Initial purchase and installation of tracking/locator devices

UNITED STATES DEPARTMENT OF THE INTERIOR
MINERALS MANAGEMENT SERVICE
GULF OF MEXICO OCS REGION

NTL No. Effective Date: June 01, 2009

Expiration Date:  

NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL AND GAS LEASES IN THE
OUTER CONTINENTAL SHELF (OCS), GULF OF MEXICO OCS REGION

Global Positioning System (GPS) for Mobile Offshore Drilling Units (MODU)

This Notice to Lessees and Operators (NTL) provides guidance and requirements for:

1. Outfitting all moored MODUs and jack-ups with multiple GPS transponders;

2. Providing MMS realtime GPS location data; and

3. Sending appropriate notification to MMS.

All GPS transponders must be installed and operational prior to July 01, 2009.

This NTL is issued pursuant to 30 CFR 250.103 and provides guidance and requirements under §§ 250.106(c), 250.107(d), 250.280(b), and 250.417. Specifically, under:

• The performance standards of §§ 250.106 and 250.107 MMS is obligated to prevent damage to, or waste of, any natural resource, property, or the environment by requiring the best available and safest technology.

• § 250.280(b) post-approval requirements for the EP, DPP, and DOCD requires lessee and operator responsibility to take appropriate measures to meet emergency situations.

• § 250.417 MMS requires lessees and operators using MODUs to demonstrate that the drilling unit is capable of performing at the proposed drilling location.

Background

The effects of several hurricanes in the past few years have been detrimental to oil and gas operations in the OCS. These effects included structural damage to fixed production platforms, platform rigs, semi-submersibles, jack-up rigs, and other equipment and facilities. Moreover, a major concern for MMS is the problem of MODUs being moved off location by a storm event. If a MODU is displaced by a storm event, there are potentially serious consequences of striking or damaging other facilities, pipelines or vessels. In March 2009, there was an incident involving a large oil tanker striking a missing jack-up that had drifted off location and sunk during Hurricane Ike in 2008. A GPS device provides a way to locate and track a displaced MODU during and after a storm event. This NTL only involves the aspect of using realtime GPS tracking while the rig is still afloat; however, in the future it is MMS’ intent for you to provide rig location if your rig has sunk. There are various new technologies whereby you may be able to locate a sunken rig. Having both the GPS realtime data and sunken rig location will provide a valuable tool to prevent future incidents involving lost or sunken rigs.

Scope

Each moored MODU and jack-up must be outfitted with multiple GPS transponders. Each MODU must be equipped with a GPS system that provides a robust and reliable means of monitoring the position and tracking the path in realtime in the event that the MODU moves from its location during a severe storm. The tracking systems’ equipment should be located and protected such that the risk of the system being disabled by storm damage is minimized. Consideration should be given for installing the equipment so the system could continue to transmit the current position as long as possible. Multiple GPS transponders should be placed in different locations for redundancy and to minimize risk of system failure.

Each GPS transponder must be capable of transmitting data for at least 7 days after the storm has passed.

GPS Realtime Data Access

By June 01, 2009, you, or your drilling contractor must contact Lance Labiche at lance.labiche @mms.gov or by calling (504) 736-2433 with the information on how you are granting MMS realtime access to the MODU location GPS data.

If your MODU moves off location during a storm event you must immediately begin to record GPS location data and contact the MMS GOMR COOP office with the following information:

• Operator name;

• Contact information;

• Rig/facility/platform name;

• Initial date and time; and

• How you provided GPS realtime data access.

You must allow the MMS realtime access to the MODU location data.

MMS GOMR COOP Office contact information

To speak with someone in the MMS GOMR, COOP Office please call either (504) 736-5793 or

(504) 736-5794.

Guidance Document Statement

The MMS issues NTL’s as guidance documents in accordance with 30 CFR 250.103 to clarify, supplement, and provide more detail about certain MMS regulatory requirements and to outline the information you provide in your various submittals. Under that authority, this NTL sets forth a policy on and an interpretation of a regulatory requirement that provides a clear and consistent approach to complying with that requirement. However, if you wish to use an alternative approach for compliance, you may do so, after you receive approval from the appropriate MMS office under 30 CFR 250.141.

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 find and locate MODUs that are off location and to determine if other facilities/pipelines are in the path of any debris. Responses are required to obtain or retain a benefit. No proprietary data are collected. The Office of Management and Budget (OMB) has approved the collection of information pertaining to General requirements under 30 CFR 250, subpart A, 1010-0114. We estimate the reporting burden pertaining to this NTL to be 84 total burden hours for industry, and the non-hour cost burden to total $1,650,000. 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 Office of Management and Budget (OMB) control number. The OMB has approved the collection of information and assigned OMB Control Number 1010-xxxx. Direct any comments regarding the burden estimate or any other aspect of this collection of information to the Information Collection Clearance Officer, Mail Stop 5438, Minerals Management Service, Department of the Interior, 1849 C Street, NW, Washington, DC 20240.

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Contact

If you have any questions regarding this NTL, please contact Lance Labiche, (504)736-2433.

Lars Herbst

GOMR Regional Director

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