In Reply Refer To: MS 5231 August 26, 1992

Walter Oi l & Gas Corporation Attention: Ms. Judy Archer 1021 Main Street, Suite 2200 Houston, T<xas 77002- 05

Gentlemen:

Reference Is made to the following plan received August 18, 1992:

Type Plan - I n i t i a l Development Operations Coordination Document Lease - OCS-C 9040 Block - 288 Area - Galveston Ac t iv i t i e s Proposed -Wel l and Caisson No. 1

I n accordance wi th 30 CFR 250.34, th is plan Is hereby deemed submitted and is now being considered for approval.

Your control number i s N-4335 and should ba referenced i n your communication and correspondence concerning this plsn.

Sincerely,

(Orip, Sgd) D r n 1 , t 1 r ' , r o i r

D. J . Bourgeois _ ' r Regional Supervisor

Field Operations

bcc: Lease OCS-G 9040 POD File (MS 5032) /MS 5034 w/public in fo , copy of the plan \ and accomp. i n f o .

BNewton: c i c : 08/19/92: D0CDC0M

NOTED-SCHEXNAILDRE

W A L T E R OIL & G A S C O R P O R A T I O N D r n r

AUG 1 8 1992 OPERATIONS 4

August 17, 1992

Mr. Daniel J. Bourgeois Regional Supervisor office of Field OperaUons U. S. Department of the Interior Minerals Management Service 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123-2394

Attention: Mr. Mike Tolbert

Re: Initial Developmenl Operations Coordination Document OCS-G 9040, Galveston Area Block 288 Offshore, Texas, GOM, OCS Federal Waters

Gentlemen:

In accordance with the provisions of Title 30 ' FR 250.34, Walter Oil & Gas Corporation (Walter) hereby submits for your review and app i /al nine (9) copies of an Initial Development Operations Coordination Document (DOCD) ks lease OCS-G 9040, Galveston Area Block 288, Offshore, Texas. Five (S) copies are "Confidential Information" and four (4) copies are "Public Information".

Excluded from the "Public Information" copies are certain geologic discussions and structure map.

Walter anticipates commencing development operations associated with lease OCS-G 9040, Galveston Area Block 288 approximately August 20, 1992, contingent upon approval of the necessary permits.

A copy of the subject plan has been forwarded to Mr. Floyd Bryan, Geology Department, Minerals Management Service, Regional Office.

RUlC INFC" ' WON

1021 Main Street. Suite 2200. Houston, Texas 770024805 (713)869-1221

U. S. Department of the Interior Minerals Management Service OCS-O 9040, Block 288 Galveston Area, Offshore, Texas Initial DOCD

Page Two

Should you have any questions or need additional information, please contact the undersigned at (713) 659-1222.

Very truly yours,

WALTER OIL & GAS CORPORATION

Judy Archer Regulatory/Environmental Coordinator

:JA

enclosures

WALTER OIL & CAS CORPORATION

INITIAL DEV ELOPMENT OPERATIONS COORDINATION DOCUMENTS

OCS-G 9040 GALVESTON AREA BLOCK Ml

Walter Oil & Gas Corporation (Walter), as designated operator of the subject block, submits this proposed Initial Development Operations Coordination Document (DOCD) in accordance with the regulations contained in Title 30 CFR 250.34 and more specifically defined in the Minerals Management Service Letter to Lessee's and Operators dated October 12, 1988.

DESCRIPTION OF DEVEI

Under this Initial DOCD, Walter is proposing one (I) well to be involved in the development and production activities associated with Block 288. A production caisson will be installed over the surface location of Well No. 1, 1393.59* FL and 3703.65* FEL of Biock 288, and will be permitted as Caisson No. 1.

Production from Caisson No. 1 will be transported through a 4.500" bulk gas pipeline to Ivory Production Co.'s Platfonn "A" in Galveston Block 288.

Activities proposed under this Initial DOCD for Galveston Area Block 288 will commence August 20, 1992 with production expected to commence November 1, 1992. The following schedule details the chronological order of the proposed events leading to full production.

SCHEDULE OF ACTIVITIES ACTIVITY APPROXIMATE START-VP PATE

1. Installation of Caisson No. 1 August 20, 1992 2. Installation of Pipeline October 1, 1992 3. Commence Production November I, 1992

DESCRIPTION QF STRUCTURE

A plat snowing the surface location of the proposed production Caisson No. 1 is enclosed as Attachment "A". The structure will be a production caisson with helideck and boat landing. A schematic of the caisson detailing the elevations is enclosed as Attachment "B".

All hydrocarbon handling equipment for testing and production such as separators, tanks and treaters shall be designed, installed and operated to prevent pollution.

Maintenance or repairs which are necessary to prevent pollution of offshore waters shall be undertaken immediately.

Curbs, gutters, drip pans, and drains shall be installed in deck areas in a manner necessary to collect all contaminants not authorized for discharge. Oil drainage shall be piped to a properly designed, operated and maintained sump system which win automatically maintain the oil at a level sufficient to prevent discharge of oil into offshore waters. AU gravity drains shall be equipped with a water trap or other means to prevent gas in the sump system from escaping through the drains. Sump piles shall not be used as processing devices to treat or skim liquids but may be used to collect treated-produced water, treated-produced sand or liquids from drip pans and deck drains and as a final trap for hydrocarbon liquids in the event of equipment upsets. Improperly designed, operated or maintained sump piles which do not prevent the discharge of oi) into offahore waters shall be replaced or repaired.

There shall be no disposal of equipment, cables, chains, containers or other materials into offshore waters.

STRUCTURE MAP A current structure map of the expected productive formations showing the surface and bottomhole location of Well No. 1 is enclosed as Attachment "C.

BATHYMETRY MAP

A Bathymetry Map showing the surface location of Caisson No. 1 in Galveston Block 288 is enclosed as Attachment "D".

MALLOW HAZARDS A site specific shallow hazards analysis for the existing surface location was previously addressed in Sinoefer Offshore Operating Co's Initial POE submitted on May 11, 1992 and approved by your office.

OIL SPILL CONTINGENCY PLAN

All development and production operations shall be performed in accordance with industry standards to prevent pollution of the environment. Walter's Oil Spill Contingency Plan has been approved by the MMS. This plan designates an Oil Spill Team consisting of Walter's fxrionael and contract personnel. This team's duties are to eliminate the source of any spill, remove all sources of possible ignition, deploy the most reliable means of available transportation to monitor the movement of a slick and contain and remove the slick if possible.

(2)

Walter is a member of Clean Gulf Associates (CGA). The CGA has two permanent equipment bases in Texas, at Port Aransas and Galveston, and five bases in Louisiana, at Venice, Grand Isle, Intracoastal City, Houma and Cameron. Each base is equipped with fast response skimmers and there is a barge-mounted high volume open-sea skimmer based at Grand Isle, Louisiana. In addition to providing equipment, the CGA also supplies advisors for cleanup operations. Equipment available from CGA and the base it is located at is listed in the CGA Manual, Volume I , Section III.

Estimated response time for a spill in Galveston Area Block 288 during normal weather conditions could vary from 8 to 9 hours based on the following:

I . Procurement of boat capable of handling oil spill containment equipment and deployment to nearest CGA Base in Galveston, Texas 2.5 hours

2. Load out of Fast Response Unit and related spill containment equipment 2.0 hours

3. Travel Time to Spill Site (3 Miles & iO MPH) 3.0 hours 4. Inland Travel Time 1.0 hour

Estimated Total Time 8.5 hours

In the event a spill occurs from Galveston dlock 288, our company has projected trajectory of a spUl utilizing infonnation in the Environmental Impact Statement (EIS) for OCS Lease Sales 139/141.

The IS contains oil spill trajectory simulations using seasonal surface currents coupled with wind da»i, adjusted every 3 hours for 30 days or until a target is contacted.

Hypothetical spill trajectories were simulated for each of the potential launch sites across the entire Gulf. These simulations presume 500 spills occuring in each of the four seasons of the year. The results in the EIS were presented as probabilities that an oil spill beginning from a particular launch site would contact a certain land segment (Table IV-17) within, 10 or 30 days. Utilizing the summary of the trajectory analysis (for 10 days) as presented on page IV-87 through IV-91, the probable projected landfall of an oil spill is as follows. Also listed is the CGA Map Number corresponding to the land segment which will be utilized to determine environniuitally sensitive areas that may be affected by a spill.

AREA LAND SEGMENT CONTACT & CCA MAP NUMBER Galveston Area Matagorda, Texas 1% TX Map No. 2 & 3 Block 288 Brazoria, Texas 12% TX Maps No. 3

Galveston, Texas 26% TX Map No. 3 & 4 Chambers, Texas 26% TX Map No. 3 & 4

(3)

Section V, Volume II of the COA manual containing maps as listed above, also includes containment/clean-up protection response modes for the sensitive areas.

Section VI, Volume II of the CGA Operations Manual depicts the protection response modes that are applicable for oil spill clean-up operations. Each response mode is schematically represented to show optimum deployment and operation of the equipment in areas of environmental concern. Implementation of the suggested procedures assures the most effective use of the equipment and will result in reduced adverse impact of oil spills on the environment. Supervisory personnel have the option to modify the deployment and operation of equipment to more effectively respond to site-specific circumstances.

MEW QR UNUSUAL TECHNOLOGY

No new techniques or unusual technology will be required for these operations.

LEASE STIPULATIONS

In accordance with Lease Stipulation No. 1 attached to this lease, a Shallow Hazards Survey & Cultural Resources Report assessing the potential existence of any cultural resources in this block was submitted with Sandefer Offshore Operating Co.'s fm'tial POE which was approved by your office.

DISCHARGES

AU discharges associated with the development and production of Galveston Block 288 will be in accordance with the permit limitations addressed in the Environmental Protection Agency NPDES General Permit for the Gulf of Mexieo.

Discharges will contain no free oil and will be in compliance wiui and monitored in accordance with the subject permit. Any drilling fluid contaminated with oil will be transported to shore for proper disposal at an authorized disposal site.

Solid domestic wastes will be transported to shore for proper disposal at an authorized disposal site.

Sewage will be treated on location.

(4)

t i t b i t D^l l C WASTE

Solids No Floating Once/Day Observations!!/ Number of Days Solids Solids Observed

DESALINIZATION UNIT DISCHARGE; BLOWOUT PREVENTER FLUID; UNCONTAMINATED BALLAST WATER; UNCONTAMINATED BILGE WATER; MUD, CIJTT1NGS AND CEMENT AT THE SEAFLOOR; UNCONTAMINATED SEAWATER; BOILER BLOWDOWN; SOURCE WATER AND SAND

Free Oil No Free Oil Once/day4_/ Visual/Sheen Number of Days on receiving Sheen Observed water surface

1/ When discharging and facility is manned, monitoring shall be accomplished during daylight by visual observation of the receiving water surface in the vicinity of the discharge.

21 This information shall be recorded but not reported unless otherwise requested by EPA.

3_/ May be based on the arithmetic average of four grab sample results in the twenty-four hour period. The Regional Administrator may approve an alternative test method on a case-by-case basis.

1/ When discharging, monitoring shall be accomplished during daylight by visual observation of the receiving water surface in the vicinity of the discharge.

5/ No discharge of priority pollutants except in trace amounts. Information on the specific chemical composition shall be recorded but not reported unless requested by EPA.

6V Any facility which properly operates and maintains a Marine Sanitation Device (MSD) that complies with pollution control standards and regulations under Section 312 of the Act shall be deemed to be in compliance with permit limitations for sanitary waste. The MSD shall be tested yearly for proper operation and test results maintained at the facility.

21 Hach method CN-66-DPD approved. Minimum of 1 mg/l and maintained as close to this concentration as possible.

8/ Monitoring shall be accomplished during daylight by visual observation of the surface of the receiving water in the vicinity of sanitary and domestic waste outfalls. Observations shall be made foUowing either the morning or mid-day meals and at a time during daylight and maximum estimated discharge.

Discharges will be free of oil and will be in compliance with and monitored as required by EPA NPDES General Permit (CMG 280000) in accordance with 40 CFR 122-6. Any oil contaminated mud will be transported to shore for proper disposal.

(5)

Discharge Effluent Discharge Otexactei lifte Limitation

Measurement Sample frequency Type/Method

Recorded Value(s)

PECK DRAINAGE Free Oil No Free Oil Onre/dayl/

Volume (bbls) Once/Month

PRODUCED WATER Oil St Grease 72 mg/ 1 Once/Month

daily max.

48 mg/ 1 monthly avg.

Flow (MGD) Once/Monm

PRODUCED SAND Free Oil No Free hi Once/day 47

Weight (lbs) Once/month

WELL TREATMENT FLUDS 5/ COMPLETION FLUIDS 5/ WORKOVER FLUIDS SI Free Oil No Free Oil Once/day 4./

Volume (bbls)

Visual/Sheen on receiving water

Estimate

Grab 2/

Once/month

Estimate

Visual Sheen on receiving water

Estimate

Visual Sheen on receiving water

Estir^te

Number of Days Sheen Observed

Month total 2J

Daily Maximum & Monthly Avg.

Monthly Avg.

Numbers of Days Sheen Observed

Monthly Total H

Number of Days Sheen Observed

Monthly Total V

SAMTTAPV WACTF «/ f f ^ - W — i j J fry )Q g m m pfniTm) Residual Chlorine 7i 1 mg/l Once/month Grab Concentration

Flow (MGD) Once/month Estimate Monthly avg. 2J

SANITARY WASTE (Continuously manned bv 9 or fewer persons or IntewHjeatlv bv anv number) Solids No Floating Once/day Observations/ Number of Days

Solids Solids Observed (6)

Ji

In accordance with the provisions of Title 30 CFR Part 250.67, Walter respectfully requests that the Minerals Management Service classify the subject lease area as (1) Zones known to contain hydrogen sulfide, (2) Zones where the absence os hydrogen sulfide has been confirmed or (3) Zones where the presence of hydrogen sulfide is unknown. Walter request that the subject kase be classified as "Zones where the absence of hydrogen sulfide has been confirmed by the drilling of Well No. 1 where no hydrogen sulfide was found.

PROJECTED EMISSIONS

Projected Emissions are enclosed as Attachment "E"

ONSHORE BASE

Galveston Block 288 is located approximately 30 miles south of the Texas coastline in a water depth of 63 feet. A vicinity map showing the location of Block 288 relative to the shoreline is enclosed as Attachment of "F".

Walter will utilize existing onshore facilities located in Freeport, Texas. This will serve as port of debarkation for supplies and crew. No onshore expansion or construction is anticipated with respect to this activity.

This base is capable of providing the services necessary for the proposed activities. It lias 24-hour service, a radio tower with a teiepnciv patch, dock space, equipment and supply storage base, drinking and drill water, etc. Du ing production activities one (J) supply boat will be making one (1) trip per month and one (1) helicopter will be making seven (7) trips per week.

The onshore activities associated with Galveston Block 288 should rw$ -suit in any increase in the size and number onshore support and storage facilities or land and personnel lequirements.

AUTHORIZED » "?RH?E>1IAILYE

Inquiries may be made to the following authorized representative of Waller Oil & Gas Corporation:

Judy Archer, Regu!atory7£nvironmental Coorainator Walter Oil & Gas Corporation 1021 Main, Suite 2200 Houston, Texas 77002-6605 (713) 659-1222

(7)

A. Location Plat B. Schematic of Proposed Platform D. Bathymetry Map E. Projected Air Emissions F. Vicinity Map

ATTACHMENT "A"

WELL NO WELL L J C A T I I M WEU _A>EP.l WATER PEPTH

I SL: L«93.5«' FNL & 3703.65' FEL of Block 288

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FINAL LOCATION GALVESTON BLOCK 28b

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ATTACHMENT "B"

SCHEMATIC OF PROPOSED CAISSON

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WEST EL£YATIQN KALE - 0 *

OVPTTUWHINO MOMENTS P4VW0MMCWTAI FORCES

.ET-TONS

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TOTAL GRAVITY LOADS

I f * mm mt*. mm) CmUta* W S LONC. 12. TONS TRANS, UH.TONS BAG. lot TONS

OttRATMO STORU MST.

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VAX tOMC.__212. TONS TRAN3 t \ 7 TON? PAC 312 TONS

PiMWONMtHTAl. OttOM FACTORS WAVC TMC ONT. RCTURN MTERVAL WAVC MCIGMT WAVC RCRWO STORM k ASTRO TlOC CRC IT ELEVATION SUfcfACC CURRENT_ MUDUNE CURRENT MAAMC GROWTH ORAO cccmacNT INERTIA C0ErfK3ENT_ WHO MbC

tXSTON ME THOU RlATfORM LITE (ANTlCtPATCD) C»'HOO«: PRO IEC HON

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1-WELL CAISSON PRODUCTION PLATFORM

ARCA

OPERATOR WAITER OA A OAS CORPORATION

ATTACHMENT *W

BATHYMETRY MAP

ATTACHMENT "E"

PROJECTED AIR EMISSIONS

W A L T E R OIL & C A S C O R P O R A T I O N

PROJECTED AIR EMISSIONS SCHEDULE FOR INITIAL DEVELOPMENT OPERATIONS COORDINATION DOCUMENT

GENERAL LNTORMAT10N

Location of Facility:

Facility Name: Distance Offshore: Operator

Contact Person: Date Production to Commence:

Galveston Block 288 OCS-G 9040 Caisson No. 1 30 Miles Walter Oil & Gas Corporation 1021 Main, Suite 2200 Houston, Texas 77002-45605 Judy Archer Approximately November 1, 1992

MAJOR SOURCE (OFFSHORE)

Power used aboard drilling vessel. Approximate footage to be drilled * N/A

Emitted Projected Emissions Substance »• Tons/Year

1992 CO SO, NOx VOC TSP

* Based on 60 hphr/ft. from Table 4-3, "Atmospheric Emissions from Offshore Oil and Gas Development and Production", EPA No. 450/3-77-026, June 1977

** Emission factors from Table 3.3.3-1, "Compilation of Air Pollutant Emission Factors", Third Edition, EPA Report AP-42, August 1977

1021 Main Street. Suite 2200, Houston. Texas 770024805 (719859-1221

Projected Air Emissions OCS-G 9040, Caisson No. 1 Galveston Block 288 Initial DOCD Page Two

MINOR SOURCES {Offshore)*

Including helicopter landing and take-off (7 trips/week); supply boat (1 trip/month) and crew boat (0 trips/week); loading and unloading operations.

Emitted Projected Emissions SaftaaVai ftons/yeart

1992 CO .00 SO, N/A NOx .00 VOC .00 TSP N/A

* Tables 3.2.1-3, 3.2.3-1, and 2.1, "Compilation of Air Pollutant Emission Factors" Tliird Edition, EPA Report AP-42, August 1977.

TOTAL ALL SOURCES (TONS/YEAR)

1992 CQ SQ2 NOx YQC USE

Major N/A N/A N/A N/A N/A

Minor 1.04 .03 .10 .09 .05

Total 1.04 .03 .10 .09 .05

ONSHORE SOURCES

These should be about the same as minor source, unless new facilities are installed at the onshore base. No additional facilities are required or planned at this time.

EMISSION EXEMPTION DETERMINATION

For CO. E = 3400DW « 3400 (30)w - 32,827 tons/year For NOx, VOC, TSP & SO,: E = 33.3D (30) = 999 tons/year

As per DOI/MMS regulations, this facility is exempt from further air quality review as it har

been determined that its operations will not have a significant adverse environmental impact on air quality.

Projected Air Emissions OCS-G 9040, Caisson No. 1 Galveston Block 288 Initial DOCD Page Three

PREDICTED PROPUCTION ACTIVITY AT PLATFORM

Date Production Will Begin = Approximately November 1, 1992

TRANSPORTATION SERVICES

Crew Boats (2500 hp) Trips Per Week During Drilling - N/A Trips Per Week During Production - 0

Supply Boats (3000 hp) Trips Per Week During Drilling - N/A Trips Per Month During Production - 1

Helicopters Trips Per Week During Drilling - N/A Trips Per Week During Production - 7

METHODOLOGY

Platform: Horsepower - hour method Boats: Horsepower - hour method Helicopters: Landing/Takeoff (LTO) cycle method

Production - EPA 450/3-7-026 (June 1977) - "Atmospheric Emissions from Offshore Gil and Gas development and Production", pp. 81-116

Boats - EPA Report AP-42 - "Compilation of air Pollutant Emission Factora", 3rd Edition, (August 1977), pp. 116, 125 and 127

FINDINGS OF AIR QUALITY REVIEW

As per DOI/MMS regulations, this facility is exempt from further air quality review & it has been determined that its operations will not have a significant adverse environmental impact on air quality.

ATTACHMENT "P

VICINITY MAP

Vr* HOUSTON

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Aiitiiun

FASt'

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288

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EST AWLAI LE CCW

WAITER Oil 4 OAS CORPORATION

GALVESTON BLOCK 288

OCS-Q 9040

VTCMTY PLAT