Regulations ondecommissioningand pluggingSubsea Operations Conference 2017 in Haugesund

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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

PTIL/PSA

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

PTIL/PSA

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

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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.)

PTIL/PSA

Overview of relevant acts and regulationsPSA homepage www.psa.no look into rules and regulations

Petroleum Act

Pollution Act

Regulations

Petroleum regulation

Framework

Management

Guidelines

Standards

The Petroleum Act

Chapter 5 concerning the cessation plan

Ref. the Petroleum regulation chapter 6

concerning cessation of the petroleum activity

The Petroleum Act ch. 5.1- 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

Act relating to protectionagaints pollution and waste

Chapter 1 - section 4

Application of the Act to the

activities on the continental shelf

OSPAR convention – decision 98/3

OSPAR convention (Oslo-Paris)

Intended to protect the environment in thenorth-east part of the Atlantic Ocean based on:

• Preparing in due time

• Companies responsible for pollution shall carry outnecessary clean-up and restoring of the seabed

• Use of best available technology (BAT) shall alsotaking into account the environmental aspects

• Binding decisions are made by the OSPAR commission

• Participation of observers in the commision meetings

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The Framework Regulation(Last amended 24th May 2013)

§ 30 concerning the cessation plan + guidelines

§ 25 concerning use of guidelines and recognised standards

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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

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Management regulation - section 25

The operator shall submit an application for consent

to PSA prior to start of activities (min 9 weeks)

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Permanent plugging and

abandonment of wells (PPA)

Facitilies regulation section 48 on well barriers

• Well barriers shall be designed such that well integrityis 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.

PTIL/PSA

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

• 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

Challenges in PPA

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 needrecertification to document fitness for purpose

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REUSE of offshore

installations and equipment

If the re-use option is not applicable aftercessation…

Demolition, cleaning and sorting for extensive

re-cycling of all steel and other residual materials

will prevail

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