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Abstract This paper covers the development of the regulatory review, after the Macandoevent, for a speculatively built semisubmersible (a floating production unit[FPU]) - for operations in the U.S. Gulf of Mexico (GOM). The paper alsoaddresses the use of a classification agency to document the design andfabrication review of a unit constructed without a designated location, andfollowing identification of the designated location (Who Dat field in theMississippi Canyon block), the use of the agency to provide review reports tothe U.S. government. Additionally addressed is the use of the classificationagency to interface between the United States Coast Guard (USCG) and the Bureauof Ocean Energy Management Resources and Enforcement (BOEMRE) requirement withthe operator, LLOG Exploration. The paper also documents the changes and challenges dealing with developing andchanging regulations as the first unit to receive a full regulatory reviewfollowing the Macondo event. The changes in USCG and ABS's interpretation ofexisting rules and guidelines and changes to certain documentation requiredadditional work based on experience and review of similar projects. Introduction In 2006, Exmar Offshore Group decided to build a FPS for the GOM onspeculation. This unit was designed and built to meet the generic requirementsof a majority of fields and operations with extra allowance for weights andspace for field-specific requirements. Due to financing requirements, the unitwas to be flagged. Since Exmar is considered a foreign company in accordancewith USCG documentation, the unit was flagged under the requirements ofLiberia. Liberia was selected as they had regulatory requirements for floatingproduction installation (FPI). The unit was built in two sections: the hull in Korea and the topsides in theU.S. After considering all classification agencies, Exmar decided to classifythe hull and marine systems under the guidelines of the American Bureau ofShipping (ABS). ABS was contracted to provide the design approval andfabrication of the unit to their floating offshore installation (FOI) classnotation and to the requirements of Liberia to meet the IMO MODU Code 2001 asit would apply to the unit as a FPU. After meeting with both ABS and MMS (now the Bureau of Ocean Energy Management[BOEM] and the Bureau of Safer Environment Enforcement [BSEE]), it was clearthat Exmar would not have a clear method of obtaining either agencies' approvalwithout a dedicated location on the U.S. Outer Continental Shelf (OCS). Thispaper details the method Exmar used to document and obtain final approval on aunit that was already constructed before beginning the USCG and MMS (BOEMRE)approvals and the process that was developed to ensure compliance with therevised review processes by USCG and BOEMRE during this period. |
