SEPA

SEPA is responsible for regulating aspects of environmental protection both offshore, up to the limit of the Scottish area of the UK Continental Shelf, and onshore [up to low tide mark].  SEPA is also a consultee on operator Decommissioning Plans submitted to OPRED, and planning applications for decommissioning facilities.  SEPA also plays a role in multi agency Emergency Planning, including incidents in Scottish waters  

To ensure the environment is protected, SEPA may require sites to provide information on activities on the site.  For example, decommissioning sites may need to provide management plans before an asset is received onshore for dismantling and disposal, including details of the quantities and types of waste to be received and how the site will ensure they are stored and managed in a way that protects the environment.  Cooperation with the decommissioning asset owner is key, in particular ensuring there is an accurate materials inventory for the asset as it arrives onshore.  SEPA may also require monitoring and reporting of emissions to air or water to ensure continued protection of the environment.  SEPA officers carry out proactive site inspections of sites carrying out decommissioning work.

Below are brief summaries of the activities at each stage of decommissioning which require SEPA engagement.

 

Preparation for Decommissioning and Late Life Operations

As plans start to be made for the removal of an asset from the site of production, operators need to consider how they will manage waste arising from decommissioning in line with Circular Economy principles, and in compliance with the regulatory requirements of UK onshore waste management regulations or Transfrontier Shipment (TFS) regulations. 

Operators should begin to consider how they will compile materials inventories, which will help identify which items are suitable for reuse or refurbishment, and which will be sent onshore for recycling or disposals.  An accurate waste inventory is necessary to ensure that the chosen contractor is able to handle the waste received, or that a TFS authorisation can be granted.  

The change from oil and gas production to late life and decommissioning activities may also require changes to permits held under the Radioactive Substances Act, for example the total activity and method of radioactive waste disposal, or the location of an FPSO. 

Cleaning and Making Safe

As items or materials from a decommissioning asset are deemed redundant, 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 items contaminated with naturally occurring radioactive materials (NORM), may be flushed or cleaned offshore or returned onshore for treatment and disposal. This work needs to be in compliance with the permits held by the asset and/or any onshore cleaning facilities.  

 

Offshore Dismantling and Removal

SEPA directly regulates offshore dismantling and removal activities where (i) the waste or redundant items contain NORM, or (ii) the waste is being shipped abroad for recovery or disposal under the Transfrontier Shipment Regulations. Operators also need to consider the future management of any redundant items, and whether they should be treated as waste if returned to the UK – see also ‘Cleaning and Making Safe’  

 

Onshore Dismantling and Removal

Onshore decommissioning work in the UK is subject to permitting by the environmental agencies.  Sites must apply for permits to ensure that operators are ‘fit and proper’ to carry out the activity, and that the right management and discharge conditions are in place to ensure waste is managed safely, and communities and the environment are protected.   Asset owners disposing of waste are responsible for ensuring that the site to which they plan to dispose of their asset hold the appropriate permits, and has the right conditions and limits in place to accept the waste listed in the materials inventory for the asset.

In Scotland, depending on the decommissioning activities being carried out, the discharge/disposal routes being used, and the type and quantities of waste, permits may be required under the following:

Waste Management Licensing (Scotland) Regulations 2011

Pollution Prevention and Control (Scotland) Regulations 2012

Environmental Authorisations (Scotland) Regulations 2018 

Water Environment (Controlled Activities)(Scotland) Regulations 2011 

Ship Recycling Facilities Regulation 2015