A new Notice to Lessees (NTL) has been released by the MMS, superseding NTL 2002-G09. The new NTL 2006-G21, which is effective as of October 26, 2006, provides additional guidance on the review and update of Oil Spill Release Plans (OSRP), recognizes the National Incident Management System (NIMS), adds a new Section 22 to the OSRP regarding prevention measures for facilities in State waters, updates regulatory citations, and makes a few minor technical amendments.
As with NTL 2002-G09, this NTL provides clarification, guidance and information concerning facilities, leases, and pipeline rights-of-way (ROW) located seaward of the coastline with regard to who is required to submit a regional OSRP and how to prepare and submit a regional OSRP in the MMS Gulf of Mexico OCS Region. While much of the guidance remains unchanged, there are significant differences with the addition of Section 22 regarding State waters, and with the requirement that the OSRP must be consistent with NIMS as well as the National Contingency Plan and appropriate Area Contingency Plans.
This NTL also addresses regional OSRPs when referenced in an Exploration Plan or a Development Operations Coordination Document. When the state of Florida is an ‘affected State’, the MMS GOMR will not allow reference to a regional OSRP. In this instance, a site-specific OSRP must be submitted, or with MMS GOMR approval, an approved subregional OSRP may be referenced.
For assistance with your OSRP preparation under these new guidelines, contact RCP.