BOEM offshore waters development plan open for comment

Issues on the record, awaiting the decision

• PendingThe worst-case discharge is 62,260 barrels per day for 100 days, totaling 6,226,000 barrels.

  The worst-case discharge is 62,260 barrels per day for 100 days, totaling 6,226,000 barrels. The plan states no oil spill trajectory modeling report was prepared specifically for this EP, relying instead on the generic BOEM OSRAM model. Section 8.6 states 'Modeling reports are not required for the activities proposed in this plan,' yet Section 8.4 shows this well's WCD is meaningfully different from the Regional OSRP benchmark (62,260 bbl/day vs. 432,298 bbl/day, different API gravity, different location). BOEM should require a site-specific spill trajectory model for this well rather than allowing reliance on the blanket regional model, and should explain how the generic OSRAM output adequately captures the risk profile of a 6.2-million-barrel worst-case scenario at this specific location.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 3 (Attachment 3-D, the shallow hazards assessment) identifies a Moderate Shallow Water Flow Risk and a Slight Risk of Gas in Unit F from 3,336 to 4,015 feet below seafloor, explicitly notes th

  Section 3 (Attachment 3-D, the shallow hazards assessment) identifies a Moderate Shallow Water Flow Risk and a Slight Risk of Gas in Unit F from 3,336 to 4,015 feet below seafloor, explicitly notes the nearest offset wells are 'not considered a direct analog to the conditions interpreted at the proposed well location,' and advises Drilling Caution if full well control is not established by that level. Despite this site-specific elevated risk, Section 1.6 states Walter proposes no additional safety or pollution prevention measures beyond those required by 30 CFR 250. BOEM should require the operator to explain how standard regulatory requirements alone are sufficient when the plan's own geohazard consultant has identified conditions with no valid analog and elevated blowout risk.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 9.1 states there are no environmental monitoring systems currently in place or planned.

  Section 9.1 states there are no environmental monitoring systems currently in place or planned. Yet the plan's own shallow hazards assessment (Attachment 3-D) identifies moderate shallow water flow risk in two separate depth intervals and a seafloor fault that the wellbore will cross. An unmonitored blowout or well control event in this setting could go undetected until a surface expression occurs. BOEM should require the operator to justify the complete absence of any environmental monitoring, including seafloor monitoring or real-time downhole pressure monitoring with independent data feeds, given the documented geohazard risks at this location.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 2.7 and Attachment 2-A state that Walter does not have sufficient information to anticipate that the well would bridge over and has no empirical data on bridging.

  Section 2.7 and Attachment 2-A state that Walter does not have sufficient information to anticipate that the well would bridge over and has no empirical data on bridging. The WCD calculation therefore assumes 100 uninterrupted days of flow at 62,260 barrels per day, yielding 6,226,000 total barrels. Despite this, the blowout scenario discussion claims capping stack and cap-and-flow operations will work in parallel to the relief well, but provides no timeline or probability estimate for capping success. BOEM should require a quantitative analysis of subsea intervention timelines and their effect on the expected total discharge volume before approving this plan.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 5.8 states that Ewing Bank Block 962/966 has been determined to have a high potential for containing archaeological properties and that prehistoric archaeological properties may exist there.

  Section 5.8 states that Ewing Bank Block 962/966 has been determined to have a high potential for containing archaeological properties and that prehistoric archaeological properties may exist there. Attachment 3-D (shallow hazards) confirms a sonar contact 538 feet from the proposed well and notes that the archaeological report should be consulted for avoidance assignments. Yet Attachment 15-A, Section 11, states the proposed DP semisubmersible will cause 'only an insignificant amount of seafloor' disturbance and concludes no impacts are likely. The plan provides no site-specific analysis of how drilling conductor installation and any seafloor equipment placement will avoid the sonar contact or potential prehistoric sites. BOEM should require the operator to produce and make publicly available the archaeological survey report and demonstrate clearance from the sonar contact before approving operations.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe plan proposes to drill between 2026 and 2031, a six-year window during which the rig, specific BOP configuration, and detailed well design are all unknown.

  The plan proposes to drill between 2026 and 2031, a six-year window during which the rig, specific BOP configuration, and detailed well design are all unknown. Section 1.3 states BOP information and schematics will be included only as part of the Application for Permit to Drill, which is a future submission. The public therefore cannot evaluate the adequacy of well control equipment against the documented moderate shallow water flow and gas risks in Units F and G. BOEM should not approve this EP until the BOP specifications and well design are made available for public review alongside the geohazard findings already in the record.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 8.4 shows the EP WCD oil has an API gravity of 29 degrees, which is heavier than the 37-degree crude in the Regional OSRP benchmark scenario.

  Section 8.4 shows the EP WCD oil has an API gravity of 29 degrees, which is heavier than the 37-degree crude in the Regional OSRP benchmark scenario. The spill response discussion in Attachment 8-A assumes natural evaporation and dispersion of 13 percent within 24 hours and then relies on skimming systems designed and rated for lighter crudes. The plan does not analyze whether the contracted skimming equipment EDRC ratings, which total 149,223 barrels offshore, are valid for 29-degree API crude, which weathers and disperses more slowly and is harder to skim. BOEM should require the operator to demonstrate that the contracted OSRO equipment is rated and capable for the actual API gravity of oil that could be spilled at this location.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingSection 12.1 states that the drilling unit, vessels, and crew boats associated with the proposed operations will not transit the Rice's whale area, and Attachment 12-B shows the Rice's whale area is a

  Section 12.1 states that the drilling unit, vessels, and crew boats associated with the proposed operations will not transit the Rice's whale area, and Attachment 12-B shows the Rice's whale area is approximately 234 statute miles from the proposed well. However, the plan provides no vessel routing map or enforceable routing protocol specifying how vessels departing Port Fourchon or Houma will avoid the Rice's whale area across all years of the 2026-to-2031 operational window. With fewer than 100 Rice's whales remaining in the Gulf of America year-round, any vessel strike carries population-level significance. BOEM should require submission of a specific vessel routing plan with enforceable avoidance zones before approving this EP.

  A hole PLAN found in the agency’s own analysis, quote verified against the document