Submissions: Published response

Keops Ltd
31 Jan 2019

What organisation do you represent? - Organisation

Keops Ltd

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

Not Answered

Should government be able to conduct assessments of a titleholder’s capacity to fulfil its obligations at any time? - Q11 - Y/N

Not Answered

Should industry be required to hold and demonstrate sufficient financial security to meet its decommissioning costs? - Q12 - Y/N

Not Answered

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

Not Answered

Should a ‘person’ (or another entity other than a former titleholder) be permitted to submit risk management plans? - Q15 - Y/N

Not Answered

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

Not Answered

Should NOPSEMA and the Minister be permitted to issue remedial directions to all former titleholders?

- Q17 - Y/N

Not Answered

Is there additional research (and/or development) being undertaken relevant to decommissioning that government should be aware of? - Q18 - Y/N

Yes: What research/development is being undertaken and by whom? What is the timeframe for this research/development? Will the results be made public and if so how/where?

Is there additional research (and/or development) being undertaken relevant to decommissioning that government should be aware of? - Q18 - research current

Conventional decommissioning of jacket supported installations involves a reverse installation procedure using heavy lift derrick barges to remove individual components or catamaran type vessels which are capable of lifting the complete topsides in one operation followed by separate removal of the jacket. These operations are highly weather dependant, involve extensive offshore preparatory work before and during lifting operations to enable lifting and are therefore costly . We are presently arranging to carry out a proof of concept test on a model prototype of an alternative system which allows the complete removal of the platform and topsides in-situ as a complete unit and is less weather dependant. The combined system and platform can then be towed to a suitable inshore location for final dissassembly and recycling or modification for potential re-use. The system has been granted a Patent and a separate design study confirmed the viability of the concept.
We anticpate completing the proof of concept testing during 2019 to enable the commercial development of a full scale system.

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

Yes: What opportunities are there? Should government be involved in establishing this industry and, if so, how?

Is there interest and merit in creating an Australian offshore petroleum decommissioning industry? - Q21 - Aus decomm industry

In view of the extent and potentially high cost, offshore decommissioning needs to be regarded as a new and important sector of the oil and gas industry. The work provides additional opportunities for the existing offshore , fabrication and recycling industries as well as the potential from re-use. At this stage there would not appear to be a need for governmental involvement in establishing a separate decommissioning industry . The regulatory requirements should fall within the scope of the existing petroleum authorities.

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

Not Answered

Unique ID

1013114330