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NEBA related to Offshore Decommissioning

EPS Staff (Joseph Nicolette) co-authored the first formalized framework for NEBA recognized by the USEPA, USEPA Science Advisory Board, NOAA, and the Australian Maritime Safety Authority (AMSA). EPS staff have used NEBA to assist clients in quantifying and comparing the effects that alternative actions will have on the environment. For clients, the benefits of understanding these effects has helped to reduce and manage costs, manage site risks, and maximize benefits to the environment and the public.

EPS staff (Joseph Nicolette) has focused on NEBA applications for about 25 years including recent applications of NEBA to the Comparative Assessment process for developing decommissioning options for offshore oil and gas platforms and subsea structure (e.g., jackets, subsea kits, pipelines, and sea bed deposits – cuttings piles). Mr. Nicolette has led offshore NEBA decommissioning training workshops and presentations for multiple clients in the U.S., SE Asia and Europe (e.g., North Sea). He has made demonstrated contributions to the development of NEBA and NRDA approaches in the U.S. and Internationally over the past 24 years. This includes the conduct of international presentations and workshops (Brazil, Canada, Germany, Great Britain, Italy, Malaysia, Norway, Scotland, South Africa, Sweden, Thailand, United States, etc.)  related to comparative assessment (e.g., NEBA), risk management, offshore decommissioning, resource equivalency, oil spill response and planning, site remediation and damage assessment.

Recent specific projects include the development of quantitative NEBA applications for comparative assessments of offshore decommissioning options for subsea structure for well fields in the Gulf of Mexico, Australia, and the North Sea. These have included a multi-Platform field, a Floating Production and Storage Offloading (FPSO) facility, and an analysis of specific subsea components as part of an ongoing decommissioning process. Additionally, these applications have also incorporated risk analysis of residual chemicals, where warranted, that may be associated with various management options such as removal, partial, removal, or leave in-situ, alternatives.  EPS staff has worked closely with the operators to develop and scope the NEBA comparative assessments to support agency and stakeholder discussions. The overall goal of NEBA in these cases was to support decision-making regarding what should be removed versus what should be left in place. Comparative assessment using NEBA as applied in these case studies focused on evaluating the environmental benefits and costs of the subsea structures so as to balance the risks, benefits, and tradeoffs between various removal, partial removal, and leave in-situ alternatives.

As part of the NEBA-based comparative assessments for offshore decommissioning, EPS staff experience includes the development of the overarching NEBA framework for specific sites (as all sites are not the same), remote operated vehicle (ROV) survey analysis and associated species analysis, biological index development, water/chemical diffusion modeling, ecological and human health risk assessment, health and safety implementation risk assessment, greenhouse gas emission estimation, sediment and water column chemical composition analysis and evaluation, ecosystem service modeling, etc. Our staff experience has included both domestic waters (e.g., Gulf of Mexico, Pacific Ocean) and various international locations (North Sea, Indian Ocean-Australia, Gulf of Thailand, etc.).

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