(April 2001)
The loss of the world’s largest floating deepwater
production platform, Petrobras’ P-36, last month off the coast of Brazil with
the loss of 10 men will reverberate throughout the oil industry for years to
come. We do not yet know what happened to the unit other than that there were
reported to be three separate explosions after which the unit took on severe
list of about 24 degrees and sank several days later. Was the unit unsafe? Was
it operated improperly? We do not yet know the answers and may never know all
the answers.
Here in the U.S., the USCG continues to go forward with the
regulatory project that would modify the rules on the US Outer Continental
Shelf (OCS). This rewrite of the OCS rules was proposed in December 1999 and
is probably another year away from the next publication either as another
proposed rule or as interim regulations.
There is something missing from the proposed rules
published. Licensed manning standards are not included.
There are no US manning regulations concerning how to man
these deepwater production units. Clearly, the UCSG has the authority under
the Outer Continental Shelf Lands Act amendments of 1978 to develop these
regulations. It could be said that the law requires the USCG to develop
manning regulations.
The Eighth CG District in New Orleans within whose
jurisdiction most of the US deepwater development projects take place has
stepped forward and developed manning requirements that fill the needs of
safety and the industry without being onerous.
As might be expected, the manning system is an out growth
of the existing regulations applicable to Mobile Offshore Drilling Units (MODUs)
but takes into account that the deepwater development projects are not
outgrowths of the drilling industry but rather are outgrowths of the offshore
oil production industry (of which the drilling industry is a subset).
The manning policy stems from over ten years of deepwater
development work and culminates in an 8th District Policy letter 03-2000,
ch-1, dated October 20, 2000. This letter is available on line under Policy
Letters at www.uscg.mil/d8/Divs/M/CCGD8M.HTM.
The manning scheme requires that units be staffed with
Offshore Installation Managers (OIMs) (equivalent to a ship’s Master), Barge
Supervisor (BS) (equivalent to Chief Mate), and two Ballast Control Operators
(BCOs) (equivalent to 3rd Mates), as well as a number of professional
unlicensed personnel.
These deepwater units are generally divided into two
categories: Those with active ballast systems and those with passive ballast
systems. A unit with an active ballast system is typically column stabilized
and semi-submersible. The stability (weights and moments) on these units must
be monitored very closely at all times and ballast shifted, added or
discharged on a regular basis to maintain the unit within the proper stability
operating window. On the other hand on a spar unit, which is basically a large
vertical cylinder, it is not necessary for stability purposes to continually
adjust the ballast condition because of shift in weights and changing moments.
This type unit is typically said to have a passive ballast system.
The USCG manning system recognizes that there are varying
design philosophies offshore and that deepwater units with passive ballast
systems need not necessarily have as many licensed personnel as those with
active ballast systems, wherein stability is a much more critical issue.
The manning system also takes into account that the old
requirement for Able Bodied (AB) Seamen and Ordinary Seamen (OS) for vessels
that do not navigate lacks rational justification. The USCG allows that
personnel who have received formal training in firefighting may be substituted
for the two ABs and one OS. This requirement seems to be particularly
insightful.
The policy also provides that licensed personnel on board
the unit who have been formally trained concerning lifesaving equipment and
are familiar with all lifesaving equipment on board are authorized to act as
lifeboatman in place of those personnel who have lifeboatman endorsed upon
their Merchant Mariners Document (MMD).
These licensed individuals must not be from among those
licenses that are required to be onboard the unit. They must be extra licensed
personnel. We believe that everyone would agree that personnel with deepwater
OIM, BS or BCO licenses are more familiar with the deepwater production unit
environment than would be someone who had sailed on ships for some years and
had earned a lifeboatman endorsement on their MMD.
One might well ask what all of this manning has to do with
the loss of the P-36. The answer is that the licensing and manning system used
in the US, albeit regional policy rather than federal regulations, goes a long
way toward preventing casualties such as the P-36.
The current policy does a great deal to build on the strong
points of the deepwater oil production industry and helps to avoid the
pitfalls of mandating that they use personnel not fully expert in the offshore
production environment. It appears that the USCG is on the right track in
developing personnel capable of avoiding tragedies like what happened to the
P-36.
The next step in US development is the use of Floating
Production Storage and Offloading facilities (FPSOs). While these units are
used world wide and have been used in the US, they are not currently
authorized. The Mineral Management Service is at a critical juncture
approaching an authorization to move forward with US FPSO development. We will
continue to watch this evolution with great interest.
