©2015 American Bureau of Shipping. All rights reserved.

Update on USCG Notice of Proposed Rulemaking (NPRM) Regarding DP Systems

Michael J. RoaSenior Managing Principal Engineer, ABS Pacific Division

Singapore10 September 2015

ASIAN DYNAMIC POSITIONING CONFERENCE

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Summary of Presentation

� Marine industry trend on mitigating risk associated with software

development of DP control systems

� IMO and IACS proposals to update control systems standards

� Summary of USCG Notice of Proposed Rulemaking effort

� New Provisions:

– Critical activity operating mode

– DP system assurance organizations

– Well specific operating criteria

– DP verification acceptance document

– Activity specific operating criteria

� Risk-based rules for DP Systems

� Incorporation of Industry Guidance (MTS Guide)

� Feedback, timeline, applicability, industry participation

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Mitigating Risk

� Where to begin to investigate, analysis and address to reduce

risk?

� At project start

� Review of the functional description

� FMEA/FMECA

� V&V plan

� Verification (FAT) (software included in the testing?)

� Commissioning

� FMEA proving

� System Integration Testing (SIT)

� Drill string testing

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With All that Testing, What are We Missing?

� Degraded sub-systems of the DP super-system and the programmed actions of the DP system to the numerous potential failures may not be discussed

� IMO requirement of no single point of failure still applies (DP2 and DP3 units)

� Modifications – ABS is drafting a rule change to address software modifications in the ABS DP Guide

Software Development Life Cycle

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Risk Analysis

� Request supplier add to failure testing to the FAT, then have

supplier fail the “something” and check that it acted as described

in FMEA

� Repeat for other connected systems

� Request what you want and verify that you got it

� Functional detail of the software programming is needed for review

� Details of how the supplier effects the functionality is the supplier’s business

FMEA/FMECA FAT

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IMO* Proposals

� Machinery Panel has agreed to revisit MSC

Circular 645

� Current version hardware focused

� Estimated 2 years to update circular

� Has been approved by MSC and will be

voted at next MSC meeting

� Provides templates, workflow over 5 stages

of software development

� IMO has e-navigation subcommittees

addressing:

� Software Quality Assurance (SQA)

� Human Centered Design (HCD) of

DP systems

� Proposed guidelines for Navigation, Radio-

Communication, Search and Rescue

systems

* International Maritime Organization’s Sub-

Committee on Navigation, Communications

and Search and Rescue

Photo Source: www.imo.org

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IACS Requirements & Proposals

� Unified Requirements for the On Board use

and Application of Programmable Electronic

Systems, E22 (Dec. 2006)

� IACS has setup a Expert Group

investigating complex systems

� Not exclusively focused on DP systems

� Early in the process

Photo Source: www.imo.org

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USCG Proposed Requirements

� Notice of proposed rulemaking, 28 Nov. 2014 79 FR 70944

� Adding operational provisions such as:

� CAMO – Critical Activity Mode of Operation

� DPSAO – DP System Assurance Organizations (Class Societies and others…)

� WSOC – Well Specific Operating Criteria

� DPVAD – Dynamic Positioning Verification Acceptance Document

� ASOC – Activity Specific Operating Criteria

� At present, the proposed USCG requirements are more

prescriptive than performance based

� Incorporates Marine Technical Society’s (MTS) Dynamic

Positioning Committee Operations Guide

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USCG Proposed Requirements (continued)

� For the vessels, the proposed rules are risk-based, the higher

the risk, the higher the DP class required for US OCS activities

� Restricts activities in US OCS by DP class

� DP-2 or DP-3, Enhanced DP System Requirements

– MODU, Vessels over 6000 GT performing critical well activities

– DPSAO reviews plans with USCG oversight

� DP-2: < 6000 GT Standard DP System Requirements

– Offshore Supply, Platform Supply Vessel, DPSAO reviews plans

� Report when ASOC or WSOC changes from green (defined in MTS

document as defined in the ASOC or WSOC

� If anything is changed or updated that cause a new FMEA or a change to the CAMO, then must report the change to USCG

� As the owner, how do you know when to perform a new FMEA?

� DP Failures that occur during critical activities are to be reported

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NRPM USCG-2014-0063: DPSAO

� Creates a new Dynamic Positioning Systems Assurance Organization (DPSAO) for 3rd party verification and recordkeeping

� May be a combination of Class Societies and DP consultants

� DPSAO functions:

� Collect, review and record DP incident reports for each MODU and vessel

� Prepare and submit an annual report of investigations to USCG for each

MODU and vessel

� Perform DP plan review and surveys (trials)

� Coordinate surveys with owners and USCG

� Submit DP plans and survey (trials) results to USCG for oversight review

� Issue a Dynamic Positioning Verification Acceptance Document (DPVAD)

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Industry Feedback on USCG NRPM

� Regarding the proposed requirement to report status changes

from green to yellow or red, the criticism has been that some rig

owners and DPOs change the status to raise awareness even

when no fault or loss of redundancy has occurred

� For example, some may change status to yellow when they see a

weather change happening and want to raise everyone’s attention

level

� So, will owners now be required to report this status change?

� Or, will this influence owners to stop changing the status level for

these kinds of events?

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USCG NPRM (79 FR 229)

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USCG Proposed Requirements Timeline

� Staged implementation

� Proposed rule states that the requirements the application of the STCW* Convention member states for vessels operating in US OCS

� References IMCA M117, Rev 1 on minimum training

� Language not harmonized with IMCA M117

� Every software change would require the DPSAO to review all software changes and notify the USCG and include updates to CAMO or FMEA

� All plans to be submitted to USCG

� Rule making is anticipated to effective 2017

� Applies to existing and new vessels operating in US OCS

* Standards of Training, Certification and Watchkeeping for Seafarers

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US Bureau of Safety & Environmental Enforcement (BSEE)

� Industry discussions about Real Time Monitoring (RTM) of BOPs

� Software Quality Assurance

� Data Quality

� Malware

� Security of control systems, data and software

� Requiring immediate data transmission to shore of all BOP data

� Requires collection and preservation of data

� It is not clear at this time what BSEE will “do” with all the data

� Working Group’s consensus was RTM problematic

– Satellite link

– Data storage

– Data quality, security…

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API 16D Draft

� Software requirements are listed:

� Traceable

� Consistent

� Documented

� Repeatable

� Auditable

� Requires:

� FMEA

� Verification

� Validation

� Security

Software Requirements are coming to our industry

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Classification Society Rules & Guides

� All Classification Societies’ have Rules following IMO

MSC/Circ. 645

� Additional Optional Notations

� American Bureau of Shipping (ABS)

– Seakeeping Performance (SKP)

– Enhanced System (EHS-n)

� Det Norske Veritas Germanischer Lloyds (DNV GL)

– Redundant Propulsion (RP)

– Redundant Propulsion Separate (RPS)

– Dynamic Positioning Enhanced Reliability (DYNPOS ER)

� Lloyds Register

– Performance Capability Rating (PCR)

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Industry Groups

� Marine Technical Society’s Dynamic Positioning Committee

� Operational focused and testing

� Technical and operational guidance

� International Marine Contractors Association

� The Nautical Institute

� DP officer training

� International Association of Drilling Contractors

� Comments to USCG NPRM

www.eagle.org

©2015 American Bureau of Shipping. All rights reserved.