NVIC 03-05: Oversight of post-licensing deepwater port activities

COMDTPUB 16700.4 NVIC 03-05 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-05 Subj: GUIDANCE FOR OVERSIGHT OF POST-LICENSING ACTIVITIES ASSOCIATED WITH DEVELOPMENT OF DEEPWATER PORTS (DWPs)

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — PURPOSE. This circular establishes policy to supplement existing Coast Guard regulations and

directives. It provides guidance related to design, plan review, fabrication, installation, inspection, maintenance, and oversight of deepwater ports regulated under Title 33, Code of Federal Regulations (CFR), subchapter NN, parts 148, 149, and 150. It draws assistance from multiple resources, recognizes acceptable design guides and industry standards, establishes procedures for selection and acceptance of an entity to act on behalf of the Coast Guard, discusses review and acceptance of DWP Design Basis, and identifies roles and responsibilities of involved parties. Additionally, it outlines procedures for coordinating activities between Coast Guard Headquarters, the Marine Safety Center, Captains of the Port (COTP) and Officers in Charge of Marine Inspection (OCMl), as applicable.

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — ACTION.

a. DWP operators, Certifying Entities, and Coast Guard personnel are encouraged to follow the procedures set forth in this document. b. This NVIC is available on the World-Wide Web at: http://www.uscg.mil/hq/g-m/nvic/index.htm. The Coast Guard will distribute it internally by electronic means only.

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — DIRECTIVES AFFECTED.

a. Marine Safety Manual, Volume VI, Chapter 2. COMDTINST M16000.11. DISTRIBUTION - SDL No. 141 NON-STANDARD DISTRIBUTION: (See page 10) NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-05

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — BACKGROUND.

a. In 1974, in response to the growing domestic demand for imported oil and the energy industry's declared intent to construct deepwater ports, Congress passed the Deepwater Port Act (DWPA), as amended (33 USC 1501). As defined in the original DWPA, a deepwater port is "any fixed or floating manmade structure other than a vessel, or any group of structures, located beyond the territorial sea and off the coast of the United States and which are used or intended for use as a port or terminal for the transportation, storage, or further handling of oil for transportation to any State.…". The basic tenets of the original DWPA are to:

(1) Authorize and regulate the location, ownership, construction and operation of deepwater ports in waters located beyond State seaward boundaries;

(2) Provide protection for the marine and coastal environment by preventing or minimizing any adverse impact which might occur as a consequence of the port;

(3) Protect the interests of the United States and those of adjacent coastal States in the location, construction and operation of deepwater ports;

(4) Protect the rights and responsibilities of States and communities to regulate growth, determine land use and otherwise protect the environment in accordance with law;

(5) Promote the construction and operation of deepwater ports as a safe and effective means of importing oil into the United States and transporting oil from the Outer Continental Shelf

(OCS) while minimizing tanker traffic and the risks attendant thereto; and

(6) Promote oil production on the OCS by affording an economic and safe means of transportation of OCS oil to the United States mainland. b. Upon passage of the DWPA, the Coast Guard published in 1975, the deepwater port regulations, 33 CFR, chapter I, subchapter NN (Parts 148, 149 and 150). These regulations amplified the DWPA by providing a detailed framework for obtaining a deepwater port license and operating a deepwater port. Part 148 addresses licensing requirements, Part 149 concerns engineering/ technical requirements and Part 150 focuses on facility operations. The Coast Guard processed three oil deepwater port license applications in the late 70s and issued two licenses. The Louisiana Offshore Oil Platform (LOOP) commenced operations in 1981 and has been the only operational U.S. deepwater port ever constructed to import oil. c. In the 1990s, the energy industry advised Congress of their growing concern that the deepwater regulations were too burdensome and restrictive and hindered the competitiveness of the deepwater ports with other modes of importing or transporting oil. Operational experience with LOOP indicated the regulations for engineering and technical requirements were too prescriptive and did not encourage the use of proven industry standards or introduction of innovative technologies. d. In 1996, the DWPA was amended by the Deepwater Port Modernization Act (DWPMA) to:

(1) Update and improve the Deepwater Port Act of 1974 (33 U.S.C. 1501 et seq.);

(2) Assure that the regulation of deepwater ports is not more burdensome or stringent than necessary in comparison to the regulation of other modes of importing or transporting oil;

(3) Recognize that deepwater ports are generally subject to effective competition from alternative transportation modes and eliminate unnecessary federal regulatory oversight or involvement in the port's business and economic decisions; and

(4) Promote innovation, flexibility, and efficiency in the management and operation of deepwater ports by removing or reducing any duplicative, unnecessary, or overly burdensome federal regulations or license provisions. e. To implement the Modernization Act, update deepwater port regulations and solicit comments from the public and industry, the Coast Guard published an Advanced Notice of Proposed Rulemaking (ANPRM) on August 29, 1997 (FR Vol. 62, No. 168). On May 30, 2002, after considering public comments, the Coast Guard published a Notice of Proposed Rulemaking

(NPRM) which updated the DWP regulations and solicited comments from the public and industry.

On November 25, 2002, shortly after the comment period closed for the NPRM, the Maritime Transportation Security Act (MTSA) of 2002 was signed into law and amended the DWPA to add natural gas.

Additionally, the MTSA also called for the development of implementing regulations "as soon as practicable," and authorized publication of a temporary interim rule without regard to the usual public notice and comment provisions of the Administrative Procedure Act. f.

On January 6, 2004 (FR, Vol. 69, No.3), we published a Temporary Interim Rule (TIR) to address the addition of natural gas to the DWPA.

It remains effective until October 1, 2006 by which time a final rule should be published. g.

Throughout the DWP rulemaking process, we endeavored to develop regulations that were consistent with legislative mandates and sensitive to the needs of the public and industry alike.

One primary goal, identified in the DWP Modernization Act and reflected in our TIR, is to promote innovation, flexibility, and efficiency in the management and operation of deepwater ports by removing or reducing any duplicative, unnecessary, or overly burdensome federal regulations or license provisions.

Rather than prescribing requirements by regulation, the TIR authorizes the licensee to consolidate within the deepwater port operations manual all aspects of port-related activities including vessel traffic control, cargo transfer operations, maintenance of all vital engineering systems, safety and environmental issues, emergency measures and port security, and personnel qualifications. h.

Since the MTSA was signed into law, we have reviewed and evaluated a broad range of design concepts.

The proposals included use of Gravity Based Structures (GBS), Submerged Turret Loading systems (STL), conversion of existing fixed offshore platforms, submerged underground LNG salt cavern storage arrangements, and Floating Storage and Regasification Units (FSRU).

As described in the preamble of the TIR, we chose not to attempt to identify specific standards and stated we would work to determine the adequacy of classification society guides and other relevant and proven standards.

The following excerpt from the Preamble of the TIR summarizes our plans for addressing design standards: "Accordingly, in this temporary interim rule we have removed references to industry standards in our regulatory text and instead, we have written the regulations performance levels that we believe deepwater ports must meet.

Applicants and operators will need to demonstrate the ability to maintain these prescribed levels.

We are not ready to identify industry standards in the regulations that will have the force of law for both regulators and the regulated public.

The Deepwater Port Modernization Act of 1996 was intended to encourage flexibility and innovation and to avoid rigid regulations that fit the existing model for deepwater ports represented by the Louisiana Offshore Oil Port (LOOP).

DPMA supports detailing port specific requirements in the license or, as much as possible, in the port's operations manual.

If rapid advances in technology, such as those now seen in the offshore energy and transportation industry, new regulations may lag and existing ones may not fully apply to proposed innovations.

The current situation is similar to one that existed 15 years ago when tension leg platforms were introduced to access oil and gas on the U.S.

Outer Continental Shelf at previously unattainable water depths.

At that time industry submitted a design basis plan that the Coast Guard reviewed and approved as the standards to be used for a particular project.

Now, applicants for deepwater port licenses have identified proposed standards or a design basis plan within their applications.

The Coast Guard is identifying appropriate standards as part of the application reviews and for inclusion in the final rule for deepwater ports.

In doing so, we will combine, to the extent practicable, existing standards and regulations that have proven successful for vessels, offshore structures, and onshore liquefied natural gas (LNG) import terminals.

In addition, several classification societies are developing guides for offshore LNG terminals.

We will work with them and other Federal agencies having experience in various aspects of oil and LNG terminals to determine the adequacy of these guides and other relevant standards and regulations, such as NFPA 59A and 49 CFR part 193" i.

Since the publication of the TIR, we have examined an extensive number of potential standards and guides related to the design and construction of deepwater ports.

This has served to further validate our thoughts in developing the TIR.

Given the range of design variation among proposed deepwater ports, and the spirit of the DWPMA, it is not practicable to identify a specific regulatory regime that would incorporate all the individual standards (U.S. and International) which could be applied.

We have concluded that the rules and guides published by the recognized classification societies not only identify specific standards that we would otherwise identify individually, but more importantly provide a sufficient framework for design, fabrication, installation, and maintenance to ensure safe designs and operations.

Utilization of class society rules and guides is consistent with requests from industry and establishes criteria for review, approval, and enforcement. j.

Given the resources and levels of expertise needed to address the dynamic range of designs for DWP's, we are using a new approach for the review, approval and inspection of these projects, but one that is similar to existing Coast Guard programs.

The Coast Guard, along with other federal agencies, recognizes the value of utilizing third parties to assist in fulfilling its regulatory obligations.

The Minerals Management Service (MMS), the Federal Energy Regulatory Commission (FERC), and the Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety (PHMSA-OPS), administer programs and periodically obtain assistance from outside sources in technical areas similar to those now delegated to the Coast Guard under the DWPA.

Currently, the Coast Guard uses third parties to accept vapor control systems at waterfront facilities (33 CFR 154.804), and to approve containers that comply with the International Safe Containers Act (49 CFR 450).

Additionally, other programs outlined in Navigation and Vessel Inspection Circulars (NVICs) 10-82, 10-92, and 2-95 assist the Coast Guard by recognizing the service of third party professional engineers and recognized classification societies.

We have determined the practice of using third party resources is worthwhile, if not essential, for ensuring that DWP's are designed, fabricated, installed, and maintained in accordance with safe engineering practices.

Third party certification documents issued initially and at periodic intervals over the life of a DWP will be provided to the Coast Guard to serve as evidence that all components of the DWP were built and/or are being maintained in accordance with the original approved design standards.

Follow-on certification may be conducted by the original Certifying Entity (CE) or other individual accepted by the Coast Guard. k.

This circular recognizes that deepwater port projects represent tremendous investments which can range on the order of one or several billion dollars.

Offshore projects of this magnitude are generally only undertaken with the direct involvement or support of one or more of the major energy companies.

To protect their sizeable investments, these companies are generally conservative and cooperative with the Coast Guard and other federal agencies to ensure that a safe and reliable project is obtained.

In order to achieve this, they take steps internally and through the use of third party representatives to verify their projects are properly designed, built, and operated.

Therefore, the Coast Guard does not consider it necessary to be present for every phase; rather, the Coast Guard can rely on industry professionals while maintaining sufficient oversight to ensure that the applicant and the accepted CEs are carrying out their responsibilities.

In so doing, the Coast Guard will be able to tailor its involvement through oversight as appropriate, depending on the complexity of design and their confidence in the abilities of the operator and the CE. l.

The procedures set forth in this policy provide a framework for managing DWPs in a manner which is consistent with the DWPMA, the approach taken by other federal agencies, as well as other Coast Guard programs.

We intend to incorporate details of this policy into the DWP final rule.

Notice to the public regarding availability of this guidance will be announced in a Federal Register at which time public comments will be requested to help us further develop and/or refine this policy.

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — DISCUSSION.

a. General Information - The following paragraphs discuss details related to the program we envision for handling design, fabrication, installation, maintenance and inspection of deepwater ports. Enclosures (1) through (4) incorporate the information presented in this discussion and provide a framework which outlines the roles and responsibilities of involved parties throughout different phases of a project. Participation is not mandatory. However, due to the scope and complexity of many deepwater port projects, the evaluation and approval process can be greatly facilitated with the involvement of third party technical specialists. Those agreeing to participate would be expected to follow the guidance provided. b. Applicability - All DWP operators subject to the rules effective January 6, 2004. c. Definitions - The following definitions, derived from the Code of Federal Regulations (CFRs), are applicable:

(1) Operator - means the person who is licensed under 33 U.S.C. 1503 to own, construct, and operate a deepwater port, or the person's designee.

(2) Certifying Entity (CE) - means an individual or organization, other than the operator, accepted by Commandant (G-MSO) to perform tasks on behalf of the Coast Guard such as reviewing plans and calculations for construction of deepwater ports, conducting inspections, witnessing tests, and certifying that systems and/or components associated with deepwater ports are safe and suitable for their intended purpose. d. Nomination of CE - For each deepwater port, the operator may nominate a CE for Coast Guard approval. The nominee must be capable of performing all tasks normally performed by the Coast Guard throughout the project from concept review to final certification. Operators must formally notify the Coast Guard of their proposed choice of a CE and must submit a nomination letter to Commandant (G-MSO-5) for acceptance. Nomination letters should be submitted as early as possible and shall include the following:

(1) Name and address of the nominated individual or organization;

(2) Size and type of the nominee's organization or corporation;

(3) Previous experience as a CE, Certified Verification Agent (CVA), or similar third-party representative;

(4) Experience in design, fabrication, or installation of fixed offshore oil and gas platforms, similar fixed, floating or gravity based structures, and project related structures, systems and equipment;

(5) Technical capabilities (including professional certifications and organizational memberships) of the nominee or the primary staff to be associated with the certifying functions for the specific project;

(6) In-house availability of, or access to, appropriate technology (i.e., computer modeling programs and hardware, and testing materials and equipment);

(7) Ability to perform and effectively manage certifying functions, inspections, and tests for the specific project considering current resource availability;

(8) Previous experience with regulatory requirements and procedures;

(9) A statement signed by the chief officer of the organization or the chief officer's representative that the nominee – a) Is not owned or controlled by the designer, manufacturer, or supplier of the system and its subsystems of the equipment or material to be inspected or tested under regulations applicable to this deepwater port or any manufacturer of similar equipment or material; and b) That an official representative of the Coast Guard is allowed access upon request to the place where tests and inspections take place, to verify the information submitted in the application, or to witness tests and inspections;

(10) The level of work to be performed by the nominee; and

(11) A list of documents and certifications to be furnished to the Coast Guard by the nominee. e.

Pre-Acceptance Interview - Nominees, unless previously accepted for similar projects, must be interviewed by the Coast Guard for the purpose of assessing the scope of their abilities.

Nominees should provide a presentation detailing their ability to perform actions on behalf of the Coast Guard.

Required actions include but are not limited to evaluating proposed design standards; conducting plan review; drafting plan approval letters and related correspondence; maintaining records; drafting action plans; evaluating alternative systems and designs; verifying design compliance; assessing existing structures; evaluating novel concepts; certifying systems and equipment; performing inspections; verifying adequacy of materials; witnessing tests; conducting quality assessments; evaluating risk; and communicating information to the Coast Guard.

The presentation shall take place at Coast Guard Headquarters in Washington, D.C. and include Commandant (G-MSO-5), and the Marine Safety Center (MSC).

The nominee is expected to be familiar with the project and should be prepared to briefly answer questions about handling the project on behalf of the Coast Guard.

Additionally, the nominee should identify any areas of concern and discuss their initial impression of the project. f.

Coast Guard Acceptance of Nominee - Commandant (G-MSO-5) shall consult with the MSC and provide a letter to the operator and the nominee indicating their decision to either accept or reject the nominee to act on their behalf.

If accepted, the nominee shall be designated as the CE for the Coast Guard on the project. g.

Initial Presentation and Periodic Meetings - Prior to the start of the design review phase, CEs shall provide an initial presentation to the Coast Guard outlining details of their plans for handling the project and interacting with the Coast Guard.

Primary focus of the initial meeting will be concentrated on identifying various phases of the project (i.e. design, fabrication, installation, testing, etc.), establishing dates and timelines, designating points of contact, and discussing project specific details.

CEs will be required to submit an action plan to the Coast Guard for each phase of the project detailing their plans for interacting with and acting on behalf of the Coast Guard.

Action plans for the design phase should be submitted at the initial presentation and plans for other phases of the project should be submitted at least 60 days prior to the date the phase is scheduled to begin.

The MSC will review and approve action plans for the design phase based on the requirements of Enclosure (1).

All other action plans will be reviewed and approved by Commandant (G-MSO-5).

Guidance for the fabrication and installation phases is provided in Enclosures (2) and (3).

Periodic meetings between the CE and the Coast Guard are recommended prior to the start of each major phase to identify and discuss details.

Meetings and presentations shall normally take place at Coast Guard Headquarters in Washington, D.C. and will include Commandant (G-MSO-5) and the Marine Safety Center.

As necessary, Commandant (G-MSO-5) will involve the cognizant COTP/OCMI. h.

Design Standards - All structures, systems, and components of a deepwater port must be designed, fabricated, installed, and maintained in accordance with the performance standards indicated in 33 CFR 149.625.

CEs shall review the design standards proposed by the DWP operator and provide a letter to the Coast Guard indicating their recommendation that the Coast Guard either accept or reject the proposed standards.

Guides for offshore LNG terminals developed by recognized classification societies such as the American Bureau of Shipping (ABS), Det Norske Veritas (DNV), and Lloyd's Register (LR) provide adequate guidance for safe design and may be utilized as the basis for an overall design of a DWP.

Through the Coast Guard expects most will choose to apply guidelines or rules developed by a recognized class society, each applicant is free to identify and propose the industry recognized standards they feel are most applicable to their particular design.

Deepwater ports certified to be designed, fabricated, installed, and maintained according to class guidelines will be recognized as meeting compliance with this part. i.

Drawings and Specifications - In lieu of submitting construction drawings to Commandant G-M, as required by 33 CFR 149.615, the DWP operator shall provide a list of all drawings necessary for construction to the CE, the MSC, and Commandant (G-MSO-5).

The CE shall review the list of drawings provided by the operator, identify critical systems, structures, and/or components, and request that the operator send such plans to the CE for review and approval.

In addition to bearing the seal of a registered professional engineer as required by 33 CFR 149.615(b), each drawing must identify the baseline design standard(s) used as the basis for design, and contain, or be supplemented with, sufficient information to permit a comprehensive review.

The CE shall inform the MSC of plans they have requested for review and coordinate with the MSC throughout the review process as indicated in Enclosure (1).

If necessary, Commandant (G-MSO-5) may request that the CE conduct a review of plans not previously identified.

As indicated in Enclosure

(1), the MSC may conduct oversight on selected plans. j.

Reports - The CE shall provide periodic reports to the Coast Guard throughout various phases of the project.

Details of information required during the Fabrication and Installation phase are contained in Enclosures (2) and (3).

Prior to initial operation, the CE shall provide the Coast Guard with a final report attesting that the Deepwater Port and all associated components were satisfactorily tested and have been designed, fabricated, and installed according to Professional Engineer certified plans and is suitable for its intended purpose. k.

Certification - The CE shall provide documents to the cognizant Coast Guard Officer in Charge of Marine Inspection (OCMI) certifying that all major components and critical systems of the DWP are safe and suitable for their intended service and comply with the requirements outlined in 33 CFR Subchapter NN.

Major components and critical systems may include but are not limited to all fixed, floating, or gravity based structures; cryogenic piping systems; LNG storage tanks; containment systems; vaporizers; liquefaction systems; loading arms; skid-mounted systems; control and safety systems; flare systems; cranes; lifesaving; firefighting; navigation aids; and personnel accommodations.

Annual certification shall be provided to the OCMI attesting that all components of the Deepwater Port are being operated and maintained according to the original design standards and are safe and suitable for continued service.

Annual certification may be provided by the original CE, a recognized class society, or a registered professional engineer acceptable to the cognizant OCMI. l.

Maintenance - The operator of each DWP is responsible for ensuring that their DWP is maintained and operated in a safe manner.

In addition to the items listed in 33 CFR 150.15(n), operators shall develop maintenance programs for all structures, systems, and/or components of the DWP identified by the CE or the Coast Guard as being critical for the protection of personnel or the environment.

Maintenance programs should be based on original design standards, guides, or manufacturer's recommendations and shall be submitted to the CE for review.

Upon completion of the review, the CE shall provide a recommendation to the cognizant OCMI that the Coast Guard accept, reject, or request modification of the operator's maintenance program.

The OCMI will review and comment on the maintenance program and CE recommendations and forward the maintenance program and comments to Commandant (G-MSO-5) for review and approval.

Once approved, the maintenance program will form part of the DWPs operations manual. m.

Inspection - Inspection requirements for DWPs are outlined in 33 CFR 150.100 and 150.105.

Unmanned structures, including systems and components connected to unmanned structures, are considered part of the DWP.

As such, they are also subject to inspection as outlined in 33 CFR 150.100.

Operators shall develop an inspection program which addresses procedures for conducting periodic inspections covering all aspects of the DWP.

Inspection programs should be based on original design standards, guides, or manufacturer's recommendations and shall be submitted to the CE for review.

Upon completion of the review, the CE shall provide a recommendation to the cognizant OCMI that the Coast Guard accept, reject, or request modification of the operator's inspection program.

The OCMI will review and comment on the inspection program and CE recommendations and forward the inspection program and comments to Commandant (G-MSO-5) for review and approval.

Once approved, the inspection program will form part of the DWPs operations manual. n.

Pipelines - The Department of Transportation (DOT) Office of Pipeline Safety (OPS), in cooperation with the Department of Interior (DOI) Minerals Management Service (MMS), will be responsible for regulating offshore pipelines and/or permitting pipeline Rights-of-Way (ROW) associated with deepwater ports.

Pipelines shall be designed, fabricated, installed, and maintained in accordance with DOT regulations found in 49 CFR Part 192 or Part 195 based on transported commodity.

As applicable, pipelines shall meet DOI's regulations found in 30 CFR Subpart J pertaining to ROW permits.

The Coast Guard will maintain responsibility for review and approval of pipelines, risers, and components located between the discharge point of a Pipeline End Manifold (PLEM) up to and including Single-Point Moorings (SPM), Floating Storage and Regasification Units (FSRU) or other floating marine terminal.

Pipelines and risers on fixed structures will be regulated by DOT and DOI pursuant to their respective authorities.

Commandant (G-MSO-5) will consult with DOT and DOI on issues related to pipelines for DWP projects and may request assistance in other areas where DOT and DOI have established federal regulations, policy, and expertise.

Operators should contact DOT and DOI regional offices for guidance related to pipeline plan submission and requirements applicable to their specific project. o.

Fixed Structures (New and Existing) - New and existing fixed OCS structures which are proposed for use as component of a DWP will be reviewed and approved jointly by the Coast Guard and the MMS.

These structures must be designed, fabricated, installed, and maintained in accordance with the requirements outlined in American Petroleum Institute RP-2A, 21st Edition.

Operators must provide original design information, survey reports, recent structural analysis, and other related information which demonstrates the existing structures is safe for its intended purpose.

Plans and information for new and existing structures shall be sent to the MSC and the MMS regional office nearest to where the structure is or will be located.

The MSC will work with Commandant (G-MSO-5) to coordinate issues related to fixed platforms.

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — DISCLAIMER. While the guidance contained in this document may assist the industry, public, Coast

Guard and other Federal and State regulators in applying statutory and regulatory requirements, the guidance is not a substitute for applicable legal requirements; nor is it a regulation itself. Thus, it is not intended to nor does it impose legally binding requirements on any party, including Coast Guard, other federal agencies, states or the regulated community.

Guidance for oversight of post-licensing activities associated with development of deepwater ports (DWPS). — QUESTIONS. Questions, comments, and suggested changes may be directed to Commandant (G-

MSO-5) at (202) 267-0578. T. H. GILMOUR Rear Admiral, U.S. Coast Guard Assistant Commandant for Marine Safety, Security and Environmental Protection Encl: (1) Deepwater Port (DWP) Guidance - Design Phase (2) Deepwater Port (DWP) Guidance - Fabrication Phase (3) Deepwater Port (DWP) Guidance - Installation Phase (4) Deepwater Port (DWP) Guidance - Maintenance and Inspection NON-STANDARD DISTRIBUTION B:a Commandant G-LMI, G-MOC, G-MSE C:m Marine Safety Center