Government Appears to Prefer Complete Rig Removal

[covediver]

BSEE Issues Offshore Energy Infrastructure Decommissioning Analysis | Bureau of Safety and Environmental Enforcement

CAMARILLO, Calif. – To guide future oil and gas platform removal off the California coast, the Bureau of Safety and Environmental Enforcement (BSEE) has published the final Programmatic Environmental Impact Statement (PEIS) for Oil and Gas Decommissioning Activities on the Pacific Outer...

www.bsee.gov

BSEE has completed an Environmental ImpacT Statement on the fate "decommissioning" of offshore oil and gas platforms and related infrastructure off Southern California. In the document, it looks like the government's preference is the complete removal of all offshore oil and gas platforms. It seems as if a rigs-to-reef approach will not be favored, despite a preponderance of scientific evidence that shows these strctures function as intact "hotspots." A final decision on the approach will not be made until at least 30 days from now, but the "proposed action" is usually the option selected.

The environmental activists, led by Linda Krop at the Enviornmental Defense Center in Santa Barbara have long agitated for complete femoval and obliteration of any structure related to oil and gas. They believe that offshore oil and gas is the ultimate evil and that good cannot come from evil.

I had a chance to dive the Platform Hilda before it was removed in the 1990s. It was a fascinating structure loaded with marine life--all of which was carted off to the local landfill once the structure was removed for scrap.

 

[Gone for diving]

So no more sinking ships?
Anything oil and gas is bad......
People are stupid.

I would like to know what people want to drive on,
Tesla's still need oil and grease,
And lots of plastic.
Pretty much everything in your house is made from oil or has oil in it or had a byproduct.

 

[Wookie]

People are stupid.

'nuff said.

 

[broncobowsher]

After removal there will be a cry for the loss of habitat.
Not a problem, there will be artificial habitats built and installed. There will be the call to have them made from some recycled materials. After they are installed it will be found that the recycled materials (if not the whole design of the habitat) was a poor choice. Even if not a total flop, still a fraction of what leaving the rig in place would have done.

Just my prediction of the future.

 

[sea_ledford]

BSEE's point of view (and MMS before that) has always been complete removal is the best option, and is specifically stated in the lease agreements. In the Gulf of Mexico, that was removal down to 15' below the mud line. Donations to artificial reef programs was always the exemption to their preference, and a federal agency probably can't require or even recommend that a state take on liability for the structure.

All of the Artificial Reef Programs that have platform donations are run by the state. In Texas is was Texas Parks and Wildlife. Florida is weird in that it has multiple programs run by counties, but they don't have any platforms. I'm not sure California ever got an artificial reef program up and running, despite the fact that it was authorized to do so in 2010 through the California Marine Resources Legacy Act.

There is a National Artificial Reef Plan, that covers California as well, but that doesn't mean donations are a requirement. It will always come down to cost: if it costs the O&G company less money to remove than to reef, it will remove. If it costs less to reef than remove, they they reef. The challenge in CA is that in addition to all the very volatile market forces that make the call (price of scrap, fuel costs, removal operators availability, etc) there will be significant legal fees, particularly for the first attempt. When I was working for the TPWD reef program, we only captured about 15% of the platforms as donations, and we had a very well defined and widely supported process. If that holds true in CA, you are only looking at 3-4 reefed platforms.

 

[Cthippo]

How would that work? Are they going to cut them down to the waterline, or allow them to degrade and collapse? I would love a standing oil platform out in the water to explore, but people will manage to kill themselves on it.

 

[Wookie]

How would that work? Are they going to cut them down to the waterline, or allow them to degrade and collapse? I would love a standing oil platform out in the water to explore, but people will manage to kill themselves on it.

Cut them to 85 feet below mean low low, the top part goes ashore, as it has equipment not worth cleaning on it. The conductor pipes get plugged and abandoned 15 feet below the mud line.

 

[Ken Kurtis]

I've been involved somewhat off and on in this discussion/debate about what to do with the CA rigs for many years now, easily 25. I'm working on the assumption that there are two reasons to "save" the rigs in some form or another:
1. To preserve the thriving marine habitat that has developed on most of these rigs.
(Which was an unpredicted consequence/benefit of their being permitted.)
2. To preserve them as a diving attraction/destination.

That being said . . .

Cut them to 85 feet below mean low low . . .

That makes them into a Dive Death Trap IMHO. In CA, we might have vis on the rigs as little as 20-30 on some days (and some days we can get 100 feet of vis). But can you imagine live-dropping divers in those conditions onto a rig that's 85 feet below them? How many will miss the rig structure all together and keep going until it's too late? Or do you drop a crew member down to try to secure a morrting line for the boat??? Also risky. On top of that, by cutting down to that depth, at least out here, you destroyed some of the most productive and interesting parts of the reef.

I think a better idea is is to cut down the superstructure but leave the top 10-15 feet sticking above the waterline. This fully preserves everything underwater. It should also leave enough structure intact above the waterline so that it will show up on radar of vessels in the area. For those who complain that the rigs are an eyesore, you can paint the part that faces the shoreline some shade of blue/green to match the color of the water which will make the less visible, if you could even see them from shore once they're cut down as I suggest. And you can even paint the part that faces away from shore neon orange or something like that so it will further visually stick out.

I realize the USGC regs require 60 feet (I think) of clearance which is why if you cut them down at all, you have to go to at least that depth. But I think cutting them down raises a host of issues from a diving standpoint that leaving the rigs intact and still visible solves.

Additionally, there have been some studies, or at least conjecture, that to take them all the way down to the sediment on the bottom will stir up who-knows-what into the water column, stuff that is now somewhat contained inside the mud and sediment that's settled over the years.

So to my mind, the cut-them-down argument requires destruction of a thriving ecosystem, destruction of a viable dive site, and possible mass contamination of the water column. And because they don't look pretty????? There are better options with better outcomes for all stakeholders concerned.

 

[Wookie]

That makes them into a Dive Death Trap IMHO.

I do not disagree.

If not cut at 85’ below mean low low, the CG regards them as a hazard to navigation and they require lights and audible warning until they are below 85 feet. Who would maintain the light and horn?

I wasn’t making a proposal, I was stating the regulation.

Reefs aren’t for diving, they are for fishing. Remember, divers are lower than whale crap in the hierarchy of water recreations

 

[sea_ledford]

I've been involved somewhat off and on in this discussion/debate about what to do with the CA rigs for many years now, easily 25. I'm working on the assumption that there are two reasons to "save" the rigs in some form or another:
1. To preserve the thriving marine habitat that has developed on most of these rigs.
(Which was an unpredicted consequence/benefit of their being permitted.)
2. To preserve them as a diving attraction/destination.

That being said . . .

That makes them into a Dive Death Trap IMHO. In CA, we might have vis on the rigs as little as 20-30 on some days (and some days we can get 100 feet of vis). But can you imagine live-dropping divers in those conditions onto a rig that's 85 feet below them? How many will miss the rig structure all together and keep going until it's too late? Or do you drop a crew member down to try to secure a morrting line for the boat??? Also risky. On top of that, by cutting down to that depth, at least out here, you destroyed some of the most productive and interesting parts of the reef.

Cut to 85, does make them very difficult to dive. We had a divemaster drop down to tie in a marker buoy, then tie in the boat, then at the end of the dive they would go back down to untie. So 3 90-100 foot dives by the DM for each site.

I think a better idea is is to cut down the superstructure but leave the top 10-15 feet sticking above the waterline. This fully preserves everything underwater. It should also leave enough structure intact above the waterline so that it will show up on radar of vessels in the area. For those who complain that the rigs are an eyesore, you can paint the part that faces the shoreline some shade of blue/green to match the color of the water which will make the less visible, if you could even see them from shore once they're cut down as I suggest. And you can even paint the part that faces away from shore neon orange or something like that so it will further visually stick out.

You can't leave any of the structure above water unless someone commits the money to continue to maintain the rig. It's the air/water interface that causes the worst corrosion. A fully submerged rig will last a lot longer than one with parts sticking out.

I realize the USGC regs require 60 feet (I think) of clearance which is why if you cut them down at all, you have to go to at least that depth. But I think cutting them down raises a host of issues from a diving standpoint that leaving the rigs intact and still visible solves.

Texas has a few rigs that are removed to a shallower clearance, but they require buoys. We never had to do any audible alarms. Buoys alone are eye-wateringly expensive to maintain, especially if they are deeper than 100' (thanks OSHA). We were only able to get that permission in areas where the water wasn't very deep and the structures were a long way from any shipping fairways.

In addition to USCG regulations, the structure itself determines where you can cut it. Ideally the rig is cut just above one of the horizontal conductor support levels, and they are generally at 20', 60', 100', 150' and something deeper than 200' (going from memory here, not sure those are exactly correct). So cutting at 10-15' would be great from a habitat preservation and recreation use standpoint, but is an absolute disaster waiting to happen from a vessel safety standpoint. Next option is cutting just above the 60' level, which requires all the money for marking, but functionally isn't different from cutting above the 100' level from a diving procedures standpoint.

So to my mind, the cut-them-down argument requires destruction of a thriving ecosystem, destruction of a viable dive site, and possible mass contamination of the water column. And because they don't look pretty????? There are better options with better outcomes for all stakeholders concerned.

Agree completely. All it takes is money to solve the problem. Who's money is the question.