Regulations on decommissioning and plugging

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1 Regulations on decommissioning and plugging Subsea Operations Conference 2017 in Haugesund Reidar Hamre, Principal Engineer, Drilling & Well Technology P E T R O L E U M S A F E T Y A U T H O R I T Y N O R W A Y

2 Regulations on decommissioning and plugging Contents Overview of relevant acts and regulations relating to permanent plugging and abandonment of wells decommissioning of installations offshore Market opportunities in oil & gas reuse of installations and equipment demolition and recycling

3 Principal features of the regulations The regulations are based on functional performance; express what to achieve - not how to do it allow the industry the freedom to choose solutions fit for purpose underpin the allocation of responsibility which remains with the lisensee refer to norms and industry standards; - providing predictability for users and - indicating our expectations to the use of standards The regulations require the duty holders to set firm risk targets and to manage their operations accordingly

4 Regulations guidelines - standards Regulations are part of Norwegian legislation and legally binding Guidelines are not statutory requirements suggest solutions which will meet with expectations set forth in the regulations indicate HSE level to be met refer to recognised industry standards to the extent possible combination of parts of several standards are not recommended Standards are referred to at the highest possible level in a hierarchy: international standards (ISO/IEC, CEN/CENELEC, etc.) national standards industry standards (e.g. NORSOK) recommended classification standards (DNVGL, ABS, Lloyds etc.)

5 Overview of relevant acts and regulations PSA homepage look into rules and regulations Petroleum Act Pollution Act Regulations Petroleum regulation Framework Management Guidelines Standards

6 The Petroleum Act Chapter 5 concerning the cessation plan Ref. the Petroleum regulation chapter 6 concerning cessation of the petroleum activity

7 The Petroleum Act ch decommissioning plan (1) The licensee shall submit a decommissioning plan to the Ministry (MPE) before a license expires (ref. section 3-3 and 4-3) or is surrended, or terminated permanently

8 Act relating to protection againts pollution and waste Chapter 1 - section 4 Application of the Act to the activities on the continental shelf

9 OSPAR convention decision 98/3 OSPAR convention (Oslo-Paris) Intended to protect the environment in the north-east part of the Atlantic Ocean based on: Preparing in due time Companies responsible for pollution shall carry out necessary clean-up and restoring of the seabed Use of best available technology (BAT) shall also taking into account the environmental aspects Binding decisions are made by the OSPAR commission Participation of observers in the commision meetings

10 The Framework Regulation (Last amended 24th May 2013) 30 concerning the cessation plan + guidelines 25 concerning use of guidelines and recognised standards

11 The Management regulation 25 concerning consents requirements for certain activities, part d) prior to disposal 26 concerning contents of applications for consent application to contain necessary information to cover the entire actvity

12 Management regulation - section 25 The operator shall submit an application for consent to PSA prior to start of activities (min 9 weeks)

13 Permanent plugging and abandonment of wells (PPA) Facitilies regulation section 48 on well barriers Well barriers shall be designed such that well integrity is ensured and barrier functions are safeguarded during the well s lifetime e.g. the longest time the well is expected to be abandoned This also includes the PPA-phase Refence is made to NORSOK D-010 rev. 4, ch. 4, 5, 9 and 15.

14 Permanent plugging and abandonment of wells (PPA) Activities regulation section 88 on securing wells Temporarily abandoned wells require means to check its integrity All wells shall be secured prior to being abandoned Active monitoring of PPA wells is not necessary Reference made to NORSOK standard D-010 rev 4., ch. 9 and table 15.24

15 Challenges in PPA risk of reduced robustness and quality in PPA of older wells defining adequate PPA for eternity is difficult unidentified flow potential zones in overburden verification of barriers is sometimes inadequate due lack of proper tools and methods timeconsuming and expensive need to include the PPA-phase in designing for future wells regular updating of standards requires global industry cooperation and collaboration

16 Reuse of offshore installations Offshore structures, e.g. jackets may be candidates for re-use, Topsides can be reused, partly (modules, equipment) or completely Jack-ups, floating installations (FPSO) and semi-submersible installations can be relocated Subsea installations may also be re-used to some extent Reuse of existing installations will in most cases need recertification to document fitness for purpose

17 REUSE of offshore installations and equipment If the re-use option is not applicable after cessation Demolition, cleaning and sorting for extensive re-cycling of all steel and other residual materials will prevail

18 P E T R O L E U M S A F E T Y A U T H O R I T Y N O R W A Y