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Site Clearance

Per MMS operating regulations [30 CFR 250.5(a), 250.112(i), 250.114, 250.143(a), (b), and (c)] and lease agreements (Section 22), all lessees must remove objects and obstructions upon termination of a lease. In 1989, shrimpers complained that sites of previous OCS wells and structures were not properly cleared and obstructions were left that damaged their trawls. In a "partnering" effort, the MMS formed a site clearance cOEMMittee, composed of representatives of the oil and gas industry, the International Association of Drilling Contractors, local shrimpers, the State of Louisiana, Jefferson Parish, and the MMS, to address inadequacies in site clearance procedures and verification techniques as reported by the shrimping industry. In February 1990, the MMS issued NTL 90-01 to clarify site clearance and site verification requirements for all leases. This NTL required the lessee to submit a procedural plan for site clearance verification. Further, the NTL set forth specific actions required of the lessees to ensure all objects related to their activities were removed following termination of their lease. The NTL addressed single wells, platforms, well caissons, and well protectors, citing specific radii for clearing obstructions. The NTL also established site clearance verification procedures that included trawling the cleared site over 100 percent of the established clearance radii by a licensed shrimper. Lessees were required to file reports on the results of their site clearance activities. Data collected from these site clearance reports resulted in issuance of NTL 90-03 in August 1990. NTL 90-03 superseded NTL 90-01 and further refined the site clearance and site verification procedures and requirements.