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1 SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS This report assesses alternatives for disposing of fixed offshore oil and gas structures (also called platforms) after petroleum produc- tion has ceased. It was prepared at the request of the Department of the Interior (DOI). In 1984 DOI asked the Marine Board of the National Research Council to document and assess alternatives for removing, disposing of, or reusing fixed offshore platforms that are past their useful service life, and to make recommendations concerning government policy on their disposition. Considered in the assessment are technical issues of engi neer i ng feasibility and cost, legal issues, environmental concerns, safety, and maritime and naval operational considerations. In 1983 there were 4,094 fixed offshore oil and gas drilling and production structures located in the territorial sea or on the conti- nental shelf of the United States. An additional 1,461 structures are projected for installation through 1990. More than 95 percent of the structures are or will be located in the Gulf of Mexico. This is the population of structures that may have to be disposed of in the next 35 years, the time-frame of this study. Under current rules, offshore installations are to be entirely removed at the end of their useful life. The committee found that this rule is achievable since all structures installed to date in U.S. waters can be removed and returned to shore for disposal using current technology, even though the largest platforms will involve great expense. The committee also found sufficient evidence to conclude that there is substantial justification for the U.S. government to adopt a more flexible policy on the disposition of offshore platforms. RECOMMENDATION: The Department of Interior should amend its removal policy to allow determination of the ultimate disposi- tion of offshore platforms on a case-by-case basis in accord- ance with predetermined standards and criteria. These stan- dards and criteria should be consistent with international law and preferably the product of explicit international agreement. RECOMMENDATION: The United States should develop a national position on the disposition of offshore platforms for sub- 1

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2 mission to the International Maritime Organization for interna- tiona1 consideration. The U.S. Coast Guard should initiate this process promptly, in concert wi th the Department of State, Department of Interior, Department of Defense, Envi ronmental Protection Agency, other interested agencies, and nongovern- ment interests. The amended policy and national position should retain the presump- tion that platforms installed on the outer continental shelf (OCS) can be removed. In all instances, offshore structures in water depths of less than 200 feet should be removed unless they are dedicated to an alternative, permitted use.* Decisions concerning the removal of all other platforms or parts thereof ~ including deep-water fixed steel platforms, subsea template installations, and large concrete gravi ty-base structures ) should be made after cons idering the cost of removal: versus public benefit, liability aspects, safety and freedom of surface and subsurface navigation, possible alternative uses, and potential interference with other uses of the sea and seafloor. Moreover, all platforms should be removed to a depth sui table for the safety of surface navigation, unless those portions of the structure above the surface or in the upper water column are specif ically permitted for another use . Although approvals of plans and des igns for final disposition of platforms are best made at the time of original approval for emplacement, the amended policy and national position should provide for review at the time of final disposition. Irrespective of government policy, those harmed as the result of the presence in the sea of an offshore platform or any of its parts could claim against the last entity that owned it: there is now no way that the platform--or any other wreck--could be abandoned in such a way as to eliminate the risk of legal liability (see Wyandotte Transportation Co. v. United States, 389 U.S. 191, 88 S. Ct. 379, 1967 A.M.C. 2553 (1967), discussed in the footnote on page 41 herein). This continues unless and until the platform is disposed of on shore or disposed of at sea in accordance with ocean dumping rules, or the owner is indemnified by the government. Thus, the avoidance of potential liability generates, in itself, an inducement for the removal of a platform in less than 200 feet of water (93 percent of all platforms). Additionally the difficulty of obtaining permission for ocean dumping and the relatively few opportunities for some alternative uses favor removal to shore of platforms in waters out to 200 f eat . With regard to implementation of a case-by-case decision-making policy, an alternative for the largest fixed steel structures located far offshore that would address engineering and cost concerns, legal and safety issues, and possibly environmental considerations is removal of the entire structure or the upper portion to a depth This guidance is based on and specific to conditions in the Gulf of Mexico, as elaborated in the text. Conditions in other regions may make a different depth choice more desirable.

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3 suitable for safety of surface and subsurface navigation; the removed structure or parts thereof could then be disposed of in a designated ocean dumpster. RECOMMENDATION: The Environmental Protection Agency should establish a limited number of ocean dumpsites for the disposal of offshore platforms and a policy and permitting procedure regarding use of these dumpsites. In addition, the Environ- mental Protection Agency should consider establishing a general permit, similar to that for the disposal of ships, for the disposal at an ocean dumpsite of the few largest offshore platforms. In some cases, such as use as a fishing reef, all or part of the structure may be left in place or relocated to another marine loca- tion. This creates a difficult situation for the owner, since he may be subject to claims on tort liability principles. If case-by-case decision making is to work, some solution must be found for the problem of tort liability. Complete removal of a platform with dispo- sition ashore removes the tort liability burden completely from the owner. Complete removal and ocean dumping, given faithful compliance with the Environmental Protection Agency (EPA) permit, has the same effect. No other method of disposition affords the same degree of protection from continuing liability. This reduces the practical value of other alternatives, and impairs the effectiveness of case-by- case decision making. RECOMMENDATION: The Department of the Interior should develop a proposal designed to provide relief from liability to former owners of platforms where the means of disposition approved by the government does not do so. Relief might be provided in several ways; for example, through government indemnification of former owners or conceivably through the creation of an industry-based trust fund or insurance scheme. Implementation of the liability relief proposal that is developed could possibly require an act of Congress. A policy of case-by-case decision making will result in a limited number of whole or partial structures left in place. This could impair navigation safety, naval operations, and commercial fishing. The government would probably assume some additional responsibility, perhaps liability, by authorizing all or part of a structure to be left in place. Some would view this policy as overly generous to the oil industry. Nonetheless, the committee considers it difficult to justify a government requirement for expenditure of very large sums of private monies where marginal public benefit would result. Regardless of ultimate disposition, design should consider disposal requirements and should guard against features that make final dispo- sition any more difficult than is inherent in the operations. Designs might include, for example, planning to provide adequate buoyancy at

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4 time of removal, positive connections for bolt-on clamps for auxiliary or temporary buoyancy, and planned separation points in the jacket, which would allow cutting fewer structural members. It is not likely, however, that a weak 1 ink such as a bolted or other easy-to-remove joint on j acket legs would ever be des irable or acceptable because i t could weaken the overall structure. Furthermore, it is not likely that enhancement reasonably achievable in the initial design can have substantial impact on the cost or choice of ultimate disposition for major structures.