Federal Regulator Prefers Removal of Southern California Offshore Platforms
The Bureau of Safety and Environmental Enforcement (BSEE) decided in December that “complete removal and disposal” is the best way to decommission California’s offshore oil and gas infrastructure. The “Preferred Alternative” would apply to the decommissioning of active and terminated leases in Federal waters of the Pacific Outer Continental Shelf (OCS) region.
The BSEE, an agency of the Department of the Interior’s that oversees safety and environmental protection in the offshore energy industry on the United States Outer Continental Shelf (OCS), announced the decision in its Record of Decision for the Final Programmatic Environmental Impact Statement (PEIS) for Oil and Gas Decommissioning Activities on the Pacific Outer Continental Shelf. The Final PEIS also considered alternatives addressing partial removal of infrastructure, different severance techniques, and the potential for placement of portions of the jacket for development of an artificial reef.
Pacific OCS Region
There are 43 originally active leases on the Pacific OCS that have been in production for 26 to 48 years. There are 23 oil and gas production facilities in the region, from Santa Barbara to Orange County. Twenty-two of these facilities produce oil and gas, and one is a processing facility. The first platform was installed in 1967 and the last two were installed in 1989. All platforms will eventually be subject to decommissioning.
The Preferred Alternative includes the complete removal of platforms, topside, conductors, the platform jackets to at least 4.6 m (15 ft) below the mud line, and the complete removal of pipelines, power cables, and other subsea infrastructure (i.e., wells, obstructions, and facilities), with site clearance from the POCS.
In the long term, the Preferred Alternative would ensure that no O&G infrastructure would remain on the POCS seafloor that could interfere with navigation, commercial fisheries, future O&G operations, and other current or future POCS users.
The “sub-alternative” that is part of the preferred alternative provides the most proven reliable severance means for decommissioning activities. Not all decommissioning activities under the Preferred Alternative would require explosive severance; however, the use of explosive methods may need to be implemented if non-explosive severance methods cannot successfully be utilized for piling and conductor removals.
In making its decision, the BSEE considered the impact from the removal of structures that have become manmade reefs. Some alternatives to complete removal would leave some infrastructure in place to maintain these habitats. The BSEE, however, stated that leaving some infrastructure could pose environmental risks from interference with fishing equipment or ship anchors.
Other alternatives included only partial jacket removal, to at least 26m (85 ft) below the waterline, rather than complete removal of platform topsides, jackets, pipelines, and other subsea infrastructure (wells, obstructions, and facilities).
One alternative considered in-place decommissioning of the jacket with only the top sides of the platform transported to shore for disposal. A third alternative included a Rigs-to-Reefs (RTR) option for the disposal of the jacket with the top side structures removed for on-shore disposal.
Under a fourth alternative, the BSEE would take no action on decommissioning applications in the POCS region. Other ongoing regulatory and statutory requirements for managing platforms, pipelines, wells, power cables, and subsea infrastructure following lease termination would continue to apply, notably those for maintaining safety and protecting the environment, such as plugging and abandonment activities, including emptying platform tanks, equipment, and piping of all liquids, and emptying and flushing pipelines in anticipation of decommissioning.
The removal of offshore platforms from the Pacific OCS would first require decommissioning, which includes plugging and abandoning the wells and assessing the environmental impact of the infrastructure removal through a National Environmental Policy Act (NEPA) analysis. There are currently eight offshore production platforms in various stages of decommissioning (see below).
Pacific Region Federal OCS Decommissioning
Platform Harvest, Hidalgo and Hermosa: All 46 wells have been abandoned and tested. All 62 conductors have been removed. This stage of activity has been completed.
Platform Grace: Twenty-eight (28) wells have been abandoned and 38 conductors have been removed, ten of which did not contain wells. This stage of activity has been completed.
Platform Gail: Twenty-eight (28) wells have been abandoned and 28 conductors have been removed. This stage of activity has been completed.
Platform Habitat: Well abandonment activities for the 20 shut-in wells are planned to begin by 2024, following preliminary facility and rig modifications and well diagnostics.
Platforms Hogan and Houchin: These platforms are currently being manned, monitored and maintained as part of an agreement between BSEE, BOEM, DOI Solicitors Office, and the three predecessor lessees as they await a decision on the predecessors’ appeal to the IBLA. BSEE estimates an approximately $5 million deficit in financial assurance to decommission 21 orphaned sidetrack wells associated with these platforms.