CHAPTER 11 REGULATORY REQUIREMENTS FOR ACQUIRING AND OPERATING OCS PROPERTIES

• Jurisdiction: United States

Oil and Gas Development on the Outer Continental Shelf
(Oct 1998)
CHAPTER 11
REGULATORY REQUIREMENTS FOR ACQUIRING AND OPERATING OCS PROPERTIES
Craig Wyman
Liskow & Lewis
New Orleans, Louisiana

MAJOR TOPICS

• OCS Report MMS 96-0039

• SEMP developments

• Inspections, INCs, and Penalties

• SOOs and SOPs

[Page 11-2]

OCS REPORT MMS 96-0039

"REGULATORY COMPLIANCE FOR OCS OIL AND GAS OPERATIONS"

• Materials contain MMS document plus regulations, NTLs, LTLs, and forms

• Document covers all aspects of acquisition and development from initial leasing of tract to lease termination and P&A

• Other agency requirements, e.g., EPA and Coast Guard, also briefly indicated

• Rote listing of lease blocks subject to archaeological review or military stipulations omitted from materials

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MMS COMMUNICATIONS WITH ITS LESSEES

• Rulemakings

• Notices to Lessees

• Letters to Lessees

[Page 11-4]

• Safety Alerts

• Workshops/Conferences

• Federal Register Announcements

• Technical Announcements

• News Releases

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NTLs AND LTLs, OTHER INFORMATION ALSO ACCESSIBLE AT WWW.MMS.GOV

• Regular updates of 96-0039 materials strongly recommended

• Texas has since received authority to administer local coastal zone management program

• Replacement of NTL 93-IN with new 30 C.F.R. Part 253 (B-COFR)

• Replacement of NTL 83-03 with NTL 98-20 (B-Shallow Hazards Survey)

• Replacement of NTL 91-02 with NTL 98-06 (B-Archaeological Reports)

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• Replacement of NTL 89-01 with NTL 98-12 (B-Drill Cuttings Discharges-ABCs)

• Replacement of NTL 86-09 with NTL 98-21 (C&I-POE and DOCD)

• Replacement of LTL 8/25/95 with NTL 97-16 (F-wells 500 feet from lease line)

• Replacement of NTL 90-09 with NTL 98-19 (F-TA)

• Addition of NTL 98-11N and 98-15 (H)

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• Addition of NTL 98-14N (I-DOCD)

• Replacement of NTL 96-4N with NTL 98-8N (I-DWOP)

• Replacement of NTL 94-03 with NTL 97-05 (I-Structure Application)

• Addition of NTL 98-7N (N-Platform Inspection)

• Addition of NTL 98-13N (P)

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NTL 98-9N

• 63 Fed. Reg. 29477, May 29, 1998 — "Redesignation" rule

• Redesignation of 30 C.F.R. § 250

• Effective date June 1, 1998

• Implementation period extended until 12/31/98

• Listing of "documents incorporated by reference redesignated sections" omitted from materials

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SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAM ("SEMP")

• Program first announced in 1991

• Series of workshops and other communications (e.g., LTLs, Fed. Reg.) with industry over the last several years

• Designed to prevent accidental releases and promote general improvements in environmental and safety compliance

• Data collection began January 1, 1998

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SEVERAL MEASUREMENTS OF PERFORMANCE

• Separate tracking of injury and incident rates for production, drilling, and construction operations

• Both company's and contractor's total recordable hours divided by lost work days

• MMS will still look first to the lessee for primary responsibility

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• Fire and explosion incident rates

• Blowout incident rates

• NPDES water discharge permit exceedances

• Oil spill incident rates (for both > one barrel and < one barrel)

• INC rates for production operations

• INC rates related to drilling/workover/completion/P&A operations

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NOTICE TO LESSEES NO....