OTC 18649

Compliance for FPSOGulf of Mexico and Speculative Builds

Craig Colby, Sergio Matos, and Santhosh Kumar Mony, DNV Energy

Copyright 2007, Offshore Technology Conference

This paper was prepared for presentation at the 2007 Offshore Technology Conference held in
Houston, Texas, U.S.A., 30 April3 May 2007.
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presented, have not been reviewed by the Offshore Technology Conference and are subject to
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Abstract
Floating Production, Storage and Offloading (FPSO) facilities
have developed over the last 40 years to become an
increasingly popular solution worldwide for offshore field
development. To date no FPSO has been deployed within the
US Gulf of Mexico (GOM) where the dominant production
facilities have been fixed structures and floating production
system based on Spar, TLP, and Semi-submersible platforms.
Higher oil prices and significant ultra-deepwater prospects
extending farther beyond established pipeline infrastructure,
make FPSOs an increasingly viable option. Operators,
Contractors and new entrepreneurs worldwide want to capture
that market and are committing to the FPSO solution by
placing orders for speculative builds. Many of these build
contracts are signed without a specific field destination or
production contract in hand and are contracted with a
generic FPSO specification. The design specification of a
generic FPSO presents many challenges. Selecting a workable
environmental design envelope and the type of regulatory
environment the vessel should satisfy are some of the early
decisions that will determine the success of the investment.
This paper discusses the challenges of developing a
speculative build in view of regulatory requirements
worldwide and in the US GOM.
FPSO background and practices
Floating Production, Storage and Offloading units (FPSO)
have developed over the last 40 years to become an
increasingly popular solution for development of new offshore
fields. They have practical advantages compared to more
traditional types of offshore installations. In addition to being
one of the very few feasible technical solutions for the deep
and ultra-deep water remote locations, they represent a
comparatively low capital expenditure. They can to a large
extent, be built based on conventional shipbuilding technology
and finished and commissioned at the yard avoiding costly
offshore work. FPSO units can take heavy payloads as well as

providing storage and offloading facilities.

Further
advantages
include
easy
offshore
installation,
decommissioning and re-use.
The first FPSO was taken into use offshore Spain in 1977.
Over the next ten years the FPSO established itself as a viable
solution for offshore production and from a modest 12 units in
1985 the total fleet of offshore ship-shaped units (FPSO/FSO)
increased to almost 200 units some 20 years later1. At the end
of 2006 about 60% of the fleet is comprised of units that can
produce, store and offload (FPSO) with the remainder having
storage and offloading capacity only (FSO). Almost twothirds of today's FPSO fleet is made up of tankers converted
for production and storage service as shown in Table 1.
More significant to the offshore industry is the remarkable
expansion of the FPSO fleet in the last ten years as shown by
the solid line in Figure 1. The expansion is characterized by
two distinct cycles. The first in the mid to late 1990s when
new contracting strategies resulted in floating production
vessels being introduced in large scale to the North Sea. The
second cycle started in the early 2000s following large
deepwater discoveries in areas generally remote from existing
pipeline infrastructure and suitable for wet tree development.
Also shown in that figure is the annual average world crude
price. While the first cycle took place against a more volatile
crude price environment the second cycle is benefiting from
the new crude price threshold of $50 plus and the rapid
economic growth in some large economies. Based on the
number of FPSO units on order and forecast this second cycle
is expected to be longer and stronger than the previous one.
This scenario has attracted new entrepreneurs to the floating
production market financed by private investors and the
financial market. Many of these investments however are
made on a speculative basis without a production contract in
hand, i.e., a generic FPSO solution.
The challenges of a FPSO speculative build
Recent higher oil prices have added to the pressure to shorten
the development cycle of offshore oil and gas fields. Until
recently design and build cycles for newbuild FPSO projects
were in the range of 3-4 years with some 18 months for design
and specification and 24 months for construction and
installation. Today the project cycle has been cut down to
under two years using design one, build multiple strategies2.
This schedule compression can be achieved for multiple large
developments that have similar geologic, geographic,
economic, and contractual elements. While speculative builds

are by nature very different and cannot benefit from these

elements a key success factor for investors is to bring these
vessels to market in the shortest time possible.
In present market conditions this is a major challenge. The
prospective owner must assess the market opportunities and
develop a generic specification that is flexible enough to
accommodate project specific requirements (when an
application is found) but with enough definition to allow
efficient design and build execution.
The following
paragraphs provide a discussion of the considerations to be
made when considering a speculative newbuild FPSO vessel.
Early decisions on design specification
The design specification of a generic FPSO presents many
challenges. Selecting a workable environmental design
envelope can be a difficult task if the vessel is intended to
operate in different offshore environments.
The
environmental conditions for a target operation area, e.g., Gulf
of Guinea, will be a determining factor on the choice of
mooring system, hull shape, and riser configuration and will
impact on the expected production uptime. Even within a
given target area the environmental conditions can change
when a specific location is selected. For example, the analysis
of hurricane and loop current data suggests that extreme
environmental conditions in the western Gulf of Mexico are
less severe than those to be found in central and eastern Gulf3.
If the FPSO is intended to operate in hurricane or typhoon
prone areas, e.g., Gulf of Mexico and some areas in SE Asia,
the vessel will most likely be specified with a disconnectable
turret either internal or external. Depending on the local
environment during production and offloading uptime targets
may additionally require thruster assistance. The decision to
specify a permanent mooring or disconnectable turret with
thruster-assist will significantly affect the capital investment.
Environmental conditions will determine the FPSO
optimal hull shape, a wave-piercing bow or a flat-bottom
barge. Wave-piercing bows are normally associated with a
turret mooring system and suitable for harsher environment
locations. The vessel must be designed for larger bow
slamming, bow impact pressures and possible green water
loads. Barge-like FPSOs will normally be spread-moored and
are more efficient for locations characterized by long-crested
seas and where extreme design conditions are marginally
higher than the operating design condition. In that case the
combination of beam or quartering seas with frequent loading
and unloading of cargo tanks will introduce fatigue loading
that will govern the design of the side shell, side longitudinals
located at intermediate drafts and other hull internal structure4.
Both hull shapes can be designed to operate in a range of
environmental conditions but the floater performance can
result sub-optimal.
In addition to fatigue and ultimate strength considerations
FPSOs intended to operate in tropical areas will be subject to a
significantly more aggressive corrosion environment due to
higher ambient temperatures and humidity. The corrosion rate
of steel will double when temperature increases from 20C to
30C5. Uncontrolled corrosion can lead to structural failure
and loss of containment with unacceptable consequences. A
corrosion control strategy must be selected at the early stages

OTC 18649

considering a combination of suitable design corrosion

margins, type and expected breakdown of coating systems and
type and expected depletion rate of anodes.
Generally production contracts require the vessel to be on
location for the life of the field as disconnection from live
wells for a prolonged period of time can present flow
assurance problems in addition to the loss of revenue.
Provision for in-place inspections in lieu of regular five-year
dry-docking cycle must be decided in the design phase to
allow proper access for inspection without significant
economic consequences.
A key issue in the conceptual design of a FPSO is the
impact of the hydrocarbon process plant and its major
components on vessel motions, response and stability due to
their mass, position of the centre of gravity and windage area.
Other early decisions will be necessary regarding the demand
on systems and utilities by the future hydrocarbon plant and
how much integration is possible between those serving the
vessel and the plant. A speculative FPSO specification may
add some additional system/utility capacity and a plug-andplay approach to integrate needs e.g., for power, sea water,
compressed air and other facilities. However issues like gas
handling and the possiblility to flare or reinject produced gas
will impact the vessel arrangement and facilities. Another
aspect for systems and utilities serving the hydrocarbon plant
is that they must comply with the specific technical
requirements of National regulations. Experience shows these
requirements can cause substantial re-work and major negative
impact on production schedules if they are not identified at an
early stage. Finally, while the riser system is not normally part
of the supply scope the speculative FPSO specification must
address the interface and impact of different riser systems.
The speculative FPSO development process must be
flexible to accommodate as many options as possible but
having enough definition to allow specification and design,
initial cost estimates and possibly procurement and
fabrication. One approach is to define core generic elements
allowing for customization or upgrading in other areas when
the final location is known. This approach is illustrated in
Figure 2.
Construction Challenges
The growth in the FPSO market is constrained in the short
term by the building capacity. Slots at traditional shipyards
are booked up to three years in advance. With most booked for
the foreseeable future speculative FPSOs will have to look
elsewhere to find a slot. Yards and fabrication sites in China,
Middle East and elsewhere are the next option. Most of these
yards are capable of installing and/or expanding capacity to
build or outfit an FPSO. However they may fall short of the
engineering capacity or experience.
This will require
developing engineering construction documentation beyond
what is normally done for the more experienced yards, and
increased integration, technical support and quality
supervision of the production line of the yards.
Speculative builds may not have the freedom to select
design, fabrication and procurement suppliers as local content
requirements may force work to be done in-country or by local
companies. Selecting local partners and the implications and
limitations in the execution of the project resulting from the

OTC 18649

same should be well understood from early enough to cater for

a smooth execution.
Planning for Regulatory Compliance in the Global
Market
One key decision in the planning phase for a generic FPSO is
the type of regulatory environment the vessel should satisfy,
i.e., country-specific or international.
States have full
sovereignty with respect to regulating activities on their
continental shelves and, similar to other types of production
units, FPSOs are governed by National regulations. In
addition, FPSOs intended for multi-country operation must
comply with international safety regulations for transit in
international waters. In that case FPSOs must be registered
with a Flag State and have a valid Classification certificate.
While some National regulations incorporate the mostly
prescriptive international conventions, e.g., the IMO MODU
Code and require FPSOs to be registered with a Flag State and
classed, they may also contain risk-based performance criteria.
This will require risk analyses work that is supposed to be
repeated and refined at all project stages. This means that new
requirements may be introduced at later stages in the project
with a potential impact on cost and schedule depending on the
contracting strategy selected. An early decision on the type of
regulatory environment will help determine the extent of risk
analysis to be undertaken and documented, and the
opportunity cost to implement risk-based solutions.
National authorities tend to specify technical requirements to
hydrocarbon plants leaving the FPSO hull and machinery as
"marine" and covered by class/flag standards. Utility and
auxiliary systems, e.g., compressed air, instrument air, fresh
water, sea water cooling, etc. are however used for marine and
process systems and subject to a double set of requirements.
While establishing a set of consistent and workable standards
is a challenge for offshore projects that is augmented when the
project is generic. In most cases the project will be faced with
the application of National standards that are not well known
or rarely used outside the country of origin or have to
reconcile sometimes conflicting technical requirements. The
following paragraphs offer a brief review of some National
regulations and how they would impact the specification and
execution of a speculative newbuild.
FPSOs are commonly used in the North Sea. The FPSO
activity in the UKCS is regulated by the HSE. The regulations
are performance-based and require a Safety Case with
extensive supporting risk analysis work. The Operator has the
overall responsibility for safety and is responsible for
establishing a written verification scheme for the safety
critical elements identified in the Safety Case.
An
independent competent person (ICP) shall execute verification
according to this scheme. Classification may be used to
document partial compliance with regulations and Class
Societies also normally act as ICP for FPSOs. FPSO
operations in Norway are regulated by the Norwegian
Petroleum Safety Authority (PSA). The regulations are
essentially performance-based with the Operator having the
overall responsibility for safety objectives and for
documenting compliance. The operator must develop a

comprehensive verification program. Classification can be

used as part of the verification program to document partial
compliance with the regulations.
Until the Petroleum law is regulated in ANGOLA the offshore
E&P activities are governed by Production Sharing
Agreements (PSAs) where SONANGOL is a stakeholder.
There is no requirement for flagging or classing FPSO units
but Operators have used best practice and used class and
international conventions as basis. The offshore regulations in
NIGERIA are prescriptive and include aspects of safety,
environment and fiscal revenues. These regulations have not
been updated in many years and more recently the Department
of Petroleum Resources (DPR) has asked for risk explosion
studies. FPSOs must register with Nigerian administration
(Flag) and have a valid classification certificate documenting
satisfactory structural integrity, and follow mandatory surveys.
The requirements are enforced by the DPR as lead agency
although the Nigerian Maritime Authority (NMA) and Navy
have some jurisdiction on FPSO projects. In China the rules
and regulations are established by China Offshore Oil
Operation Safety Office (COOOSO). COOOSO reports to the
State Administration of Work Safety (SAWS) that in turn
reports to the State Council of China.
COOOSO
acknowledges some international rules and standards, and for
FPSOs Rules of major classification societies are accepted.
The Operator is responsible for obtaining the Certificate of
Compliance / Fitness from a certification agency authorised by
COOOSO. The Australian regulatory regime has many
elements of the US regime.
The Provinces in Canada have a large degree of independence.
There are two relevant regional jurisdictions on the east coast
of Canada, namely, the Canada Newfoundland Offshore
Petroleum Board (CNOPB) and the Canada Nova Scotia
Offshore Petroleum Board (CNSOPB), each having their own
regulations and slightly differing practices. Production units
must comply with the Drilling, Installation and Production
Regulations of the respective Boards, and be issued with a
Certificate of Fitness from an approved Certifying Authority
(e.g. DNV). In addition all floating units must comply with
Transport Canada Marine Safety Regulations. US regulatory
requirements are discussed in the following paragraphs.
US GOM Regulatory Compliance for FPSOs
Despite the prevalence of FPSOs world wide, no ship-shaped
FPSO have yet been deployed within the US Gulf of Mexico
(GOM). There have been many factors such as an established
transport pipeline network, US restrictions on flaring, and
preference for dry-tree wells contributing to a bias towards
other field production solutions.
With the new ultradeepwater developments extending farther from existing
infrastructure and a shifting preference towards shorter and
less capital risky field development cycles, FPSO are being
looked at as an increasingly viable option for the GOM. Also
with the recent GOM hurricane experiences over the past few
years, detachable self-propelled FPSOs can bring additional
risk mitigation by the ability to avoid a storm. These factors
are bringing FPSOs closer to reality in the GOM and it is very
possible to see some FPSO projects deployed soon. Many are

now looking at FPSO concepts both for specific projects and

on a speculation basis for the GOM. This brings up the issue
of how the regulatory compliance would be applied in US
waters and how it differs from other regions in the world.
With the risk adverse nature of the GOM oil & gas industry,
the lack of established regulatory track record for a US GOM
FPSO solution has been one concern for project development
decisions. MMS and USCG have been actively working with
industry over the past decade to address these concerns. A
quick summary of some major activities by both industry and
the US Government that have helped establish a basis for a
regulatory framework where FPSO can be deployed in the
GOM:
- FPSO Risk Assessment JIP6
- Development of an API Recommended Practice 2FPS
applicable for FPSO use in Gulf of Mexico7
- Numerous Deepstar studies supporting FPSOs8
- A comparative risk analysis of FPSOs with other
deepwater production systems in GOM9
- FPSO Environmental Impact Study (EIS) and Record of
Decision10
- Numerous workshops and technical papers initiated by
both MMS and USCG outlining expectations for FPSOs11, 12
What follows now is a summary of regulatory compliance
considerations for a speculative FPSO concept for the GOM.
In the US, both USCG and MMS share regulatory oversight
responsibilities for OCS floating production facilities and thus
both agency requirements must be considered. USCG
jurisdiction is specified in Title 33 of the US Code of Federal
Regulations (CFR) and MMS in Title 30. A Memorandum of
Understanding (MOU) outlining the shared responsibilities
and designates where one agency will take the lead in
particular areas13. For FPSOs, USCG is designated as the lead
agency for the vessel and MMS is the lead for the production
related systems with some shared responsibility for specific
items.
Different countries take different statutory regimes having a
prescriptive vs. risk-based performance approach. The US has
been normally prescriptive in nature towards compliance with
CFR specified requirements. Both MMS and USCG have or
are in the process of updated portions of CFRs to bring in new
requirements and establish a framework for FPSOs. As these
have limited application and many aspects of ultra-deep FPSO
for GOM are evolving, there may be aspects of project not
covered in the CFRs. Also for consideration, MMS has
publicly stated in various forums that they will need to be
assured that the use of [FPSO] technology does not increase
the general risk to the environment over other alternatives12.
Many of the previously cited risk assessments6, 9 were efforts
by industry to demonstrate this in a general basis for FPSOs
on the GOM. The issue of risk assessments is raised here as
there may be a potential to demonstrate acceptable risk for
areas that may fall outside the specifications established by the
MMS and USCG. It is encouraged that early dialog with both
agencies to clarify any such areas which fall outside specific
CFR and policy requirements.

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USCG FPSO Requirements

As stated earlier, the USCG is the lead agency responsible for
most areas of the vessel outside the production area and
production safety systems for shipped-shaped FPSOs. These
include, for example, structural integrity, stability, fire
protection, life saving, and offloading systems. A few areas
are specified as joint responsibility with the MMS such as the
mooring, turret, and hull-turret interface. The requirements of
USCG for an FPSO are specified in Title 33 CFR Subchapter
N; more specifically 33 CFR 143.120 which is very brief in
nature. A more comprehensive proposed rulemaking by
USCG for floating OCS facilities including FPSOs was
published in 199914 specifying requirements for design and
equipment, plan approval, inspection and certification, etc.. In
the proposed rule are cross references to CFR design
requirements for MODUs and tank vessels in addition to
industry recommended practices such as API 2FPS. Due to
the backlog of legislative activity for homeland security post
9/11/2001, this proposed rule is still pending and could be
soon published as either a final rule or interim final rule. In
the meantime, one aspect of the proposed rule the USCG has
made clear is the applicability of the requirements in OPA-90
for a GOM FPSO given by the tank vessel hull construction
standards found in 33 CFR 157.10d11.
For various reasons, many of possible FPSOs being consider
for the GOM are planning on maintaining a non-US Flag.
One is use of a foreign flag can facilitate a simpler path in the
USCG approval process under USCG Merchant Vessel
Inspection (MVI) policy letter 13-9215. This MVI has similar
to the language to that contained in the proposed Subchapter N
rule and for what USCG uses for foreign flagged MODUs
operating in the OCS. The compliance primarily must be to
one of the following options:
- US Flag requirements
- Foreign Flag requirements found equivalent by USCG to
US Flag requirements
- IMO MODU Code requirements
- Having both a valid SOLAS Cargo Ship Safety
Construction Certificate and SOLAS Cargo Ship Safety
Equipment Certificate plus meet US Flag requirements for
items not addressed in these certificates.
The last option, SOLAS, appears to be the most preferred
option as SOLAS compliance is an area well understood by
FPSO operators and already in place for candidate vessels.
Apart from the MVI requirements, other areas for USCG
consideration are:
- Offloading methods and specifications.
- Any special crew manning and certification of personnel
requirements.
- OCS Facility Security Requirements covered in 33 CFR
Part 105.
Where do Classification Societies such as DNV fit into such a
schemes? First, classification rules for FPSOs have a long
established history of application and a familiar to most design
and operating companies. API when creating a standard
applicable for FPSO in API 2FPS chose to incorporate by
reference Recognized Classification Society (RCS) Rules for

OTC 18649

many parts instead of trying to recreate them. Classifications

Societies have long worked closely with established flag states
in the application of international standards towards FPSOs.
Finally, Classification Societies such as DNV have a track
record of working with USCG assisting Foreign Flagged
MODUs with the documentation requirements in order to
obtain USCG Letter of Compliance to cooperate in the US
OCS. With such experience, the Classification Societies such
as DNV can facilitate documenting compliance in a
streamlined manner.
MMS FPSO Requirements
The applicable MMS regulations for OCS production facitlies
are specified in 30 CFR 250 and are covered by:
- Subpart B: Field Development Plans and Information
- Subpart H: Oil & Gas Production Safety Systems
- Subpart I: Platform and Structure Requirements
Requirements for field development are specified in Subpart
B, Plans and Information which cover the permitting including
the approval of the Exploration Plans (EP), Deepwater
Operations Plan (DWOP) and Development Operations
Coordination Plans (DOCD). This is handled by the lease
holder for each specific field but some key information to be
submitted is particular to the chosen facility and accordingly
such information must be considered when planning a
speculative FPSO project. These requirements were recently
updated in 200516. Many of the submitted information pertain
towards the potential environmental impact of a development
solution. Information that must be supplied and evaluated
related towards air emissions and overboard discharges. For
OCS facilities, MMS must ensure compliance with the
National Environmental Policy Act (NEPA) which includes
new permitting for new OCS discharge sources and may
require mitigation measures for high volume seawater cooling
systems that can be applicable for an FPSO. The NEPA
requirements are being phased in for new OCS Oil and Gas
facilities and can affect concepts new being considered. Also
for consideration is if the FPSO concept falls outside the case
considered in the EIS12. If so, additional work may be
required to update the EIS. Finally, this CFR part covers a
process for proposing and vetting with the MMS through the
DWOP process any new technology that could be employed or
any alternate compliance measures that are proposed.
FPSO topsides production safety requirements are listed in 33
CFR Subpart H (250.800) incorporating by reference many
API standards such as:
- API RP 14C for Safety Analysis for Production Safety
Systems.
- API RP 14E, Design and Installation of Offshore
Production Platform Safety Systems
- API RP 500 or 505 for Hazardous Area Classification
- API 14F or API 14FZ for Design and Installation of
Electrical Systems
- ASME code for Pressure Vessels and Pressure Relief
systems.
Designs for the mechanical and electrical systems much be
certified by a registered professional engineer to the applicable
standards in this subpart.

For speculative FPSOs, the additions of API RP 14FZ and API

RP 505 to the CFRs were an improvement that was made
possible after the introduction of Article 505 in the 1999
National Electrical Code. These documents specify hazardous
locations as classed by designations Zone 0, Zone 1, and Zone
2 instead of the traditional US Division 1 and Division 2
designations used in the API RP 500. The zone approach is
closer aligned with definitions used by the IEC and
Classification Societies for floating facilities and should
reduce the modifications needed to existing FPSO design
practices as well as produce more cost effective and reliable
installations. Hazardous equipment may require an ANSI
AEx designation that are normalized versions of the IEC
60079 series standards and can have some extra requirements
that exceed IEC specifications.
One area of focus for MMS will be the interface between the
marine systems and production systems so any impact of
marine system safety and reliability that effect production or
subsea ESD systems must be documented as adequate. For
FPSO conversions, documentation of preexisting equipment
safety standards and obtaining MMS approval of alternate
standards, if they are found as adequate, should be considered.
Requirements for the vessel are identified in Subpart I,
Platform and Structure Requirements and were updated in
200517. For this subpart, MMS employs a third-party Certified
Verification Agent (CVA) which acts on its behalf to verify
compliance with applicable requirements. The recent update
formalized the MMSs and its CVAs role for ship-shaped
floating facilities limited to turret and turret-and-hull
interfaces, foundation and anchoring systems, and mooring
systems. Additional design and certification requirements
were added for all floating facilities including FPSOs for
drilling, production, and pipeline risers, and riser tensioning
systems. Finally, this updated incorporated by reference many
industry standards applicable for FPSOs such as API RP 2FPS
referenced earlier and API RP 14J, Recommended Practice for
Design and Hazards Analysis for Offshore Production18.
Conclusion
Over the last decades the FPSO has established itself as a
preferred solution for deepwater production both as early
production and as a permanent production system due to its
cost, schedule and its ability for potential re-deployment to
produce other fields. The surge in deepwater discoveries in
recent years has prompted many operators, contractors and
investors to consider building speculative FPSO units for
worldwide use.
Deepwater discoveries in areas beyond existing infrastructure
make the FPSO an increasingly viable option also for the
GOM. The MMS and USCG have been actively working with
industry over the past decade on the FPSO issue. Both
agencies have or are in the process of updating portions of
Code of Federal Regulations to bring in specific requirements
and establish a basis for a regulatory framework where the
FPSO can be deployed in the GOM.

OTC 18649

The more conservative nature of the GOM oil & gas industry
and the lack of an established regulatory track record for a US
GOM FPSO solution are concerns for project development
decisions. For that reason investors will require some
flexibility in the speculative FPSO. The speculative FPSO
must be targeted at an operation area(s) or prospect(s) with
due consideration of the regulatory regime and requirements.
The specification should be prepared in a format that is
flexible enough to accommodate future project needs but
having enough definition to allow design and build. A
systematic approach early in the investment phase to address
the technbcial and regulatory elements mentioned in this paper
will help in achieving a cost effective and smooth execution
for speculative FPSOs.
References
1.
2.

3.

4.

5.

6.

7.

8.
9.

10.
11.

12.

13.

14.

15.

International Maritime Associates (2006), Floating Production

Systems,
L.B. Waters, P.P. Smith, and C.A. Prescott (2006), Leveraging
Lessons Learned Across Multiple Deepwater Projects, OTC
17918, Proceedings of the Offshore Technology conference,
Houston, TX
C. Cooper and J. Stear (2005), Hurricane Climate in the Gulf of
Mexico, OTC 18418, Proceedings of the Offshore Technology
conference, Houston, TX.
V.L. Hansen, A. Duggal, A. MacMillan, L. Wang and O. Sad
(2004), Hydrodynamic and Structural Design Challenges in
Benign Areas, Proceedings of the Offshore West Africa
Conference, Abuja, Nigeria.
A. MacMillan, K.P. Fischer, H. Carlsen, . Goksyr (2004),
Newbuild FPSO Corrosion Protection - A Design and
Operation Planning Guideline, OTC 16048, Proceedings of the
Offshore Technology Conference, Houston, TX.
Karsan, Demir, et al., Risk Assessment of a Tanekr Based
Floating Production Storage and Offloading (FPSO) System in
Deepwater Gulf of Mexico, Offshore Technology Conference,
11000, 1999
API RP 2FPS, Recommended Practice for Planning, Designing,
and Constructing Floating Production Systems, First Edition,
March 2001.
Verret, Allen, Hys, Paul, Deepstars Program Related to
FPSOs, Offshore Technology Conference, 10703, 1999.
Gilbert, R.B., Ward, E.G., Wolford, A.J. A Comparative Risk
Analysis of FPSOs with Other Deepwater Production Systems
in GOM, Offshore Technology Conference, 13173, 2001.
Cranswick, D. Eve, H., FPSO EIS Results and Record of
Decision Offshore Technology Conference, 13167, 2001.
Daughdrill, W.H., Proctor, R.C., Cushing, J.M., Recent
Regulatory Developments Affecting Floating Production,
Storage, and Offloading Systems Offshore Technology
Conference, 13172, 2001.
Regg, J.B., Floating Production, Storage, and Offloading
Systems in the Gulf of Mexico OCS: A Regulatory Perspective,
Offshore Technology Conference, 10701, 1999.
Memorandum of Agreement between the Minerals Management
Service Department of Interior and United States Coast Guard
Department of Homeland Security, MMS/USCG MOA: OCS
01, 30 September, 2004.
Federal Register Volume 64, No. 234, December 7, 1999, 33
CFR Part 140, et al; Outer Continental Shelf Activities Proposed
Rule.
USCG Commandant MVI Policy Nov. 13-92, Floating
Production, Storage and Offloading (FPSO) Units, November
12, 1992.

16. Federal Register Volume 70, No. 167, August 30, 2005, 30
CFR Part 250; Oil and Gas and Sulphur Operations in the Outer
Continental Shelf Plans and Information; Final Rule.
17. Federal Register, Vol. 70, No. 137, Tuesday, July 19, 2005 Oil
and Gas and Sulphur Operations in the Outer Continental Shelf
(OCS)Fixed and Floating Platforms and Structures and
Documents Incorporated by Reference.
18. API RP 14J, Recommended Practice for Design and Hazards
Analysis for Offshore Production Facilities, First Edition,
September 1, 1993.

Table 1 Distribution of existing FPSO and FSO fleet

Type
FPSO
converted
from
existing tanker
FPSO new-built
FSO converted from existing
tanker
FSO new-built

Single
hull
40%

Double
hull
2%

Double
sides
2%

Unknown
-

2%
25%

12%
1%

9%
-

2%
-

1%

2%

1%

1%

120

$70

100

$60
$50

80

$40
60
$30
40

$20

20

$10

$0
1985

1990

1995

2000

2005

Figure 1 FPSO fleet development and annual

average world crude price

SPECIFICATION
PROJECT-SPECIFIC NEEDS

CUSTOMIZATION

SPECULATIVE FPSO
ADVANTAGE

CORE
ELEMENTS
1ST OIL

Figure 2 Speculative FPSO strategies

TIME