United States Region 10 Alaska
Environmental Protection 1200 Sixth Avenue Idaho
Agency Seattle, WA 98101 Oregon
Washington
ESSENTIAL FISH HABITAT ASSESSMENT
FOR THE COOK INLET NPDES PERMIT
KAd Surface Access Restrictions
— — Boundary between Coastal Waters and Territorial Seas
Boundary between Territorial Seas and Federal Waters
¦¦ General permit wilt authorize discharges from exploration facilities and new source development and production facilities
\/A General permit will authorize discharges from exploration facilities and existing development and production facilities
H Proposed New Area of Coverage for which the general permit will authorize discharges from exploration facilities
and new source development and production facilities.
January 20, 2006
Prepared for:
U.S. Environmental Protection Agency, Region 10
Office of Water
NPDES Permits Unit
Prepared by:
Tetra Tech, Inc.
6100 219th Street, SW, #550
Mountlake Terrace, WA 98043
-------
-------
CONTENTS
1.0 Introduction 1
2.0 Proposed Action 1
2.1 Description of Project Area 1
2.1.1 General 1
2.1.2 Discharge-Restricted Areas 4
2.2 Covered Facilities and Nature of Discharge 5
2.2.1 Exploration Facilities 5
2.2.2 Development Facilities 5
2.2.3 Production Facilities 6
2.2.4 Existing Facilities 6
2.3 Authorized Action Under General NPDES Permit 7
2.3.1 Technology-Based Permit Requirements 7
2.3.1.1 Drilling Fluids 7
2.3.1.2 Drill Cuttings 8
2.3.1.3 Produced Water 8
2.3.1.4 Produced Sand 9
2.3.1.5 Well Treatment, Completion and Workover Fluids 9
2.3.1.6 Deck Drainage 10
2.3.1.7 Sanitary Waste 10
2.3.1.8 Domestic Waste 10
2.3.1.9 Miscellaneous Discharges 10
2.3.1.10 Chemically Treated Seawater Discharges 12
2.3.1.11 Stormwater Runoff from Onshore Facilities 12
2.3.1.12 All Discharges 12
2.3.2 Water Quality-Based Permit Requirements 12
2.3.2.1 Alaska State Water Quality Standards 13
2.3.3 Monitoring Requirements 17
2.3.3.1 Drilling Fluids and Drill Cuttings 17
2.3.3.2 Deck Drainage and Stormwater Runoff 17
2.3.3.3 Sanitary Wastewater 20
2.3.3.4 Domestic Wastewater 21
2.3.3.5 Miscellaneous Discharges 22
2.3.3.6 Produced Water and Produced Sand 23
2.3.3.7 Fate and Effects Monitoring for Large-Volume Produced Water Discharges 24
2.3.3.8 New Study Requirements 24
3.0 Essential Fish Habitat within Project Area 25
3.1 Species Essential Fish Habitat Descriptions 26
3.1.1 Walleye Pollock 26
3.1.2 Pacific Cod 26
3.1.3 Arrowtooth Flounder 27
3.1.4 Rock Sole 27
3.1.5 Alaska Plaice 27
3.1.6 Rex Sole 27
3.1.7 Dover Sole 27
3.1.8 Flathead Sole 28
3.1.9 Sablefish 28
3.1.10 Rockfish 28
3.1.11 Sculpins 28
3.1.12 Skates 29
3.1.13 Squid 29
3.1.14 Weathervane Scallop 29
3.1.15 Pink Salmon 29
3.1.16 Chum Salmon 30
COOK INLET NPDES PERMIT i 1/20/2006
ESSENTIAL FISH HABITAT ASSESSMENT
-------
3.1.17 Sockeye Salmon 30
3.1.18 Chinook Salmon 30
3.1.19 Coho Salmon 30
4.0 Effects of the Proposed Action on EFH 30
4.1 Drilling Fluids and Cuttings 31
4.1.1 Turbidity 32
4.1.2 Chemical Toxicity 32
4.1.3 Effects on EFH 34
4.2 Produced Water 34
4.2.1 Effects on EFH 35
4.3 Mixing Zones and Water Quality Standards 35
4.3.1 Mixing Zones 36
4.3.2 Water Quality Standards 36
4.3.3 Effects on EFH 37
4.4 Seismic Surveys and Boat Traffic 37
4.5 Offshore Pipeline Construction and Operation 38
4.6 Accidental Oil Spills 39
4.7 Effect on Prey Resources 40
5.0 Proposed Mitigation 41
6.0 Action Agency's View Regarding Effects of Proposed Actions on EFH 42
7.0 Literature Cited 43
COOK INLET NPDES PERMIT ii 1/20/2006
ESSENTIAL FISH HABITAT ASSESSMENT
-------
LIST OF ACRONYMS
ADEC
Alaska Department of Environmental Conservation
AMSA
Area Meriting Special Attention
API
American Petroleum Institute
BAT
Best available pollution control technology economically achievable
BCT
Best conventional pollution control technologies
BE
Biological Evaluation
BOD
Biochemical Oxygen Demand
BPT
Best Practicable Control Technology
CFR
Code of Federal Regulations
CHA
Critical habitat area
CWA
Clean Water Act
DMR
Discharge Monitoring Report
EEZ
exclusive economic zone
EFH
essential fish habitat
EIS
environmental impact statement
EPA
U.S. Environmental Protection Agency
ESA
Endangered Species Act
FMP
fisheries management plan
g
gram
GC/MS
Gas Chromatography/Mass Spectrometry
gpd
Gallons per day
m
Meter
mg/L
Milligrams per liter
mL
Milliliter
MLLW
Mean lower low water
MMS
Minerals Management Service
MSD
Marine Sanitation Device
NAF
nonaqueous drilling fluids
NMFS
National Marine Fisheries Service
NOAA Fisheries
National Oceanic and Atmospheric Administration's National Marine Fisheries
Service
NPDES
National Pollutant Discharge Elimination System
NSPS
New Source Performance Standards
OCS
Outer Continental Shelf
OOC
Offshore Operators Committee
PAH
Polynuclear Aromatic Hydrocarbons
RPE
Reverse Phase Extraction
SBMs
Synthetic-based drilling muds
SGR
State game refuge
SGS
State game sanctuary
SPP
Suspended particulate phase
TAH
Total Aromatic Hydrocarbons
TAqH
Total Aqueous Hydrocarbons
TSS
Total Suspended Solids
WET
whole-effluent toxicity
WQBEL
water quality-based effluent limitation
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
111
1/20/2006
-------
COOK INLET NPDES PERMIT iv 1/20/2006
ESSENTIAL FISH HABITAT ASSESSMENT
-------
1.0 Introduction
This assessment of Essential Fish Habitat (EFH) is for the issuance of a general National Pollutant
Discharge Elimination System (NPDES) permit for oil and gas exploration, development, and production
facilities in Cook Inlet, Alaska. The Magnuson-Stevens Fishery Conservation and Management Act, as
amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), established the procedures
designated to identify, conserve, and enhance EFH; that is, essential habitat for species regulated under a
federal fisheries management plan (FMP). The act requires federal agencies to consult with National
Oceanic and Atmospheric Administration's National Marine Fisheries Service (NOAA Fisheries) on all
actions, or proposed actions, authorized, funded, or undertaken by the agency that might adversely affect
EFH. This document provides details suitable for an EFH assessment from the considered U.S.
Environmental Protection Agency (EPA) actions related to the proposed project.
An EFH assessment must include (1) a description of the proposed action, (2) an analysis of the effects,
(3) the federal agency's (in this case, EPA's) view of the effects of the action, and (4) mitigation, if
necessary. To satisfy these requirements EPA includes the following sections:
> A description of the proposed actions including facilities, authorized activities, and
monitoring requirements of the NPDES permit
> List of EFH of species and life history stages that may be affected by the project
> EPA's assessment of the effects of the action
> Mitigative actions being proposed
> Concluding EPA's EFH effects determination
2.0 Proposed Action
The federal action that is the subject of this EFH Assessment is the issuance of a general NPDES permit
for oil and gas exploration, development, and production facilities in Cook Inlet, Alaska. This section of
the EFH describes the geographical area (project area) covered by the permit, as well as the operations
and discharges that would be authorized under the permit.
2.1 Description of Project Area
2.1.1 General
The expired general permit authorized discharges from exploratory oil and gas extraction facilities in
Cook Inlet north of a line extending between Cape Douglas (58 ° 13' N latitude, 153 ° 15' W longitude) and
Port Chatham (59° 13' N latitude, 151 °47' W longitude) (Figure 1-1). Development and production
facilities were authorized to discharge only in the northern (coastal) portion of this area of coverage. This
is the area north of a line extending across the Inlet at the southern edge of Kalgin Island (Figure 1-1).
The project area of coverage for the reissued general permit would include the areas covered by the
expired permit (Figure 1-1) and an additional area to the south in the lower portion of Cook Inlet to the
northern edge of Shuyak Island (Figure 1-2). The expanded area of coverage includes areas under
Minerals Management Service lease sales 191 and 199 and the adjoining state waters (Figure 1-2).
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
1
1/20/2006
-------
Anchor
J'oint
keiiiii
FVninsuLi
Augustine
Island
Kam[sfrak Bay
Gulf of Alaska
9 %
Pint (hatham
Lf\r«r*
¦SriT M i
Barren
Islands
C apt*
Douglas
i ' i i i i i i i
0 15 30 60 Miles
Nliuvak
(stand
— — Boundary between Coastal Waters and Territorial Seas
Boundary between Territorial Seas and Federal Waters
Expired permit authorized discharges (or exploration facilities
Y77\ Expired permit authorized discharges from new exploration facilities and existing development and production facilities
Figure 1-1. Expired NPDES permit areas.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
2-2
1/20/2006
-------
KA^l Surface Access Restrictions
— — Boundary between Coastal Waters and Territorial Seas
Boundary between Territorial Seas and Federal Waters
General permit will authorize discharges from exploration facilities and new source development and production facilities
X/A General permit will authorize discharges from exploration facilities and existing development and production facilities
| Proposed New Area of Coverage for which the general permit will authorize discharges from exploration facilities
and new source development and production facilities.
Figure 1-2. Proposed NPDES permit areas.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
2-3
1/20/2006
-------
2.1.2 Discharge-Restricted Areas
The proposed general permit would contain restrictions and requirements to ensure that unreasonable
degradation, as defined by the Ocean Discharge Criteria (40 CFR 125.121), would not occur. Restrictions
and prohibited areas of discharge are listed below:
• No discharges in water depths less than 5 meters (mean lower low water [MLLW] isobath)
for all facilities
• Exploration facilities are prohibited from discharging in waters less than the 10-meter MLLW
isobath
• No discharges in Kamishak Bay west of a line from Cape Douglas to Chinitna Point
• No discharges in Chinitna Bay inside the line between the points of the shoreline at latitude
59°52'45" N, longitude 152°48'18" W on the north and latitude 59°46'12" N, longitude
153°00'24" W on the south
No discharges in Tuxedni Bay inside of the lines on either side of Chisik Island
- From latitude 60°04'06" North, longitude 152°34'12" W on the mainland to the
southern tip of Chisik Island (latitude 60°05'45"N, longitude 152°33'30" W)
- From the point on the mainland at latitude 60° 13'45" N, longitude 152°32'42" W to
the point on the north side of Snug Harbor on Chisik Island (latitude 60°06'36" N,
longitude 152°32'54"W)
No discharges within 20 nautical miles of Sugarloaf Island, as measured from a center point
at latitude 58°53' N and longitude 152°02' W;
No discharges within the boundaries of, or within 4,000 meters of, a coastal marsh (the
seaward edge of a coastal marsh being defined as the seaward edge of emergent wetland
vegetation), river delta, river mouth designated as an Area Meriting Special Attention
(AMSA), state game refuge (SGR), state game sanctuary (SGS), or critical habitat area
(CHA). Areas meeting the above classifications within the proposed area of coverage are as
follows;
Palmer Bay Flats SGR Trading Bay SGR
Goose Bay SGR Kalgin Island CHA
Potter Point SGR Clam Gulch CHA
Susitna Flats SGR Kachemak Bay CHA
McNeil River SGS Anchorage Coastal Wildlife Refuge
Redoubt Bay CHA Port Graham/Nanwalek AMSA
Lake Clark National Park
• Mineral Management Service Lower Kenai Peninsula deferral area and Barren Island deferral
area, including the area between the deferral areas and the shore.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
4
1/20/2006
-------
• In Shelikof Strait, south of a line between Cape Douglas on the west (latitude 5 8 ° 5 l'N,
longitude 153 ° 15'W) and the northernmost tip of Shuyak Island on the east (latitude
58°37'N, longitude 152°22'W)
• Prohibited tracts identified under the Alaska Department of Natural Resources (ADNR)
Division of Oil and Gas's Mitigation Measure Number 33 (including the mouth of the Susitna
River and Knik and Turnagin Arms).
2.2 Covered Facilities and Nature of Discharge
The federal action would authorize discharges from three types of facilities—exploration, development,
and production. Each type of facility is briefly described below.
2.2.1 Exploration Facilities
Exploration for hydrocarbon-bearing strata can involve indirect methods, such as geological and
geophysical surveys; however, direct exploratory drilling is the only method to confirm the presence and
determine the quantity of hydrocarbons that might be present. Jackup rigs, which are barge-mounted
drilling rigs with extendable legs that can be used in waters up to 300 feet deep, and semisubmersible
units are the most common exploratory drilling facilities likely to be used in Cook Inlet (MMS 2003;
USEPA 1996). Shallow exploratory wells are typically drilled in the initial phase of exploration to
discover the presence of oil and gas reservoirs; deep exploratory wells are usually drilled to establish the
extent of the reservoirs (USEPA 1996). The major waste streams discharged from exploratory facilities
are drilling fluids, drill cuttings, cooling water, sanitary and domestic wastewater, and deck drainage.
Exploratory wells are not expected to extract hydrocarbons and therefore have not been authorized for the
discharge of produced waters.
The Minerals Management Service (MMS) estimated that exploratory well depths in the southern portion
of the Cook Inlet outer continental shelf would average 6,000 feet and that each well would generate
approximately 150 dry tons of drilling fluids and approximately 440 dry tons of drill cuttings for disposal
(MMS, 2003). Exploratory operations were limited to a maximum of five wells per site under the expired
NPDES general permit.
2.2.2 Development Facilities
Development of oil and gas reservoirs requires the drilling of wells into the reservoirs to begin
hydrocarbon extraction, increase hydrocarbon production, or replace wells that are not producing on
existing production sites (USEPA 1996). Operations are conducted from fixed or mobile facilities.
Development wells tend to be smaller in diameter than exploratory wells because the information gained
from exploratory drilling allows the driller to anticipate difficulties associated with the geological and
geophysical properties of the subsurface strata. Development operations may occur prior to, or
simultaneously with, production operations. The waste streams discharged from development operations
include those generally discharged from exploratory facilities (drilling fluids, drill cuttings, cooling water,
sanitary and domestic waste water, and deck drainage), but they can also include produced water.
MMS (2003) estimated that development and production well depths in the southern portion of the Cook
Inlet outer continental shelf would average 7,500 feet and that each well would require approximately 75
dry tons of drilling fluids and generate approximately 550 dry tons of drill cuttings for disposal.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
5
1/20/2006
-------
2.2.3 Production Facilities
Production operations consist of the active recovery of hydrocarbons from producing reservoirs. Facilities
conducting production operations usually are not involved in exploration activities. These facilities
typically discharge cooling water, sanitary and domestic wastewater, deck drainage, and produced water.
2.2.4 Existing Facilities
Eighteen facilities were active during the 5-year period from 1998 through 2003 and subject to the
expired NPDES general permit within the area of coverage in Cook Inlet, Alaska (Table 2-1). Other
facilities that were covered by that permit included three exploratory drilling wells (Fire Island, Sturgeon,
and Sunfish), Steelhead blowout relief well, and North Forelands.
Table 2-1. Cook Inlet, Alaska NPDES General Permit No. AKG285000 Active Facilities
NPDES permit no.
Facility name
Operator
AKG285001
Granite Point Treatment Facility
Unocal
AKG285002
Trading Bay Treatment Facility
Unocal
AKG285003
East Foreland Treatment Facility
XTO Energy
AKG285004
Platform Anna
Unocal
AKG285005
Platform Baker
Unocal
AKG285006
Platform Bruce
Unocal
AKG285007
Platform Dillon
Unocal
AKG285008
King Salmon Platform
Unocal
AKG285009
Dolly Varden Platform
Unocal
AKG2850010
Spark Platform
Marathon
AKG2850011
Platform A (Tyonek Platform)
Phillips
AKG2850012
Cross Timbers Platform A
XTO Energy
AKG2850013
Cross Timbers Platform C
XTO Energy
AKG2850014
Spurr Platform
Unocal
AKG2850015
Granite Point Platform
Unocal
AKG2850016
Grayling Platform
Unocal
AKG2850017
Monopod Platform
Unocal
AKG2850019
Steelhead Platform
Unocal
Oil and gas are extracted from numerous wells associated with production and development platforms.
Oil is generally produced in emulsion with water and must be separated from the water. Gas is generally
produced with significantly less water than is associated with oil production. Oil and gas are separated
from the produced water in various ways. Some production platforms are equipped to separate oil and
gas from produced water onboard and discharge produced water directly to Cook Inlet. Other production
platforms perform initial oil/water separation and then route their produced water to onshore facilities
(Granite Point, Trading Bay, and East Foreland) for further treatment. In such cases, produced water is
discharged from the onshore facility. Under the expired NPDES general permit, produced water is an
authorized discharge from the following facilities: Granite Point Treatment Facility; Trading Bay Facility;
East Forelands Treatment Facility; and platforms Anna, Baker, Bruce, Platform A (Tyonek), Cross
Timbers Platform A, Cross Timbers Platform C, and Spark.
Occasionally, operators might decide to stop platform operations, ceasing production and subsequent
discharges for some time. These facilities may resume production and discharging during the effective
period of the permit. At this time, the platforms Baker, Dillon, Spurr, and Spark have ceased operations
and, with the exception of deck drainage, are not discharging.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
6
1/20/2006
-------
2.3 Authorized Action Under General NPDES Permit
Requirements and activities that would be authorized under the proposed general permit include
technology-based permit requirements, water quality-based permit limits, and monitoring requirements
2.3.1 Technology-Based Permit Requirements
Technology-based limitations and conditions are proposed in the general permit as required under federal
regulation (Effluent Limitations Guidelines, 40 CFR Part 435, Subparts A and D). These guidelines
establish best practicable control technology (BPT), best conventional pollution control technology
(BCT), best available pollution control technology economically achievable (BAT), and new source
performance standards (NSPS) for the offshore and coastal subcategories of the oil and gas extraction
point source category. The limitations and monitoring requirements for the individual waste streams that
would be authorized by the general permit are described below.
2.3.1.1 Drilling Fluids
Drilling fluids are complex mixtures of clays, barite, and specialty additives used primarily to remove
rock particles (cuttings) from the hole created by the drill bit and transport them to the surface. Other
functions include cooling and lubricating the drill bit and controlling formation pressures. As the hole
becomes deeper and encounters different geological formations, the type of mud, or the mud composition,
might need to be changed to improve drilling performance.
The technology-based limits for drilling fluids in the expired general permit would be included in the
reissued permit. Discharges of drilling fluids from new source facilities would not be authorized.
Federal guidelines for the discharge of drilling fluids in offshore and coastal waters establish limits that
must not be exceeded throughout Cook Inlet. Based on those guidelines, limits and prohibitions for the
proposed general permit include the following:
• No discharge of free oil.
• No discharge of diesel oil, and a minimum toxicity limit of 3 percent by volume.
• Cadmium and mercury in stock barite, which is added to drilling fluids, limited to 3 mg/kg
and 1 mg/kg, respectively.
• No discharge of nonaqueous-based drilling fluids, also known as synthetic-based drilling
fluids, except those which adhere to drill cuttings as described in section 2.3.1.2.
• No discharge of oil-based drilling fluids, inverse emulsion drilling fluids, oil-contaminated
drilling fluids, and drilling fluids to which mineral oil has been added.
Free oil in drilling mud discharges is to be measured using the static sheen test method. Toxicity is
measured with a 96-hour LC50 (concentrations lethal to 50 percent of the test organisms) on the suspended
particulate phase using the Leptachoirusplumniosus species. Cadmium and mercury are measured using
USEPA Method 245.5 or 7471 on the stock barite prior to adding it to drilling fluids. These BAT- and
NSPS-based limits apply to drilling mud discharges throughout the area of coverage of the proposed
general permit.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
7
1/20/2006
-------
2.3.1.2 Drill Cuttings
Drill cuttings are the waste rock particles brought up from the well hole during exploratory drilling
operations. During typical operations, a mixture of cuttings and drilling mud returns to the surface
between the drill pipe and the bore hole. At the surface the cuttings and mud are separated, and the
cuttings are saved for analysis or disposed of by discharge into adjacent waters. The main source of
pollutants in drill cuttings are associated with the drilling fluids that adhere to the rock particles.
The technology-based limits in the expired general permit for drill cuttings for exploratory facilities
would be included without modification in the reissued general permit. No discharge of cuttings would
be authorized for new development and production facilities.
The limits and prohibitions proposed for the general permit include:
• No discharge of free oil associated with cuttings discharges.
• No discharge of drill cuttings generated using drilling fluids that are contaminated by oil or
contain diesel oil or mineral oil.
• Cadmium and mercury in stock barite, which is added to drilling fluids, are limited to
3 mg/kg and 1 mg/kg, respectively.
• The toxicity of the suspended-particulate phase of drilling fluids is limited to 30,000 ppm.
Although the discharge of nonaqueous-based drilling fluids would be prohibited under the proposed
permit (see Section 2.3.1.1), the discharge of drill cuttings that are generated using nonaqueous-based
drilling fluids is proposed to be authorized by the reissued permit. These new discharges are proposed to
be authorized only in the territorial seas and federal waters in Cook Inlet. Nonaqueous-based drilling
fluids, also known as synthetic-based muds, are a pollution prevention technology because the drilling
fluids are not disposed of through bulk discharge at the end of drilling. Instead, the drilling fluids are
brought back to shore and refurbished so that they can be reused. Drilling with synthetic-based muds
allows an operator to drill a slimmer well and causes less erosion of the well during drilling than drilling
using water-based muds. Therefore, relative to drilling with water-based muds, the volume of drill
cuttings discharged is reduced.
The limitations on the discharge of nonaqueous-based drilling fluids associated with cuttings are based on
the Effluent Limitations Guidelines for the Oil and Gas Extraction Point Source Category (see 40 CFR
Part 435, Subpart B). New limits are proposed for both the stock synthetic base muds that are added to
drilling fluids and the drilling fluids that adhere to discharged drill cuttings. The limits proposed to be
applied to stock base muds include polynuclear aromatic hydrocarbons (PAHs), sediment toxicity (10-
day), and the biodegradation rate. Prior to use, the drilling mud is also limited for formation oil
contamination, measured using gas chromatography/mass spectrometry (GC/MS). Drilling fluids that
adhere to drill cuttings and are discharged are limited for sediment toxicity (4-day), formation oil
contamination as measured by a reverse-phase extraction test or GC/MS, and base fluids that are retained
on discharged drill cuttings.
2.3.1.3 Produced Water
The term produced water refers to the water brought up from the oil-bearing subsurface geologic
formations during oil and gas extraction; it can include formation water, injection water, and any
chemicals added to the well hole or added during the oil/water separation process (USEPA 1996).
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
8
1/20/2006
-------
All the existing development and production facilities in Cook Inlet are in coastal waters in the area north
of a line extending across Cook Inlet at the southern edge of Kalgin Island (Figure 1-1). Federal
guidelines for the coastal subcategory of the oil and gas extraction point source category allow produced
waters to be discharged to Cook Inlet coastal waters provided the discharges meet a monthly average oil
and grease limit of 29 mg/L and a daily maximum oil and grease limit of 42 mg/L. These limits are
contained in the expired general permit for produced water and would be included without modification,
for existing facilities only, in the reissued general permit.
Produced waters would not be authorized for discharge in either coastal or offshore waters for new
sources. Federal regulations define the term new source for the oil and gas extraction point source
category (61 FR 66125, December 16, 1996). In simple terms, a new source with respect to produced
waters is a development/production facility, or an onshore treatment facility, that was constructed after
EPA issued the New Source Performance Standards.
The proposed general permit would include a new produced water sheen monitoring requirement that was
not part of the expired general permit. Under this requirement, operators of existing facilities would
observe the receiving water down-current of the produced water discharge once a day to see if there is a
visible sheen. If a sheen is observed, the operators would then be required to collect and analyze a
produced water sample to ensure compliance with the oil and grease limit. Observations would be
required to be made during slack tide so that the turbulence that can be present during periods of high
ambient velocity would not interfere with the ability to see a sheen. Observation of a sheen would not be
required at times when conditions such as sea ice make it difficult to see a sheen.
2.3.1.4 Produced Sand
The term produced sand refers to slurried particles that are the accumulated formation sands and scale
particles generated during oil and gas production (USEPA 1996). It also includes de-sander discharge
from the produced water waste stream and blowdown of the water phase from the produced water treating
system.
The expired general permit prohibited the discharge of produced sand based on NSPS, BAT, and BCT
established by the Offshore Subcategory Effluent Limitations Guidelines. This restriction would be
included without modification in the reissued general permit.
2.3.1.5 Well Treatment, Completion and Workover Fluids
The term well treatment fluids refers to any fluid used to restore or improve the productivity of a well by
chemically or physically altering the oil-bearing subsurface geologic formations (strata) after a well has
been drilled (USEPA 1996). Well completion fluids are salt solutions, weighted brines, polymers, and
various additives used to prevent damage to the well bore during operations that prepare the drilled well
for hydrocarbon production (USEPA 1996). Workover fluids are salt solutions, weighted brines,
polymers, or other specialty additives used in a producing well to allow safe repair and maintenance or
abandonment procedures (USEPA 1996).
The federal guidelines for NSPS and BAT (40 CFR 435.15) for the offshore category of the oil and gas
extraction point sources require monthly average oil and grease limits of 29 mg/L and a daily maximum
oil and grease limit of 42 mg/L for well treatment, well completion, and workover fluids. A limit of no
free oil discharge is also required for these discharge categories. These limits for produced water are
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
9
1/20/2006
-------
contained in the expired general permit and would be included without modification in the reissued
general permit.
2.3.1.6 Deck Drainage
The term deck drainage refers to any waste resulting from deck washings, spillage, rainwater, and runoff
from gutters and drains, drip pans, and work areas (USEPA 1996). Federal guidelines for NSPS, BAT,
and BCT for the offshore and coastal subcategories of the oil and gas extraction point source category
require no discharge of free oil for this discharge category. The proposed general permit would also
include new requirements for stormwater discharges for the existing onshore production facilities. (See
Section 2.2.3.11 for the stormwater discharge requirements).
2.3.1.7 Sanitary Waste
The term sanitary waste refers to human body waste discharged from toilets and urinals within facilities
subject to the general permit (USEPA 1996).
The federal guidelines for NSPS and BCT for the offshore and coastal subcategories of oil and gas
extraction point sources require that residual chlorine be maintained as close to 1 mg/L as possible for
facilities continuously staffed by 10 or more persons. The NSPS and BCT guidelines also require no
discharge of floating solids for offshore facilities continuously staffed by nine or fewer persons or
intermittently staffed by any number of persons.
The expired general permit specified a maximum total residual chlorine limit of 19 mg/L and a minimum
requirement of 1 mg/L. The proposed general permit would specify a lower maximum Total Residual
Chlorine limit of 2 mg/L and maintain the existing minimum requirement of 1 mg/L for facilities located
in territorial seas. The proposed general permit will specify a maximum Total Residual Chlorine limit of
13.5 mg/1 and a minimum of lmg/1 for facilities in coastal waters.
The expired general permit also included water quality-based limits for biochemical oxygen demand
(BOD), and total suspended solids (TSS). The proposed general permit would maintain the existing
effluent limitations for BOD (average monthly limit of 30 mg/L; daily maximum limit of 60 mg/L) and
TSS (average monthly limit of 51 mg/L; daily maximum limit of 67 mg/L).
2.3.1.8 Domestic Waste
The term domestic waste refers to materials discharged from sinks, showers, laundries, safety showers,
eyewash stations, and galleys within facilities subject to the general permit (USEPA 1996).
The federal guidelines for NSPS, BAT, and BCT for the offshore and coastal subcategories of oil and gas
extraction point sources require no discharge of floating solids or foam for this discharge category. This
limit is contained in the expired general permit and would be included without modification in the
reissued general permit.
2.3.1.9 Miscellaneous Discharges
Miscellaneous discharges that were authorized by the expired general permit include desalination
wastewater, blowout preventer fluid, boiler blowdown, fire control system test water, non-contact cooling
water, uncontaminated ballast water, bilge water, excess cement slurry, muds, cuttings, and cement at the
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
10
1/20/2006
-------
seafloor, and water-flooding wastewater. Brief definitions (USEPA 1996; 63 FR 211) of these discharges
are provided below:
• desalination wastewater wastewater associated with the process of creating fresh
water from sea water.
blowout preventer fluid
• boiler blowdown
fire control system test water
non-contact cooling water
• uncontaminated ballast water
bilge water
excess cement slurry
Water-flooding discharges
hydraulic fluid used in blowout preventer stacks during
well drilling.
discharges from boilers necessary to minimize solids
buildup in the boilers.
sea water that is sometimes treated with biocide, used for
the fire control system on oil and gas platforms and other
facilities.
sea water that is sometimes treated with biocide, used for
non-contact, once-through cooling of crude oil, produced
water, power generators, and various other pieces of
machinery.
tanker or platform ballast water, either local sea water or
fresh water, from the location where the ballast water
was pumped into the vessel.
seawater that becomes contaminated with oil and grease
and solids such as rust when it collects at low points in
the bilges.
excess mixed cement, including additives and waste
from equipment washdown, after a cementing operation.
discharges associated with the treatment of sea water
prior to its injection into a hydrocarbon-bearing
formation to improve the flow of hydrocarbons from
production wells.
The expired general permit limited these miscellaneous discharges by requiring no free oil discharges, as
monitored by the visual sheen test method. The permit required that discharges of uncontaminated ballast
water and bilge water be treated in an oil-water separator. Bilge water discharges were required to be
sampled for free oil using the static sheen test method when discharges occurred during broken, unstable,
or stable ice conditions. The proposed general permit contains a new sheen monitoring requirement for
produced water discharges. The proposed general permit does not require the use of the static sheen
method during times when storms or ice make observation of a sheen difficult. NPDES permittees were
also required to maintain a precise inventory of the types and quantities of chemicals added to water
flood, non-contact cooling water, and desalinization wastewater discharges.
Federal guidelines for the offshore and coastal subcategories of oil and gas extraction point sources for
this discharge category are not available. The limitations and monitoring requirements described above
for the expired general permit are proposed to be included without modification, except as described
below in Section 2.3.1.10, in the reissued general permit.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
11
1/20/2006
-------
2.3.1.10 Chemically Treated Seawater Discharges
A broad range of chemicals are used to treat sea water and fresh water in offshore oil and gas operations;
the available literature shows that more than 20 biocides are commonly used. They include derivatives of
aldehydes, formaldehyde, amine salt, and other compounds. The toxicity of those compounds to marine
organisms, as measured with a 96-hour LC50 test, varies substantially (0.4 mg/L to greater than
1,000 mg/L). The scale inhibitors commonly used are amine phosphate ester and phosphonate
compounds. Scale inhibitors are generally less toxic to marine life than are biocides; 96-hour LC50
concentrations for scale inhibitors have been shown to range from 1,676 mg/L to greater than 10,000
mg/L. Corrosion inhibitors are generally more toxic to marine life; 96-hour LC50 values for corrosion
inhibitors are reported to range from 1.98 mg/L to 1,050 mg/L.
The discharge of specific biocides, scale inhibitors, and corrosion inhibitors is not proposed to be limited
in the reissued general permit. Because of the large number of chemical additives used, it would be very
difficult to develop technology-based limits for each individual additive. Also, if the permit were to limit
specific chemicals, it could potentially halt the development and use of new and potentially more
beneficial treatment chemicals, which would not be specifically listed in the permit and for which
discharge would not be authorized. An additional reason for not specifying chemical additives is that the
field conditions for each producing well can change and require different treatment over the life of the
permit. Instead, chemically treated sea water discharges would be limited on the basis of the following
requirements:
• The concentrations of treatment chemicals in discharges of sea water or fresh water would be
limited to the most stringent of the following: (1) the maximum concentrations and any other
conditions specified in the EPA product registration labeling if the chemical additive is an
EPA-registered product, (2) the maximum manufacturer's recommended concentration when
one exists, or (3) a maximum of 500 mg/L.
2.3.1.11 Stormwater Runoff from Onshore Facilities
The proposed general permit would include new requirements for existing onshore production facilities.
The operators of the onshore facilities would be required to develop and implement Storm Water
Pollution Prevention Plans. The plans would include management practices implemented to monitor and
maintain operations to prevent contamination of stormwater. The change in requirements would ensure
greater consistency between the stormwater requirements of onshore production facilities and those
typically required for shore-based industrial facilities.
2.3.1.12 All Discharges
The proposed general permit would prohibit the discharge of rubbish, trash, and other refuse. It would
also require that the discharge of surfactants, dispersants, and detergents be minimized.
2.3.2 Water Quality-Based Permit Requirements
The proposed general permit establishes water quality based limitations and monitoring requirements
necessary to ensure that the authorized discharges comply with Alaska's Water Quality Standards and
with the federal Ocean Discharge Criteria (40 CFR Part 125, Subpart M, and section 403 of the Clean
Water Act).
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
12
1/20/2006
-------
2.3.2.1 Alaska State Water Quality Standards
Section 301(b)(2)(C) of the Clean Water Act and 40 CFR 122.44(d)(1) require that NPDES permits
contain the limitations and conditions necessary to attain state Water Quality Standards. The expired
general permit contained limits based on state Water Quality Standards for metals, hydrocarbons, and
toxicity in produced water discharges. On the basis of updated mixing zone computations described
below, the expired permit's Water Quality Standards-based limitations are proposed to be recalculated. In
addition, new limits for whole-effluent toxicity on miscellaneous discharges to which treatment chemicals
have been added are proposed. The industry uses treatment chemicals such as biocides, corrosion
inhibitors, and oxygen scavengers in a number of discharges such as cooling water and water flood waste
water. Many of those chemical additives have been shown to be highly toxic. To ensure that such
discharges comply with the requirements of both state Water Quality Standards and federal Ocean
Discharge Criteria, whole effluent toxicity limitations are included in the proposed general permit.
EPA and states establish mixing zones to minimize the portion of a waterbody in which water quality
criteria are exceeded. In state waters, states typically have the authority to define mixing zones and
determine their size. Chronic aquatic life and human health criteria are limited on the basis of the
calculated critical dilution at the edge of the mixing zone. In general, criteria to protect aquatic life from
acute toxic effects of discharges must be met at the edge of a smaller mixing zone called the zone of
initial dilution. The zone of initial dilution is typically intended to further restrict the portion of the
waterbody that is acutely toxic to aquatic life. Alaska's Water Quality Standards also specify that acute
water quality criteria must be met at the edge of a smaller initial mixing zone (see 18 ACC 70.255(d)).
Aquatic life would tend to pass through a smaller zone of initial dilution fairly rapidly and, because of the
short exposure time, the acute toxic effects of the discharged pollutant would be minimized. Chronic
aquatic life criteria and human health criteria are based on longer-term exposure of aquatic life to
pollutants. Thus, mixing zones are larger than zones of initial dilution and allow for a longer exposure
time.
Alaska's Water Quality Standards do not allow mixing zones to be used unless they are authorized by
ADEC (Alaska Department of Environmental Conservation). When they are authorized, the standards
require that they be as small as practicable (see 18 ACC 70.240). The state regulations at 18 AAC 70.245
require that in determining the appropriateness and size of a mixing zone, the existing uses of the
waterbody must be fully protected and maintained. Numeric water quality criteria are used to measure
the attainment of Water Quality Standards. Although the standards allow numeric criteria for chronic
aquatic life and human health protection to be exceeded within the mixing zone, the criteria must be met
at its boundary. The standards (18 AAC 70.255) also require that there be no lethality to organisms
passing through mixing zones and that acute aquatic life criteria be met at the boundary of a smaller zone
of initial dilution established within the mixing zone.
Alaska's Water Quality Standards do not allow ADEC to authorize mixing zones if the pollutants could
bioaccumulate or persist in concentrations above natural levels in the environment or if they can be
expected to cause a carcinogenic or other human health risk. ADEC is required to take the potential
exposure pathways into account in determining whether to authorize mixing zones. ADEC has
determined that the discharges authorized by the previous permit are not likely to persist in the
environment and therefore has authorized mixing zones. The state has previously authorized mixing
zones ranging in size from 363 meters to 1,420 meters from the discharge point for Cook Inlet oil and gas
facilities.
On the basis of the maximum projected discharge rates and pollutant concentrations forecast by the
permittees, ADEC has approved the new mixing zones. The new mixing zones radii and the previous
mixing zone radii are shown in Table 2-2.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
13
1/20/2006
-------
Table 2-2. Proposed and Previous Mixing Zone Radii (meters)
Total aromatic
Facility
hydrocarbons (TAH)/
total aqueous
hydrocarbons (TAqH)
Acute metals
Chronic metals
Whole-effluent toxicity
Proposed
Previous
Proposed
Previous
Proposed
Previous
Proposed
Previous
Granite Point
(Onshore)
2,685
955
19
20
21
66
780
20
Trading Bay
2,418 a
1,420
<1 a
42
9 c
431
31 a
59
East Foreland
1,794
412
142
20
121
106
1,742
20
TyonekA
36
20
36
20
60
663
73
46
Anna
2,734
363
239
20
262
37
274
40
Bruce
1,840
867
201
20
218
31
715
58
Baker
3,016
555
202
22
216
37
248
20
Dillon
2,121
405
11
20
13
43
210
20
Granite Point
(Platform)
1,863
None
12
None
14
None
533
None
a Mixing zone will be 5,791 m initially. Unocal will reduce the mixing zone to 2,418 m by installing a diffuser on a two
year compliance schedule.
b Mixing zone will be 124 initially. Unocal will reduce the mixing zone to <1 m by installing a diffuser on a two year
compliance schedule.
c Mixing zone will be 760 initially. Unocal will reduce the mixing zone to 9 m by installing a diffuser on a two year
compliance schedule.
d Mixing zone will be 804 initially. Unocal will reduce the mixing zone to 31 m by installing a diffuser on a two year
compliance schedule.
The new mixing zones in the proposed general permit are in many cases larger than those previously
authorized by ADEC. The main reasons for these larger mixing zones are that a more conservative model
was used in the mixing zone applications for the proposed permit (CORMIX versus Plumes) and that
mixing zones were established for reasonable worst-case conditions.
The proposed general permit includes a new requirement for a diffuser on the Trading Bay discharge.
The Trading Bay discharge is significantly greater in volume than the other discharges that would be
authorized under the general permit. The discharge is also located in fairly shallow water and is much
nearer to sensitive areas than any other produced water discharge in Cook Inlet. Therefore, EPA has
determined that additional controls are needed for the Trading Bay produced water discharge. By
dividing the effluent and discharging it through a number of separate ports, a diffuser can greatly increase
mixing. Through more efficient mixing, the size area of the mixing zone can be greatly reduced. The
Trading Bay discharge was examined for a number of discharge velocities, diffuser lengths, and ambient
current speeds to determine a diffuser design that is technically feasible and would result in the smallest
mixing zone. As a result of coordinated efforts between ADEC, the Operator, and EPA, a diffuser has
been designed for the Trading Bay discharge that would reduce the mixing zone length from 5,791 meters
to 100 meters under most ambient current conditions. Under conditions representative of very low
current speeds, the mixing zone with a diffuser would be 2,418 meters. Because mixing zones were
established based on reasonable worst-case conditions, the mixing zone approved by ADEC for Trading
Bay is 2,418 meters. This much smaller mixing zone would help to ensure that any potential effects from
the discharge are greatly minimized. A compliance schedule is included in the proposed permit, and it
affords the permittee 2 years to design, construct, and install the diffuser.
As noted, all mixing zones were derived using conditions representative of a reasonable worst-case
scenario. ADEC used the CORMIX dispersion model to calculate the dilution the effluent plume receives
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
14
1/20/2006
-------
and determine where the discharges would meet Water Quality Standards. The discharges were examined
for a variety of conditions. The current speed at which the discharges were modeled was found to have
the most significant effect on mixing. For a single-port discharge, the worst-case scenario was generally
found to exist at high current speeds. The worst-case scenario for a discharge made through a multiple-
port diffuser was found to exist at low current speeds. The difference between single-port discharges and
diffiisers is caused by changes in the receiving water dynamics created by the discharge made through a
diffuser. A diffuser discharge is typically made at a high velocity through a number of ports. The
diffuser line and the multiple discharges made from a diffuser cause localized instability of the currents.
At high current speeds, that instability results in a very high degree of mixing relative to a discharge made
through a single port. The mixing is less when current speeds are lower; however, better mixing at low
current speeds can be achieved by increasing the diffuser length. For the Trading Bay discharge, a
diffuser approximately 100 meters in length is planned. That diffuser would accommodate a high degree
of mixing at both low and high current speeds.
The number of dilutions calculated for the different produced water discharges is shown in Table 2-3.
The dilutions, calculated by CORMIX, were used to derive the numeric Water Quality Standards-based
limits shown in Appendix A.
Table 2-3. ADEC Calculated Dilutions
Facility
TAH/TAqH
Acute metals
Chronic metals
Whole-effluent
toxicity
Mixing
zone(m)
Dilutions
Mixing
zone(m)
Dilutions
Mixing
zone(m)
Dilutions
Mixing
zone (m)
Dilutions
Granite Point
(Onshore)
2,685
7,756
19
32.2
21
35.9
780
1,638
Trading Bay
2,418 a
1,970
<1 b
20.3
9 c
183.3
14 d
346
East Foreland
1,794
2,556
142
64.6
121
55.1
1,742
1,476
TyonekA
36
175.6
36
178.7
60
276.7
73
327
Anna
2,387
12,509
197
599.1
262
665.6
274
701
Bruce
1,447
9,170
130
496
218
550.7
715
2,625
Baker
3,016
15,668
202
151
216
168
248
210
Dillon
2,121
3,386
11
24
13
26
210
358
Granite Point
(Platform)
1,863
7,756
130
32.2
14
35.9
533
1,638
a Mixing zone will be 5,791 initially. Unocal will reduce the mixing zone to 1,554 m by installing a diffuser on a two
year compliance schedule.
b Mixing zone will be 124 initially. Unocal will reduce the mixing zone to 4 m by installing a diffuser on a two year
compliance schedule.
c Mixing zone will be 988 initially. Unocal will reduce the mixing zone to 14 m by installing a diffuser on a two year
compliance schedule.
d Mixing zone will be 83 initially. Unocal will reduce the mixing zone to <1 m by installing a diffuser on a two year
compliance schedule.
In addition to the limits based on the current discharges, the proposed general permit would include
incremental limits intended to accommodate future changes in the volume of produced-water discharges.
The previous permit did not include incremental limits. Consequently, when the Trading Bay discharge
increased from 2,742,660 gallons per day to 5,598,600 gallons per day, the assumptions made in deriving
the Water Quality Standards-based limits were no longer valid. The incremental limits in the proposed
permit were calculated using the range of discharge rates that could reasonably be expected for each
discharge. The ranges of discharge rates were analyzed using CORMIX to determine the changes in flow
that would significantly affect the dilution at the edge of the state-established mixing zones. The
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
15
1/20/2006
-------
incremental ranges in the discharge volumes that were examined and the calculated dilutions are shown in
Table 2-4.
Table 2-4. Incremental Discharges and the Associated Dilutions
GRANITE POINT
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(2,685 meters)
Dilutions at
acute metals
mixing zone
(19 meters)
Dilutions at
chronic metals
mixing zone
(21 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(780 meters)
Dilutions at
ammonia
mixing zone
(53 meters)
7,000
7,756
32.2
35.9
1,638
90
10,000
15,158
79
136
3,235
117.4
15,000
13,227
68
118
2,821
102.1
20,000
12,005
62
107
2,558
91.7
30,000
10,521
54
93
2,237
80.7
TRADING BAY
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(2,418 meters)
Dilutions at
acute metals
mixing zone
(1 meters)
Dilutions at
chronic metals
mixing zone
(9 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(31 meters)
Dilutions at
ammonia
mixing zone
(1 meters)
5,000,000
2,181
20.3
183.3
346
72
5,600,000
1,970
20.3
183.3
346
72
6,000,000
1,850
20.3
183.3
346
72
7,000,000
1,619
20.3
183.3
346
72
EAST FORELAND
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(1,794 meters)
Dilutions at
acute metals
mixing zone
(142 meters)
Dilutions at
chronic metals
mixing zone
(121 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(1,742 meters)
Dilutions at
ammonia
mixing zone
(21 meters)
200,000
1,812
107
129
1,748
1
500,000
1,365
77
93
1,277
1
700,000
2331
70
85
1,152
1
840,000
2,556
64.6
55.1
1,476
1
PLATFORM ANNA
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(2,734 meters)
Dilutions at
acute metals
mixing zone
(239 meters)
Dilutions at
chronic metals
mixing zone
(262 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(274 meters)
Dilutions at
ammonia
mixing zone
(81 meters)
25,000
15,584
752
839
874
291
51,000
12,509
599.1
665.6
701
234
75,000
10,886
506
564
587
194
100,000
9,794
439
491
512
166
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
16
1/20/2006
-------
Table 2-4. Incremental Discharges and the Associated Dilutions (continued)
PLATFORM BRUCE
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(1,840 meters)
Dilutions at
acute metals
mixing zone
(201 meters)
Dilutions at
chronic metals
mixing zone
(218 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(715 meters)
Dilutions at
ammonia
mixing zone
(29 meters)
5,000
12,138
660
728
3,846
128
11,500
9,170
496
550.7
2,625
108
15,000
8,217
411
456
2,306
73
20,000
7,232
318
357
1,964
48
TYONEKA
Discharge
rate (gpd)
Dilutions at
TAH/TAqH
mixing zone
(36 meters)
Dilutions at
acute metals
mixing zone
(36 meters)
Dilutions at
chronic metals
mixing zone
(60 meters)
Dilutions at
whole-effluent
toxicity mixing
zone
(73 meters)
Dilutions at
ammonia
mixing zone
(4 meters)
25,000
166
166
267
324
0
31,066
175.2
175.2
274.5
323.5
0
40,000
164
164
251
300
0
2.3.3 Monitoring Requirements
Monitoring requirements for authorized discharge categories are described below.
2.3.3.1 Drilling Fluids an d Drill Cuttings
The monitoring requirements for the discharge of drilling fluids and drill cuttings for the proposed general
permit are specified in Table 2-5.
In addition to the requirements shown in Table 2-5, the permittee must maintain a precise chemical
inventory of all constituents added down hole, including all drilling mud additives used to meet specific
drilling requirements. The permittee must maintain these records for each mud system for 5 years and
must make the records available to EPA upon request.
2.3.3.2 Deck Drainage and Stormwater Runoff
The monitoring requirements for the discharge of deck drainage and stormwater for the proposed general
permit are shown in Table 2-6. In addition, operators of shore-based facilities must comply with Storm
Water Pollution Prevention Plan requirements. The free oil limits and toxicity testing requirements are
not proposed to be changed from those in the expired permit.
The permittee must ensure that deck drainage contaminated with oil and grease is processed through an
oil-water separator prior to discharge. Once per discharge event, the permittee must sample deck
drainage discharges that are processed through the oil-water separator and test for sheen, total aromatic
hydrocarbons, total aqueous hydrocarbons, and PAHs.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
17
1/20/2006
-------
Table 2-5. Effluent Limitations and Monitoring Requirements for Drilling Fluids and Drill Cuttings (Discharge 001)
Discharge
Pollutant parameter
Effluent limitation
Monitoring requirements
Average Maximum daily
monthly limit limit
Measurement
frequency
Sample type
Water-based muds and
cuttings
Suspended particulate phase toxicity3
Minimum 96-hour LC50 of
30,000 ppm
Monthly and
end-of-well
Grab
Drilling fluids
No dischargeB
Daily
Grab
Free oil
No discharge0,0
Daily
Visual
Diesel oil
No discharge
Daily
Grab
Mercury
1 mg/kge
Once per well
Grab
Cadmium
3 mg/kge
Once per well
Grab
Total Volumeb
See II.B.6
Monthly
Estimate
Depth-dependent discharge rate c
0 to 5 meters
>5 to 20 meters
>20 to 40 meters
>40 meters
No discharge
500 bbl/hr
750 bbl/hr
1,000 bbl/hr
Continuous during
discharge
Estimate
Nonaqueous muds
Drilling fluids
No discharge
Daily
Observation
Nonaqueous stock base
mud
(C16-C18 internal olefin,
C12-C14 ester or Cs ester)
Mercury
1 mg/kg®
Annual
Grab
Cadmium
3 mg/kge
Annual
Grab
PAH'
mass ratio9 <1x10"s
Annual
Grab
Sediment toxicity
ratio" <1.0
Annual
Grab
Biodegradation rate
ratio' <1.0
Annual
Grab
Total volume
See II.B.6
Monthly
Estimate
Nonaqueous
drilling fluids which adhere
to drill cuttings
(offshore subcategory only)
Free oil
No discharge0,0
Daily
Grab
Diesel oil
No discharge
Daily
Grab
SPP toxicity3
Minimum 96-hour LC50 of
30,000 ppm
Monthly
Grab
Sediment toxicity
Drilling mud sediment toxicity ratioJ
<1.0
Annual
Grab
Formation oil
No dischargeK
Daily
Grab
Base mud retained on drill cuttings
(C16-C18 internal olefin stock')
6.9 g NAF base mud/100 g wet
drill cuttings m
Daily0
Grab
Base mud retained on drill cuttings"
(C12-C14 ester or Cs ester stock)
9.4 g NAF base mud/100 g wet
drill cuttings m
Daily0
Grab
Total volume
See II.B.6
Monthly
Estimate
-------
Table 2-5. Effluent Limitations and Monitoring Requirements for Drilling fluids and Drill Cuttings (Discharge 001) (continued)
a As determined by the 96-hour suspended particulate phase (SPP) toxicity test. See 40 CFR Part 435, Subpart A, Appendix 1.
b Report total volumes for all types of operations (exploratory, production and development). See part II.B.3 of this permit.
c Maximum flow rate of total muds and cuttings includes pre-dilutant water; water depths are measured from mean lower low water.
d As determined by the static sheen test. (See Appendix 1 to 40 CFR part 435, subpart A.)
e Dry weight in the stock barite. Analysis shall be conducted using EPA Methods 245.5 or 7471. The permittee shall analyze a representative sample of
stock barite once prior to drilling each well and submit the results with the Discharge Monitoring Report (DMR) for the month in which drilling operations
commence for the respective well. If the permittee uses the same supply of stock barite to drill subsequent wells, the permittee may submit the same
analysis for those subsequent wells.
f Polynuclear aromatic hydrocarbons.
g PAH mass ratio = [mass (g) of PAH (as phenanthrene)] [mass (g) of stock base mud] as determined by EPA method 1654, Revision A, entitled "PAH
Content of Oil by HPLC/UV," December 1992. See part II. 1.4. of this permit.
h Base mud sediment toxicity ratio = [10-day LC50 of C16-C18 internal olefin, C12-C14 ester or Cs ester] [10-day LC50 of stock base mud] as determined by
ASTM E 1367-92 method: "Standard Guide for Conducting 10-day Static Sediment Toxicity Tests with Marine and Estuarine Amphipods,"1992, after
preparing the sediment according to the method specified at 40 CFR Part 435, Subpart A, Appendix 3. See part II. 1.2 of this permit.
' Biodegradation rate ratio = [cumulative gas production (ml) of Ci6-Ci8 internal olefin, C12-C14 ester or C8 ester] [cumulative gas production (mL) of stock
base mud], both at 275 days as determined by ISO 11734:1995 method: "Water quality - Evaluation of the 'ultimate' anaerobic biodegradability of organic
compounds in digested sludge—Method by measurement of the biogas production (1995 edition)" as modified for the marine environment. See part II.1.3
of this permit.
j Drilling mud sediment toxicity ratio = [4-day LC50 of C16-C18 internal olefin] [4-day LC50 of drilling mud removed from drill cuttings at the solids control
equipment] as determined by ASTM E 1367-92 method: "Standard Guide for Conducting 10-day Static Sediment Toxicity Tests with Marine and Estuarine
Amphipods,"1992, after preparing the sediment according to the method specified in Appendix A of this permit.
k As determined before drilling fluids are shipped offshore by the GC/MS compliance assurance method (see part II. 1.5 of this permit), and as determined
prior to discharge by the Reverse Phase Extraction (RPE) method (see part II.H.6 of this permit) applied to drilling mud removed from drill cuttings. If the
operator wishes to confirm the results of the RPE method, the operator may use the GC/MS compliance assurance method (part 11.1.5 of this permit).
Results from the GC/MS compliance assurance method shall supercede the results of the RPE method.
' This limitation is applicable only when the nonaqueous drilling fluids (NAF) base mud meets the stock limitations defined in this table.
m As determined by the American Petroleum Institute (API) retort method. See part II. 1.7 of this permit.
" Monitoring shall be performed at least once per day when generating new cuttings, except when meeting the conditions of the Best Management Practices
described in section II.B.3 below. Operators conducting fast drilling (i.e., greater than 500 linear feet advancement of the drill bit per day using
nonaqueous muds) shall collect and analyze one set of drill cuttings samples per 500 linear feet drilled, with a maximum of three sets per day. Operators
shall collect a single discrete drill cuttings sample for each point of discharge to the ocean. The weighted average of the results of all discharge points for
each sampling interval would be used to determine compliance.
° Averaged over all well sections.
-------
Table 2-6. Effluent Limitations and Monitoring Requirements for Deck Drainage and Storm
Water Runoff
Effluent
parameter
Units
Effluent limitations
Monitoring requirements
Average Maximum
monthly limit daily limit
Sample frequency
Sample type
Free oil
—
No discharge3
Dailyb
Visual
Whole effluent
toxicity0
TUce
Report
Once during the first year
the permittee is covered by
the permitd
Part III.A
Flow
MGD
Monthly
Estimated
a If discharge occurs during broken or unstable ice conditions, or during stable ice conditions, the Static Sheen
Test must be used (see Appendix 1 to 40 CFR Part 435, Subpart A).
b When discharging.
c Contaminated deck drainage must be processed through an oil-water separator prior to discharge, and
samples for that portion of the deck drainage collected from the separator effluent must be sampled for
whole-effluent toxicity (WET) testing.
d Sample must be collected during a significant rainfall or snowmelt. If discharge of deck drainage separate
from produced water is initiated after the first year of the permit, sampling must occur during the year
following the initiation of separate deck drainage discharge.
e With the final report for each test, the following must also be reported: date and time of sample, the type of
sample (i.e., rainfall or snowmelt), estimate of daily flow and basis for the estimate (e.g., turbine meters,
monthly precipitation, estimated washdown).
If deck drainage is commingled with produced water, this discharge must be considered produced
water for monitoring purposes (see Section 2.2.5.6). However, samples collected for compliance
with the produced water oil and grease limits must be taken prior to commingling the produced
water stream with deck drainage or any other waste stream. The estimated deck drainage flow
rate must be reported in the comment section of the discharge monitoring report (DMR).
2.3.3.3 Sanitary Wastewater
The monitoring requirements for the discharge of sanitary wastewater for the proposed general
permit are shown in Table 2-7.
The term M10 refers to platforms continuously staffed by 10 or more persons. The term M9IM
refers to platforms continuously staffed by nine or fewer persons or intermittently staffed by more
persons. Intermittently staffed means staffed for fewer than 30 consecutive days.
For any facility using a marine sanitation device (MSD), the permittee must conduct annual
testing of the MSD to ensure that the unit is operating properly. The permittee must note the
results of the test on the December DMR.
In cases where the sanitary and domestic wastes are mixed prior to discharge and sampling of the
sanitary waste component of the discharge is infeasible, the discharge may be sampled after
mixing; however, the most stringent discharge limitations for both discharges apply to the mixed
waste stream.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
20
1/20/2006
-------
Table 2-7. Effluent Limitations and Monitoring Requirements for Sanitary Wastewater
Discharge
Effluent
Effluent limitations
Monitoring requirements
parameter
Average
monthly limit
Maximum
daily limit
Sample
frequency
Sample
type
Sanitary Waste Water
All Discharges b
Flow rate
Report
1/month
Estimate
Fecal coliforms
Report
1/month a
Grab
Floating solids
No discharge
1/day
Observationa
M10 MSD
and MSD/Biological
BODc
30 mg/L
60 mg/L
1/month
Grab
TSSc
51 mg/L
67 mg/L
1/month
Grab
Treatment Units
Total residual
chlorine
Between 1 mg/L and 2 mg/L
1/month
Grab
M9IM MSD
BODc
30 mg/L
60 mg/L
1/month
Grab
and MSD/Biological
Treatment Units
TSSc
51 mg/L
67 mg/L
1/month
Grab
BODc
30 mg/L
60 mg/L
1/month
Grab
M10 Biological
Treatment Units
TSSc'd
30 mg/L
60 mg/L
1/month
Grab
Total residual
chlorine
Between 1 mg/L and 2 mg/L
1/month
Grab
M9IM Biological
BODc
48 mg/L
90 mg/L
1/month
Grab
Treatment Units
TSSc'd
56 mg/L
108 mg/L
1/month
Grab
a The permittee must monitor by observing the surface of the receiving water in the vicinity of the outfall(s)
during daylight at the time of maximum estimated discharge. For domestic waste, observations must
follow either the morning or midday meal.
b In cases where sanitary and domestic wastes are mixed prior to discharge and sampling of the sanitary
waste component stream is infeasible, the discharge may be sampled after mixing. In such cases, the
discharge limitations for sanitary wastes must apply to the mixed waste stream.
c The numeric limits for BOD and TSS apply only to discharges to state waters.
d The TSS limitation for biological treatment units is a net value. The net TSS value is determined by
subtracting the TSS value of the intake water from the TSS value of the effluent. Report the TSS value of
the intake water on the comment section of the DMR. For those facilities that use filtered water in the
biological treatment units, the TSS of the effluent may be reported as the net value. Samples collected to
determine the TSS value of the intake water must be taken on the same day, during the same time period
that the effluent sample is taken. Intake water samples must be taken at the point where the water enters
the facility prior to mixing with other flows. Influent samples must be taken with the same frequency that
effluent samples are taken.
2.3.3.4 Domestic Wastewater
The monitoring requirements for the discharge of domestic wastewater for the proposed general
permit are shown in Table 2-8.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
21
1/20/2006
-------
Table 2-8. Effluent Limitations and Monitoring Requirements for Domestic Wastewater
Effluent
parameter
Effluent limitations
Monitoring requirements
Discharge
Average
monthly limit
Maximum daily
limit
Sample
frequency
Sample
type
Domestic Waste
Flow rate
Report
1/Month
Estimate
Water
(004)note2
Floating solids
No discharge
1/Daynote1
Visual
Foam
No discharge
1/Day
Visual
Footnotes:
1 The permittee must monitor by observing the surface of the receiving water in the vicinity of the outfall(s)
during daylight at the time of maximum estimated discharge. For domestic waste, observations must follow
either the morning or midday meal.
2 In cases where sanitary and domestic wastes are mixed prior to discharge, and sampling of the sanitary waste
component stream is infeasible, the discharge may be sampled after mixing. In such cases, the discharge
limitations for sanitary wastes must apply to the mixed waste stream.
In cases where the sanitary and domestic wastes are mixed prior to discharge, and sampling of the
sanitary waste component of the discharge is infeasible, the discharge may be sampled after
mixing, however, the most stringent discharge limitations for both discharges apply to the mixed
waste stream.
2.3.3.5 Miscellaneous Discharges
The monitoring requirements associated with the discharge of miscellaneous categories
(desalination unit wastes, blowout preventer mud, boiler blowdown, fire control system test
water, non-contact cooling water, uncontaminated ballast water, bilge water, excess cement
slurry, mud, cuttings, cement at the seafloor, and waterflooding must comply with the effluent
limitations and monitoring requirements shown in Table 2-9.
Table 2-9. Effluent Limitations and Monitoring Requirements for Miscellaneous
Discharges (Discharges 005-014)
Effluent limitations
Monitoring requirements
Parameter
Average monthly
limit
Maximum daily
limit
Sample
frequency
Sample
type
Flow
Report
Monthly
Estimate
Free oil
No dischargenote l
No discharge note l
1/Weeknote'
Visual
Chemical additives
See Section II.F.3 of draft permit
Monthly
Calculation
Whole-effluent
See Section II.F.4
See Section II.F.4
1/Quarter
Grab
Toxicitynote2
of this permit
of this permit
Footnotes:
1 Discharge is limited to those times that a visible sheen observation is possible unless the operator uses the
static sheen method. Monitoring shall be performed using the visual sheen method on the surface of the
receiving water once per week during periods of slack tide when discharging, or by use of the static sheen
method at the operator's option. The number of days a sheen is observed must be recorded. For discharges
during stable ice, below ice, to unstable ice or broken ice conditions, a water temperature that approximates
surface water temperatures after breakup shall be used.
2 Applicable to discharges to which chemical additives have been added.
In addition to the monitoring requirements specified in Table 2-9, permittees must maintain an
annual inventory of the quantities and rates of chemicals and biocides that are added to the
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
22
1/20/2006
-------
desalination unit waste water. Each annual inventory must be assembled for the calendar year
and submitted to EPA by March 1 of the following year.
2.3.3.6 Produced Water and Produced Sand
The monitoring requirements for produced water discharged from existing facilities are shown in
Table 2-10. There are no monitoring requirements for produced sand because no discharges are
allowed.
Table 2-10. Effluent Limitations and Monitoring Requirements for Produced Water and Produced
Sand
Effluent
Limitations
Monitoring Requirements
Parameter
Monthly average
Daily maximum
Sample
frequency
Sample
type
Flow Rate
Report
Report
1/Week
Estimate
Produced Sand
No Discharge
No Discharge
Oil and Grease
29 mg/L
42 mg/L
1/Week
Grabnote'
pH < 1 MGD
6.0 to 9.0 S.U.
1/Month
Grab
pH > 1 MGD
6.0 to 9.0 S.U.
1/Week
Grab
Free Oil
Report
1/Daynote^
Visual sheen
Footnotes
1 The sample type shall be either grab, or a 24-hour composite, which consists of the arithmetic average of the
results of four grab samples taken over a 24-hour period. If only one sample is taken for any one month, it
must meet both the daily and monthly limits. Samples shall be collected prior to the addition of any seawater
to the produced water waste stream.
2 See Section II.G.6.b ofthe draft permit.
In addition to the monitoring requirements shown in Table 2-10, produced waters must be
analyzed once a month for total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons
(TAqH) in accordance with the analytical requirements cited in Alaska Water Quality Standards
(18 AAC 70.020(b)); once a month for ammonia, total copper, total mercury, total nickel, and
total zinc; and once a quarter for whole-effluent toxicity.
The proposed general permit would reduce the monitoring frequency for produced water if the
permittee has complied with the water quality-based effluent limits (WQBELs) for 12
consecutive months. Compliance with water quality limits would be determined on the basis of
measured sample results and the application of the dilution factors shown in Tables 2-3 and 2-4
for the mixing zones proposed in Table 2-2. If compliance has been achieved for 12 consecutive
months, the monitoring frequency for TAH, TAqH, ammonia, total copper, total, mercury, total
nickel, and total zinc would be reduced to once per quarter; the monitoring frequency for whole
effluent toxicity would be reduced to once every 6 weeks.
If the permittee has not complied with the WQBELs, the proposed general permit would increase
the monitoring frequency for produced water until compliance has been demonstrated for 3
consecutive months. After compliance has been established for 3 months, the required frequency
would return to the default frequency of one sample per month (TAH, TAqH, ammonia, total
copper, total, mercury, total nickel, and total zinc) or one sample per quarter whole-effluent
toxicity). The increased monitoring frequency would be once per week for TAH, TAqH,
ammonia, total copper, total, mercury, total nickel, and total zinc and once per month for whole-
effluent toxicity.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
23
1/20/2006
-------
2.3.3.7 Fate and Effects Monitoring for Large-Volume Produced Water Discharges
The expired general permit required operators of new facilities located within 4,000 meters of
coastal marshes to conduct baseline monitoring. However, no new facilities were located within
4,000 meters of coastal marshes, so no baseline monitoring was conducted under the expired
permit. To fulfill EPA's requirements under Clean Water Act (CWA) section 403(c), which
requires that the potential impacts of permitted discharges be fully understood, the monitoring
requirement from the expired general permit is proposed to be extended to cover all new facilities
installed after the effective date of the new permit.
2.3.3.8 New Study Requirements
Few ambient data associated with oil and gas discharges in Cook Inlet currently exist. The only
available sediment data were collected in the far southern portions of Cook Inlet, well over 100
miles from the existing large-volume produced water discharges. Although those data could
indicate whether general contamination exists, because of the collection location, there is no way
to draw a connection to the existing produced water discharges. Available ambient water column
data relevant to the existing discharges are also extremely limited. Because of the data
limitations, EPA has historically relied on tools like dispersion modeling to analyze the potential
effects of discharges for permitting decisionmaking.
As a means to increase available ambient data and ensure that future permit decisions are based
on a better body of information, the proposed general permit would require new fate and effects
monitoring for large-volume produced water discharges. Under this new requirement, an
operator with a produced water discharge greater than 100,000 gallons per day would be required
to conduct a sediment and water column sampling study. The goal of the study is to determine if
there is a reasonable potential for large-volume produced water discharges to adversely affect
sensitive areas of Cook Inlet. To achieve that goal, the proposed permit would require that
operators plan and conduct studies that at a minimum would include the collection of both
sediment and water column samples at 50-meter intervals over a distance of 2,000 meters
between the discharge point and the closest sensitive habitat. Sediment would be sampled by a
minimum of one box core or similar sample collected at each station. At a minimum, water
column monitoring would include collection of a sample from both the mid and lower water
column at each station. All samples would be analyzed for the metals and hydrocarbons that are
limited in produced water discharges. An operator with large-volume produced water discharges
would be required to submit a study plan to EPA for approval before starting to monitor. Because
the studies would be in areas within Alaska state waters, EPA plans to coordinate review of the
study plans with ADEC and obtain input as a part of the approval process. Therefore, operators
would be required to submit their plans to ADEC as well as to EPA.
Pursuant to the Ocean Discharge Criteria, EPA is required to fully understand the potential
impacts on the marine environment of future large-volume discharges that might be placed in
Cook Inlet. The information obtained from these studies would help EPA comply with the
requirements of Ocean Discharge Criteria Evaluations in future permitting actions. In addition,
EPA and ADEC would use the information to determine whether any future changes to the permit
conditions are needed to meet the requirements of Alaska's Water Quality Standards.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
24
1/20/2006
-------
3.0 Essential Fish Habitat within Project Area
An EFH assessment is applied to the defined EFH for all species managed under a federal
Fisheries Management Plan (FMP). Currently three FMPs have fisheries resources that might be
affected by the proposed action:
• The Fisheries Management Plan for Groundfish of the Gulf of Alaska
• The Fisheries Management Plan for Scallop Fishery off Alaska
• The Fisheries Management Plan for the Salmon Fisheries in the exclusive economic
zone (EEZ) off the Coast of Alaska
NOAA Fisheries has recently completed an environmental impact statement (EIS) defining EFH
for the Alaskan region affected by these and other FMPs (NMFS 2005). The definition NOAA
Fisheries uses for a species' EFH is based on the subset of the species' population and is 95
percent of the population for a particular life stage, if life history data are available for the
species. Where information is insufficient and a suitable proxy cannot be inferred, EFH is not
described for that species life stage.
The EFH species and life stages present in the Gulf of Alaska are shown for groundfish,
weathervane scallops, and salmon in Tables 3-1, 3-2, and 3-3, respectively. EFH species and life
stages present in the project area (Figure 1-2) are indicated in these tables. Species that have at
least one life stage defined as having EFH in the project area are discussed in Section 3.1.
Detailed maps of defined EFH species' life stage distribution for the Gulf of Alaska, including the
project area, are presented in the EIS (NMFS 2005), Appendix D, and are not included here.
Table 3-1. Gulf of Alaska Groundfish EFH Species Life Stages Present in the Project Area
Gulf of Alaska species
Eggs
Larvae
Early juvenile
Late juvenile
Adult
Walleye pollock
1
1
-
1
1
Pacific cod
2
1
-
1
1
Yellowfin sole
2
-
2
2
Arrowtooth flounder
-
1
-
1
1
Rock sole
-
1
-
1
1
Alaska plaice
1
-
1
1
Rex sole
1
1
-
1
1
Dover sole
1
1
-
1
1
Flathead sole
1
1
-
1
1
Sablefish
2
1
-
1
1
Shortraker/rougheye
rockfish
-
1
-
2
2
Northern rockfish
-
1
-
-
2
Thornyhead rockfish
-
1
-
2
2
Yelloweye rockfish
-
1
-
2
2
Dusky rockfish
-
1
-
-
2
Atka mackerel
-
2
-
-
2
Sculpins
-
-
-
1
1
Skates
-
-
-
-
1
Sharks
-
-
-
-
-
Forage fish complex
-
-
-
-
-
Squid
-
-
-
1
1
Octopus
-
-
-
-
-
- = no information is available to define EFH in the Gulf of Alaska.
1 = life stage with defined EFH in the project area.
2 = life stage with defined EFH, but none in the project area.
Source: NMFS 2005.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
25
1/20/2006
-------
Table 3-2. Alaska Scallops' EFH Life Stages Present in the Project Area
Scallop
Egg
Larvae
Early juvenile
Late juvenile
Adult
species
Weathervane
-
-
-
1
1
- = no information is available to define EFH in the Gulf of Alaska.
1 = life stage with defined EFH in the project area.
2 = life stage with defined EFH, but none in the project area.
Source: NMFS 2005.
Table 3-3. Salmon Species' EFH Life Stages Present in the Project Area
Salmon
Freshwater
Freshwater
Estuarine
Marine
Marine
Freshwater
species
eggs
larvae and
juveniles
juveniles
immature
adults
juveniles
and
maturing
adults
Pink
Chum
Sockeye
Chinook
Coho
2
2
1
1
1
2
2
2
1
1
1
2
2
2
1
1
1
2
2
2
1
1
1
2
2
2
1
1
1
2
- = no information is available to define EFH in the Gulf of Alaska.
1 = life stage with defined EFH in the project area.
2 = life stage with defined EFH, but none in the project area.
Source: NMFS 2005.
3.1 Species Essential Fish Habitat Descriptions
This section presents information on EFH characteristics and general life history for only species
with defined EFH in the project area. Species without defined EFH in the project area are not
discussed. With the exception of EFH for salmon species, all other defined EFH in the project
area (Figure 1-2) is limited to the outer third of Cook Inlet, with most near or just outside the
Cook Inlet entrance. (See Appendix D of NMFS 2005.)
3.1.1 Walleye Pollock
The egg, larval, late juvenile and adult life stages of walleye pollock have essential fish habitat in
the project area. With the exception of the adult life stage, which extends into Kachemak Bay, all
others are restricted to extending slightly inside the Cook Inlet entrance. Eggs, which are pelagic,
are found at depths from 0 to 1000 m. The epipelagic larvae have a similar distribution.
Juveniles and adults are most often in the lower and middle portions of the water column, at
depths less than 200 m for juveniles and less than 1000 m for adults. These life stages have no
substrate preference. Seasonal migrations occur from the outer continental shelf to shallow
waters (90 to 140 m, or 295 to 459 ft) for spawning. Spawning takes place in early spring; the
eggs hatch in about 10 to 20 days, depending on water temperature, and larvae spend 20 to 30
days in the surface waters.
3.1.2 Pacific Cod
EFH for larvae, late juveniles, and adults is present in the NPDES permit area, however only the
adult stage EFH extend well into Cook inlet, while others are restricted to near the entrance.
Pacific cod is a demersal species that occurs on the continental shelf and upper continental slope.
Spawning habitat occurs along the continental shelf and slope from about 40 to 290 m (131 to
951 ft); spawning typically occurs from January to April. The optimal conditions for embryo
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
26
1/20/2006
-------
development are water temperatures between 3 and 6 °C and dissolved oxygen concentrations
from 2 to 3 ppm saturation. The larvae are epipelagic, occurring primarily in the upper 45 m (148
ft) of the water column shortly after hatching, and they move downward in the water column as
they grow. The larvae occur primarily in waters less than 100 m deep over soft substrate.
Juvenile and adult EFH occurs in the lower portion of the water column in the inner, middle, and
outer continental shelf from 0 to 200 m, where their preferred substrate is soft sediment primarily
from mud to gravel (NMFS 2005).
3.1.3 Arrowtooth Flounder
EFH in the project area includes larvae, near the Cook Inlet entrance, and juveniles and adults,
extending into Cook Inlet as far as Kachemak Bay. All life stages of Arrowtooth flounder occur
in the inner continental shelf regions with water depths ranging from 1 to 50 m (3 to 164 ft).
Spawning is thought to occur from September through March. Larvae are planktonic for at least
2 to 3 months until metamorphosis occurs; juveniles usually inhabit shallow areas. Adults are
found in continental shelf waters until age 4, and they occupy both shelf and deeper slope waters
at older ages with highest concentrations at 100 to 200 m (NMFS 2005). Both adults and
juveniles are often found over soft substrate, typically mud and sand, in the lower portion of the
water column.
3.1.4 Rock Sole
Project area EFH for larvae occurs near the Cook Inlet entrance, while juvenile and adult EFH
extends beyond the Kachemak Bay entrance. All life stages of rock sole except the egg stage
occur in the inner continental shelf regions. Spawning takes place during late winter/early spring
near the edge of the continental shelf at depths from 125 to 250 m (410 to 820 ft). The eggs are
demersal and adhesive. The larvae are planktonic for at least 2 to 3 months until metamorphosis
occurs. The juveniles inhabit shallow waters until at least age 1 (NMFS 2005). Juveniles and
adults occur over moderate to softer substrates of sand, gravel, and cobble, mostly at depths from
0 to 200 m.
3.1.5 Alaska Plaice
EFH for Alaska plaice in the project area includes eggs, late juveniles, and adults. The EFH for
all three life stages is at the outer edge of the project area, outside Cook Inlet. Alaska plaice is
considered a "deep water" species in the Gulf of Alaska groundfish management area. Eggs are
present over a range of depths (0 to 500 m) in the spring. Juvenile and adult EFH is in the lower
portion of the water column at depths of 0 to 200 m, over sand and mud substrate (NMFS 2005).
3.1.6 Rex Sole
Egg, larval, late juvenile, and adult EFH is present in the project area. All EFH is present only in
the NPDES area at the entrance of Cook Inlet. Eggs and larvae are present over a range of depths
(0 to 500 m) in the spring. EFH of juveniles and adults is in the lower portion of the water
column at depths of 0 to 200 m, over gravel, sand, and mud substrate (NMFS 2005).
3.1.7 Dover Sole
The project area EFH for Dover sole egg, larval, late juvenile, and adult life stages is present only
near the Cook Inlet entrance. This fish is considered a "deep water flatfish" in the Gulf of Alaska
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
27
1/20/2006
-------
management area. The EFH ranges to great depths (0 to 3,000 m) for larvae and eggs, although
adult and juvenile EFH is less deep (0 to 500 m) in the middle and outer shelf and upper slope
areas, occurring in the lower portion of the water column over soft substrate of sand and mud
(NMFS 2005).
3.1.8 Flathead Sole
The flathead sole EFH for eggs and larvae extends inside the Cook Inlet entrance, while late
juvenile and adult habitat extends into Kachemak Bay in the project area. The adults are benthic
and have separate winter spawning and summer feeding distributions. The fish over-winter near
the continental shelf margin and then migrate onto the mid and outer continental shelf areas in the
spring to spawn in deepwater areas near the margin of the continental shelf. The eggs are pelagic,
and the larvae are planktonic, and usually inhabit shallow areas. Egg and larval EFH ranges from
0 to 3000 m, while juveniles' and adults' EFH is shallower (0 to 200 m) and occurs over sand and
mud substrate. Like all flatfish, flathead sole occur in the lower portion of the water column.
3.1.9 Sablefish
The EFH for larval, juvenile, and adult sablefish is present only at the entrance of the Cook Inlet
in the project area. Spawning is pelagic at depths of 300 to 500 m (984 to 1,640 ft) near the edges
of the continental slope. Larvae are oceanic through the spring; by late summer, small juveniles
(10 to 15 cm [4 to 6 in]) occur along the outer coasts of southeast Alaska, where they
predominantly spend their first winter. First- to second-year juveniles are found primarily in
nearshore bays; they move to deeper offshore waters as they age, with EFH habitat at depths of
200 to 1,000 m. Adults are found on the outer continental shelf mainly on the slope and in deep
gullies at typical depths of 200 to 1000 m, over varied habitat, usually in soft substrate (NMFS
2005).
3.1.10 Rockfish
Some 32 rockfish species are present in Alaskan waters, but only 7 rockfish species (Table 3-1)
have designated EFH in the Gulf of Alaska (NMFS 2005). The EFH of larvae for all rockfish
species is grouped, not separated by species. Within the project area rockfish larvae are present
only near the Cook Inlet entrance. No juvenile or adult EFH for any of the seven rockfish species
is present in the project area because all habitat for these life stages is present in deeper water,
often near the continental shelf, or in other nearshore areas of the Gulf of Alaska. The EFH for
rockfish larvae is characterized as being in the entire shelf (0 to 200 m) and slope areas (200 to
3000 m), except the EFH for Pacific Ocean perch, which extends only to a 500 m depth in the
upper slope area. In general, rockfish tend to be demersal as late juveniles and adults, although
some species are pelagic occupying midwater areas. Many species are associated with rocky
substrates. Rockfish have internal fertilization and release live young in the spring (NMFS 2005).
3.1.11 Sculpins
The EFH for juvenile and adult sculpins in the project area is present only in a narrow band
extending from Kachemak Bay in the east to Kamishak Bay, north of Augustine Island, to the
west (NMFS 2005). Both juveniles and adults are present in the lower portion of the water
column in the inner, middle, and outer shelf (0 to 200 m) and also in the upper slope (200 to 500
m) in the Gulf of Alaska, over varied substrate (mud to rock). Most spawning occurs in the
winter, and some species have internal fertilization. Typically eggs are laid in rocks, where males
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
28
1/20/2006
-------
guard them. Larvae often have diel migration (near the surface at night) and might be present
year-round.
3.1.12 Skates
The EFH for adult skates extends well into the Cook Inlet project area, beyond Kachemak Bay,
and covers most of outer third of the Inlet (NMFS 2005). Adult EFH is found in waters of 0 to
500 m on shelf and upper slope areas. Adult skates are present in the lower portion of the water
column over varied substrate from mud to rock. Skates are oviparous, fertilization is internal, and
eggs are deposited in a horny case for incubation. After hatching, the juveniles likely remain in
shelf and slope waters, but their distribution is unknown. No data on habitat requirements or
movement are available (NMFS 2005).
3.1.13 Squid
The EFH for juvenile and adult squid is present only in the outer portion of the project area,
between Cape Douglas and the Barren Islands, outside Cook Inlet. Juveniles and adults use the
entire water column over the shelf (0 to 500 m) and all the slope (500 to 1,000 m) regions (NMFS
2005). Reproduction is poorly known, but fertilization is internal, and squid lay eggs in
gelatinous masses in water 200 to 800 m deep. Young juveniles are often in water less than 100
m deep, while older juveniles and adults are more often in waters 150 to 500 m deep. Spawning
occurs in the spring (NMFS 2005).
3.1.14 Weathervane Scallop
The designated EFH for late juvenile and adult weathervane scallops extends well into the outer
half of Cook Inlet to beyond the entrance to Kachemak Bay. The EFH habitat of late juveniles
and adults is along the seafloor in the middle (50 to 100 m) to outer (100 to 200 m) shelf areas. It
is generally elongated along the current lines, as is apparent in the EFH in Cook Inlet, which
tends to be in an elongated distribution toward the middle of the inlet (NMFS 2005). The
scallops are generally over clay to gravel substrates. Although they are capable of swimming,
they usually remain along seafloor depressions. Fertilization is external, and pelagic larvae drift
for a month before they settle to the seafloor (NMFS 2005).
3.1.15 Pink Salmon
The essential fish habitat for pink salmon within the project area includes estuarine juvenile,
marine juvenile, and marine immature and maturing adults (NMFS 2005). The estuarine EFH is
the mouth areas of streams from the mean high tide line to the salinity transition zone. All other
marine life stage EFH includes the entire project area because EFH for this species extends from
the mean higher tide line to the 200 nautical mile limit of the U.S. EEZ. This species is pelagic to
a depth of about 200 m. Pink salmon spawn in small streams within a few miles of the shore,
within the intertidal zone, or at the mouths of streams. Eggs are laid in stream gravels. After
hatching, salmon fry move downstream to the open ocean. Pink salmon stay close to the shore,
moving along beaches during their first summer feeding on plankton, insects, and small fish. At
about 1 year of age, pink salmon move offshore to ocean feeding areas.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
29
1/20/2006
-------
3.1.16 Chum Salmon
The EFH for chum salmon within the project area includes estuarine juveniles, marine juveniles,
and marine immature and maturing adults (NMFS 2005). The estuarine EFH is the mouth areas
of streams from the mean high tide line to the salinity transition zone. All other marine life stage
EFH includes the entire project area because EFH for this species extends from the mean higher
tide line to the 200-nautical-mile limit of the U.S. EEZ. This species is pelagic to a depth of about
200 m. Most chum salmon spawn in small streams within a few miles of the shore, or within the
intertidal zone, but some travel great distances up large rivers. Eggs are laid in stream gravels.
After hatching, salmon fry move downstream to the open ocean.
3.1.17 Sockeye Salmon
The EFH for sockeye salmon within the project area includes estuarine juveniles, marine
juveniles, and marine immature and maturing adults (NMFS 2005). The estuarine EFH is the
mouth areas of streams from the mean high tide line to the salinity transition zone. All other
marine life stage EFH includes the entire project area because EFH for this species extends from
the mean higher tide line to the 200-nautical-mile limit of the U.S. EEZ. This species is pelagic to
a depth of about 200 m. Sockeye spawn in stream systems with lakes. After 1 to 3 years in fresh
water lakes, the fry move downstream to the open ocean.
3.1.18 Chinook Salmon
The EFH for Chinook salmon within the project area includes estuarine juveniles, marine
juveniles, and marine immature and maturing adults (NMFS 2005). The estuarine EFH is the
mouth areas of streams from the mean high tide line to the salinity transition zone. All other
marine life stage EFH includes the entire project area because EFH for this species extends from
the mean higher tide line to the 200-nautical-mile limit of the U.S. EEZ. This species is pelagic to
a depth of about 200 m. Chinook spawn in small and large streams, and the eggs are laid in
stream gravels. After hatching, salmon fry move downstream to the open ocean.
3.1.19 Coho Salmon
The EFH for coho salmon within the project area includes estuarine juveniles, marine juveniles,
and marine immature and maturing adults (NMFS 2005). The estuarine EFH is the mouth areas
of streams from the mean high tide line to the salinity transition zone. All other marine life stage
EFH includes the entire project area because EFH for this species extends from the mean higher
tide line to the 200-nautical-mile limit of the U.S. EEZ. This species is pelagic to a depth of about
200 m. Coho salmon spawn in small streams and the eggs are laid in stream gravels. After 1 to 3
years in fresh water ponds, lakes, and stream pools, the salmon fry move downstream to the open
ocean.
4.0 Effects of the Proposed Action on EFH
The direct and indirect effects of activities associated with the NPDES permit for the Cook Inlet
project area have been assessed in documents related to this EFH. The Biological Evaluation for
listed species in the project area for issuance of this NPDES permit addresses the effects of
various chemical discharges on marine organisms, and major portions of that study are
incorporated within this EFH. Another document, the Final Environmental Impact Statement for
the Cook Inlet Planning Area Oil and Gas Lease Sales 191 and 199 (MMS 2003), includes an
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
30
1/20/2006
-------
EFH that addresses the effects of permitted actions in the project area, including chemical
discharges in Cook Inlet as well as related activities such as seismic testing, associated boat
traffic, and potential oil spills. That document and the Fact Sheet for the reissuance of the general
permit for oil and gas exploration, development and production facilities in Cook Inlet were used
extensively in assessing potential effects on EFH in the project area.
The following sections address the effects on EFH in the project area under types of effects or
actions. Each section includes a description of the parameter, followed by an assessment of the
effect of that parameter on EFH.
4.1 Drilling Fluids and Cuttings
Drilling fluids are complex mixtures of clays and chemicals, and their potential impact on marine
organisms has been examined in several studies. Recent reviews of studies conducted in federal
Outer Continental Shelf (OCS) areas include Neff (1982), National Research Council (1983),
Petrazzuolo et al. (1985), and Parrish and Duke (1990). Drill cuttings are the waste rock particles
brought up from the well hole during exploratory drilling operations.
The permit restrictions for drilling fluids and cuttings are provided in Sections 2.3.1.1 and 2.3.1.2,
respectively. No discharge of drilling fluids or cuttings would be allowed for new development
and production facilities. Existing facilities would be allowed to discharge drilling fluids and
cuttings subject to technology-based restrictions that (1) prohibit the discharge of free oil; (2)
prohibit the discharge of diesel oil and set a minimum toxicity limit of 3 percent by volume; (3)
allow maximum concentrations of 3 mg/kg cadmium and 1 mg/kg mercury in stock barite; (4)
prohibit the discharge of nonaqueous-based drilling fluids, except those which adhere to drill
cuttings; and (5) prohibit the discharge of oil-based drilling fluids, inverse emulsion drilling
fluids, oil-contaminated drilling fluids, and drilling fluids to which mineral oil has been added.
MMS (2003) estimated that the completion of each exploration or delineation well would result in
the discharge of an estimated 140 tonnes (metric dry weight) of drilling fluids and 400 tonnes of
cuttings. The drilling of production and service wells from an existing platform is estimated to
require disposal of 70 tonnes of drilling mud and 500 tonnes of cuttings per well.
The Offshore Operators Committee (OOC) and Exxon Production Research Company have
developed a model (the OOC model) that has been used extensively in Alaskan waters to predict
the transport and deposition of drilling fluids. Comparison of model results with field
observations has shown that the model is capable of predicting many important aspects of drilling
mud discharge plume behavior. When released into the water column, the drilling mud separates
into an upper plume, which contains fine-grained solids, and a lower plume, which contains the
majority of solids. The OOC model does not predict the fate and transport of cuttings. These
materials are expected to be of coarser grain size than drilling fluids and would therefore settle
more rapidly to the seafloor. Model simulations of drilling mud discharges in Cook Inlet show
that both solids and dissolved components are diluted rapidly with distance from the point of
discharge. At 100 m (328 ft) from the point of discharge, the dilution factors ranged from 905 to
5,793 for discharges in water depths ranging from 40 m (131 ft) to 120 m (394 ft) (Tetra Tech
1993). Dilution factors for dissolved components ranged from 1,285 to 9,127 for discharges to
the same range of water depths (Tetra Tech 1993).
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
31
1/20/2006
-------
4.1.1 Turbidity
Drilling fluids and cuttings discharged into Cook Inlet would increase the turbidity of the water
column and the rate of accumulation of particulate matter on the seafloor in the vicinity of the
exploratory drilling unit or existing platform. Most of the solids in the discharge (more than 90
percent) are predicted to descend rapidly (within 1 hour) to the seafloor as part of the lower mud
plume (MMS 2003). Dye studies and modeling of the discharge plume associated with the
drilling of a well in lower Cook Inlet during 1977, at a site between Kachemak and Kamishak
bays, indicated rapid dilution to a minimum value of 10,000:1 within 100 m of the drilling vessel
(MMS 2003). Following dilution, the increase in turbidity was estimated to be about 8 ppm;
background turbidity in the area ranged from 2 to 20 ppm.
The finer-grained material that does not rapidly settle might be kept in suspension by turbulence
or settle to the seafloor farther away from the point of discharge. These particulates can cause an
increase in turbidity. In general, however, the concentration of suspended particulate matter in
the water column is expected to be reduced to levels comparable to naturally occurring suspended
particulate matter (1 to 50 ppm) within about 100 to 200 meters of the discharge site (MMS
2003).
Only part of the solids in the drilling fluids and cuttings discharged into Cook Inlet might
accumulate near the discharge. The bottom currents in lower Cook Inlet are strong enough to
prevent the deposition of sand-size and smaller particles. The general southwest flow of Cook
Inlet currents indicates that discharged substances that are dissolved or remain in suspension
generally would be transported out of Cook Inlet and into the Gulf of Alaska within about 10
months (MMS 2003).
4.1.2 Chemical Toxicity
A variety of Alaskan marine organisms have been exposed to drilling mud in laboratory or field
experiments. Most of these studies have addressed short-term acute1 effects in a relative or
"screening" sense, with little effort directed at separating chemical from physical causes. A few
studies have looked at chronic sublethal effects and bioaccumulation of heavy metals from
drilling mud. Chronic is used to refer to a stimulus that lingers or continues for a relatively long
period, often 1/10 of the life span of an organism or more (USEPA 1990). Results are typically
reported as LC50s (concentrations lethal to 50 percent of the test organisms) or EC50s (median
effective concentrations, or the concentrations at which a designated effect is displayed by 50
percent of the test organisms). Because drilling mud discharges are episodic and typically only a
few hours in duration (Jones and Stokes 1990), organisms that live in the water column are not
likely to have long-term exposures to drilling fluids and risks to these organisms are best assessed
using acute toxicity data. Benthic organisms, particularly sessile species, are likely to be exposed
for longer periods; risks to these organisms are best assessed with chronic toxicity data.
As noted above, the effects of drilling fluids on biological organisms are most commonly
assessed by conducting acute laboratory toxicity tests. Results obtained in most studies to date
have not shown drilling mud to have a high degree of acute toxicity (USEPA 1988a; 1988b). For
example, Parrish and Duke (1990) reviewed research findings on the toxicity of drilling fluids
used in the Gulf of Mexico and concluded that available models suggest that discharges made
1 In aquatic toxicity tests, a response measuring lethality observed in 96 hours or less is typically
considered acute (USEPA 1990).
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
32
1/20/2006
-------
from oil platforms in open, well-mixed waters deeper than about 20 m (66 ft) would result in no
detectable acute effects, except within a few hundred meters of the point of discharge.
The general NPDES permit has incorporated a standard acute toxicity test using the amphipod
Leptocheirus plumulosus. Under the permit, discharge of drilling fluids with an LC50 of less than
30,000 ppm SPP (suspended particulate phase) is prohibited. The classification of relative
toxicity of chemicals to marine organisms proposed by the IMCO/FAO/UNESCO/WHO,
reported by Neff (1991), provides a means of qualitatively assessing relative toxicities (MMS
2003). Concentrations less than 1 ppm are classified as very toxic; 1 to 100 ppm, toxic; 100 to
1,000 ppm, moderately toxic; 1,000 to 10,000 ppm, slightly toxic; and greater than 10,000 ppm,
practically nontoxic. The NPDES permit would allow discharge of drilling fluids only from
exploratory wells and existing platform facilities, and the muds discharged from such facilities
would be considered "practically nontoxic." Drilling fluid toxicity data compiled by USEPA
(1993) from Alaskan exploratory and production wells indicate that the muds used in all current
and recent operations are acutely toxic to only a slight degree to Mysidopsis bahia. LC50s for the
91 valid toxicity test data points ranged from 2,704 to 1,000,000 ppm SPP with a mean of
540,800 ppm. Only 7 of the 91 tests had LC50s less than the 30,000-ppm limit.
Although the discharge of nonaqueous-based drilling fluids would be prohibited under the
proposed permit (see Section 2.3.1.1), it is proposed that the discharge of drill cuttings that are
generated using nonaqueous-based drilling fluids be authorized by the reissued permit. These
new discharges are proposed to be authorized only in the territorial seas and federal waters in
Cook Inlet. Nonaqueous-based drilling fluids, also known as synthetic-based muds (SBM), are a
pollution prevention technology because the drilling fluids are not disposed of through bulk
discharge at the end of drilling. Instead, they are brought back to shore and refurbished so that
they can be reused. Drilling with SBMs allows operators to drill a slimmer well and causes less
erosion of the well during drilling than drilling using water-based drilling fluids. Therefore,
relative to drilling with water-based drilling fluids, the volume of drill cuttings discharged is
reduced.
Unlike the water-based drilling fluids, the SBMs are not water-soluble and do not disperse in the
water column, as do water-based drilling fluids, but rather sink to the bottom with little dispersion
(USEPA 2000). Since 1984 EPA has used the suspended particulate phase toxicity test, an
aqueous-phase toxicity test, to evaluate the toxicity of drilling fluids, including SBMs. By using
the SPP toxicity test, SBMs have routinely been found to have low toxicity; however, an inter-
laboratory variability study indicated that SPP toxicity results are highly variable when applied to
SBMs (USEPA 2000). In general, benthic test organisms appear to be more sensitive to the
SBMs than are water-column organisms. The ranking for SBM toxicity from least toxic to most
toxic is esters
-------
4.1.3 Effects on EFH
The discharge of drilling fluids and cuttings is not likely to cause acute effects on EFH habitat
organisms, including prey resources such as those living in or on the substrate (MMS 2003).
Minimal effects would result because the discharge would meet water quality standards outside
the mixing zone, rapid dilution would occur in the mixing zones (see section on mixing zones),
and drilling would be timed relative to important life stages of fish and fish prey. Within the
mixing zones some sublethal effects, and possibly lethal effects at the discharge point (within 1 to
2 meters), might occur. Adverse effects within the mixing zone would be primarily from physical
factors such as burial (MMS 2003). Some temporary displacement of organisms (e.g., fish,
shellfish) might occur within the mixing zones, which could be reoccupied following cessation of
discharge. Overall adverse effects on EFH from the discharge of drilling fluids and cuttings,
relative to total EFH in the project area and the few areas with discharge (six sites, Table 2-2),
would be negligible.
4.2 Produced Water
The term produced water refers to the water brought up from the oil-bearing, subsurface geologic
formations during the extraction of oil and gas. It can include formation water, injection water,
and any chemicals added to the well hole or added during the oil/water separation process
(USEPA 1996).
All the existing development and production facilities in Cook Inlet are in coastal waters in the
area north of a line extending across Cook Inlet at the southern edge of Kalgin Island (Figure 1-
1). Federal guidelines for the coastal subcategory of the oil and gas extraction point source
category allow the discharge of produced waters to Cook Inlet coastal waters provided these
discharges meet a monthly average oil and grease limit of 29 mg/L and a daily maximum oil and
grease limit of 42 mg/L. These limits are contained in the expired general permit for produced
water and would be included without modification, for existing facilities only, in the reissued
general permit. Produced water would not be authorized for discharge in either coastal or
offshore waters for new sources.
Table 4-1 shows data compiled by EPA (USEPA 1996) from several sampling programs to
characterize the composition of produced water in Cook Inlet.
Table 4-1. Chemical Analyses of Produced Water Samples: Source Samples from
Shelikof Strait Sediment Quality Study and Produced Water Samples from the
Trading Bay Production Facility Outfall
Parameters
Net weight
(parts per million wet weight)
Total PAHs
0.380
Total PHCs
6.20
Silver
<0.0001
Arsenic
0.0024
Barium
20.7
Beryllium
<0.0001
Cadmium
0.000
Chromium
0.0032
Copper
0.0060
Iron
0.76
Mercury
<0.0005
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
34
1/20/2006
-------
Manganese
1.71
Nickel
0.0075
Lead
0.0001
Antimony
0.0001
Selenium
<0.0002
Tin
0.008
Thallium
0.00025
Vanadium
0.067
Zinc
0.0030
Notes:
< = less than
PAHs = polycyclic aromatic hydrocarbons
PHCs = petroleum hydrocarbons
4.2.1 Effects on EFH
The discharge of processed water might have slight adverse effects on EFH in very limited
regions of the project area. Although some processed water might have toxic characteristics to
marine biota, several factors would greatly limit its effects on EFH. First, new development in
the region of outer Cook Inlet, where the greatest number of EFH individual species habitats
occurs in the project area, would have processed water injected back to the underlying rock or
taken to shore for treatment. In addition, discharged processed water has very low toxicity to
marine organisms. Overall bioassay studies of the processed water have rated it "slightly toxic"
to "practically nontoxic" (MMS 2003). Therefore, much of the water would have minimal direct
toxic affects on EFH species or their habitat. Although a variety of components in the discharge
water could affect toxicity, most currently meet state water quality standards (Department of
Environmental Conservation 2003a, 2003b) (Table 4-1). The primary exception to meeting state
water quality standards (Department of Environmental Conservation 2003a, 2003b) in the
discharge water would be total hydrocarbons in the water column (15 parts per billion) and total
aromatic hydrocarbons in the water column (10 parts per billion), which would likely be
exceeded at the point of discharge (MMS 2003)(Table 4-1). EPA does not include criteria for
these compounds directly; however, EPA's draft general permit does include criteria for total oil
and grease and individual hydrocarbons. Dilution (well over 1,000:1 at most sites, Table 2-3) in
the allowed mixing zone for existing facilities would result in the state standard's being met for
the hydrocarbon parameters beyond the mixing zone. However, within the mixing zones
established in the reissued general permit and ADEC's 401 certification, acute and chronic
criteria would be exceeded. This would result in very slight adverse effects on EFH in the inner
portion of Cook Inlet where processed water discharge would be allowed.
4.3 Mixing Zones and Water Quality Standards
The general NPDES permit would authorize mixing zones as described in Section 2.3.2.1 and
would require that numeric criteria for chronic aquatic life be met at the boundary of the mixing
zone. To evaluate potential affects on EFH species, two issues need to be addressed: (1) whether
adverse effects would occur as a result of exposure to contaminant concentrations above water
quality standards within the mixing zone boundaries and (2) whether the water quality standards
are protective of EFH species.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
35
1/20/2006
-------
4.3.1 Mixing Zones
States and EPA establish mixing zones to minimize the portion of a waterbody in which water
quality criteria are exceeded. Alaska's Water Quality Standards require that when mixing zones
are authorized, they be as small as practicable. Numeric criteria for chronic aquatic life and
human health protection may be exceeded within the mixing zone, but they must be met at its
boundary. The standards (18 AAC 70.255) also require that there be no lethality to organisms
passing through mixing zones and that acute aquatic life criteria be met at the boundary of a
smaller zone of initial dilution established within the mixing zone.
Alaska's Water Quality Standards do not allow ADEC to authorize mixing zones if the pollutants
could bioaccumulate or persist in concentrations above natural levels in the environment, or if
they can be expected to cause a carcinogenic or other human health risk. ADEC is required to
take into account the potential exposure pathways in determining whether to authorize mixing
zones. ADEC has determined that the discharges authorized by the previous permit are not likely
to persist in the environment and therefore has authorized mixing zones. The state has previously
authorized mixing zones ranging in size from 363 to 1,420 meters from the discharge point for
Cook Inlet oil and gas facilities.
The size of the mixing zone that is required to meet water quality standards depends on the
concentration of the parameter in the discharge water, how the water is discharged to receiving
waters, and the characteristics of the receiving water. ADEC and EPA used the CORMIX
dispersion model to calculate the dilution that the effluent plume receives and determine how far
from the point of discharge water quality standards would be met. The radii of the mixing zones
are shown in Table 2-2. The largest mixing zones would be necessary to meet water quality
standard for total aromatic hydrocarbons (TAH)/total aqueous hydrocarbons (TAqH); the
proposed mixing zones for existing facilities range from 36 to 3,016 meters (Table 2-2). Mixing
zones for whole effluent toxicity, chronic metals, and acute metals would range from 31 to 1,742
m, 9 to 262 m, and <1 to 239 m, respectively (Table 2-2).
Most of the EFH species evaluated in the EFH are mobile organisms with extended geographic
ranges that include areas outside the project area for the general NPDES permit. These organisms
are unlikely to spend extended periods within the mixing zone boundaries. However,
weathervane scallop and some prey resources, such as benthic and epibenthic prey organisms, are
less mobile and might spend extended periods in some mixing zones.
4.3.2 Water Quality Standards
Because aquatic ecosystems can tolerate some stress and occasional adverse effects, EPA has not
deemed it necessary to protect all species at all times and in all places (USEPA 1985). EPA
guidance suggests that if acceptable data are available for a large number of appropriate taxa from
a variety of taxonomic and functional groups, a reasonable level of protection would be provided
if all but a small fraction (5 percent) of the taxa is protected (USEPA 1985). Thus, it is
conceivable that an individual Endangerd Species Act (ESA)-listed species might not be
protected by a water quality standard.
In June 2003 Alaska submitted revisions to its numeric water quality criteria for toxic and other
deleterious organic and inorganic substances (18 AAC 70.020(b)) to the EPA for approval in
accordance with Section 303(c)(2) of the Clean Water Act. The effect of the federal action of
approving these criteria, which included acute and chronic marine criteria for the metals found in
discharges from oil and gas production facilities (see Table 4-1), on all threatened and
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
36
1/20/2006
-------
endangered species found in Alaskan waters was evaluated in a biological evaluation (BE)
completed in January 2004 (Tetra Tech 2004). That statewide biological evaluation determined
that the water quality standards for toxic and other deleterious organic and inorganic substances
might affect, but were not likely to adversely affect, all the threatened and endangered species
considered in the BE.
4.3.3 Effects on EFH
Several factors indicate that mixing zones and applicable state water quality standards, as they
relate to the proposed project, would not have more than negligible adverse effects on EFH in the
project area. The criteria used for mixing zones indicate that other than some organism near the
outfall, no others would be adversely affected. The criteria for mixing zones, such as the
requirement for no bioaccumulation of discharged parameters, and ensuring no lethality for
organisms passing through the zones, would help ensure no marked adverse effects on EFH or
their major prey resources. Also, as noted above, ADEC has determined that past permits have
not resulted in persistence of toxic substances in the environment. In addition, the state has
recently revised its water quality standards to help ensure proper protection of marine aquatic
resources. A BE of the effectiveness of these standards to protect endangered or threatened
species in marine waters included salmon species. The BE concluded that implementations of the
water quality standards would not adversely affect any listed species (Tetra Tech 2004). Salmon
assessed include EFH species that would be present in much of the project area. Water quality
protection adequate for an ESA fish species is a good indicator of likely risk to other EFH
species. Also, water quality standards undergo rigorous review to ensure that they protect aquatic
organisms. These standards would be met at the edge of the mixing zone. The protections
suggest that EFH species would be completely protected in the project area outside the mixing
zones. Overall, some sublethal effects on EFH in the mixing zone, as well as indirect effect on
EFH species from adverse effects on epibenthic and benthic prey species in the mixing zone,
would occur. However, the relatively small area affected by the few discharge and exploration
sites would have inconsequential effects on EFH in the project area.
4.4 Seismic Surveys and Boat Traffic
Seismic surveys and boat traffic both emit sound waves that might have adverse effects on EFH
species. The types of adverse effects would vary from adverse physical effects on hearing organs
to mild behavioral changes. The particular effects depend on the type, magnitude, frequency and
location relative to the EFH species. MMS (2003) developed a detailed description of the types
of effects and overall effects on EFH in most of the project area for activities associated with
facilities in Cook Inlet. The following is a summary of types and magnitude of effects on EFH in
the project based primarily on the MMS 2003 document.
Seismic survey might cover a substantial area of Cook Inlet (46 square kilometers, or 18 square
miles) and would occur during brief periods (typically 2 to 10 days annually) in late summer and
fall for exploration over a 5-year period. Only one survey is expected during development and
production. Nearly all EFH species discussed in Section 3, along with other important prey
species such as Pacific herring, Pacific sand lance, capelin, and eulachon, could be subject to
noise emissions from seismic surveys. The spawning areas of some of the important prey species
such as Pacific herring in Kamishak Bay would be unlikely to be affected because surveys would
not occur there. Demersal fish and those near bottom areas would be the most likely to be
subjected to increased noise levels from seismic surveys. It has been reported that fish can detect
seismic air guns like those to be used at nearly 2.7 to 63 kilometers (1.6 to 39 miles) depending
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
37
1/20/2006
-------
on water depth (MMS 2003). Also, some pelagic and nomadic fish have shown movement up to
33 kilometers from the seismic testing central area.
The direct effect on fish in close proximity to a seismic test is unclear (MMS 2003). However,
damage to hearing organs has been documented in very close proximity to the air guns (a few to
20 meters) (MMS 2003). Gradually increasing the sound at the test site, however, could allow
mobile fish to move away from the test area, thereby reducing the potential for adverse effects.
Some of the best information on fish response to noise is from their reaction to boats. Often,
many fish species would dive away from the surface noise of the boat. Herring in particular have
been well studied. Pacific herring have often been noted to dive as a school away from passing
boats, although they often return shortly (within seconds or minutes) to their original depth after
boats pass. Typically, documented herring response to noise from boats has been much less than
1 kilometer (Misund et al. 1996; Valbo et al. 2002).
Unlike seismic surveys, project-associated boat traffic would affect only fish behavior and on a
short-term basis. It has been estimated that the boat traffic for new exploration would be about
160 to 360 trips per year for 5 years. Each trip would be about 10 hours. This is a small number
compared to other boat traffic in Cook Inlet, but it is comparable to commercial fishing boat
activity in the region. As noted above, this type of activity would result in short-term (minutes)
displacement of fish from boat passage and would be limited to fish closer to the surface, having
less effect on demersal species.
The overall effect on EFH from seismic surveys and boat traffic would be mostly short-term and
temporary. For seismic survey, because testing would be brief each year (2 to 10 days), over a
limited area at any given time the major effect would be short-term displacement of fish
responding to the sound. Most fish affected by seismic surveys would rapidly return to their
previous location after completion of the tests. A limited number of fish might incur hearing
damage that could affect their behavior and viability, but that number would be small. For boat
traffic, fish would be displaced briefly (for a few minutes) during boat passage. Adverse effects
on EFH from these noise-related activities would be very low and short-term.
4.5 Offshore Pipeline Construction and Operation
Prey and prey and fish habitat could be disrupted by the construction of pipelines primarily from
increased short-term turbidity and burial of habitat from the pipeline (MMS 2003). Pipeline
construction could consist of about 50 kilometers (30 miles). Past observations indicate an
increased turbidity plume along the pipeline excavation of a few hundred to 1,000 meters.
Although this turbidity would be near background in the natural high-turbidity environment of
Cook Inlet, some burial of local benthic organisms (e.g., attached or surface organisms, including
some larval fish) would occur along this route. The elevated plume would be short-term (2 to 3
hours), so overall effects would very localized and short term.
Some temporary loss of habitat and habitat modification would occur over an 18-acre area,
assuming a 10-foot-wide disturbed area for pipeline construction in the shallow inner shelf habitat
(0 to 50 meters). Additional habitat would be affected in the continental shelf (1 to 200 meters
deep). In all these areas there would be initial loss of organisms and modification of habitat. It is
expected, however, that lower food chain organisms (diatoms, polychaetes) would recolonize
such areas in 80 days after construction. Disturbed fish habitat would likely be recolonized
within 3 years (MMS 2003). In the short term, however, many of the demersal fish species and
potential egg and larvae areas would be displaced.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
38
1/20/2006
-------
Overall the adverse effects on EFH from construction of the pipeline would be slight to negligible
due to the relatively small size of the affected population, the abundance of similar habitat in the
region, and the short recolonization period for many species.
4.6 Accidental Oil Spills
Although the granting of the NPDES permit renewal does not authorize oil spills, issuance of the
permit allows for associated activities that have the potential to result in oil spills. The MMS
(2003) developed a detailed analysis of the potential for oil spills and effects on EFH in the
project area. The following discussion is primarily summarized from that document.
MMS (2003) characterized the types of oil spills that could affect EFH into two categories-those
less than 1,000 barrels and those greater than or equal to 1,000 barrels. The smaller spills (less
than 1,000 barrels) can have some adverse, primarily short-term effects with some compounding,
primarily very local effects unless occurring frequently; the larger spills could have long-term
large effects that could radiate through the ecosystem.
Small spills (less than 1,000 barrels) are not expected to affect the overall quality of Cook Inlet.
However, oil is toxic to many species life stages at low concentrations. It is likely that
individuals (e.g., prey organisms, eggs, larvae) encountering oil, even at low concentrations could
suffer deformities or mortality. This is especially true for some of the early life stages of some of
important prey species (herring) and important EFH species such as intertidal-spawning pink
salmon eggs (MMS 2003). Effects in intertidal areas could persist for generations and might have
multiple effects by affecting more than one life stage. Other EFH species and life stages in the
Cook Inlet area could be similarly affected. The overall effects of individual small spills on EFH
would be small, however, because of the size of the area affected.
Large oil spills would be likely to have a worse effect on EFH than smaller spills. MMS (2003)
modeled the probability of large spills. MMS estimated the probability of a spill of 1,500 to
4,600 barrels from project-related activities over the life of the project at 19 percent. This spill
range is similar to actual spills that occurred in Glacier Bay (3,100 barrels), while it is only about
2 percent of the large Exxon Valdez spill (257,000 barrels) in Prince William Sound.
For comparison, initial impacts from the Glacier Bay spill were locally significant, but within a
year most measurable parameters had returned to pre-spill conditions. In the Glacier Bay spill oil
dissipated in less than a week, a total of % mile of beach was oiled, and .63,000 sockeye salmon
were discarded because of oil contamination. Within a year, only a few tar balls were visible, and
no wetland or spawning beaches appeared to be affected.
Intertidal beach and bay habitats (primarily in Cook Inlet) are most likely to suffer long-term
impacts if a major oil spill were to occur (MMS 2003). A large oil spill in the project area would
adversely affect fish, EFH, and fish prey from lethal and nonlethal effects. Organisms that rely
most heavily on these environments would be most affected. These include fish, such as Pacific
herring, that spawn in intertidal and shallow subtidal habitat because they are very sensitive to oil.
In addition, many eggs and larvae of other species are generally more sensitive to oil than adult
stages. These fish species life stages would be more easily affected because of their sensitivity
and their inability to avoid oil.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
39
1/20/2006
-------
In these habitats the effects, though locally severe, would be expected to affect cohorts of a
species within the Cook Inlet region but not affect the overall Gulf of Alaska region. The model
developed by MMS (2003) projects that beaches within Cook Inlet would have a 20 percent
chance of being oiled; the beaches most immediately outside Cook Inlet and larger bays within
the Inlet (Kamishak Bay) would have only a 2 percent chance of being oiled if a large spill were
to occur from project-related activities. If an oil spill originated in the outer portion of Cook
Inlet, the chance of oil reaching Kamishak Bay would increase to 18 percent (MMS 2003). In
intertidal areas, some of the species and life stages that might be most affected are Pacific herring
eggs, Pacific sand lance and capelin eggs and adults, yellowfin sole, pink salmon eggs, adult
squid, juvenile sablefish, walleye pollock larvae and adults, Pacific cod larvae and adults,
eulachon juveniles, and Greenland turbo eggs (MMS 2003). Some of these species are primary
prey species (e.g. herring, walleye pollock) for other EFH species, which could reduce production
at least in the short term. Based on results from Prince William Sound, however, very large oil
spills could influence the intertidal area for over a decade.
Lower Cook Inlet, including the open water portion, is considered an estuary. Large oil spills
could affect the open water and demersal habitat of Cook Inlet, as well as the beaches. After the
Prince William Sound spill, some of the demersal fish showed stress hormones even at depths of
60 meters (MMS 2003). The oil spill model projects that some estuarine areas in Cook Inlet
(Kamishak Bay) and outside Cook Inlet (west Kodiak Island) have a greater than 33 percent
chance of being affected by oil. Many species and life stages use these habitat areas, particularly
the outer Cook Inlet areas, which have been designated EFH for many species (see Section 3).
Some of the more common species are herring, rock sole, salmon eulachon, squid, sable fish and
Pacific cod, and weathervane scallop. Adults would be able to avoid oil, but juveniles and larvae
stages would be less able to avoid a spill and would be more at risk. Salmon smolts arriving in
the estuarine environment might also be susceptible because they are small and often stay near
the surface, where they would be more likely to encounter oil.
Any oil reaching marine waters outside Cook Inlet and nearby waters would have weathered at
least 10 days and would be much less toxic (MMS 2003). This would greatly reduce the overall
impact on EFH in these regions from oil spills. Marine waters seaward of Kodiak and Barren
Islands have less than a 0.5 percent chance of being oiled even with a large spill. Although some
eddy effect might keep some organisms (e.g., walleye pollock) in contact with oil for greater
periods, the chances of this occurring are low. Although some contract with oil for demersal fish
could occur, the effect should be slight to none because oil levels would likely be less than the
state water quality standard of 15 parts per billion.
Overall adverse effects on EFH from oil spills would likely be low to moderate in magnitude and
possibly of long duration. The risk of a large spill (1,500 to 4,600 barrels) is estimated to be 19
percent. A spill of that size could affect primarily beach and intertidal habitat because it would
persist in those areas, possibly for more than a decade. However, the spill would affect a small
portion of the total habitat and likely would be limited to subpopulation-level effects. Effects on
other marine habitat (marine, estuarine) would be less because of limited effects on these areas
and rapid recovery (months, few years).
4.7 Effect on Prey Resources
Prey resources for EFH species include a wide variety of items, such as zooplankton, euphausids,
and various forage fish species. As noted above, the primary risk to EFH from the proposed
action is from the oil spills related to development and operation of the project (MMS 2003). The
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
40
1/20/2006
-------
MMS (2003) document provided a summary of the types of effects that might occur on prey
resources from all project actions in the project vicinity, with emphasis on a National Resource
Council analysis on the effects of oil spills in the ocean environment (National Research Council
2002, as cited in MMS 2003). This information was used to provide the summary of effects on
prey resources from issuance of the NPDES permit.
Acute oil spills can affect nearshore habitat such as marshes and can affect overall production and
survival of organisms in both direct and indirect ways. Examples include reduction in attached
algae, which in turn reduces limpet and other invertebrates that rely on this resource. This type of
action could move through the food web, ultimately affecting EFH organisms.
Organisms can be exposed to hydrocarbon levels that are several orders of magnitude less than
direct acute levels but still could affect feeding, growth rates, development rate, energetics, and
other factors. Some low concentration of specific types of hydrocarbons (e.g., PAH) have been
found to affect certain life stages of important forage fish (such as Pacific herring) at levels less
than 1 part per billion (Carls et al. 1999). Marine zooplankton and euphausids might also be
affected by toxicity from hydrocarbon concentrations. Zooplankton and euphausids (up to 70
percent of the walleye pollock diet) are important components of food to many of the EFH
species, especially during early life stages.
Forage fish ultimately are the major prey for many of the EFH species. This diverse group of fish
includes Pacific herring, Pacific sand lance, lantern fish deep-sea smelt, sand fish, gunnel, and
many others. In addition, some life stages of some EFH fish, particularly walleye pollock as also
major forage fish resources, with walleye pollock accounting for up to 80 percent forage fish prey
in the Gulf of Alaska for some groundfish species. For Pacific herring, direct effects from oil
spills can be marked if spawning success or early life stage survival is affected, as has been noted
in Prince William Sound from the Exxon Valdez oil spill. Also, pollock juveniles are associated
with eddies, which tend to retain oil. Therefore, there is the potential for oil spills to have both
direct effects on these important forage fish and indirect effects on the predators that rely on
them.
As noted in earlier discussions, project-related actions other than oil spills would have local
adverse effects on prey resources. These effects, however, would be short-term and of small
magnitude. Such actions might include pipeline construction, drilling discharges within the
mixing zone, and seismic testing and boat operations that cause noise.
Overall, project-related actions might have adverse effects on prey resources for EFH species.
These adverse effects would be related primarily to large or frequently occurring oil spills. Oil
spills have the potential to adversely affect prey resources, including forage fish resources and
ultimately EFH, by affecting EFH species' food supply. The magnitude is hard to predict, but if
spills were large or frequent and occurred at critical times or locations, they could have marked
adverse effects because they could affect the food chain, ultimately having population-level
effects. If spills were less severe and were small, they would not be expected to have population-
level effects. Other project-related actions would also have adverse effects on prey resources but
primarily at local levels. They would be short-term and of minor consequence.
5.0 Proposed Mitigation
The reauthorized NPDES permit would include several restrictions. The restrictions on regions
of discharge (Section 2.1.2) would eliminate effects on critical areas. These permit requirements
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
41
1/20/2006
-------
(see Section 2.3) include detailed restrictions on the different types of discharges under this
permit. Part of the process includes detailed monitoring (Section 2.3.3) that would ensure that the
characteristics of the permitted discharge would be met. In addition, new study requirements
(Section 2.3.3.8) would be used to help understand the effects of large-volume discharges to the
Cook Inlet marine environment. EPA and ADEC would use this information to determine
whether any future changes are needed to the permit conditions to meet Alaska's Water Quality
Standards.
6.0 Action Agency's View Regarding Effects of Proposed Actions on EFH
Other than effects from potential oil spills, overall adverse effects on EFH in Cook Inlet and
vicinity would be low and primarily short-term because of the limited magnitude and extent of
the effects. Adverse effects from the discharge of drilling fluids and cuttings would be very
limited in distribution and would be negligible. Processed water discharge would have slight
adverse effects, but only at limited areas within inner Cook Inlet. The water quality standards
administered at the edge of mixing zones would protect most organisms and EFH habitat; overall
effects on EFH would be inconsequential because of the small area directly affected. Seismic
surveys and boat traffic would cause very low adverse effects, primarily from short-term
displacement of fish, but a very small number of fish could be directly harmed. Pipeline
construction would disrupt habitat and initially bury prey and other resources, but rapid
recolonization and the limited area directly affected by construction would render the effects
negligible. Prey resources in general would suffer minor short-term adverse effects from all
project actions unless substantial oil spills were to occur. Although the chances of substantial oil
spills are small (estimated at less than 20 percent) they could have low to moderate adverse
effects on local regions of the project area and possibly effects of long-term duration. The
mitigative measures noted, including restrictions on the location of discharge, quality and
treatment of discharge, proper construction methods and timing of activities, and discharge
monitoring and testing, would aid in reducing the risk of adverse effects from project-related
actions.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
42
1/20/2006
-------
7.0 Literature Cited
ADEC (Alaska Department of Environmental Conservation). 2003a. Alaska water quality
manual for toxic and other deleterious organic and inorganic substances, as amended
through May 15, 2003. Alaska Department of Environmental Conservation, Juneau,
Alaska.
ADEC (Alaska Department of Environmental Conservation). 2003b. 18 AAC 70. Water quality
standards, as amended through June 26, 2003. Alaska Department of Environmental
Conservation, Juneau, Alaska.
Carls, M.G., S.D. Rice, and J.E. Hose. 1999. Sensitivity of fish embryos to weathered crude oil:
Part I. Low-level exposure during incubation causes malformations, genetic damage, and
mortality in Pacific herring (Clupea pallasi). Environmental Toxicology and Chemistry.
18:481-493.
Jones and Stokes (1990). (Cited in BE but not referenced there)
Misund, O.A., J.T. Ovredal, and M.T. Hafsteinsson. 1996. Reactions of herring schools to the
sound field of a survey vessel. Aquatic Living Resources 9:5-11.
MMS (Minerals Management Service). 2003. Cook Inlet Planning Area, Oil and Gas Lease Sales
191 and 199: Final Environmental Impact Statement. OCS EIS/EA MMS 94-0066. U.S.
Department of the Interior, Minerals Management Service, Alaska Outer Continental
Shelf, Anchorage, AK.
NMFS (National Marine Fisheries Service). 2005. Final Environmental Impact Statement for
Essential Fish Habitat Identification and Conservation in Alaska. U.S Department of
Commerce, National Oceanic and Atmospheric Administration, National Marine
Fisheries Service, Alaska Region, Juneau, AK. April.
National Research Council. 1983. Drilling Fluids and Cuttings in the Marine Environment.
Marine Board, panel on fates and effects of drilling fluids and cuttings in the marine
environment. National Academy Press, Washington, DC.
Neff, J.M. 1982. Fate and Biological Effects on Oil Well Drilling Fluids in the Marine
Environment: A Literature Review. EPA-600/3-82-064. U.S. Environmental Protection
Agency, Environmental Research Laboratory, Gulf Breeze, FL.
Neff, J.M. 1991 (cited in BE but not referenced there)
Osborne, J., and C. Leeder. 1989. Acute and chronic toxicity of base oil and cuttings from three
wells drilled in the Beaufort Sea. In Drilling Wastes, Proceedings of the 1988
International Conference on Drilling Wastes, Calgary, Alberta, Canada, ed. F.R.
Engelhardt, J.P. Ray, and A.H. Gilliam, pp. 481-494. Elsevier Science Publishers Ltd.,
London.
Parrish, P.R., and T.W. Duke. 1990. Effects of drilling fluids on marine organisms. In Oceanic
Processes In Marine Pollution, Volume 6, ed. D.J. Baumgartner and I.W. Duedall, pp.
207-217.
COOK INLET NPDES PERMIT
ESSENTIAL FISH HABITAT ASSESSMENT
43
1/20/2006
-------
Petrazzuolo, G., A.D. Michael, C.A. Menzie, H. Plugge, E.J. Zimmerman, R.G. Rolan, T.A.
Mores, L.A. Smith, W.K. Parland, and S.E. Roth. 1985. Assessment of Environmental
Fate of Effects of Discharges from Offshore Oil and Gas Operations. EPA 440/4-85/002.
Washington, DC.
Tetra Tech, Inc. 1993. Ocean Discharge Criteria Evaluation for Cook Inlet/Shelikof Strait Oil
and Gas Lease Sale 149. Prepared for U.S. Environmental Protection Agency, Region
10, by Tetra Tech, Inc., Redmond, WA.
Tetra Tech, Inc. 2004. Preliminary Draft Biological Evaluation of the Alaska Water Quality
Standards. Prepared for U.S. Environmental Protection Agency, Region 10, Seattle, WA
by Tetra Tech, Inc., Mountlake Terrace, WA.
USEPA (U.S. Environmental Protection Agency). 1985. Guidelines for Deriving Numerical
National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses.
U.S. Environmental Protection Agency, Office of Research and Development,
Environmental Research Laboratories, Duluth, MN.
USEPA (U.S. Environmental Protection Agency). 1988a. Final Ocean Discharge Criteria
Evaluation for Beaufort Sea OCS Oil and Gas Lease Offering 97. U.S. Environmental
Protection Agency, Region 10, Seattle, WA.
USEPA (U.S. Environmental Protection Agency). 1988b. Final ocean discharge criteria
evaluation for Chukchi Sea OCS oil and gas lease offering 109. U.S. Environmental
Protection Agency, Region 10, Seattle, WA.
USEPA (U.S. Environmental Protection Agency). 1996. Development Document for Final
Effluent Limitations Guidelines and Standards for the Coastal Subcategory of the Oil and
Gas Extraction Point Source Category. EPA-821-R-96-023. U.S. Environmental
Protection Agency, Region 10, Seattle, WA.
USEPA (U.S. Environmental Protection Agency). 2000. Environmental Assessment of Final
Effluent Limitations Guidelines and Standards for Synthetic-based Drilling Fluids and
Other Nonaqueous Drilling Fluids in the Oil and Gas Extraction Point Source Category.
EPA-812-B00-014. Office of Water, Washington, DC.
Valbo, R., K. Olsen, and I. Huse. 2002. The effect of vessel avoidance of wintering Norwegian
spring spawning herring. Fisheries Research 58: 59-77.
COOK INLET NPDES PERMIT 44 1/20/2006
ESSENTIAL FISH HABITAT ASSESSMENT
------- |