Industry Input - Shell

Supporting Statement A
30 CFR 250, subpart H, Oil and Gas Production Safety Systems
OMB Control Number 1014-0003
Section 1.
Please list your title, company name, address and phone number.
Regulatory Project Advisor
Shell Offshore Inc
Hancock Whitney Building
701 Poydras, New Orleans, LA 70139
281-630-1524
Section 2.
Please put the current industry hour burden under the far right column. The hours that were
submitted in the previous information collection cycle are listed in the 3rd column.
Citation
30 CFR
250
Subpart H
and
NTL(s)
800(a);
880(a)(1),
(2)
801(c)

801(c);
802(c)(1);
802(c)(1)
802(c)(5),
(e)

803(a), (d)
803(b), (d)

803(c), (d)

Reporting and Recordkeeping
Requirement

General Requirements
Prior to production, request approval and pre-production
inspection; notify BSEE 72 hours before commencement;
notify upon commencement of production.
Request evaluation and approval from OORP that includes all
relevant information of other quality assurance programs by
appropriate qualified entity; or third-party certification mark
covering manufacture of SPPE.
Independent third-party for reviewing and certifying various
statements throughout this subpart.
Maintain a description of the process used to ensure the device
is designed to function as required in 802(a). Make available to
BSEE.
Document all manufacturing, traceability, quality control,
installation, testing, repair, redress, performance, and inspection
requirements, etc. Retain all required documentation of SPEE
equipment until 1 year after the date of decommissioning the
equipment.
Within 30 days of discovery and identification of SPPE failure,
provide a written notice of equipment failure to manufacturer
and Chief, OORP, or BSEE designee.
Document and determine the results of the SPPE failure within
120 days and corrective action taken; if appropriate, per
requirements, give copy of report to manufacturer and Chief,
OORP, or BSEE designee.
Submit to Chief of OORP or BSEE designee modified
procedures you made if notified by manufacturer of design

Hour
Burden
submitted
in 2018

Current
Burden
Hours

1

1

34

50

$30,000
1

1

2

2

2

5

5

5

2

2

814(a);
815(b);
828(a);
829(b);
841(b)
810; 816;
830
831;
833(a), (b);
837(c)(5);
838(c);
874(g)(2),
(h)(1)

changes or you changed operating or repair procedures as result
of a failure, within 30 days of changes.
BSEE will approve on a case-by-case basis.

1

Request District Manager approval of temporary repairs to
1
facility piping not to exceed 30 days.
Surface and Subsurface Safety Systems – Dry Trees
Submit request for a determination that a well is incapable of
14
natural flow.
Verify the no-flow condition of the well annually.
¼
Subsea and Subsurface Safety Systems – Subsea Trees
Notify/contact BSEE: (1) if you cannot test all valves and
Notifications
sensors; (2) 48 hours in advance if monitoring ability affected;
(1) ½
(3) primary USV designation changes; designating USV2 or
(2) 2
another qualified valve; (4) resuming production; (5) 12 hours
(3) 1
of detecting loss of communication; immediately if you cannot
(4) ½
meet value closure conditions.
(5) ½

1

5
20
2
1
1
3
1
1

831

Submit a repair/replacement plan to monitor and test.

2

2

837(a)
837(b)(2);
(c)(2)
838(a)(2);
839(a)(2)
838(c)(3)

Request approval to not shut-in a subsea well in an emergency.
Obtain approval to resume production (1) after communication
is restored; (2) P/L PSHL sensor.
Verify closure time of USV upon request of BSEE.

½
½

1
1

2

2

Request approval to produce after loss of communication include alternate valve closure table or alternate hydraulic bleed
schedule.
Production Safety Systems
Submit application, and all required/supporting information, for
a production safety system with > 125 components.
25 – 125 components.

2

2

26

60

19

40

< 25 components.

12

25

Submit modification to application for production safety system
with > 125 components.
25 – 125 components.

13

48

10

30

< 25 components.

7

17

Your application must also include all required certification(s)
[i.e., hazards analysis, etc.,] that the designs for mechanical and
electrical systems were reviewed, approved, and stamped by
registered professional engineer. [NOTE: Upon
promulgation, these certification production safety systems
requirements will be consolidated into the application hour
burden for the specific components]

6

10

6

6

842;

842(b)

842(d)

842(e)

851(a)(2)
851(b);
852(a)(2),
(3); 858(b);
865(b)
851(c)(2)
852(c)(1)
852(c)(2)
852(e)(1)
855(a)

855(b)

858(a)(3)
859(a)(3),
(4)
859(c);
860(b), (c);
related
NTL(s)
860(d)

861(b)

864
867(a)
867(b)
867(c)

Submit a certification letter within 90-days after production that
the as-built diagrams, piping, and instrumentation diagrams are
on file, certified correct, and stamped by a registered
professional engineer; submit all the as-built diagrams.
Maintain records pertaining to approved design and installation
features either the onshore field office, readily available
offshore, or location available to BSEE; make available to
BSEE upon request and retain for the life of the facility.
Additional Production System Requirements
Request approval to continue using uncoded pressure and fired
vessels.
Maintain most current pressure-recorder information at location
available to BSEE for as long as information is valid.
Request approval for activation limits set less than 5 psi.
Request approval to vent to some other location.
Request a different sized and upstream location of the PSV.
Review manufacturer’s Design Methodology Verification
Report and IVA’s certificate to ensure compliance.
Uniquely identify all EDS stations. [NOTE: while this is
considered a usual and customary business practice, not all
companies have done this correctly. The burden listed is only
for those who have new floating facilities.]
Maintain ESD schematic listing control function of all safety
devices on the platform, field office closest to facility, or at
location conveniently available to BSEE for the life of the
facility.
Request approval to use different procedure for gas-well gas
affected.
Post diagram of firefighting system; furnish evidence
firefighting system suitable for operations in subfreezing
climates.
Request approval to use a chemical-only fire system in lieu of a
water system (including extensions up to 7 days of your
approved request) by submitting, including but not limited to,
submittal of justification and risk assessment (and all relevant
information listed in the table of this section).
Change(s) made after approval rec’d re 860(b) - document
change; maintain the revised version at facility or closest field
office for BSEE review/inspection; submit new request
w/updated risk assessment for approval; maintain for life of
facility.
Annually conduct inspection of foam concentrates and tanks;
make documentation of foam available to BSEE.
Send foam concentrate sample(s) to authorized representative
for quality condition testing.
Maintain erosion control program records for 2 years; make
available to BSEE upon request.
Request approval of safety system/devices associated with
temporary quarters prior to installation.
Submit supporting information/ documentation if required by
BSEE to install a temporary firewater system.
Request approval to use temporary equipment for well
testing/clean-up.

½

1

½

1

2

2

35

35

1
1
1
1

1
1
1
1

8

8

18

18

1

1

8

8

39

39

½

1

2

2
$418 per sample

21

21

6

10

1

3

1

2

870(a)
874(g)(3)
874(h)(2)
876

880(a)(3)
880(d)(1)
890(a), (b)

890(c)

Document PSL on your field test records w/delay greater than
45 seconds.
Submit request with alternative plan ensuring subsea shutdown
capability.
Request approval to continue to inject w/loss of
communication.
Document and retain, for at least 5 years, all tube-type heater
information / requirements; make available to BSEE upon
request. Have qualified 3rd party remove and inspect, repair or
replace fire tube.
Safety Device Testing
Notify BSEE and receive approval before performing
modifications to existing subsea infrastructure.
Request approval for a well that is completed and disconnected
from monitoring capability to exceed more than 24 months.
Records and Training
Maintain records for 2 years on subsurface and surface safety
devices to include, but limited to, status and history of each
device; installation date and details, inspection, testing, repair,
removal, adjustments, reinstallation, etc.; at field office nearest
facility AND a secure onshore location; make records available
to BSEE.
Submit annually a contact list (w/all required information) for
all OCS operated facilities or submit when revised.

½

1

2

2

1

1

1

1
$ for 3rd party

½

1

1

2

48

48

½

1

½

1

Section 3.
Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories from the SPE link. If other
“Positions” are needed, please add to the table as appropriate.
https://www.spe.org/en/industry/oil-and-gas-salary-survey/

Position
Non-Engineering Technical
(Regulatory)
Non-Engineering Technical
(Operations)
Engineering – Production/Chemical
Weighted Average ($/hour)
Annualized Cost Burden

Hourly
Pay rate
($/hour
estimate)
$53.00

Hourly rate
including
benefits (1.4*
x $/hour)
$75.00

Percent of
time spent
on
collection
100%

Weighted
Average
($/hour)

$53.00

$75.00

100%

$75.00

$83.00

$166.00

150%

$249.00
$399.00
($829,920)

$75.00

Section 4.
Are there any other annual “non-hour” cost burdens resulting from the required collection of
information under 30 CFR 250, Subpart H that are not currently listed below? If so, please
provide the total annual non-hour cost burden resulting from the collection of information. The
estimates should take into account costs associated with generating, maintaining, and disclosing
or providing the information (including filing fees paid for form processing).
This ICR includes 19 non-hour cost burdens
In § 250.842 there are 10 cost recovery fees; as well as 6 non-hour cost burdens for Professional
Engineering (PE) costs:
•

•

•

Submit application for a production safety system with > 125 components - $5,426 per
submission; $14,280 per offshore visit; and $7,426 per shipyard visit. PE costs of
$126.47/hour.
o 1 submittal per year at $5,426
o Total = 1 x $5,426 = $5,426
Submit modification to application for production safety system with > 125 components $605 per submission and PE costs of $126.47/hour.
o 8 facilities with 3 modifications per year at $605
o Total = 8 x 3 x $605 = $14,520
Maintaining a regulatory compliance database for collection and distribution of information
on production safety systems. This is for CTG SMART database
o 8 facilities at $5000 per month
o Total = 8 x 5000 x 12 = $480,000

Do you have any comments on the availability of the data we are requesting, the frequency of
collection, the clarity of instructions and recordkeeping, the reporting format, or on the data
elements that are reported to BSEE?
o Most difficult thing is trying to collect the non-hour
costs associated with all the submittals.
o The instructions could have more detail and examples to
help with understanding the data collection.
o If BSEE could present a company’s prior submittal, that
would help in comparison and updating information.
o How is the data used? Is this a requirement for reporting
and how often?
o How is the information used to improve/reduce the burden on
the industry?