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.


[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Notices]
[Pages 36334-36335]
[FR Doc No: 2015-15430]

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DEPARTMENT OF ENERGY

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Combined Notice of Filings #1

    Take notice that the Commission received the following electric
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intervention is necessary to become a party to the proceeding.
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    Dated: June 17, 2015.
Kimberly D. Bose,
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[FR Doc. 2015-15430 Filed 6-23-15; 8:45 am]
 BILLING CODE 6717-01-P


[Federal Register Volume 76, Number 188 (Wednesday, September 28, 2011)]
[Notices]
[Pages 60012-60013]
[FR Doc No: 2011-24890]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

Combined Notice of Filings 1

    Take notice that the Commission received the following electric
rate filings:

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    Comment Date: 5 p.m. Eastern Time on Wednesday, October 12, 2011.

    The filings are accessible in the Commission's eLibrary system by
clicking on the links or querying the docket number.
    Any person desiring to intervene or protest in any of the above
proceedings must file in accordance with Rules 211 and 214 of the
Commission's Regulations (18 CFR 385.211 and 385.214) on or before 5
p.m. Eastern time on the specified comment date. Protests may be
considered, but intervention is necessary to become a party to the
proceeding.
    eFiling is encouraged. More detailed information relating to filing
requirements, interventions, protests, service, and qualifying
facilities filings can be found at: http://www.ferc.gov/docs-filing/efiling/filing-req.pdf. For other information, call<PHONE_NUMBER>
(toll free). For TTY, call<PHONE_NUMBER>.

    Dated: September 21, 2011.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2011-24890 Filed 9-27-11; 8:45 am]
BILLING CODE 6717-01-P