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REQUIREMENTS FOR ESTABLISHMENT OF PROGRAM A great amount of effort will be required by the USGS to institute a valid third-party verification plan. Besides the sizable task of recruiting personnel, numerous imple- menting documents must be developed including a substantial policy guidance document. It is also necessary that industry shift to independent reviewers and inspectors. This will understandably cause a certain realignment of expertise within the industry and will take time. Transition Period The industries that are affected by a verification pro- gram are those that are involved in the exploration, produc- tion, and recovery of petroleum and gas resources. These include designers, builders, and operators. Their primary concern is not with the concept of structural verification, but rather with the potential problems resulting from a system that is poorly conceived or administered. The panel identified the negative effects that could occur if a veri- fication system is adopted too hastily, such as delays in the updating of regulations; use of inadequate criteria or an appearance of "waivers" or "exceptions" in the application of the system; an overdependence on "following codes" rather than "good engineering." It noted that opposing views of regulations by individual verifying agents or regional offices would have a frustrating effect on operators, designers, and builders, and that technical development could be inhibited due to the lack of technical competence or lack of experience of verifying agents or USGS approving officials. By establishing a transition period with specified time- linked milestones to be reached during this period, govern- ment and industry can proceed in an orderly manner to the implementation of a full third-party verification program designed to avoid these pitfalls. While it is important to assure that the implementation of the third-party verification program is established in an orderly manner, it is also necessary that the continuity of the development of offshore energy is not unduly interrupted or delayed by the verification implementation process. The 35

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36 USGS, the Congress, the Executive Branch and their budgeting offices, and industry must take appropriate actions, par- ticularly with respect to the USGS personnel requirements and third-party verification agents to minimize the delays. Many of the milestones to be achieved during the tran- sition period are readily evident by reviewing the program policy document outlined in Appendix D. In fact as will be noted, the policy document itself will take considerable time to develop and may undergo modification during the transition period as the USGS gains the necessary manage- ment staff. Table III outlines the requirements for the orderly establishment of the ultimate third-party verification program in relation to the transition period. These re- quirements are discussed in the following paragraphs. Board of Consultants A board of consultants should be named by the USGS at the beginning of the transition period and become an inte- gral part of the third-party verification program. As noted in Table III, the board would perform a variety of functions on a continuing basis. It would guide the USGS in the development and review of proposed environmental design conditions and construction practices (by geographical area and structural type) and provide recommendations for verification procedures, and for the qualifications of third- party reviewers. It is important that this board is in place and functioning before the USGS issues environmental design conditions and construction practices for third party and industry use in a given area of OCS operations. The USGS, however, would be responsible for the final decisions. Because of its function and close working relationship with the USGS, the board must reflect a high level of tech- nical knowledge from industry, academia, and government, and it must also reflect the needs of the public. The board need not be made up entirely of technical experts. Program Policy Document This document is considered to be necessary to ensure consistent, logical enforcement throughout the several USGS regions.

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37 Table III REQUIREMENTS FOR ESTABLISHMENT OF VERIFICATION PROGRAM Item Needed 1. Program Policy Document Description of Heeds and Sources of Information and Assistance Notes and Transition Steps Necessary to insure consistent, logi- cal, enforcement. USGS can adopt outline based on one provided herein as an interim document. Third Party System USGS should develop locument based on outline provided herein. Can use Regional Office help in devel- oping document. Board of Consul- tants*should assist 'JSGS management in reviewing policy before it is promulgated by Federal Register Route** to assure broad input. 2. USGS Regulation Requir- ing Verification of Structural Integrity Legal Necessity. USGS can publish an "Intent to adopt regulation using outline based on present recommen- dations as "interim regulation"." USGS should develop Proposed Ruling based on recorimendations provided herein; and should use Board of Consultants* and Federal Register Route** to issure broad input. 3. Recommended Practices (Design Procedures, Standards, Codes, etc.) Necessary part of system. USGS can include in publication of "Intent to adopt regulation" and "interim regu- lation' noted above in Item 2. Material can be taken, as appropriate from existing versions of DCS Order • 8. USGS should use Board of Consul- tants* and USGS contractors to develop these from the Recom- mended Practices, Specifications, Standards, and Codes not in existence. They can then be pro- mulgated using the Federal Register Route.** These items can then be updated and amended as needed by the same process as the system develops in actual operation. Environmental Design Conditions (for design and operation) Same as for Item 3 USGS should use Board of Consul- tants* and USGS contractors to develop these from the best currently-available information, and promulgated by the Federal Register Route.** They can then be updated and amended as needed. These conditions should be specified only in terms comparable to "100- year storms" and not in terms of specific wave heights, etc. The specific numbers will be a part of the plan submitted and approved for each structure and need not be specified in the regulations if the reviewing, verifying, and approving per- sonnel are truly competent. S. Qualification Standards for Third-Party Personnel Necessary part of system. USGS can begin with simple requirements for: "Registered Professional Engineer or qualified*companies with experience in design of offshore structure s" and "Qualified Inspector with experience in inspection & quality control in con struction of offshore structures." Both should be "Third Parties" as de- fined by USGS in Fed. Reg. of Jan. 29, 1976. The final qualification standards should also be developed by the Board of Consultants,* and promul- gated through the Federal Register.** Third parties are individuals or companies having no participation in design, fabrication, installation or operation of the platform to be verified or corporate affiliation with companies who do. 6. Internal USGS Procedures Essentially same as for Item 1. Essentially same as for Item 1. 7. Acquisition and Training of Personnel 50 to 100 offshore engineering related personnel to be recruited or arrangement for services obtained. 1 rtol'lish contract (s) with T.' "L.T<;ity (ics) or other sources for intensive overview and detailed offshore technologv courses pertinent to verification. Continuation of transition period efforts *Board of Consultants should consist of eminent personnel in practice, drawn from academia, industry, and the public. It should be used on a continuing basis to update Items 1 through 6 as needed. **"Federal Register Route" consists of: Publication of proposed document or regulation in Federal Re.gi t££: Receipt and response to comment (written or public hearing) from all concerned parties; and Final Promulgation by publication in Fedora 1 Register.

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38 The final document should be reviewed by the board of consultants and then published in the Federal Register to assure broad input and wide acceptance. In the transition period, an abbreviated interim version could be published in the Federal Register. An example of such a document was prepared for the panel and has been included as Appendix D. The USGS staff should seek advice of the board of consultants and others to aid in the preparation of a credible schedule for transition milestones. Program pro- gress will dictate the necessity for adjustments to the transition milestone dates, and depend not only upon the USGS efforts, but also upon appropriate funding and the recruitment of key technical personnel. Early development and publication of the program policy document and transition milestone dates and the achievement thereof is necessary to assure the government, the Congress, and the public of the viability of the transition period as well as the succeeding third-party verification program. Requirements Regulation A regulation requiring a verification plan for each OCS structure is a legal necessity. The USGS should develop a Proposed Ruling based on the recommendations provided herein; and should use the above-noted board of consultants and the Federal Register publication process to assure broad input. As with the program policy document, the final document can be developed with assistance from the USGS Regional Offices. Recommended Practices, Design Standards, and Codes The USGS can adopt, by reference, the various Recom- mended Practices, Specifications, Standards, and Codes now cited in existing OCS Orders using the Federal Register process. It must be noted, however, that some of these documents are incomplete, contradictory, out-of-date, some- times too explicit, and sometimes too vague. As a result, their literal application would stifle design and construc- tion. The effort demanded by step 3 of Table II (p. 32) to get procedurally satisfactory documents is considerable. Technically, the available documents, when coupled with en- gineering judgment, are adequate as guidelines; but, they are not adequate as documents for verification. These items can be updated and amended by the board of consultants through the same process as the system develops.

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39 Environmental Design Conditions Some specification of the environmental conditions which the structure must withstand is needed. The USGS can begin with the "conditions" now specified in the various versions of OCS Order No. 8 as part of the adoption of "Procedures" noted above. This should be updated and amended as soon as feasible using the board of consultants. These conditions should be specified only in terms of general conditions such as 100-year storms, ice loadings, and seismic activity. Unusual geological conditions such as subbottom faulting, potential slumping, and turbidity currents may be pertinent to the particular offshore areas and addressed in the veri- fication plan. They would have also been addressed in both the pre-leasing studies by the Bureau of Land Management (BLM)/USGS, as well as in petroleum drilling and wellhead completion operations. The specific numbers of data such as wave heights and amounts of ice or the particulars for obtaining such data will be part of the verification plan submitted for each structure. Being site specific, they would not normally be specified in the regulations. Compe- tent specialists will be necessary for reviewing, verifying, and approving the environmental data to be used as the con- ditions for design. This area, among others, requires con- tinuing research. Qualification Standards for Third-Party Verification Agents In reviewing the availability of third-party verifica- tion agents the panel considered, in depth, the potential sources of technically qualified agents. As a standard engineering practice, the operator and the industry contractors conduct design reviews and in- spect the quality of fabrication. To accomplish this, expertise has to be drawn from in-house teams as well as from outside contractors and consultants. Since the personnel nominated by operators to conduct the actual verification (review and inspection) functions are subject to approval by the USGS, standards must be established for their approval. During the transition period, the USGS can begin with simple requirements such as "Registered Professional Engineer with experience in design of offshore structures," and "Qualified Inspector with ex- perience in inspection and quality control in construction of offshore structures." Verification agents may be from the applicant's firm, provided they have not been directly involved in performing the work being verified. From ini- tiation of the transition period, "third parties" or firms

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40 as defined by the USGS in the Federal Register of January 29, 1976 should be used when possible. By completion of the transition period, only independent third parties or firms should be selected for each particular structure. Profes- sional standards would be the standards amplified during the transition period by the board of consultants, and promulgated through publication in the Federal Register. Internal USGS Procedures The requisite internal USGS procedures for implementing the system can be developed in essentially the same manner as described for the program policy document. However, since these are internal procedures, they can probably be developed initially in a slightly more informal manner. The USGS Personnel Many skills requiring experience in offshore operations are integrated into the design of a safe and efficient plat- form system. The system is designed to meet a multitude of factors such as drilling and production and environmental conditions as well as fabrication and installation tech- niques. Verification programs require a combination of experience, technical training, and management skill of all personnel in order to be effective. It is evident, therefore, that in addition to regula- tory and verification management ability, the USGS should have personnel possessing skills in the following disciplines Drilling Technology Geology Geophysics Geotechnical Engineering Hydrodynamics Ice Engineering Meteorology Oceanography Seismology Construction Engineering Installation Engineering Marine Engineering Materials Engineering (concrete) Materials Engineering (steel) Naval Architecture Production Engineering Quality & Inspection Engineering Structural Engineering (concrete)

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41 Statistics Structural Engineering (steel frame) Systems Engineering Welding Engineering Acquisition and Training of the USGS Personnel Recruitment should be immediately initiated for an acknowledged leader in offshore structure technology possess- ing management skills and a keen sensitivity to the inter- action of the structure with environmental factors. Recruitment should follow for other senior specialists and managerial skilled offshore engineers with the realiza- tion that it will take a significant amount of time. Con- tracts to gain additional support for specific efforts would be contingent on sufficient in-house expertise to monitor these efforts properly. The USGS will need to recruit from the offshore industry and its supporting contractors in order to obtain personnel with the appropriate experience. It will probably be neces- sary to work closely with the Civil Service Commission so that sufficiently high ratings are available for those who meet the stringent qualifications that will be required. The USGS may also wish to consider other methods to find such talent: 0 A government-industry personnel interchange program; 0 Arranging an assignment of qualified personnel from other government agencies; 0 Contracts with various segments of the supporting offshore consulting, servicing, and classification organizations; and, 0 Arranging temporary hiring of academic personnel knowledgeable in offshore engineering. Other Personnel Considerations for the USGS The overall success of the verification system depends not only on the competence but also on the continued dedi- cation of its personnel. The USGS personnel will have, through the verification process, a significant impact on

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42 offshore oil and gas production. Therefore, it is incumbent upon the USGS that its personnel maintains its competence, enthusiasm, and objectivity by active participation in the various verification functions, close contact with support- ing research and development activities and participation in appropriate technical society activities. Since not only senior level experienced offshore en- gineers will be recruited but also engineers who have other applicable experience, it will be necessary to initiate inten- sive training courses in offshore technology. (An example of the breadth and scope of training applied to another as- pect of oil field operations has been detailed for the panel by Rupert C. Craze in Appendix E.) Engineering colleges that have curricula with a heavy concentration of offshore courses as well as various segments of the off- shore industry should be consulted for training programs that would reflect new technologies, operations techniques, and scientific knowledge. Intergovernmental Agency Cooperation Although the USGS will have primary responsibility for the verification system, it will need the cooperation of other government agencies to initiate the program. In particular, the Civil Service Commission should be consulted at the outset so that the USGS has the flexibility to employ the highly qualified people it will require. In addition, the Office of Management and Budget should be apprised of the need, scope, and details of the system, so that the USGS can benefit from their advice on its implementation. Research and Development Implications Despite the need for continuing revision and forma- lization, the present design procedures, standards, and codes are deemed satisfactory for initiating a verification system. This is evidenced by the record of structural integrity of existing offshore structures. However, with the extension of platform construction into harsher areas, design and construction procedures, standards, codes, and environmental conditions will require continued research support from both industry and the government. The verifi- cation system should utilize the existing procedures and standards as a starting point. The formal specification of environmental design conditions should receive priority because the task is far from simple and requires lead time to collect critical data. Both now and in the future, this

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43 will involve quantification of environmental conditions for design purposes, determination of acceptable intervals of extreme occurrences, and determination of minimum design requirements either for extreme loads or for complete load spectra. Determination of the appropriate loads based on specific conditions and intervals is another R&D priority. Further, the quantified load values are subject to revision as addi- tional environmental data are acquired and as improved methods are developed for conversion into energy forces. Many of the current design procedures and standards are in the process of revision and will continue to be revised in the foreseeable future.