Copyright 2001, Offshore Technology Conference

This paper was prepared for presentation at the 2001 Offshore Technology Conference held inHouston, Texas, 30 April–3 May 2001.

This paper was selected for presentation by the OTC Program Committee following review ofinformation contained in an abstract submitted by the author(s). Contents of the paper, aspresented, have not been reviewed by the Offshore Technology Conference and are subject tocorrection by the author(s). The material, as presented, does not necessarily reflect anyposition of the Offshore Technology Conference or its officers. Electronic reproduction,distribution, or storage of any part of this paper for commercial purposes without the writtenconsent of the Offshore Technology Conference is prohibited. Permission to reproduce in printis restricted to an abstract of not more than 300 words; illustrations may not be copied. Theabstract must contain conspicuous acknowledgment of where and by whom the paper waspresented.

AbstractThe oil and gas production industry has expressed an interestin being able to utilize Floating, Production, Storage andOffloading (FPSO) units as a development option in thedeepwater areas of the United States (U.S.) Gulf of Mexico(GOM) outer continental shelf (OCS). Operators will needregulatory approval from both the United States Coast Guard(USCG) and the Minerals Management Service (MMS) for aFPSO project. Neither the USCG nor MMS currently haveregulations specifically for the design and operation of FPSOson the OCS. A workgroup was formed under the OffshoreOperators Committee’s Deepwater Subcommittee to assistMMS and USCG in reviewing the existing regulations andbody of standards, specifications, recommended practices andclassification society rules and guides concerning the designand operation of FPSOs on the OCS for the Gulf of Mexico.The effort also aimed to identify gaps in the regulations andindustry standards. This paper provides a summary of themajor findings of the workgroup. In addition to the itemsdiscussed in this paper, the workgroup report identified otherareas where additional modifications to regulations or industrystandards may be warranted.

IntroductionAs operators have moved into the deeper waters of the GOMover the last several years, interest has been growing inpotentially utilizing FPSOs as a development option to thefloating production systems (tension leg platforms (TLP),spars, etc) and subsea tie backs to either floating productionsystems or fixed platforms that are currently being utilized. Indiscussions with MMS and USCG, it became apparent thatseveral studies would need to be conducted to confirm theacceptability of these systems for the GOM. MMS indicated

that an Environmental Impact Statement (EIS) would beprepared for the first FPSO proposed to be utilized in theGOM. In working with industry, MMS agreed to do aprogrammatic EIS on the generic use of FPSOs in the GOM ifindustry would fund the study. The joint industry projectDeepStar agreed to fund the EIS1. The draft EIS on theProposed Use of Floating Production, Storage and OffloadingSystems on the Gulf of Mexico Outer Continental Shelf in theWestern and Central Planning Areas2,3 was published inAugust 2000 for comment. The final EIS is expected to bepublished in the first quarter of 2001 with a Record ofDecision to be published no earlier than 30 days from thepublication of the final EIS.

The second study effort was to do a comparative riskassessment to evaluate and compare oil spill and fatality risksfor the FPSO with a spar, a TLP and a shallow-water jacketserving as a hub and host to deepwater production. TheOffshore Technology Research Center completed that studyfor MMS4.

The third step in the process was to identify any gaps inthe existing regulations and to develop a regulatory model thatcould be used by MMS and the USCG in the review andapproval of a FPSO project. On March 22, 2000, Mr. ChrisOynes, MMS GOM Regional Director, sponsored a meetingbetween MMS, USCG and industry to discuss the regulatoryrequirements for FPSOs in the GOM, should they be found tobe an acceptable development option. Although it wasrecognized that MMS and the USCG would have to agreeamong themselves the appropriate regulations and regulatorysplit between the two agencies, they agreed that it would bebeneficial and appropriate to have industry provide input onthe model. It was decided that a workgroup would be formedunder the direction of the OOC Deepwater Subcommittee andconsists of industry representatives and classification societyrepresentatives along with personnel from MMS and theUSCG. A report was prepared by the workgroup andsubmitted to MMS and the USCG in September 2000 for theirconsideration5.

Regulatory Model WorkgroupGoalThe overall goal of the workgroup was to review the existingregulations and industry standards covering the design,construction and operation of FPSOs in the GOM and identify

OTC 13170

FPSO Standards and Recommended PracticesWanda J. Parker, WJP Enterprises, and Todd W. Grove, American Bureau of Shipping

2 WANDA J. PARKER AND TODD W. GROVE OTC 13170

any gaps in either the regulations or standards that needed tobe addressed prior to bringing FPSOs into the GOM. Theworkgroup was focused on the design and operationalconsiderations for the FPSO. The work group did not addressthe design of shuttle tankers or operational considerationsonce they were disconnected from the FPSO.

ParticipantsThe workgroup was formed under the direction of the OOCDeepwater Subcommittee and met five times following theinitial meeting. It was agreed that a cooperative effort withopen discussions between the regulatory agencies and industrywas desired and would produce the best work product. Due tothe broad scope of the discussions, it was necessary to includea large number of participants. MMS agreed to have Mr.James Regg, Section Chief, Technical Assessment andOperations Support serve in the workgroup along with supportfrom other MMS personnel. LCDR Bill Daughdrill from theEighth USCG District represented the USCG in the workgroup. Personnel from the MMS Headquarters and USCGHeadquarters groups were kept informed of the workgroup’sactivities through e-mail. Twenty-five persons representing 17companies participated in one or more of the meetings. Sinceclassification societies have historically played a large role inthe approval of FPSOs worldwide, it was felt that it wasimportant to have broad representation from the majorclassification societies who currently class FPSOs. Fourclassification societies; American Bureau of Shipping, BureauVeritas, Det Norske Veritas and Lloyd’s Register of Shippingwere represented in the workgroup. Tim Sampson representedthe American Petroleum Institute (API). Wanda Parker agreedto chair the workgroup for OOC. A complete listing of allworkgroup participants is in the workgroup report5. All ofthese individuals dedicated a considerable amount of time andexpertise to this effort.

FPSO CharacteristicsFor consistency, the workgroup decided to use the FPSOcharacteristics used in the EIS and CRA studies as the FPSOmodel for this effort. The workgroup considered theregulations that would apply to a US flag FPSO or anundocumented FPSO that is designed to US flag requirements(similar to the existing GOM floating production systems).Limited discussions were held on the differences in permittinga US flag FPSO and a foreign flag FPSO. The FPSO wasconsidered to be ship-shaped with limited discussions on thedifferences between a ship-shaped FPSO and a non ship-shaped FPSO. Discussions were limited to a permanentlymoored FPSO for simplicity since a disconnectable FPSOintroduces many complicating factors into the discussion.Finally, discussions were focused on systems that are uniqueto FPSOs with only limited discussion of systems that arecommon to fixed platforms or other floating productionsystems. This list of system includes:

1. In Hull Cargo Storage Systems2. Cargo Piping and Transfer3. Turret/Mooring/Stationkeeping/Swivel

4. Propulsion5. Stability6. Motions/Global Performance7. Risers8. Offloading Systems9. Layout10. Operational Considerations11. Discharges12. Manning

RegulationsMOUIt is recognized that both MMS and USCG have a large bodyof regulations that could be applied to FPSOs. In theMemorandum of Understanding (MOU) between MMS andUSCG6 signed on December 16, 1998, the delineation ofjurisdictions regarding floating production systemcomponents, operations and issues is addressed. Theworkgroup reviewed the MOU for completeness in coverageof systems on a FPSO and put together a table showing theapplicable regulations, industry standards and classificationsociety rules for each system and sub-system in the MOU.While this table was not exhaustive, it quickly pointed outareas where regulations and standards were well establishedand systems where either regulations or standards werelacking. The work group made some specificrecommendations concerning the implementation of the MOUthat will be discussed below.

MMSMMS regulations that are applicable to FPSOs are primarilylocated in 30 CFR 250, Subparts H and I. In conjunction withtheir regulations for specific systems, MMS has said that theyintend to utilize the Deepwater Operations Plan (DWOP)process in their review of a FPSO project7. The workgroupreviewed the MMS regulations for adequacy and made somespecific recommendations that will be discussed below.

USCGThe USCG has said that FPSOs will be regulated as vesselsand therefore will be required to meet specific vessel designand operational regulations8,9. USCG regulations that areapplicable to FPSOs are primarily located in 46 CFR,Subchapters D and IA and 33 CFR Subchapter N. On Dec 7,1999, the USCG published a Notice of Proposed Rulemakingfor 33 CFR Subchapter N that includes proposed regulationsapplicable to FPSOs. The workgroup considered theseproposed regulations in addition to the established regulations.The workgroup report was submitted to the record as acomment to the proposed regulations. The specificrecommendations will be discussed below.

Industry StandardsBoth USCG and MMS regulations incorporate by reference alarge number of industry specifications and recommendedpractices, particularly API documents. Many of these areapplicable to FPSO system design or operation. In addition,

OTC 13170 FPSO STANDARDS AND RECOMMENDED PRACTICES 3

there are a host of other international standards that may beapplicable to FPSOs. Most of these standards cover individualsystems or subsystems that may be used in conjunction with awide variety of types of installations. It was outside of thescope of the workgroup to conduct a thorough review of theadequacy of the individual industry specifications andrecommended practices. Rather, the workgroup focused on afew key standards and made recommendations of standardsthe agencies should consider incorporating by reference.

Classification Society Rules and GuidesAnother body of standards applicable to FPSOs andrecognized worldwide are those developed and applied by anumber of the major classification societies. The rules andguides of the societies are utilized in assessing the fitness-for-purpose of FPSOs and are focused on safety aspects. Theclassification requirements address design requirements aswell as those for fabrication, installation, and commissioning.Unlike the snapshot nature of certification, classification is anongoing process by which the societies survey a FPSOperiodically during its operational life to ensure compliancewith the rules. Given their unique independent roleinternationally, classification societies are also often delegatedstatutory responsibilities by flag and coastal state authorities toact on behalf of the administration. USCG has, to varyingdegrees, delegated to several classification societies approvalresponsibilities for existing GOM floating production units.Expectations are that similar delegations will be forthcomingas experience is gained in GOM FPSO applications. Severalclassification societies have also been active to varyingdegrees in the MMS Certified Verification Agent program forexisting structures, which may also be extended to FPSOs.The relevant practical experience from classification andstatutory responsibilities is utilized in maintaining the rulesand guides in a current and relevant form. The fourparticipating societies contributed citations to the regulatorymatrix for the most prevalent rule and guide requirementsapplicable to the various aspects of the FPSO.

Gaps and RecommendationsDuring the review process, the workgroup identified a numberof recommendations either for ways to close existing gaps inthe regulations or for additional work that should beconsidered. These recommendations were broken out intoareas for consideration by MMS and USCG and for industry.

MMSIn 30 CFR 250, Subpart I, MMS has established a platformverification program requiring a third party certification of theplatform design. These regulations were established for fixedplatforms, but MMS has been applying them to floatingproduction facilities. It is recommended that MMS revisethese regulations to update them for floating facilities,including FPSOs. The workgroup recommended adding theturret, risers and mooring systems to the verification program.

In lieu of the agency writing prescriptive regulations for

FPSOs, the workgroup recommended that MMS considerincorporating by reference additional industry standards andrecommended practices as they become available. Thefollowing were identified as candidates for MMS review andconsideration for incorporation in their entirety10,11,12,13,14:

1. API RP 2FPS, Planning, Designing and ConstructingFloating Production Systems

2. API RP 2SM, Design and Analysis of SyntheticMoorings

3. API RP 2SK, Design and analysis of StationkeepingSystems for Floating Structures

4. API RP 2RD, Design of Risers for FloatingProduction Systems (FPSs) and Tension-LegPlatforms (TLPs)

5. API Spec 17J, Specification for Unbonded FlexiblePipe

USCGOn December 7, 1999, a Notice of Proposed Making waspublished revising 33 CFR, Subpart N. In that revision, bothMobile Offshore Drilling Unit (MODU) regulations located in46 CFR, Subchapter I-A and tank vessel regulations located in46 CFR, Subchapter D were referenced. However, theregulation was not clear in many cases which regulationshould be followed if both regulations cover the same systemor subsystem. Also, in many cases, modifications to theseregulations may be needed to address the uniquecircumstances of FPSO or floating system operations versus atank vessel or MODU. The workgroup recommends thatspecific regulations for floating facilities should be written inlieu of pointing to regulations for various types of vessels,which may not be completely applicable to floating productionfacilities. The workgroup also recommended that their reportbe included in the comment record for the proposedrulemaking.

The workgroup recommended that marine crew manningand qualification regulations should be codified for FPSOsand for other floating production systems. The Eighth CoastGuard District has issued a policy letter15 for marine crewmanning for floating production systems other than thosestoring oil in bulk, which could serve as an appropriatestarting base for non-self propelled FPSOs. It was recognizedthat self-propelled FPSOs would need additionalconsideration.

MMS has adopted API RP 500/50516,17 for areaclassification while the USCG has prescriptive regulations in46 CFR, Subpart J. The workgroup recommended that theUSCG adopt API RP 500/505 for floating production systemsincluding FPSOs. Adopting common standards wouldminimize confusion and duplication of effort for industrysince both agencies have jurisdiction for area classification.

Although the USCG has been given sole jurisdiction overfire fighting systems for floating production systems,including FPSOs, the USCG has not yet proposed regulationsfor fire fighting systems in the production area. It isrecommended that the USCG adopt fire-fighting regulationsfor the production area.

4 WANDA J. PARKER AND TODD W. GROVE OTC 13170

Both MMS and USCG have voluntary safety managementsystem programs that could be applicable to FPSOs. MMS hasrecognized API RP 7518 as an acceptable basis for a safetymanagement system for fixed and floating production systemson the US OCS. Most oil and gas production companies havebased their safety management programs for operations on theUS OCS on API RP 75. However, the USCG has recognizedthe International Safety Management Code (ISM)19, which isapplicable to vessels that must comply with Chapter IX ofSOLAS. While both programs have merit, and individualcompanies may want to base their programs on eitherstandard, a combination of the standards or some otherstandard, the workgroup recommends that the USCGrecognize API RP 75 as an acceptable basis for a safetymanagement program in addition to ISM.

In the event that foreign flagged FPSOs are acceptable foruse in the GOM, the USCG will issue a Letter of Compliance(LOC)8. Since a full design review is not normally conductedfor a LOC, the workgroup recommended that the USCGdevelop a LOC checklist that could be either used withexisting foreign flagged FPSOs or new-built foreign flaggedFPSOs proposed for operations in the GOM.

Although the USCG has general lightering regulations andadditional operational regulations that apply to the designatedlightering areas in the GOM, there are no specific operationalregulations that apply to FPSOS or to tandem offloading. It isrecommended that a work group be formed to review existinginternational standards to determine their adequacy for GOMoperations.

Joint MMS and USCGIn the MOU, both MMS and USCG have been givenjurisdiction for reviewing and approving the design of theturret and mooring system. The workgroup agreed thattechnology is rapidly evolving for these systems and that itwould be burdensome on the regulatory agencies to havepersonnel fully knowledgeable about these systems as theychange. It is recommended that a verification agent acceptableto both agencies be selected to review and certify the design.

In the MOU, both MMS and USCG have been givenjurisdiction for reviewing and approving various portions ofthe integrated monitoring and safety systems. It isrecommended that a work group consisting of representativesof Industry, MMS and the USCG be formed to address theintegration of these systems.

In the MOU, both MMS and USCG have been givenjurisdiction over piping systems. It is recommended that forcargo tank piping that the specification break between MMSand USCG jurisdiction occur at the 1st valve downstream ofthe last processing vessel (and its control valves and safetysystem) prior to the oil entering the cargo storage tanks. It isrecommended that a work group be formed consisting ofrepresentatives of industry, MMS and USCG to review othersimilar systems and agree to where the specification breaksbetween the systems should occur. These breaks should becodified into the MMS and USCG regulations. Alternatively,MMS and USCG should consider adopting consistent industry

standards for piping systems.Neither MMS nor USCG regulations address integral hull

tanks used as process vessels (such as wet/dry oil tanks). Thework group recommended that all integral hull tanks be underUSCG jurisdiction for structural design. For tanks used asprocess vessels, the safety system, control valves, and pipingto and from the process vessels should be under MMSjurisdiction. It is recommended that piping specificationbreaks should occur at the first flange outside the tank.

IndustryBoth the Environmental Protection Agency (EPA) and theUSCG have regulations concerning discharges to the oceanthat could occur from FPSOs. It is recommended that a workgroup under the OOC Deepwater Subcommittee be formed toreview the overboard discharge regulations of both agencies toensure that all discharges are adequately addressed for FPSOoperations.

Although the USCG has regulations that provide for theinspection of foreign flagged tank vessels, no formaldetermination has been requested or received from USCustoms that indicates if foreign flagged FPSOs will or willnot be allowed to operated on the OCS (i.e. Will Customsinterpretation and policy for foreign flagged FPSOs be similarto their current interpretation and policy for foreign flaggedMODUs?) The workgroup recommended that industrydevelop a strategy for obtaining a formal, writtendetermination from Customs.

It was recommended that the various API standards andrecommended practices for mooring systems and riser designbe reviewed to determine if the inspection guidelines given inthose documents are adequate for floating production systemsand updating the documents as needed.

It was recommended that API RP 14C be reviewed andrevised if needed for floating production systems, includingtaking into account the effect environmentally inducedmotions may have on the safety and monitoring systems. Inaddition, it is recommended that the safety and monitoringsystems for swivels, integral hull tank process vessels andother unique systems to a FPSO be covered in therecommended practice.

It was recommended that API RP 14E20 be reviewed foradequacy and updated as needed for the effects of motion andpiping support.

It was recommended that the various API documents oncomposite materials should be reviewed for adequacy forfloating facilities including FPSOS.

It was recommended that API RP 75 be reviewed andupdated as needed to ensure the document is an adequate basisfor a safety management system for FPSO systems andoperations. Applicable portions of ISO 9000/14000 could beincorporated, if desired.

The work group recognized that standards for cargo tankcleaning for FPSOs might be different from trading tankerssince inspections may occur when the FPSO is on location andin operation and not in dry dock. It is recommended thatappropriate standards for cargo tank cleaning be confirmed.

OTC 13170 FPSO STANDARDS AND RECOMMENDED PRACTICES 5

ConclusionsWhile neither MMS nor USCG has regulations thatspecifically apply to the design or operation of FPSOs, there isa multitude of regulations that are applicable to FPSOs andwith the modifications indicated in the work group’srecommendations, the existing framework is adequate. A largebody of industry recommended practices and standardsconsisting of classification society rules and guides, APIstandards, specifications and recommended practices andinternational standards exist that cover FPSO system designand operation. In some cases these need to be reviewed andupdated, where needed, to ensure they are applicable to GOMFPSO operations. Many of the recommendations identifiedfor FPSOs are also applicable to other types of floatingfacilities.

The majority of the discussions by the workgroup focusedon systems that are unique to FPSOs. The FPSO model usedfor the discussions was a ship-shaped permanently mooredFPSO. It is recognized that a FPSO is not dependent on shapeand some variations occur as you move between ship-shapedand non-ship-shaped FPSOs that will need additionalattention. Likewise, a disconnectable, self-propelled FPSO hasmany aspects that are different from a permanently mooredFPSO that will need to be considered.

The review of the existing regulations was conductedwithout representation from the USCG Marine Safety Centeror Headquarters groups. These groups need to be fullyengaged before final determinations can be made on theappropriate regulations for FPSO design and operations. Therepresentatives from the Eighth Coast Guard Districtparticipated fully in the discussions, but it was recognized bythe workgroup that they were not authorized to speakdefinitively on USCG policy or regulation.

OOC appreciated the opportunity to take the lead role inthis cooperative effort between MMS, USCG and Industry. Byworking together and pooling our thoughts and ideas,regulations that meet the needs of all concerned can be put inplace for FPSOs in the GOM. A large number of industryrepresentatives and classification society representativesdedicated a considerable amount of time and expertise to thistask. The efforts of Mr. Jim Regg and LCDR Bill Daughdrillwere recognized for their active participation in the workgroup. As policies and rulemaking for FPSOs are drafted,continuing the cooperative effort between the regulators,industry and the classification societies will be beneficial.

AcknowledgmentsThe authors would like to thank the Offshore OperatorsCommittee for allowing us to publish the results of the workgroup.

References1. Verret, Allen J., Hays, Paul R., “Deepstar’s Program Related to

FPSO’s”, Offshore Technology Conference, 10703, May 1999.2. “Proposed Use of Floating Production, Storage, and Offloading

Systems on the Gulf of Mexico Outer Continental Shelf,

Western and Central Planning Areas, Draft EnvironmentalImpact Statement”, Minerals Management Service, Gulf ofMexico OCS Region, August 2000.

3. George, J.E., Parker, W.J., Cranswick, D.J., “FPSOEnvironmental Impact Statement: What is Happening?”,Offshore Technology Conference, 10705, May 1999.

4. Gilbert, R.B., Ward, E.G., Wolford, A.J., “A Comparative RiskAnalysis of FPSO’s with Other Deepwater Production Systemsin the Gulf of Mexico”, Offshore Technology Conference,13173, May 2001.

5. Letter to Carolita Kallaur, Minerals Management Service, fromAllen Verret, Executive Director, Offshore OperatorsCommittee, Regarding Regulatory Framework – FloatingProduction Storage and Offloading Systems, September 2000.

6. Memorandum of Understanding (MOU) Between the MineralsManagement Service and the United States Coast Guard”,Federal Register, Vol. 64, No. 10, January 15, 1999.

7. Regg, James B., “Floating Production, Storage and OffloadingSystems in the Gulf of Mexico OCS: A Regulatory Perspective”,Offshore Technology Conference, 10701, May 1999.

8. Daughdrill, W.H., Brown, M.J., “The Regulatory SchemeApplicable to Floating Production, Storage, and OffloadingSystems”, Offshore Technology Conference, 10702, May 1999.

9. Letter to Carolita Kallaur, Minerals Management Service, fromRADM North, United States Coast Guard, November 16, 1998.

10. “API Recommended Practice for Planning, Designing, andConstructing Floating Production Systems”. AmericanPetroleum Institute, 2000 Draft.

11. “Recommended Practice for Design, Manufacture, Installation,and Maintenance of Synthetic Fiber Ropes for OffshoreMooring”. American Petroleum Institute, November 1999 Draft.

12. “API Recommended Practice for Design and Analysis ofStationkeeping Systems for Floating Structures”. AmericanPetroleum Institute, December 1996.

13. “API Recommended Practice for Design of Risers for FloatingProduction (FPSs) and Tension-Leg Platforms (TLPs)”.American Petroleum Institute, June 1998.

14. “API Specification for Unbonded Flexible Pipe”. AmericanPetroleum Institute, July 2000.

15. The Eighth Coast Guard District policy letter for marine crewmanning for floating production system other than those storingoil in bulk

16. “API Recommend Practice for Classification of Locations forElectrical Installations at Petroleum Facilities Classified as ClassI, Division 1 and Division 2”. American Petroleum Institute,November 1997.

17. “API Recommend Practice for Classification of Locations forElectrical Installations at Petroleum Facilities Classified as ClassI, Zone 0, Zone 1 and Zone 2”. American Petroleum Institute,November 1997.

18. “API Recommend Practice for Development of a Safety andEnvironmental Management Program for Outer ContinentalShelf Operations and Facilities”. American Petroleum Institute,July 1998.

19. “International Management Code for the Safe Operation ofShips and for Pollution Prevention”, International MaritimeOrganization, Assembly Resolution A.741(18), 1993.

20. “API Recommend Practice for Design and Installation ofOffshore Production Platform Piping Systems”. AmericanPetroleum Institute, October 1991.

TODD GROVE

Todd Grove is a graduate of theUniversity of Michigan with a degreein Naval Architecture and MarineEngineering. He has been with ABS for 19 years serving in theCorporate office in the New Yorkarea, Pacific Divisional Headquartersin Singapore and Americas Divi-sional Headquarters in Houston. He

was the manager of the Offshore Engineering Department inHouston where he was responsible for ABS classificationand certification design review of structure, stability andsafety issues for Mobile Offshore Drilling Units, FloatingProduction Systems and other Site-Specific Installations.Currently Todd is the Director of ABS’ Offshore ProjectDevelopment Team where he coordinates ABS’ globaloffshore resources for bid and proposal development.

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