250.300(a), (b)(6), (c), (d); NTL - Annual Report

UNITED STATES DEPARTMENT OF THE INTERIOR

BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT

GULF OF MEXICO OUTER CONTINENTAL SHELF REGION

Effective Date: August 8, 2013

BSEE NTL No. 2013-G03

NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL, GAS, AND SULPHUR

LEASES IN THE OUTER CONTINENT AL SHELF (OCS), GULF OF MEXICO OCS

REGION

Pollution Inspection Intervals for Unmanned Facilities
Purpose
This Notice to Lessees and Operators (NTL) supersedes NTL No. 2008-G03, dated April 14,
2008. It clarifies current policy by describing how District Managers will determine the
appropriate intervals for the pollution inspection you conduct for unmanned facilities and by
explaining that you may conduct some of these inspections "visually" instead of by
physically boarding the facility.

Authority
According to 30 CFR 250.301, you must inspect production facilities daily or at intervals
approved or prescribed by the District Manager to determine if pollution is occurring. Under
this authority, the appropriate Gulf of Mexico OCS Region (GOMR) District Manager will
use the following point system matrix and evaluation code to determine the pollution
inspection interval for an individual unmanned facility.

Pollution Inspection Matrix
VALUE
Distance of facility to
nearby manned platforms
Distance of facility to
shoreline or sensitive area
Capacity of hydrocarbon
storage tanks on facility
General direction of
currents
Supervisory Control And
Data Acquisition
(SCAD A) or other
continuous monitoring

10 Points

20 Points

30 Points

40 Points

50 Points

20 miles

>60 miles

31-60 miles

21 -30 miles

10-20 miles

<10miles

<20 bbls

20-75 bbls

76-100 bbls

101-125 bbls

>125 bbls

Away from
shoreline
All operating
conditions;
shut-in (SI)
capability

Pressures,
levels, etc. ;
no SI
capability

Parallel to
shoreline
Pressures
only

Towards
shoreline
Not
monitoring
anything

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VALUE

10 Points

20 Points

30 Points

40 Points

50 Points

Product

Dry gas
or <10
Barrels of
Condensate
per Day
(BCPD)
or100
BCPD

Gas and
<100 BOPD

>100 BOPD
or >20 parts
per million
(ppm)
Hydrogen
Sulfide (H 2 S)

No pollution
incidents
c umul atively
>I bbl

One or more pollution incidents cumu lative ly > I bbl is 200
points

One or more pollution
incidents cumu latively >I
bbl in the 2 years before
the request date

,

Evaluation Code
Points

Inspection Interval

Physical Boarding
Inspection Inter val

70-100
110-150
160-200
210-250
260+

Bi-weekly
Weekly
Every three days
Every other day
Daily

Bi-weekly
Weekly
Weekly
Weekly
Weekly

Exceptions
1. The BSEE GOMR will not approve an increase in the prescribed daily pollution
inspection interval until production has been established on the facility for a period of 7 days
for a minor platform and 30 days for a major platform. For purposes of this NTL, a major
platform is a structure with either six or more completions or zero to five completions with
more than one item of production process equipment. A minor platform is a structure with
zero to five completions with one item of production process equipment.
2. When all of the wells on an unmanned facility (a) are disconnected from production
facilities and blind flanged; (b) are equipped with a tubing plug; or (c) have their master
valves locked closed, and you have drained the hydrocarbons from all of the tanks and
vessels, the appropriate GOMR District Manager may approve a pollution inspection interval
of up to 1 month. Perform this monthly inspection by physically boarding the facility.
3. The appropriate GOMR District Manager will not approve an increase in the
prescribed daily pollution inspection interval if your facility is producing, processing, or has
the capacity of storing more than 400 barrels of liquid hydrocarbons per day.
4. The appropriate GOMR District Manager may rescind an approval for an increase in
the prescribed daily pollution inspection interval if a pollution incident involving a spill
greater than one barrel subsequently occurs at the facility.

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5. When you perform a "physical boarding" inspection, ensure that you inspect each
deck of the facility with an emphasis on major components. Indicate the date of each
"physical boarding" inspection in your records .
6. For "visual" inspections, fly-over inspections are acceptable provided the personnel
on the aircraft can identify evidence of pollution on the surface of the water. Visual
inspections utilizing binoculars to see from one platform to another are not acceptable.
7. If there is a substantial change in the conditions under which the GOMR District
Manager approved an increase in the prescribed daily pollution inspection interval, the
GOMR District Manager may withdraw approval of the increase.

Guidance Document Statement
The BSEE GOMR issues NTLs as guidance documents in accordance with 30 CFR 250.103
to clarify or provide more detail about certain BSEE regulatory requirements and to outline
the information you must provide in your various submittals. Under that authority, this NTL
sets forth a policy on and an interpretation of a regulatory requirement that provide 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 BSEE GOMR office under the terms set forth in 30 CFR 250.141.

Paperwork Reduction Act of 1995 Statement
The information collection referred to in this NTL provides clarification, description, or
interpretation of requirements contained in 30 CFR 250, Subpart C . The Office of
Management and Budget (OMB) approved the information collection requirements for this
regulation and assigned OMB Control Number 1014-0023. This NTL does not impose any
additional information collection requirements subject to the Paperwork Reduction Act of
1995.

Contacts
If you have any questions regarding this NTL, please contact the Production Engineer in the
appropriate GOMR District Office.

Lars Herbst
Regional Director