Drill ship oil record book question

[ChiefRob]

I have a question about how to handle drilling mud in the oil record book onboard a drill ship. When fuel, oil based, or synthetic base mud is hauled out to a rig on a supply boat, I know it is considered cargo. However once the fuel comes onboard the drill rig, it is no longer cargo, it is considered machinery space operations. This is the same thing we do on our ROV boat. The drilling mud makes me wonder if it is still considered cargo and gets recorded under part II cargo/ballast operations, or does it go into the oil record book under part I as machinery space operations.

1 It is an oil product and has to be accounted for.
2 Sometimes it does get pumped back off the rig to the supply boats
3 Sometimes the well does drink and mud gets lost.
4 Under part I machinery space operations in the oil record book there is no sub title for unloading cargo. Only bunkering, storing, accidental discharges and automatic discharges. That is why it makes me wonder about mud belonging under part II cargo. Even though when mud is stored onboard a rig it is technically not cargo. ie sometihng they are making revenue by transporting.
5 If it is technically considred cargo should the engineers be required to have a tankerman pic endorsemant. My reading of the cfr's seems like they would if it is considered liquid cargo in bulk.
6 Under part I machinery space operations the only place I could see being able to accuratley record getting rid of oil base mud is under section C collection and disposal of oil residues, (sludge, and other oil residues) This is the one we have always used for disposing of dirty oil, and recording the weekly tank soundings.
7 If it is considered cargo it would be under part II in the oil record book and they have a header for unloading, but not really for loosing it down the hole, unless it would be approiate to use header J, (disposal of residues and oily mixtures not otherwise dealt with) Most probably though header N ( accidental or other exceptional discharges of oil).

Maybe some of the guys on drilling rigs or ships can shed some light on this for me, or have a different opinion.

[c.captain]

Darned good question ChiefRob...a very good question indeed...

Can we have the next question please?

[c.captain]

Actually this is a very good question and one without any clear answer.

An OSV although not certified as a tankship is allowed to carry cargo oil in bulk to support offshore facilities.

Since a MODU doesn't carry oil in bulk for transport then it would not be considered cargo and that is a good thing for MODUs because I for one would not want to have to follow tankship rules.

But the base oil and oil based mud on a MODU is not part of machinery space operations but rather industrial operations. I would think it would be best to have a second machinery space oil record book to specifically record and document all rig based oil transfer ops and that way if there is an incident, then you do have something to show the history of transfers, but the question is who maintains the book? It should not be the chief since that oil is not under his control. I would say that it would be maintained by the drilling department and signed by the OIM and master. It is also possible that the BSEE has something for this but I have never seen such as record.

The most important thing IMO is to NOT treat the oil as cargo. You wouldn't want to go there!

[+A465B]

Is the mud treated as MARPOL Annex II - a NLS?

[Fraqrat]

We use NLS Cargo Record Book for all mud water or oil based.

[ChiefRob]

We use NLS Cargo Record Book for all mud water or oil based.

I understand how it is done on a supply boat, because drilling mud is cargo on a osv. I searched through the cfr's this morning and could not really find anything about drilling mud or base oil once it is onboard a rig.

As c.captain pointed out some rigs don't have any licensed crew at all. Who takes care of the oil record book on a modu, the ballast control operator?

I am still reasearching trying to find out the answer. It seems to be one of those grey area's again, that may not have a correct answer.

[Fraqrat]

Is the answer "C" ?

[cmakin]

I only
II only
I and II
Sometimes I but not II
Sometimes II but not i
Never I but sometimes II
Never I and II. . . . . .