GCREAG Regulatory Update January, 2014

Lincoln StrohJ. Connor Consulting, Inc.

Key Topics

• BSEE Regulatory Agenda• USCG Regulatory Agenda• DOT Regulatory Agenda• Form / Information Collection Updates• Proposed, Final Regulations & New NTL• Deepwater Exploration Plan Approval Times

BSEE Regulatory Agenda

• BOPs– NPRM March 2014– Final Rule October 2014

• Production Safety Systems and Lifecycle Analysis– NPRM August 22, 2013– Comment Period Ended October 21, 2013– Final Action May 2014

USCG Regulatory Agenda• Proposed regulations to add new requirements

for lifesaving, fire protection, training, hazardous materials used as stores, and accommodation spaces

• Add standards for electrical and machinery installations in hazardous locations

• Provide regulations for DP systems • Provide for USCG acceptance and approval of

specified classification society plan reviews, inspections, audits, and surveys

• NPRM September 2014

USCG Regulatory Agenda• Nontank Vessel Response Plans requires owners or

operators of nontank vessels to prepare and submit oil spill response plans. Definition of nontank vessel:– Self-propelled vessels of 400 gross tons or greater that

operate on the navigable waters of the US– Carry oil of any kind for main propulsion that are not

tank vessels• Updates SOPEP requirements that apply to nontank

vessels and tank vessels• Final Rule September 30, 2013 with effective date

of October 30, 2013

DOT Regulatory Agenda• PHMSA: Pipeline Safety regs at proposed rule stage:

– Safety of On-Shore Liquid Hazardous Pipelines • Addresses hazardous liquid operators improving protection

of High Consequence Areas (HCA) and other vulnerable areas• NPRM April 2014

– Issues with using Plastic Pipe in Gas Pipeline Industry• Includes several issues regarding plastic pipe gas lines.• NPRM April 2014

– Operator Qualification, Cost Recovery and other Pipeline Safety Proposed Changes

• Affects renewal process for special permits, cost recovery for design reviews, and incident reporting.

• NPRM November 2013

DOT Regulatory Agenda• MARAD: Regulations To Be Followed by All Departments,

Agencies and Shippers Having Responsibility To Provide a Preference for U.S.-Flag Vessels in the Shipment of Cargoes on Ocean Vessels – Would update and clarify the Cargo Preference rules that have

not been revised substantially since 1971. – Next action is currently “undetermined”

Forms Update - APD / APM

• Application for Permit to Drill and Application for Permit to Modify updates will include a certification statement to state that false submissions are subject to criminal penalties

• Minor APD modifications • Comments on each are due by Feb. 3, 2014

New Form BSEE-0011 iSEE• Internet-Based Safety and Environmental Enforcement

Reporting System– Created to clarify the needed information when someone reports

an apparent violation

• Any person may report to BSEE any hazardous or unsafe working condition on any facility engaged in OCS activities, and any possible violation or failure to comply with:– Any provision of the Act– Any provision of a lease, approved plan, or permit issued under the

Act,– Any provision of any regulation or order issued under the Act, or– Any other Federal law relating to safety of offshore oil and gas

operations

• Comments due January 17, 2014

OSHA Injury Reporting Proposed Rule

• To require DIRECT electronic submission of workplace injury / illness data to OSHA “or its designee” (i.e. BSEE / form BSEE-0131)– Expands OSHA’s current direct collection abilities– Data is already tracked by employers (this won’t

change), but is only accessed during inspections– 3 new requirements:

• > 250 employees = quarterly e-submission of info• > 20 employees AND in certain industries = annual e-

submission via form 300A to replace annual survey• E-submit injury / illness data as requested by OSHA

Extension of Prior Notices to Lessees

• Two NTLs previously extended until the end of calendar year 2013 (NTL No. 2013-G02) are being extended again until June, 30, 2014. – NTL 2008-G04 provides guidance on the

information requirements for OCS plans required by 30 CFR 550, subpart B, and

– NTL 2008-G05 describes the shallow hazards program, which was designed to ensure that exploration, development, production, and transportation operations are conducted with a minimum risk to human life and the environment.

Upcoming Regulations

• Mike Saucier (BSEE) listed upcoming regulations at the December OOC Meeting:– Blowout Prevention Systems (in preparation, due out

early 2014)– Arctic regulations (joint with BOEM)

• Upcoming proposed rules:– Suspensions of Production and Operations – Natural Gas Fluids Measurement – Oil Spill Mechanical Recovery

Deepwater Initial EP Approval Times

Time Period EP Avg. Approval Time (Days)

Pre DWH 52

2010 (Post DWH) 234

2011 144

2012 121

2013 118

Down the Road

• January 28/29 – Hilton N.O. BSEE Standards Workshop• January 29 – USCG Sector New Orleans Area

Committee meeting• March 19 – Central GOM Lease Sale 231 – N.O.• March 19 – Eastern GOM Lease Sale 225 – N.O.

(following CGOM sale) • April 9/10 – Center for Offshore Safety 2nd Annual

Forum• June 4 - Must be in compliance with SEMS II

Lincoln StrohJ. Connor Consulting, Inc.

281.578.3388Lincoln.Stroh@jccteam.com

Thank you!