Recommendation No. 6.

Action Taken:

System Analysis

System analyses were performed on 13 installations in the Gulf of Mexico under two Geological Survey contracts. These studies are currently being evaluated with the objective of possible adoption into the lease management program in connection with the work being done in this area by the committee on standards and specifications.

Recommendation No. 7. Engineering Documentation

Action Taken:

The current proposed revision of OCS Order No. 8 includes requirements on documentation as recommended by the

studies.

Recommendation No. 8. Wearout Prevention

Action Taken: The proposed revision of OCS Order No. 8 includes an erosion control program. This is also the subject of

one of the research and development committee's projects.

Recommendation No. 9. Training

Action Taken:

A committee has been formed in conjunction with the API
on offshore safety and anti-pollution training and moti-
vation. This committee is outlining the training needed
for personnel working offshore, setting up training pro-
grams, and establishing a time-framework for accomplishing
this. The Geological Survey is establishing a more forma-
lized training program for their own personnel and have
plans for developing a training course in OCS Orders and
regulations for presentation to the industry.

Action Taken: The API and oil industry are taking the lead in

developing a motivation program.

Recommendation No. 11. Lease Management Program

Action Taken:

Additional personnel have been hired for the Gulf of Mexico OCS Office. The areas of responsibilities and goals of the individual organizational units are being developed. Also under development is a system for incorporating reports from other program areas into an annual review.

Recommendation No. 12. Inspection Procedures

Action Taken:

Data processing equipment has been installed in the Gulf
of Mexico area office. Inspection checklists are being
updated to keep current with OCS Orders. Special inspec-
tions are conducted bi-monthly as data gathering exercises.
Consistent enforcement policy is being applied in each OCS
Computerized data files regarding inspections, plat-
forms, and accidents have been established and are used as

area.

input for the safety review committee.

Recommendation No. 13. OCS Order Development Procedures

Action Taken: The Geological Survey is currently developing formalized procedures for the evaluation and revision of existing OCS Orders and the development of new OCS Orders. Proposed new and revised orders are now being published in the Federal Register for public comment prior to their

adoption.

Recommendation No. 14. Standardization of Pollution Report Form

Action Taken: This form is currently being revised by the area

offices.

Recommendation No. 15. Safety and Advisory Committees

Action Taken: The industry has established a committee on OCS

Safety in both the Gulf of Mexico and Pacific Areas.

The area offices have designated personnel to form
systems analysis review committees to meet on a regular
basis. These committees have had their initial meet-
ings. The Director of the Geological Survey has
formed a review committee on safety of OCS petroleum
operations. This committee is composed of experts
not regularly employed by industry or the Government
and is sponsored by the Marine Board of the National
Academy of Engineering. The initial meeting of this
committee was held in Washington, D. C. during

August 1973, and the next meeting was held in New

Orleans, Louisiana during the later part of November

1973.

In addition to the above studies and reports, the General Accounting Office issued a report at the request of the Conservation and Natural Resources Subcommittee of the Committee on Government Operations, House of Representatives 1/. This study, like those mentioned above, presents

1/ General Accounting Office, "Improved Inspection and Regulation Could Reduce the Possibility of Oil Spills on the Outer Continental Shelf", Report No. B-146333, June 29, 1973.

a critical review of OCS regulatory and inspection procedures and includes recommendations designed to achieve more effective capability and procedures. In a letter dated August 3, 1973, from Secretary Morton to Mr. Henry S. Reuss, Chairman of the Conservation and Natural Resources Subcommittee, it is pointed out that the recommendations contained in the GAO report which have not already been implemented

are being implemented as part of the Work Group's recommendations (see

Vol.3 Attachment D for the Work Group's recommendations).

Many of the recommendations contained in the GAO report were also made in the studies discussed above. Nevertheless, the following statements

specifically apply to the GAO report:

1.

2.

3.

4.

5.

6.

Inspectors are instructed to apply prescribed enforcement
actions for violations of OCS Orders unless deviations have
been authorized and properly documented for each case by the
Chief, Conservation Division, Geological Survey.

The inspection staff is to be increased and the number of
inspections, both scheduled and unannounced, have been
increased.

Inspections include workover and remedial operations as well
as drilling, producing and abandonment operations.

Work groups have been formed to study the feasibility of:
Requiring operators to submit a preventive maintenance
schedule.

a.

b.

Requiring operators to perform scheduled inspections and
report results in a specified format.

GS is working with industry and with the API in an attempt
to set standards and requirements for training personnel.
GS personnel would participate in this training.
meantime, Conservation Managers have been instructed to
initiate formalized training in inspection procedures.

Plans are being adopted to limit the conditions under which
multiple operations may be conducted for a single platform.

In early fall, 1973, a comprehensive report of a technology assessment of oil and gas operations on the U.S. Outer Continental Shelf was published by an interdisciplinary research team from the Science and Public Policy Program at the University of Oklahoma 1/. The independent analysis, funded by the National Science Foundation, was conducted over a 20 month period beginning in September, 1971.

The principle conclusions of the study are: (1) That existing OCS technologies are adequate for continued oil and gas operations; (2) that more sharply defined concerns for safety and environmental protection continue to pose a challenge to OCS management even though technologies responsive to these new concerns are gradually evolving; (3) that in the past, participation in the management of OCS oil and gas operations was limited to the Department of the Interior and the petroleum industry and that this relatively closed management system was initially unable to sense and respond quickly to a changing social climate.

Interested groups and

Federal agencies representing concerns such as environmental conservation are now participating in the management system primarily through the impact statement process required by NEPA. These new participants are demanding changes from past patterns of operations; and (4) but most

of the new demands being made on OCS technologies are well within stateThe necessary information modifications in the physical

of-the-art.

1/

The Technology Assessment Group, Science and Public Policy Program,
University of Oklahoma, Energy Under the Oceans: A Technology
Assessment of Outer Continental Shelf Oil and Gas Operations,
University of Oklahoma Press, September, 1973.