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DISPOSAL OF OFFSHORE PLATFORMS Committee on D1spositlon of Offshore Platforms Marine Board Commisslon on Englneering and Technical Systems N~tlona1 Research Council Natlona1 Academy Pres Washlngton, O.C. 1985

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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This report has been reviewed by a group other than the authors according to procedures approved by a Report Review Commi t tee cons; st- ing of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Research Council was established by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering know- ledge and of advising the federal government. The Council operates in accordance with general policies determined by the Academy under the authority of its congressional charter of 1863, which establishes the Academy as a private, nonprofit, self-governing membership corpora- tion. The Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineer- ing in the conduct of their services to the government, the public, and the scientific and engineering communities. It is administered jointly by both Academies and the Institute of Medicine. The National Academy of Engineering and the Institute of Medicine were established in 1964 and 1970, respectively, under the charter of the National Academy of Sciences. This report represents work supported by cooperative Agreement No. N00014-82-C-0032 between the Department of the Interior and the National Academy of Sciences. Limited copies are available from: Marine Board Commission on Engineering and Technical Sy5 tems National Research Council 2101 Constitution Avenue, N.W. Washington, D.C. 20418 Printed in the United States of America

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t COMMITTEE ON DISPOSITION OF OFFSHORE PLATFORMS William M. Benkert, Chairman U.S. Coast Guard (retired) McLean, Virginia Roger D. Anderson Gulf and South Atlantic Fisheries Development Foundation, Inc Tampa, Florida Robert B. Ditton Texas A&M University College Station, Texas Francis P. Dunn Shell Oil Company Houston, Texas Griff C. Lee Griff C. Lee, Inc. New Orleans, Louisiana Maurice H. R;ndskopf Wes t i nghouse Electric Corporation Annapolis, Maryland Sidney A. Wallace, Esq Reston, Virginia Staff Charles A. Bookman Linda J. Cannon . . . e

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MARINE BOARD of the COMMISSION ON ENGINEERING AND TECHNICAL SYSTEMS NATIONAL RESEARCH COUNCIL Bramlette McClelland, Chairman McClelland Engineers, Inc. Houston, Texas William C. Webster, Vice-Chairman University of California Berkeley, California Roger D. Anderson Gulf and South Atlantic Fisheries Development Foundation, Inc. Tampa, Florida Robert D. Ballard Woods Hole Oceanographic Institution Woods Hole, Massachusetts William M. Benkert U.S. Coast Guard (retired) McLean, Virginia Kenneth A. Blenkarn Amoco Production Company Tulsa, Oklahoma Donald F. Boesch Louisiana Universities Marine Consortium Chauvin, Louisiana H. Ray Brannon, Jr. (NAE) Exxon Production Research Houston, Texas Wi 11 i am Creelman National Marine Serv i c e St. Louis, Missouri Robert G. Dean (NAE) University of Florida Gainesville, Florida Charles D. Hollister Woods Hole Oceanographic Institution Woods Hole, Massachusetts Ralph D. Cooper, Director Donald W. Perkins, Asst. Director for Plann i ng and Admi n i s brat i on Charles A. 800kman, Asst. Director for Programs Richard W. Rwake, Senior Staff Officer Martin J. Finerty, Jr., Staff Off leer STAFF iv Peter Jaquith St. John Shipbuilding, Ltd. News Brunswick, Canada Kenneth S. Kamlet National Wildlife Federation Washington, D.~. Don E. Kash Un ivers i ty of Oklahoma Norman, Oklahoma Wi 11 lam If. Ni cholson U . S . Navy ( re t i red ) Annapol i s, Maryland Ernest L. Perry Port of Los Angeles San Pedro, Cal i forn i a Ri chard J . Seymour Scripps Inst i but ion of Oceanography La Jolla, California William H. Silc02 Chevron Corporation San Francisco, California Richard T. Soper Sea-Land Service, Inc . Iselin, New Jersey Robert J. Taylor Exxon International Florham Park, New Jersey Doris C. Holmes, Administrative Associate Linda Cannon, Senior Secretary Joyce Somerville, Senior Secretary Charlene Taylor, Secretary

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PREFACE In compliance with the 1958 Continental Shelf Convention, the current U.S. regulatory requirements governing fixed offshore struc- tures (also called platforms) on the outer continental shelf (OCS) stipulate their complete removal to a depth 5 meters below the sea- floor. The general practice is to remove all structural elements after petroleum production has ceased and return these to shore for salvage or scrap. In a few instances, offshore structures have been towed to deep water and dumped, or placed in specified locations to serve as artificial reefs to enhance living resources. The Department of the Interior (DOI) is considering changing these rules. The offshore industry is reaching a state of maturity such that the number of platforms to be removed in the Gulf of Mexico will increase dramatically. Moreover, it is predicted that the number of large deep-water platforms, which are expensive and difficult to remove, will increase. Some argue that complete removal of all OCS platforms may not be beneficial to local biological communities. There is increasing support among various constituencies, especially recreational f i shing interests, for using offshore platforms as artificial reefs at additional locations on the continental shelf. In the international arena, the Law of the Sea Convention, which may enter into force even without the ratification of the United States and several other industrial nations, provides for the International Maritime Organization (IMO) to develop new international guidance on such matters as the disposition of offshore structures. New inter- national rules will probably be written over the next few years. It is appropriate for the United States, having hundreds of offshore structures in relatively shallow water in the Gulf of Mexico, to develop the technical basis for its national position in advance of international negotiations. For all of these reasons, the DOI considered it timely and neces- sary to evaluate alternative dispositions for offshore oil and gas platforms after petroleum production has ceased. The DOI requested advice from the National Research Council. Accordingly in 1984 the Research Council appointed the Committee on Disposition of Offshore Platforms under its Marine Board to document and assess alternatives for removing, disposing, or reusing fixed offshore platforms that are past their useful service life, and to make recommendations concerning government policy on their disposition. v

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Members of the committee were selected with regard for the exper- tise necessary for the assessment and also knowledge of activities affected by alternative dispositions of offshore structures. Commit- tee members' backgrounds spanned the fields of offshore structures, marine transportation, marine environment, marine policy, naval opera- tions, and ocean law. Biographies of the committee members appear in Appendix A. The principle guiding the constitution of the committee and its work, consistent with the policy of the Nat i ona1 Research Counc i 1, was not to exclude the b i as that mi ght accompany expert i se vital to the study, but to seek balance and fair treatment. The platform types cons idered by the cocci t tee included steel- jacket, tension-leg, concrete, guyed-tower platforms, and subsea oil and gas structures. Excluded from the study were pipelines and gravel islands as well as the operations of abandoning wells and removing wellhead equipment. The area1 extent of the study is the OCS of the United States (lands under federal jurisdicti on ~ . This fact notwithstanding, much of the issues analysis is directly relevant to the disposition of platforms located on offshore lands under state jurisdiction. With these limitations, the committee considers its work to be applicable to the disposition of all existing offshore platforms on the OCS and all platforms to be installed on OCS lands within the next five years. Considering the average productive life of offshore structures, the time horizon of the study is 35 years. The committee proceeded by identifying options for the removal and disposal of offshore structures, as well as issues for assessment. To ensure that the committee addressed all the issues, the Mineral Management Service (MMS) of the DOT requested public comments on the disposition of offshore platforms (see Appendix B). Committee members then prepared a set of background papers' which assessed the issues that were identified. This provided the basis for considering policy alternatives and developing conclusions and recommendations. At the time of the study, there was considerable national interest in an expanded program for planning, financing, and constructing artificial reefs to enhance fishing opportunities. The National Fi sh ing Enhancement Act of 1984 mandates a net tonal plan for s i t ing and developing artificial reefs. The plan is being developed by the National Marine Fisheries Service, with technical assistance from the Sport Fishing Institute's Artificial Reef Development Center and others. Concurrently, wi th the leadership of the DOI, federal agencies were negotiating a memorandum of understanding to plan and direct a national program to encourage proper placement and use of artificial reefs. The committee considers its work to be a necessary and timely contribution to artificial reef planning--putting the potential use of petroleum platforms as reef-building materials into proper perspective. The committee acknowledges with gratitude the material and invalu- able assistance provided by Richard Krahl of the Minerals Management Service, the Office of Navigation, and the Eighth District of the U.S. Coast Guard, as well as Rex Alford of Conoco, Inc . who provided 1 i a i son wi th the Amer i c an Petroleum Ins t i Lute . V1

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CONTENTS - SU~ARY, CONCLUS IONS, AND RECOMMENDATIONS 1 2. DESCRIPTION OF THE PROBLEM! Number of Platforms Platform Life Removal Schedule Options for Disposing of Offshore Platforms Reference ENGINEERING AND COST OF PLATFORM REMOVAL Removal Procedures Technology Advances and Needs Reuse of Platforms Cost of Platform Removal Comparison of Cost of Return-to-Shore and Ocean Disposal Options Engineering and Cost of Removal of Other Platform Types References 4. LEGAL ISSUES Introduction The Options International Law Ocean Dumping Law in the Uni ted States Legal Limi tations on Platform Disposition References and B i bl i ography 5. ENVIRONMENTAL CONST0ERATIOIJS Effect of Offshore Platforms on Biological Resources Environmental Ramifications of Disposal Options Regional Considerations References 6. SAFETY Hazard to Surface Navigation Hazard to Submerged Nav i get i on Platforms as Aids to Navigation or Havens Hazard to Personnel in Dismantling Offshore Platforms References Hi 8 10 11 13 14 14 15 17 19 24 ~5 30 31 31 33 33 38 39 41 43 45 46 47 51 52 53 53 57 58 59 59

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7. NAVAL OPERATIONS Introduc t i on The DOD Draf t Standards Impl i c at i ons for Submerged Navi get i on Disposition Options Internat i onal Impl i c at i ons 8. ALTERNATIVE POLICIES FOR DISPOSING OF OFFSHORE PLATFORIlS Str i ct Removal Pol i cy A D i sc ret i onary Pol i cy APPENDIX A B i ograph i es of Commi t tee Me~nbers APPENDIX B Federal Regi ster Reguest for Conunents and Li st of Respondents APPENDIX C Positions of the Department of Defense and the Oil Tndus t r i e s In te mat i onal Explorat i on and Produc t i on Forum . . . v ~ ~ ~ 61 61 61 63 64 65 66 66 67 71 71 73 73 76 76

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r TABLES AND FIGURES TABLE 1 Water Depth of Structures Installed in the Gulf of Mexico, Off California, and Off Alaska as of 1983 TABLE 2 Number of Structures to be Removed and Estimated Removal Costs in the Gulf of Mexico TABLE 3 Number of Structures to be Removed Off Alaska and Estimated Removal Costs TABLE 4A Number of Structures to be Removed Off California and Estimated Costs by Time of Removal TABLE 4B Number of Structures to be Removed Off California and Estimated Removal Costs by Water Depth TABLE 5 Comparative Costs for Several Removal Options TABLE 6 Hazard of Offshore Platforms to Surface Navigation in the Gulf of Mexico FIGURE 1 FIGURE 2 FIGURE 3 FIGURE 4 FIGURE 5 FIGURE 6 FIGURE 7 Deep water platform. A 700-foot jacket being towed out of San Francisco, California for installation off southern California. Gulf of Mex i co of Ashore s true Lures. Structures removed and to be removed--Gulf of Mexico. Options for disposing of offshore platforms. Comparison of jacket weight versus water depth. Estimated number of structures to be removed by category--Gulf of Mexico. 9 22 23 23 24 25 S5 6 7 8 10 12 19 20 _ FIGURE 8 Total cost of removing Gulf of Mexico structures. 21 FIGURE 9 Guyed tower (water depth l, 100 feet ) . 26 FIGURE 10 Tens ion leg platform (water depth 485 feet) . 27 FIGURE 11 Concrete gravity-base platform--North Sea 29 (water depth 520 feet). FIGURE 12 Proximity of offshore platforms and merchant 54 vessel traffic. FIGURE 13 Collisions of ships with offshore structures, 56 Gulf of Mexico. 1X

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