Post-Hurricane Inspection and Reporting

UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF AMERICA OCS REGION

NTL No. 2026-G01 Effective Date: May 9, 2026

NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL AND GAS LEASES AND PIPELINE RIGHT-OF-WAY HOLDERS ON THE OUTER CONTINENTAL SHELF, GULF OF AMERICA OCS REGION

Post-Hurricane Inspection and Reporting The Bureau of Safety and Environmental Enforcement (BSEE) Gulf of America OCS Region (GOAR) is issuing this Notice to Lessees and Operators and Pipeline Right-of-way (ROW) Holders (NTL) to provide updated guidance on inspections, reports, and plans to assess and address hurricane damage to Outer Continental Shelf (OCS) facilities and pipelines in the Gulf of America. This NTL supersedes NTL No. 2009-G30 addressing this same topic.

Authority

BSEE’s regulations at 30 CFR 250.103 authorize BSEE to issue NTLs that clarify or provide more detail about certain requirements. Various other BSEE regulations require, or provide BSEE with the authority to require, operators and pipeline ROW holders to submit to BSEE various reports, information, and notifications to assess damage from hurricanes. They include:

Pursuant to 30 CFR 250.192 you are required to submit reports and information to BSEE regarding impacts to your facility, production equipment, or pipeline due to a hurricane.

Pursuant to 30 CFR 250.919(b), if any of your structures were exposed to a natural occurrence (e.g., hurricane, earthquake, or tropical storm), the Regional Supervisor may require you to submit an initial report of all structural damage, followed by subsequent updates, which include the following:

1. A list of affected structures; 2. A timetable for conducting the surveys described in Section 14.4.3 of API RP 2A- WSD; and 3. An inspection plan for each structure that describes the work you will perform to determine the condition of the structure.

Pursuant to 30 CFR 250.919(c), the Regional Supervisor may also require you to submit the results of the inspections referred to in 30 CFR 250.919(b)(2), including a description of any detected damage that may adversely affect structural integrity, an assessment of the structure’s ability to withstand any anticipated environmental conditions, and any remediation plans.

Pursuant to 30 CFR 250.1005(a), the Regional Supervisor may prescribe inspections of pipeline routes for indication of pipeline leakage. Under 30 CFR 250.1010(h), the pipeline right-of-way holder remains responsible for accidents or damages that might occur as a result of failure to timely remove improvements and equipment and restore a site.

BSEE also requires that you remain in compliance with operational and inspection regulations at all times. Your ability to demonstrate and maintain compliance may be affected by a hurricane and this NTL provides guidance regarding inspection intervals and compliance requirements immediately following hurricanes.

Affected Area of a Hurricane

The affected area for each hurricane will be defined in future NTLs, which will be issued after the passage of each hurricane. For initial planning purposes, you should, at a minimum, include in your inspection plans any offshore OCS facility or pipeline that experiences hurricane force winds, as defined by the National Hurricane Center, as one-minute average wind speeds of at least 74 mph (64 knots). Surface winds are those observed to occur at the standard meteorological height of 10 meters (33 feet) in an unobstructed exposure. The future NTLs will also specify time frames for conducting inspections and surveys, submitting reports, and completing work to correct any damage.

Fixed OCS Platforms and Structures

A. Survey Requirements for Fixed OCS Platforms and Structures

Below are minimum assessment requirements for all fixed OCS platforms located in the affected area of a hurricane in the Gulf of America, pursuant to 30 CFR 250.919:

1. Perform a Level I survey on all platforms in the affected area A Level I survey, as described in API 2A-WSD Section 14.3.1, as incorporated by 30 CFR 250.901(a) and 250.919(b)(2), consists of an above-water general visual inspection (GVI) that focuses on obvious damage to the primary structure. Perform a GVI by conducting a walk-through of the structure with the goal of visually identifying specific areas of damage and potential concern. If damage is detected, use nondestructive testing when visual inspection cannot fully determine the extent of damage.

You should use post-hurricane flyovers or a close approach by boat to establish the general condition of the structure, including to determine if the structure has obvious damage or if a discharge of pollution is occurring. Access to the structure by normal means may be unsafe and may require special planning for the initial boarding party. Examples of potentially unsafe conditions include a leaning structure; structural damage to the helideck; and damaged or missing boat landings, walkways, and stairways.

In performing a GVI of the topside deck structure, inspect the structure from the lowest deck to the highest deck. Include inspection of:  deck framing in areas such as the drilling, process, production, and utility;  tie-downs and main deck connections for drilling rigs, flare booms, quarters buildings, etc.; and  helideck.

In performing a GVI of the primary jacket structural members in the splash zone and above water, concentrate on the condition of the more critical areas, such as deck legs, deck leg to pile connections, pile to jacket connections, and above-water jacket members. Typical structural damage to investigate includes:  bent, missing, or damaged structural members;  visual indications of overloading (i.e., bent or bowed members, severed members, cracks at pile to jacket connections);  dents on outboard members caused by impact from floating or fallen objects; and  distorted or twisted beams and columns.

In performing a GVI of the cellar (or lowest) deck, look for beams that may be buckled or out of square due to wave impact. If beams exhibit indications of wave impact induced buckling or yielding, trace structural members back to the deck leg to check for connection integrity and perform a Level III underwater structural inspection on that platform.

You should perform additional surveys in accordance with API RP 2A-WSD as follows: 2. Perform a Level II underwater survey for any platform: a. that experienced severe accidental loading that could lead to structural degradation as defined in API RP 2A-WSD, Section 14; b. that experienced an event that exceeded the platform’s original design or latest assessment criteria; or c. where Level I survey results indicate that a Level II survey is necessary.

3. Perform a Level III underwater survey for any platform: a. with areas of known or suspected damage, including platforms that experienced wave induced buckling or yielding of structural members API RP 2A-WSD, Section 14.3.3; or b. where Level II survey results indicate a Level III survey is necessary.

4. Perform a Level IV survey for any platform a. if a Level III survey detects significant structural damage; or b. if visual inspection alone cannot determine the extent of the damage.

The flowchart in Attachment No. 1 of this NTL depicts these post-hurricane survey requirements.

B. Manning and Resumption of Production for Fixed OCS Platforms and Structures Do not quarter personnel overnight or have them work on the platform 24 hours a day without prior BSEE GOAR approval if the Level I survey indicates structural damage, or if an engineering assessment determines that the latest assessment criteria have been exceeded (30 CFR 250.900). If it is operationally impractical for you to wait to complete the inspections or engineering assessment before you quarter personnel on a platform, obtain BSEE GOAR approval before you do so. At a minimum, make sure that you:

a. Develop a detailed, comprehensive around-the-clock weather monitoring plan; b. Comply with U.S. Coast Guard regulations contained in 33 CFR Subchapter C (Aids to Navigation), and 33 CFR Subchapter N (Outer Continental Shelf Activities); and c. Provide 24-hour full radio communications between any “field” boat used to conduct or assist in operations and the platform.

Before you quarter personnel on any platform, ensure that all firefighting equipment; flame, smoke, or heat detectors; gas detection equipment; and personnel safety and lifesaving equipment are maintained, inspected, and operational. Note: If you are required to maintain a firewater system and the system becomes inoperable, the appropriate BSEE GOAR District Office may grant you a temporary approval to utilize an adequate chemical firefighting system in lieu of a pre-existing firewater fire-fighting system while you make the necessary repairs.

If Level I, II, or III surveys identify structural damage, do not man the platform until you complete a structural analysis and perform any necessary repairs (see 30 CFR 250.900).

You may resume production after you complete a Level I survey that indicates no major structural damage, and after you successfully perform the tasks outlined in the section below titled “Safety Device Testing Time Extensions, Casing Pressure Monitoring, Pollution Inspections and Returning to Production.”

C. Notifications, Reports, and Repairs for Fixed OCS Platforms and Structures Pursuant to 30 CFR 250.919(b) and (c), if any of your structures have been exposed to a natural occurrence (e.g., hurricane, earthquake, or tropical storm), the Regional Supervisor may require you to conduct and submit reports of all structural damage, followed by subsequent updates. BSEE has determined that within 60 days of the passage of the hurricane, you must submit the information listed below via TIMSWeb:

a. A list of all your OCS platforms in the affected area; b. For each listed structure, an initial inspection plan that generally describes the work you will perform to determine the condition of the structure; and c. A timetable that shows how you will complete all inspections within 180 days after passage of the hurricane.

BSEE GOAR will review the inspection plans. You may submit amendments to your list of platforms and inspection plans for our consideration. Further, submit an amendment to your inspection plans whenever the results of a Level II survey require you to conduct a Level III survey.

Complete all surveys within 180 days after passage of the hurricane. On a case-by-case basis, BSEE GOAR may request that you submit the results of these surveys pursuant to 30 CFR 250.919(c). Complete all work to correct any damage you find during a platform survey before the beginning of the next hurricane season.

In accordance with 30 CFR 250.900(c), under emergency conditions, you may make repairs to primary structural elements to restore an existing permitted condition without submitting an application or receiving prior BSEE GOAR approval for up to 120-calendar days following an event. Notify BSEE GOAR within 24 hours of the discovery of the damage and provide a follow up written report to the BSEE GOAR within 1 week after you complete the repairs, as required under 30 CFR 250.900(c).

Make the required 24-hour damage notification required by 30 CFR 250.900(c) concurrent with your e-mail or electronic hurricane reports, as required by 30 CFR 250.192, and consistent with the guidance in NTL No. 2015-G02, “Hurricane and Tropical Storm Effects Reports,” effective July 27, 2015.

After completion of emergency repairs, make the required notification to BSEE GOAR via TIMSWeb. In the TIMSWeb submittal, provide sufficient information for BSEE GOAR to ensure that the structure has been repaired to its existing permitted condition.

In accordance with 30 CFR 250.919(a), you must submit a comprehensive in-service inspection report annually by November 1 to BSEE GOAR of the platforms you inspected during the preceding 12 months. For any post-hurricane surveys you conduct referenced in this NTL, provide the information described in Attachment No. 2 of this NTL in your annual report, using the standard OSTS inspection report format.

Surveys you conduct and are referenced in this NTL may omit requirements regarding the inspection of corrosion protection systems-marine growth, and the cathodic protection systems. However, in order for any inspection to be acceptable under the survey interval requirements indicated in subsection 14.4.2 of API RP 2A-WSD, you must perform a survey that includes all of the elements specified in Section 14.3 of API RP 2A-WSD.

Floating OCS Platforms and Structures

The United States Coast Guard (USCG) is the lead regulatory authority over floating OCS structures, as outlined in the Memorandum of Agreement between BSEE and USCG (BSEE/USCG MOA: OCS-04, Subject: Floating Offshore Facilities). BSEE GOAR and USCG intend to work in close cooperation with regard to the material condition, operational status, and any necessary repairs to any floating facility subject to this NTL.

In addition to this NTL, you should consult USCG D8 Policy Letter 01-2014, Guidance on

Post-Hurricane Inspection Requirements for Floating Offshore Production Facilities, published October 10, 2014, which contains USCG guidance on post-hurricane inspection requirements for floating facilities.

A. Survey Requirements for Floating OCS Platforms and Structures

BSEE regulates the structural integrity of floating OCS structures through 30 CFR part 250, Subpart I. BSEE GOAR recommends the following for all floating OCS structures located in the affected area of a hurricane:

1. Above-water Inspections for Floating Platforms and Structures For all floating structures in the affected area, conduct an above-water general visual inspection to establish the general condition of the structure, including to determine if the structure has obvious damage or if a discharge of pollution is occurring. Carefully inspect the critical connections of the deck to the hull. Visually inspect the hull from the structure and, if needed, by boat, looking for dents or other damage. Examine the underside of the topside deck for beams that may be buckled or out of square due to wave impact. For a tension leg platform (TLP) in particular, evidence of wave impact to the cellar deck can indicate that design criteria have been exceeded and/or the possibility of damage to the tendon system.

Visually inspect structural appurtenances that are vulnerable to damage from motion, such as the base of flare towers, crane pedestals, and drilling rig connections to the deck. Inspect hatches, doors, and other openings to the hull to confirm that they remained watertight throughout the storm and that no water entered the hull. Visually inspect mooring jacks and chain stoppers for indications of extreme stress or failure. Verify the operation of critical marine systems, including emergency power, ballast, bilge, firewater, and the marine monitoring system. If available, retrieve information from the marine monitoring system and review it for indications of hurricane severity and floating structure performance during the storm.

2. Underwater Inspections for Floating Platforms and Structures Conduct a general underwater visual inspection by divers or remotely operated vehicle (ROV) of the structure when the above-water inspection indicates that underwater damage may have occurred. In addition, conduct a general underwater visual inspection of the structure after severe accidental loading, such as a large object being knocked loose and potentially causing structural damage to the structure as it fell to the seafloor, or after an event exceeding the platform’s latest design/assessment criteria.

Conduct a general visual inspection of the mooring system if there is any unexpected offset after the hurricane or if the mooring line tensions exceeded 70 percent of the minimum breaking load (MBL) during the hurricane (or, for a TLP, any negative tendon tensions or unexpected changes in tendon tensions). You may determine the mooring tensions either from measured tension data or by using hindcast data to model the tensions that were on the mooring lines. Conduct this inspection on all mooring

lines, fairleads, and their foundations and piles. For a TLP, inspect the tendon porches, tendon top connections, tendons, tendon load measurement units, fairings or strakes (if so equipped), tendon couplings, and tendon bottom connector for any signs of damage or unexpected tendon movement. You may use flooded member detection to help identify leaks in buoyant tendons. Inspect tendon fairings for damage and for loss of free rotation. Inspect tendon bottom connectors for indications of vertical or rotational movement at the pile and intrusion of debris into the tendon receptacle.

B. Manning and Resumption of Production for Floating OCS Platforms and Structures USCG has the lead regulatory authority over approval to man (personnel on board more than 12 hours in successive 24-hour periods) a floating structure. Once USCG has initially approved the manning of the floating structure and is otherwise satisfied with the condition of the facility, you may resume production after you complete the BSEE and USCG required surveys that indicate no major structural damage, and after you successfully perform the tasks outlined in the section below titled “Safety Device Testing Time Extensions, Casing Pressure Monitoring, Pollution Inspections and Returning to Production.”

C. Notifications, Reports, and Repairs for Floating OCS Platforms and Structures Make sure that you begin all inspections immediately upon boarding the floating facility. Report all findings of these inspections and coordinate the repairs with BSEE GOAR. The time frame required for the completion of these repairs will be determined on a case-by-case basis.

Under emergency conditions, pursuant to 30 CFR 250.900(c), you may make repairs to primary structural elements to restore an existing permitted condition without submitting an application or receiving prior BSEE GOAR approval for up to 120-calendar days following an event. Notify BSEE within 24 hours of the discovery of the damage and provide a follow up written report to BSEE GOAR within one week after you complete the repairs. As a reminder, you should also coordinate with USCG regarding emergency, temporary, and permanent repairs on floating platforms.

Make the required 24-hour damage notification required by 30 CFR 250.900(c) concurrent with your e-mail or electronic hurricane reports, as required by 30 CFR 250.192, and consistent with the guidance in NTL No. 2015-G02, “Hurricane and Tropical Storm Effects Reports,” effective July 27, 2015.

Make the required emergency conditions repair notification via TIMSWeb. In the TIMSWeb submittal, provide sufficient information for BSEE GOAR to ensure that the structure has been repaired to its existing permitted condition.

Moored Mobile Offshore Drilling Units

BSEE and USCG have regulatory authority over mobile offshore drilling units (MODUs) on the OCS, as outlined in the Memorandum of Agreement between BSEE and USCG (BSEE/USCG MOA: OCS-08, Subject: Mobile Offshore Drilling Units (MODUs)).

Pursuant to 30 CFR 250.713(a), you must demonstrate that a moored mobile offshore drilling unit (MODU) is capable of operating in hurricane conditions. Following a hurricane, BSEE GOAR recommends that you to conduct the following inspections