Floating Production, Storage, and Offloading Systems in the Gulf of Mexico OCS: A Regulatory Perspective
Authors: Regg James B. 
Published: October 2008

Abstract
Floating Production, Storage, and Offloading (FPSO) systems represent an untested technology in the U.S. Gulf of Mexico (GOM) Outer Continental Shelf. The reemergence of the GOM asone of the principal offshore oil and gas basins in he world hasbrought the challenge of integrating new technology into the business of developing the deepwater discoveries. On of those technologies is the FPSO. The U.S. Minerals Management Service (MMS) has been investigating FPSO technologies by paticpatingin discussions with the industry, both domestic and international. The goal has been to understand how an FPSO-based development will be addressed within the existing OCS regulatory structure, and to determine what supplemental efforts might be necessary.
This paper will address the role of industry-accepted practices, worldwide experience, and international efforts directe at thedevelopment of safety guidelines in the regulatory review process. It will also discuss the role that risk assessment methulatory process to help MMS better understand the risks associated with FPSO's and to identify what might be done tominimize the risk levels. The intent of this paper is to give an overview of the regulatory process for a GOM-based FPSO project; it will also be an overview of the MMS Deepwater Operations Plan process.

Introduction
The possibility of FPSO systems in the Gulf of Mexico has beendiscussed extensively throughout industry for the past two years; MMS has participated in many of these discussions. According to information compiled and maintained by Bluewater Offshore (posted on their website), there are approximately 50 FPSO's worldwide - located in the North Sea; Indonesia; West Africa; and Brazil.1 Industry is actively pursuing FPSO systems as a development strategy for the Gulf, although no one has yet submitted a development application for such.
Prior to the mid-1990's, the use of an FPSO in the GOM seemed to be unlikely given the infrastructure already available and an apparent preference to use fixed platform technology to develop discovered oil and gas reserves. During that time the GOM could be characterized as a mature oil and gas basin; in fact, some considered the GOM to show little promise for significant new discoveries. A renewed interest in the GOM resulted with the technical and economic successes achieved in deepwater. 2, 3, 4 With this move into deepwater, MMS found industry searching for alternatives to the conventional GOM development strategies. The result has been the installation of six tension leg platforms, two spars, a semisubmersible-based floating production system, and numerous subsea developments. More of the same are in the construction phase. Several other recent discoveries in the GOM have been discussed as likely candidates for FPSO-based development.
A paper presented at the 1998 Offshore Technology Conference outlined the major initiatives that MMS has undertaken to address FPSO issues.5 This year's paper is designed to update and expandon the discussions of regulating FPSO operations in the GOM Outer Continental Shelf, with an emphasis on how the Deep water Operations Plan (DWOP) process will be used in the review.