CEQ 11. The Council recommends that the Departments of the Interior and Transportation and the Environmental Protection Agency develop and implement a common reporting system for all accidents associated with OCS operations. This improved system should provide complete unambiguous reporting, with special attention to the analysis of cause-effect relationships.

The Work Group agrees with the CEQ recommendation that the agencies with responsibilities for offshore petroleum operations should report accident statistics in compatible formats so that statistical analyses of composite figures may be performed. That part of the CEQ recommendation which refers to unambiguous reporting and analysis of cause-effect relationships has already been addressed by the Work Group in its Recommendations Nos. 1 and 2.

Accordingly, Work Group Recommendation No. 2 (May 1973 report) is revised as follows:

WORK GROUP RECOMMENDATION NO. 2 (Revised)

a. Reports of major accidents stemming from the current USGS procedure for investigation of accidents should be made available to the public promptly.

b.

c.

d.

e.

Work Group Recommendation No. 3, calling for a system for disseminating information concerning equipment failures and accidents, should include a means for the public to have access to the information.

Analyses of causes of major oil spills should be made a
part of the accident investigation procedure and, if
required, by additional follow-up studies. Results of
all such analyses should be provided to the Review
Committee (see Work Group Recommendation No. 15).

Results of accident investigations, in addition to being
made available to the public, should be provided to the
Review Committee for possible further analyses.

The USGS accident reporting system should be modified in conjunction with DOT and EPA to insure compatible formats so that statistical analyses of composite figures may be performed.

IMPLEMENTATION ACTION REQUIRED (additional to those in May 1973 report)

Liaison should be established with the DOT and EPA to determine what modifications to the systems used by the agencies will be necessary to provide a comprehensive basis for adequate analyses.

CEQ 26. The Council recommends that the Department of the Interior determine the frequency and type of inspections necessary to verify compliance during all phases of OCS operations. It should establish inspection teams and procedures in light of those determinations and the scale of OCS development in various regions. State agencies should be invited to participate in these inspection efforts. In addition, the Department should establish a formal training program for the inspection staff.

• Work Group Recommendation No. 12 (May 1973 report) takes into account inspection frequency, strategy, and policy. While the Work Group agrees that personnel requirements for inspectors should be based on inspection strategies, it did not address this point specifically in its earlier response.

The Solicitor has informally advised the USGS that personnel from a State agency cannot assume the responsibility of the Federal Government for assuring compliance with the OCS Lands Act. The Work Group agrees, however, that in the absence of legal constraints it would be desirable to include representatives from coastal States in certain inspections.

Work Group Recommendation No. 9, Revised (Supplement No. 1, May 1974) responds to the need for a training program for the inspection staff.

Accordingly, in response to CEQ Recommendation No. 26, Work Group Recommendation No. 12 (May 1973 report) is revised as follows:

WORK GROUP RECOMMENDATION NO. 12 (Revised)

a.

The USGS should incorporate into its inspection program all of the NASA recommendations (a. through e. above) and LMS recommendations 1, 2, 3, and 5 above. Punitive fixedperiod shutins (LMS recommendation No. 4 above) are not permissible under existing legislation, nor are they considered advisable.

b.

c.

d.

e.

f.

g.

OCS Orders should include requirements for lessees to
conduct inspections on a scheduled basis and report the
results in a specified format to the USGS.

The USGS should explore the feasibility of third-party
inspections as an alternative or supplement to lessee
inspections.

The USGS should invite representatives from interested
State agencies to become familiar with Federal inspection
procedures. USGS should also request an opinion from the
Solicitor on the extent of possible participation by
State employees in OCS inspections, and respond accordingly
with invitations to the States to participate, as
appropriate.

The PINC system of inspection should be periodically
reviewed to determine how it should be modified and
improved.

The USGS should formalize inspection strategies and
policies, including optimum frequencies of inspections,
and emphasize improvement of methods for evaluating
inspection results. These results should be used in
determining the number of inspectors required.

The USGS should continue to evaluate procedures for
inspection and enforcement to insure the application of
rigorous and uniform practices in light of new require-
ments and past experiences.

IMPLEMENTATION ACTION REQUIRED (additional to those in

May 1973 report)

A Solicitor's opinion on the extent of State participation in OCS inspections should be requested.

Exploration and development of the OCS must take place under a policy which puts very high priority on environmental protection.

The location and phasing of OCS leasing should be designed to achieve the energy supply objectives of the leasing program at minimum environmental risk.

The best commercially available technology must be used to minimize environmental risks in new OCS areas.

• Regulatory authorities available to Federal agencies must be fully implemented and requirements strictly enforced to minimize environmental risks in new OCS areas.

Planning at all phases of OCS oil and gas operations must respect the dynamic relationship between initial Federal leasing decisions and subsequent State and local community action. The States and the communities affected must be given complete information as early as possible so that planning can precede and channel the inevitable development pressures. Experience must be continuously integrated into the management process.

The interested public must be given the opportunity to participate and play a major advisory role in the Federal management and regulation of the OCS.

1/ From the report to the President by the Council on Environmental Quality, entitled "OCS Oil and Gas An Environmental Assessment," April 1974.

REFERENCES

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Burley, J. D., and A. H. Drouin, October 1970, a Solution to ground subsidence casing strings and wellheads: AIME, 45th Annual Meeting.

California Department of Fish and Game, 1972, Listing of California's endangered and rare fish and wildlife.

Carlisle, J. G., H. Turner, and E. Ebert, 1964, Artificial habitat in the marine environment: California Department of Fish and Game, Fish Bulletin, 124, 93 p.

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Council on Environmental Quality, April 1974, OCS oil and gas--an environmental assessment: a report to the President by the Council on Environ

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