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INTRODUCTION The magnitude of a verification program for offshore oil and gas structures can be estimated on the basis of the number of existing platforms. Since 1947, more than 3,000 offshore oil and gas production platforms have been erected on the outer continental shelf (OCS) around the U.S., mostly in the Gulf of Mexico. Approximately 50 more structures are now being built for installation in U.S. waters.1 The history of offshore platform structural integrity is described in papers by G. C. Lee and Bernhard Stahl, and in presentations to the panel by Lyle S. St. Amant and the Offshore Operators' Committee.2'3 The record shows that as offshore experience in structure design has in- creased, damages to structures have decreased, even though work has extended to greater depths in the oceans. Stahl states that this is largely a result of continual improve- ments in industrial design and construction and work practices. About 850 major platforms and 2,200 lesser structures were installed in the Gulf of Mexico between 1947 and 1975. Of these, major hurricanes completely destroyed only 26. Eleven others were damaged, but could be salvaged and repaired. Few of the destroyed structures embodied modern design practices. There is no record that any lives were lost as a result of structure failures from the storms. Furthermore, no major oil spills in the Gulf have been attributed to structural failure. The outlook is for increasing the pace of development for offshore oil and gas to meet the demand for these fuels that cannot be met by onshore development in the United States. It is estimated that from 20 to 35 platforms will be installed each year during the next five or six years, about half of these to be erected in the waters off Alaska or in the Arctic. Such structures must be built to withstand storm and seismic conditions that do not exist in the Gulf of Mexico, where much of the offshore technology experience has been gained. Furthermore, many of them will be operated by 200 to 400 people who may find themselves cut off from rescue during severe storms at sea. Moreover, newly organized and possibly less experienced firms may be involved in such offshore exploration and production, thereby increas- ing the possibility of structural failures and accidents.

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Concurrent with the expansion of offshore technology into harsher environments is a growing tendency of the public and the Congress to question the adequacy of safety provisions and environmental precautions in offshore re- covery operations. Although unrelated to structural failures of fixed platforms, the loss of life and other acci- dents in North Sea oil and gas operations have called public attention to the hazards posed by hostile environ- ments for man and structures. While the public recognizes that offshore production can augment the dwindling supplies of oil and gas required to heat their homes, fuel their cars, and operate their farms and industries, at the same time, it is increasingly sensitive to activities that affect human safety and damage the environment. Leonard C. Meeker, in a working paper prepared for the panel, has noted several consequences of public interest in environmental safeguards. Thus, public reaction to the oil spill in the Santa Barbara channel off California in 1969 led the Department of Interior to halt further OCS oil and gas development in the area for several years. Even though the oil leakage resulted from the nature of the subbottom geology and leakage around the well casing, rather than structural deficiency of the platform, the event was a rallying point for many environmental groups who were seek- ing Congressional support for their concerns. Public pressure brought about the National Environmen- tal Policy Act (NEPA) of 1969, which has led to legal actions taken by environmental groups. As a result of public concern for environmental protection in the OCS, the federal government, in April 1973, deferred drilling on the Atlantic OCS and' in the Gulf of Alaska until a study of the environmental impacts of oil and gas production in these areas could be carried out. The study was conducted during the following year by the President's Council on Environ- mental Quality (CEQ) in consultation with the Environmental Protection Agency and other federal agencies, the National Academy of Sciences, and the governors, legislators, and citizens of the coastal states involved. In a report, issued in April 1974, the CEQ stated: Development of OCS oil and gas...poses major challenges to Federal management and regulatory agencies, to the states affected by the offshore activities, and to the oil industry. Risk of damage to the human and natural environment is an insepar- able part of almost any development, including the

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OCS. The guiding principles must be to keep risks at an acceptable level and to balance risks with benefits. When a risk — based on the current state of knowledge and technology — appears to outweigh that of an available alternative for meeting the same objectives, we should not move ahead until we know more and can do better. When the risk is accept- able, we should proceed with caution and with a commitment to prevent or minimize damage. This means that the oil industry must have adequate technology and must use it safely, that Federal agencies must exercise their management and regulatory responsibilities to ensure that the oil industry meet its obligations, and the Federal, state, and local agencies must coordinate their efforts to mini- mize disruption of coastal communities and en- vironments by those facilities and other develop- ment required to support offshore operations .** During the year in which the CEQ study was conducted, other events abroad bore directly on the question of OCS oil and gas development in the frontier areas. In October 1973, war broke out in the Mideast, and as a consequence, the Arab states imposed embargoes of oil to several nations, including the United States. When the embargo ended in April 1974, the Organization of Petroleum Export- ing Countries (OPEC) had established prices which were substantially higher. In the meantime, the Administration had announced Project Independence with the stated purpose of making the United States independent of foreign oil and gas imports by 1980. To reach self-sufficiency, the pace of exploration and production of OCS oil and gas resources would have to increase. But when foreign imports of even larger quantities of oil resumed, concern was again expressed by the public, members of Congress, and state governments that the federal government and the industry were rushing into OCS develop- ment without the necessary environmental studies and en- vironmental safeguards. There were doubts that the USGS could effectively supervise and regulate OCS development because of its dependence upon the expertise, evaluation, and judgment of companies with a direct interest in develop- ing OCS oil and gas resources. Furthermore, there were questions that the existing regulations developed for appli-

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cation in the Gulf of Mexico would be appropriate in the Atlantic, off Alaska, and in other deep water regions.