Alan
Spackman
<
alan.
spackman@
ia
To:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
ksatt@
Shell.
Com
dc.
org>
cc:
Jennifer
Chan/
DC/
USEPA/
US@
EPA,
John
Fox/
DC/
USEPA/
US@
EPA,
Timothy
Connor/
DC/
USEPA/
US@
EPA,
12/
22/
2003
09:
26
anne.
jones@
erg.
com,
George
Denning/
DC/
USEPA/
US@
EPA
AM
Subject:
RE:
small
entity
representatives
for
EPA
panel
Please
respond
to
alan.
spackman
Carey,

Sorry,
but
I
don't
have
any
additional
information
that
would
assist
you
in
your
SBA
activities.

I
am
aware
that
Axxis
has
two
inland
barge
rigs,
but
whether
they
have
other
assets
or
not,
I
don't
know.
I
also
don't
know
whether
their
rigs
use
seawater
for
cooling
water
or
not.

Best
wishes
for
the
Holidays.

______________________________________
Alan
Spackman
Director,
Offshore
Technical
&
Regulatory
Affairs
International
Association
of
Drilling
Contractors
P.
O.
Box
4287
Houston,
TX
77210
USA
Phone:
+
1
713
292
1945
Fax:
+
1
713
292
1946
E­
mail:
alan.
spackman@
iadc.
org
Physical
Address:
10370
Richmond
Avenue,
Suite
760
Houston,
TX
77042­
4141
USA
­­­­­
Original
Message­­­­­
From:
Johnston.
Carey@
epamail.
epa.
gov
[
mailto:
Johnston.
Carey@
epamail.
epa.
gov]
Sent:
Friday,
December
19,
2003
1:
10
PM
To:
alan.
spackman@
iadc.
org;
ksatt@
Shell.
Com
Cc:
Chan.
Jennifer@
epamail.
epa.
gov;
Fox.
John@
epamail.
epa.
gov;
Connor.
Timothy@
epamail.
epa.
gov;
anne.
jones@
erg.
com;
Denning.
George@
epamail.
epa.
gov
Subject:
small
entity
representatives
for
EPA
panel
Dear
Alan
and
Kent:

As
I
indicated
in
my
previous
e­
mail,
we
hope
IADC
and
OOC
(
and
others)
will
be
able
to
participate
in
our
small
business
outreach
activities,
formally
called
small
business
advocacy
review
(
SBAR).
SBREFA
(
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
Pub
Law
No.
104­
121)
requires
EPA
to
convene
a
small
business
advocacy
review
panel
prior
to
proposing
any
rule
that
will
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
The
SBA
size
thresholds
are
500
employees
(
of
the
parent
entity)
for
most
sectors,
and
5
million
annual
revenue
for
exploration
&
development
services
and
oilfield
services
(
see
http://
www.
sba.
gov/
regulations/
siccodes/
siccodes.
html).
Using
these
definitions
we
were
able
to
identify
the
following
companies
that
are
or
might
be
a
"
small
business."
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
MODU
owner
name
|
Affiliation
|
Employee
Size
|
Size
of
Company
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
Blake
Workover
&
|
presumed
privately
|
|
presumed
small
|
|
Drilling
|
held
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
BSI
Drilling
|
presumed
privately
|
|
presumed
small
|
|
|
held
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
Drillmar
|
64%
owned
by
Blue
|
11
|
small
|
|
|
Dolphin
Energy
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
Energy
Equipment
|
presumed
privately
|
|
presumed
small
|
|
Resources
|
held
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
Ensearch
Exploration
|
Became
sub
to
Newfield|
488
|
small
|
|
|
Exploration
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|
|
NR
Marine
|
presumed
privately
|
|
presumed
small
|
|
|
held
(
noted
to
be
out
|
|
|
|
|
of
business)
|
|
|
|­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­­­­­­­­­­­­­­­­­+­­­­­­

­­­­­­­­­­­­­­­­|

Additionally,
Alan
identified
the
following
two
companies
which
may
meet
SBA's
definition
of
a
"
small
business."

Axxis
Drilling
1015
N.
Cruse
Avenue
Broussard,
LA
70518
Coastal
Drilling
Company,
L.
L.
C.
311
Saratoga
Blvd
Corpus
Christi,
TX
78417­
3506
Please
let
me
know
if
the
two
above
companies
meet
the
SBA's
definition
of
a
"
small
business."
Additionally,
please
let
me
know
how
you
would
like
to
ask
these
companies
if
they
would
be
interested
in
participating
in
the
SBREFA
panel
(
which
runs
60
days).
Do
you
want
place
the
call
or
would
you
like
EPA
to
call
these
companies?
If
you
would
like
to
make
the
call
then
please
let
us
know
which
of
these
companies
are
interested
in
participating
in
the
SBREFA
panel.
Additionally,
please
send
us
the
contact
information
of
any
other
companies
that
are
interested
in
participating
in
the
SBREFA
panel
if
they
meet
SBA's
definition
of
a
"
small
business."
If
you
would
like
EPA
to
make
the
call
then
please
send
me
the
appropriate
company
contacts.
The
SBREFA
panel
will
likely
convene
next
February
or
March
2004.
When
SBREFA
panel
is
convened
we
will
have
materials
&
analyses
to
distribute.
This
will
be
another
opportunity
for
EPA
to
take
comment.
The
SBREFA
panel
consists
of
representatives
from
EPA,
SBA,
and
OMB.
Note
that
only
small
businesses
and
their
representatives
may
be
selected
by
the
panel
to
serve
as
"
small
entity
representatives".
However,
it
is
routine
for
organizations
representing
a
range
of
business
sizes
to
provide
comments.
All
of
this
activity
occurs
before
EPA
publishes
the
316(
b)
Phase
III
proposal.

Thank
you
again
for
your
continued
help.

Sincerely,

Carey
A.
Johnston,
P.
E.
U.
S.
EPA,
Office
of
Water
ph:
(
202)
566
1014
fx:
(
202)
566
1053
johnston.
carey@
epa.
gov
Carey
Johnston
To:
alan.
spackman@
iadc.
org
08/
15/
2003
05:
57
cc:
"'
Leach,
Gary'"
<
GLeach@
houston.
deepwater.
com>,
PM
"
Kent
Saterlee
III
(
E­
mail)"
<
ksatt@
Shell.
Com>,
"'
Cleaver,
Marc
A.'"
<
MCleaver@
houston.
deepwater.
com>,
"'
McBride,
Mickey'"
<
MMcBride@
houston.
deepwater.
com>,
John
Fox/
DC/
USEPA/
US,
Timothy
Connor/
DC/
USEPA/
US@
EPA,
Jennifer
Chan/
DC/
USEPA/
US,
Shari
Goodwin
<
shari.
goodwin@
tetratech­
ffx.
com>,
scockerill@
hatch.
com.
au
Subject:
RE:
Sea
Water
Intake
Structures(
Document
link:
Carey
Johnston)

Dear
Alan:

EPA
is
sharing
all
the
data
collected
by
IADC,
OOC,
WSPA,
LMOGA
(&
others)
regarding
cooling
water
intake
structures
for
offshore
O&
G
facilities
with
Mr.
Cockerill.
Mr.
Cockerill
is
an
EPA
contractor
helping
EPA
better
analyze
this
data.
Help
that
IADC
or
OOC
members
can
extend
to
Mr.
Cockerill
with
his
analyses
will
help
EPA
better
understand
the
issues
specific
to
the
O&
G
extraction
industry.

We
hope
you
will
be
able
to
participate
in
our
small
business
outreach
activities,
formally
called
small
business
advocacy
review
(
SBAR).
There
will
be
at
least
two
opportunities
to
share
our
analyses
&
approaches
and
to
receive
comments
and
advice,
a
November
2003
SBAR
outreach
meeting
and
a
February­
April
2004
SBREFA
panel
(
which
runs
60
days).
SBREFA
(
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
Pub
Law
No.
104­
121)
requires
EPA
to
convene
a
small
business
advocacy
review
panel
prior
to
proposing
any
rule
that
will
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

We
would
like
to
invite
the
participation
of
IADC
and
OOC
(
and
others)
in
the
SBAR
process.
At
the
first,
preliminary
outreach
meeting
in
October
2002,
we
distributed
materials
to
(
among
others)
American
Petroleum
Institute
(
Roger
Claff
and
Marc
Meteyer)
and
National
Petrochemical
&
Refiners
Association
(
Tom
Wigglesworth).
EPA
intends
to
have
a
second
SBAR
outreach
meeting/
conference­
call
this
November.
In
the
background
materials
distributed
before
that
meeting,
we
will
discuss
oil
&
gas
cooling
water
intakes,
and
approaches
we
are
considering
(
the
level
of
detail
will
depend
upon
how
far
along
we
are
in
our
analyses).
After
that
meeting
and
before
convening
a
SBREFA
panel,
we
may
also
distribute
materials
(
to
bring
industry
up
to
date
on
our
analyses).

When
SBREFA
panel
is
convened
in
February
2004,
we
will
have
materials
&
analyses
to
distribute,
and
that
is
another
opportunity
for
you
to
comment.
The
SBREFA
panel
consists
of
representatives
from
EPA,
SBA,
and
OMB.
Note
that
only
small
business
and
their
representatives
may
be
selected
by
the
panel
to
serve
as
"
small
entity
representatives".
However,
it
is
routine
for
organizations
representing
a
range
of
business
sizes
to
provide
comments.
All
of
this
activity
occurs
before
EPA
publishes
the
316(
b)
Phase
III
proposal.

Thank
you
again
for
your
continued
help
and
for
cc:'
ing
me
on
this
message.

Sincerely,

Carey
A.
Johnston,
P.
E.
U.
S.
EPA,
Office
of
Water
ph:
(
202)
566
1014
fx:
(
202)
566
1053
johnston.
carey@
epa.
gov
