NOTICE TO LESSEES AND OPERATORS OF FEDERAL
OIL AND GAS LEASES
         IN THE PACIFIC OUTER CONTINENTAL SHELF REGION

Standby Testing Requirements During Air Pollution
Emergency Episodes

This notice supersedes NTL No. 00-P01 on this subject.

In keeping with the MMS policy of safe and environmentally sound offshore operations, we are providing Pacific OCS (POCS) operators with policy regarding potential air emission abatement measures. 

The local air agencies require planning actions to reduce the emissions of air contaminants from stationary sources during exceptional air pollution events.  This is in response to emission abatement measures required by the State of California, as administered by the local air agencies to protect public health in the advent of a second- or third-stage emission episode. POCS operators are required to develop emission abatement measures to reduce emissions when episodes are predicted or attained.  These measures are included in "Emergency Action Plans" as submitted to local air quality agencies subject to approval by the Air Pollution Control Officer.

MMS provides the suspension of certain testing requirements for standby equipment during these emergency health episodes.  The suspension allows POCS operators the ability to curtail stationary source emissions during the testing of standby equipment and pressure safety relief valves within your facilities according to the measures contained in your required emergency abatement plans. Standby equipment is defined in relation to emergency emission episodes as equipment which is only operated in a temporary or emergency mode. MMS will suspend any testing of standby equipment and safety relief valves as required by us for the duration of second- and third-stage emergency episodes to reduce public exposure to unhealthful air pollution concentrations.

MMS authorizes pre-approval for you to delay the subject testing described in the emission abatement measures you submit to the air agencies.  This delay in testing will be in effect for the duration of the emergency episode.  We authorize this pre-approval if POCS operators who are required to submit the subject Emergency Action Plans to the local air quality agencies also provide us with a copy of the subject plan.  We can then address any safety concerns with the proposed abatement measures prior to the event of an air pollution episode to ensure that such abatement measures do not jeopardize safe platform operations.

POCS operators should take air quality conditions into consideration when finalizing schedules for equipment testing. Most MMS testing requirements allow for flexibility within the prescribed time frames, so operators should be able to meet those requirements without suspension/post­ponement. MMS believes it to be the responsibility of the operators to meet such requirements.

Paperwork Reduction Act of 1995 Statement:  The Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.) requires us to inform you that MMS collects information requested in this NTL to ensure safe and prudent offshore operations.  No proprietary information will be collected.  Responses are voluntary.  The Office of Management and Budget (OMB) approved the infor­mation collection under OMB Control Number 1010-0059.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The reporting burden is estimated to average 1 hour per response.  Direct comments regarding the burden estimate or any other aspect of this collection of information to the Information Collection Clearance Officer, Mail Stop 4230, Minerals Management Service, Department of the Interior, 1849 C Street, NW., Washington, DC 20240.

If you have any questions or need clarification regarding the NTL, please contact the Office of District Operations at (805) 389-7777.