Polar Pioneer

Activity Summary Report
Title:
Activity ID:
Activity Start Time:
Originating Unit:
Owner Unit:
Controlling Unit:
Activity Type:
Team Lead:
Status:
Status Date:
Prompt Date:
Subject POC:
Ltr of Determination - Ice Advisors

5147719
06/08/2015 8:48:00 AM
SEC Anchorage
SEC Anchorage
SEC Anchorage
Vessel Inspection/PSC
Open - Submitted for Review
06/08/2015
Vessel Information
=============================================================================================
Vessel Name:
VIN:
Flag:
Length:
Tonnage(GRT/ITC):
POLAR PIONEER
8754140
MARSHALL ISLANDS
380.7
Year Completed:
Vessel Type:
Propulsion Type:
1985
Offshore-MODU-Semisubmersibles
Engine Compartment:
Fuel Compartment:
Construction:
Unknown
Unknown
Unknown
Activities Conducted:
=============================================================================================
Type
Date
Unit
Administrative Inspection
06/08/15
SEC Anchorage
Inspection Results
=============================================================================================
System
Date
Results
Inspection Results - Deficiencies

=============================================================================================
(None)
Documents and Certificates:

=============================================================================================
Certificates:
Document Description
Issue Date Expire Date
Minimum Safe Manning Document
05/08/15
Documents:
Name:
Description
PP & ND Ice Advisor Letter D17.pdf
PolarPioneer_NobleDiscoverer_IceAdvisors_08Jun2015.pdf
Locations:
Latitude
Longitude
Time
Description
=============================================================================================
61 16.13942 N
149 38.29344 W
06/08/2015 08:48
US Coast Guard Sector Anchorage
Narrative Summary:
=============================================================================================
Completed Adminstrative Inspection to issue Letter of Determination (LOD). No requirements issued, cleared, or outstanding.
Rcvd attached ltr dtd 03Jun2015 requesting LOD for Ice Advisors for POLAR PIONEER & NOBLE DISCOVERER. Drafted LOD
for Sp signature.
08Jun2015 - Attached OCMI LOD dtd 08Jun2015 indicates Ice Advisors not members of the regular complement of a unit as
defined in 33CFR141.15(b). Mailed LOD to requesting party.
No requirements issued, cleared, or outstanding. Administrative inspection complete.
//s//
GS12, USCG
Sector Anchorage
Activity Action Log:

Eff. Date Unit
Individual
Description
=============================================================================================
06/08/2015
SEC Anchorage
Activity Created. Status: "Open - In
Progress"
06/08/2015
SEC Anchorage
Status Changed to "Open - Submitted for
Review"

Title:
Activity ID:
Originating Unit:
Owner Unit:
Controlling Unit:
Activity Type:
Team Lead:
Status:
Status Date:
Prompt Date:
Subject POC:
EEP Review, Deficiency Check

5142251
06/01/2015 8:27:00 AM
SEC Anchorage
SEC Anchorage
SEC Anchorage
06/02/2015
(
Vessel Information
=============================================================================================
Vessel Name:
VIN:
Flag:
Length:
Tonnage(GRT/ITC):
POLAR PIONEER
8754140
MARSHALL ISLANDS
380.7
Year Completed:
Vessel Type:
Propulsion Type:
1985
Engine Compartment:
Fuel Compartment:
Construction:
Unknown
Unknown
Unknown
=============================================================================================
Type
Date
Unit
Deficiency Check
06/02/15
SEC Anchorage
Plan Review (Other than "T")
06/01/15
SEC Anchorage
Inspection Results
=============================================================================================
System
Date
Results
Operations/Management
06/02/15
Deficiencies Found and Corrected

=============================================================================================
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
1
By specified date and/or by 06/19/2015
05/19/2015
06/02/2015
SYSTEM
SUBSYSTEM
COMPONENT
Vessel Safety Management
Emergency Preparedness
---Description--0199 - Other(certificate) - Emergency evacuation plan (EEP) not present during exam. Submit EEP for approval from OCMI of
Western Alaska. - 33CFR146.140 - Action code: 50c.

=============================================================================================
Certificates:
Documents:
Name:
Description
2015-05-28 Discoverer and Polar Pioneer EEP Submittalpdf.pdf
PolarPioneerEEPChecklist_01Jun2015.pdf
PolarPioneer_EEPApproval_02Jun2015.pdf
Locations:
Latitude
Longitude
Time
Description
=============================================================================================
Locations:
Latitude
(Continued)
Longitude
Time
Description
=============================================================================================
61 16.13942 N
149 38.29344 W
06/01/2015 08:27
Narrative Summary:
=============================================================================================
Completed review of EEP & deficiency check. Issued approval letter & stamped cover page. Administratively cleared
requirement issued 19May2015 during COC examination w/in OCMI Puget Sound zone.
Rcvd attached EEP Rev 2.0 (18May2015) submitted by Shell Gulf of Mexico, Inc for the semisubmersible Polar Pioneer in the
Chukchi Sea (Burger Prospect Posey Blocks 6912 & 6762). Reviewed to 33 CFR 146.140 requirements. Attached OCMI
Western AK ltr w/ stamped "Approved" cover page to documents/certificates.
//s//
, GS12, USCG
Sector Anchorage

Eff. Date Unit
Individual
Description
=============================================================================================
06/02/2015
SEC Anchorage
Progress"
06/02/2015
SEC Anchorage
Review"

Title:
Activity ID:
Originating Unit:
Owner Unit:
Controlling Unit:
Activity Type:
Team Lead:
Status:
Status Date:
Prompt Date:
Subject POC:
Initial COC-MODU
5102919
05/19/2015 9:00:00 AM
SEC PgtSnd
SEC PgtSnd
SEC PgtSnd
06/18/2015
Vessel Information
=============================================================================================
Vessel Name:
VIN:
Flag:
Length:
Tonnage(GRT/ITC):
POLAR PIONEER
8754140
MARSHALL ISLANDS
380.7
Year Completed:
Vessel Type:
Propulsion Type:
1985
Engine Compartment:
Fuel Compartment:
Construction:
Unknown
Unknown
Unknown
=============================================================================================
Type
Date
Unit
Deficiency Check
06/02/15
SEC PgtSnd
Deficiency Check
06/08/15
SEC PgtSnd
Deficiency Check
06/12/15
SEC PgtSnd
Deficiency Check
06/14/15
SEC PgtSnd
Ballast Water Examination
05/19/15
SEC PgtSnd
COC-MODU Renew
05/19/15
SEC PgtSnd
Inspection Results
=============================================================================================
System
Date
Results
Communications
05/19/15
Inspected Satisfactory
Electrical
06/12/15
Engineering
05/19/15
Fire Fighting
05/19/15
Outstanding Deficiencies Exist
Navigation
05/19/15
Personnel
05/19/15
Accommodation/Occupational Safety 05/19/15
05/19/15
Construction/Loadline
05/19/15
Deck/Cargo
05/19/15
Documentation
05/19/15
Lifesaving
06/08/15
Pollution Prevention/Response
05/19/15
Stability
05/19/15

=============================================================================================
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
1
05/19/2015
06/02/2015
SYSTEM
SUBSYSTEM
COMPONENT
Vessel Safety Management
Emergency Preparedness
---Description--0199 - Other(certificate) - Emergency evacuation plan (EEP) not present during exam. Submit EEP for approval from OCMI of
Western Alaska. - 33CFR146.140 - Action code: 50c.
ITEM
COMPLIANCE DATE
10
SYSTEM
SUBSYSTEM
Deck/Cargo
Holds/Tanks
DATE ISSUED
DATE RESOLVED
05/19/2015
06/02/2015
COMPONENT
Ventilation Exhaust Outlet
---Description--0900-Safety in general- Numerous flame screens found in poor condition. Replace vent flame screens throughout rig. action
taken: 16a.c.
ITEM
COMPLIANCE DATE
11
SYSTEM
SUBSYSTEM
Deck/Cargo
Ballast
DATE ISSUED
05/19/2015
COMPONENT
Pumps
DATE RESOLVED
06/02/2015
---Description--1499-other(prop.& aux machinery)- Ballast pump motor #2 not available for inspection(pulled for service). Provide pump motor
for inspection. action taken: 17a.c.
ITEM
COMPLIANCE DATE
12
SYSTEM
SUBSYSTEM
Fire Fighting
Means of Escape
DATE ISSUED
05/19/2015
COMPONENT
Blocked
DATE RESOLVED
05/19/2015
---Description--0960-Means of escape- Emergency exit located between laundry room and cinema room blocked. Provide clear passage way for
emergency exit.- MODU code 9.3.1.3 action taken: 10c.
ITEM
COMPLIANCE DATE
13
SYSTEM
SUBSYSTEM
Accommodation/Occupational Safety
DATE ISSUED
05/19/2015
COMPONENT
Ventilation
DATE RESOLVED
06/02/2015
ITEM
COMPLIANCE DATE
14
SYSTEM
SUBSYSTEM
Accommodation/Occupational Safety
DATE ISSUED
05/19/2015
COMPONENT
Medical/First Aid
DATE RESOLVED
05/19/2015
ITEM
COMPLIANCE DATE
15
SYSTEM
SUBSYSTEM
Fire Fighting
Fire Hoses
DATE ISSUED
05/19/2015
COMPONENT
Condition
DATE RESOLVED
05/19/2015
General
---Description--0999-Other(safety in general)-Ventilation dampers shall be labeled to indicate "open and close" position. Prove satisfactory
operation.-79MODU code 9.10.1 action taken: 17a.c.
Medicine Chest
---Description--0371-Medical equipment-No first aid kit present in ballast control room as per fire fighting and life saving plan. Provide first aid kit
for this location. 79MODU code 10.9 action taken: 10c.
---Description--0799- other(fire fighting equipment)- Wasted gasket on fire hose found at fire station 24. Provide new gasket.
79MODU code 9.4.3.2 action taken: 10c.
ITEM
COMPLIANCE DATE
16
SYSTEM
SUBSYSTEM
Fire Fighting
Nozzles
DATE ISSUED
05/19/2015
COMPONENT
Condition
DATE RESOLVED
05/19/2015
---Description--0799-other(fire fighting equipment)- Seized fire fighting nozzle found at fire station 15. Provide operational nozzle.74MODU code 9.4.4 action taken: 10c.
ITEM
COMPLIANCE DATE
17
SYSTEM
SUBSYSTEM
Pollution Prevention/Response Prevention Equipment
DATE ISSUED
DATE RESOLVED
05/19/2015
05/19/2015
COMPONENT
Oily Water Separator (15 ppm)
---Description--1735-Pumping discharge arrangements- The first valve located after the 3-way valve on OWS overboard discharge piping has
two missing bolts on flange face. Replace missing bolts. 73/78 MARPOL action taken: 10c.
ITEM
COMPLIANCE DATE
18
SYSTEM
SUBSYSTEM
Pollution Prevention/Response Prevention Equipment
DATE ISSUED
DATE RESOLVED
05/19/2015
06/02/2015
COMPONENT
Oily Water Separator (15 ppm)
---Description---
1799-other(MARPOL Annex I)- Crew was unable to operationally test the OWS. Demonstrate proficiency, to include oil content
meter history. 73/78 MARPOL Annex I/14.6 action taken: 17c.
ITEM
19
SYSTEM
Stability
COMPLIANCE DATE
SUBSYSTEM
Watertight Integrity
DATE ISSUED
05/19/2015
COMPONENT
General
DATE RESOLVED
06/02/2015
---Description--1270-Doors- Prove proper operation of watertight doors. Ensure gasket material is in good condition and watertight. 79MODU code 3.4.1 action taken: 17a.c.
ITEM
2
SYSTEM
Lifesaving
COMPLIANCE DATE
SUBSYSTEM
Rescue Boat
DATE ISSUED
DATE RESOLVED
05/19/2015
06/08/2015
COMPONENT
Propulsion Engine
---Description--0615 - Rescue Boats - Forward fast rescue craft not operational. Demonstrate satisfactory operation of forward fast rescue craft.
- 79MODU code 10.2.1.4 action taken: 17a.c.
ITEM
20
SYSTEM
Electrical
COMPLIANCE DATE
DATE ISSUED
05/19/2015
COMPONENT
Generator
DATE RESOLVED
06/02/2015
SUBSYSTEM
Electric Generation Source (emergency)
---Description--0950- Prove satisfactory safety tests of emergency generator. 79MODU code 5.3.7 action taken: 17a.c.
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
21
05/19/2015
06/05/2015
SYSTEM
SUBSYSTEM
COMPONENT
Documentation
Safety Management System
Key Shipboard Operations Plans/Instructions
---Description--0199-Other(certificate)- Provide approved revision of operations manual.(Approval from class society).- MODU code 14.1.1
Action taken: 50a.c.
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
22
05/19/2015
06/02/2015
SYSTEM
SUBSYSTEM
COMPONENT
Fire Fighting
Structural - A Class Divisions
Bulkheads - Machinery Spaces
---Description--0750-Fire prevention- A-0 boundary in way of fuel oil equipment room not sealed. Properly weld tight to not allow passage of
smoke or flames. 79MODU code 9.2.5 action taken: 17a.c.
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
23
05/19/2015
06/02/2015
SYSTEM
SUBSYSTEM
COMPONENT
Fire Fighting
Openings - Doors
---Description--0750-Fire prevention- Laundry room door handle and lock missing at time of exam. Fire boundary compromised. Properly install
laundry room door handle and lock to maintain structural fire protection.-79MODU code 9.2.3 action taken: 17a.c.
ITEM
COMPLIANCE DATE
3
SYSTEM
SUBSYSTEM
Drills/Instruction
DATE ISSUED
05/19/2015
COMPONENT
Abandon Ship
DATE RESOLVED
06/02/2015
---Description--0925 - Musters and drills - Witnessed unsatisfactory fire and abandon ship drill. Demonstrate satisfactory fire and abandon ship
drills. 79MODU code 10.6.3.1 action taken: 17a.c.
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
4
05/19/2015
07/11/2015
SYSTEM
SUBSYSTEM
COMPONENT
Fire Fighting
Structural Fire Protection - General
Structural Bulkhead Construction
---Description--0950 - Electrical equipment in general - Multi-cable transit runs contain packing material for differing manufactures. Provide
uniform packing material for all multi cable transit runs. 79MODU code 3.6.1/I.A.W. table 9.2 action taken: 50a.c.
ITEM
5
COMPLIANCE DATE
DATE ISSUED
05/19/2015
DATE RESOLVED
06/02/2015
SYSTEM
Fire Fighting
SUBSYSTEM
COMPONENT
Openings - Fire Doors
---Description--0750 - Fire prevention - Multiple fire screen doors cannot properly close. Demonstrate proper operation of all fire screen doors. 79MODU 9.1.5 & 9.2.1 action taken: 17b.c.
ITEM
COMPLIANCE DATE
DATE ISSUED
DATE RESOLVED
6
05/19/2015
06/02/2015
SYSTEM
SUBSYSTEM
COMPONENT
Documentation
Safety Management System
Critical Equipment/Systems ID Procedures
---Description--0900 - Safety in general - Vital system piping (emergency bilge and ballast) not labeled in working language of the crew. Provide
labeling in working language of the crew (english), as identified in the operations manual. - 79MODU code 14.1.2.6
action taken: 16a.c.
ITEM
7
SYSTEM
Electrical
COMPLIANCE DATE
SUBSYSTEM
Lighting (emergency)
DATE ISSUED
05/19/2015
COMPONENT
Lighting Fixture
DATE RESOLVED
06/12/2015
---Description--0945-Emergency lighting etc.-Emergency lighting located in numerous spaces was not fully functional; numerous bulbs missing
and dead batteries. Demonstrate proper operation of emergency lighting throughout the vessel.- 79MODU code 5.3.2.1.3
ITEM
COMPLIANCE DATE
8
SYSTEM
SUBSYSTEM
Engineering
Steam System (auxiliary)
DATE ISSUED
DATE RESOLVED
05/19/2015
06/02/2015
COMPONENT
Lagging/Insulation
---Description--0900-Safety in general- Boiler condensate piping not properly insulated. Ensure piping is satisfactorily insulated.MODU code 4.1.3 action taken: 50a.c.
ITEM
COMPLIANCE DATE
9
SYSTEM
SUBSYSTEM
Documentation
Certificates/Documents
DATE ISSUED
DATE RESOLVED
05/19/2015
06/02/2015
COMPONENT
International Air Pollution Prevention Certificate
---Description--0160-IAPP certificate- Provide updated IAPP certificate to include shipboard incinerator.- 73/78 MARPOL annex VI/6 & 16

=============================================================================================
Certificates:
COC-MODU Renewal
06/14/15
06/14/17
Documents:
Name:
Description
POLAR PIONEER FORM B 19MAY2015.pdf
POLAR PIONEER FORM B ISSUED 19MAY2015.PDF
POLAR PIONEER FIRE SCREEN DOORS REPAIRS EFFECTED 02JUN2015.pdf
POLAR PIONEER WATERTIGHT DOORS REPAIRS EFFECTED 02JUN2015.pdf
POLAR PIONEER COC ISSUED 14JUN2015.pdf
POLAR PIONEER FORM A ISSUED 14JUN2015.pdf
TOPP Recommendations.pdf
Locations:
Latitude
Longitude
Time
Description
=============================================================================================
05/19/2015 09:00
Foss T-5
Narrative Summary:
=============================================================================================
19 MAY 2015: Sector Puget Sound conducted an initial COC exam for the MODU POLAR PIONEER, IMO 8754140 (option c).
PII and BW exams were also conducted IAW MSM Vol. II Section D, international laws and treaties, and applicable U.S. laws
and regulations. The POLAR PIONEER is a Marshall Islands flagged, 380.7ft long, non-self propelled, semi-submersible MODU
with a keel laid date of 1984. The vessel's class society is DNV-GL. The vessel was moored at T-5, Seattle, Washington, port
side to the pier.
In addition to Sector Puget Sound personnel, the COC exam was conducted with Sector Anchorage, OCS NCOE, and CG-5 TI
personnel in attendance. Bureau of Safety and Environmental Enforcement (BSEE) Inspectors attended the exam to familiarize
themselves with CG inspected equipment as BSEE inspectors will be living onboard the vessel 24/7 during drilling operations.
HULL INSPECTION:
Examined the following certificates and documents: IMO MODU Certificate, COFR, Construction Portfolio, Certificate of Registry,
ITC, ILLC, IAPP, EIAPP, IAFS, Class Certificates, CSSE, IOPP, SOPEP, ORB, Bunkering Notes, EPA Vessel General Permit,
NTVRP, Garbage Log, Waste Management Plan, and BWM Plan; found rig had an incinerator aboard that wasn't listed on the
IAPP or IOPP certificate supplements; issued def #9. Verified proof of BW Report submittal. Examined all officer national
licenses with flag endorsements and verified compliance with the Minimum Safe Manning Certificate; all sat. Verified required
number of lifeboat certified persons were onboard; all sat. Examined fire and abandon ship drill records; all sat. Examined
maintenance records for lifesaving equipment; all sat. Examined firefighting equipment maintenance records; all sat. Examined
DNV-GL Crane Load Test Survey Statements of Fact dated 05 MAY 2015 for stbd crane and 27 APR 2015 for port crane; all sat.
Examined report detailing testing for all pressure vessels dated 22 JUL 2015; all sat. Examined class approved Operating
Manual dated 31 OCT 2011. However the previously approved Operating manual was not up-to-date. The most current version
had multiple changes, including changes to the stability section that was being routed to DNV-GL for approval. Issued def #21.
Emergency Emergency Evacuation Plan has not yet been approved; issued def #1. Reviewed a satisfactory Minimum Safe
Manning Certificate. Previous Safe Manning certificates was a topic of discussion between the CG, Class, Marshall Islands &
Transocean since it allowed "field moves" of 20 nautical miles or less. The "field move" statement was problematic as it was not
consistent with the Ops Manual and all other documentation indicating that that the rig was non-self propelled. In the current,
valid Safe Manning Cert, the statement allowing field moves was removed. Instead, it contained a clause permitting the use of
thrusters in the event of an emergency & as an aid to maintain position while anchored & while being towed.
Conducted deck walk: Inspected deck/hull openings, safety items, hull markings, and draft marks; found some flame screens on
fuel tank vent were missing or in poor condition; issued def #10. Examined port crane (National Oilwell Varco, OC 3000 LCV) &
stbd crane (Liebherr BOS 4200-50); all sat. Examined firefighting equipment; all sat. Witnessed testing of 3 fire pumps: 1 pump
supplying 2 monitors, 1 pump supplying 2 fire hoses, and 1 pump supplying 1 hose & 1 monitor; all sat. Inspected heliport and
associated firefighting equipment; all sat.
Inspected lifesaving equipment: Completed check of lifeboat breathing air system, food, water, & distress flares on all 4 lifeboats
in the stowed position; all sat. Witnessed operation of all 4 lifeboat engines and steering while in the stowed position; all sat.
Witnessed operation of all 4 lifeboats' sprinkler systems after lowering the lifeboats to the water; all sat. Tested all 4 lifeboat limit
switches during their retrieval; all sat. Witnessed operation of the aft Fast Rescue Craft (FRC) in the water; all sat. The forward
FRC failed to start despite numerous attempts. The crew informed the inspections team that they knew of a cracked fuel filter
and bad fuel; parts were on order; issued def #2.
Conducted general health and safety walkthrough: Examined hospital and first aid equipment. Medical items stocked and
inventoried. Found that first aid kit was missing in ballast control room; issued/cleared def #14. Spot-checked crew
accommodations, and workplace health and safety; found laundry fire door missing its door handle and lock. The door also had
a hold back arrangement constructed of line and duct tape; issued def #23. Found emergency exit located between laundry and
cinema rooms blocked; issued/cleared def #12. Examined galley spaces; all sat. Witnessed operational test of smoke detectors
at the following locations: Hospital, Technical Section Leader room, Electronic Engineer room, radio room, laundry room,
passageway at cooks & catering room & paint stores; all sat. Found wasted gasket on fire hose station #24; issued/cleared def
#15. Found seized nozzle on fire hose station #15; issued/cleared def #16. Found several vent dampeners were not labeled
indicating the opened and closed positions; issued def #13.
HAZARDOUS LOCATIONS:
Examined hazardous location plan and conducted walkthrough from the drilling floor, throughout mud system, and return. Found
several multi cable transit (MCT) bulkhead were packed using different systems in the same penetration and/or had nonapproved sealant applied to the penetration; issued def #4.
MACHINERY INSPECTION:
Conducted walkthrough of all machinery spaces including Port and Stbd Pontoons. Found numerous fire screen doors that did
not completely close or had missing closure devices; issued def #5. Found numerous watertight doors (WTD) with
deteriorated/improper gaskets and/or indicator light malfunctions; issued def #19. Found multiple emergency lights throughout
the rig were inoperable; issued def #7. Found that emergency bilge and ballast system piping was not labeled in the working
language of the crew; issued def #6. Fire extinguisher #69 was not secured in the Stbd Aft Computer Room (column upper level);
corrected on the spot. Found EEBD #5 in the Stbd Aft Pump Room was low on pressure (approximately 1/2 charge); crew to
replace/recharge. Vent valves were spot-checked in the Stbd Fwd Pump Room after the Barge Engineer located the correct
actuation/indicator panel in the Control Room. Found #2 Ballast Pump motor was removed for service; issued def #11. Found
machinery guards in the pump rooms were not installed; corrected on the spot. Found that a small section of electrical mat in the
LV Room was missing; corrected on the spot. Found a hole in the A-0 boundary bulkhead in the fuel oil equipment room; issued
def #22.
Witnessed testing of the following equipment:
Stbd Aft Thruster Room:
-Remote sea chest valve; all sat.
-Remote (manual) brine valves; all sat.
-Bilge alarm; all sat.
Stbd Pontoon
-Bilge alarm (aft); all sat.
Stbd Fwd Pump Room:
-Vent valve 205 (remote ventilation valve); all sat.
-Vent valve 204; all sat.
Engine safeties verified:
-MDG 1 Overspeed; intake air flaps closed; all sat.
-MDG 2 Reverse Power Relay (RPR), Low lube oil trip; all sat.
-MDG 3, 4, 5: accepted recent DNV-GL testing.
-E-Gen auto-start & bus transfer (2 & 19 seconds, respectively); all sat. Overspeed was attempted but crew could not get E-Gen
to reset for restart; issued def #20.
Aux boilers were not tested due to being 'cold iron'. Found boiler condensate piping missing insulation; issued def #8.
MARPOL:
Reviewed Oil Record Book. Verified operation of the OWS OCM and 3-way overboard valve via the OCM simulated PPM
change. The 3 A/E was somewhat familiar with the system but did not know much about the OCM other than the simulated test
feature. The OWS itself was not operated; issued def #18. Found two missing bolts on the first valve after the OWS 3-way
valve; issued/cleared def #17.
DRILLS:
Fire Drill - Witnessed UNSATISFACTORY fire drill initiated within laundry room. Crewmember used to find the simulated fire had
no knowledge of where nearest portable fire extinguisher was & had no knowledge where the nearest call point(s) were. In order
to notify responsible person(s) of the fire, he walked to his foreman (a distance of at least 100 ft), walked past at least 2 rooms w/
phones, 2 call boxes, all while wearing a portable radio. The foreman had a portable radio and provided some on the spot
training to the crewmember. During fire drill, the inspectors also found a tertiary labeled means of escape located between the
laundry room & cinema that was blocked (corrected on the spot). Fire Team 2 donned fire fighting gear and proceeded to the
scene through the main stairwell. Stairwell doors were not closed and boundaries were not maintained. Flash hoods were not
properly donned and the team's dress was not checked prior to entry. The on-scene leader and unprotected team members
were all in the passageway adjacent to Laundry Room. The fire hose was not fully connected at the scene and was not the
correct fire station to use for the affected space (too far from the scene). Drill failed; issued def #3.
Abandon ship drill - Witnessed UNSATISFACTORY abandon ship drill using the alternate (aft) muster location. Since rig will be
operating within Arctic waters, the inspectors specifically required crew to don immersion suits. Crew instead arrived with
lifejackets. Upon further direction, immersion suits were properly donned. The crew never achieved full accountability. 5
personnel were found at the wrong muster station. The muster was also delayed due to 3rd party contractor personnel number
conflicts. Found that accountability namecards are only at one muster location and not at the other muster location.
Recommended to OIM to have crewmembers speak up and take full accountability. All other observations on the bridge were
satisfactory. Drill failed; see def #3.
It was apparent that Transocean was not ready for the exam. Vessel recently completed an extensive shipyard period in
Singapore; the vessel recently changed out crew and the crew is still learning the vessel's systems. To make the exam more
complicated, the DNV-GL surveyor was still completing necessary surveys. Overall, the vessel was not ready for the CG's
examination.
Issued 23 deficiencies: 5 corrected on the spot and 18 remain outstanding. 9 of the deficiencies were required to be corrected
prior to departure to satisfaction of Class and/or CG. Issued Form A and Form B. COC was not issued. There are also an list of
inspection recommendations named "TOPP Recommendations" , included on Documents.
Examination to continue.
//
02JUN2015: Visited vessel same as before to conduct Deficiency Check. Met with OIM
& vessel representative
. Discussed MCT repair proposal and emergency lighting repair proposal. MCT repair proposal plan prioritized
repairs in 3 levels of priority. Priority 1: Below the waterline, in hazardous locations and/or protected by fixed fire extinguishing
systems to be completed prior to departure; Priority 2: other machinery spaces, drilling spaces and one room leading into the
radio room; Priority 3: spaces above the waterline other than Priority 1 or Prioroty 2 spaces. All priority 1 repairs have not been
completed; currently 31 percent complete. Advised Transocean request plan approval from DNV-GL. Noted that Transocen
received Stability Manual approval letter and DNV-GL cleared CC 519. Discussed remaining outstanding conditions of class and
requested the updated DNV-GL survey report.
DRILLS:
FIRE: Witnessed fire drill in the paint locker. Crew members dressed in fire fighting gear and was tested on their ability to operate
their SCBAs. All crew members were knowledgeable and capable of fire-fighting techniques and how to use their equipment. All
sat.
ABANDON SHIP: Witnessed abandon ship/lifeboat drill. All crew mustered at their respective life boats with life jackets and
donned immersion suits as per their safety procedures. Lifeboat captains took personnel accountability and reported to the
master on the bridge. No boats were lowered because they were lowered on 19MAY2015 with exception of 1 FRC pending
repairs. All sat.
The following 13 defs were cleared:
Def #3: Fire and Abandon Ships drills conducted satisfactorily on 02JUN2015.
Def #5: All fire screen doors were verified to close properly.
Def #6: Bilge and Ballast Piping Label in working language of crew.
Def #8: Boiler condensate piping insulation was added back, as per original design.
Def #9: Current IAPP certificate included incinerator.
Def #10: Verified that all previously broken flame screens renewed throughout vessel.
Def #11: Ballast Pump Motor #2 available for inspection and operationally tested satisfactorily.
Def #13: Ventilation dampers labeled indicating open and closed positions..
Def #18: Crew operationally tesed the OWS and proved proficiency with equipment.
Def #19: Verified that all WTD's closed properly and had functional indicator lights.
Def #20: Witnessed satisfactory tests of emergency generator.
Def #22: The hole in the A-0 bulkhead in the fuel oil equipment room was welded shut.
Def #23: Laundry room door was fitted with proper handle and lock.
Noted overboard discharge missing lockout device. Corrected on the spot. All sat. In STBD column leading to bilge and ballast
space: noted light cover missing from WTD indicator & paint on the WTD light alarm. Corrected on the spot. All sat.
Cleared 13 defs, issued 00 defs, 05 remain outstanding.
Examination to continue.
//
03JUN2015: Received EEP Approval letter from OCMI Western Alaska dated 02JUN2015; cleared def #1.
05JUN2015: Received Operations Manual, examined by DNG-GL dated 02JUN2015. Found Ops Manual complete. Cleared
def #21.
//
08 JUN 15 - Attended vessel to conduct a deficiency check. Witnessed FWD fast rescue boat operation satisfactorily; cleared
def #2. Witnessed battery powered emergency light operation in the following spaces: all port pontoon spaces and elevators, well
test deck, rig control room, high and low voltage switchboard rooms, generator and purifier rooms, and fwd lifeboat embarkation
area; all sat. Approximately 200 emergency lights had been replaced. Amended def #7 to require that the emergency lights be
repaired prior to departure instead of by 03Jun15. There are still approximately 100 emergency lights that needed to be
repaired/replaced. Inspected newly packed MCTs in Priority 1 areas (below the water line, in hazardous zones, and in spaces
protected by a fixed gas firefighting system); all sat. Changed due date on def #4 from prior to departure to 30 days from 08
June.
02 pending defs: #4 and #7.
Recommendations to resolve.
Found leaking hydraulic valve actuator and small amount of oil in the Stbd Aft Pump Room bilge; crew to
repair/clean. Found portable oil pump and 55 gal oil drums in the stbd aft thruster room; crew to stow or properly
mount pump and stow 55 gal oil drums. Found one filter was missing from the #1 high voltage (6kV) transformer;
crew to renew all filters. Found numerous indicator lamps were out in the LV Room (breaker/MCC position
indication); crew will check all bulbs and replace as needed.
A leaking hydraulic valve actuator in the Stbd Aft Pump Room (adjacent to the fwd WTD) was repaired and
hydraulic oil was cleaned from the bilge. Intake screens/filters for the #1 high voltage (6kV) transformer were all
renewed; all sat. Approximately 40 indicator lamps were renewed in the LV Switchgear Room; all sat. Portable
waste oil pump was secured and 55 gal drums were removed from the Stbd aft thruster room; all sat.

Title:
Activity ID:
Originating Unit:
Owner Unit:
Controlling Unit:
Activity Type:
Team Lead:
Status:
Status Date:
Prompt Date:
Subject POC:
Port State Control - In-Service Inspection

5129741
04/17/2015 11:31:00 AM
SEC PgtSnd
SEC PgtSnd
SEC PgtSnd
Closed - Approved Inspection
05/19/2015
Vessel Information
=============================================================================================
Vessel Name:
VIN:
Flag:
Length:
Tonnage(GRT/ITC):
POLAR PIONEER
8754140
MARSHALL ISLANDS
380.7
Year Completed:
Vessel Type:
Propulsion Type:
1985
Engine Compartment:
Fuel Compartment:
Construction:
Unknown
Unknown
Unknown
=============================================================================================
Type
Date
Unit
In-Service Inspection
04/17/15
SEC PgtSnd
In-Service Inspection
04/21/15
SEC PgtSnd
Inspection Results
=============================================================================================
System
Date
Results

=============================================================================================
(None)

=============================================================================================
(none)
Locations:
Latitude
Longitude
Time
Description
=============================================================================================
48 07.1001 N
123 27.0166 W
04/17/2015 11:31
PORT ANGELES BOAT HAVEN
Narrative Summary:
=============================================================================================
17 APR 2015: LT
and CWO
attended the POLAR PIONEER, a semi-submersible MODU upon its arrival in
Port Angeles WA. The rig was cargo onboard the heavy lift ship BLUE MARLIN and could not be accessed because the
required scaffolding from the BLUE MARLIN's deck to the rig's main deck underside catwalk had not been assembled. Visually
inspected the outboard sides of the rig's pontoons and the overhanging pontoon bottoms from a USCG small boat; no issues
visible. Visually inspected inboard sides of the pontoons from the deck of the BLUE MARLIN; no issues visible. There was no
apparent damage caused by Greenpeace stowaways.
Workers are beginning to cut the welded sea fastenings that connect the POLAR PIONEER's pontoons to the BLUE MARLIN's
deck. Additionally, the vessel's towing chocks will be renewed with larger chocks.
Vessel will be refloated in 7-10 days once all sea fastenings are removed, new chocks installed, and rig startup crew has
activated all safety and control systems.
21 APR 2014: Mr.

Mr.
and LT
attended the POLAR PIONEER while the rig was still on the deck of the
BLUE MARLIN to verify safety systems had been brought on line by the rig startup crew. The scope of this exam was much less
than that of a PSC or COC exam. The exam was a brief walkthrough to verify that it was safe for the full crew to begin manning
the rig post transit on the heavy lift ship. Verified crew was familiar with the muster station and personnel accountability for
emergencies while the rig was atop the BLUE MARLIN. Fire detection and the rig's sprinkler system were operational. Fire main
water was supplied by the BLUE MARLIN and was tested by the startup crew prior to the USCG walk through. The rig's
generators were providing power to the rig and the emergency generator had been successfully tested prior to USCG walk
through. Machinery cooling water was supplied by the BLUE MARLIN. Spot checked lifejackets and immersion suits; found
several lifejackets were missing lights; lights appeared to be cut/ripped off, likely in Malaysia. Lifeboat and rescue boat fall
protection devices will be removed immediately prior to the rig's refloating on 25 APR. Inspected several empty ballast tanks
through their manholes for cleanliness; all sat.
COC exam is scheduled for 19 May.
, LT, USCG

Eff. Date Unit
Individual
Description
=============================================================================================
05/19/2015
SEC PgtSnd
Progress"
05/19/2015
SEC PgtSnd
Status Changed to "Closed - Approved
Inspection"

Title:
Activity ID:
Originating Unit:
Owner Unit:
Controlling Unit:
Activity Type:
Team Lead:
Status:
Status Date:
Prompt Date:
Subject POC:
Ltr of Determination - Maritime MODU Advisor

5102556
02/23/2015 1:46:00 PM
SEC Anchorage
SEC Anchorage
SEC Anchorage
04/15/2015
Vessel Information
=============================================================================================
Vessel Name:
VIN:
Flag:
Length:
Tonnage(GRT/ITC):
POLAR PIONEER
8754140
MARSHALL ISLANDS
380.7
Year Completed:
Vessel Type:
Propulsion Type:
1985
Engine Compartment:
Fuel Compartment:
Construction:
Unknown
Unknown
Unknown
=============================================================================================
Type
Date
Unit
Administrative Inspection
02/25/15
SEC Anchorage
Inspection Results
=============================================================================================
System
Date
Results

=============================================================================================
(None)

=============================================================================================
Certificates:
Documents:
Name:
Description
Letter of Determination Request.pdf
Dated 02-17-2015
CG Ltr - Regular Complement Determination.pdf Dated 02-25-2015
Locations:
Latitude
Longitude
Time
Description
=============================================================================================
61 16.13942 N
149 38.29344 W
02/23/2015 13:46
Narrative Summary:
=============================================================================================
Completed Adminstrative Inspection to issue Letter of Determination (LOD). No requirements issued, cleared, or outstanding.
Rcvd attached ltr dtd 17Feb2015 requesting LOD for Maritime MODU Advisors for the NOBLE DISCOVERER & POLAR
PIONEER.
25Feb2015 - Unfamiliar w/ this position & knowing our determination may impact other OCMI zones , I spoke w/ 2 senior MODU
inspectors fm MSU Morgan City. They both indicated the MODU advisors are like auditors/inspectors, therefore, not a regular
complement of the unit. Attached OCMI LOD dtd today indicates Maritime MODU Advisors not members of the regular
complement of a unit as defined in 33CFR141.15(b). Mailed LOD to requesting party.
No requirements issued, cleared, or outstanding. Administrative inspection complete.
//s/
, GS12, USCG
Sector Anchorage

Eff. Date Unit
Individual
Description
=============================================================================================
04/13/2015
SEC Anchorage
Progress"
04/15/2015
SEC Anchorage
.
Status Changed to "Open - In Progress"
04/15/2015
SEC Anchorage
Review"
Phone:
Fax:
Email:
(202) 572-8391
@BlankRome.com
February 17, 2015

VIA EMAIL AND REGULAR MAIL
Commander Hector L. Cintron
Chief of Prevention
U.S. Coast Guard Sector Anchorage
510 L Street, Ste. 100
Anchorage, AK 99501
Re:
Request for Determination that Maritime Advisors are not Members of the
Regular Complement of an Outer Continental Shelf Unit
Dear Commander Cintron:

On behalf of Shell Exploration & Production Company and Shell Gulf of Mexico, Inc.
(collectively Shell), we request an exemption from the employment restrictions pertaining to units
engaged in Outer Continental Shelf (OCS) activities on the basis that certain individuals are not
members of the regular complement of the crew. 33 C.F.R. 141.15. Specifically, Shell requests that
the Coast Guard exempt four (4) foreign national Maritime Mobile Offshore Drilling Unit (MODU)
Advisors (Maritime MODU Advisors) from the requirement to employ U.S. citizens or resident aliens
aboard a vessel engaged in OCS activities. The following information is provided in support of this
request.
Background
Shell intends to conduct exploration drilling activities in 2015 on federally-managed OCS oil and
gas leases located a minimum of 64 miles from the coastline in the Chukchi Sea. These operations will
take place pursuant to Shells Chukchi Sea Revised Exploration Plan which is scheduled to occur during
the short open-water season, defined historically as approximately July through November.
Shell has, in light of its experience operating on the Alaska OCS, identified a need to employ
individuals with unique job skills during this period. Shell completed a review of its 2012 Chukchi and
Beaufort Seas OCS exploration drilling operations and concluded, among other things, that there was a
need to strengthen its maritime assurance controls for future operations. As part of this review, Shell
identified a need to more closely monitor its Alaskan contractor operations to ensure that its contractors
meet or exceed Shell standards and to ensure all operations are conducted in a safe and environmentally
compliant manner.
Consequently, a new Maritime Assurance team was developed and charged with overseeing and
executing maritime assurance tasks on board two MODUs, the Noble Discoverer and Polar Pioneer (the
1

February 17, 2015
Page 2
Vessels), which are owned and operated by Shell contractors. The goal of this team and its marine
experts is to ensure that all maritime aspects of Shells drilling operation will be conducted in accordance
with applicable regulatory requirements, industry best practices, and Shells internal maritime standards.
These individuals will help to ensure that the company executes its drilling activities exceptionally well in
2015.
The Maritime Assurance team tasked with overseeing the Vessels consists of four Maritime
MODU Advisors that will work in rotating shifts aboard the Vessels to oversee operations on behalf of
Shell. The Maritime MODU Advisors are Shell employees and will be Shells onboard marine assurance
representatives. These are the four (4) foreign nationals for which we request the exemption from the
OCS employment restrictions
This type of Maritime MODU Advisor is not typically employed by Shell on drillships during
normal drilling operations occurring elsewhere on the U.S. OCS. However, as noted above and as
explained in more detail below, Shell has determined that the employment of these Maritime MODU
Advisors is critical to enhancing Shells ability to provide the necessary oversight over some of its key
contractors in order to operate safely in the Chukchi Sea this season.
Legal Requirements and Policy Guidance
An employer of personnel on any unit engaged in OCS activities must employ, as members of the
regular complement of the unit, only citizens of the United States or resident aliens. 33 C.F.R.
141.15. Personnel considered part of the regular complement of the unit are those necessary for the
routine functioning of the unit, including marine officers and crew, industrial personnel and general
maintenance personnel. Individuals not considered part of the regular complement of the unit are
specialists, professionals and other technically trained personnel called in to handle emergencies or other
temporary operations, extra personnel on a unit for training, and other personnel temporarily on a unit for
specialized operations, such as construction, alteration, well logging, or unusual repairs or emergencies.
The CG-543 Policy Letter 02-01, dated February 2, 2002, provides additional guidance clarifying
the Coast Guards interpretations of exemptions for specialists, professionals and technically trained
personnel. According to this policy letter, the following factors should be considered in making an
employment exemption determination: (1) job description relative to the units; (2) the period of time
requested or anticipated; (3) type of operations (i.e., temporary, specialized); (4) degree of expertise or
training needed; and (5) safety considerations.
The Vessels
Shell will utilize the Maritime MODU Advisors on the following two vessels:
M/V Noble Discoverer: Self-propelled drillship owned, operated, and crewed by
Noble Drilling International GmbH. Liberian flag (IMO # 6608608).
MODU Polar Pioneer: Mobile Offshore Drilling Unit owned, operated, and crewed
by Transocean. Marshall Islands flag (IMO # 8754140).
The Vessels will be operating on the Alaskan OCS in Chukchi Sea lease blocks 6714, 6762,
6764, 6812, 6912, and 6915.

February 17, 2015
Page 3
Personnel and Specialist/Temporary Nature of the Work Performed by the Maritime MODU Advisors
The four individuals that will serve as Maritime MODU Advisors are Mr.
, Mr.
, Mr.
, and Mr.
. These individuals are all permanent Shell
employees based in Shells offices in the United Kingdom and Singapore. Specific information on each
of the identified individuals is provided in Enclosure (A).
The following is a brief discussion addressing each of the factors listed in the G-MOC Policy
Letter 02-01:
Job Description Relative to the Unit: The job description for a Maritime MODU Advisor is discussed in
Enclosure (B).
The Period of Time Requested: It is anticipated that the four individuals will perform their specialized
work from approximately June 1, 2015 November 10, 2015 when activities occur in the Chukchi Sea
OCS. This should be considered temporary in nature, for among other reasons, due to the short openwater season in Alaska.
Type of Operations: As discussed in the background section above and in Enclosure (B), the Maritime
MODU Advisors will perform highly specialized services when the MODU is operating on the Alaska
OCS. In short, the Maritime MODU Advisors will be Shells onboard marine assurance representatives
employed specifically to oversee contractor operations to ensure they are conducted in accordance with
applicable regulatory requirements, industry best practices, and Shells internal maritime standards to
ensure safe and environmentally compliant operations. Maritime MODU Advisors are neither necessary
nor normally utilized in MODU operations. They are clearly not necessary for the routine functioning
of the Vessels. They are neither officers nor crew of the Vessels, they will not stand watches, and they
serve no direct industrial purpose (e.g., their duties are not akin to toolpushers, drillers, roustabouts, floor
hands, crane operators. etc.), and they cannot be considered support personnel (e.g. cooks or stewards).1
Degree of Expertise or Training Needed: Each of the individuals is specifically trained and has extensive
experience performing the functions required of a Maritime MODU Advisor in the offshore Alaska
environment. The Maritime MODU Advisors are highly experienced Shell employees that possess a
specialized level of expertise and in-depth knowledge of the maritime regulatory framework, best
maritime operating practices, Shells internal maritime standards, and a mature HSSE culture. These
individuals would report to the Shell Manager of Maritime Assurance through the on board Shell drilling
For example, the Policy Letter states that a weld inspection technician aboard a pipe-lay barge to ensure quality
assurance or operate equipment that requires specialized training is not considered part of the regular crew
complement. Clearly, a weld inspection technician performing services onboard a pipe-lay barge to assure quality
or operate equipment would benefit the operations and mission of the barge. Nevertheless, because the technician is
aboard temporarily to provide specialized services, he/she is not considered part of the regular crew complement.
Another example involves drilling advisors that have been authorized for use on drill ships during specialized ultradeep drilling operations following the Deepwater Horizon incident to ensure for the overall safety of operations.
Specifically, Wellsite Geologists have been approved to supplement the current crew complement and not replace
any of the U.S. citizen crew. These personnel provide specialized oversight, advice, training, and mentoring of the
crew with regard to drilling operations and they do not stand any watches while onboard the Vessels. These
personnel have been approved for use up to one year at a time in the Gulf of Mexico.

Polar Pioneer

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Activity Summary Report

Ltr of Determination - Ice Advisors

Inspection Results - Deficiencies

Documents and Certificates:

Activity Action Log:

Activity Summary Report

EEP Review, Deficiency Check

Inspection Results - Deficiencies

Documents and Certificates:

Activity Action Log:

Activity Summary Report

Inspection Results - Deficiencies

Documents and Certificates:

Activity Summary Report

Port State Control - In-Service Inspection

Inspection Results - Deficiencies

Documents and Certificates:

21 APR 2014: Mr.

Activity Action Log:

Activity Summary Report

Ltr of Determination - Maritime MODU Advisor

Inspection Results - Deficiencies

Documents and Certificates:

Activity Action Log:

February 17, 2015

Dear Commander Cintron:

Commander Hector L. Cintron

Commander Hector L. Cintron

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