Development of a Regulatory Compliance Plan for Incorporation of USCG Requirements into the Genesis SPAR Topsides Design

Abstract

Abstract This paper focuses on the development of the regulatory compliance plan in regard to working directly with the USCG to satisfy the requirements for the Genesis SPAR topsides facility. It summarizes the processes that were developed and implemented to: identify the specific areas of jurisdiction by the USCG, identify the requirements and clarify areas of uncertainty, ensure requirements were incorporated, and establish a plan for design submittal and approval. Authors focus on examples of the processes implemented and suggest lesson learned to assist future projects. Introduction The regulatory effort for the Genesis project had three key areas: SPAR hull, drilling rig and topsides facility, each of which had a unique regulatory strategy. The regulatory effort for the spar hull, although not classed, was handled by a third party classification agency. The drilling rig was to be a converted platform rig and a third party with MODU (mobile offshore drilling unit) experience was to provide regulatory support to the drilling team. The strategy for the topsides design was to work directly between the topsides team and the USCG to obtain necessary approvals. At the time of establishment of the topsides regulatory team, the following characterized the status of the effort:an aggressive project schedule in which detailed design and procurement had begun,a client and contractor team experienced in oil and gas facilities design, but virtually no experience in designing a USCG compliant facility,limited industry information that was available or could be shared on this certification path, andanxiety regarding the significant uncertainty as to the project cost and schedule impact. Establishment of Regulatory Team The initial step was to establish a core person or team to manage the regulatory effort. Ideally, the skill set required consisted of knowledge of regulatory processes and agencies, technical knowledge of facilities design, and knowledge of detailed requirements for floating systems; however, this combination of skills was not available in a single individual(s). Given the constraints, the team organization makeup and organization worked very effectively and progressed as follows. Initially, two company personnel with technical facilities design experience co-located with the company-contractor design team. The initial regulatory effort was divided along their areas of expertise:instrumentation and electrical,mechanical, architectural and structural. They worked to establish a regulatory plan integral with the design plan and focused on understanding and identifying USCG requirements applicable to the topsides. As shown in Figure 1, to supplement the lack of experience in floating systems and USCG requirements, consultants were brought in that had design experience in the shipping industry and with MODUs. Company personnel with a regulatory background were used to support the effort and establish contacts with the USCG. After the regulatory effort moved from incorporation of design requirements to submittals and then final approvals, the company regulatory personnel played an increasing role until they became the focal point for management of the regulatory effort and the technical resources were phased out.