Streamlining the regulatory journey for offshore oil and gas decommissioning

Cleaning and Making Safe

Once an installation has ceased production it will need to be cleaned and made safe and engineered down before main dismantlement activities commence. As the work progresses and the safety profile of the installation changes, and certain safety or environmental critical components are changed or retired, material changes to the Safety Case, or amendments to environmental discharge permits may be required. 

HSE

OSDR  assessment of a material change to a safety case will follow the same framework and process as a full Safety Case assessment. Guidance on when a material change may need to be made is contained in The Offshore Installations (Offshore Safety Directive)(Safety Cases) Regulations 2015 Approved Guidance on Regulations booklet

 

Safety Case Competent Authority Portal (CAP) A link to the CAP portal 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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OPRED

Cleaning or emptying of tanks, pipes and other components prior to dismantling may result in a change in the quantity and chemical composition of discharges. Changes from operation to decommissioning may heighten risk of incidents if not managed correctly.    

 

Offshore Oil and Gas Environmental Legislation  environmental regulations and guidance on licensing for offshore decommissioning activities and assessing the environmental impact of decommissioning

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SEPA

As items or materials are deemed redundant on a decommissioning asset, operators need to consider the regulations which apply to their future management, whether refurbishment and reuse, repurposing or disposal as waste.  Radioactive material, in the form of NORM-contaminated items may be flushed or cleaned offshore, or returned onshore for treatment and disposal; this should be in line with conditions in the asset's existing permit under Radioactive Substances Act 1993 .

 

'Is It Waste?' Guidance on Understanding the Definition of Waste  This guidance helps identify when a substance or object becomes waste, and when something that has been designated as waste may cease being waste.  It helps the owners of materials understand when the requirements of the Waste Framework Directive (75/442 EEC as amended) will apply.

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Definition of Waste - Supplementary Guidance  This supplementary guidance expands on the framework given in the guidance document "Is It Waste? Guidance on Understanding the Definition of Waste", available above. 

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Guidance on the Classification and Assessment of Waste (WM3)  The document provides technical guidance on how to classify a waste before it can be moved, disposed of or treated. The guidance was developed jointly by all UK Environment Agencies and applies throughout Great Britain and Northern Ireland.    

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Guidance on Decommissioning of Non-Nuclear Facilities  This guidance details what SEPA expects from an operator if a facility previously used for working with or storing radioactive material, or which is contaminated with radioactivity is no longer to be used for that purpose.  The document refers to radioactive substances regulated onshore under the Environmental Authorisations (Scotland) Regulations 2018, but the principles are equally applicable to facilities offshore.

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