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OMB Approval Number: 1010-0050
OMB Expiration Date: January 31, 2006
UNITED STATES DEPARTMENT OF THE INTERIOR
MINERALS MANAGEMENT SERVICE
GULF OF MEXICO OCS REGION
| NTL No. 2004-G18 |
Effective Date:
October 4, 2004
Expiration Date: June 30, 2004 |
NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL, GAS,
AND SULPHUR LEASES AND PIPELINE RIGHT-OF-WAY HOLDERS
IN THE OUTER CONTINENTAL SHELF, GULF OF MEXICO OCS REGION
Damage
Caused by Hurricane Ivan
The Minerals Management Service (MMS) Gulf of Mexico OCS
Region (GOMR) is issuing this Notice to Operators and Pipeline Right-of-way
Holders (NTL) pursuant to 30 CFR 250.103 and 30 CFR 250.106(b) and (c) to
describe the inspections you need to conduct and the plans and reports you need
to prepare because of the known and potential damage to OCS facilities caused by
Hurricane Ivan when it struck land on September 16, 2004.
OCS Platforms and Structures
Pursuant to 30 CFR 250.912(a), you must periodically
inspect OCS platforms and structures (platforms) in accordance with the
provisions of American Petroleum Institute Recommended Practice 2A-WSD,
Twenty-First Edition (API RP 2A-WSD), Section 14, Surveys.
Subsection 14.4.3 of API RP 2A-WSD requires that you
conduct a Level I survey (above-water visual inspection) of the platform after
direct exposure to a design environmental event (e.g., hurricane). Therefore,
you must perform a Level I survey on all platforms that were exposed to
hurricane force winds (74 miles per hour (mph) or greater) from Hurricane Ivan.
Subsection 14.3.2 of API RP 2A-WSD requires you to conduct
a Level II survey (general underwater visual inspection by divers or remotely
operated vehicle (ROV)) of the platform when the Level I survey indicates that
underwater damage may have occurred. In addition, subsection 14.4.3 of API RP
2A-WSD requires you to conduct a Level II survey of the platform after severe
accidental loading, such as a large object (e.g., boat landing, sump, staircase)
being knocked loose and potentially causing structural damage to the platform as
it fell to the seafloor.
Subsection 14.3.3 of API RP 2A-WSD prescribes a Level III
survey (underwater visual inspection of areas of known or suspected damage) when
a Level II survey detects significant structural damage.
In light of these requirements and the numerous reports of
severe damage to platforms (both above and below the water line) along the path
of Hurricane Ivan, the MMS GOMR has determined that you must conduct the
following surveys:
|
Survey
Level |
Platform
Category |
|
I |
All platforms exposed to winds speeds greater than 74
mph. |
|
II |
All platforms located within 35 miles of Hurricane
Ivans eye center storm track (see Attachment A of the NTL for a map of the
described area). |
|
III |
All platforms that experienced wave loading on the deck
and where Level II survey results prescribe Level III surveys. |
Begin immediately
to conduct the required surveys of the affected platforms. We encourage you to
inspect first the older platforms located nearest the eye center storm track,
and then gradually inspect those platforms toward the outer limits of the
described area. Complete all inspections/surveys by May 1, 2005. Complete all
work to correct any damage you find during a platform inspection before June 1,
2005.
Make every attempt to complete the required underwater
inspections before you man any of the affected platforms. If it is
operationally impractical for you to wait to complete the inspections before you
man an affected platform, make sure that you:
a.
Develop a detailed, comprehensive around-the-clock weather monitoring
plan;
b.
Comply with U.S. Coast Guard regulations regarding ingress/egress to the
boat landing; and
c.
Provide a 24-hour stand-by boat with full radio communications between
the boat and the platform.
In addition, if your Level II or Level III surveys find
structural damage, do not man the platform until you complete a structural
analysis and perform any necessary repairs. Please be reminded that 30 CFR
250.900(e) requires you to obtain approval from the MMS GOMR before you make
major repairs of any damage.
The MMS is currently working to obtain emergency approval
from the Office of Management and Budget (OMB) to collect reports from you on
inspections on the structures that are located in the area affected by Hurricane
Ivan. After this approval is obtained, the MMS GOMR will likely issue an NTL
that will require you to submit the following information:
a. A list of platforms affected by the
hurricane;
b. An initial inspection plan for each
platform;
c. A timetable that shows you will complete
each inspection by May 1; and
d. Inspection reports.
These information collection requirements are very similar
to those required by MMS GOMR after Hurricane Lili damaged OCS structures in the
Gulf of Mexico (NTL No. 2003-G04).
OCS Pipelines
Pursuant to 30 CFR 250.1005(a), you must conduct
inspections of pipeline routes at intervals and using methods prescribed by the
MMS. Under this authority, and because of the numerous reports of severe damage
to OCS pipelines along the path of Hurricane Ivan, the MMS GOMR hereby directs
you to conduct the following inspections by May 1, 2005:
1. Pipeline Tie-in
Inspections - Conduct an underwater visual inspection using divers or ROV, a
scanning sonar processor, or a 500-kHz sidescan sonar in combination with a
magnetometer to inspect each of your OCS pipeline tie-ins located within the
corridor between 89º 30 W longitude and 87º 30 W longitude (see Attachment B
of this NTL for a map of the described area). Design each inspection to
determine whether any valves or fittings became exposed and to determine the
extent of any damage, including damage to protective devices, mats, and
sandbags.
2. Pipeline Riser
Inspections - Conduct a visual inspection of the above-water portion of each
pipeline riser located within the corridor between 89º 30 W longitude and 87º
30 W longitude (see Attachment B of this NTL for a map of the described area).
If applicable, conduct this riser inspection in conjunction with the required
platform Level I survey described above. Inspect the riser and riser clamps for
damage. If this inspection indicates that damage may have occurred, conduct an
underwater riser and pipeline inspection described in Item No. 4 below (if you
are not already required to do so) to determine if the pipeline has been
displaced or exposed.
3. Pipeline Steel Catenary Riser
Inspections - Conduct an inspection using divers or ROV of the underwater
portions of each of your OCS pipeline steel catenary risers located within the
corridor between 89º 30 W longitude and 87º 30 W longitude (see Attachment B
of this NTL for a map of the described area). Inspect the riser, vortex-induced
vibration (VIV) suppression devices, and the connection point (flexible element,
titanium stress joint, etc.) to the structure for damage.
4. Underwater Riser and Pipeline
Inspections - Conduct a visual inspection using divers or ROV, a scanning
sonar processor, or a 500-kHz sidescan sonar in combination with a magnetometer
to inspect the underwater portions of each of your OCS pipeline risers and
adjacent pipelines located in water depths between 200 feet and 500 feet within
the corridor between 89º 30 W longitude and 87º 30 W longitude (see Attachment
B of this NTL for a map of the described area). If applicable, conduct this
riser and pipeline inspection in conjunction with the required platform Level II
surveys described above. Inspect the riser and riser clamps for damage.
Inspect the pipeline for evidence of displacement or exposure from the base of
the riser along the entire length of the pipeline.
5. Remedial Action - If
an inspection indicates (a) factors that could detrimentally affect the
performance or integrity of pipeline valves and fittings at a tie-in, (b)
conditions that could cause interference with navigation or other uses of the
OCS, (c) riser or riser clamp damage, or (d) that a
pipeline has been displaced, exposed, or damaged, submit a plan of corrective
action, pursuant to the requirements of 30 CFR 250.1008(g), by mail to the GOMR
Pipeline Section (MS 5232) or by e-mail to
elizabeth.komiskey@mms.gov for approval within
30 days after completing the inspection. Within 30 days after you complete the
work, submit a written report indicating that the repairs were performed as
proposed, confirming the type and/or cause of damage, and including the results
of any pressure tests by mail to the GOMR Pipeline Section (MS 5232) or by
e-mail to
elizabeth.komiskey@mms.gov. Complete all work
requiring corrective action before June 1, 2005.
6. Additional inspections. If you
suspect that Hurricane Ivan may have damaged a pipeline or related structure
that is located outside the corridor between 89º 30 W longitude and 87º 30 W
longitude (see Attachment B of this NTL for a map of the described area),
conduct the appropriate inspections described in Items Nos. 1, 2, and 4 above
and, as appropriate, submit a plan of corrective action as described in Item No.
5 above.
If you havent already done so, perform a leak test before
you return to service any pipeline located within the corridor between 89º 30 W
longitude and 87º 30 W longitude (see Attachment B of this NTL for a map of the
described area). Make sure that the leak test successfully tests the integrity
of the pipeline. A successful leak test means no unobservable leakage during
the test period. When you conduct a leak test, make sure that you use a
stabilized pressure that is capable of detecting all leaks; use pressure gauges
and recorders that are sufficiently accurate to determine whether the pipeline
is leaking during the test; and conduct the test for at least two hours during
daylight hours. For major oil pipelines, provide aerial surveillance of the
pipeline route while you perform the test.
Paperwork Reduction Act of 1995 Statement
The Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3504
et seq.) requires us to inform you that the MMS collects this
information to carry out its responsibilities under the OCS Lands Act, as
amended. The MMS will use the information to determine if the structural
integrity of platforms and pipelines may have been adversely affected by
Hurricane Ivan, if any damage poses a threat to continued safe operations or the
environment, and, if so, whether to require correction action on damaged
structures. Responses are mandatory. No proprietary data are collected. An
agency may not conduct or sponsor, and a person is not required to respond to, a
collection. There is no new reporting burden in this NTL. Reporting
requirements in this NTL are per current regulations at 30 CFR 250 1008(g). The
OMB has approved the collection of information and assigned OMB control number
1010-0050. Direct any 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, N.W., Washington, D.C. 20240.
Contacts
Please address any questions regarding platform inspections
or reports to Mr. Tommy Laurendine of the GOMR Office of Technical and
Structural Support by telephone at (504) 736-5709 or
by e-mail at
tommy.laurendine@mms.gov and questions
regarding pipeline inspections or reports to Ms. Elizabeth Komiskey of the GOMR
Pipeline Section by telephone at (504) 736-2418 or by e-mail at
elizabeth.komiskey@mms.gov.
Chris C. Oynes
Regional Director
Attachments
(Attachments included in the available PDF file. See link at top of
this page)
