Streamlining the regulatory journey for offshore oil and gas decommissioning

Preparation for Decom and Late Life Operations

Decommissioning and dismantlement are the final stages of an asset's natural lifecycle, which brings with it a number of challenges for both operator and regulator.

The following links provide information and guidance for operators at the early stages of preparing for decommissioning. They provide an overview of the various options available to help deliver regulatory obligations. 

Please contact the individual regulators for full information on the specific requirements for individual projects.

NSTA

NSTA's role at this early planning and preparation stage is to ensure plans for decommissioning are being made in accordance with its Decommissioning  Strategy - that is, achieving safe, timely and environmentally sound decommissioning whilst meeting NSTA's aims of achieving cost certainty and reduction, supply chain capability and capacity, prioritising cost reduction, supporting the supply chain and working with stakeholders to optimise parameters for decommissioning scope and industry engagement  

 

Decommissioning Strategy  The NSTA's Decommissioning Strategy outlines the cost reductions, efficiency savings and transformative options which will support the delivery of MER UK

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Stewardship Expectations This guidance outlines the OGA's expectations of the plans and strategies an operator should have in place to ensure they minimise decommissioning costs in line with MER targets.

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Supply Chain Action Plan guidance. This guidance helps operators produce SCAPs demonstrating how best value is being achieved through contracting and collaborative behaviours in field development or decommissioning.

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Decommissioning Technology. The UKCS is one of the most technologically advanced hydrocarbon provinces in the world.  The OGA's Technology Strategy supports adoption and development of new technologies to meet the objectives of MER and plan for cost effective decommissioning, and position the UK as a global leader in oil and gas technology.

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Decommissioning Roadmap  This tool has been created by NSTA to display the regulatory stakeholder engagement requirements for an asset operator through a decommissioning project lifecycle.  The building blocks can be used to create a project-specific plan which takes account of regulatory interactions. 

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NSTA Energy Pathfinder provides a real-time view of energy projects, including decommissioning, in the UKCS.  The Pathfinder provides an opportunity for supply chain to view upcoming tenders and offer solutions to aid project delivery, and to identify opportunities for pooling resources and campaigning.

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HSE

HSE as part of OSDR, regulates health and safety in both offshore and onshore decommissioning and dismantling activities. Health and safety and major accident hazard aspects of late life operations and early enabling works for decommissioning and dismantlement will be managed through the current installation operational safety case and continued pro-active inspection. 

 

HSE Offshore Health and Safety Law A summary of the main legislation which HSE use to regulate the offshore oil and gas industry

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Safety Case Competent Authority Portal (CAP) A link to the CAP homepage for submitting documentation relating to Safety Cases, Material Changes and reviews

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Safety Case Guidance A guide which explains the regulatory requirements of SCR 2015 to duty holders, including licensees, installation operators and well operators

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OSDR Intervention Plans and Inspection Guidance Information on the intervention planning framework and OSDR's offshore inspection process

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OPRED

Planning for decommissioning should begin during the late life stage of operations and engagement with OPRED should be initiated in advance of cessation of production.  Most oil and gas operators will start dialogue with the regulator two to five years in advance of cessation of production, depending on the complexity of the project.

 

Decommissioning Programme Templates – non derogation  This template can be used for all projects which do not involve infrastructure being considered for derogation from OSPAR Decision 98/3. The template includes all required content as detailed in Annex C of the Guidance Notes 

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Decommissioning Programme Template – derogation  This template should be used for projects involving installations which are being considered for derogation from OSPAR Decision 98/3. the template includes all required content as detailed in Annex c of the Guidance Notes 

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Guidance Notes to Industry on the Decommissioning of Offshore Oil and Gas Installations and Pipelines  This document provides operators, licencees and contractors with guidance on the regulatory requirements for decommissioning offshore oil and gas installations and pipelines in accordance with international obligations and those set out in the Petroleum Act, including detail on the founding principles of decommissioning; contents of a decommissioning programme; and clarification of policy requirements.   

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SEPA

As plans start to be made for disposal of the asset, operators need to consider how they will manage waste arising in line with Circular Economy principles and in compliance with regulatory requirements of UK onshore waste management regulations or Transfrontier Shipment regulations The change from oil and gas production to decommissioning activities may also require changes to RSA93 permits, for example the type and disposal route of waste or location of an FPSO. 

 

Guidance on Regulation of Offshore Oil and Gas Waste  This guidance outlines the main types of waste arising from offshore oil and gas activities during routine and decommissioning activities.  It summarises the key risks to consider and the current environmental regulatory framework for such waste.

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Regulatory Position Statement on Offshore Regulation of Radioactive Substances  This document summarises how radioactive substances will be regulated offshore until the Environmental Authorisation (Scotland) Regulations 2018 apply to the UK Continental Shelf, specifically the thresholds for high-activity sealed sources and NORM clearance and exemption values.

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Duty of Care - A Code of Practice  This guidance explains the duties which apply to anyone who produces, keeps, imports, manages or controls waste in Scotland, to maximise recovery of useful materials and ensure the environment is protected.

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Scope of Radioactive Substances Regulation Offshore Radioactive Substances regulation offshore is restricted to certain activities and 'installations'. This paper highlights which activities will and won't be in scope of radioactive substances regulation in the Scottish Area including how this may change as an asset or field is decommissioned. 

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