Saturday, May 23, 2015

Taylor Energy Oil Discharge at MC-20 Site and Ongoing Response Efforts



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The Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) and the Bureau of Ocean Energy Management (BOEM) have worked with the U.S. Coast Guard under a Unified Command to monitor and respond to discharges from Taylor Energy’s Mississippi Canyon 20 (MC-20) site since the oil production platform and 25 of 28 connected wells were impacted and damaged during Hurricane Ivan in 2004. 

The multi-agency effort has worked continuously to prevent and control the oil discharge, improve the effectiveness of containment around the source of the oil discharge, and mitigate environmental impacts.

BSEE and the Coast Guard have also worked closely with representatives of Taylor Energy to mitigate the impacts of the discharge associated with the felled platform. Collaborative efforts have resulted in removal of the platform deck, removal of subsea debris, decommissioning of the oil pipeline, and efforts to plug nine of the 25 impacted wells. Despite these efforts, there is an ongoing oil discharge from Taylor Energy’s MC-20 site.

Based on data collected from nearly daily overflights since September 2014, oil sheens have been observed and reported by Taylor Energy to be as large as 1.5 miles wide and 14 miles long, with an average of 1 mile wide and 5.5 miles long, covering an average area of 8 square miles. 

Over this period, the daily volume of oil discharging from the MC-20 site has fluctuated between a low of less than one barrel of oil (1 barrel = 42 gallons) to a high of 55 barrels (2,329 gallons). The average reported daily oil volume on the sea surface over the past seven months has been over 2 barrels (84 gallons); the volume on over 75 days was greater than 1 barrel, including 23 days of volume greater than 3.8 barrels (160 gallons) and 4 days greater than 35 barrels (1,470 gallons). 

These spill size and volume estimates are based on reports submitted by Taylor Energy’s contractors to the National Response Center (NRC). All NRC reports can be viewed at www.nrc.uscg.mil.

BSEE’s current estimate is that the oil discharge from the site, if left unchecked, could continue for 100 years or more.

The specific source(s) of discharge at the MC-20 site are not fully known. However, because the discharge volume is greater than can reasonably be accounted for by oil released from sediment only, oil is most likely emanating from one or more of the 25 wells.

Taylor had originally been ordered by the Minerals Management Service (MMS) in October 2007 to permanently plug and abandon all the wells by June 2008. In November 2007, MMS issued Taylor an order to provide supplemental bonding to guarantee performance of Taylor’s decommissioning obligations at the site. In December 2007, MMS ordered Taylor to prevent any 2 further hydrocarbon seepage from the MC-20 site. 

In February 2008, MMS sent Taylor a Notice of Incident of Noncompliance for failure to provide the required supplemental bonding.

The Department of the Interior and Taylor Energy entered into a Trust Agreement in 2008 wherein Taylor Energy committed funds to fulfill obligations under the Outer Continental Shelf Lands Act (OCSLA) regarding the MC-20 site. 

By entering into the Agreement, Taylor Energy fulfilled its supplemental bonding obligations and resolved the pending administrative citation with respect to those obligations. Decommissioning of the wells at the site, required under the regulations and the 2008 Trust Agreement, has not yet been completed. 

For example, not all of the wells have been permanently plugged and abandoned. Future work to be performed under the Trust Agreement will be determined based on site conditions and the availability of applicable technology.

In addition to its obligations under OCSLA, pursuant to the Oil Pollution Act (OPA) and BOEM regulations, Taylor Energy is required to provide evidence of financial responsibility (e.g., bond, insurance) demonstrating that it can fulfill its OPA obligations (e.g. removal, compensation for damages) for oil spills from the MC-20 site.

Significant uncertainty exists about future events, including discharge sources, cross-flows, pressure recharge in the oil reservoirs, evolving technology, and suitable remedial measures.

There is still more that can be done by Taylor to control and contain the oil that is discharging from the MC-20 site. BSEE and BOEM are committed to working with the Unified Command to contain and stop the ongoing oil spill.