Submissions: Published response
What organisation do you represent? - Organisation
Should the property removal obligation be amended to specifically require titleholders to either remove property or make other arrangements that are satisfactory to NOPSEMA? - Q1 - Y/N
Not Answered
Should timeframes for property removal be mandated? - Q2 - Y/N
Not Answered
Should a new standalone decommissioning obligation be included within the regime? - Q3 - Y/N
Not Answered
Should titleholders be required to inform government of their overarching plans for decommissioning? - Q4 - Y/N
Not Answered
Should titleholders be required to periodically update government about decommissioning-related information, including an inventory of infrastructure and its status, and a progress report on decommissioning items of infrastructure? - Q5 - Y/N
Not Answered
Should titleholders be required to submit ‘close-out’ reporting after decommissioning? - Q6 - Y/N
Not Answered
Should current titleholders be made expressly (in the OPGGS Act) liable for the costs of carrying out their decommissioning obligations? - Q7 - Y/N
Not Answered
Should alternative liability arrangements be included in a revised framework, providing government with the ability to pursue previous titleholders in the chain of ownership if the current titleholder is unwilling or unable to decommission? - Q8 - Y/N
Not Answered
Should titleholders be released from liability in appropriate circumstances? - Q8 - Y/N
Not Answered
Should titleholders ever be released from liability for infrastructure left in the marine environment? - Q10 - Y/N
Should government be able to conduct assessments of a titleholder’s capacity to fulfil its obligations at any time? - Q11 - Y/N
Should industry be required to hold and demonstrate sufficient financial security to meet its decommissioning costs? - Q12 - Y/N
Should a former titleholder operating under a remedial direction be subject to all the duties and responsibilities as if it were operating under their previous title? - Q13 - Y/N
Not Answered
Should a former titleholder be permitted to submit risk management plans? - Q14 - Y/N
Should a ‘person’ (or another entity other than a former titleholder) be permitted to submit risk management plans? - Q15 - Y/N
Should a new category of title be established to enable a former titleholder to have a current title under which to undertake relevant decommissioning and remediation activities with relevant regulatory approvals? - Q16 - Y/N
Should NOPSEMA and the Minister be permitted to issue remedial directions to all former titleholders?
- Q17 - Y/N
Is there additional research (and/or development) being undertaken relevant to decommissioning that government should be aware of? - Q18 - Y/N
Is there additional research that should be undertaken on decommissioning, and in particular on environmental standards? - Q19 - Y/N
Not Answered
Should more be done to encourage industry collaboration to help ensure that options for the continued use of offshore petroleum infrastructure in Commonwealth waters are explored prior to its decommissioning? - Q20 - Y/N
Not Answered
Is there interest and merit in creating an Australian offshore petroleum decommissioning industry? - Q21 - Y/N
Not Answered
Are there other issues relating to decommissioning that are not covered in this discussion paper and you think it is appropriate for government to be involved in?
- Q22 - Y/N
Yes: What are they? What is the suggested government involvement?
Are there other issues relating to decommissioning that are not covered in this discussion paper and you think it is appropriate for government to be involved in?
- Q22 - other decomm issues
Good day,
I have read your discussion paper – Decommissioning Offshore Petroleum Infrastructure in Commonwealth Waters
and would like to highlight some issues that may help. With recently visiting the OGA in Aberdeen regarding
providing lessons learned and proposed method to try and reduce the decommissioning costs within the UKCS, the
main topic that was not addressed within your discussion paper which I feel is a vital part of the overall
decommissioning project is preparing for onshore disposal. In the UK, when an offshore decommissioning project is
to be brought onshore to be disposed of, the project falls under the Construction (Design and Management)
Regulations 2015. When an asset is to be decommissioned and identified for UK disposal CDM regulations must
apply. The topside/jackets/subsea equipment should be decommissioned in a way that it does not create hazards
for the onshore disposal and demolition phase.
Previous to working for ABB I was the Topside Destruct Engineer and Project Manager for the Shell Brent
Decommissioning Project at Able UK and from this project we gained many lessons learned. Key issues to look at for
cost savings when decommissioning offshore are:
• Identify areas that can be decommissioned onshore rather than offshore, as the onshore contractor will
double check these lines.
• Get a fully intrusive Hazardous Material survey offshore, minimising any onshore discoveries i.e. Asbestos,
that could hold the job up. Identification early can lead to preparing a robust programme to free the quay
early for other projects.
• Identify any onshore regulations that should be bridged from offshore regulations
• Make sure onshore disposal contractor has a licenced disposal facility for each waste removed from site and
tracking record to hand over to the operator.
• Once the asset is onshore it is in the public eye more than offshore, operator reputation is more at risk and
identifying a competent demolition contractor is vital.
If you would like to discuss in more detail our Decommissioning, Demolition and Remediation Manager, Mr Steve
Andrew frequently visits Melbourne as we have a decommissioning project ongoing in the area, I am sure he will be
happy to call in for a chat. Other than that please feel free to contact me if you have any questions I’ll be happy to
help.
Kind Regards
Daniel Breeze MCMI AMIDE
Late Life Decom Project Manager
ABB Ltd.
Pavillion 9, Bylands Way
TS23 4EB, Billingham, United Kingdom
Phone: +44 (0)1642 372047
Mobile: 07795536052
Email: daniel.breeze@gb.abb.com
Web: www.abb.com/consulting
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