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Environmental
Monitoring Site Clearance
Per BOEMRE 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 BOEMRE formed a site
clearance committee, 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 BOEMRE, to address inadequacies in site clearance
procedures and verification techniques as reported by the shrimping industry. In February 1990, the
BOEMRE 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 NTL 90-03 superseded NTL 90-01 and further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.
Based on approximately two years of data gained from the
two NTL's, the site clearance committee recommended additional
modifications to the NTL. Issued in May 1992, the current NTL (NTL 92-02)
incorporates the committee's recommendations and will serve as the model
to formulate changes to BOEMRE regulations.
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