—
—
—
— -
—
—
—

—
-—

^~
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—

—

E
E
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—
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-------
5-14	




Exhibit 5-8. Endangered, Threatened, or Candidates for Listing in Cook Inlet, Alaska

Humpback Whale
Fin Whale
Sei Whale
Gray Whale
Steller Sea Lion
American Peregrine Falcon
Arctic Peregrine Falcon
Beluga Whale
Steller's Eider
Short-tailed Albatross
Harlequin Duck
Kittlitz's Murrelet
Marbled Murrelet
Status
Endangered
/
/
/
See footnote 1





/



Threatened




/
/
See footnote 1






Candidate







S
S

s
s
s
1 Removed from list but continues to be monitored.




Source: EPA Region X, 1995.

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                                	6-1
              6.  RADIUM RISK ASSESSMENT AND MONETIZATION OF
                       POTENTIAL HUMAN HEALTH BENEFITS

6.1  Methodology

     An assessment of the potential human health impacts from ingestion of seafood contaminated with
radium from discharged produced water is presented in this section.  This assessment is a first-order
assessment, based on a plume dispersion modeling approach to estimate radium contaminant levels in
seafood.  This benefits analysis is an assessment of incremental risk reduction based on the selection of
the zero discharge option, as compared to risk from current technology discharges. A different
modeling approach and different endpoints are used for two baselines, based on available data for each
of these baselines.

     In the proposed rulemaking, the radium risk assessment was conducted using modeling and field
collected data. However, because of the uncertainty of background radium in areas where there has
been heavy oil and gas exploration, no field data-based approach is taken to assess the  potential human
health impacts in this WQBA for the final rule. Rather, a modeling approach that is based on
incremental risk estimates is used to eliminate the uncertainty due to background contributions to risk.

     The estimated seafood radium levels based on modeling are combined with high-rate (147.3 g/d)
and average-rate (15 g/d) seafood consumption levels (disaggregated for fish, crab, and oyster
consumption levels) developed for the Galveston Bay National Estuary Program (Brooks et al.,  1992)
and modified per Steimle and Associates (1995; see Section 5.2). As per EPA methodology (EPA,
1989a; 1993b), an exposure duration of 30 years for average-rate consumers, an exposure duration of
70 years for high-rate consumers, and carcinogenicity potency factors for radium 226 (1.2 x 10"10) and
radium 228 (1.0 x 10'10) are used. Resulting individual carcinogenic risks from all seafood categories
are adjusted, also as per EPA methodology (EPA, 1989b), by factors of 0.20 and 0.75, to account for
ingestion of seafood from various locations, some of may not be contaminated by produced water
dischargers.                      '.
      Produced water radium concentrations are provided by EPA and were presented in Section 2.
Bioconcentration factors (BCFs) are obtained from an earlier EPA risk assessment of potential radium
health effects conducted for the offshore subcategory (EPA, 1993b).

-------
6-2	
      For the current requirements baseline, site-specific water quality modeling is used to project
average, available dilutions, based on results for 50-foot and 200-foot mixing zones, for major deltaic
pass dischargers. This analysis of major deltaic pass dischargers is used to project individual lifetime
cancer risk estimates. Based on produced water radium activities, projected produced water effluent
dilution, and species-specific bioconcentration factors, edible tissue levels of radium are projected for
finfish, crabs, and oysters. Based on these edible tissue levels, seafood consumption data presented in
Section 5 of this WQBA, and radium carcinogenic potency factors, individual excess lifetime cancer
risk estimates are derived, accounting for consumption of recreational sources of seafood from other
than contaminated waters.  Also, because of insufficient data for Cook Inlet, Alaska and low reported
levels of radionuclides in produced water, there was no risk assessment conducted for the Cook Inlet
dischargers.

      For the alternative baseline, the same methodology is used except for the modeling of produced
water dilution estimates. Produced water dilutions are estimated from the average dilutions available at
50-foot and 200-foot mixing zones based on water quality modeling at flow-weighted depths and mean
discharge rates for Louisiana open bay and Texas permit applicant dischargers. Individual excess
lifetime cancer risk estimates are derived and applied against exposed populations (recreational anglers
and their household members) to quantify  and monetize cancer case risk reductions based on the
selected regulatory option.

6.1.1 Current Requirements Baseline Dischargers

6.1.1.1 Major Deltaic Pass Dischargers

      Because of uncertainty and  difficulty in determining the population at risk of exposure from
major deltaic pass dischargers, only maximum individual lifetime cancer risk assessments are
conducted for each major deltaic pass discharge hi this WQBA. No valid estimate of an exposed
population could be determined for major deltaic pass dischargers.  These operators constitute a small
number of dischargers located in a rather geographically limited area of Louisiana.  They do  not
represent an adequate statistical basis for projecting the exposure characteristics for recreational anglers
and their household members who consume seafood species  caught near these oil and gas facilities.
Thus, no population-based, cancer case risk reduction could be quantified or monetized for major
deltaic pass dischargers.

-------
                                                                                             6-3
 6.1.1.2 Cook Inlet, Alaska

      Because of the minimal concentration of radium detected in produced water discharges in Cook
 Inlet, and the uncertainty over the level of fishing near oil and gas structures and proportion of dietary
 intake that such catch might represent, no radium risk assessment is conducted for Cook Inlet
 dischargers in this WQBA.

 6.1.2 Alternative Baseline Dischargers

 6.1.2.1 Open Bay Dischargers, Louisiana

      The estimated exposed population used for this assessment of open bay dischargers is inshore
 recreational anglers and their household members in Louisiana (presented in Section 5, Exhibit 5-1).
 As discussed in Section 5, the total population of recreational anglers (i.e., including those that fish in
 freshwater areas beyond the geographic scope of this coastal rule) has been adjusted to include only
 those anglers who fished in coastal (inshore) waters. The percentage of anglers who fish in coastal
 (inshore) waters was determined as part of a DOE study of coastal oil and gas impacts (Steimle and
 Associates, 1995).  The total population of all inshore recreational anglers and their household
 members is 0.61 million.  Ten percent of the population of inshore recreational anglers and their
 households in Louisiana is considered as the high-rate seafood consumer group (147.3 g/d). This
 population totals 0.06 million individuals in  Louisiana. Ninety percent of the population of inshore
 recreational anglers and their households is assumed to be average-rate seafood consumers (15 g/d).
 This population totals 0.55 million individuals in Louisiana.

 6.1.2.2 Individual Permit Applicants,  Texas
      The estimated exposed population used for this assessment is inshore recreational anglers and
their household members in Texas (presented in Section 5, Exhibit 5-2). The total population of all
inshore recreational anglers and .their household members is 1.13 million.  Ten percent of this
population of inshore recreational anglers and their households in Texas is considered as the high-rate
seafood consumer group (147.3 g/d). This population totals 0.11 million individuals in Texas.  Ninety

-------
6-4
percent of the population of recreational anglers and their households is assumed to be average-rate
seafood consumers (15 g/d). This population totals 1.02 million individuals in Texas.

6.2   Results

6.2.1 Current Requirements Baseline Dischargers

6.2.1.1 Major Deltaic Pass Dischargers

      Exhibit 6-1 summarizes the estimated lifetime cancer risks for high-rate and average-rate
consumers attributed to major deltaic pass dischargers.  Exhibits 6-2 through 6-8 present the
calculations by individual outfall. The range presented for modeling estimates of risk result from the
application of a factor of 0.2 and 0.75 to the maximum lifetime excess cancer risk. The application of
these factors accounts for seafood consumption from noncontaminated sources.  For the average-rate
seafood consumer, the estimated increased lifetime cancer risk from produced water Ra226 and Ra228
ranges from 1.0 x ICr6 to 2.8 x 10'5.  Estimated increased lifetime cancer risk due to Ra226 and Ra228 for
high-rate consumers ranges from 2.4 x 10"5 to 6.3 x IQ4.

6.2.2 Alternative Requirements Baseline Dischargers

6.2.2.1 Open Bay Dischargers, Louisiana

      Exhibit 6-9 presents the complete calculations and results of estimated increases of lifetime
cancer risks for high-rate and average-rate consumers attributed to produced water discharges from
Louisiana open bay dischargers. The range presented for modeling estimates of risk result from the
application of a factor of 0.2 and 0.75 to the maximum lifetime excess cancer risk.  The application of
these factors accounts for seafood consumption from noncontaminated sources.  For the average-rate
seafood consumer (15 g/d), the estimated current technology increased lifetime cancer risk from
produced water Ra226 and Ra228 ranges from 1.3 x lO'5 to 4.8 x 10'5.  Estimated  current technology
increased lifetime cancer risk from produced water Ra226 and Ra228 for the high-rate consumer (147.3
g/d)  ranges from 2.9 x 1Q-4 to 1.1 x 10'3.

-------
                                    	6-5

Exhibit 6-1.  Summary of Major Deltaic Pass Discharger Maximum Individual Lifetime Cancer Risks


Multiple Seafood Source Reduction Factor*'
Major Pass Operator Maximum Liretime KISK


Flores & Rucks
Chevron
Amoco
North Central(a)
Warren

Average-Rate
3.7E-05
1.1E-05
5.8E-06
1.6E-05
5.2E-06
@0.20
Consumer
7.3E-06
2.2E-06
1.2E-06
3.1E-06
l.OE-06
@0.75

2.8E-05
8.3E-06
4.3E-06
1.2E-05
3.9E-06
High-Rate Consumer
Flores & Rucks
Chevron
Amoco
North Central00
Warren
Average-Rate
Average-Rate
High-Rate
High-Rate
8.4E-04
2.5E-04
1.3E-04
3.6E-04
1.2E-04
Consumer Risk Range:
Consumer Mean Risks:
Consumer Risk Range:
Consumer Mean Risks:
1.7E-04
5.0E-05
2.6E-05
7.2E-05
2.4E-05
l.OE-06
3.0E-06
2.4E-05
6.8E-05
6.3E-04
1.9E-04
9.9E-05
2.7E-04
8.9E-05
2.8E-05
1.1E-05
6.3E-04
2.5E-04
(a>  Composite of three outfalls.
(b)  Use of the 0.2 and 0.75 reduction factors (from the maximum value) is the EPA methodology to account for the ingestion
    of seafood from various locations, some contaminated, some not; the resulting range is believed to be the estimated risk
    (EPA, 1989b).

-------
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6-14	
      Exhibit 6-10 presents projected excess lifetime cancer cases in Louisiana for estimated exposed
populations.  Assuming that 0.55 million coastal recreational anglers and their households (90% of the
total resident in-state recreational inshore angler population) are average-rate seafood consumers, there
are 7.1 to 26 excess lifetime cancer cases projected for average-rate consumers.  Assuming that the
population of 0.06 million recreational anglers and their households (10% of recreational angler
population) are high-rate seafood consumers, there are 18 to 67 excess lifetime cancer cases projected
for high-rate consumers. Thus, excess individual lifetime cancer cases projected for Louisiana for
combined average- and high-rate seafood consumer populations ranges from 25 to 93 cases.

      Exhibit 6-11 presents a summary of estimated lifetime excess cancer cases and the projected
annual lifetime cancer cases (based on a 70-year life span) for the coastal populations of recreational
inshore anglers and their household members hi the state of Louisiana.  For average-rate consumers,
there will be an excess of 0.10 to 0.38 cancer cases per year.  There will be an increase of 0.25 to 0.96
cancer cases per year for high-rate seafood consumers. For the total coastal population of inshore
recreational anglers and their household members (high- and average-rate consumers), there will be an
increase of 0.35 to 1.3 cancer cases per year in Louisiana due to produced water Ra226 and Ra228
contamination from open bay dischargers.

      Exhibit 6-12 presents the annual monetized benefits, using 1995 dollars, for cancer case
avoidance due to selection of the zero discharge option, compared to current  technology risk
projections, and assuming the lifetime cost of each cancer case ranges from $2.5 million to $13.4
million (Violette and Chestnut, 1983; 1986). The annual monetized benefits in 1995 dollars of cancer
case avoidance in Louisiana for the average-rate seafood consumers are valued at $0.30 million to $5.1
million, with a range of midpoint values from $0.8 million to $3.1 million.

      The annual monetized benefits hi 1995 dollars of cancer case avoidance for high-rate consumers
in Louisiana range from $0.6 million to $13.0 million, with a range of midpoint values from $2.0
million to $7.7 million (1995 dollars).  The total annual monetized benefits hi 1995 dollars for cancer
case avoidance hi Louisiana is $0.9 million to $18 million, with a range of midpoint values from
$2.8 million to $11 million.

-------
6-15









































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 6-16	

Exhibit 6-11   Estimated Lifetime Excess Cancer for Louisiana Recreational Anglers and Their
              Households
Target Population
10% Recreational
Anglers &
Households
90% Recreational
Anglers &
Households
Total
Exposed
Population
60,897
548,072
608,969
Consumption
Rate
High
Average
Total
Projected Lifetime
Cancer Cases
20%
MLECCb
18
7
25
75%
MLECC
67
26
93
Projected Annual
Excess Cancer
Casesa
20%
MLECC
0.25
0.10
0.35
75%
MLECC
0.96
0.38
1.34
* The estimated lifetime is 70 years.
b MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75% of calculated
  MLECC to account for food sources from other than contaminated sites.
Exhibit 6-12   Estimated Annual Monetized Benefits of Cancer Case Avoidance for Louisiana
              Recreational Anglers and Their Households'1
Target Population
10% of Recreational
Anglers & Households
90% of Recreational
Anglers & Households
Total
Consumption
Rate
High
Average
Total
$ Million Saved/Annual Cancer Cases Avoided
20% MLECCb-c
$2.0C ($0.6-$3.4)
$0.80($0.30-$1.30)
$2.8 ($0.90-$4.7)
75% MLECCb-c
$7.7 ($2.4-$12.9)
$3.1($1.0-$5.1)
$10.7 ($3.4-$18.0)
*   Cancer case avoidance valued at $2.5 million to $13.4 million per case (1995 dollars).
b   MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75% of calculated
    MLECC to account for food sources from other than contaminated sites.
c   Midpoint (range).

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                                                                                           6- 17
6.2.2.2 Individual Permit Applicants,  Texas
      Exhibit 6-13 presents the complete calculations and results of estimated increases of lifetime
cancer risks for high-rate and average-rate consumers attributed to produced water discharges from
Texas individual permit applicants. The range presented for the modeling estimates of risk result from
the application of a factor of 0.2 and 0.75 to the maximum lifetime excess cancer risk. The application
of these factors accounts for seafood consumption from noncontaminated sources.  For the average-rate
seafood consumer (15 g/d), the estimated current technology increased lifetime cancer risk from
produced water Ra226 and Ra228 ranges from 1.6 x 10'6 to 6.1 x 10"6. Estimated current technology
increased lifetime cancer risk due to Ra226 and Ra228 for the high-rate consumer (147.3 g/d) ranges from
3.7xlO-5to  1.4X10-4.

      Exhibit 6-14 presents projected excess lifetime cancer cases in Texas for estimated exposed
populations.  Assuming that the population of 1.0 million coastal recreational inshore  anglers and their
households (90%  of the total resident in-state, inshore recreational angler population)  are average-rate
seafood consumers, there are 1.6 to 6.2 excess lifetime cancer cases projected for average-rate
consumers.  Assuming that the population of 0.11 million coastal recreational inshore anglers and their
households (10%  of recreational population) are high-rate seafood consumers, there are 4.2 to 16
excess lifetime cancer cases projected for high-rate consumers. Thus, excess individual lifetime cancer
cases projected for Texas for combined average- and high-rate seafood consumer populations ranges
for 5.8 to 22 cases.

      Exhibit 6-15 presents a summary of estimated lifetime excess cancer cases and the projected
annual lifetime cancer cases (based on a 70-year life span)  for the populations of coastal recreational
inshore anglers and their household members in the state of Texas. For average-rate consumers, there
will be an excess of 0.02 to 0.09 cancer cases per year.  There will be an increase of 0.06 to 0.23
cancer cases per year for high-rate seafood consumers. For the total population of recreational anglers
and their household members (high- and average-rate consumers), there will be an increase of 0.08 to
0.32 cancer cases per year  in Texas due to produced water Ra226 and Ra228 contamination.
      Exhibit 6-16 presents the annual monetized benefits, in 1995 dollars, for cancer case avoidance
due to selection of the zero discharge option, compared to current technology risk projections, and

-------
6-18
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                                                                             6- 19
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6-20	

Exhibit 6-15.   Estimated Lifetime Excess Cancer for Texas Recreational Anglers and Their Households
Target Population
10% Recreational
Anglers &
Households
90% Recreational
Anglers &
Households
Total
Exposed
Population
112,863
1,015,768
1,128,631
Consumption
Rate
High
Average
Total
Projected Lifetime
Cancer Cases
20%
MLECC"
4.2
1.6
5.8
75%
MLECC
15.8
6.2
22
Projected Annual
Excess Cancer
Cases3
20%
MLECC
0.06
0.02
0.08
75%
MLECC
0.23
0.09
0.32
    The estimated lifetime is 70 years.
    MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75% of calculated MLECC to
    account for food sources from other than contaminated sites.
 Exhibit 6-16    Estimated Annual Monetized Benefits of Cancer Case Avoidance for Texas Recreational
               Anglers and Their Households"
Target Population
10% of Recreational
Anglers & Households
90% of Recreational
Anglers & Households
Total
Consumption
Rate
High
Average
Total
$ Million Saved/ Annual Cancer Cases Avoided
20% MLECC"-0
$0.48°($0.15-$0.80)
$0.16($0.05-$0.27)
$0.64($0.20-$1.07)
75% MLECCb-c
$1.8 ($0.58-43.08)
$0.72 ($0.23-$1.21)
$2.55 ($0.81-$4.29)
 *   Cancer case avoidance valued at $2.5 million to $13.4 million per case (1995 dollars).
 b   MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75 % of calculated MLECC to
    account for food sources from other than contaminated sites.
 c   Midpoint (range).

-------
	6-21
assuming the lifetime cost of each cancer case ranges from $2.5 million to $13.4 million (Violette and
Chestnut, 1983; 1986).  The annual monetized benefits in 1995 dollars of cancer case avoidance in
Texas for the average-rate seafood consumers are valued at $0.05 million to $1.2 million, with a range
of midpoint values from $0.16 million to $0.72 million.

      The annual monetized benefits in 1995 dollars of cancer case avoidance for high-rate consumers
hi Texas range from $0.15 million to $3.1 million, with a range of midpoint values from $0.48 million
to $1.83 million. The total annual monetized benefits in 1995 dollars for cancer case avoidance in
Texas is $0.20 million to $4.3 million, with a range of midpoint values from $0.64 million to
$2.6 million.

6.2.3 Total Monetized Benefits for Louisiana Open Bay Dischargers and Texas Individual Permit
      Applicants

      Exhibit 6-17 presents total projected excess lifetime cancer cases in Louisiana and Texas for
estimated exposed populations.  Assuming that 1.6 million coastal recreational inshore anglers and their
households (90% of the total resident in-state, recreational inshore angler population) are average-rate
seafood consumers, there are 9 to 32 excess lifetime cancer cases projected. Assuming that the
population of 0.17 million coastal recreational inshore anglers and their households (10% of
recreational angler population) are high-rate seafood consumers, there are 22 to 83 excess lifetime
cancer cases projected. Thus, there is a range of 31  to 115 lifetime excess cancer cases projected for
Louisiana and Texas for combined average- and high-rate seafood consumer populations.

      Exhibit 6-18 presents a summary of estimated lifetime excess cancer cases and the projected
annual lifetime cancer cases  (based on a 70-year life  span) for the populations of coastal recreational
inshore anglers and their household members in Louisiana and Texas. For average-rate consumers,
there will be an excess of 0.12 to 0.47 cancer cases per year. There  will be an increase of 0.31 to 1.19
cancer cases per year for high-rate seafood consumers.  For the total population of recreational anglers
and their household members (high- and average-rate consumers), there will be an increase of 0.43 to
1.66 cancer cases per year in Louisiana and Texas due to produced water Ra226 and Ra228
contamination.

-------
6-22





















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                                 	6-23
Exhibit 6-18.   Estimated Total Lifetime Excess Cancer for Louisiana and Texas Recreational Anglers
               and Their Households
Target Population
10% Recreational
Anglers &
Households
90% Recreational
Anglers &
Households
Total
Exposed
Population
173,160 :
1,563,840
1,737,600
Consumption
Rate
High
Average
Total
Projected Lifetime
Cancer Cases
20%
MLECC"
22
9
31
75%
MLECC
83
32
115
Projected Annual
Excess Cancer
Cases"
20%
MLECC
0.31
0.12
0.43
75%
MLECC
1.19
0.47
1.66
a The estimated lifetime is 70 years.
b MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75% of calculated
  MLECC to account for food sources from other than contaminated sites.
      Exhibit 6-19 presents the annual monetized benefits in 1995 dollars for cancer case avoidance due
to selection of the zero discharge option, compared to current technology risk projections, and
assuming the lifetime cost of each cancer case ranges from $2.5 million to $13.4 million (Violette and
Chestnut,  1983; 1986).  The annual monetized benefits in 1995 dollars of cancer case avoidance in
Louisiana and Texas combined for the average-rate seafood consumers are valued at $0.35 million to
$6.3 million, with a range of midpoint values from $0.96 million to $3.8 million.
      The total annual monetized benefits in 1995 dollars of cancer case avoidance for high-rate
consumers in Louisiana and Texas combined range from $0.75 million to $16.0 million, with a range
of midpoint values from $2.5 million to $9.5 million.  The total annual monetized benefits in 1995
dollars for cancer case  avoidance in Louisiana and Texas combined is $1.1 million to $22.3 million,
with a range of midpoint values from $3.4 million to $13.3 million.

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6-24	
Exhibit 6-19    Estimated Annual Monetized Benefits of Cancer Case Avoidance for Louisiana and
               Texas Recreational Anglers and Their Households3
Target Population
10% of Recreational
Anglers & Households
90% of Recreational
Anglers & Households
Total
Consumption
Rate
High
Average
Total
$ Million Saved/Annual Cancer Cases Avoided
20% MLECCb-c
$2.48C ($0.75-$4.20)
$0.96($0.35-$1.57)
$3.44($1.10-$5.77)
75% MLECCb-c
$9.5 ($2.98-$16.0)
$3.77($1.23-$6.31)
$13.3 ($4.21-$22.3)
* Cancer case avoidance valued at $2.5 million to $13.4 million per case (1995 dollars).
b MLECC—Maximum Lifetime Excess Cancer Cases; reduction to 20% and 75% of calculated
  MLECC to account for food sources from other than contaminated sites.
c Midpoint (range).
6.3   Evaluation of the Assessment
      The assessment and monetized risk reductions projected for the selected option is a first-order
analysis based on available data.  The assessment is qualified both by the paradigm used in its
conceptual approach and the extent and quality of the data used as input to the risk assessment. This
assessment uses a modeling approach for which data and analytical requirements include: effluent Ra226
and Ra228 levels, surface water dispersion modeling, and aquatic bioconcentration factors. Data on
effluent Ra226 and Ra228 levels in produced water are sufficient for this assessment.  Input data and the
surface water model used to estimate available dilution are adequate for this assessment. Modeling is
based on operational and environmental data (e.g., discharge rate, effluent density, pipe diameter, port
location, water depth, current speed, salinity, etc.) representing site-specific conditions for major
deltaic pass dischargers and average or typical conditions for Louisiana open bay or Texas individual
permit applicants.  In these latter two cases, only a subset of the subcategory-wide variation in these
parameters is modeled.  However, the parameters selected are believed to adequately represent the
industry as a whole. The model selected (CORMIX Version 2.1) is considered satisfactory without any
further modification for the type of discharge conditions that are thought to represent the typical case,
specifically, where the discharge plume impacts the bottom of the receiving water body.

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                                                                                  	6-25
      Human exposure assessments are then based on consumption patterns of these seafood product
types (fish, crabs, and oysters) and projected radium levels in finfish, crustaceans, and bivalves.
Tissue levels of radium in seafood from model projections are based on available BCF data specific to
these three seafood groups.  Average and upper 95th percentile values were used for this assessment.
BCFs are available for all three seafood groups, but supporting data also are not extensive.  In addition,
BCFs only apply to water-mediated bioaccumulation. Produced water impacts are largely sediment-
related, and the BCFs used do not account for sediment routes of exposure (ingestion; higher pore
water concentrations than projected by surface water dilution models) or ingestion of contaminated food
by finfish, crabs, or oysters.

      Consumption data are derived from consumption patterns in the Gulf of Mexico region.  These
data are applicable and sufficient for this assessment. The methodology for risk estimation and risk
reduction monetizations are based on standard EPA methodologies. Agency specified carcinogenic
potency factors, exposure durations, and valuations of life estimates are used.  Discussion of these
factors are found the EPA guidance that is cited previously in this section of the WQBA.

      One consideration that requires more data than are currently available relates to the time-course
of recovery after produced water discharges have ceased. The physical and biological response
kinetics of Ra226 and Ra228 are not known in sufficient detail to assess the rate of recovery of affected
ecosystems. Dispersion and decay: of these pollutants; and sedimentation, capping, and complexation
phenomena will reduce their availability to consumed species.  Depuration in formerly exposed
organisms will occur.  However, the rates of these processes are largely unknown. For this rule, total
impacts and recovery are calculated and averaged as a snap-shot, i.e., assumed to occur over a one-
year time period.  This renders the ecological and human health benefits assessment comparable to the
technology and economic assessments as all use annualized (i.e., average) costs.

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                                                                                           7-1
       7. ECOLOGICAL IMPACT ASSESSMENT AND MONETIZED BENEFITS

      To assist in characterizing the benefits of the final coastal oil and gas effluent guideline, the
WQBA assesses projected ecological impacts resulting from current technology discharges from certain
alternative baseline dischargers (i.e., Louisiana open bay and Texas individual permit applicant
dischargers). Projections of impacts are based on a study conducted in a shallow coastal embayment in
Texas and, as such, are not being used to assess impacts from the current requirements baseline
dischargers (i.e., major deltaic pass dischargers in Louisiana or facilities in Cook Inlet, Alaska).
Projected impacts from current technology discharges are then compared to projected impacts resulting
from discharges subject to the limitations of each regulatory option under consideration for the final
rule.  The improvement attributable to each option (i.e., the reduction in impact) is quantified and
monetized for comparison to the costs associated with implementation of each option.

      A series of ecological impact analyses, based on a study of a produced water outfall to a coastal
embayment in Texas, is presented below.  This particular study is used as the basis for these analyses
because of the extent of its spatial and temporal data on benthic community measures that are required
to develop estimates of ecological impact.  Based on estimates of the produced water flow at this
facility and its associated ecological impacts, and application of estimates of ecological valuation that
also are developed in this section, monetized ecological benefits are estimated for the IGF and zero
discharge (selected) options for Louisiana open bay and Texas permit applicant dischargers.
      Data quantifying the impact of produced water discharges on benthic community status para-
meters with respect to a spatial standard are required for these analyses.  The Trinity Bay study
(Armstrong, et al., 1977) was selected as the case study example for estimating and projecting impacts
                                l
because it is the most thorough and extensive study conducted on produced water impacts at a shallow
water, Gulf of Mexico site. The study was conducted over nearly two years and consisted of monthly,
synoptic sediment chemistry and biology sampling and analysis at 15 stations.  The study site is
                                l
generally homogenous in its physical and ecological characteristics within the scale of the study, and is
thus not confounded by boundary effects.

-------
7-2
      The approach used in this section uses the Trinity Bay study to quantify the acreage affected by a
produced water discharge. The acreage affected by Louisiana open bay and Texas individual permit
applicant discharges of produced water are proportionately scaled to total produced water flow and
changes in effluent quality (effluent naphthalene concentrations).  Resource valuation estimates (per
acre) are then applied to project monetizations of ecological benefits.
7.1   Description of the Trinity Bay Study

      A study of a coastal subcategory oil and gas production facility located in Trinity Bay, Texas has
been performed (Armstrong et al., 1977). This 21-month study was conducted at the C-2 separator
platform located in Trinity Bay, Texas from April of 1974 to December of 1975.  The separator
platform was located in 8 feet of water, with a range in the bay of 6 feet to 9 feet.  The authors noted
that during the study, the platform discharged 4,100-10,000 bpd of produced water (midpoint = 7,050
bpd). The outfall was located 3 feet from the bottom. Sediment texture in the study area was uniform,
with all stations classified as silty-clay except one that was classified as sandy-silty-clay. From
November of 1974 to April of 1975, a temporary second outfall was used,  located 900 feet NW of the
C-2 separator outfall. This outfall was located within 400 feet of sampling station A-l.

      Sediment benthic community analyses and sediment total naphthalenes (naphthalene through
dimethyl naphthalenes) analyses were performed monthly (except for April and November of 1975).
Benthic grab samples (0.023 m2) were obtained at 15 stations located from 50 feet to 19,000 feet from
the C-2 separator along 3 transects (Exhibit 7-1).  Benthic total abundance  and species richness were
assessed.  A 0.5 mm sieve was used to separate benthic organisms from April to November of 1974,
when the sieve size was reduced to 0.25 mm for the remainder of the study. Sediment naphthalene
analyses also were performed using two methods.  From April to November of 1974, sediment was
obtained by scooping the top layer of sediment from the grab sampler; a 5°C/24-hour, n-hexane static
extraction protocol was used.   Beginning in December of 1974, a core sampler was used for obtaining
sediment samples, and in addition to the 5°C/24-hour static extraction, a 20°C/72-hour extraction with
continuous shaking was performed.  Total naphthalenes were determined by UV spectrophotometry.

      The authors observed a distance-dependent decrease in total sediment naphthalenes.  Exhibit 7-2
presents a scatter plot of sediment naphthalenes concentrations versus distance for 20°C/72-hour

-------
                                                                                          7-3
Exhibit 7-1.     Map of Trinity Bay Showing Location of C-2 Separator Platform and Extent of
               Transects
                                                                           LAKE       f.
                                                                       .  ^\  ANAHUAC :••'••
                               T  R I  N  /  T  Y

-------
7-4
Exhibit 7-2.
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Scatter Plot: Sediment Naphthalene vs. Distance from Outfall, All Samples, 20°C/72hr

Extraction
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        _ Mean concentrations
                                            1000                   10000

                        Distance (m)


                               _s_ All Stations, 20C/72h Extraction

-------
                                                                                           7-5
extraction data.  Exhibit 7-3 presents a plot of mean sediment naphthalene concentrations versus
distance for both 5°C/24-hour and 20°C/72-hour extractions.  Exhibit 7-4 presents these same data for
both extraction protocols in a log:k>g format.  The authors noted a reasonably consistent, 3- to 5-fold
higher level of extracted naphthalenes hi samples treated at 20°C for 72 hours.  GC-MS analyses
indicated the 20°C/72-hour extraction method recovered 90-95% of the total naphthalenes.

      Benthic abundance and species richness were found to be correlated with total sediment
naphthalenes (Exhibit 7-5).  The 50-foot station was devoid of biota,  and stations within 500 feet were
severely depressed (< 25% peak levels for both community parameters).  These observations were
thought surprising because analysis of receiving water samples at the 50-foot station indicated a 2,000-
fold dilution of naphthalene compared to effluent levels.  However, although effluent samples showed a
total naphthalenes level of 1.62 ppm while the 50-foot station water column samples showed 1.6 ppb
total naphthalenes, the 50-foot station sediment samples showed total naphthalenes of 18.7 ppm.

      The authors also observed that the temporary second outfall produced a rapid buildup of sediment
naphthalenes at Station A-l, which remained unusually high at least 6 months after the discharge from
this outfall ceased.  The authors noted the use of this second outfall may have created an additional
depressed area equal to that of the single platform outfall, rather than minimizing the effect of the
single outfall.

7.2   Case Study  Approach

7.2.1 Ecological Impact Assessment
      This study site had sufficient temporal and spatial data, both field and operational, to assess
benthic community impacts from this facility. Spatial impact assessments are developed for benthic
abundance and species richness. Because the sieve size was changed during the course of the study,
two sets of analyses are performed, one for the 0.25 mm mesh size sieve and one for the 0.50 mm
mesh size sieve. Based on field measurements of benthic abundance and species richness at various
distances from the outfall (Exhibit 7-6), linear interpolations of reductions in these community
                               |
parameters are derived for the study area.  Exhibits 7-7 and 7-8 present benthic abundance and species
richness versus distance for the 0.50 mm sieve and the 0.25 mm sieve sizes, respectively.  Exhibit 7-9

-------
7-6
Exhibit 7-3.    Mean Sediment Naphthalene vs. Distance from Outfall, Distance-Averaged
     25
    20
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 Thousands

Distance (m)
                      5C/24h Extraction
         20C/72h Extraction

-------
                                                                                7-7
Exhibit 7-4.    Log Mean Sediment Naphthalene vs. Log Distance from Outfall, Distance-Averaged
     0.1
         10
100
1000
                                    Distance (m)
                       5C/24h Extraction   _s_ 20C/72h Extraction
10000

-------
7-8
Exhibit 7-5.   Fractional Benthic Abundance and Species Richness vs. Sediment Naphthalenes


    1.2  i	——•	1  1-2
                                                                             1
                                  10           15
                          Sediment Naphthalene (mg/kg)
20
             Fractional Species Richness  _s_ Fractional Abundance

  Annual averages, 1.0 = max avg annual value
  All stations included
                                                                             0

-------
                                                                                          7-9
Exhibit 7-6.   Trinity Bay, Texas Produced Water Outfall Fractional Abundance and Species Richness
              Data
Distance
Station (m)
Total Abundance and Species Richness -
1 15.2
AO 76.2
X 76.2
Al 152
A 152
1.5 183
2 457
B 457
A2 686
C 915
3 915
4 1,677
O 3,963
5 5.183
A3 5,793
Total Abundance and Species Richness -
1 15.2
X, AO 76.2
A, Al 152
1.5 183
B,2 457
A2 686
3, C 915
4 1,677
D 3,963
5 5,183
A3 5,793
Relative Abundance and Species Richness
1 15.2
X. AO 76.2
A, Al 152
1.5 183
B, 2 457
A2 686
3, C 915
4 1.677
D 3.963
5 5,183
A3 5,793
Area @ unit (100%) biol. density
(nrx 100% relative biol. density)
Area @ fractional biol. density
(m-x 100% fractional density)

Areally- reduced biol. density
Acres within impact radius
Acre -equivalents affected
0.50 mm Sieve
Average Average
Abundance Spp Richness
All Stations
7 1.78
10 1.11
1 0.56
6 2.22
7 2.00
8 1.56
21 2.56
17 3.78
18 3.00
39 4.11
26 4.00
23 3.22
43 5.33
28 3.33
19 2.00
Distance - Averaged Stations
7 1.78
5 0.83
7 2.11
8 1.56
19 3.17
18 3.00
33 4.06
23 3.22
43 5.33
28 5.33
19 2.00
— Distance - Averaged Stations
0.16 0.33
0.12 0.16
0.16 0.40
0.20 0.29
0.44 0.59
0.43 0.56
0.77 0.76
0.55 0.60
1.00 1.00
0.66 0.62
0.44 0.38
49.364.647 49,364,647

37.958.835 39.237.664

23.1% 20.5%

12.192 12.192
2.817 2.501
0.25 mm
Average
Abundance

58
110
87
106
182
253
472
462
677
684
592
703
491
510
596

58
98
144
253
467
677
638
703
491
510
596

0.08
0.14
0.21
0.36
0.66
0.96
0.91
1.00
0.70
0.73
0.85
8.830.713

8,021,322

9.2%

2.181
200
Sieve
Average
Spp Richness

4.09
9.27
6.36
6.18
9.55
11.36
10.45
13.00
13.91
15.45
12.82
12.45
14.55
10.36
11.00

4.09
7.82
7.86
11.36
11.73
13.91
14.14
12.45
14.55
10.36
11.00

0.28
0.54
0.54
0;78
0.81
0.96
0.97
0.86
1.00
0.71
0.76
49.364,648

46.070.207

6.7%

12,192
817

-------
7-10
Exhibit 7-7.    Fractional Abundance/Species Richness vs. Distance, 0.50 mm Mesh Sieve Size
                     123456
                                             Thousands
                                      Distance from Outfall (m)

              . Abundance, 0.50mm mesh sieve        0  Species Richness, 0.50mm mesh sieve

-------
                                                                                        7-11
Exhibit 7-8.   Fractional Abundance/Species Richness vs. Distance, 0.25 mm Mesh Sieve Size
                                             3           4
                                             Thousands
                                      Distance from Outfall (m)
              . Abundance, 0.25mm mesh sieve
Species Richness, 0.25mm mesh sieve

-------
7- 12
Exhibit 7-9.   Fractional Abundance vs. Distance, 0.25 mm and 0.50 mm Mesh Sieve Size
                  . Abundance, 0.50mm mesh sieve
       3456
       Thousands
Distance from Outfall (in)

             ,  Abundance, 0.25mm mesh sieve

-------
                                                                                          7- 13
presents the results of both sieve sizes for abundance versus distance; Exhibit 7-10 presents the same
data for species richness versus distance.

      The reductions in benthic abundance and species richness are expressed as an aggregate,
normalized, percentage reduction in benthic abundance and species richness within the observed impact
radius.  The impact radius is defined as the minimum distance at which stations exhibit 100% benthic
abundance or species richness.  This normalized percentage reduction in benthic abundance or species
richness, when integrated over the total area circumscribed within the impact radius, determines the
reduction in areal productivity.  This reduction in areal productivity is expressed as the number of
equivalent acres affected (i.e., a 10% reduction over 500 acres would result in 50 equivalent acres
affected). Based on the different sieve sizes used and the differences in benthic abundance and species
richness as community impact measures, a range of equivalent acreage affected is developed.  Details
of the calculations used to derive ecological impacts are provided in the memorandum from G.
Petrazzuolo to the record, dated October 30, 1996.

      Analysis of this study in the proposed rulemaking was based on naphthalene concentration as
measured in 1975.  However, comments on the proposed rulemaking suggested that because the study
was conducted on effluent discharged prior to EPA's establishment of the Best Practicable Treatment
(BPT) technology for this industry, current technology discharges would contain lower concentrations
of pollutants than the Trinity Bay effluent. As a result, the acreage affected by the Trinity Bay effluent
is adjusted by the percentage difference between Trinity Bay pre-BPT effluent naphthalene
concentration and current technology effluent naphthalene concentrations.  The naphthalene con-
centration for the Trinity Bay study whole effluent is 300 ppb; the current technology effluent concen-
tration is 184 ppb, or 61.3% of the'pre-BPT level.  Thus, for projections of affected benthos for the
current technology effluent, the acreage affected is adjusted to 61.3% of the estimated Trinity Bay
acreage affected.
      The results of this analysis are scaled to the receiving waters for discharges described by USDOE
(1996) for Louisiana open bay dischargers and the Texas individual permit applicant log. This
projection is based on the assumption of receiving water impacts proportional to those observed in this
case study after adjusting for naphthalene reductions. Thus the acreage affected, as determined for this
case study, is proportionated to the estimated total produced water discharge volume for each subset of

-------
7-14
Exhibit 7-10.  Fractional Species Richness vs. Distance, 0.25 mm and 0.50 mm Mesh Sieve Size
                     123456
                                             Thousands
                                      Distance from Outfall (m)

              . Species Richness, O^Omm mesh sieve   0  Species Richness, 0.25mm mesh sieve

-------
                                                                                           7-15
dischargers.  A range of ecological value per acre, based on a review of the literature, is then applied
to the estimated total acreage affected for each state to determine the ecological cost of produced water
discharges.

7.2.2 Ecological Resource Valuation

7.2.2.1 Review of Coastal Wetland Values

      In addition to projecting potential ecological impacts due to current technology dischargers and
the improvement due to the elected option, monetizing such impacts and improvements requires some
valuation of affected wetland resources. A literature review for wetland value estimates was conducted
for MMS (MMS, 1991).  The literature review contains many different ways to value wetlands,
depending on the different uses of these wetlands.  Demonstrating the difficulty in estimating the value
of wetlands, MMS (1991) establishes three broad types of wetland use values.  These values include
on-site use values, off-site use values, and nonuse values.  On-site use values of wetlands are the easily
recognized and priceable benefits that come from wetlands.  On-site use values include hunting,
trapping, and hay and peat production.
      Off-site use values of wetlands are not as easily recognized because these use values do not occur
at the wetlands.  Rather, they are recognized as values associated with other geographic areas. For
example, wetlands are breeding, nesting, and nursery grounds for many species of animals, especially
fish and birds, that occur outside of wetlands.  Off-site use values of wetlands include sport and
commercial fisheries, waterfowl, and fur-bearing animals. Values can be assigned to such off-site uses
of wetlands after the wetlands' dependence of these end uses is established. Nonuse values of wetlands
are benefits that are the most difficult to quantify.  It is difficult,  and in some cases even impossible, to
put a price on the nonuse values of wetlands. Nonuse values of wetlands include:

       •  Biological productivity
       •  Biological diversity
       •  Ecosystem stability
       •  Flood control
       •  Climate control
       •  Water purification

-------
7-16
        •  Pollution filtration
        •  Aesthetic values.

      The following briefly summarizes the different methods of valuing wetlands as identified by
MMS (1991).

Market Price Method.  Estimates the economic value of commercially traded products and services
from wetlands (e.g., peat, hay, hunting rights) on the basis of their market prices. This method does
not deduct market value of other resources used to bring wetland products to market.

Net Factor Income Method.  Estimates the value of wetland resources in commercial production by
estimating the profits of wetland-dependent commercial activities after payments are made to other
factors of production.

Travel Cost (TC) Method. Used to estimate the value of recreational benefits generated by wetlands.
Assumes that the value of a site is reflected in how much people are willing to pay to get there.

Hedonic Pricing—Property Value (PV) Analysis.  Hedonic techniques assume that the price paid for a
commodity is directly related to the supply of the commodity's attributes.  Most common is the PV
approach, which uses variations in property values to reveal implicit values and demand for
environmental amenities.
Contingent Valuation (CV) Method. The only available technique for estimating most nonuse values.
This method questions individuals directly about their willingness to pay (WTP) or willingness to accept
payment.

Valuation (Benefit) Transfer: The Activity Day Method.  Simple transfer:  an activity day valued at one
site is used to value the same activity at the study site.  Values are usually site/location/user specific,
but transfers can be useful for gross estimates of recreational values.

-------
                                                                                          7- 17
Replacement Cost (RC) Method. Estimates the value of a non-market service based on the cost of

substitution.  This involves three steps: estimate level of service provided, identify least cost

alternative, and establish public demand for this alternative.


Damage Cost (DC) Method. Estimates the value of a service based on the cost of damage that may
                                i
result from its loss.  Steps include: assess service level, estimate potential damage, translate to dollar

terms, and identify possible substitute.


Energy Analysis/Biological Productive Method.  Assumes that the value of a good is reflected in the
energy required to produce it.  Values wetlands on the basis of their biological productivity [(kilo
calories of biomass) x (energy price)].

                                I
Opportunity Cost Method.  Proxy value for uncertain wetland functions/services calculated on the basis
of the cost of foregone development values and appropriate least-cost substitutes.


      In the literature reviewed in MMS (1991), generalized unit wetland values range from $424 to
over $200,000 per acre.  MMS (1991)  states that the "emerging consensus" for appropriate wetland
values ranges from $7,000 to $20,000 per acre. However, the value of certain specific uses and
products of wetlands covers a much broader range.  Exhibit 7-11 gives a complete list of wetland value
estimates for the Gulf of Mexico. The  following summary provides ranges of wetland value estimates
for different products and uses of wetlands.
                              Product or Use
                          Commercial fishing
                          Recreational fishing
                         Fur trapping/hunting
                                  Water fowl
         Shellfish (blue crab, shrimp, or oyster)
                   Nonconsumptive recreation
                             Storm protection

           Sum of the above products and uses

 Various total intrinsic/extrinsic wetlands values
       (energy analysis, life support, biological
              productivity, replacement value)
Estimated Value
$34.55 - $l,775/acre
$21 - $559/acre
$6 - $524/acre
$178 - $299/acre
$0.88 - $14/acre
$8 - $270/acre
$0.58 - $767/acre

$48.96 - $18,700/acre

$818-$209,100/acre

-------
7-18


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$608/acre/yr
$939/acre/yr
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$241/acre/yr (1
$352/acre/yr(l
$544/acre/yr(l
$231/acre/yr (1




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$383/acre





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$107 million

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                                                                                           7-19
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"Best estimate"

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-------
7-20

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-------
7-21



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                                                                                          7-23
      Based on the information presented in this review of Louisiana wetlands values, a range of $57 to
$940 per acre per year (median value is $410 per acre per year), in 1990 dollars, is identified and used
as the basis for the ecological monetization developed later in this section. These values are taken from
the total annual value for coastal Terrebonne Parish, Louisiana ($48.96/acre for commercial fishing and
trapping values, $7.84/acre for recreational value, and $0.58/acre for stormwater protection) reported
in Farber and Costanza (1987) and gross benefits (fish and fur harvests; recreational hunting and
fishing) reported in Mumphrey et al., 1978.  The studies reviewed are Costanza and Farber, 1985;
Farber and Costanza, 1987; Gosselink et al.,  1974; Gosselink,  1980; Mumphrey et al., 1978; and
Vora, 1974. These values are used;for the monetization of ecological benefits presented in Section 7.4
ofthisWQBA.

7.2.2.2 Recreational Fisheries, Galveston Bay

      The draft document prepared for the Galveston Bay  National Estuary Program (GBNEP;
                                 I
Whittington et al., 1994),  using contingent valuation and benefit transfer, estimated the annual
economic value of recreational fishing to the Houston-Galveston area using two different data sets:
Texas Parks and Wildlife Department (TPWD) data, and data collected from a mail-only survey
performed by the authors of the report.  The mail-only survey was performed in a five-county region
around Galveston Bay. This survey did not include people who travel to the bay and are not from these
counties, and therefore under-represents the actual value of the recreational fishery.  This survey
estimated 4.5 million recreational fishing days in Galveston Bay, based on the mean number of fishing
days per household.  The mail survey only had a 49% response rate. Thus, the authors assumed that
nonrespondents ranged from zero to half the usage rate of respondents.  Using the range of $25 to $38
(1993 dollars) as the value for a fishing day (Walsh et al., 1992 as cited by Whittington et al., 1994),
the value of recreational fishing in the Galveston Bay ranges from $75 million to  $150 million per year.
     The second data set used to estimate the value of recreational fishing in Galveston Bay was site-
intercept data collected by TPWD. The authors state that this data also may underestimate the
recreational fishery value because not all boats are accessible.  The authors indicate that this number
could be up to 25% higher (McEachron and Green, 1984 as cited in MMS, 1991).  This estimate also
does not take into account fishing done from shore, which could account for an additional 33% to 36%
of the recreational landings along the Texas coast (Campbell et al, 1991 as cited in MMS, 1991).

-------
7-24
Finally, this estimate does not include night fishing from private- and party-boats. Using the TPWD
data, the estimated value of recreational fishing in the Galveston Bay in 1993 was $44 million to $60
million per year.  The authors assume that their survey was a more accurate estimate of the number of
recreational fishing days in the Galveston Bay.  However, when $44 million is increased by 25% to
account for boat access and 35% to account for shore fishing, the resulting range of values is $74
million to $101 million. This range is not far from the estimate by Whittington et al. (1994), especially
because night fishing is not included hi this calculation.

7.2.2.3 Nonconsumptive and Other Recreational Values, Galveston Bay

     The draft document prepared for the GBNEP presents a survey of the value of recreational
boating in the Galveston Bay, not including the economic value of recreational fishing from a boat
(Whittington et al., 1994). Using benefit transfer, the value of a boating day was assumed to be $15 to
$33 (1993 dollars; Walsh et al., 1992 as cited in Whittington et al., 1994). The estimate of the number
of boater days is based on boat registration, commercial marina,  and wet slip data for the area of
Galveston Bay. Data on the frequency of boat use is based on a TPWD report entitled 7990
Comprehensive Outdoor Recreation Plan.  The resulting value of recreational boating in this Galveston
Bay study was estimated to be $25 million to $50 million per year.

     The same document estimates the value of other land-based recreational activities in Galveston
Bay.  These activities include swimming, hiking, picnicking, camping, hunting, and trail walking/
jogging.  A mail-only survey was used to estimate that there were 1,620,000 use days in the Houston-
Galveston area in 1993. This survey assumed that the use by non-respondents was one-half that of the
respondents. The value of land-based recreational activities was  estimated to be $15 million to $50
million per year.
7.2.2.4 Total Recreational Value, Galveston Bay

     The draft document prepared for the GBNEP presents a range of values for all recreational uses
of Galveston Bay. These values were developed by adding the estimates of the values for recreational
fishing, the value of boating to users of the bay, and the value of other recreational uses of the bay.

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                                                                                         7-25
These valuations are summarized in Exhibit 7-12.  For all recreational uses, the estimated value of the
bay ranges from $115 million to $250 million per year.  Based on Galveston Bay acreage of 342,275
acres, derived from an EPA document (EPA, 1994), this represents a range of $336 to $730 per acre,
with a midpoint value of $533 per acre. These range and midpoint values are used to develop estimates
of monetized ecological benefits developed for the Trinity Bay case study.

Exhibit 7-12. Summary of Galveston Bay Recreational Values
Activity
Recreational Fishing
Recreational Boating
Other Recreation
Total Recreational Value
Galveston Bay Acreage
Recreational Value of Galveston Bay
Midpoint Value ;
Value
$75-$150 million
$25-$50 million
$15-$50 million
$115-$250 million
342,275 acres
$336-$730 per acre
$533 per acre
     Nonconsumptive wildlife uses;in Texas and Louisiana were estimated by USFWS (1993a; 1993b).
These uses include observing wildlife, feeding wildlife, and photographing wildlife. In Texas, in 1991,
5.5 million participants over the age of 16, spent up to $878 million on nonconsumptive wildlife uses.
In Louisiana, in 1991, 1.4 million participants over the age of 16, spent $22 million in
nonconsumptive wildlife activities. ;
7.3  Trinity Bay, Texas Case Study Assessment

     Differences in distance-to-background estimates occur between two benthic sieve mesh sizes used
in the study.  The larger mesh size (0.50 mm) results in clear impacts to about 4,000 meters for both

-------
7-26
total benthic abundance and species richness (see Exhibit 7-7). The smaller mesh size (0.25 mm,
which captures smaller and earlier life stage forms) shows a faster recovery for both benthic abundance
and species richness and, for abundance, suggests an impact radius of only 1,677 meters (see Exhibit 7-
8). Comments were received on the appropriateness of these  impact zones for assessing impacts in
Trinity Bay.  Commentors noted these large impact areas result from the inclusion of one stray data
point at 4,000 meters, which exhibited spuriously high community parameters but is used as the "no
effect" benchmark in the assessment and excludes consideration of measurements at the remaining two
control sites.
     Although these commentors may have an arguable point if the data are only considered from a
limited point of view, additional data and analyses and the weight of evidence do not support their
contention.  First, the validity of "control" stations did not appear to be tested in any way. Second, the
4,000-meter station had the lowest sediment naphthalene concentration of the three control stations.
Third, sediment naphthalene levels at all of the control stations ranged from 2.9 mg/kg to 4.5 mg/kg,
whereas the Effects Range Median (ERM, the level at which benthic effects are probable) for
naphthalene is 2.1 mg/kg (Long et al., 1995).  Fourth, even if a "zone of stimulation" is used to
explain the peak in benthic community parameters, it still represents an effluent-mediated impact.
Thus, for the final rule, the same impact areas  are used as developed for proposal.  (See also response
to late comment 1 for further discussion.)

     Projections of benthic impact are, therefore, run for all four scenarios (both total abundance and
species richness for both 0.25 mm and 0.50 mm mesh size data) and are summarized in Exhibit 7-13.
For 0.50 mm mesh size data, benthic abundance/species richness  are respectively reduced 23 % and
21 % within a 3,963-m impact radius, amounting to 2,817 and 2,501 equivalent acres affected.  For
0.25 mm mesh size data, species richness was reduced 7% within a 3,963-meter impact radius, for 814
equivalent acres affected; benthic abundance was reduced 9% within a 1,677-meter impact radius for
200 equivalent acres affected. Thus, the equivalent acreage affected at this case study facility ranges
from 200 to 2,817 acres (midpoint of the extremes = 1,509 acres; mean = 1,583 acres). These  acres
affected are used to determine receiving water  impacts from current technology effluent discharges.

     The current technology effluent discharge was determined in Section 7.2.1 to contain 61.3% of
the Trinity Bay study naphthalene (pre-BPT naphthalene). For  current technology effluent discharges,

-------
	;	7-27
Exhibit 7-13.   Total Abundance and Species Richness for 0.25 mm and 0.50 mm Mesh Size Data and
               Equivalent Acres Affected
Sampling Period
Sieve Size (mm)
Community Metric
Impact Radius (m)
Reduction in Biological Density (%)
Equivalent Acres Affected (pre-BPT)
Equivalent Acres Affected (Current
Technology)"1
4/74-1 l/74a
0.50
Abundance
3,963"
23.1%
2,817C
l,727c'd
0.50
Species
Richness
3,963b
20.5%
2,501C
l,533c-d
12/74-12/75"
0.25
Abundance
1,677"
9.2%
200C
123c,d
0.25
Species
Richnes
s
3,963"
6.7%
814C
499c,d
a Samples taken monthly, except 6/75 and 11/75
b Based on the maximum, distance-averaged community metric
cAcre equivalents based on a linear proportionation of percentage affected and area of the impact radius (i.e.,
 a 10% reduction in abundance over 2;000 acres results in 200 acre-equivalents affected)
d Current technology naphthalene concentration as a % of Trinity Bay, pre-BPT concentration = 61.3%


the projected acreage affected, based on the Trinity Bay study acreage affected,  is adjusted by this

percentage (Exhibit 7-13).
7.3.1   Current Requirements Baseline Dischargers
7.3.1.1 Major Deltaic Pass Dischargers, Louisiana
      The ecological impact assessment presented above is based on data applicable to a shallow bay
ecosystem contiguous with the Gulf of Mexico. It cannot be extrapolated to potential impacts in the

major deltaic passes of the Mississippi River.  Also, because there is a scarcity of data in the literature
on effects of produced water to aquatic systems in fast moving channels or rivers, as well as of the

ecological resources available and exploited in these major deltaic passes,  no ecological assessment of
benefits is conducted for major deltaic pass dischargers in this WQBA.

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7-28
7.3.1.2 Cook Inlet, Alaska

     As stated in the preceding section, the above ecological impact assessment presented is based on
data applicable to a shallow bay ecosystem in the coastal Gulf of Mexico region.  It cannot be
extrapolated to potential impacts in Cook Inlet, Alaska.  There is no study of produced water impacts in
Cook Inlet comparable to the Trinity bay study. Therefore, no assessment of ecological impacts is
developed for  Cook Inlet produced water discharges.

7.3.2   Alternative Baseline Dischargers

7.3.2.1 Open Bay Dischargers, Louisiana

     Using the Trinity Bay baseline estimate, percentage difference in Trinity Bay and current
technology naphthalene concentrations, and projected discharge rates, acreage affected for current
technology effluent ranges from 5,739 to 80,828 acres (midpoint of 43,298 acres) for the 69 open bay
outfalls in Louisiana (Exhibit 7-14).

7.3.2.2 Individual Permit Applicants, Texas

        Using the Trinity Bay baseline estimate, percentage difference in Trinity Bay and current
technology naphthalene concentrations, and projected discharge rates, acreage affected for current
technology effluent ranges from 1,179 to 16,610 acres (midpoint of 8,897 acres) for the 82 individual
permit applicant dischargers in Texas (Exhibit 7-15).
7.4  Trinity Bay-Based Ecological Benefit Monetization Estimates for the Selected BAT
     Option

     As presented earlier in this section, a wetland values range of $57 to $940 per acre per year (with
a median value of $410 per acre per year) is used for this assessment.  This range is based on values
presented in 1990 dollars; in this section of the WQBA these values are escalated by 16.55% to obtain
ecological values in 1995 dollars.

-------
7-29
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                                                                                           7-31
7.4.1   Current Requirements Baseline Dischargers

7.4.1.1 Major Deltaic Pass Dischargers, Louisiana

     As no ecological impact assessment is conducted for major deltaic pass discharges of produced
water, no projection of monetized benefits is performed for these discharges.
                               !
7.4.1.2 Cook Inlet, Alaska

                               \
     As no ecological impact assessment is conducted for Cook Inlet discharges of produced water, no
projection of monetized benefits is performed for these discharges.

7.4.2   Alternative Baseline Dischargers

7.4.2.1 Open Bay Dischargers, Louisiana

     Assuming the full range of wetland values ($57 to $940/acre in 1990 dollars; median ecological
value estimate of $410/acre) and the full range of ecological impact areas affected (i.e., using the
5,739- to 80,828-acre estimates from the adjusted current technology effluent/Trinity Bay study as the
basis for the Louisiana assessment), ecological benefits of the selected zero discharge option in 1990
dollars range from $0.3 million to  $76.0 million, with a midpoint of $38.2 million.  These values
escalate to  a range of $0.4 million  to $88.6 million with a midpoint of $44.5 million presented in 1995
dollars. Assuming the midpoint impact area estimate of 43,298 equivalent acres and the full range of
ecological valuations per acre (i.e., the $57 to $940/acre estimates), ecological benefits of the selected
zero discharge option in 1990 dollars range from $2.5 million to $40.7 million, with a midpoint of
$17.8 million; in 1995 dollars, values range from $2.9 million to $47.4 million with a midpoint of
                               i
$20.8 million (see Exhibit 7-14). ,
7.4.2.2 Individual Permit Applicants, Texas

     Similar to open bay dischargers, assuming the full range of wetland values ($57 to $940/acre in
1990 dollars; median ecological value estimate of $410/acre) and the full range of ecological impact
areas affected (i.e., using the 1,179- to 16,610-estimates from the adjusted current technology effluent/

-------
7-32
Trinity Bay study as the basis for the Texas permit applicant assessment), ecological benefits of the
selected zero discharge option range from $0.07 million to $15.6 million, with a midpoint of $7.8
million in 1990 dollars; in 1995 dollars values range from $0.08 million to $18.2 million with a
midpoint of $9.1 million. Assuming the midpoint impact area estimate of 8,897 equivalent acres and
the full range of ecological valuations per acre (i.e., the $57 to $940/acre estimates), ecological
benefits of the selected zero discharge option range from $0.5 million to $8.4 million,  with a midpoint
of $3.7 million in 1990 dollars; benefits range from $0.6 million to $9.8 million with a midpoint of
$4.3 million in 1995 dollars (see Exhibit 7-15).
7.5  Evaluation of the Assessment

     The Trinity Bay study represents an extensive and useful examination of point source impacts of a
produced water discharge presenting a reasonably coherent collection of chemical and biological impact
data. The study includes several methodological alterations (changes in extraction protocols and
benthie sieve mesh sizes).  These alterations generate uncertainty over the exact extent of potential
impacts (i.e., the distance to a background or reference condition).  The approach used to mitigate this
uncertainty hi the WQBA is to present the analysis in terms of a range of possible impacts.

     An issue with respect to the state-wide impact estimate is the central assumption that impacts will
be linearly related to flow.  This assumption cannot be readily tested with available data.  However, the
case study presented data that indicated when the discharge flow was separated to two outfall locations,
a second focus of impact quickly developed and did not quickly attenuate. These data support the
assumption that impacts are generally related to flow, although they do not unequivocally prove the
validity of this assumption. This case study appears to be a reasonable basis for assuming impact from
outfalls in Texas, based on the general nature of receiving waters in Texas (i.e., shallow bays).  Its
reasonableness for estimating impacts in certain receiving waters in Louisiana (e.g., river passes and
marshes)  is less certain.

     With respect to the monetization of ecological impacts, a factor not explicitly considered is
benthie:\vater column coupling.  The assumption of this WQBA is that the total recreational use value is
applied to benthie acreage that is 100% affected.  This probably is not the case for certain recreational
values, e.g., for hiking or bird-watching values.

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                                                                                         7-33
     EPA lacks data to estimate how quickly biological resources would recover following
implementation of controls, but calculates total benefits assuming they are fully realized.  The temporal
dynamics of both impacts and benefits assessments are an issue relevant to the human health risk
assessment (and to the projected ecological benefits assessment, discussed below, as well).  For the
assessments of benefits in this WQBA, the methodology uses a one year "snap-shot" to be consistent
with the methodology for estimating the costs of the rule. However, this approach can be interpreted to
imply that all benefits are restored within a one-year time-frame. While this assumption may be true in
some cases, it will not be valid in all cases.  Few data on recovery times exist on produced water
impacts.  However, some data indicate recovery times (as measured by sediment chemistry alterations)
may be as long as several years.  Thus, allocating the full value of annual monetized benefits within
one year following cessation of produced water discharges may appear to overestimate the potential
annual benefits in cases where incomplete recovery has occurred.  This analysis does not attempt to
identify or allocate benefits on a yearly basis, but merely averages total benefits so that benefits may be
compared to costs that are developed using the same approach.
     The temporal dynamics of produced water impacts are complicated, and data scant.  For cases in
which impacts are incompletely recovered within one year (and benefits commensurately reduced to the
level of recovery which has occurred), a logical conclusion is that impacts are likewise extended
beyond the one-year time-frame. Thus, a consideration of total impact would include impacts not only
occurring during the one-year period at issue, but also include any impacts occurring that year from
previous discharges, as well as impacts from discharges during this period that may be expected to
occur beyond the year. Thus, the two processes of impact and recovery are coupled, move in opposite
directions to each other, and have very large uncertainties associated with their understanding for
produced water discharges.

-------

-------
                                                                                          -1
         8. QUANTIFIED, NONMONETIZED WATER QUALITY BENEFITS,
                                 COOK INLET, ALASKA
8.1  Pollutants of Concern and Levels in Fish Tissue

     There is little tissue data available with which to assess the risks from consumption of fish and
shellfish from Cook Inlet. The public comments to the proposed regulation provided references to two
studies of contaminant concentrations in fish tissue (ENRI, 1995 and Arthur D. Little, Inc, 1995).
These studies are described below. In addition, personnel at the Alaska Department of Fish and
Game's Subsistence Division, and the National Marine Fisheries Service were contacted, but no
additional data on fish and shellfish were obtained.

     One of the available studies of contaminant concentrations in Cook Inlet was conducted by the
University of Alaska's Environment and Natural Resources Institute (ENRI, 1995) in 1993. This study
analyzed the occurrence of petroleum hydrocarbons, naturally occurring radioactive materials, and
trace metals in water, sediments, and biota (mussels). Composite samples of approximately 30 mussels
were taken from six sampling stations on the eastern and western sides of lower Cook Inlet.

     The ENRI study found very low levels of PAH in four of six mussel samples (6 sites).  For
individual target PAHs, the mussels with detectable naphthalene concentrations came from the western
side of the inlet. However, the study authors concluded that concentrations were so low that they did
not point to a pattern depicting hydrocarbon loading in tissues from of any point source of hydrocarbon
input (ENRI, 1995).  The authors also found no anomalous trends evident from the metals
concentrations in the mussel samples (ENRI, 1995).

      Another study by the Cook Inlet Regional Citizens Advisory Council (RCAC) was conducted as
part of an environmental monitoring program to determine the impact of oil-industry operations in
Cook Inlet (Arthur D. Little, Inc., 1995).  The pilot study included monitoring for contamination in
sediments and caged mussels in 1993. Caged mussels were attached to a produced water outfall in
Trading Bay and at an up current reference site, and retrieved one month later.  The mussel tissue
samples were analyzed for total hydrocarbons and several individual PAHs. Concentrations of

-------
8-2
petroleum hydrocarbons in the mussel tissue were found to be low, and within the range of
concentrations observed hi organisms from unpolluted offshore environments (Arthur D. Little, Inc.,
1995).

      Mussel data may provide an upper bound on contaminant concentrations likely to be found in
other shellfish.  However, the data are insufficient to assess risk from consumption of fish because
mussels have much higher bioaccumulation rates.  Therefore, a risk assessment was not conducted for
Cook Inlet.

8.2   Contaminants of Concern

      Exhibit 8-1 lists the contaminants found in produced waters and drilling fluids and drill cuttings.
Also shown in the table are the pollutants for which mussel tissue contaminant data are  available from
the ENRI study. The analysis focused on the contaminants for which data were available from the
ENRI study and for which the tissue concentrations found in mussels could be of concern for toxicity to
mammals via a consumption pathway (shown in the last column of Exhibit 8-1).  These contaminants
are arsenic, cadmium, chromium, copper, lead, mercury, zinc, and naphthalene.

      The status of arsenic, cadmium, chromium, copper, lead, mercury, zinc, and naphthalene with
respect to their human toxicity potential is shown in Exhibit 8-2.  As can be seen from Exhibit 8-2,
cancer slope factors and oral reference doses are  not available for several of the contaminants; these
contaminants could not be included in the analysis.
8.3   Tissue Contaminant Concentrations

      Exhibit 8-3 provides the measured tissue contaminant concentrations from the ENRI study for the
pollutants with human toxicity potential that are presented in Exhibit 8-2.  Concentrations for metals
were converted to a wet weight basis assessment assuming that mussels are 85% water (Helder Costa,
Inchcape Testing Services, personal communication, June 1996).

-------
                                                                                         8-3
Exhibit 8-1.    Pollutants of Concern in Drilling and Production Discharges
Pollutant Name
Present in
Drilling Fluids
and Drill Cuttings
Present hi
Produced Water
Analyzed in ENRI
Study
Data on
Toxicity to
Mammals
Conventional Pollutants
TSS
Oil and Grease
X
X :
X
X




Priority Organic Pollutants
2,4-Dimethylphenol
Anthracene
Benzene
Benzo(a)pyrene
Ethylbenzene
Fluorene
Naphthalene
Phenanthrene
Phenol
Toluene





x
X
X


X
X
X
X
X

X

X
X
X
X
X
X
X

X
X








X



Priority Metal Pollutants
Cadmium
Mercury
Antimony
Arsenic
Beryllium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Thallium
Zinc
X
X :
X
X
X '
X
x
X
X
X
x ;
X
x
X




X
X,
X
X

X

X
X
X
X
X
X
X
X
X
X

X
X
X
X
X

X

X
X
X




X
Nonconventional Pollutants
Aluminum
Ammonia
Barium
Benzoic Acid
x

x

X
X
X
X
X

X






-------
8-4
Exhibit 8-1.   Pollutants of Concern in Drilling and Production Discharges (Continued)
Pollutant Name
Present in
Drilling Fluids
and Drill Cuttings
Present in
Produced Water
Analyzed in
ENRI Study
Data on
Toxicity to
Mammals
Nonconventional Pollutants (continued)
Boron
Calcium
Chlorides
Cobalt
Hexanoic Acid
2-Hexanone
Iron
Magnesium
Manganese
2-Methylnaphthalene
Molybdenum
n-Alkanes
o-Cresol
p-Cresol
Steranes
Strontium
Sulfur
Tin
Titanium
Triterpanes
Total Xylenes
Vanadium
Yttrium
Radium 226
Radium 228
Alkylated Benzenes
Alkylated Naphthalenes
Alkylated Fluorenes
Alkylated Phenanthrenes
Total Biphenyls
Total Dibenzothiophenes






X










X
X






X
X
X
X
X
X
X
X
X
X
... ...x- 	 -
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X












X

X









X












































-------
Exhibit 8-2.     Human Toxicity Potential of the Contaminants of Concern
                                                                                                         8-5
Pollutant Name
Arsenic (inorganic)
Cadmium
Chromium (VI) ;
Copper
Lead
Mercury
Methylmercury
Zinc
Naphthalene
Cancer
Classification1
A
Bl2
A2
D2
B22
D2
C
D2
D2
Oral RFD
Availability
Yes
Yes
Yes
No
No3
No4
Yes
Yes
No
                        1 U.S. EPA cancer classifications:
                           A   Human carcinogen
                           B   Probable human carcinogen
                           Bl  Limited evidence of carcinogenicity in humans
                           B2  Sufficient evidence of carcinogenicity in animals with inadequate or
                               lack of evidence in humans
                           C   Possible human carcinogen
                           D   Not classifiable as to human carcinogenicity.
                        2 No oral slope factor available.

                        3 RfD workgroup determined that some effects occur at levels so low as to
                         be essentially without threshold; thus, no RfD has been developed (EPA,
                         1996b).      ;

                        4 RfD available from Health Effects Assessment Summary Tables (HEAST)
                         (EPA, 1993c).;

-------
8-6
Exhibit 8-3.    Tissue Contaminant Concentrations in Mussel Samples from Cook Inlet
Pollutant Name
Naphthalene
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Zinc
Dry Weight Basis

0.33-0.59 Afg/g
1. 76-6.67 /zg/g
9.3-192.0 Atg/g
7.7-22.9 A*g/g
12.8-70.4 A
-------
                                                                                           9-1
                     9.  PRODUCED WATER LITERATURE REVIEW

9.1   Summary of the Produced Water Literature Review

      A literature review is presented to identity field studies for assessing impacts from coastal
produced water discharges.  Queries from electronic databases, trade associations, and personal
contacts with state and federal agencies and sources were used to  identify potential citations. Studies
were obtained and reviewed to characterize the nature, extent, and duration of potential impacts from
coastal discharges of produced water.  From this review, impacts from organic and metal pollutants
                                 1
(Exhibit 9-1) and radiochemical pollutants (Exhibit 9-2) are summarized. Abstracts of the selected
studies follow the summary tables.
                                 !
                                 I
      A total of 30 study sites (17 sites in Louisiana and 13 sites in Texas) are summarized. Of these
30 study sites, 17 sites (3 in Texas and 14 in Louisiana) are in relatively low energy locations (marshes,
canals, etc.) and 13 sites (9 in Texas and 5 in Louisiana) are in relatively high energy areas (bayous,
river distributaries, open bays/lakes, etc.).  Also, 17 wetlands locations are included in the 30 study
sites reviewed. Of these 17 wetlands sites,  8 are saltmarsh sites and 9 are fresh or brackish marsh
sites. For both groups of saltmarsh and  fresh/brackish marsh sites,  10  sites are located in Louisiana
and one site is located in Texas.  Water depth is reported for 21 study sites; 17 are in depths less than 3
meters.  Of these 17 shallow water study sites, 7 sites are in Texas,  and 10 sites are in Louisiana.  The
remaining 4 sites, located in waters greater  than 3  meters, are all  in Louisiana.

      Most studies that examined impacts of produced water discharges on normal estuarine salinity
gradients have documented effects.  Typical salinity effects were detected between 100 and 300 meters
                                 I
from the discharge(s).  However, in one dead-end canal, a salinity effect was detected to 800 meters
from the discharge.
      Water column hydrocarbon and metals effects were generally apparent near the discharges, often
elevated as far as 1,000 meters or more, and in one instance to 1,800 meters. Sediment hydrocarbon
impacts typically were detected as far as 100 to 300 meters from the discharge, and were detected at
distances over 1,000 meters from discharges at several sites.  Sediment metals impacts also show a

-------
9-2
distance-dependent relationship. A study of two open bays in Louisiana indicates PAH and metals in
sediments exceed sediment quality criteria as described by Long et al. (1990 and 1995 as cited in
USDOE, 1996). Metals and PAHs exceeded the Effects Range Low (ERL; lower tenth percentile for
biological effects) or the minimal effects range and PAHs exceeded the Effects Range Median (ERM;
fiftieth percentile for biological effects) or the possible effect range.

      Impacts to biota usually showed a spatial correlation to the discharge (i.e., depressed community
structure such as abundance or diversity).  Sediments near outfalls (< 50 feet) have been shown to be
virtually devoid of organisms; within 500 feet of outfalls, benthic fauna have been shown to be severely
depressed (< 25% peak abundance at farther distances).  Caged organism studies had highly variable
results, including high control mortality. Statistically significant benthic biotic impacts were detected
from 80 meters to over 1,000 meters from the discharge(s). Whole effluent  toxicity risk assessment for
69 outfalls in Louisiana indicated 23% of effluents exceed the acute LC50 value for mysids and
sheepshead minnows at a 50-foot mixing zone.  At 200 feet,  18% exceed LC50 values and 57% and
56% exceed chronic NOEL for survival and growth-inhibition, respectively.
      Radiochemical impacts on water column and sediments were variable, but generally limited to
close proximity to the discharge (background levels were often unknown at the study sites). Indigenous
biota were generally found to have detectable levels, but again, background levels were generally not
known. Caged organisms (deployed for 14 days) showed bioaccumulation occurring as far as 350
meters from the discharge.

-------
                                                           9-3
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-------
9-4
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-------
                                                              9-5
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-------
                                                                                    9-7
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-------
9-8

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9-10






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                                                                                  9- 11
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9-12
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                                                                                        9-13
9.2   Summary of Coastal Studies Cited

Author and Title:  USDOE.  1996.  Final Report: Risk Assessment for Produced Water Discharges to
Louisiana Open Bays. Prepared by Brookhaven National Laboratory. 145 pp.
                                I

Study Overview: A risk assessment was conducted on discharges of PW to open bays of Louisiana.
The authors approach was to model and compare available field data taken from a partially completed
field study to data extracted from Louisiana Department of Environmental Quality (DEQ) permit files
on produced water discharges. Over a one week sampling effort for two discharges, metal and PAH
concentrations in sediments and radium concentrations in the effluent and edible biota were examined
in the field study portion of this report.  Also, a three month telephone and intercept survey produced
fish ingestion rate (g/d) data for recreational fishermen and their families. Additional chemical and
radionuclide data analyses, location data, water depths, and produced water discharge flow rates were
obtained by DOE from LDEQ permit files. The CORMIX Expert System was used to model dilutions
at 50-foot and 200-foot mixing zonjes for water quality standards comparisons.
                                                              \
                                                              \
The data were used to conduct:  (1) a probabilistic risk assessment, (2) an ecological risk assessment
for radionuclides, (3) a human health risk assessment for chemical contaminants, and (4) an ecological
risk assessment for chemical contaminants and effluents.
Summary of Results: Using Monte Carlo risk assessment method and data from radium
concentrations in fish (field study and modeling), fish ingestion rates (Steimle, 1996), and risk factors
for cancer mortality, the author reported the 95th percentile individual lifetime cancer risks for both
DOE field study sites (DOE sites) as less than 1 x 10'5 and the 95th percentile for continuing open bay
dischargers (LDEQ permit files) as 4.3 x 10'6.  In their screening analysis, the authors reported a mean
risk from contaminated fish of 6.2 x 104 and a maximum of 1.6 x 10"3 individual lifetime fatal cancer
risks for continuous dischargers.  The authors used concentrations of radionuclides measured in the
effluent at the two DOE sites and LDEQ permit files to determine possible impacts on aquatic
organisms. Using screening dose-rate factors developed by IAEA, 1988, the authors determined that
none of the predicted doses to aquatic organisms exceeded the range of 0.1 to 24 mSv/d which is
associated with a potential for only minor effects on organisms.

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Using the EPA approach to estimating risks of toxic materials and carcinogens, the authors conducted a
human health risk assessment screen for metals and organic compounds.  Results of a quantitative
assessment indicated that cadmium was the only compound in open bay discharges that exceeded oral
reference dose values.  Benzene had a mean value of 1.6 x 10'6 and a 95th percentile value of 7.4 x 10'6
for incremental individual lifetime risk of cancer mortality.

The authors performed three ecological risk assessments:  a screening assessment of chemical toxicity
to benthic biota, an assessment of potential toxicity of individual produced water  components to fish
and crustaceans in the water column, and an assessment of whole effluent toxicity to fish and
crustaceans.  Sediment concentrations were compared to sediment quality criteria values.  Arsenic and
nickel were measured hi excess of the Effects Range Low value (ERL-minimal effects range; see Long,
1990; 1995) up to 500 m and  1000 m from discharge, respectively. Total PAHs  and five
(acenaphthene, fluorene, phenenthrene, benzo(a)anthracene and fluoranthene) and four (anthracene,
chrysene, dibenzo(a,h)anthracene and pyrene) individual PAHs in excess of the ERL were measured up
to 300 m and 100 m from discharge, respectively.

The total PAHs, high molecular weight PAHs, and six individual PAHs (chrysene, benzo(a)anthracene,
benzo(a)pyrene, dibenzo(a,h)anthracene, fluoranthene, and pyrene) in excess of Effect Range Median
value (ERM-possible-effects range; Long, 1990;  1995) were also measured near the discharge.  The
concentrations above the ERL value but less than the ERM value "represent a possible-effect range
within which effects would occasionally occur," while the concentrations above ERM value "represent
a probable effects range within which effects would frequently occur."

Predicted water concentrations of continuous dischargers exceeded acute water quality standards for
copper,  lead, nickel,  silver, and zinc.  Chronic water quality standards were exceeded for antimony,
cadmium, copper, lead, mercury, nickel, silver, zinc, and phenol.
Whole effluent toxicity risk assessment for LDEQ-permitted discharges was determined by modeling
effluent discharges to determine 50- and 200-foot mixing zones, then applying the reported acute and
chronic LCSOs and chronic NOEL values to determine a ratio of modeled concentration versus effect
levels. At 50 feet, 23% exceed their LC50 values for mysids (17%) and sheepshead minnows (6%).
At 200 feet, 18% exceed the LC50 values for the same organisms (mysids 15%, and sheepshead

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                                                                                          9- 15
minnows 3%). Chronic toxicity was estimated at only 200 feet, where 57% exceed chronic lethality
values and 56% exceed growth inhibition values.

Author and Title:  Rabalais, N.N., B. McKee, and D. Reed. 1991.  Fate and Effects of Nearshore
Discharges of OCS Produced Waters. Prepared for the U.S. Department of the Interior, Minerals
Management Service, Gulf of Mexico OCS Regional Office.  Three Volumes - Executive Summary,
337 pp. Technical Report, and Appendices.

Study Overview:  An extensive chemical and biological assessment of seven produced water
discharges in coastal Louisiana was conducted. The produced water that is generated by oil and gas
production activities on the outer continental shelf (OCS) was the specific target of the study. This
study expanded on the initial assessment by Boesch and Rabalais (1989) by increasing the temporal and
spatial studies of three areas and also studied different areas (including an abandoned site) representing
a larger cross section of discharge types and configurations.

At each study area, produced water and the near bottom water of the receiving water column were
examined for contaminants, including salinity, hydrocarbons, trace metals, radionuclides and sulfides.
The top 10 centimeters (cm) of surficial sediments were sampled at all stations along a gradient away
from the discharge for interstitial salinity, hydrocarbons, trace metals, and radionuclides (sediment
cores were also taken at some of the stations).  Studies of bioaccumulation of selected contaminants
(including total radium activity, expressed as 226+228Ra) in oysters (Crassostra virginica)  that had been
deployed at known distances from the discharges for known periods of time were conducted for two of
the study sites.
Summary of Results:  The study included a data synthesis of the fates and effects of OCS produced
water discharged into coastal waters based on the field assessments.  The data synthesis resulted in the
discussion of a variety of issues,  including a comparison of effluents, receiving waters/environments,
dispersion of the brine effluent, sediment contamination, and biological effects.  Maximum impacts
found in this study include elevated PAH and volatile hydrocarbon levels in sediments at distances up to
1,300 m from the discharge. No spatial trends in trace metal elevations were noted in sediments,  but
maximum levels of Ba, Zn, and Ni were found as far as 600 m from a discharge to a dead-end canal
(the Pass Fourchon site).  Water column volatile hydrocarbon levels were detected as far as 1,000 m

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9-16
from the Pass Fourchon site; and water column PAH levels were elevated as far as 800 m from the
same discharge (along with a clearly recognizable density (i.e., salinity) plume).

The most severely depressed benthic macroinfaunal communities (abundance and diversity) were found
within 800 m of one of the discharges to the Pass Fourchon site.  Benthic infauna were essentially
absent or substantially reduced at 400, 500, 600, and 800 m from the discharge point for most of the
sampling periods. Bioaccumulation of produced water origin contaminants (alkylated PAH, total
hydrocarbons, and total radium activity) was documented near discharges at both sites and up to 200 m
from one site (the Pass Fourchon site) where oysters were deployed (the other site is the Bayou Rigaud
site).  Clear potential for uptake was demonstrated both in close proximity to the discharge and to great
distances from the discharge.
Author and Title: St. Pe, K.M. (Editor).  1990. An Assessment of Produced Water Impacts to Low-
Energy, Brackish Water Systems in Southeast Louisiana. Prepared by the Louisiana Department of
Environmental Quality. 199pp.

Study Overview:  The objectives of this study were to further evaluate past observations made by the
Louisiana Department of Environmental Quality staff and other investigators and to add to the available
data base with respect to produced water discharges to low-flow systems.  Four sites were examined at
which produced water was being discharged in coastal Louisiana.  These sites (Lirette,  Bully Camp,
Delta Farms, and Lake Washington) all discharge to  canals or passes and are located in the coastal
subcategory.

At each study site, the hydraulic behavior of the produced water was evaluated by tracking the chloride
concentrations in the receiving water and surficial sediments, A produced water effluent sample was
collected as well as sediment samples and water quality data along three transects radiating from a point
near each discharge. In addition, caged oysters  were used to assess the potential for uptake of 226Ra
(among other pollutants) at three of the four sites.

Summary of Results:  Results indicated that produced water influences on chloride concentrations of
the receiving water body are much more apparent in the sediments than in the water column.  A
recognizable salinity plume was recorded at distances at least 300 m from the discharge point at all four

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                                                                                           9-17
study sites.  Toxicity testing was conducted on produced water effluents and sediments and indicated
that acute toxicity was attributable to produced water components other than salinity.

High levels of metals and organics were found in the produced water effluent samples as well as
elevated levels of total hydrocarbon homologs in sediment samples up to 1,000 m from the discharge at
one of the sites (the Lirette site - background levels were achieved at 600 m from the discharges at the
other three study sites).

With respect to radionuclides, the study found that 226Ra levels were elevated at all of the sites, ranging
from a low of 355 pCi/1 at Delta Farms to 567 pCi/1 at Bully Camp.  The top 10 cm of sediment from
the sample stations nearest the outfalls on each transect contained 226Ra concentrations of 182 pCi/g at
Bully Camp to 533 pCi/g at Lirette,!  Levels of 226Ra were noted as being above background levels as
far as 500 m from the outfalls at the Lirette,  Bully Camp, and Lake Washington sites.  Sediment
accumulation of 226Ra did not follow the same pattern at the Delta Farms site.  The authors attributed
this to the predominantly organic nature of the sediments at that site.

Among caged oysters deployed (at all of the  sites except Delta Farms), increased 226Ra levels were
found only at the Lirette site (3.1 pCi/g with an error of 0.3). Sediment hydrocarbon contamination
resulting in decreased filtering rates was offered as a possible explanation.  An additional point of
particular interest in this study is the hydraulic behavior of the produced water effluent in a receiving
water body and underlying sediments.  The study found that the high density/salinity water did not mix
with receiving waters (at some stations) and penetrated the sediments to a depth of up to 30 cm.
Interstitial chlorinity values were greatest near the discharge points and decreased with distance.

Author and Title:  Steimle and Associates.  1991. Lirette Field Sediment Radionuclide Sampling
Survey February 21, 1991. Prepared for the Louisiana Division of the Mid-Continent Oil and Gas
Association.  23 pp.  + Tables, Figures, and Appendices.
Study Overview:  The Lirette site from the St. Pe (1990) study was revisited and the analytical
methods used in that study were verified by comparing the 226Ra content of collected sediment samples
to the results from this site in the St. Pe study.

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9-18
Summary of Results: The results of this study indicate that the methods used by St. Pe may have
introduced a positive bias (by a factor of 2-3) to the results. The study bases this conclusion on the
comparison of results using gamma spectroscopy methods (used by St. Pe) to  other methods that are
assessed in the report.

Author and Title: Southwest Research Institute.  1978. Effect of Oil Field Produced Water
Discharge on Water and Sediment Quality at Five Selected Sites in Copano, Nueces, and Corpus
Christi Bays, Texas.  Prepared by the Southwest research Institute for the Corpus Christi Area
Operators. 251 pp. + Appendices.

Study Overview:  In June and July of 1978 Southwest Research Institute, utilizing the facilities of its
Ocean Science and Engineering Laboratory at Corpus Christi, Texas, conducted a water and sediment
sampling program at five produced water discharges in the Corpus Christi area. At each site, in situ
physicochemical water characterizations  were determined.  The parameters analyzed included dissolved
oxygen content, pH,  transmissivity, current speed and direction, temperature, and salinity.  Grab
samples of bottom sediment were obtained and analyzed for cadmium, lead, mercury,  zinc, and oil and
grease content.

Summary of Results:  Based on the data collected during the course of this study, a discernible
detrimental effect of the produced water discharge on the physicochemical water parameters studied
could not be identified at any of the five discharge sites. The sediment parameters tested offer a long-
term indication of the continuing effect of the produced water discharges hi that the sediment has
collected in it a long-term accumulation of the materials found in the discharged waters as well as
materials introduced from unknown sources. Generally, no significant demonstrable adverse effect of
the produced water discharges was found on the sediment chemical parameters tested.  However, the
sediment data indicated distance dependent elevations of: oil and grease up to 500 m from the discharge
at two sampling sites (and up to 100 m at another site); Hg up to 500 m at one site; and Cd up to 100 m
at one site.

Author and Title: Knecht, A.T.  and M. Poirrier. 1988.  A Survey to Determine the Impact of
Produced Water Discharge on the Estuarine Environment of Lake Salvador.  Prepared by the
Department of Biological Sciences, University of New Orleans for Texaco, Inc. 29 pp. + Appendices.

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                                                                                          9-19
 Study Overview: A study was conducted to determine if produced water discharged from Texaco's oil
 and gas operation in Lake Salvador has a measurable impact on the infauna and epifauna in the area.
 Chemical and biological surveys were conducted to determine the distribution of petroleum
 hydrocarbons and salinity, and indigenous organisms in the area around the discharge.

 Summary of Results:  Volatile hydrocarbons (benzene, toluene, ethylbenzene and total xylenes -
 BTEX) were detected in the water column to distances up to 90 m from the discharge.  Paraffinic
 hydrocarbons were detected in the water column to distances of up to 1,800 m from the discharge.

 PAH and BTEX were detected in sediments near the discharge and paraffinic hydrocarbons were
 detected  in the sediment up to 90 m from the discharge. Metals were present in essentially all sediment
 samples but did not exhibit a spatial correlation to the discharge.

 Benthic infauna and epifauna community distribution and abundance were negatively impacted within
 90 m of the discharge.  The salinity effects appear to be partly responsible, relative to reference sites.
 The community structures present are representative of typical oligohaline Louisiana estuaries.

 Author and Title: Roach, R.W., R. Carr, C. Howard, and B.  Cain.  1993.  An Assessment of
 Produced Water Impacts in the Galveston Bay System.  Prepared by the U.S. Fish and Wildlife Service
 and the University of Houston-Clear Lake, Biology Department. 56 pp.

 Study Overview:  This study provides a general assessment of adverse environmental effects resulting
 from tidal disposal of produced water.  Three parameters were used in making this assessment: (1)
 documenting any alteration to the benthic macroinvertebrate communities; (2) physically and
 chemically characterizing impacted and unimpacted sediments; and (3) assessing the sediment toxicity
 caused by these discharges.
Summary of Results: Petroleum hydrocarbons and strontium levels were elevated above background
at all sample stations at one of the study sites (the Cow Bayou site). Petroleum hydrocarbons,
strontium, and barium levels were elevated above background at all sample stations up to 364 m from
the discharge at the other study site (the Tabbs Bay site).

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9-20
Reduced abundance, species richness, and species diversity of the benthic macroinvertebrate
community was documented up to 1,030 m from the discharge at the Cow Bayou site.  Reduced
abundance, species richness, and species diversity of the benthic macroinvertebrate community was
documented up to 82 m from the discharge at the Tabbs Bay site.

Author and Title:  Caudle, C.S.  1993. An Impact Assessment of the Waters Discharging into Nueces
Bay. Prepared by the Texas Water Commission.  30 pp. + Appendices.

Study Overview: The purpose of this project was to: (1) develop data concerning location, quantity,
and quality of produced water discharges into Nueces Bay and the Nueces River Tidal and (2) to
examine the physical, chemical, and toxicological properties of these produced water discharges.  A
total of 16 produced water discharges were found to be active in Nueces Bay and the Nueces River
Tidal and were responsible for discharging a total volume of 654,537.6 gallons/day of produced water
to the Nueces estuary.

Summary of Results: The produced water effluents characteristically had low dissolved oxygen
concentrations, high water temperatures, and elevated levels of salinity and conductivity.  Additionally
the effluents contained inordinate amounts of salts, ammonia, and oil and grease, as well as, varied
levels of aromatic hydrocarbons and metals known to be toxic.  The discharges were all found to be
acutely and chronically toxic to mysid shrimp.

Advanced degradation of the aesthetic quality of the aquatic environment was observed at all outfall
sites.  Impacts observed included highly stained and discolored sediments, extensive oil sheens on  the
surface of the discharges, denuded areas within and around the discharge streams in which vegetation,
organisms and birds were absent.  The resultant compounding impact of these discharges is a noticeable
degradation of valuable habitats and biological communities in Nueces Bay and the Nueces River Tidal,
as well as a reduction hi the ecological suitability of this system as a high quality estuary. These
. findings have implications concerning the future permitting of produced water discharges to these  areas
 and in  the future management decisions of the Nueces Estuary.

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                                                                                           9-21
Author and Title:  Continental Shelf Associates.  1991.  Measurements of naturally Occurring
Radioactive Materials (NORM) at Three Produced water Outfalls.  Final Report. Prepared for Mid-
Continent Oil and Gas Association.  41 pp. + Appendices.

Study Overview: The objective of this study was to provide information concerning concentrations of
radium (Ra226 and Ra228) in water, sediment, and biological tissue in the immediate vicinity of three
produced water outfalls known to contain varying levels of NORM. The receiving waters at each of
the discharge sites,  located in coastal Louisiana, were generally low energy, brackish water, canal
environments. Discharges at each of the sites have been occurring for several years with rates that are
typical of produced water outfalls (3,000 to 5,000 bbl/d).

Summary of Results: The results of the study included produced water effluent Ra226 values ranging
from 199.4 to 258.3 pCi/1; and Ra228 values of 233.6 to 380.0 pCi/1 at the three sites. Receiving water
concentrations of Ra226 ranged from 0.1 pCi/1 at 15.2 m from the discharge at two of the sites to 5.6
pCi/1 at a distance of 7.6 m from the discharge at another site.  Concentrations of Ra228 in the receiving
water ranged from zero near the discharge at all three of the sites (but not all replicate samples were
zero values) to as high as 26.9 pCi/1 at a distance of 7.6 m from the discharge at on of the sites.

Sediment Ra226 values ranged from 0.5 pCi/1 to 23.5 pCi/1 near the discharge at two of the sites to 3.2
pCi/1 at a distance of 7.6 m from one of the sites.  Sediment Ra228 values ranged from zero near the
discharge (for certain replicates at all three of the sites) to 2.6 pCi/1 near the discharge at one of the
sites; and ranged from 0.1 pCi/1 to 1.7 pCi/1 at distances of 15.2 m from two of the sites.
Tissue samples of total radium (226+228Ra) in bivalves ranged from 0.004 pCi/g near the discharge at
one site to 0.4 pCi/g at a distance of 1,200 m from the discharge at another site.  Total radium
(226+228Ra) in crustacean tissue samples ranged from 0.041 pCi/g near the discharge at one site to 0.197
pCi/g at a distance of 3,000 m from the discharge at another site.  Total radium (226+228Ra) in fish tissue
samples ranged from zero to 0.107'pCi/g near the discharge at two sites to as much as 0.202 pCi/g at a
distance of 3,000 m from the discharge at another site. Tissue samples of total radium (226+228Ra) taken
from plants ranged from 0.032 to 0.639 pCi/g near the discharge at two sites to 0.520 pCi/g at a
distance of 2,000 m from the discharge at another site.

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9-22
Author and Title:  Mackin, J.G. 1971.  A Study of the Effects of Oil Field Brine Effluents on Biotic
Communities in Texas Estuaries.  Texas A&M Research Foundation Project 735.  73 pp.  + Figures
and Tables.

Study Overview:  The objective of this study was to measure the effect on the estuarine and marine
communities of Texas bays caused by the discharge of produced water effluents.  Six oil field areas
were targeted for study primarily based on the differing salinity of the receiving water to test the effects
of such discharges on as wide a range of natural environments as possible.

Summary of Results:  The results of this study indicated that, based mostly on the evaluation of
benthic macroinvertebrate communities, effects varied considerably with the nature of the receiving
environment.  Effects were detected up to 1,000 m from the discharge of one effluent dominated creek
(the Cow Bayou site); about 800 m from the discharge in a large, shallow (< 1 m) lake; less than 100
m from the discharge in two of the open bay systems studied (zones of stimulation were also observed
at these sites); and no effects were detected at two other open bay study sites.

Author and Title:  Armstrong, H.W., K. Fucik, J. Anderson, and J. Neff.  1979.  Effects of Oilfield
Brine Effluent on Sediments and Benthic Organisms in Trinity Bay, Texas.  In Marine Environmental
Resources, pp. 55-69. Prepared by the Department of Biology, Texas A&M University, College
Station, TX.
Study Overview:  Field studies have established the concentration of naphthalenes in bay sediments
and water in the vicinity of an oil separator platform and their effects on the benthic fauna. Fifteen
stations were occupied monthly, from July, 1974 to December, 1975, along three transects extending
from the separator platform outward for a distance of 4.0 to 5.6 km.  A lesser number of stations were
occupied from April, 1974 to June, 1974.  Bottom sediments  at each station were analyzed for total
naphthalenes content and for number of species and individuals.

Trinity Bay, Texas, the site of this investigation, has a mean depth of 2.5 m (all stations were located in
2 to 3 m of water). Bay waters are highly turbid due to the presence of a high concentration of clay-
sized particulate matter.  The brine outfall was located approximately 1 m above the bay bottom.
These special conditions undoubtedly contributed significantly to the observed impact of the brine.

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                                                                                           9-23
Therefore extrapolations from the results of this study to offshore oil production and brine disposal
should be made with extreme caution.

Summary of Results: There was a definite correlation between sediment naphthalenes concentration
and number of species and individuals.  As expected, the first station, located 15 m from the outfall,
had the highest concentration of naphthalenes of all stations sampled. The naphthalenes levels dropped
sharply from the outfall to the stations located 75 m from the platform where levels were about 20-50%
of those found  15 m from the outfall.  Naphthalenes concentrations then decreased gradually to near
background levels at stations farther out. Hydrocarbon concentrations in bottom water 15 m from the
outfall were three orders of magnitude lower than those in the full strength effluent, but sediments 15 m
from the outfall had hydrocarbon concentrations four times as great as in the full strength effluent.
There were approximately four orders of magnitude more hydrocarbons in the sediment than in the
overlying water.                 ;

The bay bottom was almost completely devoid of organisms within 15 m of the effluent outfall.
Stations located 150 m from the outfall had severely depressed benthic faunas but not to the extent of
stations nearer the outfall.  Stations located 455 m from the platform were unaffected.  Both numbers of
species and individuals increased with distance from the platform and reached a peak at the first station
medial to the control on each transect (685 to 1,675 m from the platform) and then dropped at the
control station. Physical environmental factors such as temperature, salinity, water depth, and
sediment type were essentially the same at all stations.

The temporary use of a second outfall located 275 m from the main platform outfall resulted in a rapid
build up of naphthalenes in surrounding sediments which persisted for at least six months following the
termination of use of the second outfall. The benthic fauna was also severely depressed in the vicinity
of the second outfall.  The use of multiple outfalls, located some distance apart, appears to be more
harmful than the use of a single outfall.
Author and title: Boesch, D.F., N. Rabalais (1989) Ed., Environmental Impacts of Produced Water
Discharges in Coastal Louisiana.  Prepared for Louisiana Division of Mid-Continent Oil and Gas
Association.  287 pp.

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9-24
Study Overview: The study had three components: 1) determination of the potential impacts of
numerous brine discharges to the salinity regime; 2) assessment of the effects of produced water
discharges on wetlands based on analysis of aerial photographs; and 3) hydrological, chemical and
biological field surveys. Study Component 1 examined the salinity distribution and trends, location and
mass of brine discharges and the flushing rates of the Barataria and Terrebonne-Timbalier basins.  For
study components 2 and 3, three study sites were selected with produced water discharges into: a marsh
environment within the Bayou Sale oilfield in the Atchafalaya Basin; a brackish marsh environment
within the Lafitte field in the Barataria basin; and a brackish-saline transitional marsh within the Golden
Meadow field in the Terrebonne-Timbalier Basin.

Summary of Results: The potential effects of produced water discharges on salinity were measured
through 1) estimation of the refill times, that is the time required for produced water discharges  to refill
the water or salt within determined segments of the estuary, and 2) tidal prism modeling to predict the
dilution of produced water due to tidal flushing.  At the lowest flushing rates estimated (for the
Barataria Basin), dissolved materials would be reduced to 10% of their starting concentrations within
1.75 months.  By combining the refill analysis with tidal prism'modeling, the authors reported a mean
increase of no more than a few percent due to produced water discharges.

Analysis of historical aerial photographs of the three study sites indicate that approximately one half of
the losses of wetlands was directly attributable to canal construction between 1952 and 1978.  There
were no differences hi the amount or pattern of wetland losses not directly attributable to canal
construction between discharge and reference areas.

Live biomass of wetland vascular plants was not significantly different between discharge and reference
areas except at the Golden Meadow site.  However, the differences in plant biomass and species
composition at Golden Meadow did not appear to be related to an increase of soil salinity due to
produced water discharges,  but may have been due to observed petroleum hydrocarbon  contamination.
The authors suggest that there were no effects  of produced water discharges on marsh loss at the three
study sites.

Sediments within a kilometer of the discharges exhibited elevated concentrations of polynuclear
aromatic and saturated hydrocarbons. Trace metals, except for barium, did not show a  consistent

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                                                                                          9-25
pattern of enrichment in sediments near produced water discharges.  Hydrocarbon contamination of
sediments at the Lafitte and Bayou Sale sites extended to at least 750m and 500m, respectively. At
Golden Meadow, elevated levels were only found within 100m of the discharges.
Benthic organisms were present in reduced densities and reduced diversity of species where there was
high to moderate contamination of sediments by petroleum hydrocarbons (polynuclear aromatic
hydrocarbon levels over 1,000 ppb).  There were changes in species composition and population size
structure in areas of moderate contamination (over 300 ppb PAH) when compared to uncontaminated
                                i
sediments.  The effects on benthos were greatest at the Lafitte site, with reduction in both species and
densities out to 500m.  The authors also indicated an increase in oligochaete worms at the Bayou Sale
site over the reference site. Although there were statistical differences between the reference and
discharge stations, there was no correlation with distance associated with this statistical difference for
the other two study sites.

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                                                                                     10-1
                                   10. REFERENCES
Andreasen, J.K. and R.W. Spears.  1983.  "Toxicity of Texan Petroleum Well Brine to the Sheepshead
     Minnow (Cyprinodon variegqtus) a Common Estuarine Fish." Bull. Environ. Contain. Toxicol.
     30:277-283.              :

Alaska Department of Environmental Conservation (ADEC). 1994. Alaska Administrative Code
     Drinking Water Regulations. (18 Alaska Administrative Code 80.)

ADEC. 1989.  Water Quality Standards. (18 Alaska Administrative Code 70.)

Alaska Department of Fish and Game (ADFG).  1995.  ADFG Division of Subsistence Community
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Alaska Department of Labor.  1991. Alaska Populations Overview: 1990 Census and Estimates. July.

Armstrong, H.W., K. Fucik, J.W. Anderson and J.M. Neff. 1977. Effects  of Oil Field Brine Effluent
     on Benthic Organisms in Trinity Bay,  Texas.  Submitted by the Center for Marine Resources
     Texas A&M University to the API, Department of Environmental Affairs.

Arthur D. Little. 1995. Cook Inlet Pilot Monitoring Study. Prepared for Cook Inlet Regional Citizens
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Boesch, D.F., and N. Rabalais, Eds., 1989.  Environmental Impacts of Produced Water Discharges in
     Coastal Louisiana.  Prepared for Louisiana Division of the Mid-Continent Oil and Gas
     Association. 287pp.

Brandsma, M.G., T.C. Sauer, Jr., and R.C. Ayers, Jr. 1983. OOC mud discharge model, report, and
     user's guide, model version 1.0. Exxon Production Research Co., Houston, TX.

Brooks, J.M., Wade, T.L., M.C. DennicutJI, D.A. Wiesenburg, D. Wilkinson, T.J.  McDonald, and
     S.J. McDonald.  1992.  "Toxic Contaminant Characterization of Aquatic Organisms in Galveston
     Bay: A Pilot Study."  In: The Galveston Bay National Estuary Program Publication GBNEP-20.

Brown, T.C. and E.S. Burch, Jr. i992. Estimating the Economic Value of Subsistence Harvest of
     Wildlife in Alaska.  In: G.L. Peterson, C.S. Swanson, D.W. McCollum, and M.H. Thomas,
     eds., Valuing Wildlife Resources in Alaska. Boulder, CO: Westview Press,  pp. 203-254.

CACI.  1993.  The Sourcebook of County Demographics, Sixth Edition.

Cain, B.W.  Undated.  Contamination of Brine Discharge Dominated Bayou. U.S. Fish and Wildlife
     Service.  Clear Lake, TX.  Draft. 7 pp.

Carmody, G.A. 1993. "Endangered Species in Florida."  Letter from G. Carmody,  USFWS, Panama
     City, PL to H. Mueller, EPA Region 4 Federal Activities Branch, Atlanta, GA.  April 23, 1993.

-------
 10-2
Caudle, C.S. 1993. An Impact Assessment ofProducedWater Discharge to Nueces Bay. Texas Water
      Commission, Near Coastal Waters Program.

Center for Food Safety and Applied Nutrition (CFSAN).  1990.  Report of the Quantitative Risk
      Assessment Committee. Department of Health and Human Services, Food and Drug
      Administration. Washington, D.C.  August.

Chapman, D. Undated.  Nueces Bay Produced Waters: A Preliminary Investigation ofToxicity and
      Chemistry. USFWS, National Fisheries Contaminant Research Center.

Columbia River Inter-Tribal Fish Commission (CRITFC).  1994.  A Fish Consumption Survey of the
      Unatilla, Nez Perce, Yakima, and Warm Springs Tribes of the Columbia River Basin.  Technical
      Report 94-3.  CRITFC, Portland, OR. October.

Continental Shelf Associates, Inc. 1991. Measurement of Naturally Occurring Radioactive Materials
      (NORM) at Three Produced Water Outfalls.  Prepared for Mid-Continent Oil and Gas
      Association.

Doneker, R.L. and G.H. Jirka.  1993.  Cornell Mixing Zone Expert System (CORMIX v. 2.10).
      Prepared by Cornell University for U.S. EPA, Environmental Research Laboratory, Athens,
      GA.  May 1993.

Ebasco Environmental.  1990.  Cook Inlet Discharge Monitoring Study: Produced Water.  Summary
      Report. Prepared for the Anchorage, Alaska Offices of Amoco Production Co., ARCO Alaska,
      Inc., Marathon Oil Co., Phillips Petroleum Co., Shell Western E&P Inc., and Unocal
      Corporation, and EPA Region 10, Seattle, WA.

Environment and Natural Resources Institute (ENRI).  1995.  Current Water Quality in Cook Inlet,
      Alaska, Study. University of Alaska, Anchorage, Alaska.  March. 124 pp.

Environmental Protection Agency (EPA).  1996a.  Development Document for Final Effluent
      Limitations Guidelines and Standards for the Coastal Subcategory of the Oil and Gas Extraction
      Point Source Category. Office of Water, Washington,  D.C.

EPA. 1996b. Integrated Risk Information System (IRIS).  Database Search Results.  Cincinnati, OH.
      June.

EPA. 1994. Draft Document - Comparisonof Gulf of Mexico Drainage Systems: Input of Toxic
      Chemicals and Potential for Ecological Effects.  Prepared for the  Gulf of Mexico Program,
      Toxics and Pesticides Subcommittee.

EPA. 1993a. Development Document for Effluent Limitation Guidelines and New Source Performance
      Standards for the Offshore Subcategory of the Oil and Gas Extraction Point Source Category.
      EPA 821-R-93-003, January, 1993.

EPA. 1993b. Produced Water Radioactivity Study. Final Draft.  Office of Science and Technology
      and Office of Water, Washington, D.C.

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                                                                                     1Q-3
EPA. 1993c. Health Effects Assessment Summary Tables (HEAST).  EPA 540-R-93-058. Office of
     Solid Waste and Emergency Response, U.S. EPA. Washington, D.C. March.

EPA. 1992. Tribes at Risk: The Wisconsin Tribes Comparative Risk Project. Prepared by the Office
     of Policy, Planning, and Evaluation. October.

EPA. 1989a. Risk Assessment Guidance for Superfund. Volume I: Human Health Evaluation Manual
     (Part A).  Interim Final.  OSWER Directive 9285.7-Ola.  Office of Solid Waste and Emergency
     Response, Washington, D.G.  EPA Library Call No. 9285.8-Ola.

EPA. 1989b. Exposure Factors Handbook.  Office of Health and Environmental Assessment,
     Washington, D.C.  EPA 600-8-89 043. July. PB90-106774.

EPA. 1989c. Assessing Human Health Risks from Chemically Contaminated Fish and Shellfish: A
     Guidance Manual.  EPA-503/8-89-002. Office of Water and Office of Marine and Estuarine
     Protection, U.S. EPA. Washington, D.C.  September.

EPA, Region X. 1995.  Draft NPDES General Permit for Cook Inlet, Fact Sheet.  Permit No.
     AKG285100. 44pp. (60 FR 48796, 9/20/95)

EPA, Region X. 1986.  Final NPDES General Permit for Oil and Gas Operations on the OCS and in
     State Waters of Alaska: Cook Inlet, Gulf of Alaska.  Permit No. 285000 (51 FR 35460, 10/3/86)

Francesco, J. 1994. "Endangered species in Louisiana."  Facsimile from J. Francesco, USFWS,
     Atlanta, GA. June 16, 1994.

Great Lakes Indian Fish and Wildlife Commission (GLIFWC).  1994.  GLIFWC1993 Survey of Tribal
     Spearers,  Wisconsin.

Hale, D. (Louisiana Department of Environmental Quality). 1996. Major Pass Determination for
     Grand and Emeline Passes. Facsimile to C. White, EPA.  March 8, 1996.

Heffernan, T.L. 1971.  Effects of Oilfield Brine on Marine Organisms, An Ecological Evaluation of
     the Aransas Bay Area, Job No. 1. Texas Parks and Wildlife Department.  Project Report.

Knecht, A.T. and M.A. Poirrier. 1988.  Final Report, A Survey to Determine the Impact of Produced
     Water Discharge on the Estuarine Environment of Lake Salvador.  Prepared for Texaco, Inc.,
     New Orleans.

Louisiana Department of Environmental Quality. 1996. Permitting Guidance Document for
     Implementing Louisiana Surface Water Quality Standards. Office of Water Resources. February
     5, 1993.                 :

Louisiana Department of Environmental Quality. 1996. Louisiana Administrative Code Title 33
     Environmental Quality, Part IX. Water Quality Regulations Chapter 7.  Effluent Standards,
     Chapter 11.  Surface Water Quality Standards.  (LA DEQ 33:IX.705-711 and

-------
 10-4
 Macauley, J., EPA. Personnal communication and facsimile of temperature data of the Mississippi
      River. Sent to R. Montgomery, Avanti Corp. May 29, 1996.

 Mackin, J.G.  1971. A Study of the Effect of Oil Field Brine Effluents on Biotic Communities in Texas
      Estuaries.  Texas A&M Research Foundation.  Sponsored by Humble Oil & Refining Co., Baffin
      Bay Study.  Co-sponsored by Amoco Production Co., and Texaco, Inc.  72 pp plus appendices.

 Mackin, J.G. and F.S. Conte. 1971.  "Bioassay studies of effects of brine and crude oils on fishes and
      shrimp." In: Harper, D.E., Jr.  1986. A Review and Synthesis of Unpublished and Obscure
      Published Literature Concerning Produced Water Fate and Effects. Prepared for OOC.

 Minerals Management Service (MMS). 1991. Estimating the Environmental Costs ofOCS Oil and
      Gas Development and Marine Oil Spills: A General Purpose Model.  Volume I—Economic
      Analysis Environment Costs.  Prepared by A.T. Kearney.  OCS Study, MMS 91-043.

 National Marine Fisheries Service (NMFS). 1995. Fisheries of the United States, 1994.  NOAA,
      NMFS.  Current Fishery Statistics No. 9400.  115pp.

 National Oceanic and Atmospheric Administration (NOAA). 1985. Gulf of Mexico Coastal and Ocean
      Zones Strategic Assessment:  Data Atlas. NOAA, National Ocean Service.

 Nelson, D. 1994. Area Management Report for the Recreational Fisheries of the Kenai Peninsula.
      Alaska Department of Fish and Game, Division of Sport Fish.  Anchorage, AK.

 Nobmann, E.D., T. Byers, A.P. Lanier, J.H. Hankin, and M.Y. Jackson.  1992.  "The Diet of Alaska
      Native Adults: 1987-1988."  American Journal of Clinical Nutrition,  55:1024-32.

 Petrazzuolo, G. 1996.  Memorandum to the Record - "Calculations Used to Derive Ecological
      Impacts." October 30,  1996.

 Rabalais, N.N.  B.A. McKee, D.J. Reed,  and J.C. Means.  1991. Fate and Effects ofNearshore
      Discharges of OCS Produced Waters, Volume I: Executive Summary,  Volume II:  Technical
      Report, Volume III: Appendices. MMS,  Gulf of Mexico OCS Region Office. OCS Study MMS
      91-0006.

 Roach, R.W., R.S. Carr, and C.L. Howard.  1992.  An Assessment of Produced Water Impacts at Two
      Sites in the Galveston Bay System.  16 pp.

 St. P6, K., (Ed.).  1990. Assessment of Produced Water Impacts to Low-Energy, Brackish Water
      Systems in Southeast Louisiana.  Submitted by Louisiana Department  of Environmental Quality
      and Louisiana State University Institute for Environmental Studies.

Sauer, T.C., Jr., T.J. Ward, J.S. Brown, S. O'Neill, and M.J. Wade.  1992. "Identification of
      Toxicity in Low-TDS Produced Waters." In: J.P. Ray and F.R.  Engelhardt (Eds.) Produced
      Water, Technical Issues and Solutions. Plenum Press, pp. 209-222.

Schurr, K.  1986.  Computer Modeling of Produced Water Discharges  in Cook Inlet.  U.S. EPA,
      Region 10.

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                                                                                       10-5
Southwest Research Institute.  1978.  Effect of Oil Field Produced Water Discharge on Water and
      Sediment Quality at Five Selected Sites in Copano, Nueces, and Corpus Christi Bays, Texas.
      Part 1, Final Report.  Prepared for Corpus Christi Area Operators.

Spears, R.W;  1960.  An Investigation of Pollution in Chiltipin Creek. Texas Game and Fish Project
      Reports, No. MP2-R-2, Job No. F-3.
                                i
Stanek, R.T. 1994. Alaska Department of Fish and Game, Division of Subsistence.  Personal
      Communication. September 23.

Stanek. R.T., J. Fall, and D. Foster.  1982. Subsistence Shellfish Use in Three Cook Met Villages,
      1981: A Preliminary Report. Prepared for the Alaska Department of Fish and Game, Division of
      Subsistence.  March.  22 pp.

Steimle and Associates, Inc. 1995. Synthesis of Seafood Catch, Distribution, and Consumption
      Patterns in Gulf of Mexico Region. Prepared for USDOE.

Steimle and Associates, Inc. 1991. Lirette Field Sediment Radionuclide Sampling Survey. Submitted
      with API Comments to EPA on Proposed Offshore Oil and Gas Guidelines.

Stevens, L.  1993.  "Endangered Species in Florida." Letter from L. Stevens, NMFS, St. Petersburg,
      FL. to H. Mueller, EPA Region 4 Office  of Federal Activities, Atlanta, GA.  March 25, 1993.

Temple, R.F., D.L. Harrington, and J.A. Martin. 1977.  Monthly Temperature and Salinity
      Measurements of Continental Shelf Waters of the Northwestern Gulf of Mexico.  NOAA Tech.
      Rep., SSRF-707. 29pp.

TetraTech.  1994.  Ocean Discharge  Criteria Evaluation for Cook Inlet (Oil and Gas Lease Sale 149)
      and Shelikof Strait. Final Draft. Prepared for EPA Region 10, Seattle, Washington.

Texas A&M University.  1991. Mississippi-Alabama Shelf Ecosystem Study Data Summary and
      Synthesis, Volume L Executive Summary,  Volume II: Technical Narrative, Volume III:
      Appendices Part 1, Volume IV:  Appendices Part 2. J.M. Brooks and G.A. Wolff (Eds.). MMS,
      GOM OCS Region Office, New Orleans,  LA.  OCS Studies MMS 91-0062, MMS 91-0063, and
      MMS 91-00064.

Texas Natural Resource Conservation Commission (TNRCC).  1996a. Texas Water Code
      Chapter 307 Texas Water Quality Standards, Standards 307.2-307.10.

TNRCC.  1996b.  Implementation of the Texas  Natural Resource Conservation Commission Standards
      Via Permitting.

Texas Parks  and Wildlife Department. 1991. Trends in Finflsh Landings, and Social and Economic
      Characteristics of Sport-Boat Fishermen in Texas Marine Waters, May 1974-May 1989.
      Fisheries Division.
U.S. Department of Energy (USDOE).  1996. Final Report: Risk Assessment for Produced Water
     Discharges to Louisiana Open Bays.  Prepared by Brookhaven National Laboratory.

-------
10-6
U.S. Fish and Wildlife Service (USFWS) and Bureau of the Census. 1993a. 1991 National Survey of
     Fishing, Hunting, and Wildlife-Associated Recreation, Louisiana.  USFWS and U.S. Department
     of Commerce, Economics and Statistics Administration, Bureau of the Census. GPO
     Washington, D.C.

USFWS and Bureau of the Census.  1993b.  1991 National Survey of Fishing, Hunting, and Wildlife-
     Associated Recreation, Texas.  USFWS and U.S. Department of Commerce, Economics and
     Statistics Administration, Bureau of the Census. GPO Washington, D.C.

USFWS. 1992. Threatened and Endangered Species of Texas.  USDOI, USFWS, Ecological Field
     Services Field Offices in Austin, Arlington, Corpus Christi, and Houston, TX.

Violette, D.M. and L.G.  Chestnut.  1986. Valuing Risks:  New Information on the Willingness to Pay
     for Changes and Fetal Risks. Contract No. 68-01-7047.  Report to EPA, Washington, D.C.

Violette, D.M. and L.G.  Chestnut.  1983. Valuing Reduction in Risks:  A Review of Empirical
     Estimates. Environmental Benefits Analysis Series. Report to EPA, Washington, D.C.

Welsch, J., Chevron USA.  1996. Letter to  Kerri Kennedy, Avanti, regarding produced water
     discharge modeling, including two studies dated February 1992 and December 1992. April 8,
     1996.

Whitting, D., G. Cassidy, D. Amarai, E. McClelland, H. Wang, and C. Poulos. 1994. The Economic
     Value of Improving the Environmental Quality  ofGalveston Bay.  A Report to the Galveston Bay
     National Estuary Program.  Department of Environmental Sciences and Engineering, University
     of North Carolina at Chapel Hill.

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APPENDIX A

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