U.S. Department of the Interior Minerals Management Service Gulf of Mexico OCS Region

Minerals Management Service Publishes Proposed Rule to Incorporate into Its Regulations
Nine Industry Standards Related to Floating Production Systems;
Extends Comment Period

The U.S. Department of the Interior's (DOI) Minerals Management Service (MMS) announced today the publication of a Notice of Proposed Rulemaking (NPR) to incorporate by reference into MMS regulations eight American Petroleum Institute (API) standards and one American Welding Society (AWS) standard. Incorporating these standards will enhance MMS's ability to permit floating offshore platforms that have not been specifically covered under its existing regulations. Floating offshore platforms, also known as floating production systems (FPS’s), include column-stabilized-units (CSU’s); floating production, storage and offloading systems (FPSO’s); tension-leg platforms (TLP’s); and spars.

Several years of cooperative efforts between MMS, API, and the offshore industry provided the opportunity to develop reasonable standards for offshore developments. Publication of these documents represents the industry and Government consensus for design, manufacture, installation, and operation of floating production systems and many of their components. Carolita Kallaur, MMS Associate Director for Offshore Minerals Management, states: "These specific standards were identified as critical to the continued success of deepwater developments that rely on floating production systems." The incorporation of these standards benefits all stakeholders in the development of deepwater. "Industry assumes the high financial risks of developing deepwater areas; this effort would provide certainty in the regulatory expectations for equipment and systems used in deepwater developments. These documents also improve MMS engineers’ efforts in reviewing each new project to ensure structural integrity, operational and human safety, and environmental protection," according to Ms. Kallaur. Incorporating these specifications and recommended practices (collectively referred to as standards) would also save the public the cost of developing Government-specific standards.

The standards to be incorporated by reference into MMS regulations include:

1. API Recommended Practice 2A (API RP 2A)—WSD, Recommended Practice for Planning, Designing and Constructing Fixed Offshore Platforms—Working Stress Design; Twenty-first Edition, December 2000, API Order No. G2AWSD. The 21st edition of API RP 2A provides the rationale for revising much of the "Platforms and Structures" regulations contained in 30 CFR 250 Subpart I. With the incorporation of the 21st edition, we can eliminate much of the verbiage in the current subpart I regulations. This notice of proposed rulemaking substantially revises and reorganizes Subpart I to eliminate prescriptive and duplicative requirements. This proposed revision of Subpart I also includes language specific to FPS’s.
   
2. API RP 2T, Recommended Practice for Planning, Designing, and Constructing Tension Leg Platforms, Second Edition, August 1997, API Order No. G02T02. Every TLP installed in the Gulf of Mexico OCS to date has relied on API RP 2T. There are currently eleven TLP installations in deepwater areas of the Gulf.
   
3. API RP 2RD, Design of Risers for Floating Production Systems (FPSs) and Tension-Leg Platforms (TLPs), First Edition, June 1998, API Stock No.G02RD1. This standard covers both production and pipeline riser systems on FPS’s, which have not been explicitly covered under MMS regulations.
   
4. API RP 2SK, Recommended Practice for Design and Analysis of Stationkeeping Systems for Floating Structures, Second Edition, December 1996, Effective Date: March 1, 1997, API Stock No. G02SK2. This document covers the design and analysis for steel wire and chain mooring systems used on offshore floating structures.
   
5. API SPEC 17J, Specification for Unbonded Flexible Pipe, Second Edition, November 1999, Effective Date: July 1, 2000, API Stock No. G17J02. The application of flexible pipe in deepwater is increasing, particularly for pipeline and flowline applications associated with subsea well developments. Industry sources project that half of future deepwater wells will be remote subsea wells tied back to existing production facilities.
   
6. API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, First Edition, Sept. 1, 1993, API Stock No. 811-07200. API RP 14J provides flexibility by identifying numerous methods for conducting a hazard analysis. Deepwater FPS’s are typically the most complex systems on the OCS, combining new technologies and extending the capabilities of existing technologies to achieve economic development. These FPS’s also combine marine equipment and operations with industrial systems and processes that increase the hazards on the OCS facilities. The integration of API RP 14J into regulations allows MMS and industry to be assured that an FPS can operate safely in the GOM.
   
7. AWS D3.6M: 1999, Specification for Underwater Welding. AWS D3.6M is the primary document the industry follows for underwater welding repairs.
   
8. API RP 2FPS, Recommended Practice for Planning, Designing, and Constructing Floating Production Systems, First Edition, March 2001, API Stock No.G2FPS1). RP 2FPS serves as an “umbrella document” for all floating production systems, except for TLP’s (addressed by RP 2T, which is also proposed for incorporation).
   
9. API RP 2SM, Recommended Practice for Design, Manufacture, Installation, and Maintenance of Synthetic Fiber Ropes for Offshore Mooring. This document is a companion to RP 2SK, addressing the use of synthetic fiber ropes for mooring offshore floating drilling and production systems. It focuses on the differences between synthetic fiber moorings and the conventional steel moorings.

We will consider all comments we receive by March 27, 2002. We will begin reviewing comments then and may not fully consider comments we receive after March 27, 2002. If you wish to comment, you may submit your comments by any one of several methods. You may mail or hand-carry comments (three copies) to the Department of the Interior; Minerals Management Service; Mail Stop 4024; 381 Elden Street; Herndon, Virginia 20170-4817. Attention: Rules Processing Team. Because the Department has been enjoined by court order from remaining connected to the Internet, it is not possible at this time to submit comments by e-mail. For additional information on the subject matter of this announcement, please contact Carl Anderson, physical scientist, at (703) 787-1608, or Joseph Levine, chief, Operations Analysis Branch, at (703) 787-1033 or fax (703) 787-1555.

MMS is the Federal Agency in the U.S. Department of the Interior that manages the Nation's oil, natural gas, and other mineral resources on the Outer Continental Shelf in Federal offshore waters. The Agency also collects, accounts for, and disburses million revenues from Federal and Indian leases. These collections total nearly 8 billion last year and more than 110 billion since the Agency was created in 1982. Annually, nearly 1 billion from those revenues go into the Land and Water Conservation Fund for the acquisition and development of the state and Federal park and recreation lands.

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