GCREAG Regulatory Update
January, 2014
Lincoln Stroh
J. Connor Consulting, Inc.
Key Topics
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BSEE Regulatory Agenda
USCG Regulatory Agenda
DOT Regulatory Agenda
Form / Information Collection Updates
Proposed, Final Regulations & New NTL
Deepwater Exploration Plan Approval Times
BSEE Regulatory Agenda
• BOPs
– NPRM March 2014
– Final Rule October 2014
• Production Safety Systems and Lifecycle Analysis
– NPRM August 22, 2013
– Comment Period Ended October 21, 2013
– Final Action May 2014
USCG Regulatory Agenda
• Proposed regulations to add new requirements
for lifesaving, fire protection, training, hazardous
materials used as stores, and accommodation
spaces
• Add standards for electrical and machinery
installations in hazardous locations
• Provide regulations for DP systems
• Provide for USCG acceptance and approval of
specified classification society plan reviews,
inspections, audits, and surveys
• NPRM September 2014
USCG Regulatory Agenda
• Nontank Vessel Response Plans requires owners or
operators of nontank vessels to prepare and submit oil
spill response plans. Definition of nontank vessel:
– Self-propelled vessels of 400 gross tons or greater that
operate on the navigable waters of the US
– Carry oil of any kind for main propulsion that are not
tank vessels
• Updates SOPEP requirements that apply to nontank
vessels and tank vessels
• Final Rule September 30, 2013 with effective date
of October 30, 2013
DOT Regulatory Agenda
• PHMSA: Pipeline Safety regs at proposed rule stage:
– Safety of On-Shore Liquid Hazardous Pipelines
• Addresses hazardous liquid operators improving protection
of High Consequence Areas (HCA) and other vulnerable areas
• NPRM April 2014
– Issues with using Plastic Pipe in Gas Pipeline Industry
• Includes several issues regarding plastic pipe gas lines.
• NPRM April 2014
– Operator Qualification, Cost Recovery and other
Pipeline Safety Proposed Changes
• Affects renewal process for special permits, cost recovery for
design reviews, and incident reporting.
• NPRM November 2013
DOT Regulatory Agenda
• MARAD: Regulations To Be Followed by All Departments,
Agencies and Shippers Having Responsibility To Provide a
Preference for U.S.-Flag Vessels in the Shipment of
Cargoes on Ocean Vessels
– Would update and clarify the Cargo Preference rules that have
not been revised substantially since 1971.
– Next action is currently “undetermined”
Forms Update - APD / APM
• Application for Permit to Drill and Application
for Permit to Modify updates will include a
certification statement to state that false
submissions are subject to criminal penalties
• Minor APD modifications
• Comments on each are due by Feb. 3, 2014
New Form BSEE-0011 iSEE
• Internet-Based Safety and Environmental Enforcement
Reporting System
– Created to clarify the needed information when someone reports
an apparent violation
• Any person may report to BSEE any hazardous or unsafe
working condition on any facility engaged in OCS activities,
and any possible violation or failure to comply with:
– Any provision of the Act
– Any provision of a lease, approved plan, or permit issued under the
Act,
– Any provision of any regulation or order issued under the Act, or
– Any other Federal law relating to safety of offshore oil and gas
operations
• Comments due January 17, 2014
OSHA Injury Reporting Proposed Rule
• To require DIRECT electronic submission of
workplace injury / illness data to OSHA “or its
designee” (i.e. BSEE / form BSEE-0131)
– Expands OSHA’s current direct collection abilities
– Data is already tracked by employers (this won’t
change), but is only accessed during inspections
– 3 new requirements:
• > 250 employees = quarterly e-submission of info
• > 20 employees AND in certain industries = annual esubmission via form 300A to replace annual survey
• E-submit injury / illness data as requested by OSHA
Extension of Prior Notices to Lessees
• Two NTLs previously extended until the end of
calendar year 2013 (NTL No. 2013-G02) are
being extended again until June, 30, 2014.
– NTL 2008-G04 provides guidance on the
information requirements for OCS plans required
by 30 CFR 550, subpart B, and
– NTL 2008-G05 describes the shallow hazards
program, which was designed to ensure that
exploration, development, production, and
transportation operations are conducted with a
minimum risk to human life and the environment.
Upcoming Regulations
• Mike Saucier (BSEE) listed upcoming regulations
at the December OOC Meeting:
– Blowout Prevention Systems (in preparation, due out
early 2014)
– Arctic regulations (joint with BOEM)
• Upcoming proposed rules:
– Suspensions of Production and Operations
– Natural Gas Fluids Measurement
– Oil Spill Mechanical Recovery
Deepwater Initial EP Approval Times
Time Period
EP Avg. Approval
Time (Days)
Pre DWH
52
2010 (Post DWH)
234
2011
144
2012
121
2013
118
Down the Road
• January 28/29 – Hilton N.O. BSEE Standards Workshop
• January 29 – USCG Sector New Orleans Area
Committee meeting
• March 19 – Central GOM Lease Sale 231 – N.O.
• March 19 – Eastern GOM Lease Sale 225 – N.O.
(following CGOM sale)
• April 9/10 – Center for Offshore Safety 2nd Annual
Forum
• June 4 - Must be in compliance with SEMS II
Thank you!
Lincoln Stroh
J. Connor Consulting, Inc.
281.578.3388
Lincoln.Stroh@jccteam.com