Decommissioning of Pacific OCS Facilities

This NTL supersedes NTL No. 99-P05.   

On May 17, 2002, the Minerals Management Service (MMS) published a final rule on Decommissioning Activities in the Federal Register (67 FR 35398), that took effect on July 16, 2002.  The rule includes requirements for decommissioning platforms and pipelines, plugging wells, and clearing lease sites. This NTL describes some of the requirements and gives general guidelines regarding the permitting process for decommissioning platforms, pipelines and other related oil and gas facilities on the Pacific Outer Continental Shelf (OCS).  It provides advice and guidance to you (lessees/operators) on procedures for coordinating with MMS and other affected parties.  Plugging of wells (covered by 30 CFR 250.1710 through 1723) and site clearance (covered by 30 CFR 250.1740 through 1743) are not discussed in this NTL.

In addition, we remind you that, in accordance with 30 CFR 250.107(a), operators must protect health, safety, and property, and the environment by (1) performing all operations in a safe and workmanlike manner and (2) maintaining all equipment in a safe condition.  These requirements remain in effect during decommissioning operations, from the cessation of production through the actual removal activities.  During the time the platform is stacked, equipment must be maintained in a safe condition.  Questions regarding the platform equipment safety requirements should be directed to the District Supervisor.

Decommissioning Requirements

Certain OCS platforms may be approaching the end of their projected economic life, so you may be in the early stages of developing applications for decommissioning and removing such facilities.  In developing these applications you should refer to your Lease Agreements and the Code of Federal Regulations (30 CFR Part 250, Subpart Q) for specific requirements pertaining to Permanently Plugging Wells (250.1710 through 1717), Removing Platforms and Other Facilities (250.1725 through 1780), Site Clearance for Wells, Platforms, and Other Facilities (250.1740 through1743), and Pipeline Decommissioning (250.1750 through 1754).

You should also review lease stipulations and approval conditions for your Development and Production Plan and its modifications, including those placed on a former lessee/operator for

which the current lessee/operator is now responsible pursuant to MMS granting an assignment of that lease.

We will conduct a detailed technical and environmental review of proposed decommissioning projects to ensure that you conduct operations in a safe and environmentally sound manner. We will conduct this review in close consultation with Federal, State, and local agencies and other affected parties. The technical review will focus on engineering and safety considerations and compliance with applicable regulations and requirements. We will conduct the environmental review according to Federal Regulations (40 CFR 1501.4 and 1506.6) and Departmental procedures that implement the National Environmental Policy Act.  The MMS environmental review will also involve consultation (formal or informal) with the National Marine Fisheries Service and U.S. Fish and Wildlife Service pursuant to the requirements of the Endangered Species Act, Marine Mammal Protection Act, and the Sustainable Fisheries Act/Magnuson-Stevens Fishery Conservation and Management Act.

Early Notification and Coordination

We urge you to meet at the earliest practicable time with us to discuss your plans for decommissioning OCS oil and gas facilities. These meetings should take place during the early conceptual design stages of the project, before you submit the initial platform removal application, which is due to the MMS at least 2 years before production is projected to cease.

We also encourage you to schedule early coordination meetings with Federal, State, and local regulatory agencies and other affected parties to review preliminary information outlining the conceptual framework and general timetable for decommissioning facilities.  The goal of these meetings is to share information and promote open communication by all parties.  This approach will help identify permitting requirements and timetables, information needs, environmental concerns, and other issues that could have an important bearing on how you conduct decommissioning operations.  This approach will also provide an opportunity for regulatory agencies to develop a more coordinated and streamlined process for reviewing and approving projects.

Decommissioning Applications and Timing

According to 30 CFR 250.1704, the initial platform removal application is due to the MMS at least 2 years before production is projected to cease, and a final platform removal application is due not more than 2 years after the submittal of the initial platform removal application.  As is the case for other MMS requirements, applicants may propose alternate timing, which will be considered by the MMS on a case-by-case basis.  These applications and the pipeline decommissioning/removal application referenced below are to be submitted to the Chief, Office of Facilities, Safety and Enforcement. 

According to 30 CFR 250.1725(a) - (c), you must remove all platforms and other facilities within 1 year after the lease or pipeline right-of-way terminates, unless you receive approval from the MMS to maintain the structure to conduct other activities; you must submit a final removal application to the MMS for approval; and you must remove a platform or other facility according to the approved application.

The information to be included in the initial and final platform removal applications is specified at 30 CFR 250.1726 and 1727 and listed here in abbreviated form for easy reference:

Initial Platform Removal Application

a. Platform/facility removal procedures, including the types of vessels and equipment you will use;

b. Facilities (including pipelines) you plan to remove or leave in place;

c. Platform/facility transportation and disposal plans;

d. Plans to protect marine life and the environment during decommissioning operations, including a brief assessment of the environmental impacts of the decommissioning operations and procedures and mitigation measures that will be taken to minimize such impacts; and

e.  Projected decommissioning schedule and duration.

Final Platform Removal Application

a. Identification of the applicant…

b. Identification of the structure…

c. Description of the structure…

d. Description, including anchor pattern, of the vessel(s) you will use…

e. Identification of the purpose [of the removal]…

f. Description of the removal method…

g. Plans for transportation and disposal (including as an artificial reef) or salvage…

h. If available, the results of any recent biological surveys conducted in the vicinity of the structure and recent observations of turtles or marine mammals at the structure site.

i. Plans to protect archaeological and sensitive biological features during removal operations, including a brief assessment of the environmental impacts of the removal operations and procedures and mitigation measures you will take to minimize such impacts.

j. A statement whether or not you will use divers to survey the area after removal to determine any effects on marine life.

Pipeline Decommissioning/Removal Application

Pipeline decommissioning/removal requirements are at 30 CFR 250.1750 through 1754.  Decommissioning pipelines in place is covered by 30 CFR 250.1750 through 1751.  Removal of pipelines is covered by 30 CFR 250.1752.  The regulations specify that pipeline decommissioning or removal applications must be submitted to the MMS for approval before the proposed activity is performed, and identifies the information to be included.

Environmental Considerations and Information Sources

As specified above, environmental information is required to be included in the initial and final platform removal applications; such information is also required for pipeline removal applications.  Although decommissioning of oil and gas facilities may have long-term environmental benefits, the process of removing the facilities can potentially cause short-term adverse impacts to water quality, air quality, sensitive species (marine mammals) and habitats (hard bottoms), commercial and recreational fishing, and other resources. You should consider these impacts when formulating decommissioning applications and develop effective measures to minimize such impacts.  The environmental documents prepared for Development and Production Plans provide detailed information on environmental concerns and mitigation measures.  To date, Exxon’s Offshore Storage and Treatment Vessel (OS&T) was the only oil and gas facility decommissioned on the Pacific OCS.  The environmental document MMS prepared for the OS&T project provides a perspective on environmental concerns and mitigation measures that Exxon adopted or MMS and other regulatory agencies required.  The comprehensive mitigation program Chevron (now ChevronTexaco) developed for removing Platforms Hope, Heidi, Hilda, and Hazel from State Tidelands in the Santa Barbara Channel also provides a reference point for other lessees/operators considering similar projects on the OCS.   Information regarding the Chevron project can be obtained from the California State Lands Commission.

We look forward to working closely with you on decommissioning and removing OCS oil and gas facilities as the need arises.  Again, we encourage you to contact MMS at the earliest practicable time to discuss plans for decommissioning facilities.

Paperwork Reduction Act of 1995 Statement: The collection of information referred to in this notice provides clarification, description, or interpretation of requirements in 30 CFR 250, subparts B, J, and Q. The Office of Management and Budget (OMB) approved the information collection requirement in these regulations and assigned OMB control numbers 1010-0049, 1010-0050, and 1010-0142, respectively, for these subparts. This notice does not impose additional information collection requirements subject to the Paperwork Reduction of 1995.