Bureau of Safety and Environmental Enforcement Gulf of Mexico OCS Region
TJ Broussard Chief, Environmental Enforcement Branch
The Bureau of Safety and Environmental Enforcement (BSEE) is responsible for permitting the placement and eventual removal of temporary facilities on the Federal OCS for the exploration, development, and production of oil and gas.
Caissons & Well Protectors
Jacketed Platforms
Floating Facilities (SPARs/TLPs/MPUs)
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Outside of 21 Platforms found on the Pacific OCS, all other OCS Platforms/Facilities (~2,900) are located in the Gulf of Mexico (GOM).
Approximately 250 Platforms are located off of Texas with nearly 2,600 centered off the Louisiana coast. 3
Decommissioning
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When an OCS Lease expires and/or development and production operations cease, companies are obligated to decommission and remove their platforms and clear the seabed of all obstructions in order to avoid potential conflicts with other users of the Federal OCS.
The need to remove obsolete OCS infrastructure is not new; decommissioning requirements under Subpart Q of the OCS Lands Act (OCSLA) Regulations have remained relatively unchanged for decades. 5
Decommissioning Elements and Requirements: 30CFR§250.1702 Establishes “Who” and “What”
Lessees, Operators, and Right-of-Way Holders Take on Decommissioning Obligations whenever they: Drill a Well, Install a Platform, Pipeline, or Other Facility, Create on Obstruction to Other Users of the OCS, or Acquire Leases or Rights-of-Way from other groups.
30CFR§250.1703 Establishes “When” and “How”
Whenever Facilities are No Longer Useful for Operations: Permanently Plug All Wells, Remove All Platforms and Other Facilities, Decommission All Pipelines, Clear the Seafloor of All Obstructions, and Conduct All Decommissioning Activities a Manner that is Safe, will not Interfere with Other OCS Users, and does not cause undue/serious damage to the environment. 6
Most Decommissioning and Removal Operations for Caissons and Jacket Platforms are similar:
Once all equipment is flushed and removed, the decks (i.e., topsides) are removed... 7
Steel piles pinning the jackets to the seabed and well conductors are severed below the mudline via mechanical cutters, divers, or explosive charges... 8
The jacket is lifted and all components are loaded onto material barges and brought to shore for disposal/recycling...
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The final stage of decommissioning involves debris removal and site-clearance verification methods to clear the seabed of obstructions that may impact other users of the OCS such as future OCS energy efforts, commercial fishermen and shrimpers, sand replenishment activities, etc.
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Idle Iron
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Between 2004 and 2008, OCS infrastructure in the Gulf of Mexico was hit by several major storm systems that destroyed and damaged over 200 platforms.
Hurricanes Katrina and Rita alone, accounted for 111 destroyed/severely damaged platforms, with ~50% of those structures on terminated leases - meaning they should not have been there to begin with. Each toppled or damaged platform posted a grave threat to the environment, navigation, and to the safety of workers who had to repair/remove the structures. 12
EC222 Platform A & Platform AUX before Rita:
After Rita: 13
Platform Typhoon before Storm:
Platform Typhoon after storm: 14
WD117 Platform F before storm:
WD117 Platform F after storm: 15
Production Equipment before storm:
Production Equipment after storm: 16
The decommissioning of a toppled platform is greatly complicated and extremely dangerous; requiring a much greater use of divers, dangerous cutting equipment, and special lifting operations.
Several contractors developed improved equipment to support the challenges; including Versabar’s “Bottom Feeder,� used to lift toppled decks and components from the seabed with minimal diver interaction. 17
Following the 2008 storm season, the decommissioning program underwent an Alternative Internal Control Review (AICR) to address the problems brought to light by the hurricane damage. Among other proposed improvements, the AICR determined that the agency needed to better clarify decommissioning requirements; especially, 30CFR§250.1703: “Whenever Facilities operations.”
are
no
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In September of 2010, a Notice to Lessees and Operators (NTL) was issued to: • Clarify the definition of ‘no longer useful’ phrase, • Propose better planning and reporting, and • Remind companies that they needed to remove obsolete platforms and wells within 5-Yrs of making the determination. 18
Despite recent comments about Idle Iron, the NTL did not impose any new requirements. Most companies had already become more vigilant about meeting their decommissioning obligations after witnessing the damage caused by the storms and having to cope with the dramatically-increased costs; often 10 to 15 times that of a standard/non-toppled removal.
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Rigs-To-Reefs
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The Minerals Management Service (MMS), the predecessor of BSEE, was a key figure in artificial reef policy, studies, and cooperation in the early 1980’s. The role of active OCS platforms in marine ecology and how decommissioned facilities could serve as valuable reef material has been studied and recognized: Design
of most platform jackets allows for effective water circulation; Jacket material is long lasting and provides a stable substrate for a host of organisms; and Jacket size can support species throughout the water column.
The Rigs-to-Reefs Program was formalized in 1985 and has resulted the donation of over 420 platforms as reef material on the GOM OCS. 21
BSEE continues to support and encourage the reuse of obsolete platform jackets as artificial reef material and will grant a departure from removal requirements under 30 CFR §250.1725(a) and applicable lease obligations provided that:
The structure becomes part of a State reef program that complies with the National Artificial Reef Plan; The State agency acquires a permit from the Army Corps of Engineers and accepts title and liability for the reefed structure once removal/reefing operations are concluded; The operator satisfies any U.S. Coast Guard navigational requirements for the structure; and The reefing proposal complies with BSEE engineering and environmental reviewing standards. 22
Rigs-to-Reefs Policy Addendum (2009): Outlined enhanced reviewing and approval guidelines in response to the Post-Hurricane Katrina regulatory environment; “Put the Brakes” on dozens of reef proposals incorporating platforms destroyed or toppled during the 2005-2008 hurricane seasons that were not adequately prepared for reefing; and Helped the agency tackle public criticism and NGO assertions that Rigs-to-Reefs was becoming a de facto “Ocean Dumping Program.”
Rigs-to-Reefs Interim Policy Document (2013): The Interim Policy Document (IPD) is a continuation of the Federal, State, and public coordination recommended in the 2009 Addendum. Removes the approval restrictions on Special Artificial Reef Sites (SARS). Minimum reef-site spacing now pending case-by-case review with State. IPD is currently in final review/surnaming.
New Rigs-to-Reefs Coordinator (2013): Unit Chief ready to select the new Rigs-to-Reefs Coordinator. Full time position to conduct permit reviewing and oversee agency and public outreach/program improvements;
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Questions?
TJ Broussard t.j.broussard@bsee.gov 504-736-3245
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