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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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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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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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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.
Representative terms from entire chapter:
national position
