A joint submission consisted of eight environmental organizations issued a letter, requesting more information on Shell’s decommissioning project of four Brent offshore oil and gas platforms.
In particular, WWF-UK, Greenpeace UK, Whale & Dolphin Conservation, Marine Conservation Society, Friends of the Earth Scotland, Scottish Wildlife Trust, KIMO, and RSPB Scotland said that the material presented by Shell lacks of quantitative analysis based on hard data, a significant reliance on subjective, qualitative judgments and opinions by experts, including Shell’s own engineers. This means can not be clearly cross referenced to OSPAR 98/3 requirements and means organizations cannot assess whether or not there is a solid case with full legal, technical, environmental and economic justification, aligned specifically against the requirements of OSPAR 98/3, for each of the major components and pollutants for which Shell seeks derogation.
Background
The Brent oil and gas field, owned by a Shell/Esso joint venture and operated by Shell, lies approximately 136 km north east of the Shetland Islands, in water depth of around 140 m, just within the UK Exclusive Economic Zone (EEZ). It is served by four large platforms, 154 oil and gas wells, associated subsea infrastructure and a network of seabed pipelines. Production of oil commenced 1976 and shifted to mainly gas with a major upgrade of facilities in the 1990s. After 40 years of operations, almost all the economically recoverable oil and gas reserves have been produced.
In line with UK legislation, the Brent Field will now be decommissioned, which will take over 10 years. In addition to the regulatory and assessment process for such decommissioning in UK waters, which is stipulated under the UK Petroleum Act 1998 and related guidelines, the Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR Convention) also applies, including inter alia a prohibition on the dumping, and the leaving wholly or partly in place, of disused offshore installations within the maritime area, under OSPAR Decision 98/3 on the Disposal of Disused Offshore Installations (OSPAR 98/3 or simply 98/3).
However, under OSPAR 98/3, for certain defined sub-sea components, the operator may make a case for exemption – or derogation – from the general rule of complete removal from the sea. In such cases the operator must undertake a comparative assessment of all possible options considering environmental, safety, cost, technical and other criteria, including life-cycle analysis, and demonstrate that there are significant reasons why leaving in place is preferable to reuse, recycling or final disposal on land.
General comments on the plan
According to the organizations, OSPAR 98/3 requires that before seeking a derogation from the general prohibition on leaving disused offshore facilities in the marine environment, the proponent must show significant reasons why leaving the material in place is preferable to reuse or recycling or final disposal on land.
Annex 2 of 98/3 provides very clear, systematic guidance on the issues, criteria and process that must be considered in making such an assessment. Annex 2 of 98/3 also requires that the impacts of the proposed disposal (leaving in place) must be compared to the impacts of other options, including reuse, recycling and disposal on land. Factors that must be considered when comparing and selecting options include inter alia:
- Technical, engineering and safety aspects.
- Impacts on the marine environment and on other environmental compartments.
- Interference with other legitimate human uses, amenity etc.
- Emissions to the atmosphere.
- Consumption of natural resources and energy.
- Economic (cost) factors.
- Application of internationally agreed principles for environmental life cycle assessment.
- Identifying and quantifying the inherent uncertainties associated with each option.
- Adopting conservative assumptions about potential impacts.
- Considering cumulative effects
It is explained that many potential options for reuse, recycling and disposal on land were pre-empted internally by Shell by being ruled as being non-feasible / non-viable / unsafe, based on subjectve opinion of Shell engineers only, before full CA was applied to the remaining options only.
“OSPAR 98/3 requires that CA should be applied to all potential options before pushing the option of derogation to leave abandoned facilities and pollutants in the marine environment…Additionally, life cycle analysis, energy consumption and gas emissions were only assessed for pre-selected options, and not applied to the pre selection of options” said in their statements.
Environmental Assessment
Detailed review of the Environmental Statement (ES) Report by DNV-GL is generating an entire review report of its own, and given time constraints and the need to be focussed the following major points are highlighted:
- The environmental assessment was only applied to the options that were preselectedinternally by Shell, using their own safety, cost and technical feasibility judgements, which pre-screened many options out from further analysis. OSPAR 98/3 requires that environmental assessment should be applied to ALL options up front, as a key part in the screening and selection process.
- The environmental assessment was based more on subjective, expert judgements than quantitative analysis using hard data.
- The environmental assessment relied a lot on modelling, which is subject to the limitations outlined above and by the IRG.
- The criteria selected to examine environmental impacts are quite broad:
i) Marine needs sub-criteria.
ii) Operational discharges not included.
iii) Energy use and gas emissions are not complete “footprint”.
- The criteria used for determining the likely scale and severity of impacts needs much closer scrutiny – as does grading the sensitivity and value of receiving environments. These appear to be quite qualitative and subjective.
- The criteria for positive and negative impacts, and low, moderate and large impacts also need closer scrutiny, and also seem to be subjective / qualitative / relative only.
- The scores for the environmental impacts of options used in the CA do not correspond to impacts outlined in the ES.
On the contrary, Shell supports that the IRG has read and assessed the reports produced by the contractors and consultants for Shell and provided detailed criticisms where necessary. It confirms that the scientific information available is sufficient to characterize the baseline environmental conditions near the surface of the sea bed prior to decommissioning adequately.
“Shell engaged specialist consultants to estimate the safety risks to users of the sea from the GBS legs being left in place, their subsequent deterioration to just below sea level and their longer term deterioration leading to eventual total collapse. The IRG indicated to Shell that for a number of reasons the risk estimates that emerged from the analyses were very uncertain and may be over or underestimated possibly by one or several orders of magnitude. In the light of these extreme uncertainties Shell is now proposing, as part of its monitoring programme, to repeat the assessment of safety risk to users of the sea at regular intervals using the latest published data and new data on trends in fishing and commercial shipping activity”.
“These proposals are the result of 10 years of engineering and scientific analysis, independent studies and planning.”
Further details may be found by reading Shell’s report on Brent decommissioning project:
You may also find the environmental organizations’ official response herebelow:
You may watch Shell’s Brent decommissioning assessment herebelow:
