Decommissioning; a duty of care

Decommissioning is now firmly on the North Sea oil and gas industry’s agenda.

Some US$21.98 billion is forecast to be spent on decommissioning UK North Sea facilities in the next 10 years.* 

As the number of operational platforms decreases and the pace of decommissioning increases, the industry will gradually shift from producing oil and gas to instead producing significant wastes and reusable materials.

Between 2015-2024, it is estimated that the UK will generate more than 600,000-tonne of waste and material to be brought to shore for recycling and disposal. The majority of this material will be steelwork for recycling at the smelters, which equates to more than 78 Eiffel Towers being dismantled at the disposal yards.* 

As part of managing this mountain of reusable material and waste, operators will need to meet waste duty of care legislation, which ensures that all waste generated is handled correctly throughout the full process. Failure to comply with the waste duty of care is a criminal offense and could lead to prosecution and an unlimited fine on conviction.

In the UK, the Environmental Protection Act (1990) includes responsibilities for the waste producer which are implemented by the Waste (England and Wales) Regulations 2011, as well as the Waste (Scotland) Regulations 2012.

Many other countries also have similar regulations, so it is important that operators are aware of the waste and environmental legislation relevant to all regions of operation.

This in effect means that, as the level of waste being produced increases, similar management procedures and systems to those of oil and gas production must be put in place, such as information management systems and “live” materials inventories. These will help operators identify, control and manage the wastes and materials generated through decommissioning.

The challenge 

All producers of waste have a responsibility to take all reasonable measures to ensure that waste is managed correctly from initial production to disposal or recovery.

For offshore decommissioning, this means waste producers must:

• Accurately describe and classify the waste - All waste and materials anticipated from the decommissioning of offshore assets (topsides, jackets and subsea) must be identified, quantified, characterized and documented in an inventory, so that the waste details can be communicated with regulatory bodies, the project team and supply chain. This must also include a written description of the waste which is then agreed and signed for by the operator and the subsequent asset holder.
• Check authorization of the subsequent waste holder - When passing the waste onto the next handler, either by contract, sale or for credits, the operator must confirm that the recipient is suitably authorized to receive and manage the waste. This includes confirmation of the correct permits and licenses, as well as registrations.
• Ask the subsequent waste holder where the waste will be disposed - Ensure that they know where the waste is going to be taken, to ensure the final disposition can be overseen. On occasion, the waste is not taken to the correct final disposition site by the contractor, which can result in a breach of waste duty of care.
• Carry out detailed checks if non-compliance is suspected - If operators suspect that wastes are not being managed correctly, then it is their duty to carry out checks on contractors and supply chain to ascertain whether wastes are being handled correctly and efficiently.
• Prevent the uncontrolled escape of waste - Operators and their waste contractors must prevent the uncontrolled escape of waste. This means ensuring waste is handled and stored safely and securely throughout the decommissioning phases and cycles, including using suitable containers for the storage, transport and subsequent management activities by the operator and subsequent waste holders.

Case Study – Central North Sea Decommissioning Project

On completion of the waste and materials inventory for a central North Sea platform in 2016, the operator subscribed to D3 Consulting’s DAWN system, an information management system for preparing materials inventories and managing waste throughout the decommissioning process.

The waste and materials inventory included 3272 entries for individual items and structural elements, totaling more than 23,500-tonne for decommissioning. The largest waste and materials fractions are steelwork and concrete (about 20,425-tonne combined) with the other waste streams including nearly 500-tonne of potentially hazardous wastes and NORM. 

To enable the operator to ensure that all wastes and materials, especially the hazardous wastes, are effectively managed, the DAWN system gives the operator access to waste management protocols for each type of waste and material present on the platform which had been identified for decommissioning. 

Each of these protocols specifies the regulatory compliant handling and treatment activities for these materials. D3 maintains these waste management protocols to ensure that they are kept up to date with legislation and regulations, both in the UK and Norway.

The operator utilizes these protocols for the development of its Project Waste Management Plan and included the protocols in contracts throughout the supply chain.

Martin Bjerregaard is Director of D3 Consulting. Bjerregaard has more than 25 years’ experience in the planning, designing and implementation of industrial and offshore decommissioning and demolition works. Martin has supported operators with waste assurance works for onshore disposal of platforms, development of materials inventories for offshore platforms and budget development for offshore decommissioning of assets.

*Oil & Gas UK decommissioning Insight Report.