United States
Environmental Protection
Agency
Office of Environmental     EPA-600/7-82-013
Processes and Effects Research April 1982
Washington DC 20460      ^
Research and Development
Summary of the
Drilling Fluid  Hazard
Assessment Program
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                           EPA-600/7-82-013
                           AonM982
Summary of the Drilling Fluid Hazard Assessment Program
    of the U.S. Environmental Protection Agency
               Office of
          Research and Development

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                           ACKNOWLEDGMENTS
     This report was prepared with the assistance of The MITRE
Corporation, McLean, Virginia 22102, under contract no. 68-02-3196.
                                  iii

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                          TABLE OF CONTENTS
                                                             Page

     LIST OF TABLES                                          vii
     LIST OF FIGURES                                         viii

1.0  INTRODUCTION                                            1-1

1.1  Statement of the Problem                                1-1

     1.1.1  Discharges from Offshore Oil and Gas             1-1
              Platforms
     1.1.2  Purpose and Composition of Drilling Muds         1-3
     1.1.3  State of Knowledge Concerning Drilling           1-^
              Fluids Prior to Initiation of the EPA
              Program
     1.1.4  Need for an EPA Research Program                 1~5

1.2  Organization of Summary                                 1-6

2.0  STATUTORY AND REGULATORY MANDATES                       2-1

3.0  EPA RESEARCH PROGRAM                                    3-1

3.1  Program Goals and Objectives                            3-1
3.2  Research Approach                                       3-1

     3.2.1  Components of a Hazard Assessment                3-2
     3.2.2  Tiered Approach of Research                      3-2
     3.2.3  Selection of Drilling Fluids Used in             3-3
              Effects Assessment Research Projects
     3.2.4  Rationale for Testing of Individual Mud          3-5
              Components

3.3  EPA Research Program                                    3-5

     3.3.1  Generic Studies                                  3-6
     3.3.2  Flower Garden Banks, Gulf of Mexico              3-14
     3.3.3  Georges Bank, Gulf of Maine                      3-21

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                     TABLE OF CONTENTS  (Concluded)



                                                             Page

4.0  RESEARCH  RESULTS TO DATE                                4-1

4.1  Introduction                                            4-1
4.2  Exposure  Assessment                                     4-1

     4.2.1  Field  Studies of Discharge Plume Dispersion      4-2
     4.2.2  Models of Plume Dispersion                       4-3
     4.2.3  Sedimentation and Monitoring Studies             4-3

4.3  Effects Assessment                                      4-4

     4.3.1  Pentachlorophenol Tests                          4-4
     4.3.2  Short-Tenn Toxicity Tests                        4-5
     4.3.3  Long-Term Toxicity Tests                         4-8
     4.3.4  Bioaccumulation Studies                          4-9
     4.3.5  Effects on Benthic Communities                   4-10
     4.3.6  Effects on Corals                                4-11

4.4  Summary                                                 4-13

5.0  FUTURE DIRECTION OF THE EPA PROGRAM                     5-1

5.1  Factors Affecting che Final Year of the EPA Program     5-1
5.2  Strategy  for  the Final Year of the Program              5-2

APPENDIX A - PROJECT DESCRIPTIONS                            A-l
             GENERIC STUDIES                                 A-2
             FLOWER GARDEN BANKS                             A-19
             GEORGES BANK                                    A-37

APPENDIX B - SECTIONS 402 AND 403 OF THE CLEAN WATER ACT     B-l

APPENDIX C - CALCULATION OF VOLUME OF DRILLING MUD           C-l
               DISCHARGED TO THE MARINE ENVIRONMENT
               DURING 1980

REFERENCES                                                   D~1
                                  vi

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                           LIST OF TABLES
TABLE NUMBER

   3-1        SOURCE OF SOME DRILLING FLUIDS USED IN
                RESEARCH SPONSORED BY THE U.S.
                ENVIRONMENTAL PROTECTION AGENCY

   3-2        AGGREGATED SUMMARY OF MAIN RESEARCH AREAS         3-7
                OF THE DRILLING FLUID HAZARD ASSESSMENT
                PROGRAM

   3-3        PROJECT SCHEDULES FOR GENERIC STUDIES OF         3-8
                FATE AND EFFECTS OF DRILLING FLUIDS IN
                THE MARINE ENVIRONMENT

   3-4        PROJECT SCHEDULES FOR STUDIES OF FATE AND         3-16
                EFFECTS OF DRILLING FLUIDS ON THE FLOWER
                GARDEN BANKS, GULF OF MEXICO

   3-5        PROJECT SCHEDULES FOR STUDIES OF FATE AND         3-22
                EFFECTS OF DRILLING FLUIDS ON GEORGES
                BANK, GULF OF MAINE
                                 vii

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                           LIST OF FIGURES

FIGURE NUMBER                                                 PAGE

     1-1      TRACTS PROPOSED FOR OIL AND GAS EXPLORATION       1-2
                AND DEVELOPMENT

     5-1      RESEARCH STRATEGY FOR THE FINAL YEAR OF THE       5-3
                DRILLING FLUIDS HAZARD ASSESSMENT PROGRAM
                                 viii

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                          1.0  INTRODUCTION

     The purpose of this report is to provide an overview of the
Drilling Fluids Hazard Assessment Program being carried out by the
Office of Research and Development of the U.S. Environmental Protec-
tion Agency.  Included is a synopsis of the program origins, legisla-
tive mandates, program goals and objectives, research rationale and
strategy, summary of some research results to date, and direction of
the program for the final year.

     The Drilling Fluid Hazard Assessment Program was conceived in
1975 in response to the King-Muir Report Drilling Fluid Hazard
Assessment Program (King and Muir, 1974) in which was examined the
environmental issues associated with more rapid development of oil
and gas resources in offshore areas of the United States.  The
program was given added importance by the need for a technical data
base to support the issuance of discharge permits as required in the
Clean Water Act when this authority was extended to offshore areas by
the Outer Continental Shelf Lands Act.  Funds for the program were
provided in 1976 and the first research grants awarded in 1977.  At
present, the program is scheduled to end in 1982.

1.1  STATEMENT OF THE PROBLEM

     As the quantity of foreign crude oil imported into the United
States has risen rapidly over the past decade, the search for addi-
tional domestic sources of oil and gas has intensified.  This search
has been increasingly focused on the continental shelf with the
result that many areas have been proposed for leasing by the Depart-
ment of the Interior (Figure 1-1).  While some of these areas, such
as the Gulf of Mexico, have experienced extensive drilling activity
in the past, most have not.  Under the provisions of the Clean Water
Act and the Outer Continental Shelf Lands Act Amendments, the U.S.
Environmental Protection Agency must issue permits for the discharge
of materials from offshore oil and gas drilling and production plat-
forms.  A technical data base is required as the basis for the
discharge conditions established in the permit.

1.1.1  Discharges From Offshore Oil and Gas Platforms

     Principal among the discharges from offshore oil and gas plat-
forms are fluids used during well drilling, commonly called drilling
muds.  These muds are used in large volume.  For example, during
1979, 1.5 to 5.5 million m3 (2 to 7 million yd3) of drilling mud
were used in off-shore drilling activities (see Appendix C).  About
90 percent of this volume was discharged from platforms in the Gulf
of Mexico off Texas and Louisiana, where most offshore drilling is
presently taking place.  This compares in volume to the average of

                                  1-1

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                 14 12 11  13
      art
      ATLANTIC COAST

       1.  NORTH ATLANTIC
       2.  MID-ATLANTIC
       3.  SOUTH ATLANTIC AND BLAKE PLATEAU


      GULF OF MEXICO

       H.  EAST GULF
       5.  CENTRAL GULF
       6.  WEST GULF
 PACIFIC

  7.  SOUTHERN CALIFORNIA BORDERLAND
  8.  SANTA BARBARA
  9.  NORTH AND CENTRAL CALIFORNIA
 10.  WASHINGTON-OREGON

ALASKA

 11.  COOK INLET  (STATE-FEDERAL)
 12.  SOUTHERN ALEUTIAN SHELF
 13.  GULF OF ALASKA
 14.  BRISTOL BAY
 IS.  BERING SEA  SHELF
 16.  BEAUFORT SEA
 17.  CHUKCHI SEA
                                    FIGURE 1-1
TRACTS PROPOSED FOR OIL AND GAS EXPLORATION AND DEVELOPMENT
                                         1-2

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about 6 million tor (about 8 million yd-') of dredged material from
Mew York Harbor disposed of annually at the designated ocean dis-
posal site in the New York Bight.  During the drilling period at an
average platform location, about 1500 to 4500 m3 (about 2000 to
6000 yd^) of drilling mud may be used in drilling up to 40 wells.
Drilling fluids are released as relatively small-volume operational
discharges and as infrequent large-volume bulk discharges.

1.1.2  Purpose and Composition of Drilling Muds

     Mud used in offshore drilling is a mixture consisting princip-
ally of barite, water and chemical additives, which Is pumped into
the well through the drill pipe and drill bit.  The mud serves a
number of purposes:

     •  Cooling of the rapidly rotating drill bit

     •  Lubrication of the string of drilling pipe as it turns in
        the wellbore

     •  Carrying of rock cuttings to the surface

     •  Formation of a plaster on the sides of the hole to prevent
        the formation from crumbling or collapsing into the well and
        to prevent loss of fluid to the formation

     •  Providing hydrostatic pressure to prevent formation fluids
        from entering the well and to control pressures in the well.

A wide variety of chemical ingredients are used to formulate drill-
ing muds.  These can include:
        biocides
        pH control products
        calcium removers
        corrosion inhibitors
        deformers
        emulsifiers
        filtrate reducers
        flocculants
        foaming agents
lost circulation materials
lubricants
shale-control inhibitors
surface-active agents
thinners
dispersants
viscosifiers
weighting agents
The chemical composition of drilling muds can vary greatly.  Muds are
often custom formulated for conditions encountered at each well and
even for conditions encountered at different depths in a specific
well.  Additionally, the chemical properties of a mud may be altered
by the physical conditions encountered in a well and by materials
gained as the well is drilled.

                                  1-3

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1.1.3  State of Knowledge  Concerning  Drilling  Fluids  Prior  to
       Initiation of  the EPA  Program

     Although relatively large  amounts  of money have  been spent by
several Federal agencies on research  related to the effects  of devel-
opment of oil and gas  resources  on  the  outer continental shelf, com-
paratively few studies  have been undertaken to evaluate the  effects
of discharges of drilling  fluids from platforms.  When the  EPA Drill-
ing Fluids Hazard Assessment  Program  was conceived  in 1975,  consider-
able research was underway on the potential effects of more  rapid
development of offshore oil and  gas resources.  At  that time, how-
ever, environmental concern was  focused principally on the  effects of
petroleum in the marine environment.  Only a few  studies had been
undertaken to examine  the  toxicity  of drilling fluids, cuttings, and
produced waters routinely  discharged  from offshore  platforms.  Most
of the information available  was published only as  project  reports
("gray" literature) which  generally had not been  subject to  a peer-
review process for confirmation  of  the  findings.  Few data  were
available in tne peer-reviewed  journal  literature.

     Despite this scanty data base, there was  a general lack of con-
cern at that time over  the potential  effects of drilling mud and
produced waters discharged in the marine environment.  This  feeling
was based primarily on  some commonly  held assumptions.  The  general
assumptions about the  potential  effects of produced waters  (Koons et
al., 1976) were that:

     •  their toxicity  was low

     •  natural dilution on discharge greatly  reduced the environ-
        mental concentrations of hydrocarbons  and inorganic  compo-
        nents.

General assumptions regarding the consequences of the discharge of
drilling fluids (Monaghan  et  al., 1976) were that:

     •  bioassay data  indicated  that  any acute toxicity for a typical
        drilling mud  would be due mainly to the dissolved lignosul-
        fonate thinner

     •  rapid dispersion and  dilution quickly  lowered che concen-
        trations below those  found  to be toxic in bioassay  tests

     •  dispersion model calculations indicated that  bulk mud
        discharged at  a rates of 250  bbl/hr was diluted one-hundred
        fold 0.2 mile  down-current  in less then 1 hour
                                 1-4

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     •  both measurements and theoretical calculations indicated
        that mud discharged during normal drilling quickly mixed
        with seawater and was diluted at least a thousand fold
        about '300 yards down current

     •  discharges had not caused long-lasting effects, as a wide
        variety of motile organisms were found on and under oil
        producing platforms

     •  divers found barnacles growing on and in the exit of dis-
        charge pipes

     •  drilling mud and cuttings from more than 19,000 wells had
        reportedly not caused detectable environmental damage

     •  material added in greatest amounts to drilling muds was
        barite (33804), which was considered to be nontoxic.

1.1.4  Need for an EPA Research Program

     In 1975, EPA personnel determined that an inadequate data base
existed on the effects of discharges of drilling fluids from offshore
platforms.  The basis for this finding was that:

     •  few data were available to support the general lack of con-
        cern over the environmental effects of drilling fluids

     •  drilling fluids contain components such as biocides and heavy
        metals that are potentially toxic in the environment

     •  the environmental effects of many drilling fluid components
        were unknown

     •  large volumes of drilling fluids are discharged to the envi-
        ronment

     •  large oceanic areas could potentially be affected.

Based on the need for information to establish the transport,  fate
and effects of drilling fluids in the marine environment, it was
determined that the EPA Drilling Fluids Hazard Assessment Program
should be undertaken.

     The need for an adequate technical data base on drilling  fluid
effects was given added importance by the Outer Continental Shelf
Lands Act, which extended the Clean Water Act to discharges on the
outer continental shelf.  EPA must issue permits for the discharge  of
effluents to aquatic environments under the provisions of Section  402

                                1-5

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of the Clean Water  Act.   The  permit  process required  a  base of  scien-
tific information on  which  to establish defensible  and  reasonable
permit conditions.

1.2  ORGANIZATION OF  SUMMARY

     This program summary is  organized  into four  section.  EPA
responsiblities as  given  in the  Clean Water Act and the Outer
Continental Shelf Land Act  Amendments are given in  Section 2.0.  A
discussion of program goals and  objectives, the research approach,
and the research program  is given  in Section 3.0.   A  brief overview
of research findings  at the present  time is given in  Section 4.0.
The direction of research in  the final  year of the  program is out-
lined in Section 5.0.
                                  1-6

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                2.0  STATUTORY AND REGULATORY MANDATES

     Several Federal agencies have mandates involving Che protection
of the marine environment through the regulation and planning of the
development of offshore oil and gas resources.  These Federal agen-
cies Include:

     •  Environmental Protection Agency

     •  National Oceanic and Atmospheric Administration

     •  Bureau of Land Management

     •  Geological Survey

     The U.S. Environmental Protection Agency has the responsibility
to issue permits for discharges from drilling and production plat-
forms under the National Pollutant Discharge Elimination System
(NPDES) program.  There are several regulated discharges:

     •  Drilling fluids - chemicals ("muds") used In the well during
        drilling

     •  Cuttings - solid materials from the geological formation
        being penetrated by the well that are brought to the surface
        as drilling proceeds

     •  Produced waters - liquids (often a brine) .from the geological
        formation that come to the surface in the well and which are
        discharged after separation from the oil and gas

     •  Other miscellaneous discharges - these can include sanitary
        wastes, deck drainage, and cooling water.

     The authority for EPA regulatory activities over discharges to
aquatic environments is contained in Sections 402 and 403 of the
Clean Water Act (see Appendix B for the text of these sections).
This authority has been extended to the waters of the continental
shelf under  the provisions of the Outer Continental Shelf Lands Act
Amendments.

     Authority for issuing NPDES permits is contained in Section 402
of the Clean Water Act.  The conditions established for these permits
are to be based on technical guidelines required under provisions of
Section 403(c)(l).  The kinds of information that the guidelines must
contain are defined in this section.  The guidelines have been
                                 2-L

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published as  ocean  dumping  criceria  (40  CFR Part  125).   No  permit
will be issued  if  insufficient  information exists  regarding the
potential effects  of  the  discharge  (Section 403(c)(2)),  emphasiz-
ing the importance  of research  on which  to base  permit  conditions.
                                  2-2

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                      3.0   EPA RESEARCH PROGRAM

3.1  PROGRAM GOALS AND OBJECTIVES

     The goal of Che EPA Drilling Fluids Hazard Assessment  Program  is
to assess what effect the discharge of drilling fluids is likely  to
have on the marine environment.  This information will serve as the
basis for determining discharge permit conditions, as required in the
Clean Water Act.

     Research results related to the program goal will partially  pro-
vide a basis for the Agency to address the following major  questions
important to the permit issuance process:

     •  Are there any significant adverse affects Chat can  result
        from the discharge of drilling fluids to the marine environ-
        ment?

     •  What are the causes if significant effects occur?

     •  How can effects be mitigated?

     •  What are the environmental tradeoffs associated with the
        regulatory options available to the Agency?

The research program as presently constituted is addressing only  the
first two issues.

     Specific objectives of the Drilling Fluids Hazard Assessment
Program are as follows:

     •  Undertake a hazard assessment, which consists of the integra-
        tion of exposure assessments and effects assessments

     •  Determine the generic effects of drilling fluids in the
        marine environment

     •  Develop region-specific research programs utilizing the
        hazard assessment approach

     •  Assemble, review, and synchesize available literature on
        drilling fluids in the marine environment.

3.2  RESEARCH APPROACH

     EPA research is designed to assess the potential hazard to the
marine environment and humans from drilling discharge practices.
Such a hazard assessment is the integration of knowledge of concen-
trations of drilling fluids that could occur in the environment under

                                 3-1

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specific conditions  (exposure  assessment)  and  the effect of these
concentrations during  the  period of  exposure on marine ecosystems and
organisms (effects assessment).

3.2.1  Components of a Hazard  Assessment

     In general, an  exposure assessment would  consist of investiga-
tions to define the  following:

     •  characteristics of drilling  muds

     •  dilution, transport, and fate of drilling muds

     •  concentrations of  muds extant in the environment

     •  resuspenslon and movement of muds  following deposition.

An effects assessment  should define:

     •  acute toxicity

     •  chronic toxicity (carcinogenic, mutagenlc, teratagenic
        properties)

     •  sublethal effects

     •  potential for  bioaccumulation in components of the food web

     •  habitat alteration

     •  effects on ecosystem structure and function

     •  hazard to humans.

3.2.2  Tiered Approach of  Research

     The hazard assessment, using exposure assessment and effects
assessment as the research approach, has been  implemented in the EPA
program as a tiered  process.   In general,  laboratory-oriented toxic-
ity tests are undertaken as the first phase.   These were usually
acute static toxicity  tests designed to determine the range of con-
centrations of drilling fluids that affect organisms.  Next, more
realistic flow-through toxicity tests are  conducted.  Field studies
of effects are deferred until  a need for them  is established.   In
other words, if no significant effects on  marine organisms can be
detected in laboratory experiments using high concentrations of
drilling fluids, determination of effects  at lower concentrations
likely to occur in the environment are unnecessary, or at least of


                                 3-2

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low priority.  Some aspects of the exposure assessments involving
transport and dispersion experiments were scheduled for a later
program phase for the same reason.

3.2.3  Selection of Drilling Fluids Used In Effects Assessment
       Research Projects

     An important scientific consideration in the selection of muds
for use in toxicity tests has been that the sample be fresh.  Prac-
tical considerations that have influenced the selection of muds have
been the proximity of the well to EPA laboratories and EPA research-
ers, the availability of muds, and other factors related to the
logistics of obtaining samples.  The result has been that muds were
generally obtained in a manner partially determined by circumstances
at the time muds were needed for study.

     Mud samples used in the EPA program were selected in cooperation
with a number of oil companies, the Petroleum Equipment Suppliers
Association, and the Offshore Operators Committee.   Some samples
were selected and collected by oil industry personnel and shipped
directly to  the researchers or to the EPA Gulf Breeze, Florida
Laboratory,  from which they were transhipped as needed to the
researchers.  Other samples were collected directly by EPA personnel
and supplied to the researchers.  In addition, some researchers,
through their own initiative, obtained some mud samples outside usual
supply channels of the EPA program.  The sources of some of the muds
used in the  program are given in Table 3-1.  Additionally, tests are
being conducted using a reference mud prepared by the U.S. National
Bureau of Standards (see section 3.3.1.1.1).

     Mud samples were handled as expeditiously as possible.  Short-
term storage immediate after collection varied depending on who made
the collection.  Treatment of samples not collected by EPA were the
responsibility of whomever collected them.  Samples for biological
testing maintained at the EPA Gulf Breeze, Florida Laboratory were
kept cool or refrigerated until distributed to researchers.
*A controversy has arisen over the use of the muds obtained from
 the MOBIL well in Mobile Bay, Alabama.  The drilling permit  from
 the State of Alabama for this well did not allow the discharge of
 drilling muds to Mobile Bay.  Consequently, mud from this well was
 collected in barges and disposed of on land.  These particular muds
 may be considered atypical  of OCS discharged muds because some
 samples contained oil and/or high levels of chrome llgnosulfonate.
 At present, muds from other wells to be drilled in the same
 geological formation in Mobile Bay are being considered for  ocean
 disposal.
                                  3-3

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                       TABLE 3-1

   SOURCE OF SOME DRILLING FLUIDS USED IN RESEARCH
SPONSORED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY
                         SUPPLIER                   WELL
OPERATOR	OF MUD	LOCATION

                           USGS                  Louisiana
                           USGS                  Louisiana
AMOCO                      Artique               Florida
MOBIL                      Ayres/Ray             Louisiana
SHELL                      Ayres/Ray             Louisiana
EXXON                      Ayres/Ray             Louisiana
MOBIL                      Hellis                Alabama
EXXON                      Ayres                 New Jersey
EXXON                      Yowell                Florida
                          3-4

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     Mode of transportation and shipment conditions varied depending
on the person shipping the sample.  Oil company personnel were
responsible for shipping conditions for samples shipped directly to
researchers or to EFA.  Samples shipped to researchers by EPA were
generally sent unrefrigerated by the United Parcel Service.

     Samples were sometimes stored in a refrigerator at the EPA Gulf
Breeze Laboratory for longer periods until needed by researchers.  A
study found that there were no differences in toxicity between fresh
samples and those stored under refrigeration for long periods (Rao,
personal communication).

3.2.4  Rationale for Testing of Individual Mud Components

     Toxicity studies have been carried out on individual drilling
mud components known to be used in offshore drilling.  These compo-
nents have included biocides, barite, diesel fuel, clay, and com-
pounds of zinc and chromium.  Testing of single components of muds
may help identify those parts that are toxic.  A disadvantage of
component testing is that, under drilling conditions, these compo-
nents may react with other components of the mud or be altered so
that toxicity could be different than that determined from testing
unused mud components.

3.3  EPA RESEARCH PROGRAM

     Research has been undertaken at a generic level and within  two
lease areas of special concern in order to meet the general and site-
specific information needs of the EPA program offices and regions in
establishing discharge permit conditions.  The lease areas are:

     •  Flower Garden Banks, Gulf of Mexico

     •  Georges Bank, Gulf of Maine.

These areas were chosen for study over other proposed lease areas
(see Figure 1) because:

     •  drilling would occur in areas thought to be more biologically
        sensitive than other lease areas

     •  the areas had been proposed as marine sanctuaries under the
        Marine Protection, Research, and Sanctuaries Act

     •  the areas represented different temperature environments

     •  no drilling had ever taken place on Georges Bank, while  the
        Gulf of Mexico was an established drilling area.


                                 3-5

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An aggregated  summary  of  program areas  is  given in Table 3-2.

3.3.1  Generic Studies

     Generic studies have been undertaken  in  both the effects and
exposure assessment areas.   Project  schedules and total funding are
given in Table 3-3.

     3.3.1.1   Exposure Assessment

     Generic exposure  assessment studies have involved the charac-
terization of  drilling muds  and development of models for use in
predicting drilling mud transport and dispersion in the marine envi-
ronment.

     3.3.1.1.1  Characterization of  Drilling Muds.  Because of the
wide variation in  drilling mud composition, analyses of used muds to
which organisms have been exposed must  be  carried out in support of
effects assessment research.   Additionally, reference drilling muds
of known chemical  composition  are needed for comparative toxicity
testing and for use as chemical standards  for quality assurance in
analyzing used muds.

     Project Title;  Drilling  Fluid  Reference Standards for Chemical
     Analysis  (A-3 ) - Develop and provide drilling fluid reference
     standards for use in characterization efforts and in a quality
     assurance program to improve and maintain reliability of mea-
     surements made on discharges from  drilling and production opera-
     tions.

     Project Title:  Chemical  Analysis  of  Drilling Fluids (A-4*) -
     Provide data  on the  chemical analysis of tissue residues of
     organisms exposed to drilling fluids  and selected metals in
     drilling  fluids.

     Project Title;  Chemical  Analysis  for Energy Program (A-5*) -
     Provide organic analytical chemical support to the aquatic
     toxicity  testing  program  at the EPA Gulf Breeze Laboratory.
     3.3.1.1.2  Transport,  Transformation  and Fate of Drilling Muds
in the Marine Environment.   In  order  to  establish permit conditions
for discharges of drilling  muds under the  NPDES permit system, the
movement and behavior  of  the material in the marine environment must
be known in order to determine  the  zone  of initial dilution and to
*Page number of project  description  in  Appendix A.

                                  3-6

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                                                        TABLE 3-2

                AGGREGATED SUMMARY OF MAIN RESEARCH AREAS OF THE DRILLING FLUID HAZARD ASSESSMENT PROGRAM
   PROGRAM ELEMENT
                                                              1976    1977    1978    1979    1980    1981    1982
                                                              ***L(««J.««».L«BtX*««J.«*«J.a««J
UJ
I
GENERIC RESEARCH

  Chemistry of well profile
  Quality Assurance
     Feasibility, reference, trials
     Complex standard
  Plume modeling
  Symposium
  Adaptive Environmental Assessment Workshop
  Benthlc Communities
  Crustaceans
  Echlnoderms
  Telcost fish
  Literature Review
  State-oT-the-Art Review
  Synthesis of results
  Technical Assistance

FLOWER GARDEN BANKS

  Effects on Coral
     Respiration, growth, physiology, behavior
     Cage design
  Other Research

GEORGES BANK

  SedJment/organism relationships
  Benthic Larvae
  Commercially Important Species
     Toxlclty, accumulation, behavior
     Ecological Relationships

PROGRAM MANAGEMENT

  Experimental  design,  quality  assurance
  Semiannual peer program review
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	 1
	 	 .T
                                                             I	
                                                                                                  I	1
                                                                                            I	1
                                                                                                     T.	

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                                                                        TABLE 3-3

                                                     PROJECT SCIIKDIJIES  PUR GENERIC SIUIUKS OF FATE
                                                AND  EFFECTS OF  IIKII.I.ING FI.UII1S IN TDK MAR INK KNVlKONMhNT
             PROJECTS
             EXPOSURE ASSESSMtNT
                                                                                                       FISCAL YEAR
                                                                                                 76  77  78  79  80  81  82
                                                                                                                TOTAL FUNDING
                                                                                                                (Dollar In
                                                                                                                 Thousands)
OJ

CO
    Generic exposure  asbubument  studies  have Involved tlie characterization of
      drilling niidb ami development  of models tor use in predicting drilling
      mud tranaport nml dispersion In the marine  environment.

Characterization of Drilling Muds

    Because of the ulde variation in drilling composition,  analyses of used
      muds to whlrh 01 gnu I sins have been  exposed must  be  carried  out In
      support of effects assessment  research.  Additionally,  reference
      drilling muds of known chemical composition arc needed  for comparative
      loxlclty testing and for use as chemical standards for  quality
      assurance In analyzing used muds.

    drilling mid referenda ntandarda for ohemioal aiuilyoie
    Chemical analyaiu of drilling fluids
    Chsmiual aniliioia ffi- energy program

Tranaport. Tranaforin.-itIon and Fntc of Drilling Huds In the  Marine Environment

    In order to establish permit conditions  for dltirharRe of  drilling  muds
      under the NPDI'.S puna It system, the movement  and behavlnr of the  Material
      in the marine environment must be  known  In  order to determine the zone of
      initial dilution and to estimate exposure of effected ecosystems and
      organisms to pol lutniilu.

    Mixing none definition fop nanlaioyant diaahargea  in  oumtoft  of oeotion -i03(a)
      of the Cleiiii d'.itec Aji
                                                                                                                                  90
                                                                                                                                  18
                                                                                                                                 178
                                                                                                                                 III

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                                                              TABU: 3-3  (coniim.L.  h"°"'""•• °f "" «"«.l. «* drim£ .Is
       after dlmhnrgu ..„ marine ecosystem and orgonlM. uust be  oblalncd
       BO that opiiriiprl.nc  penult  conditions can be established.
     Totio, oublatlial ,m,l  latail  effeata of oeleated petroleum »i/uroTndirUH" VfT e"Wjr0""IC"t ""'lur -Pcclflc  cnmlltlons

      period of exposiuc on luurlne eLosyston.s aiid^prBanl'sM1™1 'U"S ''"rln8 Ul°

    Captation of luian,-,! auoeomtnt
                                                                                                                       214

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U)
                                                                       TABLE 3-3  (Conr I tided)

                                                   PROJECT SCHEDULES FOR GENERIC STUDIES Of  FATE
                                               AND EFFECTS OF DRILLING FLUIDS IN THE MARINE  ENVIRONMENT
                                                                                                                             TOTAL  FUNDING
           PROJECTS                                                                            _ FISCAL YEAH _  (Dollar  tu
                                                                                                76  77  78  79  80  81  82   Thousands)



           SUPPORT 1U THE KI'.SEAKCII  tFFORTS

               Urcuusc thu reoonri.li efforts  are mulil-aguin.y and multi-Investigation
                 efforts, cinuiiiiiiilr.il Ion and  dlsucinlnatlun of Information among the
                 Intercbtutl parties Iti  nccdoil lo impruvc lliu viiurdliul Ion and
                               of efforts.
                          iwieu of environmental effauto of uell-drilling, ahaniaiila                            _ X           30
               KffealB of ohemiaalo uaed in offohove oil and gas drilling operationo                            __ X          4Bft
                 on miirina organ iomo                                                                                          3,1 90 TOTAL
           X'Projcct ruport or product.

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estimate exposure of effected ecosystems and organisms to pollutants.
A computer model is under development for use as a predictive tool in
determining dilution and dispersion of a discharge from a proposed
platform.  Field studies underway on the Flower Garden Banks of  actu-
al discharge plumes will also contribute to a general understanding
of plume behavior.

     Project Title;  Mixing Zone Definition for Nonbuoyant Discharges
     in Support of Section 403(c) of the Clean Water Act (A-6")  -
     Develop or revise mixing-zone calculation methods for industrial
     discharges, emphasizing ones containing fluids, emulsions,  and
     suspensions heavier than marine water, or those which, in gen-
     eral, behave differently than municipal wastes for which mathe-
     matical models are available.

     Related Project Title;  Assessment of Exposure of the Texas
     Flower Garden to Pollutants Originating from Drilling Rigs  -
     see section 3.3.2

     Related Project Title:  The Erodibility of Drilling Muds
     Deposited on the Sea Floor - see section 3.3.3
     3.3.1.2  Effects Assessment

     Since drilling muds and fluids contain components that are
potentially toxic to marine organisms, knowledge of the effects of
drilling muds after discharge on marine ecosystems and organisms must
be obtained so that appropriate permit conditions can be established.
Generic projects in this area are laboratory studies.  Information
gained in regional studies will also contribute to the overall under-
standing of the effects of drilling muds in the marine environment.

     Project Title;  Toxic, Sublethal and Latent Effects of Selected
     Petroleum Hydrocarbons and Barium Sulfate on Marine Organisms
     (A-7 ) - Expose marine organisms, with emphasis on crusta-
     ceans, to components of drilling fluids.  Determine acute and
     sublethal toxic effects and the potential for bioaccumulation of
     materials.

     Project Title;  Behavioral Assays for the Effects of Drilling
     Muds on Marine Animals (A-8 ) - Develop a device capable of
     measuring the behavioral responses of the scallop to drilling
     fluids.
*Page number of project description in Appendix A.

                                 3-11

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     Project Title;  Laboratory and Field Studies of Used Drilling
     Fluids and Fluid Formulation Components on Benthic Communities
     (A-9 ) - Develop and apply methods for determining the effect
     of diesel oil on a marine offshore benthic community microcosm.

     Project Title;  Offshore Pollutant Effects Program** (A-10*)
     - Utilize offshore platform (Stage I) in the Gulf of Mexico 19
     km south of Panama City, Florida owned and operated by the
     Naval Coastal Systems Laboratory for experiments on oceanic
     species for comparison with data obtained on estuarine species
     in other laboratory research projects.

     Project Title;  The Effect of Drilling Mud on Marine Organisms
     (A-11K) -Provide support for the operation of Stage I, and
     offshore research laboratory in the Gulf of Mexico near Panama
     City, Florida.

     Project Title:  Effects of Drilling Mud Constituents on the
     Sedimentary Microflora and the Base of the Marine Benthic Food
     Web (A-12 ) - Determine effects that result from exposure of
     marine organisms.

     Project Title:  Effects of Soluble Fractions of Drilling Fluids
     on Larval Development and Behavior of Callinectes sapidus and
     Rhithropanopeus harrissii (A-13 ) - The research Includes
     measurements of drilling fluid effects on (a) long-term
     development of crab larvae, (b) short-term development of
     specific larval life stages, (c) swimming speed of larvae, and
     (d) positive or negative phototaxis of the larvae.

     Project Title;  Effects of Drilling Fluids on Embryo Development
     (A-14 ) - The effects of drilling fluids on the developmental
     stages of the embryos of fish and echinoderms will be deter-
     mined.

     Project Title;  Effects of Barium Sulfate on Fertilization and
     Early Development (A-15") - The effects on sea urchin gametes
     and  embryos will be assessed.  The cellular events which are
     disturbed by barium sulfate will be characterized and the
     concentrations necessary to induce these perturbations will be
     determined.
**.
*Page number of project description in Appendix A.
 'This project has been terminated because of  storm  damage to the
 platform.


                                3-12

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     Related Project Title;   Development of Components of  a Monitor-
     ing System - see section 3.3.2.

     Related Project Title;   New Methodologies for Measuring Energy-
     Related Consent Decree Toxic Compounds in the Marine  Environment
     - see section 3.3.2.

     3.3.1.3  Hazard Assessment

     A hazard assessment is the integration of knowledge of concen-
trations of drilling fluids that occur in the environment  under spe-
cific conditions (exposure assessment) and the effects of  these
concentrations during the period of exposure on marine ecosystems and
organisms (effects assessment).

     Project Title;  Completion of Hazard Assessment Program
     (A-16 ) - synthesize existing literature and conduct  a limited
     amount of research on the effects of the fluids on selected
     marine organisms.  Principle efforts will the directed toward
     completion of the five-year Drilling Fluid Hazard Assessment
     Program.

     3.3.1.4  Support to the Research Efforts

     Because the research on the effects of drilling fluids on the
marine environment are multiagency and multi-investigator  efforts,
communication and dissemination of information among the interested
parties is needed to improve the coordination and effectiveness-of
the efforts.

     Project Title;  Literature Review of Environmental Effects of
     Well-Drilling Chemicals (A-1731) - Prepare a review of avail-
     able literature on the origins, fate and effects of chemicals
     discharged from oil and gas drilling operations into  the marine
     environment.

     Project Title:  Symposium on the Effects of Chemicals Used in
     Offshore Oil and Gas Drilling Operations on Marine Organisms
     (A-18 ) - Establish program committee for symposium,  advertise
     meeting, select papers and session chairmen, hold meeting, pub-
     lish proceedings.
*Page number of project description in Appendix A.


                                 3-13

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3.3.2  Flower Garden  Banks,  Gulf  of  Mexico

     Presently  being  investigated by several  Federal  agencies  includ-
ing EPA is the  potential  impact of proposed oil and gas drilling
activities near the Flower Garden Banks  in the Gulf of Mexico.  This
bank, located 120 nautical miles  south of  Cameron, Louisiana,  con-
tains the northernmost  tropical coral reefs in the Gulf of  Mexico.
At issue is the potential harm that  could  result  to the reef system
from drilling muds discharged from platforms  in the vicinity.   Of
chief concern is that turbidity and  sedimentation of  muds could
adversely affect the  coral.

     At present the U.S.  Department  of the Interior requires that
drilling should be limited to the edge of  the bank and effluents from
the platforms must be released to the naturally turbid layer of water
near the bottom (nepheloid layer), where the material would probably
remain in the lower density  layer.   Since  coral growth is primarily
restricted to surface waters,  such a discharge practice should, in
principle, protect the  coral reef ecosystem.  The certainty of  this
protection is only conjecture, however,  since no  research has  been
undertaken to verify  its  accuracy.   Consequently, EPA has undertaken
laboratory and  field  studies of the  effect of drilling muds on  reef
organisms and field studies  of discharge plume behavior.  Some
specific discharge-related questions being addressed  by EPA research
are as follows:

     o  Are drilling  fluids  or their components toxic to sclerac-
        tinean  corals in  laboratory  testing?

     o  Given the dispersion of discharged materials  during drilling
        operations, will  actual concentrations and exposure duration
        be produced that  will adversely  and significantly affect the
        coral reef ecosystem?

     o  Will discharge  of fluids  to  the  nepheloid layer protect
        corals  from toxic drilling fluids  if extensive oil  and  gas
        field development takes place?

     o  What is the expected and  worst case of exposure to  the  reefs
        likely  to be  encountered  during  production drilling?

     o  Under actual  surface discharge conditions, what minimal dis-
        tance from the  reef  ecosystem is needed to mitigate against
        adverse exposure?

     The research program on the  Flower  Garden Banks  encompasses an
exposure assessment and an effects assessment.  In addition, biologi-
cal monitoring  methods  necessary  to  carry  out the research  program

                                  3-14

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are under development.   Several activities designed to support the
overall research effort are also included, as is technical support to
Region VI on an as-needed basis for permit review.  The schedule and
total funding for research projects is given in Table 3-4.

     3.3.2.1  Exposure Assessment

     Research has focused on dilution, dispersion, and fate of the
plume of drilling fluid discharged from the platforms and on deter-
mining the extent of resuspension of drilling muds from the bottom.

     Project Title:   Assessment of Exposure of the Ecosystem of
     the Texas Flower Gardens to Pollutants Originating from Oil
     and Gas Drilling Rigs (A-20") - Determine the transport,
     transformation and fate of materials discharged from drilling
     platforms.  Field measurements of dispersion of particulate and
     dissolved components of fluid discharges will be used to devel-
     op predictive computer models for estimating dosage of ecosys-
     tems from wells near the Flower Garden Banks.

     Related Project Title;  The Erodibility of Drilling Muds Depos-
     ited on the Seafloor - see section 3.3.3.

     3.3.2.2  Effects Assessment

     The EPA research effort has focused on laboratory studies of the
effect of drilling nuds on reef organisms, principally corals.  A
field study of reef  fish is also planned.

     3.3.2.2.1  Coral Research.  These efforts are aimed at deter-
mining what effects drilling fluids have on reef-building corals and
what indicators of toxicity might be useful in field studies.  Cri-
teria for measuring coral stress include respiration nitrogen, liplds
in corals and zooxanthellae, amino acids and rate of calcification,
and neurochemclal and other biochemical characteristics.

     Project Title;   Offshore Laboratory Studies of the Impact of
     Used Drilling Fluids on Behavior of Corals Representative of the
     Flower Garden Banks (A-21") - Expose corals to drilling fluids
     and determine the rate of sediment removal or polyp contrac-
     tion.
*?age number of project description in Appendix A.


                                 3-15

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                                                             TARI.E  J-4


                                    PKO.IECT SCHEDULES FOR STUDIES OP FATE  All!) EFFECTS OF
                                UKILLING FLUIDS ON 'IIII! FI.OWEU HARDEN HANKS.  GULF OF MEXICO
 PROJECTS
                                                                                             FISCAL YEAR
                                                                                       76  77  78   79   80  81
                                               TOTAL FUNDING
                                          	  (Dollar In
                                           82   Thousands)
 EXPOSURE ASSESSMENT

     Kcaejrc.li linu foriibi-d on dilution and  fnln of tlic plume of drilling  fluids
       discharged from I lie- ulatfornui.

     Aoaeaament of e.\.poaura of the ecoayalein of the Texaa Garden Banks to fiol-
       lutanta oriyinn tiny fivm oil and gaa  drilling t'iga

 EFFECTS  ASSESSMENT

     The  research cffoit li-iu focused on laboiatory studies, principally  corals.

 Coi.-il  Research

     Offuhore laboratory ntudico of the impaot of uaed tli'illin.j fluids oil behavior
       of aonilo rci>raadilative of the  t'loiMi' Ciu'dcn A.inAo
     Kffeata  of drillintj fluids and oil on oontl  oa.nifying hai\l bank aaamaiitica
     BioalMiiiaal anatyaaa on coral ami  othei" inuevtalivite metabolia aotiaitiea
       and nutritioniil alnLite aith exyoaura  to oil and gaa drilling mid
     Efftiata  of drilliiKj mud on ooralo:  aome biochemical and nam-oloyical aapeota
     Effects  of offalwe oil and gaa drilling on  i-aaf building aural a
     Effeato  of oil'drilling lauda on the iilujniologij and nutritional at
       Texas  Floacr Garden Reef aoral
     I'hyuiaal and <:>Mtiiijril effentu of drill mud on aorai skeleton

Oilier  licBudrch

    Comparison of i-aaf fiitli palliations at  the floasr Cm-den Hmka and at oil and
      ijaa drilling [>lat.fo,inn
    Toxic a,Ul Mblethal  cffcutn  of uaatc drilling muij and certain vhronmm „„.
      I'Oimda in CruuUinaann
status of
                                                   790
SOO

 64
 92

117
IBB
114

 If,
                                                  660


                                                  261

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                                                                      TADLK  3-4 (Concluded)

                                             PROJECT SCIIEDIHbS KOK STUDIES OK FATK AND EFFKLTS OF
                                         "RILLING I'UIIOS OH TIIK FMWER fiARDUl BANKS.  ClILF OF HKX1CO
          PROJECTS
                                                                                                      FISCAL YEAR
                                                                                                76   77   78  79  BO  81
                                                                                                                    TOTAL FUNDING
                                                                                                               	  (Dollar  In
                                                                                                                82   Thousands)
u>
         KI'FbCTS  ASSESSMENT (Cont.)

         Biological MonltoiliiB Methods
                 of iiomitunantB of a monitoring oyotem
           (I)   'fetharuj atuja
          (II)   Evaluation of deoicttu and materials for aeauatcr ahemioal  aamyle
                 aollention -  {nimanaentration and analyoio
         (III)   Aut»Mnutia ncmpler for traae  organiao in marine uater
    «c« methoduloyiea f,»- maaouring energy-related oonaent decree toxio aom-
      pounila in tlia miiriuo environ/riant

sueroKT TO me  RESLAKCII KFFOK-IS

    UucaiiHc ilic rchuiin.li iiffurta In tlie Flower Garden Bnnka urea Is a nultl-
      liwchtli-alur and toiil t l-ugcncy effort,  communication and dissemination
      of  Infurmiitluii aiming Hie Jntcrcnted parties la nuudcd to iapiove co-
      ord I nut Ion and effectiveness of these efforts.
                       eiivitviaiiantiil aaaaaamant uorkohopo on drilling mud diapoeal
              Identifiaat inn of iiKiafoinftuoia fi\m ex\tevimenta tiotiduoted at  the  U.S.  Hai'y
               I'latfomi "fft.nje I."

         TKCIINICAI.  ASS1STANCIC 'I'D hl'A KECIUN VI

              bl'A  Ki-cliin VI  requires technical assistance In dlucliarcc permit natters

              'fauhniaal aaaiatanuc to Kl'A Region  VI
                                                                                                            as  net-dud
                                                                                                                                  100
                                                                                                                                  30

                                                                                                                                  HO
                                                                                                                                 400
                                                                                                                         97
                                                                                                                         14
                                                                                                                                 All.
                                                                                                                               3.956 TOTAL
                   ii-|nirt or

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     Project Title;  Effects of Drilling Fluids and Oil on Corals
     Occupying Hard Bank Communities (A-22") - Test the toxicity of
     a variety of drilling fluids to corals under laboratory and
     field conditions.

     Project Title:  Biochemical Analyses on Coral and Other Inverte-
     brate Metabolic Activity and Nutritional Status with Exposure to
     Oil and Gas Drilling Mud (A-23") - Develop and test biochemi-
     cal measures of the effects of drilling muds on (1) the coral-
     zooxanthellae interaction using lipid analysis, (2) the nutri-
     tional status with the triglyceride, wax ester, phospholipid
     ratio, (3) the metabolic status of corals using the lipid anal-
     ysis and gas chromatograph/mass spectrometry.

     Project Title:  Effects of Drilling Mud on Corals:  Some Bio-
     chemical and Neurochemical Aspects (A-24") - Study the effect
     of drilling mud treatment on some biochemical and neurochemlcal
     aspects of coral physiology.  Specifically, these studies will
     include the evaluation of protein, nucleic acid, energy and
     catacholamine metabolism.

     Project Title;  Effects of Offshore Oil and Gas Drilling on Reef
     Building Corals (A-25") - Expose corals to drilling fluids at
     the EPA-leased Navy platform in the Gulf of Mexico south of
     Panama City, Florida, and measure effects by time-lapse photog-
     raphy.

     Project Title:  Effects of Oil Drilling Muds on the Physiology
     and Nutritional Status of Texas Flower Garden Reef Coral
     (A-26") - 1) Determine Che effects of various concentrations
     of whole drilling mud on respiration, nitrogen excretion and
     calcification in a reef coral. 2) Determine the effects of
     various concentrations of whole drilling mud on the nutritional
     states of reef corals. 3) Send exposed corals to other inves-
     tigators for complementary biochemical and histopathological
     Investigations.

     Project Title;  Physical and Chemical Effects of Drill Mud on
     Coral Skeletons (A-27 ) - measure the physical and chemical
     record in coral skeletons using density of minerals deposited in
     the skeleton during periods of growth.
*?age number of project description in Appendix A.


                                 3-18

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     3.3.2.2.2  Other Research.  The effect of drilling fluids on

reef fish populations and crustaceans is being determined.

     Project Title;  Comparison of Reef Fish Populations at the
     Flower Garden Banks and at Oil and Gas Drilling Platforms
     (A-28*) - Assess the biological characteristics of natural
     reef fish populations and compare them with those of reef fish
     populations associated with oil and gas platforms in the
     northwestern Gulf of Mexico.

     Project Title:  Toxic and Sublethal Effects of Waste Drilling
     Muds and Certain Chromium Compounds in Crustaceans (A-29 ) -
     Laboratory experiments will be used to investigate the effects
     of drilling muds and their components on crustaceans.
     3.3.2.2.3  Biological Monitoring Methods.  Validation of labora-
tory experiments in the field require methods for exposing organisms
to chemical and physical conditions in the drilling fluid plume.
Also needed are methods to monitor conditions in the plume.

     Project Title:  Developments of Components of a Monitoring Sys-
     ~tem - (I) Tethered Cage (A-30") - The cage would be capable of
     maintaining its position in the thermocline and would be fitted
     with special devices for remotely monitoring the health status
     of the caged animals.

     Project Title:  Development of Components of a Monitoring
     System - (II) Evaluation of Devices and Materials for Seawater
     Chemical Sample Collection, Preconcentration, and Analysis
     (A-31 ) - The program has three objectives:  Determination of
     performance and contamination characteristics of existing moni-
     toring systems, specifically those that will be used in Texas
     Flower Gardens research; evaluation of preconcentration mate-
     rials; and, development of laboratory analytical techniques.

     Project Title;  Development of Components of a Monitoring
     System - (III) Automated Sampler for Trace Organics in Marine
     Waters (A-32 ) - The Sampler should be able to collect
     particulate and dissolved materials samples and preserve both in
     uncontaminated condition until removal for subsequent analysis.
     The sampler should be programmable in terms of sampling inter-
     vals and freqencies and the collected samples should be ready
     for analysis without significant additional handling or
     processing.
*
 'Page number of project description in Appendix A.

                                  3-19

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     Project Title;  New Methodologies for Measuring Energy-Related
     Consent Decree Toxic Compounds in the Marine Environment
     (A-33") - This project has three objectives:(1) validated
     methods for separating trace organic marine pollutants into
     major chemical classes and removal of natural marine organics
     that interfere with pollutant analysis; (2) validated techniques
     for final detection, identification and measurement of individ-
     ual trace organic pollutants; and (3) identification of poten-
     tially hazardous organic pollutants from marine vater samples
     from the Texas Flower Gardens as well as from areas near various
     ocean outfalls.
     3.3.2.3  Support  to  the Research Efforts

     Because the research efforts  in the Flower Garden Banks area is
a multi-investigator and  multi-agency effort, communication and dis-
semination of information among  the interested parties is needed to
improve the coordination  and effectiveness of these efforts.  The EPA
program includes an adaptive environmental assessment workshop and
taxonomic identification  in support of research activities.

     Project Title:  Adaptive Environmental Assessment Workshop on
     Drilling Mud Disposal (A-34*) - A scoping meeting with EPA
     personnel will be held to identify the specific problem to be
     addressed by a hypothetical model.  Staff assistance and guid-
     ance will be provided by DOI  in conducting an EPA-sponsored
     adaptive environmental assessment workshop.

     Project Title;  Identification of Macroinfauna from Experiments
     Conducted at the  U.S.  Navy  Platform "Stage I" (A-35 ) - Iden-
     tify benthlc organisms in support of  "Stage I" research on the
     effects of drilling  fluids  on marine organisms.
     3.3.2.4  Technical Assistance  to EPA Region VI

     EPA Region VI requires  technical assistance in discharge permit
matters.  This assistance will  be provided  as needed for permit
review.
*Page number  of project description in Appendix A.
                                  3-20

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     Project Title:  Technical Assistance to EPA Region VI (A-36*)
     - The EPA Gulf Breeze Environmental Research Laboratory will
     provide technical assistance to EPA Region VI on NPDES
     permitting of discharges from offshore oil and gas drilling
     activities.

3.3.3  Georges Bank, Gulf of Maine

     Georges Bank is a shallow submarine bank located off Cape Cod
along the southern boundary of the Gulf of Maine.  Leasing for
exploratory drilling in this area has taken place.  Exploratory
drilling will begin in the summer of 1981.

     The fishery of the Georges Bank is among the most productive in
the world.  Commercially important species include haddock, cod, pol-
lack, whiting, lake cusk, American dab, yellowtail flounder, grey
sole, sea herring, flounder, and lobster.  The ecological processes
that support the rich fishery are not clearly understood.  However,
productivity is related to an annual cycle of succession of benthic
organisms.  Winter storms scour the bottom, leaving many areas barren
of biota.  Springtime mlcrobial blooms reduce erosion of sediments
through a kind of gluing process.  Meiofauna and macrofauna then
dramatically increase their biomass in sediments.  This productive
habitat supports a diverse community of groundfish and crustaceans.

     At issue on the Georges Bank is the potential harm that could
occur to the commercial fishery from drilling activities, particu-
larly from the discharge of drilling muds.  To address this issue,
EPA research has focused on the effects of drilling fluid on the
following:

     •  Laboratory studies on the effect of commercially important
        species

     •  Benthic communities and organisms

     •  Sediment-animal relationships

     •  Sediment credibility.

     Exposure assessments and effects assessment have been under-
taken as part of the Georges Bank research.  Project schedules and
total funding are  given in Table 3-5.
 *Page number  of  project  description  in Appendix A.
                                  3-21

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                                                                    1'ABLK  3-5

                                                     PROJECT SCHEDULES FOR STUDIES OF FATE
                                        AND EFFECTS  OF DRILLING FLUIDS ON GEORGES BANK. GULF  OF MAINE
          PROJECTS
                                                                                                      FISCAL YEAR
                                                                                                76   77  78  79  80  81
     TOTAL FUNDING
	  (Dollar In
 82   Thousands)
U)
IN}
ro
EXPOSURE ASSESSMENT

    Because no drilling has  taken  place,  no field studies related to discharge
      Illume liehavloi have been planned.

    The erodibilitii of drilling muda  derailed on the sea floor

EFFECCS ASSESSMENT

    Research Is iindci way on loxlulty to  adults,  behavioral effects, and larval
      development utilizing  several  Important species of the Georges Rank area.

    Ton!city mid Oilier Effuits
         Kffoato of drilling naid on ailult American lobster
         Di-illing fluid effects to developmental  stages of tho American I*>l>star
         Feeding, rc\>\i>,luation and habitat  selection of lobster IJomarua_ Anurioanua-
           effeats of drilling^ niutl in laboratory  and field situations
         The cffeclu of drilling muds on  tha  behavior and benthio eaolijgij of
           three \judul a^aaiea
                   A  eluthj of f/iu- tnuwat of diaeli-uyej drilling fluid on the  oiyanioma
                     of tlecn-gev flniiA.

              Rffectu on Benlhlc UuiiuuunlrJes and Animal-Sediment Relationships
                  The im\>aoL t>f drilling mula on standing atuc.ka and  metal*) lie  aativitias
                   of aedimaiit hfi.ilan'a
                  Benthia i-onnutni ties and drilling fluid effects on the  conditions for
                   larval settl>yn^ait on the Georges Bank
                                                                                                                                15'.
         112
          30
         134

         118

         405
          60
        __
       1 . 1 14 TOTAI.
                                                     cslu»""'!
                                                                         f,o» areas other  thnn  the  Georges Bank.

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     Recent settlement of two law suits regarding research on the
Georges Bank (Commonwealth of Massachusetts vs. Andrus; Conservation
Law Foundation of New England vs. Andrus) has established the Depart-
ment of the Interior as the agency responsible for conducting stud-
ies.  EPA will provide recommendations for research through its
participation on the Biological Task Force that has been established
to advise the Department of the Interior.  The EPA will not be fund-
ing drilling mud research specific to Georges Bank in FY82.

     3.3.3.1  Exposure Assessment

     Because no drilling has taken place, no field studies related to
discharge plume behavior have been planned as part of the EPA Georges
Bank research effort.  A laboratory study of drilling-fluid-affected
sediment credibility will be carried out because of the importance of
sediment dynamics in determining ecosystem structure and function.
Transport models developed as part of the generic studies could be
applied to the Georges Bank environment.  Plume studies carried out
in the Flower Garden Bank area of the Gulf of Mexico will also pro-
vide knowledge that could be applied to the Georges Bank situation.

     Project Title:  The Erodlbillty of Drilling Muds Deposited on
     the Sea Floor (A-38") - Laboratory flume studies and field
     observations will be used to determine drilling mud stability
     once deposited on the bottom.

     Related Project Title;  Mixing Zone Definitions for Nonbuoyant
     Discharges in Support of Section 403(c) of the Clean Water Act -
     section 3.3.1.

     Related Project Title;  Assessment of Exposure of the Ecosystem
     of the Texas Flower Garden Bank to Pollutants Originating from
     Oil and Gas Drilling Rigs - section 3.3.2.

     3.3.3.2  Effects Assessment

     Research on effects of drilling fluids consists of the following:

     •  Laboratory studies of toxicity and other effects on important
        species of the area

     •  Effects on benthic communities and animal-sediment relation-
        ships
*Page number of project description in Appendix A.
                                 3-23

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     3.3.3.2.1  Toxlcity and Other Effects.  Research is under way on
toxiclty Co adults, behavioral  effects,  and larval development util-
izing several important species of the Georges Bank area.

     Project Title;  Effects of Drilling Mud on Adult American Lob-
     TFers (A-39*) - The effects of drilling muds on feeding, molt-
     ing, mating, predator  escape, shelter behavior, and substrate
     selection will be determined  by controlled laboratory experi-
     ments , in seminatural  environments, and by observations in the
     field.

     Project Title:  Drilling Fluid Effects to Developmental Stages
     of the American Lobster (A-40*) - The effects of used, whole
     drilling fluids on larval  and postlarval stages of the lobster
     will be assessed.

     Project Title;  Feeding, Reproduction and Habitat Selection of
     Lobster, Homarus Americanus - Effects of Drilling Mud in Labo-
     ratory and Field Situations (A-41 ) - Field, laboratory and
     neurophysiological studies of the behavior of larval and young
     lobsters and the relation  to  exposure to drilling fluids will be
     carried out.

     Project Title:  The Effects of Drilling Muds on the Behavior and
     Benthic Ecology of Three Gadid Species (A-42*) - The effect of
     muds on juveniles will be  determined.

     Project Title;  A study of the Impact of Discharged Drilling
     JTuid on the Organisms of  the Georges Bank (A-43 ) - Toxicity
     tests will be undertaken.

     3.4.3.2.2  Effects on  Benthic Communities and Animal-Sediment
Relationships.  Because of  the  importance of the benthic community
to the structure and function of the Georges Bank ecosystem, research
on the effects of drilling  fluids  on the benthic community and ani-
mal-sediment relationships  is an important part of the EPA program.

     Project Title;  The Impact of Drilling Muds on Standing Stocks
     and Metabolic Activities of Sediment Bacteria (A-44") - This
     project will examine the impact of  drilling mud on bacteria
     populations. Bacterial populations  from sediment samples will be
     counted and their growth rates determined.
*Page number of project description  in Appendix A.
                                 3-24

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     Project  Title;   Benthic  Communities  and Drilling Fluid Effects
     on the Conditions  for Larval  Settlement on  the Georges Bank
     (A-45")  - Traps  will be  used  for in  situ  experiments  on  the
     effects  of drilling fluids  on larval settlement.
*Page number of project description in Appendix A.


                                 3-25

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                     4.0 RESEARCH RESULTS TO DATE

4.1  INTRODUCTION

     Most of the work initiated as part of the Drilling Fluids Hazard
Assessment Program is now yielding preliminary results.  Addition-
ally, results of studies undertaken by other Federal agencies and the
oil industry are becoming available.  Corroboration of these initial
results must await completion of work in progress and additional
scrutiny and verification of the results by the scientific community.

     Given below is a brief overview of the results to date of EPA
and some other research.  The results discussed are divided into
exposure assessment and effects assessment.  Exposure assessments
have been grouped into the following categories.

     •  Field studies of discharge plume dispersion

     •  Models of plume dispersion

     •  Sedimentation and monitoring studies

Effect assessment studies have been grouped into the following
categories.

     •  Pentachlorophenol tests

     •  Short-term toxicity tests

     •  Long-term toxicity tests

     •  Bioaccumulation studies

     •  Effects on benthic communities

     •  Effects on corals

4.2  EXPOSURE ASSESSMENT

     Available research results related to exposure assessment mostly
deal with field studies of dispersion and  fate of drilling fluid dis-
charges from exploratory drilling platforms.  These studies have been
carried out by the oil industry.  Studies  sponsored by EPA are in an
early stage.
                                 4-1

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4.2.1  Field Studies  of Discharge Plume Dispersion

     At present, five studies  of discharge  plume dispersion of dril-
ling fluids from offshore  platforms carried out by oil companies have
been published.  Four of these studies have involved open ocean
situation and one a tidal  embayment:

     •  Mid-Atlantic  Ocean (Baltimore Canyon)

     •  Gulf of Mexico (two  studies)

     •  Lower Cook  Inlet,  Alaska

     •  Southern California  Shelf  (Tanner Bank)

The research design and documentation is considered adequate on only
four of the five studies (Ayers et al.,  1980a,  1980b; Ray and Meek,
1980; Houghton et al., 1980).   One of the Gulf of Mexico studies (Ray
and Shinn,  1975) is considered flawed, so that  the validity of the
results cannot be established  with any degree of confidence.  These
studies have been critiqued by Petrazzuolo  (1981).

     Several general  observations have resulted from the four studies
for which documentation of  methods and findings is considered ade-
quate.

     •  Two plumes  form when the material leaves the discharge pipe.
        A lower heavier plume  contained  the bulk of the solids and
        descended rapidly.   The upper plume, containing five to seven
        percent of  the suspended solids, remained in the water column
        for a much  longer  period and drifted away from the source
        with the prevailing current.

     •  Dilution factors of  several hundred to  several thousand were
        reached within a few meters of the  discharge.  Wave-induced
        mixing within the  submerged portion of  the discharge pipe may
        contribute  significantly to this dilution.

     •  Background  concentrations of suspended  solids in the upper
        long-lasting  plume were achieved within 500 ai to 1000 m of
        the source. These  results were variable depending on a number
        of conditions, such as sea state and discharge rate.

     •  Dilution of the discharge is enhanced by the turbulent wake
        created by  the drilling rig.  This  result was suggested by
        modeling and  in-situ measurements at the well in Lower Cook
        Inlet, Alaska (Houghton et al.,  1981).  Additional observa-
        tions are necessary to confirm this, however.


                                  4-2

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4.2.2  Models of Plume Dispersion

     The modeling effort by EPA related to discharges is just begin-
ning.  Several modeling efforts by the oil industry have been under-
taken.  These studies have been critiqued by Petrazzuolo (1981). The
results of  plume dispersion measured for a well in the Lower Cook
Inlet were fitted to several types of plume dispersion models.

     •  Discharge of a jet in deep water

     •  Plume would follow the behavior of wake dispersion and growth

     •  Thermal plume model

Although these models are designed to simulate continuous releases,
the best fit to the field data was achieved for bulk discharges.  No
real satisfactory fit to continuous discharge data was achieved with
any of the models.

     A computer model of drilling fluid plume dispersion has been
developed by Brandsma et al. (1980).  The model is an evolution of
earlier models for dredged material discharges.  The discharge is
assumed to originate as a jet.  There are three phases of plume
dispersion:

     •  Jet phase - entrainment of ambient fluid and reorientation of
        the plume to the ambient current

     •  Dynamic collapse - occurring either when the plume reaches
        the bottom or arrives at the level of neutral buoyancy, at
        which time horizontal spreading dominates.

     •  Passive diffusion - commences when transport and spreading of
        the plume is determined more by ambient currents and currents
        than by any dynamic character of its own.

     The model results were compared to field data of a fluid release
from a well in the Gulf of Mexico (Ayers et al., 1980b).  The model
results and field data agreed fairly well with respect to vertical
profiles at various distances from the discharge pipe.  The tendency
was for the calculated profile to be located at somewhat shallower
depths in the near field and somewhat deeper depths in the far field.

4.2.3  Sedimentation and Monitoring Studies

     The results of eight studies of sedimentation from drilling
operations have been reviewed by Petrazzuolo (1981).  All of the
studies suffer from some problems with research design,  methodology,


                                 4-3

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or documentation  that  reduce confidence in the results or make it
more difficult  to  draw conclusions.   Several of the studies  have  such
serious flaws  that they are  of little utility in determining the
environmental  fate of  drilling fluids and cuttings.

     Ayers et  al.  (1980b)  have reported on sedimentation of  material
from a 275 bbl/hr. and a 1000 bbl/hr. discharge from a well  in the
Gulf of Mexico.   Sediment  traps were placed from 30m to 200m downcur-
rent of the discharge.  Solids in the lower plume (see Section 4.2.1)
were deposited  on  the  bottom within  10m of the discharge, so no mate-
rial from this  plume was collected in the sediment traps. Movement
of the discharge  pipe  during the 1000 bbl/hr.  release introduced
uncertainty into  the results, since  the pipe was securely clamped in
place during the  275 bbl/hr. test.

     Material  collected in the traps was one to two orders of magni-
tude greater at  100m to 200m during  the 1000 bbl/hr. release than
during the 275  bbl/hr. release.   The transport time for barium was
increased relative to  suspended solids.  Thus, the barium to sus-
pended solids  ratio in sedimented material is less than half the
ratio in the discharged material, suggesting that the barium content
of the material remaining  in the water column is relatively
increased.

     Sediment  barium levels  as a function of distance from the plat-
form before and after  drilling have  been determined at three wells
in the Gulf of  Mexico  (reviewed in PeCrazzuolo, 1980).  The  post-
drilling levels in these three studies exhibited a consistent pattern
as a function  of distance  from the source.  When considered  as a
whole, the post-drilling sediment barium content appeared to follow
generally the  inverse  square root of the distance.  The data did  not
conclusively support a square root dispersion model, but indicate
that further study of  this relationships may prove fruitful.

4.3  EFFECTS ASSESSMENT

     Many studies  of the effect of drilling fluids on marine orga-
nisms have been undertaken since the inception of the EPA Drilling
Fluids Hazard  Assessment Program.  Some early results are available
from EPA sponsored studies.   Other studies have been funded  by the
oil industry.   Many results  have been published in the proceedings of
a recent symposium (Research on Environmental Fate and Effects of
Drilling Fluids and Cuttings, January 1980).

4.3.1  Pentachlorophenol Tests

     Early in  the  EPA  research Program the potential toxicity of  the
biocide pentachlorophenol, which was used in some drilling muds,  was

                                  4-4

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examined.  A symposium was sponsored by EPA at which the toxic effect
and distribution of this compound was discussed.  Subsequently its
use was banned by the U.S. Geological Survey.

4.3.2  Short-Term Toxicity Tests

     Results of 96-hour toxicity tests sponsored by EPA using barite
and used drilling muds have been reported by Conklin et al. (1980).
The toxicity of 18 different samples of muds from a well in Mobile
Bay, Alabama, was tested (see Section 3.2.3).  None of the muds was
toxic to intermolt grass shrimp Palaemonetes pugio at mud
concentrations of 10 and 100 ppm.  But at a concentration of 1000
ppm, six of these muds caused 30 to 60 percent mortality of intermolt
grass shrimp, while one mud caused 100 percent mortality.  Toxicity
tests with molting grass shrimp yielded LC 50 values of 363 to 739
ppm for 5 of the mud samples.

     The toxicity of four types of used chrome lignosulfonate dril-
ling mud-seawater mixtures to different life stages of the opossum
shrimp Mysidopsis almyra Bowman was evaluated by Carr et al., (1980).
The mud-seawater mixtures were also prepared with a natural reference
sediment obtained from San Antonio Bay, Texas, in order to determine
the deleterious effects of exposure to naturally occurring fine clay
particulates as opposed to those of drilling mud origin.

     No appreciable mortality was observed for one-day old juveniles
exposed  to reference sediment-seawater mixtures while similar expo-
sures to drilling mud preparations were acutely toxic.  Drilling mud
particulates were harmful to juvenile mysids.  However, the majority
of  the toxicity of the used drilling mud resided in the water-soluble
and fine particulate fractions of the mud.  The 96 hour LC50 values
for one-day old mysids exposed to the mud aqueous fraction (MAF) of
the drilling mud which was replaced daily was 27 percent, correspond-
ing to 27,000 ppm mud added to water.  The most sensitive stage in
the life history of M. almyra to drilling mud exposure was at the
first juvenile molt, which normally occurs between 24 and 48 hours
after release.

     The weight-specific  respiration rate of mysids exposed to a sub-
lethal mud aqueous fraction  (MAF) for 24 hours was significantly
greater  than  that of controls.  After  seven days of exposure to sub-
lethal MAFs  the weight-specific respiration rates were not signifi-
cantly different.  A dose-dependent retardation in growth was
observed, however, for one-, three-, and six-day old mysids exposed
to  MAFs.  An  increased feeding activity was observed for first and
second day juveniles exposed to different MAF concentrations.  The
authors  believe  that the  results indicate that drilling mud exposure
                                 4-5

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reduced biotnass  produceion  and net growth efficiency of  mysids  at
sublethal concentrations  in the range of 15 to 30 percent MAF.   Other
metabolic processes  concerned with energy transfer such  as gamete
production could  be  affected by similar exposures.

     Gerber et.  al (1980) have used 96-hour static bioassays  to
determine the relative  toxicity of five used drilling fluids  col-
lected from offshore drilling rigs, and various components of these
fluids, to cold  water marine animals.  Organisms which survived these
tests were then  assayed  for levels of cellular enzyme activities,  or
changes in the rates of  respiration, excretion, and ingestion were
determined, as indications  of sublethal stress.  The drilling fluids
to be tested were used  in the following forms:  whole mud, aqueous
fraction, and suspended  whole mud.

     With few exceptions  the adult animals when exposed  for 96  hours
to the various fractions  of the drilling fluids exhibited little
mortality.  Whole muds  were slightly more toxic than the mud  aqueous
fractions to most organisms but especially to deposit feeding orga-
nisms, and larvae were  more sensitive than adults.  Most organisms
exposed to various concentrations of the mud fractions had cellular
enzyme activities different from the controls, and differences  in
enzyme activities rates  were apparent for the different  drilling
fluids or components.   It was concluded from the 96-hour bioassays
that these drilling  muds  were most toxic to larval marine organisms,
and though much  less toxic  to adults, sublethal stress was evident.

     The acute toxicity to  several species of marine animals  of four
used offshore drilling  muds was investigated by Neff et  al.,  (1980).
The four drilling muds  included a spud mud (density, 9.2 Ib/gal),  a
seawater chrome  lignosulfonate mud density, 13.4 Ib/gal).  Two  mud-
sea water preparations designated the mud aqueous fraction (MAF) and
suspended particulate phase (SPF) were used in bioassays.  The  SPP
was similar to the MAF  except that it contained a higher concentra-
tion of suspended particulates initially (900 vs 600 mg/1).   The
stock 100 percent MAF and SPP preparations represented the water-
soluble plus fine particulate fractions of 100,000 ppm (10 percent
v/v) mud in water.

     All four drilling  muds had a low acute toxicity to  all species
tested.  The used spud  mud  was completely non-toxic.  The three other
used drilling muds varied in their relative toxicity to  different
species and life  stages  of  marine animals.  In most cases, the  mid-
weight lignosulfonate drilling mud was more toxic than the seawater
chrome lignosulfonate drilling mud and the high weight lignosulfonate
drilling mud.
                                  4-6

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     The 96-hour median lethal concentration  (96  h LC 50)  of  the  MAP
of the three used chrome lignosulfonate  drillings muds varied from
12.8 percent MAF for the first day  postlarvae of  the  opossum  shrimp
Mysidopsis almyra to greater than 100  percent MAF for adult grass
shrimp Palaomonetes pugio and the polychaete  worm Ophryotrocha
labronica.  Ninety-six hour LC 50 values for  two  species of bivalve
molluscs exposed to the SPP ranged  from  20-74 percent SPP.  Compari-
sons of the acute toxicity of the two  mud preparations indicated  that
much of the toxicity of drilling mud resided  in the water-soluble
fraction.  Based on results of these bioassays and dispersion-dilu-
tion models of drilling muds discharged  from  offshore platforms,  it
was concluded that discharge of used drilling muds like those studied
would have little or no acute lethal effect on marine animals in  the
vicinity of the platform.

     Laboratory bioassays were conducted in a portable laboratory
located on a semisubmersible drilling  vessel  during the drilling  of
the Lower Cook Inlet, Alaska Continental Offshore Stratigraphic Test
(C.O.S.T.) well (Houghton et al., 1980).  The tolerances of seven
indigenous organisms with a wide range of ecological  requirements
were tested using static, acute, 48- and 96-hour  bioassays.   Test
solutions were prepared from drilling  fluids  taken directly from  the
mud pits and mixed with ambient sea water. Toxicity  of drilling
fluids was generally low with 96-hour  LC 50 values ranging from 3,000
ppm (0.3 percent by volume of drill fluids to sea water) for  pink
salmon to greater than 100,000 ppm  (10 percent) for shrimp.   LC 50
values were lower in tests in which the  solutions were continuously
mixed than in tests in which solutions were well  mixed initially  and
then allowed to settle during the remainder of the test.

     Acute toxicity experiments were conducted in the field on key
Arctic marine species using various types of  freshwater drilling
fluids obtained from drilling rigs  operating  in the vicinity  of
Prudhoe Bay, Alaska (Tornberg et al.,  1980).   The results  of  static
bioassays indicated that test organisms  varied widely in their
responses to exposure to drilling effluents.   Ninety-six hour LC  50
values ranged from 4 percent to greater  than  70 percent (drilling
fluid volume to seawater volume) for drilling fluids  tested.   Fish
were among the most sensitive organisms  tested and invertebrates
included both sensitive and relatively resistant  species.   The
resistant species were primarily sedentary, while more sensitive
species generally had the capability of  migrating into and away from
a drilling fluid disposal site.

     Variations in drilling fluid characteristics appeared to produce
variations in toxicities approaching  those among  different species.
Drilling fluids characterized as CMC/Gel/Resinex (used near  the bot-
tom of a well) were more toxic to selected marine organisms  than  were

                                  4-7

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XC-Polymer drilling  fluids  (used  at  mid-well depths), which, in  turn,
were more toxic  than  CMC/Gel  drilling  fluids (used in the upper
depths of the well).

A.3.3  Lon8~Term Toxicity Tests

     Results are available  on only a few  studies involving long-term
exposures of organisms  to drilling fluids.  Organisms on which tests
have been conducted  include grass shrimp, a mysid, the American
oyster, and a polychaete worm.

     A flow-through  system  was employed by Conklin et al. (1980) to
assess toxicity  of drilling mud during the molt cycle of the grass
shrimp (Palaemonetes) and the life cycle  of Mysidopsis bahia.  The
muds used were from  a well  in Mobile Bay, Alabama.  The oil company
has since claimed that  these  muds were atypical.  Mysids were more
sensitive than grass  shrimp to drilling mud exposure.  In life cycle
tests with mysids, the  LC 50  for  one of the muds was 50 ppm.  The LC
50 values obtained with tests involving molting grass shrimp and
mysids are several orders of  magnitudes lower than previously
reported LC 50 values for fishes.

     A long-term (100 days) multispecies  toxicity test was conducted
by Rubenstein et al.  (1980) to elucidate  biological effects of dril-
ling fluids on representative estuarlne organisms and developing
benthic communities.  Drilling muds, collected weekly from an active
drilling site, were  introduced into  10 gallon aquaria containing
clean silica sand (10 cm deep) and flowing seawater (380 1/min).
Three nominal concentrations  of drilling  fluids (10 ppm, 30 ppm and
1000 ppm) were continuously infused  into  test aquaria.

     Organisms selected for study were:   the mysid shrimp, Mysidopsis
bahia, a water column crustacean, the  oyster, Grassestrea virginica,
an epibenthic mollusk,  and  a  deposit-feeding polychaete, Arenicola
cristata (commonly called the lugworm).   Test criteria were developed
to identify effects  of  drilling fluids on:  (1) survival of mysids;
(2) shell deposition and bioaccumulation  of drilling fluid constitu-
ents by oysters; 3)  survival  of lugworms; and 4) recolonization of
test substracts  by macrofaunal organisms  that settled in aquaria from
planktonic larvae within the  100-day test period.

     Results indicate that  the drilling fluids tested were moderately
toxic to mysids  at 30 and 100 ppm.   Oyster growth was also signifi-
cantly inhibited at  these concentrations.  Lugworm survival in all
three concentrations  was significantly reduced.  Finally, exclusion
of colonizing polychaetes was observed in aquaria containing 100 ppm
drilling fluids. These tests, however, used a drilling mud from a
well in Mobile Bay,  Alabama,  that is claimed to be atypical in
composition for  discharge into marine  waters.

                                  4-3

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4.3.4  Bioaccumulation Studies

     Several studies are available on the potential for bioaccumula-
tion of drilling fluid components by marine organisms.  Organisms
studied include the grass shrimp and three species of molluscs.

     When exposed to media containing barite or used drilling mud,
the grass shrimp Palaemonetes pugio ingested the settled barite and
drilling mud particles (Conklin et al., 1980).  Ultrastructural
studies on the midgut of shrimp exposed for a 30-day period to 100
ppm or 500 ppm barite-containing media and living on the resulting
substrate showed that prolonged ingestion of barite causes marked
perturbations in the posterior midgut epithelium.

     Barium has been shown to accumulate in hard and soft tissues of
grass shrimp (Palaemonetes pugio) (Brannon and Rao, 1979).  The rela-
tive mineral composition of the cast shells of barite-exposed shrimp
was markedly different from that of the control shrimp.  Whether this
accumulation had any harmful effects was not determined.

     Houghton and Beyer (1980) have reported increases in total met-
als concentrations in amphipods when exposed to various drilling
fluid concentrations.  Sources of metal accumulation may include both
water soluble metals and metals found in particulates.

     The bioavailability of chromium, lead, and zinc from four used
drilling muds to the marsh clam Rangia cuneata and  the Pacific oyster
Crassostrea gigas was investigated by McCulloch et  al. (1980).  The
four used drilling muds included a spud mud, a seawater chrome ligno-
sulfonate mud, a mid-weight lignosulfonate mud and  a high weight lig-
nosulfonate mud.

     Clams  (R. cuneata) accumulated significant amounts of chromium
when exposed for four days to a substrate containing a layer of
chrome  lignosulfonate mud.  However, most of the chromium was
released within 24 hours when the clams were returned  to clean sea-
water,  indicating  that much of  the chromium accumulated was in the
form of unassimilated mud components in the digestive  tract or on the
gills.  When the clams were exposed to an aqueous  fraction (water
soluble fraction) of  the mud  for 16 days, they accumulated a mean of
19  parts  per million  chromium.  When returned  to clean seawater  they
released approximately half the chromium in 24 hours.  The clams
accumulated small  amounts of  chromium  and lead  from the mud aqueous
fraction of a mid-weight lignosulfonate mud.  Less  than half the
accumulated chromium  and lead was released  in  four  days when the
clams were  returned  to clean  seawater.
                                 4-9

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     When spat  of  Che  oyster (1.  gigas were exposed  to  several  concen-
trations of  the suspended  particulate phase of spud mud and mid-
weight lignosulfonate  mud  for four days,  they accumulated  significant
amounts of chromium  from  the mid-weight but not from the spud  mud.
When exposed  to the  mud aqueous  fraction of three drilling muds  for
up to two weeks, the oyster  spat showed little or no net accumulation
of chromium,  lead  or zinc.   The  authors concluded from these experi-
ments that heavy metals from typical  used drilling  muds had a  limited
bioavailability to marine  bivalve molluscs during short term expo-
sure.  Chromium was  more  bioavailable than lead or  zinc.

     The uptake of chromium  by Mytilus edulis from  several test  solu-
tions was studied  at pH 7.8  by Page et al. (1980).   The solutions
were (1) an  aqueous  extract  of a medium density lignosulfonate mud,
(2) a solution  of  ferrochrome lignosulfonate at two different  concen-
trations, (3) a solution  of  Cr3*.  All solutions were  of approxi-
mately equal  concentration  in total chromium except for one test
solution of  ferrochrome lignosulfonate at a 10 fold excess concentra-
tion compared with the others.  The mussels gained  the most chromium
from the Cr^"1" solution followed  by the ferrochrome  lignosulfonate
solutions and the  least from the used drilling mud  extract.  The
authors felt  that  these results  showed that the form of chromium
available had a major  effect on  its uptake by organisms and should be
taken into account in  assessing  potentially harmful effects of dis-
charges of used drilling  muds at sea.

4.3.5  Effects  on  Benthic  Communities

     Because  solids  from  the discharged drilling fluids settle to the
bottom in the vicinity of  the drilling platform, benthic communities
could be affected.  Initial  results from several EPA-funded studies
are available.

     Drilling fluids and  their components have been shown  to alter
the composition of estuarine benthic  communities at microbial, meio-
fauna and megafunal  levels.   White (manu-cript in preparation),  using
new methodologies  developed  by EPA funding, has shown  that some  com-
ponents of drilling  fluids  alter the  microbial community structure of
marine sediments at  concentrations in the parts per billiom range.
Biochemical  analysis of these sediments showed total benthic biomass
was not affected by  drilling fluid components.  However, two drilling
mud additives were shown  to  selectively inhibit portions of the  ben-
thic microbial  community.   Surflo (800 ppb) and Dowicide (100  ppb)
increased the biomass  of  bacterial containing the anaerobic pathway
of fatty acid synthesis.   Microeucaryotes were inhibited by Surflo.
Surflo and Dowicide  were  shown to decrease the ratio of benthic  algae
to total microeucaryotes  while Aldicide increased this ratio.
                                  4-10

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     Tagatz et al. (1980) has shown that drilling fluids and their
components affect the community structure of the meiofaunal popula-
tions colonizing estuarlne sediments in laboratory microcosms.
Aquaria contained sand and were continuously supplied with unfiltered
seawater.  Whole drilling mud, barite, a paraformaldehyde-type bio-
cide (Aldacide®), and three chlorophenol-type biocides (pentachlo-
rophenol, Dowicide® G-ST, and Surflo® B-33) were tested.  Tests with
whole drilling mud and barite were designed to determine their impact
as a cover (2 or 5 mm) over the substratum and when mixed with clean
sand (ratios of  1:10 sand and higher).  Annelids were most sen-
sitive to drilling mud and barite and significantly fewer numbers of
organisms occurred in all contaminated aquaria than in control
aquaria.  For all phyla, the average number of species per aquarium
was significantly less in treatments with a cover of mud or barite
than in  the controls.  Mollusks were particularly affected by the
chlorophenol-type biocides and significantly fewer occurred at
concentrations (active ingredient in water) of 7 ug pentachlorophe-
nol/1, 18 ug Dowicide G/l, and 10 ug Surflo B-33/l.  Numbers of indi-
viduals  and species of annelids per experimental aquarium containing
76 ug pentachlorophenol/1, 183 ug Dowicide G/l, and 205 ug Surflo
B-33/l were also significantly less than in control aquaria.  Numbers
of animals and species did not significantly decrease in the presence
of Aldacide at nominal concentrations (active ingredient) as high as
273 ug/1.

     Similar studies are being conducted near Georges Bank.  Gilbert
(manuscript in preparation) conducted in situ studies of the effects
of drilling fluids on meiofaunal succession of Waquoit Bay sediments.
Drilling fluids  either mixed  into or layered on sediment suppressed
the biomas of the recolonizing community and altered the meiofaunal
community structure.  Contaminated sediments reduced the total number
of individuals by 52 to 38 percent (when corrected for mobile spe-
cies).   Capitella capitata, an indicator of marine pollution, was
more numerous in  the drilling mud treatments than in controls.

4.3.6  Effects on Corals

     EPA has funded a number of studies on the effects of drilling
muds on  corals as part of  the research effort related to the Flower
Garden Banks.  Some initial results of these studies are available.

     Seven species of coral, Dichocoenia stokesli, Nontastrea
annularis, Agarcia agaricites, Acropora cervicomis, Porites furcata,
P. astreoids, and £.  divaricata, were experimentally exposed to each
of these concentrations  (100, 316, 1000 ppm) of drilling mud
(obtained  from an off shore oil well  in the Gulf of Mexico), and
control  sea water for 96 hours to observe behavioral response
(Thompson and Bright, 1980).  Experiments were conducted at Carysfort
Reef,  Florida
                                 4-11

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Keys, using closed  aquaria  located in three meters of water.  Polyp
behavior was determined  with  serial closeup photography, which
allowed counting  of  retracted,  partially  retracted, and non-retracted
polyps in each colony.   Response  to drilling mud concentrations was
measured as percent of  polyps retracted.   Montastrea annularis,
Agaricia agaricites.  and Acropora cervicornis were killed by exposure
to 1,000 ppm mud.  ^.  cervicornis colonies survived this concentra-
tion in a replicate  experiment.   All corals except Dichocoenia
stokesii and Porites divaricata showed significant polyp retraction
during exposure to  100 ppm  mud  concentration, which 316  ppm mud was
the minimum concentration which induced significant polyp retraction
in Porites  divaricata.  Polyps of  Dichocoenia  stokesii did not
detectably react  to any of  the  three concentrations.

     Possible effects of drilling mud on  the growth of Montastraea
annularis were evaluated in the following separate studies  (Hudson
and Robbin, 1980):   (1)  short-term recovery and subsequent  growth of
this species exposed to  drilling mud on a Florida reef , and (2) long-
term growth record  of  these corals from East Flower Garden  Bank, Gulf
of Mexico, an area  of  possible  exposure to drilling mud from nearby
exploratory drilling operations that took place during 1974 and 1977.

     In the short-term experiment, eight  M. annularis head  corals
were heavily dosed  with drilling mud and  left with 10 untreated con-
trol corals on  the  reef  for six months to recover and grow.  All
corals were then  collected  and  analyzed using X-radiography to deter-
mine post-treatment growth  rates.  Barium and chromium levels incor-
porated in the coral skeleton before and  after  the experiment were
determined by emission spectroscopy.  Barium levels ranged  from 11
ppm (background)  In pretreatment skeletal areas to as high  as 1,200
ppm in skeletal areas deposited during and after  treatment.  Chromium
concentrations were at or below background levels in all samples.  In
the second study, cores taken by divers from large rl. annularis heads
at East Flower Garden Bank  were analyzed  in the same manner as those
in the first experiment. Annual growth rates averaged 8.9  mm over a
50 year period  (1907-1957).  In 1957 average yearly growth  declined
sharply and has remained 1.7 mm below previous  long-term growth aver-
ages.  Concentrations of barium and chromium were at or below back-
ground levels in  skeletal material from both predrilllng growth
periods and growth  periods  during drilling operations.

     Madracis decactis corals were exposed for  17 days in laboratory
aquaria to suspensions of  100 ppm drilling mud  obtained April 1979
from a working drill rig in Mobile Bay, Alabama,  and spiked in the
laboratory with 0,  3, and  10 ppm ferrochrome lignosulfonate (FCLS)
(Krone and Biggs, 1980). These muds were atypical in composition for
discharge  into marine waters.  During the first week of exposure  to
drill mud  + FCLS, corals increased their  oxygen consumption and


                                  4-12

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ammonium excretion, relative to uncontaminated controls.  Those
corals exposed Co the highest enrichments of FCLS demonstrated the
greatest increases in respiration and excretion and also the largest
variation in respiration and excretion between Individual corals.
Corals reached their highest average rates of respiration and
excretion by the end of the first week and, after a secondary
increase in excretion and respiration between days 10-13 which was
most pronounced in those corals exposed to FCLS enrichment, leveled
off at near-initial rates by the end of the second week.  Analysis of
variance demonstrated that oxygen consumption of FCLS-stressed corals
was not statistically different from uncontaminated control corals.
By contrast, ammonium excretion was significantly greater in
FCLS-stressed corals than in uncontaminated control animals.

     All corals exposed to FCLS reacted by reducing their degree of
polyp expansion.  Two of these, one exposed to 100 ppm drill mud +
3 ppm FCLS and the other to 100 ppm drill mud 10 ppm FCLS, became
bacterially infected and showed local areas of polyp mortality as the
experiment entered its second week.  These were the two corals that
had shown the most rapid and most consistent increases in excretion
and respiration during the first week of exposure to FCLS.

     When exposure to drill mud + FCLS was discontinued, respiration
and excretion of surviving corals remained low and stable while their
polyp activity returned to normal levels within 48 hours Thompson
(1980).

4.4  SUMMARY

     Petrazzuolo (1981) has reviewed those studies summarized in sec-
tions 4.2 and 4.3 as well as other studies. An environmental hazard
assessment was carried out based on the literature review in support
of the issuance of a general discharge permit for oil and gas dril-
ling rigs in the Gulf of Mexico.  The area covered by the general
permit excludes areas adjacent to the Flower Garden Banks.

     The estimates of the effect of drilling fluids and cuttings
determined by Petrazzuolo (1981) are based on the combined results of
two types of analysis.  In the first type of analysis, acute lethal
toxicity data were extrapolated to estimate the potential chronic
effects after applying a safety factor of 0.01.  These data were the
results of 303 acute lethal toxicity tests conducted on 35 to 40
drilling fluids using 48 species of test animals.  A second analysis
utilized data on the effects of chronic (10 week) drilling fluid
exposure on benthlc recruitment and development in a flowthrough
system.  These data were used in conjunction with data from short-
term, water column dispersion studies of the discharge plumes for
                                 4-13

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whole drilling fluids  and  Che  soluble and fine particulate fraction
of Che drilling fluids  Co  escimace the potential hazard of Che
discharge in che environment.

     Analysis by Petrazzuolo (1981) of the results of the acute
toxicity data for the  species  and drilling fluids chat have been
tested to date yielded the following results:

             Percentage of
         LC5Q Values Exceeding            Drilling Fluid
        Che Given Concentration          Concentration (ppm)

                    50                        100,000
                    83                          10,000
                 97-99                          1,000
                   all                             100

These results are derived  from the relative frequencies of LC$Q
values occurring within specified ranges of drilling fluid concen-
trations.  The use of  percentage frequencies instead of absolute
frequencies of occurrence  eliminates any bias in the resulting
distribution that would tend to favor che sensitivities of species
that have been tested  most often.

     The 96-hour ££50  value for the most sensicive species tested
was 100 ppm.  Utilizing dispersion data, a concentration of 100 ppm
would be achieved within 100a>  of Che discharge for whole muds and
1000m for che longer lasting soluble plume.  For most species acute
lethal effects would not be expected more Chan 15m from che
discharge.

     Estimates of the  distance beyond which no chronic effects would
result to water column organisms ranged from 40m to 1000m depending
on the sensitivity of  the  species tested.  Most species would' be
unaffected within 100m.

     Estimates of effects  on abundance of benthic organisms were as
f ollows:

                                     Percent ReducCion
           Distance (m)         (excludes burial effects)

                1-100                       50
               65-195                       17
              185-1100                    2-10
             1000-1400              No substantial effect
                                 4-14

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               5.0  FUTURE DIRECTION OF THE EPA  PROGRAM

     Ac the present point in the EPA Drilling Fluids  Hazard Assess-
ment Program, initial results are becoming available.  Additionally,
several extensive literature reviews are in preparation by EPA  and
other agencies.  While the results to date must  be verified and
placed in perspective by the work yet to be completed, enough is
known from EPA, industry, and other agency research to establish  the
needs of the final year of the EPA program.

5.1  FACTORS AFFECTING THE FINAL YEAR OF THE EPA PROGRAM

     Results of work involving transport and fate of  discharged muds
(exposure assessment) suggest that the majority  of the mud may  be
deposited near the point of discharge.  The visible plume that
remains in the water column may constitute a relatively small amount
of the total volume discharged.  These findings,  however, must  be
verified using better techniques that can overcome the hinderances
and sampling problems associated with the pioneer studies.

     Considerable laboratory work on the effects of drilling muds on
marine organisms has been carried out by EPA, the oil industry, and
other Federal agencies since the initiation of the EPA Drilling
Fluids Hazard Assessment Program in 1975.  The composition of drill-
ing muds is becoming better understood.  The range of toxicity  of
drilling muds is becoming established for the types of muds tested  to
date.  Some bioaccumulation of barium and metals has  been observed.
With this expanding data base, it is now time to synthesize and
review the data in order to develop an assessment of  the drilling mud
problem and the outline of a protocol for dealing with individual
site-specific situations Involving the discharge of drilling muds.
Still needed as an Input to this assessment is toxicity screening of
a variety of muds representative of those used on the Outer Conti-
nental Shelf.

     As part of the recent court settlement concerning oil and  gas
leasing on the Georges Bank, the Department of the Interior has been
directed to respond to the research needs for this area.  These needs
are to be identified by the Biological Task Force, the existing
interagency advisory body for environmental issues related to Georges
Bank.  EPA is a member of this committee.  To avoid duplication of
effort and in response to funding cutbacks within EPA, drilling fluid
hazard assessments for th Georges Bank will now  be one of the con-
cerns to be dealt with by the Biological Task Force.  For the Gulf  of
Mexico, an interagency five-year research plan is also being prepared
to coordinate drilling-related studies.  EPA can help determine
research to be carried out through its membership on  this committee.
Also, monitoring programs required of industry to determine

                                 5-1

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compliance with discharge  permit conditions will provide some addi-
tional data on muds in the marine environment.

5.2  STRATEGY FOR THE FINAL YEAR OF THE PROGRAM

     The proposed strategy for the final year (fiscal year 1982) of
the Drilling Fluids Hazard Assessment Program is given in Figure 5-1.
The concentration will be on in-situ discharge plume studies and on
laboratory screening of a  variety of muds  representative of drilling
fluids that are being used or will be used on the Outer Continental
Shelf.  The results of these final studies, all other studies com-
pleted as part of the EPA  program, and work carried out by other
groups will lead to an adaptive environmental assessment model and a
state-of-the-art document  that will Include guidance for assessing
the effect of drilling fluid discharges in the marine environment.

     The in-situ plume studies will include both exposure and effects
assessments.  The exposure work will be a  continuation of the dis-
charge plume transport studies by NOAA.  Emphasis will be on predict-
ing concentrations of drilling fluids that could occur under various
discharge conditions from  platforms.  The  effects assessment will be
field studies focusing on  the effects of drilling fluids on corals
and benthic organisms.

     The screening of muds typical of those used on the Outer
Continental Shelf will use about 50 muds to be furnished by the
Petroleum Equipment Supplies Association.  These mud samples will be
split with the oil industry.  EPA and industry groups will then carry
out the same kinds of chemical analyses and laboratory biological
toxicity tests so that scientific results  can be compared.

     Synthesis activities  will be undertaken in order to pull
together the results of the overall EPA drilling fluids research
program and the extensive  data base developed by the oil industry and
other Federal agencies since 1975.  This activity will be accom-
plished by preparing an assessment document that summarizes and syn-
thesizes what is known about the effects of drilling muds in marine
environments.  An Adaptive Environmental Assessment Workshop will
contribute to this effort.  Also included  in the assessment document
will be a protocol for applying the knowledge gained to the assess-
ment and monitoring of individual site-specific situations involving
the discharge of drilling  muds.
                                  5-2

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             IN-S1TU PUIME STUDIES
     EXPOSURE
     ASSESSMENT

     •  Plume
        dispersion
Ln
u>
EFFECTS
ASSESSMENT

•  Corals

•  Bentliic cages
                                    LABORATORY STUDIES USING

                                   ABOUT 50 MUDS FURNISHED BY
                           PETROLEUM EQUIPMENT SUPPLIERS ASSOCIATION
        AMERICAN
        PETROLEUM
        INSTITUTE
Chemical
Analysis
Biological
Tests
                  EPA
                  GULF BREEZE
                  LABORATORY
Chemical
Analysis
                                        INTEGRATION AND SYNTHESIS

                                   ADAPTIVE ENVIRONMENTAL ASSESSMENT MODEL

                                   STATE-OF-THE-ART AND PROTOCOL
                                   FOR DETERMINING EFFECTS
 Biological
 Tests

•  Mysids

•  Palaemonetes

•  Coral

« Nercenaria
                                                FIGURE  5-1
                        RESEARCH STRATEGY FOR THE  FINAL YEAR OF THE DRILLING FLUIDS
                                        HAZARD ASSESSMENT PROGRAM

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                  APPENDIX A




             PROJECT DESCRIPTIONS




EPA DRILLING FLUIDS HAZARD ASSESSMENT PROGRAM
                     A-l

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  APPENDIX A-l




GENERIC STUDIES
     A-2

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Project Tide:  Drilling Fluid Reference Standards for Chemical
Analysis

Performing Organization:  U.S. National Bureau of Standards
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To develop and provide drilling fluid reference
standards for use in characterization efforts and in a quality
assurance program to improve and maintain reliability of mea-
surements made on discharges from drilling and production
operations.

Approach:  (1) Obtain candidate reference material(s) from
EPA-Gulf Breeze and assess the feasibility for preparing a dry
mixture of four major drilling fluid components; (2) If step (1)
proves feasibile, prepare a batch (i.e., grind, blend, sieve) of
material and establish homogeneity; (3) Characterize the dril-
ling fluid mixture for several trace elements to be determined
by NBS and EPA-Gulf Breeze; (4) Package, label, and provide
EPA-Gulf Breeze with drilling fluid reference standard for
specified trace elements.

Output:  Report on Reference Standards of Drilling Fluids
Delivery:  2-81
                             A-3

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Project Title;  Chemical Analysis of Drilling Fluids

Performing Organization: JRB Associates
Responsible Laboratory:  Gulf Breeze Environmental Research
Laboratory

Objective:  To provide support  to the Environmental Research
Laboratory at Gulf Breeze for organic analytical chemical
analyses.

Approach:  Analytical chemical  services include the chemical
characterization of drilling fluids used in exposure of test
organisms, the accumulation of  drilling fluid components in
tissues of exposed organisms, and the uptake of particulate
drilling fluid components in organisms.

Output:  Analysis will be reported as part of the biological
experiments for which support was provided.  There will also be
a final report on chemical analyses of drilling fluids.
Delivery:  6-81
                            A-4

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Project Title;  Chemical Analysis for Energy Program

Laboratory:  Gulf Breeze Environmental Research Laboratory

Objective:  The purpose of this task is to provide organic
analytical chemical support to aquatic toxicity tests at the
Gulf Breeze Environmental Research Laboratory.

Approach:  Analytical chemical services include development of
methods for analysis, measurement of concentrations in flowing
seawater, and determination of accumulation of concentrations
in tissues of organisms utilized in experiments.

Output:  Results of the chemical analyses will be reported as
part of the study for which they were performed.

Delivery:  9-82
                            A-5

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Project Title:  Mixing Zone Definition for Nonbuoyant Discharges
in Support of Section 403(c) of  the Clean Air Act

Laboratory:  Corvallis Environmental  Research Laboratory

Objective:  The objective of this  research is. to develop/revise
mixing-zone calculation methods  for industrial discharges.
Emphasis will be  given to those  discharges containing fluids,
emulsions, and suspensions heavier than marine water, or  those
which in general  behave differently than the municipal wastes
for which mathematical models  and  limited verification data are
available.

Approach:  Laboratory and field  verification will be conducted
to substantiate the  level of confidence in predicting water
quality characteristics for pollutants regulated by numerical
criteria. Completion of this research will most likely result in
a revision of the mixing zone  definition requirements under
403(c).

Output:  Report on mixing zone calculation (model) for those
discharges containing fluids,  emulsions, and suspensions  heavier
than marine water for which mathematical models of limited
utility exist.
Delivery:  12-80

Output:  Report on verification  of model
Delivery:  9-81

Output:  Report on application of  the model to several
situations.
Delivery:  6-82
                             A-6

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Project Title;  Toxic. Sublethal and Latent Effects of Selected
Petroleum Hydrocarbons and Barium Sulfate on Marine Organisms

Performing Organization:  University of West Florida
Responsible Laboratory: Gulf Breeze Environmental Research
                        Laboratory

Objective:  To determine if drilling fluid components have
adverse affects on marine organisms with emphasis on
crustaceans.

Approach:  Laboratory tests are used to see if toxic effects and
bioaccumulation occurs.

Output:  Final report, journal articles and book
Delivery:  9-80
                             A-7

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Project Title:  Behavioral Assays for the Effects of Drilling
Muds on Marine Animals

Performing Organization:  University of West Florida
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To develop and test a device for measuring the
behavioral response of the scallop to drilling fluids.

Approach:  A device capable of recording bivalve opening,
pumping, and escape attempts was developed.

Output:  Final report
Delivery:  9-80
                            A-8

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Project Title;  Laboratory and Field Studies of Used Drilling
Fluids and Fluid Formulation Components on Benthic Communities

Laboratory:  Gulf Breeze Environmental Research Laboratory

Objective:  Develop and apply methods for determining the effect
of diesel oil on a marine off-shore benthic community microcosm.

Approach:  Utilize methods developed at the Gulf Breeze Labora-
tory and methods developed at the off-shore platform (Stage I)
to determine impact of diesel oil on a developing benthic commu-
nity microcosm.  The variation, if any, between controls and
experlmentals with respect to numbers and kinds of individuals
as well as phyla will be observed.

Output:  Final report and scientific paper
Delivery:  9-80
                            A-9

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    Project Title;  Offshore Pollutant Effects Program*

    Laboratory:  Gulf Breeze Environmental Research Laboratory

    Objective:  To determine the environmental effects of  offshore
    oil extraction.  In order to simulate the conditions of  the
    marine environment, the Stage I offshore platform owned and
    maintained by the Naval Coastal Systems Laboratory, Panama
    City, Florida, will be used.

    Approach:  the Stage I facility and support for its operation
    will be provided by the Navy.

    Output:  Conclude use of facility
    Delivery:  10-81
This project has been  suspended because of storm damage until
restoration funds become available.

                                A-10

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Project Title;  The Effect of Drilling Mud on Marine Organisms

Performing Organization:  Florida State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To provide support for the operation of Stage I, and
offshore research laboratory near Panama City, Florida.

Approach:  Specific tasks include the developments of a flowing
seawater aquatic toxicology testing laboratorys, collect organ-
isms for testing, collaborate with EPA and extramural research-
ers in the performance of toxicity tests, and logistic support.

Output:  Final project report
Delivery:  7-80
                           A-ll

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Project Title;  Effects of Drilling Mud Constituents on Che
Sedimentary Microflora and the Base of the Marine Benthlc Food
Web

Performing Organization:  Florida State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Develop and apply methods to assess environmental
effect of offshore oil and gas exploration on marine organisms.

Approach:  Determine effects that result from exposure of
marine organisms.

Output:  Journal article on impact on microflora.
Delivery:  10-80

Output:  Final project report on methodology and effects
Delivery:  10-80
                           A-12

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Project Title;  Effects of Soluble Fractions of Drilling Fluids
on Larval Development and Behavior of Callinectes sapidus and
Rhithropanopeus harrlssil

Performing Organization:  Duke University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The research includes measurements of drilling fluid
effects on (a) long-term development of crab larvae,  (b) short-
term development of specific larval life stages, (c)  swimming
speed of larvae, and (d) positive or negative phototaxis of the
larvae >

Approach:  Laboratory studies will be carried out.

Output:  Final report
Delivery:  11-81
                            A-13

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Project Title;  Effects of Drilling Fluids on Embryo Development

Performing Organization:  Trinity College
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To test for teratogenic effects of drilling fluids

Approach:  The effects of drilling fluids on the developmental
stages of the embryos of fish and echinoderms will be
determined.

Output:  Final report
Delivery:  5-82
                            A-14

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Project Title;  Effects of Barium Sulfate on Fertilization of
Early Development

Performing Organization:  Florida State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The effects of barium sulfate, a principal component
of drilling fluids, on sea urchin gametes and embryos will be
assessed.  The project will characterize the cellular events
which are disturbed by-barium sulfate and will determine the ef-
fective concentrations necessary to induce these perturbations.

Approach:  Sea urchin eggs and sperm will be exposed to solu-
tions containing barium.  Barium is a periodic analog of
calcium, which is important as a mediator of such cellular func-
tions as fertilization, cell division and later development.
The project will characterize the cellular events which are
disturbed by  barium sulfate, a major component of fluids used  in
oil and gas well-drilling.

Output:  Final report
Delivery:  3-82
                            A-15

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Project Title:  Completion of Hazard Assessment Program

Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To synthesize existing literature and conduct a
limited amount of research on the effects of the fluids on
selected marine organisms.

Approach:  Principal efforts will be directed toward completion
of the five-year Drilling Fluids Hazard Assessment Program.  A
state-of-the-art document will be prepared on the impact of
drilling fluids on marine organisms, which will include a hazard
assessment and protocol for measuring potential impact of dril-
ling fluids.  Bioassay screening of the impact of "down-hole"
and other drilling fluids on selected marine organisms will also
be carried out.

Output:  State-of-the-art document
Delivery:  9-82

Output:  Final report of the impact of drilling fluid samples
Delivery:  9-82
                           A-16

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Project Title:  Literature Review of Environmental Effects of
Well-Drilling Chemicals

Performing Organization:  Battelle-Columbus Laboratory
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Prepare a review of available literature, published
and unpublished, on the origins, fate and effects of chemicals
discharged from oil and gas drilling operation into the marine
environment.

Output:  Final report - annotated bibliography
Delivery:  10-81
                           A-17

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Project Title:   Symposium on the Effects of Chemicals Used in
Offshore Oil and Gas Drilling Operation on Marine Organisms

Laboratory:  Gulf  Breeze Environmental Research Laboratory

Objective:  Disseminate state-of-the-art information on the
effects of oil and gas drilling activities on organisms and
ecosystems to industry, government,  the academic community and
the general public.

Approach:  Establish program committee for symposium.  Advertise
meeting, select  papers and  session chairman, hold meeting, pub-
lish proceedings.  In parallel with  the above activities, pre-
pare annotated bibliography.

Output:  Symposium completed
Delivery:  2-80

Output:  Report  and  technical assistance to EPA and Region I and
VI
Delivery:  12-80

Output:  Annotated bibliography
Delivery:  12-81

Output:  Final project report
Delivery:  12-82
                            A-18

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    APPENDIX A-2




FLOWER GARDEN BANKS




   GULF OF MEXICO
       A-19

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Project Title:  Assessment of Exposure of the Ecosystem of the
Texas Flower Gardens to Pollutants Originating from Oil and Gas
Drilling Rigs

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To strengthen the scientific foundation of the esti-
mates or prediction of the dosage of drilling fluids discharged
into the water near the Flower Garden Banks.

Approach:  Acoustical, particulate and physical oceanographic
measurements of the dosage of shunted drilling fluids from a
well near the Flower Garden Banks will be made.  A predictive
model for drilling mud dispersion processes will be developed
from these data.

Output:  Final report
Delivery:  9-82
                             A-20

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Project Title;  Offshore Laboratory Studies of the Impacts of
Used Drilling Fluids on Behavior of Corals Representative of
the Flower Garden Banks

Laboratory:  Gulf Breeze Environmental Research Laboratory

Objective:  Develop and apply methods to determine lethal and
sub-lethal effectes of drilling fluids and this components on
corals.

Approach:  Expose corals to drilling fluids and through time-
lapse movies, observe the rates of sediment removal or polps
contration.  A mud-profile (muds from various depths of a
working well) will be used in the experiments.  The project also
provides  fiscal support for using Stage I.

Output:   Final report
Delivery:  9-82
                           A-21

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Project Title:  Effects of Drilling Fluids and Oil on Corals
Occupying Hard-Bank Communities

Performing Organization:  Texas A&M University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Determine if drilling fluids have adverse effects on
adult reef building corals.

Approach:  Various corals were tested to determine the toxicity
of a variety of drilling fluids to corals under laboratory and
field conditions.

Output:  Final report
Delivery:  4-79
                           A-22

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Project Title:  Biochemical Analyses on Coral and Other
Invertebrate Metabolic Activity and Nutritional Status with
Exposure to Oil and Gas Drilling Mud

Performing Organization:  Florida State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Develop and test biochemical measures of the
effects of drilling muds on:  (1) The coral-zooxanthellae
interaction using  lipid analysis; (2) The nutritional status
with the triglyceride, wax ester, phospholipid ration; (3) The
metabolic status of corals using  the lipid analysis and GC/MS.

Approach:  Expose  corals and perform chemical analyses

Output:  Final  report  on impact of drilling  muds on biochemical
aspects of corals
Delivery:  9-82
                            A-23

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Project Title:  Effects of Drilling Mud on Corals:  Some Bio-
chemical and Neurochemical Aspects

Performing Organization:  Louisiana State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To study  the effect of drilling mud treatment on
some biochemical and  neurochemical aspects of coral physiology.
Specifically, these studies will  include the evaluation of
protein, nucleic acid, energy and catacholamine metabolism.

Approach:  Radioactive amino acids will be added  to corals and
the incorporation of  the amino acid into protein will be
measured by scintillation counting.  Thin layer chromatography
and radioenzyme assay will be used to measure various enzyme
activities and the effects of drilling mud on them.

Output:  Final project report on  biochemical and  neurochemical
effect of drilling fluids on corals.
Delivery:  8-81
                             A-24

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Project Title:  Effects of Offshore Oil and Gas Drilling on
Reef Building Corals

Performing Organization:  Texas A and M University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Determine the effects of chemicals used in offshore
oil and gas drilling activities on reef-building corals.

Approach:  Expose corals to drilling fluids at the EPA-leased
Navy platform at Panama City, Florida, and measure effects by
time-lapse photography.

Output:  Final Report
Delivery:  6-82
                            A-25

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Project Title:   Effects of Oil  Drilling Muds on the Physiology
and Nutritional  Status of Texas  Flower Garden Reef Coral

Performing Organization:  Florida  State University
Responsible Laboratory:  Gulf Breeze  Environmental Research
                         Laboratory

Objective:  1) Determine the effects  of various concentrations
of whole drilling mud on respiration, nitrogen excretion and
calcification  in a  reef coral.   2)  Determine the effects of
various concentration of whole  drilling mud on the nutritional
states of reef corals.  3)  Send exposed corals to other
investigators  for complementary biochemical and
histopathological investigations.

Approach:

Output:  Final project report
Delivery:  5-81
                           A-26

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Project Title;  Physical and Chemical Effects of Drill Mud on
Coral Skeletons

Performing Organization:  Nova University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To measure the physical and chemical record in coral
skeletons using density of minerals deposited in the skeleton
during periods of growth.

Approach:  X-radiography will be used to determine the density
gradients in the coral skeletons.  Also, in-situ cores of coral
heads will be taken and x-radiography will be used to examine
those corals.

Output:  Final report
Delivery:  6-82
                           A-27

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Project Title;  Comparison of Reef Fish Populations at the
Flower Garden Banks and at Oil and Gas Drilling Platforms

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To evaluate the  impact of offshore drilling
activities on fish within a  unique coral reef ecosystem in the
northwestern Gulf of Mexico.

Approach:  Offshore drilling structures provide an artificial
habitat for fish and bring them into contact with point source
pollutants. Such contaminants may be taken up by reef fishes or
may cause mortality or histopathological effects, suppress food
organism populations, or affect growth, reproductive processes,
recruitment, behavior, movements and migrations.  The goal of
this project is to assess the biological characteristics of
natural reef fish populations and compare them with those of
reef fish populations associated with oil and gas fields in the
northwestern Gulf of Mexico.

Output:  Report covering the movements, migration, recruitment,
and standing stocks of reef  fishes by catch-effort and mark-
recapture methods.
Delivery:  12-82

Output:  Report describing the standing stocks, distribution,
and community structure of benthic macro-infauna in relation to
drilling operations.
Delivery:  12-82

Output:  Report presenting the histopathology of reef fishes in
relation to drilling operations.
Delivery:  12-82

Output:  Report that describes the microbial communities of
reef fishes, drilling plumes, nepheloid layers and surficial
sediments
Delivery:  12-82

Output:  Report that describes the movements, migration,
recruitment, and standing stocks of  reef fishes by remote
sensing assessments
Delivery:  12-82
                            A-28

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Project Title:  Toxic and Sublethal Effects of Waste Drilling
Muds and Certain Chromium Compounds in Crustaceans

Performing Organization:  University of West Florida
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The project will investigate the effects of
drilling muds and their components on crustaceans.

Approach:  Laboratory experiments will be used to predict
effects.

Output:  Report on whole drilling mud effects
Delivery:  3-81

Output:  Report on effects of drilling mud components
Delivery:  3-82

Output:  Final project  report
Delivery:  3-83
                            A-29

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Project Title:  Developments of Components of a Monitoring
System - (I) Tethered Cage

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To develop a tethered cage that can maintain its
position in the thermocline.

Approach:  The cage would be capable of maintaining its
position in that  thermocline and would be fitted with special
devices for remotely monitoring the health status of the caged
animals.

Output:  Preliminary engineering design package
Delivery:  9-80

Output:  Deicsion on final  design
Delivery:   10-80

Output:  Complete laboratory system
Delivery:  5-81

Output:  Complete field  testing
Delivery:  8-81

Output:  Final report
Delivery:  9-81
                            A-30

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Project Title:  Development of Components of a Monitoring
System - (II) Evaluation of Devices and Materials for Seawater
Chemical Sample Collection-Preconcentration, and Analysis

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The program had three objectives:  Determination of
performance and contamination characteristics of existing
monitoring systems, specifically those that will be used in
Texas Flower Gardens research; evaluation of preconcentration
materials; and, development of laboratory analytical
techniques.

Approach:  Equipment will be evaluated and  techniques
developed.
Output:  Complete  evaluation of the performance and
contamination characteristics of the trace metal sampler.
Delivery:  1-81

Output:  Complete  the  characterization of the performance and
measurement uncertainties of the in situ monitoring system.
Delivery:  8-81

Output:  Complete  the  determination of the
performance/contamination characteristics of a pump sampling
for  trace metal analysis.
Delivery:  1-82

Output:  Complete  the  determination of the
performance/contamination  characteristics of pump  sampling
system  for organic analysis.
Delivery:   1-83
                            A-31

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Project Title:   Development of  Components of a Monitoring
System - (III) Automated  Sampler  for Trace Organics in Marine
Waters

Performing Organization:   National  Oceanic and Atmospheric
                           Administration
Responsible Laboratory:   Gulf Breeze Environmental Research
                          Laboratory

Objective:  To develop a  self-contained automated sampler for
in-situ collection  of  trace organic chemicals in marine waters.

Approach:  The sampler should be  able  to collect particulate
and dissolved samples  and preserve  both in uncontaminated
condition until  removal  for subsequent analysis, presumably by
GC/MS.  The sampler should be programmable in terms of sampling
intervals and frequencies and the collected samples should be
ready for analysis  without significant additional handling or
processing.

Output:  Final report  on  shipboard  prototype
Delivery:  1-82

Output:  Final report  on  deployable system
Delivery:  10-83
                            A-32

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Project Title:  New Methodologies for Measuring Energy-Related
Consent Decree Toxic Compounds in the Marine Environment

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  This project has three subobjectives:  (1) vali-
dated methods for separating trace organic marine pollutants
into major chemical classes and removal of natural marine
organics that interfere with pollutant analysis; (2) validated
techniques for final detection, identification and measurement
of individual trace organic marine pollutants; and (3) identif-
ication of potentially hazardous organic pollutants  from marine
water samples from  the Texas Flower Gardens as well  as from
areas near various  ocean outfalls.

Approach:  Validate methods and techniques and identify
potentially hazardous organic pollutants.

Output:  Report on  filter and sorbent components for sampling
trace organic pollutants in marine waters.
Delivery: 9-81

Output:  Report or  peer-reviewed journal article on  separation
schemes  for major classes and subclasses of trace polar and
nonpolar organic marine  pollutants.
Delivery:  9-81

Output:  Report or  peer-reviewed journal article on  multiple
analytical methods  for  determining ppb-ppt  levels of individual
polar organic marine  pollutants.
Delivery:  9-81

Output:  Report or  peer-reviewed journal article on  inventory
of organic marine  pollutants,  including  those  not known,  that
could have a  potentially adverse effect  on  Flower Garden
Banks.
Delivery:  9-82
                             A-33

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Project Title;  Adaptive Environmental Assessment Workshop on
Drilling Mud Disposal

Performing Organization:  U.S. Department of the Interior
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The Adaptive Environmental Assessment Group of the
Department of the Interior will provide staff support to EPA in
conducting a workshop on an integrated approach to regulations
of drilling and disposal.

Approach:  The approach to provide this assistance will consist
of (1) a scoping meeting with key EPA personnel for identifica-
tion of the specific problem  to be addressed by hypothetical
model, and (2) providing the  staff assistance and guidance in
conducting an EPA sponsored AEA modeling workshop.

Output:  Workshop report.
Delivery:  9-82
                            A-34

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Project Title;   Identification of Macroinfauna from Experiments
Conducted at the U.S. Navy Platform "Stage I"

Performing Organizaton:  VITRO
Responsible Laboratory:   Gulf Breeze Environmental Research
                         Laboratory

Objective:  Identify benthic organisms in support of "Stage I"
research on the effects of drilling fluids on marine organisms.

Approach:  Identification will be performed using
state-of-the-art taxonomlc procedures.

Output:  Final project report
Delivery:  12-81
                            A-35

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Project Title:  Technical Assistance  to EPA Region VI

Laboratory:  Gulf  Breeze Environmental Research Laboratory

Objective:  The EPA Gulf Breeze Environmental Research
Laboratory will provide technical assistance to EPA Region VI
on NPDES permitting of discharges from offshore oil and gas
drilling activities.

Approach:  Perform hazard assessment  based on exposure
assessment and effects assessment.  This project will provide a
continuing source  of  technical assistance to EPA Program
Offices and Regional  Offices.

Output:  Permit review as needed
Delivery:  12-83 - Terminate ongoing  technical assistance
                            A-36

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 APPENDIX A-3




 GEORGES BANK




GULF OF MAINE
    A-37

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Project Title;  The Erodibility of Drilling Muds Deposited on
the Seafloor

Performing Organization:  Yale University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To explore the erodibility of drilling muds in
different ecological conditions.

Approach:  Laboratory flume studies and field observation will
be used to determine drilling mud stability.

Output:  Final report on erodibility of drilling muds of the
seafloor
Delivery:  3-82
                            A-38

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Project Title:  Effects of Drilling Mud on Adult American
Lobster

Performing Organization:  Boston University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To determine the effects of drilling muds on the
American Lobster

Approach:  The effects  of drilling muds on  feeding, molting,
mating, predator  escape, shelter behavior,  and  substrate
selection of  lobsters will be determined by controlled
laboratory experiments  and seminatural environment and  field
observations.

Output:   Final effects  assessment  report
Delivery:  3-82
                            A-39

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Project Title;  Drilling Fluid Effects to Developmental Stages
of the American Lobster

Performing Organization:  Woods Hole Oceanographic Institute
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Predict the impact of drilling operations for oil
exploration on populations of the American Lobster (Homarus
americanus).

Approach:  The effects of used, whole drilling fluids on larval
and postlarval stages of the lobster will be assessed.

Output:  Final report
Delivery:  9-81
                            A-40

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Project Title;  Feeding. Reproduction and Habitat Selection of
Lobster Homarus americanus - Effects of Drilling Mud in Labora-
tory and Field Situations

Performing Organization:  Boston University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Determine the effects, if any, of drilling fluids
pollutants on behavior of the American Lobster.

Approach:  Field, laboratory and neurophysiological studies of
the behavior of larval and young lobsters and the relation to
exposure to drilling fluids.

Output:  Final report
Delivery:  6-81
                           A-41

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Project Title;  The Effects of Drilling Muds on the Behavior and
Benthic Ecology of Three Gadid Species

Performing Organization:  National Oceanic and Atmospheric
                          Administration
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  To examine the effects of drilling on juveniles.

Approach:  There will be two major phases of the study, (1) es-
tablishment of the normal baseline of settling behavior of the
three species and their patterns of shelter acquisition and
feeding exhibited during the benthic, juvenile stages, and
(2) alterations in the behavioral baselines following pollutant
contamination from drilling muds.

Output:   Final report
Delivery:  12-81
                            A-42

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Project Title;  A Study of the Impact of Discharged Drilling
Fluid on the Organisms of Georges Bank

Performing Organization:  New England Aquarium
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  The objectives of the proposed research are to
expand the data base on the effects of drilling fluids on the
fauna of Georges Bank and to characterize toxic consitituents of
drilling fluids.

Approach:  Laboratory approach will involve toxicity tests on
marine organisms

Output:  Final report on toxicity tests
Delivery:  9-82
                             A-43

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Project Title:  The Impact of Drilling Muds on Standing Stocks
and Metabolic Activities of Sediment Bacteria

Performing Organization:  Wayne State University
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  This project will examine the impact of drilling mud
on bacteria populations.

Approach:  Bacterial  populations from sediment samples will be
counted and their  growth rates determined.

Output:  Final Report
Delivery:  3-82
                              A-44

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Project Title:  Benthic Communities and Drilling Fluid Effects
on the Conditions for Larval Settlement on  the Georges Bank

Performing Organization:  U.S. Geological Survey
Responsible Laboratory:  Gulf Breeze Environmental Research
                         Laboratory

Objective:  Develop a technique for studying the effects of
drilling muds and fluids on larval settlement on benthic organisms.

Approach:  Traps will be used for in situ experiments on the
effects of drilling fluids on larval settlement.

Output:  Final report
Delivery:  6-81
                             A-45

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        APPENDIX B




   SECTIONS 402 AND 403




CLEAN WATER ACT (PL92-500)
           3-1

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      NATIONAL POLLUTANT DISCHARGE
              ELIMINATION SYSTEM

  Sec. 402. (a)  (1) Except as provided in sections 318
and 404 of this  Act, the Administrator may, after op-
portunity for public hearing, issue a permit for the dis-
charge of any pollutant, or combination of pollutants,
notwithstanding section 301  (a), upon condition that
such discharge will meet either all applicable require-
ments under sections 301, 302, 306, 307. 308. and 403 of
this Act, or prior to the taking of necessary implement-
ing actions relating to all such rcquiiements, such condi-
tions as the Administrator determines  are necessary to
carry out the provisions of this Act.
  (2) The Administrator shall prescribe conditions for
such permits to assure compliance with the requirements
of paragraph (1) of (Ins subsection, including conditions
on data and information collection, reporting, and such
other requirements as lie deems appropriate.
  (3) The permit program of the Administrator under
paragraph  (I) of  this  subsection,  and permits  issued
thereunder, shall be subject to the same terms, condi-
tions, and requirements as apply to a State permit pro-
gram and permits issued thereunder under subsection
(b) of this section.
  (4) All permits for  discharges  into  the  navigable
waters issued pursuant to section 13 of the Act of March
3, 1S99, shall be deemed to be permits issued under this
title, and permits issued under this title shall be deemed
to be permits issued  under section 13 of the Act of
March 3, 1899, and shall continue in force and effect for
their term unless revoked, modified, or suspended in ac-
cordance with the provisions of this Act.
  (5) No permit  for a discharge  into  the  navigable
waters shall be  issued  under section 13  of the Act of
March 3, 1899, after the date of enactment of this title.
Each application for a permit under section  13  of the
Act of March 3,  1899, pending on the date of enactment
of this Act shall be deemed to be an application for a
permit under this  section. The Administrator shall au-
thorize a State,  which  he determines has the capability
of administering a permit program which will carry out
the objective of this Act, to issue permits for discharges
into the navigable waters within the jurisdiction of such
Stats. The Administrator  may exercise the  authority
granted him by the preceding sentence only during the
period which begins on the date of enactment of this Act
and ends either on the ninetieth day after the date of the
first promulgation of  guidelines required  by section
304 (h) (2) of this  Act, or the date of approval by the
Administrator of a permit program t'or.such State under
subsection (b) of this section, whichever date first oc-
curs, and no such authorization to a State shall extend
beyond the last day of such period. Each such permit
shall be subject to such conditions as the Administrator
determines are necessary to carry out the provisions of
this Act. No such permit shall issue if chc Administrator
objects to such issuance.
  (b) At any time after the oromulganon of the guide-
lines required by subsection (h) (2) of section 304 of this
Act, the Governor of each State desiring to administer
its own permit program for discharges into navigable
waters within its jurisdiction may submit to the Admin-
istrator a full and complete description of the program
it proposes to  establish and administer under State law.
or under an interstate compact. In addition, such State
shall submit a statement from the attorney general (or
the attorney for those State water pollution control
agencies which have independent legal counsel), or from
the chief legal officer in the case of an interstate agency,
that the laws of such State, or the interstate compact,
as the case may be, provide adequate authority to carry
out the described program. The Administrator shall ap-
prove  each   such  submitted  program  unless   he
determines that adequate authority does not exist:
  (1)  To issue permits which—
  (A) apply, and insure compliance with, anyapplica-
blc requirements of sections 301. 302, 306, 307, and 403:
  (D) arc for fixed terms not exceeding five years; and
  (C) can be terminated or modified for cau.sc includ-
ing, but not limited  to, (he following:
  (i) violation of any condition of the permit;
  (ii)  obtaining a permit by misrepresentation, or fail-
ure to disclose full>  all relevant facts;
  (iii) change  in any condition that requires either a
temporary or permanent reduction or elimination of the
permitted discharge:
  (D) control the disposal of pollutants into wells;
  (2) (A) To  issue permits which apnly, and insure
compliance with, all applicable requirements of section
                                                   B-2

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308 of this Act, or
  (B) To inspect, monitor, enter, and require reports to
at least the same extent as required in section 308 of this
Act;
  (3) To insure that the public, and any other State the
waters of which  may be affected, receive notice of each
application for a permit and to provide an opportunity
for public hearing before a ruling on each such applica-
tion;
  (4) To insure  that the Administrator receives notice
of each application (including a copy thereof) for a per-
mit;
  (5) To insure  thai any State (other than the permit-
ting State), whose waters may be affected by the issu-
ance of a  permit may submit written recommendations
to the permitting State (and the Administrator) with re-
spect to any permit application and, if any part of such
written  recommendations are not accepted by the per-
mitting  State, that the permitting State will notify such
affected State (and the Administrator) in writing of its
failure to so accept such recommendations together with
its reasons for so doing;
  (6) To insure that no permit will be issued if, in the
judgment of the Secretary of the Army acting through
the Chief of Engineers,  after consultation with the Sec-
retary of  the department in which  the Coast Guard is
operating, anchorage and navigation of any of the navi-
gable waters would be substantially impaired thereby;
   (7) To  abate  violations of the permit or the permit
program, including  civil  and criminal penalties and
other waj s and means of enforcement.
   (S) To insure that any permit for a discharge from a
publicly owned  treatment works includes conditions to
require  the identification in terms of character and vol-
ume of pollutants of any significant source introducing
pollutants subject to pretreatmcnt standards under sec-
tion 307 (b) of this Act  into such works and a program
to assure compliance with such prctreatment standards
by each such source, in addition to adequate notice to
the pcimilting  agency  of (A) new introductions into
such \\oiks of pollutants from any source which would
be a new source as defined in section 306 if such source
were discharging pollutants. (B) new introductions of
pollutants into such works from .1  source winch  would
be subject to section 301 if it were discharging such pol-
lutants, or (C) a substantial change in volume or char-
acter of pollutants being introduced into such works by
a source introducing pollutants into such works  at the
 time of issuance of the permit. Such notice shall include
 informaiion on the  quality  and quantity of effluent to
 be introduced into such treatment works and any  antici-
 pated impact of such change in the quantiiy or quality
 of effluent to be discharged from such publicly owned
 treatment works: and
  (9)  To insure that any industrial user of any publicly
owned treatment works will comply with sections 204
(b), 307, and 308.
  (c)  (1) Not later than ninety Jays after the date on
which  a  Slate has submitted  a program (or revision
thereof) pursuant 10 subsection (b) of this section, the
Administrator shall suspend the issuance of permits
under subsection (a) of this section as to those navigable
waters subject to such program unless he determines
that the State permit program does not meet the require-
ments of subsection (b) of this section or does net con-
form to the guidelines issued under section 304 (i) (2) of
this Act. If the Administrator so determines, he shall
notify the State of any revisions or  modifications nec-
essary to conform to such requirements or guidelines.
  (2)  Any State permit program under this section shall
at all times be in accordance with this section and guide-
lines promulgated pursuant to section 304 (h) (2) of this
Act.
  (3)  Whenever  the Administrator  determines  after
public hearing that a Stale is not administering a pro-
gram  approved under this  section in accordance with
requirements of this section, he shall so notify the State
and, if appropriate corrective action is not taken within
a reasonable time, not 10 exceed ninety days, the Admin-
istrator shall withdraw approval of such program.  The
Administrator shall not withdraw approval of any such
program unless he shall first have notified the State, and
made public, in  writing,  the reasons  for such with-
drawal.
  (d) (1) Each  State  shall transmit to  the  Adminis-
trator  a copy of each permit application received by
such State and provide notice to  the Administrator of
every action related to the consideration of such permit
application, including each permit proposed to be issued
by such State.
  (2)  No  permit  shall issue (A)  if the Administrator
within ninety days of the date  of his  notification under
subsection  (b) (S) of this section objects in writing to
the issuance of such permit, or (B) if the Administrator
within ninety days of the date of transmitial of the pro-
posed permii by the Slate objects in writing  to the is-
suance of such  permit as  being outside the guidelines
and requirements of this Act. Whenever the Administra-
tor objects to the issuance of a permit under this para-
graph such written objection shall contain a statement
of the reasons for such objection and the effluent limita-
                                                    B-3

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lions and conditions which such permit would include if
it were issued hy the Administrator.
  (3)  The Administrator may, as to any permit applica-
tion, waive paragraph (2) of this subsection.
  (4)  In any case where, after the date of enactment of
this paragraph, the Administrator, pursuant to para-
graph (2) of this subsection, objects to the issuance of a
permit, or request of the State, a public hearing shall be
held by the Administrator on such objection.  If the
State does not rcsubmit such permit revised to meet such
objection within 30 days after completion of the hear-
ing, or, if no hearing is requested within 90 days after
the date of such objection, the Administrator may issue
the permit pursuant to subsection (a) of this section for
such source  in  accordance  with  the  guidelines and
requirements of this Act.
  (c)  In accordance with guidelines promulgated pur-
suant to subsection (h) (2) of section 304 of this Act. the
Administrator is authorized to waive the requirements
of subsection (d) of this section at the time he approves
a program pursuant to subsection (b) of this section for
any categoty (including any class,  type, or size within
such category) ot point sources within the State submit-
ting such program.
  (0 The Administrator shall  promulgate regulations
establishing categories of point sources which he deter-
mines shall not be subject to the requirements of subsec-
tion (d) of this section in any State with a program ap-
proved pursuant to subsection (b)  of this section. The
Administrator may distinguish among classes,  types.
and sizes within any category of point sources.
  (g)  Any permit issued under this section for the dis-
charge of pollutants into the navigable waters from a
vessel or other floating craft shall be subject to any ap-
plicable regulations promulgated by the Secretary of the
Departmem in which the Coast  Guard is  operating,
establishing  specifications  for safe   transportation.
handling, carriage, storage, and stowage of pollutants.
  (h)  In the event any  condition of a  permit for dis-
charges from a treatment works (as defined in section
212 of this Act) which is publicly owned is violated, a
State with a program  approved under subsection (b) of
this section or the Administrator, where no State pro-
gram  is approved or where  the Administrator  deter-
mines pursuant to section 309(a) of this Act that a State
with an approved program has not  commenced appro-
priate enforcement action with respect to such permit,
may proceed in a court of competent jurisdiction to
restrict  or  prohibit the introduction of any pollutant
into such treatment works by a source not utilizing such
treatment works prior to the finding that such condition
was violated.
  (i) Nothing in this section shall be construed to limit
the authority of the Administrator  to take action pur-
suant to section 30^ of this Act.
  (j) A copy of each permit  application and each pcr-
mi! issued  under  ihis section shall  be available  to li-.e
public.  Such permit application or permit,  or portion
thereof, shall fmihcr be  available  on request for the
purpose of reproduction.
  (k) Compliance with a permit issued pursuant to this
section shall be deemed compliance, for purposes of sec-
tions 309 and SOS, with sections 301. 302, 306. 307. and
403, except any standard imposed under section 307 for
a toxic pollutant injurious to human  health.  Until
December 31, 1974, in any case where a permit for dis-
charge has been applied for pursuant to this section, but
final administrative disposition of such application has
not been made, such discharge shall not  be a violation
of (1)  section 301.  306. and 402,  of this Act, or (2)
section 13 of the  Act of March 3, IS99, unless the Ad-
ministrator or other plaintiff proves that final admin-
istrative disposition of such application has  not been
made because of the failure of the applicant to furnish
information reasonably required or requested in order
to process (he application. For  the 180-day  period
beginning on the date  of  enactment of  the Federal
Water Pollution Control Act Amendments of 1972,  in
the case of any point source discharging any  pollutant
or combination of poilutants immediately prior to such
date of enactment which source is not subject to section
13 of the Act of March 3, 1899, the discharge by such
source shall not be a violation of this Act if such a
source applies for a permit  for discharge  pursuant  to
this section within such 180-day period.
  (I) The Administrator shall not require a  permit
under this section, for discharge composed entirely  of
return flows from irrigated agriculture, nor shall the Ad-
ministrator directly or indirectly,  require any State  to
require such a permit.
  [Editor's note:  SEC.  54(c) (2)  of the Clean Water
Act of 1977 says:
  "Any State permit program approved under section
402 of the Federal Water Pollution Control Act before
the date of enactment of the Clean Water Act of 1977,
which requires modification  to conform to the amend-
ment made by paragraph (1) of this subsection, shall not
be required  to be modified before the end  of the one
year period which begins on the date of enactment  of
the Clean Water Act of 1977 unless in order to make the
required  modification a State must amend or enact a
law in  which  case  such  modification  shall not be
required for such  State before the end of the two  year
period which begins on such date of enactment."]

         OCEAN DISCHARGE CRITERIA

  Sec. 403. (a) No permit under section 402 of this Act
for a discharge into the territorial sea. the waters of the
contiguous zone,  or the oceans shall be  issued, after
promulgation of guidelines established under subsection
(c) of this section,  except in compliance with such guide-
lines.  Prior  to the promulgation  of such  cuidelmcs, a
permit may be issued under such section 402 if the Ad-
ministrator determines it to be in the puolic interest.
  (b)  The requirements of subsection (d) of section 402
of this Act may not be waived in the ease of permits lor
discharges into the territorial sea.
  (c) (1) The Administrator shall, within one hundred
and eighty days after enactment of tins Act (and from
                                                    B-4

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time to  lime thereafter),  promulgate guidelines  Tor
determining the degradation of the waters of the terri-
torial seas, the contiguous zone, and the oceans., which
shall include:
  (A) the effect of disposal of pollutants on human
health or welfare, including but not limned to plankton,
fish, shellfish, wildlife, shorelines, and beaches;
  (B) the effect of disposal of pollutants on marine life
including the transfer, concentration,  and dispersal of
pollutants or their byproducts through  biological, phys-
ical, and chemical processes; changes in marine ecosys-
tem  diversity, productivity, and stability; and species
and community population changes;
  (C) the effect of disposal, of pollutants on esthetic,
recreation, and economic values;
  (D) the persistence and permanence of  the effects of
disposal of pollutants;
  (E) the effect of the disposal at varying rates, of par-
ticular volumes and concentrations of pollutants;
  (F) oilier possible locations  and methods of disposal
or recycling  of pollutants including land-based  alter-
natives; and
  (G) the effect on alternate uses of the oceans, such as
mineral exploitation and scientific study.
  (2) In any event where insufficient information exists
on any proposed discharge to  make  a reasonable judg-
ment on any of the guidelines established pursuant to
this subsection no permit shall be issued  under section
402 of this Act.
                                                B-5

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                       APPENDIX C

CALCULATION OF VOLUME OF DRILLING MUD DISCHARGED TO THE
             MARINE ENVIRONMENT DURING 1980
                          C-l

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       CALCULATION OF VOLUME OF DRILLING FLUIDS RELEASED TO THE
                    MARINE ENVIRONMENT DURING 1979
     The drilling fluids that are discharged within the marine envi-
ronment typically are water-based slurries containing clays and vari-
ous chemical and mineral additives.  The specific formulations used
in oil and gas exploration activities vary videly,  although most con-
tain barlte (barium sulfate) for density control and low concentra-
tions of sodium hydroxide, chrome lignosulfate,  lignite and other
chemicals to control viscosity, fluid loss, corrosion and other mud
properties (Ayers, 1980).

     These materials are released at drilling rig platforms both as
relatively small-volume operational discharges and as infrequent
large-volume bulk discharges.  It is estimated that a total volume of
10,000 to 30,000 barrels of mud, containing 20 to 30 percent solids,
are discharged over the life of a typical well (Ayers,  1980).   Since
the total number of wells within the OCS increased by 1,519 from 1978
to 1979 (U.S.  Geological Survey, 1980),  it is roughly estimated that
a total of 15 million to 46 million barrels of drilling fluid  were
discharged Into the marine environment during 1979.  This is about
2.4 million to 7.1 million yd3 (1.8 million to 5.4 million m3).
                                 C-3

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REFERENCES
   D-l

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                               REFERENCES
Ayers, R.C., Jr.   1980.   Comments  on the  fate  and effects of drilling
discharges in  the  marine environment.   Prepared  on  behalf of the
American Petroleum Institute  in connection  with  the Georges Bank
Protection Act,  Senate  Bill S-2119.   March  25,  1980,  Washington,  D.C.

Ayers, R.C., Jr.,  T.C.  Saver,  Jr.,  D.O. Steubner, and R.P. Meek.
1980a.  An environmental study of  drilling  fluids on  water quality
parameters during  high  rate,  high  volume  discharges to  the ocean.  _I_n
Symposium on Research on the  Environmental  Fate  and Effects of Dril-
ling Muds and  Cuttings,  January 21-24,  1980.   Lake  Buena Vista,
Florida.

Ayers, R.C., Jr.,  T.C.  Saver,  Jr.,  R.P. Meek,  and G.  Bowers.  1980b.
An environmental study  to assess the impact of drilling discharges in
the mid-Atlantic.   I.   Quality and  fate of  discharges.  In Symposium
on Research on Environmental  Fate  and Effects  of Drilling Muds and
Cuttings, January  21-24,  1980.   Lake Buena  Vista, Florida.

Brandsma, M.G., L.R. Davis, R.C. Ayers, Jr., and T.C. Saver, Jr.
1980.  A computer  model  co predict  the  short term fate of drilling
discharges in  the  marine environment.   In Symposium on Research on
Environmental  Fate and Effects of  Drilling  Muds  and Cuttings, January
21-24, 1980.   Lake Buena Vista,  Florida.

Brannon, A.C.  and  K. R.  Rao.   1979.   Barium, strontium, and calcium
levels in the  skelton,  hepatopancreas,  and  abdominal  muscle of the
grass shrimp,  Palaemonetes pugio;   relation to molting and exposure
to barite.  Comparative  Biochemistry and  Physiology,  63A:261-274.

Carr, R.S., L.A. Reitsema, J.M.  Neff. 1980.  Influence of a used
chrome lignosulfonate drilling mud  on the survival, respiration,
feeding activity and net growth efficiency  of  the opossum shrimp
Mysidopsis abnyra.  In  Symposium on Research on  Environmental Fate
and Effects of Drilling  Muds  and Cuttings,  January  21-24, 1980, Lake
Buena Vista, Florida.

Conklin, P.J., D.G. Doughtie,  and  K.R.  Rao.  1980.  Effects of barite
and used drilling  muds on crustaceans, with particular reference
to the grass shrimp, Palaemonetes  pugio.  ^n Symposium on Research
on Environmental Fate and Effects  of Drilling Muds  and Cuttings,
January 21-24, 1980, Lake Buena Vista,  Florida.
                                 D-2

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                        REFERENCES (Continued)
Gerber, R.P., E.S. Gllfillan, B.T. Page, D.S. Page and J. B. Hottiam.
1980.  Short and long term effects of used drilling fluids on marine
organisms.  ITI Symposium on Research on Environmental Fate Effects of
Drilling Muds and Cuttings, January 21-24, 1980, Lake Buena Vista,
Florida.

Houghton, J.P. and D.L. Beyers.  1980.  Effects of oil well drilling
fluids on several important Alaskan marine organisms.  In Symposium
on Research on Environmental Fate and Effects of Drilling Muds and
Cuttings, January 21-24, 1980, Lake Buena Vista, Florida.

Haughton, J.P., R.P. Britch, R.C. Miller, A.K. Runchal, and C.P.
Falls.  1980.  Drilling fluid dispersion studies at the Lower Cook
Inlet, Alaska, C.O.S.T. well.  In Symposium on Research on Environ-
mental Fate and Effects of Drilling Muds and Cuttings, January 21-24,
1980.  Lake Buena Vista, Florida.

Hudson, J.H. and D.M. Robbin.  1980.  Effects of drilling mud on  the
growth rate of the reef-building coral, Monastrea annularis.  In
Symposium on Research on Environmental Fate and Effects of Drilling
Muds and Cuttings, January 21-24, 1980.  Lake Buena Vista, Florida.

King, D. and W. Muir.  1974.  Report of the Interagency Working Group
on Health and Environmental Effects of Energy Use.  Council on
Environmental Quality, Washington, D.C.

Koons, C.B., C.D. McAuliffe and F.T. Weiss.  1975.  Environmental
Aspects of Drilling Muds and Cuttings from Oil and Gas Extraction
Operations in Offshore and Coastal Waters.  Prepared by Sheen
Technical Subcommittee for the Offshore Operators Committee.

Krone, M.A. and D.C. Biggs.  1980.  Sublethal metabolic responses of
the hermatyplc coral Madracis decactis exposed to drilling mud
enriched with ferrochrome lignosulfonate.  In Symposium on Research
on Environmental Fate and Effects of Drilling Muds and Cuttings,
January 21-24, 1980.  Lake Buena Vista, Florida.

McCulloch, W.L., J.M. Neff and R.S. Carr.  1980.  Bioavailability of
selected metals from used offshore drilling muds to the clam Rangia
cuneata and the oyster Crassostrea gigas.  In Symposium on Research
on Environmental Fate and Effects of Drilling Muds and Cuttings,
January 21-24, 1980.  Lake Buena Vista, Florida.
                                 D-3

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                         REFERENCES  (Continued)
Monaghan, P.H., C.D.  McAuliffe  and  F.T.  Weiss.   1976.  Environmental
Aspects of Drilling  Muds  and  Cuttings from Oil  and Gas Extraction
Operations in Offshore  and  Coastal  Waters.   Prepared by Sheen
Technical Subcommittee  for  the  Offshore  Operators Committee.

Neff, J.M., W.L. McCulloch, R.S.  Carr, and K.A.  Retzer.   1980.
Comparative toxicity of four  used offshore drilling muds  to several
species of marine  animals from  the  Gulf  of  Mexico.  In Symposium on
Research on Environmental Fate  and  Effects  of Drilling Muds and
Cuttings, January  21-24,  1980.  Lake  Buena Vista, Florida.

Page, D.S., B.T. Page,  J.R. Hotham, E.S.  Gilfillan and R.P. Gerber.
1980.  Bioavailabllity  of toxic constituents of  used drilling muds.
In Symposium on Research  on Environmental Fate  and Effects of
Drilling Muds and  Cuttings, January 21-24,  1980, Lake Buena Vista,
Florida.

Petrazzuolo, G.  1981.  An  environmental  assessment of drilling
fluids and cuttings  released  onto the Outer Continental Shelf
(draft).  Prepared for  the  Office of  Water Enforcement, Division of
Oil and Special Materials Control,  U.S.  Environmental Protection
Agency, Washington,  D.C.

Ray, J.P. and R.P. Meek.  1980.   Water column characterization of
drilling fluids dispersion  from an  offshore exploratory well on
Tanner Bank.  In Symposium  on Research on Environmental Fate and
Effects of Drilling  Muds  and  Cuttings, January  21-24, 1980.  Lake
Buena Vista, Florida.

Ray, J.P. and E.A. Shinn.   1975.  Environmental  effects of drilling
muds and cuttings.   In  Conference Proceedings on Environmental
Aspects of Chemical  Use in  Well-Drilling  Operations, May  21-23, 1975,
Houston, Texas.  EPA 560/1-75-004.

Rubinstein, N.I. and R. Rigby.  1980.  Acute and sublethal effects of
whole used drilling  fluids  on representative estuarine organisms.  In
Symposium on Research on  Environmental Fate and  Effects of Drilling
Muds and Cuttings, January  21-24, 1980,  Lake Buena Vista, Florida.

Tagatz, M.E., J.M. Ivey,  H.K. Lehman, M.  Tobia,  and J.L.  Oglesby.
1980.  Effects of  drilling  mud  on development of experimental estu-
arine macrobenthlc communities.   In Symposium on Research on Environ-
mental Fate and Effects of  Drilling Muds  and Cuttings, January 21-24,
1980, Lake Buena Vista, Florida.
                                  D-4

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                        REFERENCES (Concluded)
Thompson, J.H. and T.J. Bright.   1980.  Effectis of an offshore
drilling fluid on corals,  jn Symposium on Research on Environmental
Fate and Effects of Drilling Muds and Cuttings, January 21-24,  1980,
Lake Buena Vista, Florida.

U.S. Geological Survey.   1980.  Outer Continental Shelf Statistics,
1953 through calendar year 1979.  Conservation Division, Reston, Va.
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