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Activity Summary Report Title: Ltr of Determination - Ice Advisors Activity ID: 5147719 Activity Start Time: 06/08/2015 8:48:00 AM Originating Unit: SEC Anchorage Owner Unit: SEC Anchorage Controlling Unit: SEC Anchorage Activity Type: Vessel Inspection/PSC Team Lead: Status: Open - Submitted for Review Status Date: 06/08/2015 Prompt Date: Subject POC: Vessel Information ============================================================================================= Vessel Name: VIN: Flag: Length: Tonnage(GRT/ITC): POLAR PIONEER 8754140 MARSHALL ISLANDS 380.7 Year Completed: Vessel Type: Propulsion Type: 1985 Offshore-MODU-Semisubmersibles Engine Compartment: Fuel Compartment: Construction: Unknown Unknown Unknown Activities Conducted: ============================================================================================= Type Date Unit Administrative Inspection 06/08/15 SEC Anchorage Inspection Results ============================================================================================= System Date Results Inspection Results - Deficiencies ============================================================================================= (None) Documents and Certificates: ============================================================================================= Certificates: Document Description Issue Date Expire Date Minimum Safe Manning Document 05/08/15 Documents: Name: Description PP & ND Ice Advisor Letter D17.pdf PolarPioneer_NobleDiscoverer_IceAdvisors_08Jun2015.pdf Locations: Latitude Longitude Time Description ============================================================================================= 61 16.13942 N 149 38.29344 W 06/08/2015 08:48 US Coast Guard Sector Anchorage Narrative Summary: ============================================================================================= Completed Adminstrative Inspection to issue Letter of Determination (LOD). No requirements issued, cleared, or outstanding. Rcvd attached ltr dtd 03Jun2015 requesting LOD for Ice Advisors for POLAR PIONEER & NOBLE DISCOVERER. Drafted LOD for Sp signature.
08Jun2015 - Attached OCMI LOD dtd 08Jun2015 indicates Ice Advisors not members of the regular complement of a unit as defined in 33CFR141.15(b). Mailed LOD to requesting party. No requirements issued, cleared, or outstanding. Administrative inspection complete. //s// GS12, USCG Sector Anchorage Activity Action Log: Eff. Date Unit Individual Description ============================================================================================= 06/08/2015 SEC Anchorage Activity Created. Status: "Open - In Progress" 06/08/2015 SEC Anchorage Status Changed to "Open - Submitted for Review"
Activity Summary Report Title: EEP Review, Deficiency Check Activity ID: 5142251 Activity Start Time: 06/01/2015 8:27:00 AM Originating Unit: SEC Anchorage Owner Unit: SEC Anchorage Controlling Unit: SEC Anchorage Activity Type: Vessel Inspection/PSC Team Lead: Status: Open - Submitted for Review Status Date: 06/02/2015 Prompt Date: Subject POC: ( Vessel Information ============================================================================================= Vessel Name: VIN: Flag: Length: Tonnage(GRT/ITC): POLAR PIONEER 8754140 MARSHALL ISLANDS 380.7 Year Completed: Vessel Type: Propulsion Type: 1985 Offshore-MODU-Semisubmersibles Engine Compartment: Fuel Compartment: Construction: Unknown Unknown Unknown Activities Conducted: ============================================================================================= Type Date Unit Deficiency Check 06/02/15 SEC Anchorage Plan Review (Other than "T") 06/01/15 SEC Anchorage Inspection Results ============================================================================================= System Date Results Operations/Management 06/02/15 Deficiencies Found and Corrected Inspection Results - Deficiencies ============================================================================================= ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 1 By specified date and/or by 06/19/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Operations/Management Vessel Safety Management Emergency Preparedness
---Description--- 0199 - Other(certificate) - Emergency evacuation plan (EEP) not present during exam. Submit EEP for approval from OCMI of Western Alaska. - 33CFR146.140 - Action code: 50c. Documents and Certificates: ============================================================================================= Certificates: Document Description Issue Date Expire Date Documents: Name: Description 2015-05-28 Discoverer and Polar Pioneer EEP Submittalpdf.pdf PolarPioneerEEPChecklist_01Jun2015.pdf PolarPioneer_EEPApproval_02Jun2015.pdf Locations: Latitude Longitude Time Description =============================================================================================
Locations: Latitude Longitude Time Description (Continued) ============================================================================================= 61 16.13942 N 149 38.29344 W 06/01/2015 08:27 US Coast Guard Sector Anchorage Narrative Summary: ============================================================================================= Completed review of EEP & deficiency check. Issued approval letter & stamped cover page. Administratively cleared requirement issued 19May2015 during COC examination w/in OCMI Puget Sound zone. Rcvd attached EEP Rev 2.0 (18May2015) submitted by Shell Gulf of Mexico, Inc for the semisubmersible Polar Pioneer in the Chukchi Sea (Burger Prospect Posey Blocks 6912 & 6762). Reviewed to 33 CFR 146.140 requirements. Attached OCMI Western AK ltr w/ stamped "Approved" cover page to documents/certificates. //s// , GS12, USCG Sector Anchorage Activity Action Log: Eff. Date Unit Individual Description ============================================================================================= 06/02/2015 SEC Anchorage Activity Created. Status: "Open - In Progress" 06/02/2015 SEC Anchorage Status Changed to "Open - Submitted for Review"
Activity Summary Report Title: Initial COC-MODU Activity ID: 5102919 Activity Start Time: 05/19/2015 9:00:00 AM Originating Unit: SEC PgtSnd Owner Unit: SEC PgtSnd Controlling Unit: SEC PgtSnd Activity Type: Vessel Inspection/PSC Team Lead: Status: Open - Submitted for Review Status Date: 06/18/2015 Prompt Date: Subject POC: Vessel Information ============================================================================================= Vessel Name: VIN: Flag: Length: Tonnage(GRT/ITC): POLAR PIONEER 8754140 MARSHALL ISLANDS 380.7 Year Completed: Vessel Type: Propulsion Type: 1985 Offshore-MODU-Semisubmersibles Engine Compartment: Fuel Compartment: Construction: Unknown Unknown Unknown Activities Conducted: ============================================================================================= Type Date Unit Deficiency Check 06/02/15 SEC PgtSnd Deficiency Check 06/08/15 SEC PgtSnd Deficiency Check 06/12/15 SEC PgtSnd Deficiency Check 06/14/15 SEC PgtSnd Ballast Water Examination 05/19/15 SEC PgtSnd COC-MODU Renew 05/19/15 SEC PgtSnd Inspection Results ============================================================================================= System Date Results Communications 05/19/15 Inspected Satisfactory Electrical 06/12/15 Deficiencies Found and Corrected Engineering 05/19/15 Deficiencies Found and Corrected Fire Fighting 05/19/15 Outstanding Deficiencies Exist Navigation 05/19/15 Inspected Satisfactory Personnel 05/19/15 Inspected Satisfactory Accommodation/Occupational Safety 05/19/15 Deficiencies Found and Corrected Operations/Management 05/19/15 Deficiencies Found and Corrected Construction/Loadline 05/19/15 Inspected Satisfactory Deck/Cargo 05/19/15 Deficiencies Found and Corrected Documentation 05/19/15 Deficiencies Found and Corrected Lifesaving 06/08/15 Deficiencies Found and Corrected Pollution Prevention/Response 05/19/15 Deficiencies Found and Corrected Stability 05/19/15 Deficiencies Found and Corrected Inspection Results - Deficiencies ============================================================================================= ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 1 By specified date and/or by 06/19/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Operations/Management Vessel Safety Management Emergency Preparedness
---Description--- 0199 - Other(certificate) - Emergency evacuation plan (EEP) not present during exam. Submit EEP for approval from OCMI of Western Alaska. - 33CFR146.140 - Action code: 50c.
ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 10 By specified date and/or by 06/02/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Deck/Cargo Holds/Tanks Ventilation Exhaust Outlet
---Description--- 0900-Safety in general- Numerous flame screens found in poor condition. Replace vent flame screens throughout rig. action taken: 16a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 11 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Deck/Cargo Ballast Pumps
---Description--- 1499-other(prop.& aux machinery)- Ballast pump motor #2 not available for inspection(pulled for service). Provide pump motor for inspection. action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 12 05/19/2015 05/19/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Means of Escape Blocked
---Description--- 0960-Means of escape- Emergency exit located between laundry room and cinema room blocked. Provide clear passage way for emergency exit.- MODU code 9.3.1.3 action taken: 10c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 13 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Accommodation/Occupational Safety Ventilation General
---Description--- 0999-Other(safety in general)-Ventilation dampers shall be labeled to indicate "open and close" position. Prove satisfactory operation.-79MODU code 9.10.1 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 14 05/19/2015 05/19/2015 SYSTEM SUBSYSTEM COMPONENT Accommodation/Occupational Safety Medical/First Aid Medicine Chest
---Description--- 0371-Medical equipment-No first aid kit present in ballast control room as per fire fighting and life saving plan. Provide first aid kit for this location. 79MODU code 10.9 action taken: 10c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 15 05/19/2015 05/19/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Fire Hoses Condition
---Description--- 0799- other(fire fighting equipment)- Wasted gasket on fire hose found at fire station 24. Provide new gasket. 79MODU code 9.4.3.2 action taken: 10c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 16 05/19/2015 05/19/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Nozzles Condition
---Description--- 0799-other(fire fighting equipment)- Seized fire fighting nozzle found at fire station 15. Provide operational nozzle.- 74MODU code 9.4.4 action taken: 10c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 17 05/19/2015 05/19/2015 SYSTEM SUBSYSTEM COMPONENT Pollution Prevention/Response Prevention Equipment Oily Water Separator (15 ppm)
---Description--- 1735-Pumping discharge arrangements- The first valve located after the 3-way valve on OWS overboard discharge piping has two missing bolts on flange face. Replace missing bolts. 73/78 MARPOL action taken: 10c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 18 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Pollution Prevention/Response Prevention Equipment Oily Water Separator (15 ppm)
---Description---
1799-other(MARPOL Annex I)- Crew was unable to operationally test the OWS. Demonstrate proficiency, to include oil content meter history. 73/78 MARPOL Annex I/14.6 action taken: 17c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 19 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Stability Watertight Integrity General
---Description--- 1270-Doors- Prove proper operation of watertight doors. Ensure gasket material is in good condition and watertight. - 79MODU code 3.4.1 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 2 05/19/2015 06/08/2015 SYSTEM SUBSYSTEM COMPONENT Lifesaving Rescue Boat Propulsion Engine
---Description--- 0615 - Rescue Boats - Forward fast rescue craft not operational. Demonstrate satisfactory operation of forward fast rescue craft. - 79MODU code 10.2.1.4 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 20 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Electrical Electric Generation Source (emergency) Generator
---Description--- 0950- Prove satisfactory safety tests of emergency generator. 79MODU code 5.3.7 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 21 By specified date and/or by 06/19/2015 05/19/2015 06/05/2015 SYSTEM SUBSYSTEM COMPONENT Documentation Safety Management System Key Shipboard Operations Plans/Instructions
---Description--- 0199-Other(certificate)- Provide approved revision of operations manual.(Approval from class society).- MODU code 14.1.1 Action taken: 50a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 22 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Structural - A Class Divisions Bulkheads - Machinery Spaces
---Description--- 0750-Fire prevention- A-0 boundary in way of fuel oil equipment room not sealed. Properly weld tight to not allow passage of smoke or flames. 79MODU code 9.2.5 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 23 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Structural - A Class Divisions Openings - Doors
---Description--- 0750-Fire prevention- Laundry room door handle and lock missing at time of exam. Fire boundary compromised. Properly install laundry room door handle and lock to maintain structural fire protection.-79MODU code 9.2.3 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 3 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Operations/Management Drills/Instruction Abandon Ship
---Description--- 0925 - Musters and drills - Witnessed unsatisfactory fire and abandon ship drill. Demonstrate satisfactory fire and abandon ship drills. 79MODU code 10.6.3.1 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 4 By specified date and/or by 07/08/2015 05/19/2015 07/11/2015 SYSTEM SUBSYSTEM COMPONENT Fire Fighting Structural Fire Protection - General Structural Bulkhead Construction
---Description--- 0950 - Electrical equipment in general - Multi-cable transit runs contain packing material for differing manufactures. Provide uniform packing material for all multi cable transit runs. 79MODU code 3.6.1/I.A.W. table 9.2 action taken: 50a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 5 05/19/2015 06/02/2015
SYSTEM SUBSYSTEM COMPONENT Fire Fighting Structural - A Class Divisions Openings - Fire Doors
---Description--- 0750 - Fire prevention - Multiple fire screen doors cannot properly close. Demonstrate proper operation of all fire screen doors. - 79MODU 9.1.5 & 9.2.1 action taken: 17b.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 6 By specified date and/or by 06/02/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Documentation Safety Management System Critical Equipment/Systems ID Procedures
---Description--- 0900 - Safety in general - Vital system piping (emergency bilge and ballast) not labeled in working language of the crew. Provide labeling in working language of the crew (english), as identified in the operations manual. - 79MODU code 14.1.2.6 action taken: 16a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 7 05/19/2015 06/12/2015 SYSTEM SUBSYSTEM COMPONENT Electrical Lighting (emergency) Lighting Fixture
---Description--- 0945-Emergency lighting etc.-Emergency lighting located in numerous spaces was not fully functional; numerous bulbs missing and dead batteries. Demonstrate proper operation of emergency lighting throughout the vessel.- 79MODU code 5.3.2.1.3 action taken: 17a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 8 By specified date and/or by 06/19/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Engineering Steam System (auxiliary) Lagging/Insulation
---Description--- 0900-Safety in general- Boiler condensate piping not properly insulated. Ensure piping is satisfactorily insulated.- MODU code 4.1.3 action taken: 50a.c. ITEM COMPLIANCE DATE DATE ISSUED DATE RESOLVED 9 By specified date and/or by 06/19/2015 05/19/2015 06/02/2015 SYSTEM SUBSYSTEM COMPONENT Documentation Certificates/Documents International Air Pollution Prevention Certificate
---Description--- 0160-IAPP certificate- Provide updated IAPP certificate to include shipboard incinerator.- 73/78 MARPOL annex VI/6 & 16 action taken: 50a.c. Documents and Certificates: ============================================================================================= Certificates: Document Description Issue Date Expire Date COC-MODU Renewal 06/14/15 06/14/17 Documents: Name: Description POLAR PIONEER FORM B 19MAY2015.pdf POLAR PIONEER FORM B ISSUED 19MAY2015.PDF POLAR PIONEER FIRE SCREEN DOORS REPAIRS EFFECTED 02JUN2015.pdf POLAR PIONEER WATERTIGHT DOORS REPAIRS EFFECTED 02JUN2015.pdf POLAR PIONEER COC ISSUED 14JUN2015.pdf POLAR PIONEER FORM A ISSUED 14JUN2015.pdf TOPP Recommendations.pdf Locations: Latitude Longitude Time Description ============================================================================================= 05/19/2015 09:00 Foss T-5
Narrative Summary: ============================================================================================= 19 MAY 2015: Sector Puget Sound conducted an initial COC exam for the MODU POLAR PIONEER, IMO 8754140 (option c). PII and BW exams were also conducted IAW MSM Vol. II Section D, international laws and treaties, and applicable U.S. laws and regulations. The POLAR PIONEER is a Marshall Islands flagged, 380.7ft long, non-self propelled, semi-submersible MODU with a keel laid date of 1984. The vessel's class society is DNV-GL. The vessel was moored at T-5, Seattle, Washington, port side to the pier. In addition to Sector Puget Sound personnel, the COC exam was conducted with Sector Anchorage, OCS NCOE, and CG-5 TI personnel in attendance. Bureau of Safety and Environmental Enforcement (BSEE) Inspectors attended the exam to familiarize themselves with CG inspected equipment as BSEE inspectors will be living onboard the vessel 24/7 during drilling operations. HULL INSPECTION: Examined the following certificates and documents: IMO MODU Certificate, COFR, Construction Portfolio, Certificate of Registry, ITC, ILLC, IAPP, EIAPP, IAFS, Class Certificates, CSSE, IOPP, SOPEP, ORB, Bunkering Notes, EPA Vessel General Permit, NTVRP, Garbage Log, Waste Management Plan, and BWM Plan; found rig had an incinerator aboard that wasn't listed on the IAPP or IOPP certificate supplements; issued def #9. Verified proof of BW Report submittal. Examined all officer national licenses with flag endorsements and verified compliance with the Minimum Safe Manning Certificate; all sat. Verified required number of lifeboat certified persons were onboard; all sat. Examined fire and abandon ship drill records; all sat. Examined maintenance records for lifesaving equipment; all sat. Examined firefighting equipment maintenance records; all sat. Examined DNV-GL Crane Load Test Survey Statements of Fact dated 05 MAY 2015 for stbd crane and 27 APR 2015 for port crane; all sat. Examined report detailing testing for all pressure vessels dated 22 JUL 2015; all sat. Examined class approved Operating Manual dated 31 OCT 2011. However the previously approved Operating manual was not up-to-date. The most current version had multiple changes, including changes to the stability section that was being routed to DNV-GL for approval. Issued def #21. Emergency Emergency Evacuation Plan has not yet been approved; issued def #1. Reviewed a satisfactory Minimum Safe Manning Certificate. Previous Safe Manning certificates was a topic of discussion between the CG, Class, Marshall Islands & Transocean since it allowed "field moves" of 20 nautical miles or less. The "field move" statement was problematic as it was not consistent with the Ops Manual and all other documentation indicating that that the rig was non-self propelled. In the current, valid Safe Manning Cert, the statement allowing field moves was removed. Instead, it contained a clause permitting the use of thrusters in the event of an emergency & as an aid to maintain position while anchored & while being towed. Conducted deck walk: Inspected deck/hull openings, safety items, hull markings, and draft marks; found some flame screens on fuel tank vent were missing or in poor condition; issued def #10. Examined port crane (National Oilwell Varco, OC 3000 LCV) & stbd crane (Liebherr BOS 4200-50); all sat. Examined firefighting equipment; all sat. Witnessed testing of 3 fire pumps: 1 pump supplying 2 monitors, 1 pump supplying 2 fire hoses, and 1 pump supplying 1 hose & 1 monitor; all sat. Inspected heliport and associated firefighting equipment; all sat. Inspected lifesaving equipment: Completed check of lifeboat breathing air system, food, water, & distress flares on all 4 lifeboats in the stowed position; all sat. Witnessed operation of all 4 lifeboat engines and steering while in the stowed position; all sat. Witnessed operation of all 4 lifeboats' sprinkler systems after lowering the lifeboats to the water; all sat. Tested all 4 lifeboat limit switches during their retrieval; all sat. Witnessed operation of the aft Fast Rescue Craft (FRC) in the water; all sat. The forward FRC failed to start despite numerous attempts. The crew informed the inspections team that they knew of a cracked fuel filter and bad fuel; parts were on order; issued def #2. Conducted general health and safety walkthrough: Examined hospital and first aid equipment. Medical items stocked and inventoried. Found that first aid kit was missing in ballast control room; issued/cleared def #14. Spot-checked crew accommodations, and workplace health and safety; found laundry fire door missing its door handle and lock. The door also had a hold back arrangement constructed of line and duct tape; issued def #23. Found emergency exit located between laundry and cinema rooms blocked; issued/cleared def #12. Examined galley spaces; all sat. Witnessed operational test of smoke detectors at the following locations: Hospital, Technical Section Leader room, Electronic Engineer room, radio room, laundry room, passageway at cooks & catering room & paint stores; all sat. Found wasted gasket on fire hose station #24; issued/cleared def #15. Found seized nozzle on fire hose station #15; issued/cleared def #16. Found several vent dampeners were not labeled indicating the opened and closed positions; issued def #13. HAZARDOUS LOCATIONS: Examined hazardous location plan and conducted walkthrough from the drilling floor, throughout mud system, and return. Found several multi cable transit (MCT) bulkhead were packed using different systems in the same penetration and/or had non-approved sealant applied to the penetration; issued def #4. MACHINERY INSPECTION: Conducted walkthrough of all machinery spaces including Port and Stbd Pontoons. Found numerous fire screen doors that did not completely close or had missing closure devices; issued def #5. Found numerous watertight doors (WTD) with deteriorated/improper gaskets and/or indicator light malfunctions; issued def #19. Found multiple emergency lights throughout the rig were inoperable; issued def #7. Found that emergency bilge and ballast system piping was not labeled in the working language of the crew; issued def #6. Fire extinguisher #69 was not secured in the Stbd Aft Computer Room (column upper level);
corrected on the spot. Found EEBD #5 in the Stbd Aft Pump Room was low on pressure (approximately 1/2 charge); crew to replace/recharge. Vent valves were spot-checked in the Stbd Fwd Pump Room after the Barge Engineer located the correct actuation/indicator panel in the Control Room. Found #2 Ballast Pump motor was removed for service; issued def #11. Found machinery guards in the pump rooms were not installed; corrected on the spot. Found that a small section of electrical mat in the LV Room was missing; corrected on the spot. Found a hole in the A-0 boundary bulkhead in the fuel oil equipment room; issued def #22. Witnessed testing of the following equipment: Stbd Aft Thruster Room: -Remote sea chest valve; all sat. -Remote (manual) brine valves; all sat. -Bilge alarm; all sat. Stbd Pontoon -Bilge alarm (aft); all sat. Stbd Fwd Pump Room: -Vent valve 205 (remote ventilation valve); all sat. -Vent valve 204; all sat. Engine safeties verified: -MDG 1 Overspeed; intake air flaps closed; all sat. -MDG 2 Reverse Power Relay (RPR), Low lube oil trip; all sat. -MDG 3, 4, 5: accepted recent DNV-GL testing. -E-Gen auto-start & bus transfer (2 & 19 seconds, respectively); all sat. Overspeed was attempted but crew could not get E-Gen to reset for restart; issued def #20. Aux boilers were not tested due to being 'cold iron'. Found boiler condensate piping missing insulation; issued def #8. MARPOL: Reviewed Oil Record Book. Verified operation of the OWS OCM and 3-way overboard valve via the OCM simulated PPM change. The 3 A/E was somewhat familiar with the system but did not know much about the OCM other than the simulated test feature. The OWS itself was not operated; issued def #18. Found two missing bolts on the first valve after the OWS 3-way valve; issued/cleared def #17. DRILLS: Fire Drill - Witnessed UNSATISFACTORY fire drill initiated within laundry room. Crewmember used to find the simulated fire had no knowledge of where nearest portable fire extinguisher was & had no knowledge where the nearest call point(s) were. In order to notify responsible person(s) of the fire, he walked to his foreman (a distance of at least 100 ft), walked past at least 2 rooms w/ phones, 2 call boxes, all while wearing a portable radio. The foreman had a portable radio and provided some on the spot training to the crewmember. During fire drill, the inspectors also found a tertiary labeled means of escape located between the laundry room & cinema that was blocked (corrected on the spot). Fire Team 2 donned fire fighting gear and proceeded to the scene through the main stairwell. Stairwell doors were not closed and boundaries were not maintained. Flash hoods were not properly donned and the team's dress was not checked prior to entry. The on-scene leader and unprotected team members were all in the passageway adjacent to Laundry Room. The fire hose was not fully connected at the scene and was not the correct fire station to use for the affected space (too far from the scene). Drill failed; issued def #3. Abandon ship drill - Witnessed UNSATISFACTORY abandon ship drill using the alternate (aft) muster location. Since rig will be operating within Arctic waters, the inspectors specifically required crew to don immersion suits. Crew instead arrived with lifejackets. Upon further direction, immersion suits were properly donned. The crew never achieved full accountability. 5 personnel were found at the wrong muster station. The muster was also delayed due to 3rd party contractor personnel number conflicts. Found that accountability namecards are only at one muster location and not at the other muster location. Recommended to OIM to have crewmembers speak up and take full accountability. All other observations on the bridge were satisfactory. Drill failed; see def #3. It was apparent that Transocean was not ready for the exam. Vessel recently completed an extensive shipyard period in Singapore; the vessel recently changed out crew and the crew is still learning the vessel's systems. To make the exam more complicated, the DNV-GL surveyor was still completing necessary surveys. Overall, the vessel was not ready for the CG's examination. Issued 23 deficiencies: 5 corrected on the spot and 18 remain outstanding. 9 of the deficiencies were required to be corrected prior to departure to satisfaction of Class and/or CG. Issued Form A and Form B. COC was not issued. There are also an list of inspection recommendations named "TOPP Recommendations" , included on Documents. Examination to continue.
// 02JUN2015: Visited vessel same as before to conduct Deficiency Check. Met with OIM & vessel representative
. Discussed MCT repair proposal and emergency lighting repair proposal. MCT repair proposal plan prioritized repairs in 3 levels of priority. Priority 1: Below the waterline, in hazardous locations and/or protected by fixed fire extinguishing systems to be completed prior to departure; Priority 2: other machinery spaces, drilling spaces and one room leading into the radio room; Priority 3: spaces above the waterline other than Priority 1 or Prioroty 2 spaces. All priority 1 repairs have not been completed; currently 31 percent complete. Advised Transocean request plan approval from DNV-GL. Noted that Transocen received Stability Manual approval letter and DNV-GL cleared CC 519. Discussed remaining outstanding conditions of class and requested the updated DNV-GL survey report. DRILLS: FIRE: Witnessed fire drill in the paint locker. Crew members dressed in fire fighting gear and was tested on their ability to operate their SCBAs. All crew members were knowledgeable and capable of fire-fighting techniques and how to use their equipment. All sat. ABANDON SHIP: Witnessed abandon ship/lifeboat drill. All crew mustered at their respective life boats with life jackets and donned immersion suits as per their safety procedures. Lifeboat captains took personnel accountability and reported to the master on the bridge. No boats were lowered because they were lowered on 19MAY2015 with exception of 1 FRC pending repairs. All sat. The following 13 defs were cleared: Def #3: Fire and Abandon Ships drills conducted satisfactorily on 02JUN2015. Def #5: All fire screen doors were verified to close properly. Def #6: Bilge and Ballast Piping Label in working language of crew. Def #8: Boiler condensate piping insulation was added back, as per original design. Def #9: Current IAPP certificate included incinerator. Def #10: Verified that all previously broken flame screens renewed throughout vessel. Def #11: Ballast Pump Motor #2 available for inspection and operationally tested satisfactorily. Def #13: Ventilation dampers labeled indicating open and closed positions.. Def #18: Crew operationally tesed the OWS and proved proficiency with equipment. Def #19: Verified that all WTD's closed properly and had functional indicator lights. Def #20: Witnessed satisfactory tests of emergency generator. Def #22: The hole in the A-0 bulkhead in the fuel oil equipment room was welded shut. Def #23: Laundry room door was fitted with proper handle and lock. Noted overboard discharge missing lockout device. Corrected on the spot. All sat. In STBD column leading to bilge and ballast space: noted light cover missing from WTD indicator & paint on the WTD light alarm. Corrected on the spot. All sat. Cleared 13 defs, issued 00 defs, 05 remain outstanding. Examination to continue. // 03JUN2015: Received EEP Approval letter from OCMI Western Alaska dated 02JUN2015; cleared def #1. Cleared 01 defs, issued 00 defs, 04 remain outstanding. 05JUN2015: Received Operations Manual, examined by DNG-GL dated 02JUN2015. Found Ops Manual complete. Cleared def #21. Cleared 01 defs, issued 00 defs, 03 remain outstanding. // 08 JUN 15 - Attended vessel to conduct a deficiency check. Witnessed FWD fast rescue boat operation satisfactorily; cleared def #2. Witnessed battery powered emergency light operation in the following spaces: all port pontoon spaces and elevators, well test deck, rig control room, high and low voltage switchboard rooms, generator and purifier rooms, and fwd lifeboat embarkation area; all sat. Approximately 200 emergency lights had been replaced. Amended def #7 to require that the emergency lights be repaired prior to departure instead of by 03Jun15. There are still approximately 100 emergency lights that needed to be repaired/replaced. Inspected newly packed MCTs in Priority 1 areas (below the water line, in hazardous zones, and in spaces protected by a fixed gas firefighting system); all sat. Changed due date on def #4 from prior to departure to 30 days from 08 June. 02 pending defs: #4 and #7.
Recommendations to resolve. Found leaking hydraulic valve actuator and small amount of oil in the Stbd Aft Pump Room bilge; crew to repair/clean. Found portable oil pump and 55 gal oil drums in the stbd aft thruster room; crew to stow or properly mount pump and stow 55 gal oil drums. Found one filter was missing from the #1 high voltage (6kV) transformer; crew to renew all filters. Found numerous indicator lamps were “out” in the LV Room (breaker/MCC position indication); crew will check all bulbs and replace as needed. A leaking hydraulic valve actuator in the Stbd Aft Pump Room (adjacent to the fwd WTD) was repaired and hydraulic oil was cleaned from the bilge. Intake screens/filters for the #1 high voltage (6kV) transformer were all renewed; all sat. Approximately 40 indicator lamps were renewed in the LV Switchgear Room; all sat. Portable waste oil pump was secured and 55 gal drums were removed from the Stbd aft thruster room; all sat.
Activity Summary Report Title: Port State Control - In-Service Inspection Activity ID: 5129741 Activity Start Time: 04/17/2015 11:31:00 AM Originating Unit: SEC PgtSnd Owner Unit: SEC PgtSnd Controlling Unit: SEC PgtSnd Activity Type: Vessel Inspection/PSC Team Lead: Status: Closed - Approved Inspection Status Date: 05/19/2015 Prompt Date: Subject POC: Vessel Information ============================================================================================= Vessel Name: VIN: Flag: Length: Tonnage(GRT/ITC): POLAR PIONEER 8754140 MARSHALL ISLANDS 380.7 Year Completed: Vessel Type: Propulsion Type: 1985 Offshore-MODU-Semisubmersibles Engine Compartment: Fuel Compartment: Construction: Unknown Unknown Unknown Activities Conducted: ============================================================================================= Type Date Unit In-Service Inspection 04/17/15 SEC PgtSnd In-Service Inspection 04/21/15 SEC PgtSnd Inspection Results ============================================================================================= System Date Results Inspection Results - Deficiencies ============================================================================================= (None) Documents and Certificates: ============================================================================================= (none) Locations: Latitude Longitude Time Description ============================================================================================= 48 07.1001 N 123 27.0166 W 04/17/2015 11:31 PORT ANGELES BOAT HAVEN Narrative Summary: ============================================================================================= 17 APR 2015: LT and CWO attended the POLAR PIONEER, a semi-submersible MODU upon its arrival in Port Angeles WA. The rig was cargo onboard the heavy lift ship BLUE MARLIN and could not be accessed because the required scaffolding from the BLUE MARLIN's deck to the rig's main deck underside catwalk had not been assembled. Visually inspected the outboard sides of the rig's pontoons and the overhanging pontoon bottoms from a USCG small boat; no issues visible. Visually inspected inboard sides of the pontoons from the deck of the BLUE MARLIN; no issues visible. There was no apparent damage caused by Greenpeace stowaways. Workers are beginning to cut the welded sea fastenings that connect the POLAR PIONEER's pontoons to the BLUE MARLIN's deck. Additionally, the vessel's towing chocks will be renewed with larger chocks. Vessel will be refloated in 7-10 days once all sea fastenings are removed, new chocks installed, and rig startup crew has activated all safety and control systems.
21 APR 2014: Mr. Mr. and LT attended the POLAR PIONEER while the rig was still on the deck of the BLUE MARLIN to verify safety systems had been brought on line by the rig startup crew. The scope of this exam was much less than that of a PSC or COC exam. The exam was a brief walkthrough to verify that it was safe for the full crew to begin manning the rig post transit on the heavy lift ship. Verified crew was familiar with the muster station and personnel accountability for emergencies while the rig was atop the BLUE MARLIN. Fire detection and the rig's sprinkler system were operational. Fire main water was supplied by the BLUE MARLIN and was tested by the startup crew prior to the USCG walk through. The rig's generators were providing power to the rig and the emergency generator had been successfully tested prior to USCG walk through. Machinery cooling water was supplied by the BLUE MARLIN. Spot checked lifejackets and immersion suits; found several lifejackets were missing lights; lights appeared to be cut/ripped off, likely in Malaysia. Lifeboat and rescue boat fall protection devices will be removed immediately prior to the rig's refloating on 25 APR. Inspected several empty ballast tanks through their manholes for cleanliness; all sat. COC exam is scheduled for 19 May.
, LT, USCG Activity Action Log: Eff. Date Unit Individual Description ============================================================================================= 05/19/2015 SEC PgtSnd Activity Created. Status: "Open - In Progress" 05/19/2015 SEC PgtSnd Status Changed to "Closed - Approved Inspection"
Activity Summary Report Title: Ltr of Determination - Maritime MODU Advisor Activity ID: 5102556 Activity Start Time: 02/23/2015 1:46:00 PM Originating Unit: SEC Anchorage Owner Unit: SEC Anchorage Controlling Unit: SEC Anchorage Activity Type: Vessel Inspection/PSC Team Lead: Status: Open - Submitted for Review Status Date: 04/15/2015 Prompt Date: Subject POC: Vessel Information ============================================================================================= Vessel Name: VIN: Flag: Length: Tonnage(GRT/ITC): POLAR PIONEER 8754140 MARSHALL ISLANDS 380.7 Year Completed: Vessel Type: Propulsion Type: 1985 Offshore-MODU-Semisubmersibles Engine Compartment: Fuel Compartment: Construction: Unknown Unknown Unknown Activities Conducted: ============================================================================================= Type Date Unit Administrative Inspection 02/25/15 SEC Anchorage Inspection Results ============================================================================================= System Date Results Inspection Results - Deficiencies ============================================================================================= (None) Documents and Certificates: ============================================================================================= Certificates: Document Description Issue Date Expire Date Documents: Name: Description Letter of Determination Request.pdf Dated 02-17-2015 CG Ltr - Regular Complement Determination.pdf Dated 02-25-2015 Locations: Latitude Longitude Time Description ============================================================================================= 61 16.13942 N 149 38.29344 W 02/23/2015 13:46 US Coast Guard Sector Anchorage Narrative Summary: ============================================================================================= Completed Adminstrative Inspection to issue Letter of Determination (LOD). No requirements issued, cleared, or outstanding. Rcvd attached ltr dtd 17Feb2015 requesting LOD for Maritime MODU Advisors for the NOBLE DISCOVERER & POLAR PIONEER. 25Feb2015 - Unfamiliar w/ this position & knowing our determination may impact other OCMI zones , I spoke w/ 2 senior MODU inspectors fm MSU Morgan City. They both indicated the MODU advisors are like auditors/inspectors, therefore, not a regular
complement of the unit. Attached OCMI LOD dtd today indicates Maritime MODU Advisors not members of the regular complement of a unit as defined in 33CFR141.15(b). Mailed LOD to requesting party. No requirements issued, cleared, or outstanding. Administrative inspection complete. //s/ , GS12, USCG Sector Anchorage Activity Action Log: Eff. Date Unit Individual Description ============================================================================================= 04/13/2015 SEC Anchorage Activity Created. Status: "Open - In Progress" 04/15/2015 SEC Anchorage . Status Changed to "Open - In Progress" 04/15/2015 SEC Anchorage Status Changed to "Open - Submitted for Review"
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February 17, 2015
VIA EMAIL AND REGULAR MAIL Commander Hector L. Cintron Chief of Prevention U.S. Coast Guard Sector Anchorage 510 L Street, Ste. 100 Anchorage, AK 99501
Re: Request for Determination that Maritime Advisors are not Members of the Regular Complement of an Outer Continental Shelf Unit
Dear Commander Cintron: On behalf of Shell Exploration & Production Company and Shell Gulf of Mexico, Inc. (collectively “Shell”), we request an exemption from the employment restrictions pertaining to units engaged in Outer Continental Shelf (“OCS”) activities on the basis that certain individuals are not members of the “regular complement of the crew.” 33 C.F.R. § 141.15. Specifically, Shell requests that the Coast Guard exempt four (4) foreign national Maritime Mobile Offshore Drilling Unit (“MODU”) Advisors (“Maritime MODU Advisors”) from the requirement to employ U.S. citizens or resident aliens aboard a vessel engaged in OCS activities. The following information is provided in support of this request. Background Shell intends to conduct exploration drilling activities in 2015 on federally-managed OCS oil and gas leases located a minimum of 64 miles from the coastline in the Chukchi Sea. These operations will take place pursuant to Shell’s Chukchi Sea Revised Exploration Plan which is scheduled to occur during the short open-water season, defined historically as approximately July through November. Shell has, in light of its experience operating on the Alaska OCS, identified a need to employ individuals with unique job skills during this period. Shell completed a review of its 2012 Chukchi and Beaufort Seas OCS exploration drilling operations and concluded, among other things, that there was a need to strengthen its maritime assurance controls for future operations. As part of this review, Shell identified a need to more closely monitor its Alaskan contractor operations to ensure that its contractors meet or exceed Shell standards and to ensure all operations are conducted in a safe and environmentally compliant manner.
Consequently, a new Maritime Assurance team was developed and charged with overseeing and executing maritime assurance tasks on board two MODUs, the Noble Discoverer and Polar Pioneer (the
Commander Hector L. Cintron February 17, 2015 Page 2
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“Vessels”), which are owned and operated by Shell contractors. The goal of this team and its marine experts is to ensure that all maritime aspects of Shell’s drilling operation will be conducted in accordance with applicable regulatory requirements, industry best practices, and Shell’s internal maritime standards. These individuals will help to ensure that the company executes its drilling activities exceptionally well in 2015.
The Maritime Assurance team tasked with overseeing the Vessels consists of four Maritime MODU Advisors that will work in rotating shifts aboard the Vessels to oversee operations on behalf of Shell. The Maritime MODU Advisors are Shell employees and will be Shell’s onboard marine assurance representatives. These are the four (4) foreign nationals for which we request the exemption from the OCS employment restrictions
This type of Maritime MODU Advisor is not typically employed by Shell on drillships during
normal drilling operations occurring elsewhere on the U.S. OCS. However, as noted above and as explained in more detail below, Shell has determined that the employment of these Maritime MODU Advisors is critical to enhancing Shell’s ability to provide the necessary oversight over some of its key contractors in order to operate safely in the Chukchi Sea this season.
Legal Requirements and Policy Guidance An employer of personnel on any unit engaged in OCS activities must employ, as members of the “regular complement of the unit,” only citizens of the United States or resident aliens. 33 C.F.R. § 141.15. Personnel considered part of the “regular complement of the unit” are those necessary for the routine functioning of the unit, including marine officers and crew, industrial personnel and general maintenance personnel. Individuals not considered part of the “regular complement of the unit” are specialists, professionals and other technically trained personnel called in to handle emergencies or other temporary operations, extra personnel on a unit for training, and other personnel temporarily on a unit for specialized operations, such as construction, alteration, well logging, or unusual repairs or emergencies. The CG-543 Policy Letter 02-01, dated February 2, 2002, provides additional guidance clarifying the Coast Guard’s interpretations of exemptions for specialists, professionals and technically trained personnel. According to this policy letter, the following factors should be considered in making an employment exemption determination: (1) job description relative to the units; (2) the period of time requested or anticipated; (3) type of operations (i.e., temporary, specialized); (4) degree of expertise or training needed; and (5) safety considerations. The Vessels Shell will utilize the Maritime MODU Advisors on the following two vessels:
x M/V Noble Discoverer: Self-propelled drillship owned, operated, and crewed by Noble Drilling International GmbH. Liberian flag (IMO # 6608608).
x MODU Polar Pioneer: Mobile Offshore Drilling Unit owned, operated, and crewed by Transocean. Marshall Islands flag (IMO # 8754140).
The Vessels will be operating on the Alaskan OCS in Chukchi Sea lease blocks 6714, 6762, 6764, 6812, 6912, and 6915.
Commander Hector L. Cintron February 17, 2015 Page 3
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Personnel and Specialist/Temporary Nature of the Work Performed by the Maritime MODU Advisors The four individuals that will serve as Maritime MODU Advisors are Mr. , Mr.
, Mr. , and Mr. . These individuals are all permanent Shell employees based in Shell’s offices in the United Kingdom and Singapore. Specific information on each of the identified individuals is provided in Enclosure (A).
The following is a brief discussion addressing each of the factors listed in the G-MOC Policy
Letter 02-01: Job Description Relative to the Unit: The job description for a Maritime MODU Advisor is discussed in Enclosure (B). The Period of Time Requested: It is anticipated that the four individuals will perform their specialized work from approximately June 1, 2015 – November 10, 2015 when activities occur in the Chukchi Sea OCS. This should be considered temporary in nature, for among other reasons, due to the short open-water season in Alaska. Type of Operations: As discussed in the background section above and in Enclosure (B), the Maritime MODU Advisors will perform highly specialized services when the MODU is operating on the Alaska OCS. In short, the Maritime MODU Advisors will be Shell’s onboard marine assurance representatives employed specifically to oversee contractor operations to ensure they are conducted in accordance with applicable regulatory requirements, industry best practices, and Shell’s internal maritime standards to ensure safe and environmentally compliant operations. Maritime MODU Advisors are neither necessary nor normally utilized in MODU operations. They are clearly not “necessary for the routine functioning” of the Vessels. They are neither officers nor crew of the Vessels, they will not stand watches, and they serve no direct industrial purpose (e.g., their duties are not akin to toolpushers, drillers, roustabouts, floor hands, crane operators. etc.), and they cannot be considered support personnel (e.g. cooks or stewards).1 Degree of Expertise or Training Needed: Each of the individuals is specifically trained and has extensive experience performing the functions required of a Maritime MODU Advisor in the offshore Alaska environment. The Maritime MODU Advisors are highly experienced Shell employees that possess a specialized level of expertise and in-depth knowledge of the maritime regulatory framework, best maritime operating practices, Shell’s internal maritime standards, and a mature HSSE culture. These individuals would report to the Shell Manager of Maritime Assurance through the on board Shell drilling
������������������������������������������������������������1�For example, the Policy Letter states that a weld inspection technician aboard a pipe-lay barge to ensure quality assurance or operate equipment that requires specialized training is not considered part of the regular crew complement. Clearly, a weld inspection technician performing services onboard a pipe-lay barge to assure quality or operate equipment would benefit the operations and mission of the barge. Nevertheless, because the technician is aboard temporarily to provide specialized services, he/she is not considered part of the regular crew complement. Another example involves drilling advisors that have been authorized for use on drill ships during specialized ultra-deep drilling operations following the Deepwater Horizon incident to ensure for the overall safety of operations. Specifically, “Wellsite Geologists” have been approved to supplement the current crew complement and not replace any of the U.S. citizen crew. These personnel provide specialized oversight, advice, training, and mentoring of the crew with regard to drilling operations and they do not stand any watches while onboard the Vessels. These personnel have been approved for use up to one year at a time in the Gulf of Mexico.
