Fixed Platform Inspection Process: A Regulatory Perspective

Abstract

Abstract Of approximately 330 recorded fixed platforms, 103 are listed as manned in the Galveston Marine Inspection zone. This zone includes all of Galveston and High Island Blocks, and portions of Brazos, East Breaks, Garden Banks, Alaminos and Keathley Canyon. Twenty-percent oversight inspections of both manned and unmanned platforms are being conducted to ensure the self-inspection program is meeting the intent of the regulations. This implementation of the Outer Continental Shelf (OCS) Lands Act (43 U.S.C. 1331 amended in 1978) is intended to further the promotion of safety of life and property on the OCS and the protection of the marine environment. Deficiencies that are noted during each inspection are being documented and owners and operators are normally allowed up to 30 days for correction: however, if items are of a lifesaving nature, less time may be allowed. This paper will cover the Coast Guard's regulating authority and objectives, the inspection process and common deficiencies found aboard regulated oil and gas production/exploration facilities. Requirements concerning CG-5432 "Annual Self Inspection Reports" and Emergency Evacuation Plans (EEPs) will also be reviewed. 33 CFR 140 through 33 146 and 33 CFR 151.57 are applicable to most fixed platforms on the OCS and will be discussed. Newly proposed regulations for "Subchapter N - OCS Activities" are still in development by the Coast Guard and requests for comments for these regulations have been extended until the end of this year. This paper will not cover these new regulations. Introduction Of the approximately 4000 fixed platforms that are established in the Gulf of Mexico under the oversight authority of the U. S. Coast Guard, 330 are in the Houston - Galveston area and fall under the regulatory purview of the Officer In Charge, Marine Inspection, Houston-Galveston Marine Safety Zone. This zone includes not only all the Galveston and High Island Blocks, but portions of Brazos, East Breaks, Garden Banks, Keathley, and Alaminos Canyon as well1. To promote safety of life and property on the Outer Continental Shelf (OCS), protect the marine environment, and implement the OCS Lands Act (43 U.S.C. 1331 et seq.) as amended in 1978, a number of federal agencies are tasked with the enforcement of federal regulations specifically addressing fixed platform facilities. The Code of Federal Regulations (CFR) comprises the regulatory framework. In those instances of federal agency jurisdictional overlap, interagency agreements serve to further define the application of each agency's oversight responsibilities. Regulating Authority & Objectives Regulating Authority. The responsibility of the U. S. Coast Guard with respect to OCS activities is derived from the Outer Continental Shelf Lands Act (43 U.S.C. 1331 et seq.) as amended in 1978. This act, passed to bring under federal authority the establishment and enforcement of safety and environmental standards, defines the responsibilities of the U. S. Coast Guard with respect to the promotion of safety of life, property, and navigation. It furthers establishes, in part, the responsibility of the Minerals Management Service (MMS) to conduct oversight in areas of safety, as well as the management of mineral leasing activities on the OCS.