Oil Platform Decomissioning

The Ocean Dumping Act of 1972 prohibits the disposal of various materials into the ocean and mandates permits for certain other types of waste. Improper disposal of waste from decommissioning sites, dumping outside authorized areas, or spills during loading, unloading, or transportation can lead to cleanup costs, environmental tort liability, and legal consequences for violating regulatory requirements.

Equipment can strike an underwater pipeline or other unknown hazards, causing a release of pollutants such as natural gas, fuels, or sewage. These hazardous materials can contaminate the marine environment, leading to habitat destruction and resulting in cleanup costs.

Decommissioning activities can resuspend sediments, increasing turbidity and degrading water quality, negatively impacting aquatic wildlife and vegetation. These sediments may contain pre-existing contamination from historical operations, such as heavy metals, polychlorinated biphenyls (PCBs), and petroleum residues. Disturbing these harmful substances can spread them to clean areas of the sea floor, causing environmental harm and damage to natural resources.

Oil platform decommissioning contractors may generate hazardous or regulated waste that requires special disposal procedures. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements. A decommissioning contractor can become a Potentially Responsible Party (PRP) and be liable for cleanup costs in the environmental cleanup of a non-owned disposal (NOD) facility where they sent wastes.

Portable tanks and vessels, such as transport barges, suction dredgers, and semi-submersible crane vessels, may be present during decommissioning activities. A release of fuel or hydraulic oil can occur due to malfunctions or improper use, potentially discharging pollutants into the environment and requiring cleanup.

Chemicals used during oil drilling and production, such as corrosion inhibitors, biocides, surfactants, and scale inhibitors, may remain in equipment or pipelines. Leaks or spills of these residual chemicals may enter surrounding waters, potentially harm aquatic ecosystems, and require monitoring and cleanup.

Improper plugging or decommissioning of a well can result in the release of oil directly into the water and contaminating it. Oil spills can cause immediate toxicological harm to wildlife and long-term environmental degradation.

Older platforms may contain asbestos-containing material (ACM) in insulation, fireproofing, and gaskets. Lead-based coatings were historically used for corrosion protection and durability. PCBs may be present in legacy electrical equipment and hydraulic fluids used at production sites. ACM, lead, and PCB waste may be classified as hazardous waste and must be properly handled, labeled, transported, and disposed of at an approved facility. The decommissioning contractor can be considered a waste generator and retain cradle-to-grave liability.

Explosives may be used to sever bottom-founded components, such as foundation piles, well conductors, and caissons. This can produce high-intensity underwater shock waves and acoustic energy that can injure or kill nearby marine organisms, while also disturbing seabed sediments, increasing turbidity, and potentially resuspending accumulated contaminants around the platform site. The explosive residue can contain hazardous materials, such as nitrate and fuel oil, which can harm natural resources.

Cutting operations can generate fumes and vapors containing metals, carbon dioxide, polycyclic aromatic hydrocarbons, and other chemical components that can adversely affect health and lead to bodily injury claims.

Decommissioning contractors can provide pre-decommissioning services and input on structural removal and well abandonment. Contractors may also make modifications to demolition and removal of infrastructure design specifications while at the jobsite. Malfunctions arising from these inputs/changes create a direct professional responsibility for the contractor.

Chemicals brought to the decommissioning site to purge pipelines, remove marine growth, and permanently seal wells must be properly handled. Storage container breaches, leaks, and spills may occur during storage, transportation, or loading and unloading. This could lead to cleanup liability or run-off that can cause groundwater or surface water contamination.

Uranium and thorium naturally occur in petroleum reservoirs. During extraction, their decay products (particularly radium isotopes) are brought to the surface in produced water, where they accumulate as radioactive scale and sludge on production infrastructure over time. Improper identification and disposal can lead to the accidental release of this Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) into the marine environment or on-shore scrap and recycling facilities. TENORM: Naturally occurring radioactive materials that have been concentrated or exposed to the accessible environment as a result of human activities