-------
-------
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.
-------
-------
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,
-------
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
-------
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.
-------
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%
-------
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.
-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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,
-------
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
_
-------
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.
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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)
-------
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.
-------
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).
-------
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-
-------
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.
-------
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.)
-------
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.
-------
-------
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
-------
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.
-------
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
-------
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.
-------
2-5
«g
c3 " — '
"o g
Q -S
to
GO
£
91
|1
i
oo1
T— (
i
ON
VO
CO
1
.3
1
,
9
o
O
i
I
u
3229-001-3
oo
T— t
.S
PH
i
H
_2
c^
hn
rt^
•a
(U
1
£
Q
1
Warren Petroleum Coi
VO
O
O
CO
VO
ON
ON
CO
S
'to
fe
1
Tt
ON
' ^M
«
CO
i
0
CO
;i
Y—H
o
CN
^ — i
ON
1§
"I
GO
1
Js
(2
o
£
Gulf South Operators,
Y— 1
O
T— 1
T— (
1
0
CO
TT
Vs!
k>
CO
1
•|
co
O
-s
z
z
2184-002-2
i
£••
•t-j
^
CO
^
VN
k^
S
GO
1
3
0
CO
North Central
i
c5
g
to
a>
^
1
o
CO
^-
VN
v.is^
3
CO
PH
1
O
co
North Central
i — i
o
CN
g
*O
rt
1
w
n
1
0
Amoco
1
CO
oo
a
6
ON
°l
1-H
ON
i— i
1
1
0
1
13
Q
_o
i
o
oo
,— (
oo
VO
1
i
CO
CO
PH
_O
4-*
13
Q
o
'S5
S
"3
CN
i — i
CO
.§"
: Pass Discharge Rate i
<^f
3
Q
-------
2-6
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
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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).
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
2-23
I
.^
.a
I
i
•s
3
C3
O
O
C3
!
£.
o
11
S*'c
•SJ
s ^
I
s
81
>-j P
on
in
U
s
Bill
00
VO n
>n
o
CO
ID
CS
06
0\
in
cn
00
O
0
oo
VO
cs
s
0
o
O
o
CO
CN
o
v
o
CO
c-i
m
in
CO
oo
0
'I
^3
in
ON
S3
CM
01
cs
in
cs
-------
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.
-------
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
-------
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.
-------
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
-------
3-2
a
*~
73
i"!
§ CO
S8
•g '
o
a co
8
1'
55
T-H
t ^"^
a
0
o
jg
1
O
1«
E*
o\
8
VO
8
vo
1
oo
in
00
VO
00
CO
in
CO
CO
o
m
in
3
3
IS
6
vo
00
CO
in
CO
CO
o\
CO
in
CO
CO
CO
in
CO
CO
ON
CO
O
o
VO
(S
CO
in
CO
1
1
If
oo
I
in
in
o\
oo
i
in
oo
o\
oo
^J*
%
oo
in
o\
oo
in
00
I
s
1
Q
-»-*
O X— "N
^
CO
vd
CO
vd
CO
vd
o
CO
00
1—!
1
&
Q
-------
3-3
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
-------
3-5
1
o
g
pQ
.^^
U |
^£
| £
TO O
i
1
Q
T3
w 22
£
&
1
&
JD
es
o
£
•8
•a
s
g
CD
O
,0
a
bounded
&
ibounded
^
•g
•s
o
•a
•8
T3
O
.g
P
1
1
6
^.
„.
O4
*•
^
OO
(N
m
Ambient Velocity
(m/s)
in
cs
T— I
m
S
T— 4
10
8
8
i — i
•n
cs
in !
°,
i — i
in
eN
»— i
in
CN
1
Q
«
'•^1
en
Os
T— 1
en
i — i
in
t>
en
T— 4
in
en
01
00
^
i— i
i— i
/ ^
Discharge Depth (m
o
of
3
OJ
o
m
00
o
o
en"
g
CD^
I
T-H
s
o_
en"
to
Q ^^
.^ §
O PQ
S;
i — i
CD
f-
r— 1
O
1 — 1
o
m
o
c^
1 — 1
CD
OO
m
CD
00
CD
en
CD
Port Diameter (m)
0 OJ
O Os
CD
S-3 ^^
^5 ^^
O i — i
o
in
in
o o1
o en,
CD
^ — i
o o)
O Os.
CD
*— t
O
1=
O en"
CD
00
^ 0
CD j-^
CD ' '
. _ bo'
%*.
CN t>
0^
1
0
o
o
o
0
o
o
o
o
Port Height (m)
o
o
m
o
0
0
Os
o
g
1 Vertical Discharge
Angle (deg)
o
o
o
o
0
0
o
o
CD
Horizontal Discharj
Angle (deg)
OS
r— 4
i — 1
Os
O
T 1
T— 1
I— 1
T 1
Os
T— 1
1 1
T— 4
CD
T— 1
OO
cs
* — 1
t-~
1 — 1
CD
Q
Is
.23 w>
Q &
8
CD
8
-------
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
ja
^*^
&
di
I1!
J3 5
w 0
5 ^
C
.2
•3
CD
5
£
•5
la
•s£
.S3 O
Q
a
^CQ
*3
a)
J§!
5J
•*_*
M
1
O
CO
Q
c3
O
4-*
P-*
rt Q£
B o
Cj *^
H-l
o
e; ^o
3 r^
CJ o
H
« ~
S r^
§S
« Q
C2 O
LJ g
H
4-1
it
^
S*
4-. io
C O
L^ C5
o-i
^
1
1
ibounded
£j
bounded
!§
•o
6
in
o
o
2
o
in
o
o
CO
1 Ambient Flowrate (m3
§
T— 1
in
^
CH
Ambient Density (kg/r
en
i — i
en
R
r-H
Discharge Depth (m)
o
m"
|
m"
§
/_s
£
¥
3
Distance to Nearest Ei
i-H
O
^—1
o
o
1
i
S
ts
vo in1
^J" f**"
es en
°. en"
vo "
•* in
cs en^
• en"
in in
o o\^
d a
0 0
en oo
O vo
o ^
C5 L— '
§£
0 °°
o !£L
O i — i
oo o
oo oo
0 l>
5,
OJ
S"
If
Q £.
o
o
o
1
ffi
•g
8
o
as
o
^^^
M
2-
iS'
bjo
Vertical Discharge An
o
o
o
"So
o >n
.„ .„ Cn lt-1
CO CO o O
—' —
•- •- II II " "
U1^« gg
B B 0> S 4> O
-------
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
>.
,jO
S
ea
04
i Discharge
Volume
a
•3
§
.0*
1
,
2 CM)
ra *-2
CQ O
in -§
§£
U
>i
H .2
8 "o
*M
u 8
H
n
g n
O "
in r— i
T-H f~
o c^
o po.
o '~~l
s
I
CD
•§ ^o1
.a g,-
Qfi
0
o
o
1 Port Height (m)
g
S
g
/Sn
•8
Vertical Discharge Angle
0
o
o
"55
CD
JD
"3>
Horizontal Discharge An,
ON
r-
ON
ON
£-*
Discharge Density (kg/m
S
o
S
0
s
o
Darcey Weisbach factor
o
o
0
|| Wind Velocity (m/s)
.
. a 41
"
.
"" •"
" "
' ^3 '-3 '•
-------
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
CO
O
'•§
«
o
£<
W
f
5
R
1
W>
§
<;
£
CS
•s
»>.
s
t/>
s
o
«
Q
CO
CO
«2
•§
•*-»
13
Q
(_i
o
•£>
S
1
3
Tf
T— 1
ro
.•tt
.0
2
3
0
*en Petrol
1
o
1
u
ti
o
1
§
fl
b
|
6
b
z
j,
^
E
Ss
is
Kffi
1
S
I
11
o
O
I
||
o
•s
a
6
«
3
|1
|
1
11
1
6
1
Ss
Ili
•1
g
JS
O
1
§€
11
Chronic
S
Pollutant"
1
1
D
ent vs Di
1
>-J
1
u
en
2 ! "
CN
2
•*
^
00
2
S ;
3
en •-*
2
illlliliiiii
en a
«
ts
«
-
O
-
» Subtotals
Grand Total
.
1
Si
2
1
i
el of Trea
5
f
o
!
a
1
i
VO
en
H
2
2
3
en c^
en »-<
"
£3 S- g
e "s I 1 i
8 1 1 1 1 s. i ,, s 1 1
-
-
CN
O
O
-
Jo
co C
2
£
c*-<
O ^_;
||§
S5"S
~ i) m
rt *o >
•a-cja
offe
§•"•§
^ o^
"S3 S
1 §*"
O U rt
SE-SH
-*-sz
>J §j ^
its
ill
™fe^
-C.O
o G-S
'=.2 °
S'SH
||g.
w1^ ^
rt cx S
tsl
le|
1-2S
Us
§12
0 w 0
§lfi
J S *"
4> --S
""S§
lli^
fti^S U-rt
1 Water quality exc
" The current techn
' NOTE: Outfall is
* Outfalls are owne
-------
3-22
fi
.1
as
a
y
1
2
•3
<§•
I
to
o
en
OS
"
&
3
1
-------
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.
-------
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.
-------
-------
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.
-------
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.
-------
, 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.
-------
-------
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
-------
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).
-------
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.
-------
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
-------
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
-------
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
-------
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,
-------
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.
-------
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
-------
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.
-------
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).
-------
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
—
-------
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
-^
—
—
—
—
—
—
—
—
—
—
—
T
—
—
—
—
—
—
—
—
—
—
Louisiana
E
E
—
—
^~
—
—
—
—
—
—
—
—
T
E
T
E
—
-—
—
—
E
—
—
Texas
—
—
—
—
.—
—
—
—
—
— -
—
—
—
—
-—
^~
—
—
—
E
E
—
—
—
-------
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.
-------
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).
-------
6-6
TH <->
•§ <>
Kt f^
fc, Si.
a
o
•a
0 ,-s
£3 r>]
•d •
*v2 S*
"S O
§ a
IM Cv
^ f 2
lj§
S« *w
« 8 2
tjQ t£J o
o »_3 S
CJ
i ,
o o
r§ o gj ^
5 «%^ "5 O
o o *??« Jrt
*O § ^^ »r|j
*3 "Q
PU
H ^
|||
SQ
o
,0
g *2j
g Jr
o
u
0§
PQ C-
•a w
« a
ea o
.| .§
iSQ
^ 0 §
Q) O O
^
B
D
£?
o
9 9
w w
en «n
i-H T-H
VO VO
^3 ^3
w w
^" O\
CO CO
9 9
w w
r- o
t-5 cs
*S! Ill
VO »— I CO OO CN VO
T-H T-4 CS r-4 *-* CS
£
"R o o o o o o
"° W W W WWW
»rt o o o o o o
" CS CS CM ppp
T3
o
o
U]
ej>
u, o o o o o o
JIj CO CO CO CO CO CO
0
§ OO •* CS CO •* CM
p t— 4 1— , O t-H t— C O
.^ V* O O *O O O
(U
3
01
e)
2
_5; co o S oo o o
•< CS CO CS CO
CO CO CO CO OO CO
r-l *— 1 t— 1 T-4 T-H T-H
O\ O\ O\ ^" ^° ^t"
OO CO CO VO VO VO
<-i <-i «-< CN CN CN
{S*S*ca.J3 ooMraiJ
c^ fy^ ^ 03 CM frl r*^ w
* ^ ^ °
8
w
CO
cs
S
1
W
CO
^
1
W
t>
CO
•^
%
oo
+
VO
^
•a
1
<^> ^^
W W
ON ^
c4 co
CN CO CN CO
4
f
oo oo oo oo oo oo
T— 1 ^-H T— C i-^ i— t i-H
ON ON ^^ *^i" ^rf" ^*
OO 00 OO v£> VO >O
i— i «-i i— i CM CN CN
M"S*§^J CM^ra^
CN f?^ r^ co CM fT*| *^ eo
el ° (S °
g
W
CO
vd
g
W
t-;
-*
?
^
oo
»M
pi
oo
+
VO
^
•d
g
f>
1
-------
6-7
s £
« o
1 ~
ai O
« s-'
*fi CO
^ | S
s "5
o 10
Organism
Lifetime
Cancer Risk
Radionuclide
Potency Factor
(lifetime
risk/pCi)
Ijl
fl
a^
u -^
« 0
"2 3
II
q5 Q
OO i VO C— OO
999 999
WWW WWW
t~- eM oo i ft
CM ^3 CO jL* oo CQ c^ flj
4 * ° * ^feu°
w
en
oo
§
CM
c-i
W
* — 1
T— I
1
OO
cs
C3
VO
CM
i
0
U
>O "*
i i
OO ^H
«O VI
W W
en c-
CM CM
CM •*
r(- VO VO •* VO VO
999 999
WWW WWW
— ON vo en O oo
r-H VO 1-5 rH OO 1-5
•S
a, o o o o o o
§ § w w i i i
*J CM CM CM O C3 O
in
Of)
fO
^^ ^^ ^^ ^^ ^^ ^^
gj c- r- t>- i"^- t-^ t^-
o
^^ O\ CO C*4 ON CO C^
?j O i— t O O *— < O
g irj wo
1
p^ CM en CM en
J3
f
vo vo vo vo vo vo
oo oo oo vo S vo
S I "8 8 3 | -8 S
^feU° ^feu°
i — i
-------
6-8
O ^^
^^ £*•.
ca O
t-»
o w
Organism
Lifetime
Cancer Risk
S 1 o S3
1 ^ia^
"O § ^, •%%
*£
O rt jp
w o
t*
3 eb
I*
&?
« cj,
Estimated
Diludons
l§§
^0^
&
CO
E?
o
VD VO
9 9
W W
O CO
CM CM
t- t-
VO VO
9 9
[£j W
f- '-I
CM' co
vo f~ oo vo r~ oo
999 999
WWW WWW
in t^ vq ON ON CM
"K o o o 222
^ w w w rTi rTi rTi
b< f^i t~* f~** f*~* t*~* f**s
A) CN| CM CM f*"fr f~^ f^
I-M ^H .-! T-H I-I T-H
1
U>
&D
\r. O O O O O O
jy co co co co co co
u
w OO Tl* CM OO ^f CM
£5 »— ( r-M O T— ( ^— I O
^ «o o O >n c> o
a
i
1
S> o o o o o o
2 oo o o oo o o
•^C CM CO CM CO
*— 4 1—t T— 4 *-H 1-H T— I
ON ON ON Ti* ^i* ^t*
oo oo oo vo vo vo
r-t t-l t-< (N O «•}
9 9
w w
CM •*
w w
10 vo c^ if) vo r^
o o o o cp o
WWW WWW
t-. vq T); vq CM t-;
>n co oo vd •<* ON
u
S3
a, o o o o o o
"" r* ^H ^H r-l ^j< T-<
o W W W WWW
0000 0 0 S
«g CM CM CM q q q
bfi
Jj t- t~- t— c— r- r-
i
o
^^ ON CO C"4 O\ CO C*^
S o <-< o o" T-H o
s >o
-------
6-9
1
-S?
s w
1§ '5
o £>
bo j§ o
o '-> J
J-<
-< • oo in »-!
^
"^ O O O O O O
^ o o o o o o
g^ CM CM CM O O O
s
a
v>
en
in O O O O O O
_j co co co co co en
S3
w OO ^- CM OO -^ CN
p I-H T— < O T— i T— i O
*^ *o o *o • *o ^5 *o
§
1°
s
S? O O O O O Q
5 oo O O oo O O
•< CM CO CM CO
VO VO VO VO VO VO
oo oo oo oo oo oo
CO CO CO CO CO CO
1
oo oo oo vo vo vo
-i i-t — CM CM CM
vo.d.ct-' oo,i3.a*-i
(S.agS oo^^S
"cJj^Uj^ ^^U^.
VO
9
w
co
T— t
1
CO
9
w
1—4
«
s
oo
+
CM
1
1
•I
o
a
in in
9 9
w w
Tt VO
*—! >-<
1 1
CO Tl-
9 S
w w
OO T-H
^ CM
in vo r~- in vo t>
o o o o o o
WWW WWW
t-; >-< in ON cM ON
1— 1 t— C CM T-< r— ! CM
O
a
&,
a. o o o o o o
*§ W W W WWW
.0000 o o o
'g CM CM CM O O O
in
ON
CO
•a
i2
oo
+
VO
i
1
'•f
s
u
8
1
o
I
£
.1?
1.8-i
-------
6-10
2^J
^«
nj o
ll
l|i
pj e/s
o '-i i
11 o*
"9 S S "fi
CO il ^^ •-<
P^ O
2 g ^-s
I'll
w Q
a
o
II
1*
PQ j^f
ca .O
aS
u o U
5
vo vo
9 9
™ vq
^ s
CO •*
VD VO
OO «-i
^ cs
vo t— oo vo t~- oo
(^3 Cp C3 ^3 C3 ^3
WWW WWW
F- *-j "i q «*i °j
--5 i-5
(N t>
CO CO
vo vo
QJ [I]
™ 00
oo ON
9 3
«n vo r- ir> vo f-
999 999
w fTi w w w rn
ON vj r** *O ON r*-
co" n •* IN vo
y
S?
,53
(3, O O O O O O
1— 4 t— 1 t— 4 i—4 1 — 1 T— 4
"o W W W WWW
O o O O O O O
«g CN CN cs q q q
V 1— 1 T-H T— C 1—4 T— ( »— 4
CO
(3D
3
"T' o o o o o o
*•* C** t**1 C"^1 t** C** t"-
I
0
^^ ON CO CM ON CO CS
S O <-5 C5 C5 >-H C3
S >n
-------
6-11
2 ^
rt O
P£H s*— '
a
.2
D CD
ft —
lL
j^O O **H
ll
111
bJO trH O
.ft 2 S
CJ
|H
O
•§ ^*
S *~-
^
&?
PQ o
"§ 3
1 i
CO V**i
w Q
Ide
o
•r^ri
P<
1
££ o o o o o o
^j oo o o oo ^5 ^5
i
vo vo vo ! VO vo VO
vo vo vo vo vo vo
O\ ON O\ Tf Tf ^
oo oo oo vo vo vo
*— 1 T-H *-H CS C^ CS
i
^feU5- (Sfe°c^
PH
T-H T-H
m vo vo ^ vo vo
oo en "* r-H en c—
C> VO T-H T-H f-I T-H
^
•e
M
a o o o o o o
T-H i-H T— 4 t-H t-H T-H
•O 1 1 1 III
o UJ D-l UJ Cu QU m
2t ^\ r^ ^^ *^H 53 yS
^w fTP c~* f~» ^j
-------
6-12
% f?
tJ «-:
C3 ^^
f^4 N— '
c!
.2
•§ ^"
ft> O
« N-'
t-t
"g 8
§ g
ifS TO
__ cj iQi
c3 *y4
S 3i
III
3 **3 *-*
&o *S o
Jzj ' "i j3
u
V-t
4) O
a H i> •<=•
3 •«_ "3 .p
o o* ^ l£2
^ 8B-S
/5 o
P"* *£r
g> t3
Jo ""*™^ fcj
tS d>
Q^
_§
o.'C1
H >»
1 ^h
u
&t
« o
•g a
s •
fll
<_8
1
vo vo
0 0
w (i
oo »-;
T— I C^
9 9
m m
00 vo
rf >ri
vo vo
•3- OO
CM' CM
vo t~- oo vo F- oo
fT^ £lj| I'T'I [T*| ["T"! |*T^
CM T) CM VO l> C~;
CM >-< en CM <-< en
•>; o o o o o o
{^ 1—4 »-^ 1-j4 i-H »^ T-H
^ U4 p^ [14 rT1 TT1 FT1
S 8 8 8 o o o
TJ ^ "^ *~* ^ ^ ^
o
o
1
en
m O O O O O O
JlJ en eo en en en en
s— '
o vi cJ o
0)
1
0)
CUD
eu o O O O O O
•5 oo o o oo o o
•- OO^I^U,
CM [S r^ W CS rTl J^ CQ
iMHQJ^ A1^^^
O C? O O ^3 O
prl ["T"] py f£) pij] pj
i-H CO 10 O\ OO t>
»n co i> in co 06
u
f
a o o o o o o
"" S T-I ,-C ^H rH ^H
o W W W WWW
*g CM CM CM O O C3
CU 1-H 1— ( 1"H 1-H t— •( r~H
W
en
P
3
^5 O o C5 O O
W C*^ C^* T"* C^- t^* t^~
1
Sn
o
** ON en CM ON en CM
8 o i-< o c> •-< ci
g in >n
1
t«
S~ O 0 O O 0 O
m OO O O OO O O
•2 CM en CM en
j_
a
(-, o t- ^ r5 rM
ON ON ON *^* xl* ^t*
00 OO OO VO VO VO
>— i »— ( <-H CM CM CM
§ S | S § S I S
3 - ° * 3 - ° f
ON
oo
in
i
CM
^
CM
*— (
I
n)
VO
T3
1
O
O
o-a-a-0
« si's
U trj *
-------
6-13
I
a
4)
60
O
.S3
Q
U
O
1 2 1 8
ill!
pi ^
&* !U >-»
w Q s-
(3
_o
CO ^
6
PH "SB
0 ^
W o
1> %
£*
§ o O
Organism
10 <0
9 , 9
w ; w
eN ^O
vo ! ^o
W W
ON O\
•0 >0
W '•- W
ON •*
IO **D C** "O **O C^
OOO OOO
WWW WWW
O oo en ' cs I-H O
•>; o o o 222
PQ w w rTi FTI rTi
U O O O OOO
^ eN e^ eN ooo
*— 4 T— I 1— ( 1-H i— 1 *— 1
O
=2
es
WD
•« O O O OOO
jy en en en en en en
S oo •* eN oo •* es
g T-H T 1 O i *-* T~"t O
^ iri O O >o O O
I
5 oo o o oo o o
•^ cs en eM en
ooo 222
ON ON ON "^d* ^^ ^J*
oo oo oo ^o ^o \o
t— ( i— 1 r— 1 : CN C^l CN
*V PH M £2 ^f^O^.
cb ,*-«. ro /™s
(^ O (^ O
g
w
oo
g
W
•0
w
«
g
es
Combined R
T-H ON
IO >O
^^ o^
en vo
i — i i — i
f*^ ^^
t-~ oo
•^- O IO
ooo 999
WWW WWW
eM o ON en \o e^l
o
1
ft O O O OOO
r- 1 i— 1 I— 1 1— I i— 1 i— 1
o W W W W W W
o o o o ooo
«g eN es (N ooo
OX)
ro
T' o o o ooo
[- r- t- t~- t— c— t—
o
^ ON en cs ON en eN
8 O >-i O O ^H o
| ,0
1
.22 o o o ooo
S oo o o oo o o
i
H
ooo ooo
T—t i — 1 r— I T— 4 i-H ^H
ON ON ON "^" ^f" •^~
OO 00 OO \£> VO VO
|lg| |1!|
en
PQ
T-H
T— (
1
9
>o
•a
2
8
i
[Combined R
?•§•
-------
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
c3
.S
•a
o
H-l
g
U
w
CD
1
1
t
o
^2
w
0
<8
U
§
CA
cn
8
w
CD
•1
<4-i
J
g
g
I
.2
£3 ^ '
C I*-,
s £
c
S
.a> 1
a
la
.2 gs
S« !n
1 ^
3
1 :
O
U
o
on g?
2 o
CO CS
<
CM
3 "S .2
1 li
rg W 0
S
QM " i
a-g ss1!
JO 0 <3 J3
|||| ,
o S3
U
u -^n
fl "*""' §3
K 52 *a
§ u '83
Pi 04
,
13 ™ %
** § o
•~! 0 "S
r5G o> A
0,
— _. 'I 1
|||
c
1
1
£
CO r-.
O vo
rjrl
-^
1— t
§ 22
o m
CO
CO
fe^
o
^-
tfi
V-
(U vo
O W^*
s s
^
«
W o o o
2 S S o
.S oo vo o^
oo
« 00
+ |- 2 S
r? -3
,g c j^ ^
o tf 3 o
- 1 * 21
o (O .2< ^
H os a S O
•X3 TO *j
*CA t-P t-<
a) o^«
5 o "»S
^— J_ ^~* • r.
^" O >.
-H 3
^ T3 O
g « CO
1-t " Wi
s -^ <2
3 U ^
0 0 0
§31
fl|
I E 2
gill
^^ £ W3 W
v— ' C to rt
M in K •£>
5J « S C
es V ° °
'3 ^ 2 'S
8 8 .1 1*
< '•§ |> S
1 6 s "
* u § u
•S « .§ g>
.3 S§ x S
^j o ^3 ^
ca .0 o -a
-------
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).
-------
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
1 g
J! S
rt
£
O **""*
o CM
"S S.
«
^ll
J*^ *•*
flj w
"3 ^ H
e i S
•s "j B
o
(-<
'"•I S:2 d} ?v-r
f g go
l|ll
"2 § c^-c
cd *5 *"'
pv] O
OO
9 9
Mr! rjl
c-^ •*
en •*
vo r~ oo vo r~- oo
999 999
pj pq PL) rn FM FM
^D ^^ C1^ O^ *'*>}" OO
en ^H r)-' •* I-H •«*
A
,S O O O OOO
J< rA nil W til W W
Ul 2SJ >.? CM; i«! S3 55
p, o o o ooo
jjjj 1— < f-4 1— t 1— 1 T— J 1— 1
o
1
fa
W)
2 o o o ooo
O en en en en en en
S ON r-« CN en eN en
^^
1^ i«4 i— t r-H i— < i~H
OO OO OO CO OO OO
oo oo oo vo vo vo
i— i r-< i— i es eN (N
]I3| fill
vo
S
1— 1
vo
W
vq
i— t
9
TTl
i— (
OO
1
oo
+
§
(^
•s
.S
1
o
in m
o o
W W
•^ in
vo t>
in in
§ §
t-; O
I-H ci
9 ?
w w
vq o
oo i-5
i> 06 oi ON ON en r-5
•3
1
rg O O O OOO
eg W W W WWW
s3 o o o ooo
8 CN «s ts ooo
1/1 i—5 i-5 i—5 i-H T— < rH
B*J
m
^
u o o o ooo
g f- t-- f- t-~ f-- O
o
U ON t-- cs ON r-- cs
g i-5 o d> i-5 o o
g in in
«
•p5
s
s
^ o o o ooo
0> OO O O OO O O
*g cs en CN en
1
CO OO OO CO CO OO
ON os ON •<* "»f ^
oo oo co vo vo vo
i— I i— < i— ' C-l CS CS
|I3| |SS|
1
t— <
m
en
?
W
ON
1
CO
+
vo
0$
-2
1
.s
1
-------
6- 19
B
u
(U
I
"8
•
1
<
§
I
1
S
VO
o
>-H CO
en vo
vo oo
OO
vo
>n
o
o o
-
00
^H o\
2
.
K <
a
-------
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
o.)
X
£
•a
S
rt
3
1
,3
"0
J
-1
6
is"
1
S
o
I
£
3
o
E-i
^
i— i
4-1
1
In
a>
S
U
1
u
«
1
•!
5§
iJ
g
'1
M
^^
sT§ S
(2 &
•£? i
CO
•°g £
o
§ ^
rt?
j
i— (
§§ o
t*^ oo
C-" en" en"
en t-» vo
^^ i~H V^
i — 1 i — I
vcj, ^ °1
U en" |