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Security Plan Requirements for OCS Facilities
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Published on January 21, 2004
The purpose of this Regulatory Alert is to make you aware of additional clarifications regarding Facility Security
Plan requirements for Outer Continental Shelf (OCS) facilities. The U.S. Coast Guard has issued an
Implementation Guidance for the maritime security regulations affecting OCS facilities. This guidance document,
Navigation and Vessel Inspection Circular No. 05 03 (NVIC 05-03), provides an expanded discussion on the
applicability of 33 CFR Part 106, as well as an overview of the plan review process.
NVIC 05-03 clarifies the applicability of security regulations, and states that facilities meeting either standard
below must comply with 33 CFR Part 106:
- Personnel Standard: Facilities that host more than 150 persons for 12 hours or more in each 24-hour
period continuously for 30 days or more . The guidance document states that the applicability is
determined by the actual personnel on board, not the berthing design capacity. Therefore, if the berthing
capacity is 150 persons or more, but the facility normally operates below this threshold, the facility
security plan requirements do not apply. If the operator later determines a need to exceed the 150-
person threshold, a facility security plan must be submitted 60 days prior to the anticipated increase in
personnel.
- Production Standards: Facilities that produce greater than 100,000 barrels of oil per day or greater than
200 million cubic feet of natural gas per day. Production includes “transfer of minerals to shore”, which
encompasses fixed facilities that operate as “Transmission Facilities”. Production quantities shall be
calculated as the sum of all sources of production from wells on the primary and any attending
platform(s), including the throughput of other pipelines transferring product across the same platform(s).
Existing facilities that do not exceed these threshold requirements, but anticipate exceeding these
thresholds in the future must comply 60 days prior to the anticipated date that the production will exceed
the threshold requirement(s). Applicability of the regulations to a new facility must be based on the
designed or anticipated production levels.
U.S. COAST GUARD MSO MORGAN CITY NOTES REPEATED INSPECTION DEFICIENCIES
The January 2004 Quarterly Info Bulletin published by U.S. Coast Guard Marine Safety Office Morgan City
reminds facility operators (Marine-Transportation Related facilities regulated under 33 CFR Part 154) to conduct
the required exercises. The notice states that facility inspections over the past four months “have indicated a
deficiency in the number of required exercises being conducted”. The required exercises include Qualified
Individual Notification (required quarterly), Tabletop Exercise (required annually), Boom Deployment (semiannually
for facility-owned boom), and Boom Deployment (annual for OSRO-owned boom).
If you have questions regarding any or all of this information, please contact Bea Stong at
bea.stong@jccteam.com or (281) 578-3388.
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To view this page online, please visit
http://www.jccteam.com/RegAlerts/012104.aspx.
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