MEMORANDUM
Date:
21
August
2003
To:
George
Denning,
EPA
From:
Anne
Jones,
ERG
Subject:
Assessment
of
Platforms
in
the
Gulf
of
Mexico
That
Are
Likely
To
Be
In
Scope
This
memo
discusses
my
work
to
identify
a
way
to
determine
a
priori
which
platforms
are
likely
to
be
in­
scope
for
the
platform
survey
effort
(
MODUs
are
not
included
in
this
discussion).
We
have
all
been
interested
in
determining
which
platforms
in
the
Gulf
are
likely
to
use
more
than
2
MGD
of
cooling
water.
To
help
in
this
determination,
I
spoke
to
Carey
Johnston
to
ask
if
there
was
any
engineering
information
that
might
help
us
identify
in­
scope
operations.
I
also
needed
to
clarify
what
"
platform"
meant
in
TetraTech's
database,
which
contained
information
on
design
capacity
as
well
as
actual
usage
of
cooling
water.
We
were
not
certain
whether
we
were
looking
at
cooling
water
used
exclusively
for
drilling
on
fixed
platforms,
a
combination
of
cooling
water
used
for
drilling
and
production
on
fixed
platforms,
or
cooling
water
for
production
purposes
on
fixed
platforms.
In
response,
Carey
indicated
that
the
engineers
did
have
information
on
who
might
be
unlikely
to
have
CWISs
with
greater
than
2
MGD
capacity.
He
referred
me
to
Jennifer
Chan
for
this
information.
He
also
indicated
that
he
had
a
copy
of
the
raw
information
that
went
into
the
MODUs/
platform
database,
which
he
sent
me.
The
first
part
of
this
memo
discusses
the
information
I
received
from
Jennifer
Chan,
and
the
second
part
discusses
the
platform
data
I
was
able
to
put
together
using
the
raw
data
from
Carey.

1.
Information
from
the
States
Jennifer
Chan
sent
me
a
fax
of
a
letter
from
Richard
Metcalf
of
the
Louisiana
Mid­
Continent
Oil
and
Gas
Association
and
an
email
forwarded
from
Kent
Satterlee
at
Shell
(
SEPCo).
These
items
clarified
the
likelihood
of
locating
in­
scope
platforms
in
Gulf
state
waters.
Richard
Metcalf's
letter
stated:

Based
on
the
criteria
you
provided
that
the
upcoming
rules
would
apply
to
intakes
of
two
million
gallons
per
day
and
greater,
we
have
identified
no
facilities
in
the
oil
and
gas
exploration,
production
and
pipeline
segments
of
the
industry
[
in
Louisiana]
that
would
be
impacted
by
this
rulemaking.
Mid­
Continent
also
contacted
the
Louisiana
Independent
Oil
and
Gas
Association
(
LIOGA)
regarding
this
issue
and
LIOGA
also
has
not
identified
any
impacted
facilities....
There
are
two
primary
reasons
for
the
lack
of
applicability
of
this
rule
to
oil
and
gas
operations
in
Louisiana:
the
limited
need
for
process
cooling
and
the
availability
of
groundwater.
The
typical
facility
has
very
limited
process
cooling
needs.
The
cooling
of
natural
gas
as
it
is
compressed
to
meet
pipeline
pressure
is
the
primary
process
cooling
need
at
most
facilities
and
this
is
typically
met
through
air­
cooled
exchangers
that
are
part
of
the
compressor
package.
There
is
rarely,
if
any
need
to
cool
produced
crude
oil.
Some
natural
gas
processing
plants
extract
natural
gas
liquids
through
a
cryogenic
cooling
process
but
water
is
not
sufficient
to
meet
this
need.
Water
is
also
used
to
cool
the
internal
combustion
engines
that
drive
gas
compressors,
electric
generators,
pumps,
and
other
mechanical
equipment.
These
are
closed
cooling
systems,
much
like
an
automobile
engine's
cooling
system,
and
require
no
continuous
source
of
water
supply.

The
fax
from
Kent
Satterlee,
in
response
to
the
same
type
of
question
regarding
platforms
in
Mobile
Bay,
Alabama,
noted
that
after
surveying
operators
in
Mobile
Bay,
he
had
found
only
one
CWIS,
which
had
an
intake
rate
of
3,500
gallons
per
day,
significantly
less
than
the
2
MGD
cutoff.

No
similar
information
is
available
from
Texas;
however,
it
is
likely
that
many
of
the
same
factors
that
limit
the
size
and
prevalence
of
CWISs
in
state
and
coastal
waters
of
Louisiana
and
Alabama
might
also
apply.
This
is
further
supported
by
the
additional
work
I
did
in
trying
to
determine
what
types
of
platforms
seemed
to
have
CWISs
with
greater
than
2
MGD
capacity
in
the
TetraTech
database.
This
assessment
indicated
that
2
MGD
or
more
CWISs
are
most
likely
associated
with
very
large
platforms
(
with
more
than
20
slots),
or
possibly
smaller
platforms
farther
than
15
miles
from
shore
(
see
discussion
below
in
Section
2).
Few
platforms
in
state
waters,
if
any,
are
of
this
size.
Carey
mentioned
that
he
thought
that
EPA
could
deal
with
any
platforms
in
state
waters
with
intakes
of
2
MGD
or
more
on
a
case­
by­
case
basis.
Given
this
and
given
the
fact
that
it
may
be
impossible
to
randomly
sample
and
find
in
scope
platforms
in
state
waters,
EPA
may
not
want
to
include
any
platforms
in
state
waters
in
the
survey
effort.

2.
Platform
Data
I
also
investigated
the
TetraTech
database
information
provided
by
Carey.
The
original
data,
from
which
TetraTech
extracted
some
data
for
use
in
the
database
provided
the
key
pieces
of
missing
data
that
were
needed
to
specifically
identify
which
platforms
had
been
surveyed.
The
additional
data
also
allowed
me
to
link
these
platforms
with
the
MMS
database
information
we
had
compiled.
Thirty­
four
platforms
were
listed
in
the
original
data,
although
some
platforms
did
not
provide
sufficient
data
for
use
in
my
assessment
(
e.
g.,
did
not
report
cooling
water
intake
volumes).
Once
I
identified
the
platforms
in
the
MMS
data,
I
immediately
noted
that
most
of
these
platforms
are
not
actively
drilling.
I
therefore
assume
that
the
majority
of
the
cooling
water
needs
are
for
production­
related
activities
(
confirmed
when
looking
at
the
data
on
cooling
water
uses).
However,
some
cooling
water
is
likely
to
be
used
for
drilling
on
actively
drilling
platforms.
All
the
platforms
with
sufficient
cooling
water
data
are
producing
both
gas
and
oil,
where
they
are
producing
at
all
(
a
few
have
not
begun
production).
Table
1
shows
the
platforms
in
the
TetraTech
database
with
the
cooling
water
information
and
MMS
data
combined
in
one
table.
As
the
table
shows,
most
of
these
platforms
serve
wells
that
are
producing
gas
or
oil
at
far
greater
rates
than
the
average
Gulf
of
Mexico
well
and
most
have
large
numbers
of
well
slots
and
appear
to
be
serving
more
wells
than
the
average
Gulf
of
Mexico
platform.
Furthermore,
out
of
the
34
platforms
listed,
15
are
deepwater
structures
(
there
are
only
25
deepwater
structures
total).
Thus
in
general,
the
platforms
surveyed
for
CWIS
information
are
some
of
the
larger
platforms
in
the
Gulf.
Even
so,
not
all
of
these
large
platforms
have
CWISs
with
a
design
capacity
of
2
MGD
or
more.
Twenty­
one
(
65
percent)
do
have
capacities
of
that
magnitude,
3
did
not
provide
Table
1.
Data
on
Gulf
of
Mexico
Platforms
Surveyed
for
CWIS
Volumes
Operator
Block
Field
Lease
Plat.
Name
Max.
design
daily
intake
volume
(
MGD)
Total
daily
water
intake
(
MGD)
>
2MGD
?
Y/
N
Deepwater
Y/
N
Distance
from
Shore
Monthly
oil
production
(
1000
bbl)
Monthly
gas
production
(
1000
Mcf)
(
avg=
7)

Avg.

oil/
productive
completion
(
avg=
59)

Avg.

gas/
productive
completion
Number
of
Drilled
Slots
Number
productive
completions
(
avg=
5)

Total
Slots
BP
E&
P
VK989
Pompano
G06898
Pompano
2.1
1.8
Y/
N
Y
20
288
1,319
19
88
15
15
40
BP
E&
P
MC109
Amberjack
G05825
Amberjack
1.5
1.5
N
Y
18
454
1,011
17
37
30
27
35
BP
E&
P
MI622
Matagorda
Island
G05000
MI­
622
C
6.9
3.5
Y
N
15
26
2,754
7
689
0
4
0
BP
E&
P
SS178
Ship
Shoal
G05551
SS
178­
A
0.7
0.7
N
N
40
31
26
5
4
6
6
12
BP
E&
P
MI623
Matagorda
Island
G03088
MI­
623
B
1.7
0.8
N
N
15
3
288
1
72
4
4
12
BP
E&
P
MI519
Matagorda
Island
G06032
MI­
519
L
1.7
0.9
N
N
10
3
922
1
307
1
3
1
ChevronTexaco
VK786
Vioska
Knoll
786
G12119
Petronius
14.6
9.8
Y
Y
90
1,480
1,579
164
175
16
9
21
ChevronTexaco
ST37
South
Timbalier
37
G02625
ST37
J
1.7
1.7
N
N
12
696
1,588
20
47
34
ChevronTexaco
GC205
Green
Canyon
205
G05911
Genesis
11.8
11
Y
Y
81
1,746
3,724
116
248
10
15
20
ExxonMobil
AC25
Alaminos
Canyon
25
G10380
A­
Hoover
20.7
10.1
Y
Y
138
1,739
3,043
290
507
5
6
8
ExxonMobil
MP283
Main
Pass
280
G13662
A
5.8
2.9
Y
N
43
30
516
8
129
4
4
6
ExxonMobil
GC18
Green
Canyon
19/
18
G04940
A
2.4
NA
Y
N
96
124
182
14
20
28
9
30
ExxonMobil
SP98
South
Pass
89
G01619
B
2.3
2.3
Y
N
20
34
202
4
22
18
9
24
ExxonMobil
MC280
Mississippi
Canyon
281
G03818
A­
Lena
2.3
2.3
Y
Y
22
97
761
3
21
49
36
58
Kerr­
McGee
VK826
Vioska
Knoll
826
G06888
Neptune
4.5
NA
Y
Y
81
469
836
36
64
7
13
16
Kerr­
McGee
HI379
High
Island
369
G13808
HI
379
5
NA
Y
N
106
33
54
2
3
22
16
24
Kerr­
McGee
EB602
East
Breaks
602
G14205
Nansen
10.7
NA
Y
Y
142
306
291
102
97
4
3
9
Kerr­
McGee
EB642
East
Breaks
642
G09184
Boomvang
10.7
NA
Y
Y
134
NA
NA
4
9
Marathon
EB873
Ewing
Bank
G12136
A­
Lobster
12.1
2.9
Y
N
69
644
643
36
36
24
18
30
Marathon
SP86
South
Pass
G05687
C
3.5
1.7
Y/
N
N
16
82
772
10
96
9
8
20
Operator
Block
Field
Lease
Plat.
Name
Max.
design
daily
intake
volume
(
MGD)
Total
daily
water
intake
(
MGD)
>
2MGD
?
Y/
N
Deepwater
Y/
N
Distance
from
Shore
Monthly
oil
production
(
1000
bbl)
Monthly
gas
production
(
1000
Mcf)
(
avg=
7)

Avg.

oil/
productive
completion
(
avg=
59)

Avg.

gas/
productive
completion
Number
of
Drilled
Slots
Number
productive
completions
(
avg=
5)

Total
Slots
Marathon
SP89
South
Pass
G01618
B
0.6
0
N
N
14
20
27
7
9
2
3
21
Marathon
SP87
South
Pass
G07799
D
0.8
0.8
N
N
17
56
1,145
7
143
8
8
12
Marathon
VR386
Vermillion
G02278
B
NA
NA
NA
N
10
12
Marathon
EC321
East
Cameron
G02061
A
NA
NA
NA
N
30
30
Marathon
EC321
East
Cameron
G02061
B
NA
NA
NA
N
14
15
Shell
GB426
Garden
Banks
426
G08241
Auger
7.2
NA
Y
Y
168
1,653
8,414
236
1202
16
7
32
Shell
VK956
Vioska
Knoll
956
G06896
Ram­
Powell
4.5
2.2
Y
Y
55
669
7,711
84
964
10
8
20
Shell
MC807
Mississippi
Canyon
807
G07963
Mars
7.5
0.1
Y/
N
Y
67
5,140
6,264
271
330
10
19
24
Shell
MC810
Mississippi
Canyon
810
G05868
Ursa
14
14
Y
Y
67
3,194
4,244
456
606
7
24
Shell
MC194
Mississippi
Canyon
194
G02638
A­
Cognac
0.9
0.9
N
Y
15
152
4,242
4
125
60
34
62
Shell
MC311
Mississippi
Canyon
311
G02968
A
0.9
0.9
N
N
46
21
529
2
41
24
13
24
Shell
EI300
Eugene
Island
330
G02116
B­
EI331
0.8
0.5
N
N
80
28
114
2
10
39
12
41
Shell
WD143
West
Delta
143
B­
Mensa*
7.1
1
Y/
N
Y
Shell
GC158
Green
Canyon
158
G07795
Brutus
11.2
10.8
Y
Y
92
NA
NA
0
8
*
Deepwater
subsea
wells
served
by
shallow
water
platform.
1I
was
not
able
to
find
a
pattern
when
I
used
either
total
production
of
oil
or
gas
or
average
per­
well
production
of
oil
or
gas
(
see
Table
1).
Although
there
was
some
tendency
towards
higher
production
being
associated
with
larger
intakes,
these
data
did
not
seem
to
explain
the
pattern
of
cooling
water
usage.
No
statistical
analysis
was
performed,
however.

2This
includes
Mensa,
which
has
no
well
slot
information
available.
Mensa's
platform
is
reported
in
shallow
water,
but
this
platform
serves
several
subsea
completions
many
miles
away
in
a
deep
water
location.
Mensa
would
not
be
captured
using
a
search
for
deepwater
platforms,
but
we
can
manually
include
it
as
such.
A
search
of
MMS
information
on
deepwater
operations
may
be
needed
to
ensure
that
other
projects
such
as
Mensa
have
not
been
added
since
I
last
worked
with
deepwater
projects.
information
on
design
capacity,
and
the
remainder
(
29
percent)
had
capacities
of
less
than
2
MGD.

I
determined
that
there
was
a
fairly
clear
drilling
slot
number
and
water
depth
association
with
design
capacity
in
reviewing
the
data1.
Although
we
could
do
a
regression
analysis,
if
desired,
for
fine
tuning
this
observation,
a
slot
size
of
20
or
more
OR
a
location
in
deepwater
captures
all
of
the
2
MGD
capacity
observations
with
the
exception
of
2
platforms
(
out
of
a
total
of
30
for
which
capacity
and
well
slot
data
were
available)
2.
With
these
criteria,
however,
I
still
capture
a
few
platforms
that
do
not,
in
fact,
have
cooling
water
intakes
with
a
2
MGD
capacity.
Two
are
older
deepwater
platforms
(
Amberjack,
and
the
oldest
deepwater
platform,
Cognac),
which
are
located
quite
close
to
shore
(
18
and
15
miles,
respectively).
Three
are
shallow
water
platforms
(
SEPCo
Mississippi
Canyon
311
"
A"
and
Eugene
Island
330/
1
"
B",
and
Marathon
South
Pass
89
"
B").
Thus
using
the
criteria
of
deepwater
or
more
than
20
slots,
we
would
probably
find
that
this
group
was
generally
in
scope,
but
that
some
portion
(
if
true
to
the
proportion
here,
17
percent)
might
turn
out
to
be
out
of
scope.
Several
more
platforms
might
be
out
of
scope
by
virtue
of
having
a
design
capacity
of
2
MGD
or
more,
but
with
actual
usage
much
less
than
that.
Four
platforms
in
the
data
set
(
with
both
design
and
actual
data
 
25
platforms)
had
actual
intake
of
less
than
2
MGD,
although
their
design
capacities
were
2
MGD
or
more.

I
believe,
if
we
set
criteria
to
select
deepwater
structures
and
structures
with
more
than
20
well
slots
(
210
structures,
including
Mensa),
and
also
select
for
major
production
platforms
(
no
wells,
but
with
production
equipment,
production
flag
=
Y,
major
structure,
and
manned
24
hours)
(
208
structures),
a
major
portion
of
these
will
be
in
scope.

We
are
still
left
with
the
issue
of
the
two
platforms
with
more
than
2
MGD
capacity
that
do
not
meet
the
criteria
outlined
above.
I
have
determined
that
one
of
these
platforms
is
a
large
production­
only
platform
(
generally,
no
wells
are
located
on
these
types
of
platforms;
they
are
designed
to
serve
a
number
of
affiliated
platforms,
satellite
wells,
or
other
structures
and
are
likely
to
be
associated
with
very
large
volumes
of
gas
or
oil).
The
other
is
a
platform
with
6
slots,
4
of
which
are
drilled.
This
is
ExxonMobil's
Main
Pass
280
"
A"
platform.
The
large
production
platform
and
others
like
it
might
be
identified
using
the
following
criteria
from
the
MMS
platform
masters
data:
no
slots,
major
structure
=
Y,
production
equipment
=
Y,
production
flag
=
Y,
and
manned
24
hours
=
Y.
Using
these
criteria
results
in
a
count
of
208
platforms.
The
issue
of
the
6­
slot
platform
is
not
yet
resolved,
although
the
wells
tied
to
this
platform
produce
on
average
more
gas
than
the
typical
Gulf
well
(
but
so
do
many
others
that
have
CWISs
with
intakes
of
less
than
2
MGD).

We
need
to
consider
whether
there
are
many
more
smaller
structures
such
as
Main
Pass
280
or
production­
only
platforms
that
would
be
missed
if
only
the
large
or
deepwater
structures
are
sampled.
Nine
structures
with
less
than
20
slots
were
identified.
All
but
two
had
intakes
of
less
than
2
MGD
(
both
design
and
actual).
If
we
assume
these
structures
were
sampled
randomly,
two
out
of
nine
(
22
percent)
structures
in
the
Gulf
 
that
are
neither
deepwater
structures
or
large
platforms
 
might
be
expected
to
intake
more
than
2
MGD
of
cooling
water.
The
total
number
of
small
platforms
(<
20
slots)
in
the
shallow
water
Gulf
is
2,195
(
including
production­
only
platforms).

We
could
possibly
further
narrow
down
the
number
of
small
platforms
likely
to
be
in
scope
by
using
distance
from
shore.
No
platforms
in
the
database
closer
than
15
miles
from
shore
had
intake
volumes
greater
than
2
MGD.
The
total
number
of
platforms
in
this
group
(
less
than
20
slots
but
more
than
15
miles
from
shore)
is
1517
(
excluding
the
208
production­
only
platforms).

This
suggests
a
different
sampling
strategy
than
previously
considered.
First,
as
discussed
above,
we
may
not
wish
to
sample
any
state
platforms.
The
data
from
Louisiana
and
Alabama
suggest
that
few,
if
any,
state
platforms
will
have
cooling
water
needs
requiring
2
MGD
of
cooling
water.
Even
in
Texas,
whose
platforms
extend
at
most
only
10
miles
from
shore,
may
be
unlikely
to
use
these
volumes
of
cooling
water.

If
we
retain
region
as
one
strata
(
CA,
AK,
Gulf
deepwater,
Gulf
OCS
shallow),
I
would
suggest
splitting
Gulf
OCS
shallow
into
large
platform
(>
20
slots)
and
small
platform
(<
20
slots,
including
those
identified
as
production­
only
platforms,
but
excluding
the
other
small
platforms
closer
than
15
miles
from
shore).
In
this
way
we
can
oversample
slightly
in
deepwater
and
large
platform
strata,
and
oversample
significantly
more
in
the
stratum
with
small
platforms
and
production­
only
platforms.
If
stratification
limitations
permit,
the
small
platforms
and
productiononly
platforms
could
be
further
split.

The
counts
of
interest
are
shown
in
Table
2.
Table
2
Potential
Stratification
Schemes
Strata
Count
Drilling/
Producti
on
Region
Shallow
Gulf
Only
Large
Platforms
Small
and
Production­
Only
Platforms
MODUs
451
Structures
Alaska*
19
California*
30
Gulf
Deepwater
26**

Gulf
Shallow
2,403
209
1,774+
1,933
*
Some
of
these
may
be
identified
as
out­
of­
scope.
A
quick
look
at
California
data
indicate
that
several
may
not
have
cooling
water
intakes
that
handle
2
MGD
or
more.
I
will
follow
up
on
this
shortly.
Carey
is
tracking
down
information
that
may
indicate
that
Alaska
platforms
are
not
a
concern.

**
Includes
Mensa.

+
Excludes
470
platforms
that
are
within
15
miles
of
shore
and
includes
208
platforms
that
are
considered
production­
only
platforms.
If
small
platforms
and
production­
only
platforms
are
split,
the
number
of
small
platforms
would
be
1,517.
