DECOMMISSIONING OF OFFSHORE OIL AND

GAS FACILITIES:
DECOMMISSIONING SCENARIOS:
A COMPARATIVE ASSESSMENT USING FLOW ANALYSIS

March 2005

Paul Ekins, Robin Vanner and James Firebrace

Part of a wider collaborative study

A Methodology for Measuring Sectoral Sustainable Development and its application

to the UK oil & gas sector

The project is funded under the DTIs Sustainable Technologies Initiative LINK
Programme, with funding from the Engineering and Physical Sciences Research
Council (EPSRC), matched by industry, largely through in-kind contributions in
identifying and providing data, case studies and research papers
 ACKNOWLEDGEMENTS

This report has benefited from the support of a number of organisations, and expertise
and input from many people.

Our thanks first go to the Engineering and Physical Sciences Research Council
(EPSRC), which provided the funding for the researchers at the Policy Studies
Institute (PSI) to carry out the work. Similarly, we are grateful to UKOOA, which
made the resources available to fund the input of James Firebrace.

Decommissioning of offshore structures is a highly complex and technical exercise. In

respect of some kinds of structures it is also in its infancy, so that the necessary
information to perform the kind of comparison we have attempted was unpublished,
hard to find and, sometimes, commercially confidential. Our warm thanks go to the
many members of the groups which we convened from the industry to access the
necessary documentation and ensure we fully understood what we needed to. We are
also very grateful to the group of senior managers from four offshore operating
companies (Shell, BP, ENI, and ExxonMobil) who, together with UKOOA and PSI
representatives, managed the project. All gave freely of their time when we needed it,
although all always had many other things to do. They have given a degree of insight
into the industry that we would hardly have achieved otherwise.

Our thanks also go to the four highly qualified independent peer reviewers of this
report, from whose comments and expertise we have gained great benefit.
Having said that, this report is of course our responsibility. While the great majority
of the information has necessarily come from the industry, the opinions expressed and
the conclusions drawn from it have not. They are ours alone. So too, of course, is
responsibility for any errors of fact or judgement which may remain.

Paul Ekins, Robin Vanner PSI

James Firebrace JFA Consulting
March 2005
 CONTENTS

1. Introduction..................................................................................................................1
1.1 Methodology Mapping Material, Energy and Financial Flows................. 1
2. Boundaries, scope and sources.....................................................................................7
2.1 Temporal Boundaries................................................................................. 7
2.2 Spatial Boundary ....................................................................................... 7
2.3 Economic and Fiscal Scope........................................................................ 7
2.4 Scope of the Analysis................................................................................. 8
2.5 Sources for the Analysis............................................................................. 8
3. OPTIONS FOR DECOMMISSIONING...................................................................10
3.1 Introduction to the Issues ......................................................................... 10
3.1.1 Introduction to offshore oil and gas structures .................................. 10
3.1.2 Introduction to regulatory issues....................................................... 10
3.1.3 Decommissioning experience and industrial legacy .......................... 13
3.1.4 Health & safety ................................................................................ 14
3.1.5 Economics of decommissioning ....................................................... 14
3.1.6 Brief description of decommissioning options .................................. 16
3.2 The Reference Scenario ........................................................................... 20
3.3 Top side, Jacket and Footings .................................................................. 21
3.3.1 Energy assessment experience.......................................................... 21
3.3.2 Material, energy and value chain analysis......................................... 22
3.3.3 Footings ........................................................................................... 24
3.4 Pipelines .................................................................................................. 25
3.4.1 Decommissioning scenarios ............................................................. 25
3.4.2 DTI guidelines ................................................................................. 26
3.4.3 Risk to trawling activities ................................................................. 26
3.4.4 Material, energy and value assessment of pipeline decommissioning 27
3.5 Drill Cuttings ........................................................................................... 27
3.5.1 Characterisation of cuttings piles...................................................... 28
3.5.2 Dredging of cuttings scenarios.......................................................... 30
3.5.3 Leaving in-situ scenarios .................................................................. 32
4. Assumptions for the flow analysis..............................................................................35
4.1 Financial expenditure assumptions........................................................... 35
4.2 Material flow assumptions ....................................................................... 37
4.3 Summary Assessment of Material and Energy Flows ............................... 42
5. Non-financial outcomes..............................................................................................43
5.1 Methods of assessing the non-financial outcomes..................................... 43
5.1.1 Clear seabed..................................................................................... 43
5.1.2 Health and safety.............................................................................. 44
5.1.3 Jobs in the UK.................................................................................. 44
5.1.4 Impacts on the marine environment .................................................. 45
5.1.5 Conservation of stocks of non-renewable resources.......................... 47
5.1.6 Impacts of resource extraction .......................................................... 49
5.1.7 Impacts of landfill ............................................................................ 50
5.1.8 Impacts on the fishing industry......................................................... 53
5.1.9 Impacts on fish stocks (and other marine life)................................... 57
5.1.10 Summary of the assessments of non-financial outcomes ................... 59
5.2 Evidence for the assessments ................................................................... 60
 5.2.1 Clear seabed..................................................................................... 61
5.2.2 Marine environmental impacts ......................................................... 62
5.2.3 Landfill impacts ............................................................................... 63
6. Summary outcomes ....................................................................................................67
6.1 Interpretation of summary outcome matrices............................................ 67
6.2 Summary Outcomes for Topside of Large Steel Structure (see Table 6.1) 68
6.3 Summary Outcomes for Jacket of Large Steel Structure (see Table 6.2) ... 69
6.4 Summary Outcomes for Footings of Large Steel Structure (see Table 6.3) 69
6.5 Summary Outcomes for Entire Large Steel Structure (see Table 6.4) ....... 70
6.6 Summary Outcomes for a Mostly Concrete Structure (see Table 6.5) ....... 71
6.7 Summary Outcomes for pipelines (see Table 6.6)..................................... 72
6.8 Summary Outcomes for drill cuttings (see Table 6.7)............................... 72
7. Assessment of the WIDER APPLICABILITY OF RESULTS.................................82
7.1 Assessment of the generic nature of the large steel structure results.......... 82
7.2 Assessment of the generic nature of drill cuttings pile results ................... 85
7.3 Comparison of Financial Expenditures..................................................... 86
7.4 Comparison of Total Energy Requirement ............................................... 87
7.5 Comparison of Other Non-Financial Outcomes........................................ 88
8. CONCLUSIONS ........................................................................................................90
8.1 Overview of Decommissioning Assessments and Implicit Valuations ...... 90
8.1.1 Total energy requirement (TER)....................................................... 90
8.1.2 Air emissions ................................................................................... 90
8.1.3 Clear seabed and resource conservation............................................ 90
8.1.4 Impact on the marine environment ................................................... 90
8.1.5 UK Employment .............................................................................. 92
8.1.6 Costly scenarios ............................................................................... 92
8.1.7 Covering pipelines ........................................................................... 93
8.1.8 Decommissioning the structure......................................................... 93
8.1.9 Deciding on Drill Cuttings Piles ....................................................... 93
8.2 The Differing Perceptions, Preferences and Priorities of Different
Stakeholders ........................................................................................................ 94
8.2.1 A spectrum of views......................................................................... 94
8.2.2 The authors assessment ................................................................... 95
8.3 Putting Decommissioning into a Wider Context....................................... 98
9. References.................................................................................................................100
ANNEX 1: THE REGULATORY FRAMEWORK.......................................................105
ANNEX 2: APPROVED DECOMMISSIONING PROGRAMMES ...........................108
 SUMMARY OF METHOD AND CONCLUSIONS

The Purpose and the Method of the Study

This report examines decommissioning options for the North Sea, focused on the UK
sector, in respect of large steel (considering the topsides, jackets and footings
separately) and concrete structures, together with associated pipelines and drill
cuttings piles. It is part of a research project under the DTI Link Programme, which is
seeking to develop a sustainable development methodology that can be applied to
different industrial sectors.

The methodology entails using material and energy flow analysis, with their
associated financial expenditures, in order to gain insights into the economic, social
and environmental implications of various decommissioning options, which the report
calls decommissioning scenarios, because some of the theoretical options discussed
are not currently permitted under the North Sea regulatory framework. A reference
scenario is adopted in order to have a common comparator for the other scenarios.
The reference scenario involves only basic clean up of the topside, and leaving all the
material in the structure, pipelines and cuttings in situ offshore. It is stressed that this
reference is for the purpose of comparison with the other scenarios only, rather than
being in any sense a recommendation or projection of business-as-usual. By
comparing the financial expenditures of a particular scenario with the reference
scenario, an implicit valuation can be obtained of the non-financial outcomes
associated with that scenario, were it to be adopted by society. Because of the tax
arrangements in the UK sector of the North Sea, between 30% and 70% of
decommissioning expenditures could end up being paid by the UK taxpayer because
of taxes foregone. In the numerical estimates below, the taxpayer contribution is taken
to be 50% for the sake of simplicity, but it could be more or less that this depending
on the particular tax circumstances of different fields.

Care is taken in the scenarios to compare them on the basis of equivalent material
endpoints. For example, the scenarios which envisage removal to shore of part or all
of the structure end up with large quantities of recovered metal to be recycled. For the
scenarios which envisage that this material is left offshore, account is taken of the
material and energy flows which would be required to replace it by producing the
same amount of metal from virgin sources.

The material, energy (with associated air emissions) and financial flows for the
scenarios are quantified using data from the industry, some of which is available on
websites from the results of life-cycle analyses, some of which has only recently been
generated and is as yet unpublished. A method is developed and presented for the
qualitative assessment of non-financial outcomes from the scenarios, including: a
clear seabed, health and safety, UK employment, marine environmental impacts,
conservation of stocks of non-renewable resources, the impacts of resource extraction,
impacts of landfill, impacts on the fishing (specifically trawling) industry, and
impacts on fish (and other marine life). The method entails assigning symbols, in the
manner sometimes used for environmental impact assessment, ranging from + + + to -
- -, to the possible ranges of outcomes across the different dimensions in the different
scenarios. This information, much of which is quite complex, is presented in summary

i
matrices, from the entries in which the various scenarios can be compared across the
different dimensions.

Because decommissioning, for some types of installation at least, is still in its infancy,
much of the information in the report is taken from a few industry case studies, most
importantly what is called Case Study A, relating to a large steel structure. This is the
only detailed information for the decommissioning of such structures that is available,
across the range of issues studied. An assessment is made of the extent to which the
conclusions from this case study are likely to be applicable to the UK sector of the
North Sea more generally. It is shown that the Case Study A structure is in fact in the
middle of the range of large steel structures in the North Sea UK sector and that,
while there are no doubt special factors that apply more or less to it alone, there is no
obvious reason why this should bias the results in one direction or another. Within the
bounds of error of the results generally, the results from Case Study A are taken to be
broadly representative of large steel structures in the North Sea as a whole. It is less
likely that these results could be validly applied to structures either much smaller or
much larger than Case Study A, as other factors may then become relevant which
might lead to non-linear relationships between, for example, cost and mass. It was not
possible to explore the possibility of such relationships in the project.

The Conclusions from the Study

The information from the summary matrices is presented in an overview table, from
which conclusions are drawn. Because the information in the case studies used for
this study may not be fully representative of the structures to be decommissioned in
the North Sea generally, the results and conclusions from this study should be
regarded as illustrative rather than definitive. While it is believed that the conclusions
that follow are robust, in general terms at least, they are derived from much complex
scientific and technical material, which is discussed in more detail in the text, and
which provides further context for the interpretation of the conclusions. The
conclusions should be read with awareness of this context and, especially, the
limitations of the data that it reveals.

The headline results of the study may be summarised as follows:

Energy use: it makes a difference to scenarios relative energy performance if

account is taken of the energy needed to replace materials left offshore.
Air emissions: offshore diesel use is more emission-intensive than onshore
refining, so that even those scenarios which use less energy overall than the
reference, because of savings from recycling, may produce more emissions if they
entail more offshore activity.
Clear seabed and resource conservation: taking recyclable metals to shore for
recycling conserves resources and reduces the impacts of resource extraction
which would otherwise be necessary to replace them; taking non-recyclables to
shore produces potentially considerable negative environmental impacts from
landfilling; re-injecting non-recyclables (e.g. drill cuttings) prevents landfill
impacts, but is energy-intensive, and can be logistically problematic and entail
increased safety risks.
Impact on the marine environment: compared to the reference, all the scenarios
(except those for drill cuttings) have a negative impact on the marine

ii
 environment, though in most cases the impact is only of medium or small scale
and is short-lived. For drill cuttings, preferable options for the marine
environment to leaving them in situ are covering, re-injection, or removal to
shore, though these options all have their own problems with respect to other
environmental impacts and/or feasibility on the scale envisaged, and are
expensive.
UK Employment: decommissioning expenditures may benefit UK communities if
carried out in areas with unemployment and appropriate skills; however, the study
has been unable to quantify these benefits.
Costly scenarios: the most expensive of the scenarios assessed in detail involve
the return to shore of a large mainly concrete structure, and of drill cuttings; there
are large environmental costs as well as benefits associated with these scenarios
(especially if the drill cuttings have to be landfilled); the assessment suggests that
they offer least environmental value for money of all the scenarios considered.
The bioremediation or re-injection of drill cuttings are also expensive, but have
fewer environmental drawbacks. Bioremediation is not currently being considered
as a practicable option in the UK context.
Covering cuttings and pipelines: these scenarios generate benefits for the trawling
industry, but have a number of negative environmental impacts and are relatively
expensive. Covering drill cuttings piles would improve the seabed over its current
condition.
Decommissioning the structure: the scenarios that involve removal of materials to
shore achieve a clear seabed, conserve the stock of resources, reduce the resource
extraction to produce from virgin sources the material that has been recovered,
and benefit the trawling industry through opening up areas to trawling; on the
negative side, their health and safety implications, and their impacts on the marine
environment and in terms of landfill are worse than the in-situ scenarios, which
also tend to benefit fish rather than the trawling industry; they are also more
expensive.

The Differing Perceptions, Preferences and Priorities of Different Stakeholders

A spectrum of views

There are many differences in perceptions, preferences and priorities involved in the
issue of decommissioning, which is one of the reasons why there is unlikely to be a
full social consensus on the best decommissioning scenario. In fact, there are at least
seven different kinds of consideration which will influence the attitude to
decommissioning of different stakeholders: technical feasibility, safety, cost,
environmental impacts, the regulatory framework, reputation and the political
environment.

The assessment in this study shows that the environmental outcomes from the various
decommissioning scenarios are mixed. No scenario can be said to be definitively
superior from an environmental point of view. The total removal scenarios can only
be justified environmentally if a relatively high value is put on a clear seabed, benefits
to the trawling industry, the conservation of the stock of resources (because of
recycling) and the impacts of resource extraction (which are avoided because of the
recycling). The latter two considerations do not apply to drill cuttings, the material
from which must either be landfilled or converted into an inert construction material.

iii
In addition, implementing the removal scenarios would imply that a relatively low
value is put on energy use and air emissions (for the concrete structure and drill
cuttings), landfill (for all the removal scenarios), and impacts on the marine
environment and fish (for all the removal scenarios except for drill cuttings). The
judgement over drill cuttings is made more complex in that it is the only leave in situ
scenario which is worse for the marine environment than alternative scenarios (which,
however, have other negative environmental impacts). It is not clear that the relative
valuation accorded to these issues either by the range of environmental groups
concerned about the marine environment, or by society more widely, would favour
total removal. It is also not clear what action might be most in line with the
precautionary principle. Avoiding the negative environmental impacts from the
removal scenarios may be as important in this regard as achieving a clear seabed and
recycling metals, none of which can be regarded as scarce. One advantage of the
removal scenarios from the point of view of the industry is that they remove any
future liability that might otherwise arise from materials left in situ.

The authors overall assessment

Recognising that views and values concerning the different issues involved vary
across different stakeholders, the authors have arrived at the following overall
assessment on the basis of the evidence presented in the study.

For the topside, all parties seem agreed that removal to shore is the only scenario
worthy of serious consideration, and the assessment shows this to have fewer
environmental trade-offs than some other removal scenarios. It still involves
expenditure of some 30m (15m from the taxpayer) for a single large steel structure,
some 12m more than the shallow disposal scenario. For the jacket, the same
arguments seem to apply, except that the difference in cost between the removal and
shallow disposal scenarios is significantly less. The footings are a different matter,
largely because of their difficulty of removal, causing both environmental impacts and
safety concerns, the former of which are complicated by the footings interaction with
drill cuttings. The major impact of leaving them in situ is on the trawling industry.
With a total cost of removal for the UK of nearly 1 billion (one half of which would
be paid by UK taxpayers), it is not clear that the removal of footings offers good value
for money.

Unlike the large steel structure as a whole, there are strong arguments, environmental
and financial, for not removing large concrete structures to shore, and few
environmental arguments for doing so. The taxpayer expenditure alone on this
scenario (143m) would not seem to be justified by the benefits that would result. For
drill cuttings the judgement is more complex, with the environmental benefits of
achieving a clear, and ecologically regenerating, seabed, having to be assessed against
the environmental impacts and financial costs of the scenarios concerned. On the
basis of current technologies, perhaps a light covering over the drill cuttings piles,
with continued exclusion of trawlers, might be the favoured option of those for whom
the continued existence of the uncovered drill cuttings piles is unacceptable. If re-
injection, bioremediation and drill cuttings processing techniques were to improve,
then perhaps these options for removal would become favoured. For the present,
however, the combination of environmental and financial considerations seems to
favour leaving the cuttings in situ.

iv
For large pipelines (small ones are not difficult to remove) the situation is similar to
that for footings. Recovering them clears the seabed, conserves resources and reduces
the impacts of resource extraction, but with some environmental impacts and probably
some safety risks, and involves considerable cost. The main beneficiaries of this
expenditure, as with clearing footings, would be the trawling industry. Covering the
pipelines is even more expensive and has little environmental justification over
removal. Leaving them, with remedial action to make them safe for trawling if
necessary, would be the preferred scenario, unless a very high value was put on a
clear seabed and the resources they comprise.

All scenarios with material left in situ would require monitoring, the financial and
(small) environmental implications of which need to be added to the relevant
scenarios. The financial calculations would need to include the costs of any remedial
action (for example, to pipelines, which monitoring revealed to be necessary).
Responsibility for monitoring, and for taking action on any information that it might
generate, would also need to be considered. This raises the possibility of this
monitoring being combined with marine monitoring for other purposes.

Broadening the context beyond decommissioning

Decommissioning is not the only activity in the marine context with environmental
implications. Indeed, according to OSPAR, the offshore oil and gas industry is not
responsible for any of the six human pressures on the marine environment to which it
gives a Class A (highest impact) grading. Three of the six pressures come from
fishing.

One response to marine environmental degradation, and the loss of fish stocks, has
been proposals to establish marine protected areas (MPAs). OSPAR itself is currently
engaged in efforts to complete by 2010 a joint network of well-managed, ecologically
coherent MPAs, although these are much smaller than the fishing-free zones that
would be necessary to have a significant conservation effect on fish stocks. This
simultaneous concern with decommissioning and MPAs, and current efforts to put in
place an overarching EU Marine Strategy, offers a significant opportunity to develop
an approach to marine environmental protection that embeds decommissioning into a
wider framework of marine environmental protection, which includes the regeneration
of fish stocks, which could combine into a single programme the monitoring effort
that would be required for both MPAs and to keep under surveillance any materials
for offshore oil and gas operations that were to be left offshore. Such an approach
could also support the resolution of long term liability issues related to any material
left in situ.

v
vi
1. INTRODUCTION

This report has been written as part of a collaborative study carried out under the DTIs
Sustainable Technologies Initiative LINK programme and funded by the Engineering and
Physical Sciences Research Council (EPSRC): A Methodology for Measuring Sectoral
Sustainable Development and its application to the UK oil & gas sector. The overall
objective of the study is to develop a generic sustainable development methodology that can
be applied both to the oil and gas industry and to other regions or sectors and thus be of
wider public benefit. This methodology is based on an analysis of material and energy flows
and their related financial implications down the value chain, coupled with an environmental
impact analysis.

The study as a whole will cover four issues of importance to the offshore oil and gas sector:
decommissioning, produced water, energy efficiency and employment. This report describes
the application of the methodology to and the conclusions on decommissioning.

1.1 METHODOLOGY MAPPING MATERIAL, ENERGY AND FINANCIAL FLOWS

Sustainable development is a process the assessment of which involves the simultaneous

consideration of environmental, economic and social performance. The mapping of material,
energy and financial flows is intended to cast light on the environmental and economic
dimensions, because many environmental impacts arise from the flow of materials and
energy, and financial flows are obviously intrinsic to the economic dimension.

Material and energy flow analysis is based on the fundamental principle that neither energy
nor matter can be created or destroyed, only changed from one form into another. The
analysis involves drawing a conceptual boundary around a system and undertaking an
accounting process for energy and/or material flows through the system or across its
boundary, balancing inputs, changes in stocks and outputs of a given material, or a flow of
energy, over a given timeframe. The idea is simply illustrated in Figure 1.1. Materials cross
the boundary of the system under consideration and are transformed by a process. Those that
stay within the boundary are added to the material stocks of the system. Those that leave the
boundary (whether as products or wastes) are subtracted from the material stocks of the
system. Figure 1.1 shows the mass balance equation expressing the reality that matter cannot
be created or destroyed.

The energy part of Figure 1.1 shows that typically the process under consideration in the
system will use high-grade energy and transform it into low-grade energy which will usually
be dissipated across the boundary of the system. Like matter, the amount of energy will be
conserved but it will be changed from a high-grade to a low-grade form.

1
Figure 1.1 - Conceptual mass and energy flow diagram

Material system boundary Energy system boundary

Products

Inputs Wastes
High-grade Low-grade
Process energy inputs energy outputs

Process

Stocks

Where for materials within the boundary: Where for energy within the boundary:
Inputs = Products + Wastes + (Stocks(t=1) - (Stocks(t=0)) Inputs = Outputs (high grade becomes low grade)

Industrial processes are typically like those in Figure 1.1, utilising high-grade energy and raw
materials to produce a higher value product, and one or more low-value waste products, often
themselves requiring further processing. This further processing (of which decommissioning
is an example) itself may produce low-value wastes and involve environmental impacts.
Assessment of such processes needs to consider

The impacts and environmental risks of the waste if left unprocessed;

The value and environmental burden of the input materials used in the processes
and the outputs from it; and
The wider social and distributional implications of these outcomes including the
interests of future generations.

Any perceived net benefit has to be considered in relation to the financial expenditure of the
processes and the overall benefits they yield.

Implications for the Methodology of Decommissioning of Offshore Structures

The various options for decommissioning offshore structure are described in some detail later
in this report. Here it may just be noted that such decommissioning adds a further factor to be
considered in the methodology to be used here, as there is potential to recycle the materials
comprising the structure. In essence, the two broad decommissioning options are to return the
structure to shore and recycle the materials which comprise it, or to leave it in situ. Not
recovering and processing the structure requires that raw material and energy be consumed to
replace the materials which would have been recycled if the structure had been brought
onshore. The key material and energy considerations of the different approaches to
decommissioning are therefore:

2
 In situ: the energy, emissions and input material requirement to replace the materials
which would have been recovered if the structure had been dismantled and taken to
shore;
Return to shore: the energy and material used to dismantle the structure and take it
to shore (mostly diesel in marine vessels) and the energy (and therefore emissions)
used to recycle the material back to a usable form.

The energy requirements of decommissioning of offshore structures are documented by the

Institute of Petroleum (IP 2000). This provides a methodological framework as well as
default values for companies making an assessment of energy use in the absence of case
specific figures being available. This framework is used as the starting point for this analysis
of decommissioning both for energy (diesel) and its corresponding material flows.

There is a further potential approach to the analysis of the implications of leaving the
structure in situ. The energy, material and financial implications of stimulating extra
recycling of an equal amount of already existing onshore materials, rather than the
implications of replacing them from virgin sources, could have been considered. This would
have the added benefit of conserving raw materials, by not requiring new extraction of such
materials to take place.

Any such approach would have to estimate the full implications of recycling waste materials
which are not currently recycled. Such recycling could be expected to be more difficult,
costly and energy-intensive than the recycling currently carried out, because the materials
which are easiest to access are those which are recycled first. This study has been unable to
consider this approach, because the necessary detailed analytical work does not appear to
have been carried out, and it was certainly outside the scope of this project. If it emerges
from this study that the difference between stimulating extra recycling and extracting new
resources is likely to be a significant factor in deciding between decommissioning options,
then a further study could be undertaken to investigate these differences in detail.

Material Values and Endpoints

The financial flows involved in any process consist of the financial costs of undertaking the
process. There are also various non-financial values related to the processs material and
energy flows. For example, the conservation value of recovering material through
decommissioning has to be weighed against the resource cost of the diesel required to
recover the material and the negative value of any waste materials such as emissions and
non-recyclable materials which have to be landfilled. Key considerations for the
methodology here are:

Replacement of material left in situ is only required to be considered in the

methodology if the material would have been recycled in the event of a return to
shore option being followed. If the materials are not economically recoverable after
the structure has been dismantled onshore, the energy and value within the materials
has been fully used in the commissioning stage of the structures value-chain.

3
 The possibility of re-use of the structure without full material reprocessing needs to
be considered, and could well be beneficial as it avoids the energy required in the
recycling process. In this case the material and energy benefits are those of the
material and energy which would have been required to build the structure which the
materials are going to replace. Examples of such re-use would be the use of a crudely
cut structure as a quay (some parts of Brent Spar were used in this way) or the
potential use of disused oil pipelines for the transport of CO2 for carbon sequestration.
Figure 1.2 provides a high view of the material flows for different options, and
indicates how the analysis of a re-use option could be undertaken. This diagram
shows the actual material and energy flows (solid lines) and the virtual material and
energy flows (dashed lines), which would have been required, in the absence of
recovery, to achieve the same material endpoint.

Figure 1.2 Equivalent Material Endpoints from In Situ and Recovery

Decommissioning Options
Recovered
Material
In-situ structure Offshore Recovered structure
Recovery
Landfilled
Material

Alternative
Use

Equivalent
use process

Replacement
process

Temporary steel work is often required in the decommissioning of large structures

and therefore becomes part of the structure to be decommissioned. In common with
the rest of the structural steel work, the material endpoint of this temporary steel work
will be recycled steel (or replaced steel if left offshore). Therefore, in respect of
temporary steel work the analysis does not include the energy and financial
expenditures required to generate the raw steel. It does however include the energy
and costs of fabricating the temporary steelwork from raw steel for the purpose of
carrying out the decommissioning.

Non-financial outcomes

There are social and environmental implications of the decommissioning of offshore

structures, the latter of which may be associated with the material and energy flows. These
implications, which will not necessarily be included in any way in the financial flows
associated with material and energy use, need to be addressed explicitly. The approach taken

4
in this study is not to make a valuation of such non-financial outcomes, but to identify,
inform and qualitatively assess the importance of them relative to some reference case.

A further intention of the study is to provide an implicit valuation of these non-financial

outcomes and benefits by highlighting the additional expenditures required to achieve them,
relative to the reference case. How they are assessed in this study is discussed in detail in
Sections 4 and 5. The non-financial outcomes (including the material and energy flows) to be
assessed are, in no particular order:

Assessed quantitatively (see Section 4)

1. Material inputs;
2. Material endpoints (of the material being decommissioned);
3. Total energy requirement (TER);
4. Total gaseous emissions;
5. Financial expenditures;

Assessed qualitatively (see Section 5)

6. A clear seabed;
7. Health and safety of personnel directly involved in the decommissioning process;
8. Jobs in the UK;
9. Impacts on the marine environment;
10. Conservation of non-renewable resources;
11. Impacts of resource extraction;
12. Impacts of landfill;
13. Impact on the fishing (specifically trawling) industry; and
14. Impacts on fish (and other marine life).

In the discussion of these issues that follows, any financial considerations related to the
issues are given numerically where possible, while the non-financial components are given
different symbolic representation, which is explained in Section 5. Because of the
uncertainties involved in some of the financial calculations (which relate to processes some
of which have never actually been carried out), it would have been desirable to give the
financial estimates as ranges. Usually, however, this was not possible from the extant
sources. It should, therefore, be borne in mind that point financial estimates are not intended
to suggest accuracy or levels of uncertainty, but simply reproduce the numbers in the studies
consulted. The conclusions from this tentatively drawn in order to reflect the high level of
uncertainty in the assessments overall.

As noted by Greenpeace (2004), which of all the environmental groups has taken most
interest in and exerted most influence on the decommissioning issue, any full consideration
of decommissioning also needs to take account of broader issues such as the established
international trend against dumping, the cumulative damage and the potential precedent
that could be set by dumping individual installations on a case-by-case basis, the need for
industry to take responsibility for the products it creates, the precautionary principle and the
need to protect the environment from harm. Some of these issues will be qualitatively

5
assessed under the headings above. Others will be brought into consideration in the
concluding discussion and interpretation of the results of the analysis in Section 8.

Structure of the Report

The next section of this report describes the boundaries of the analysis, the scope of the
impacts being considered and the sources for the more detailed analysis which follows.
Section 3 investigates the various options for decommissioning and chooses a number of
these for further study. Section 4 sets out various issues and assumptions related to the
calculations of the energy, material and financial flows for the chosen options. Section 5
describes the assessment methodology for the various non-financial outcomes listed above.
Section 6 then presents the information from the analysis in the form of summary outcome
matrices with a descriptive commentary. Section 7 discusses the extent to which the data
available and analysed, which is for only a few North Sea structures, is representative more
widely of North Sea structures in the UK sector which are to be decommissioned. Section 8
then presents some conclusions from the analysis and, in particular, the implicit valuation of
the different decommissioning options which have been studied, were they to be chosen by
society. As noted above, these conclusions are presented in the context of a broader
discussion of social values, not least because this is the context in which any decisions about
decommissioning will actually be taken.

6
2. BOUNDARIES, SCOPE AND SOURCES

The temporal, spatial and economic boundaries, the scope of the analysis undertaken here,
and the impacts it identifies, and the sources for the data that underpins the analysis, are now
discussed in turn.

2.1 TEMPORAL BOUNDARIES

The temporal boundary of the analysis is defined by the start and end times of the
decommissioning options chosen:

The start of the analysis is after shutdown and all the required tasks which are
common to all decommissioning options. These include shutdown, well
decommissioning and flushing and cleaning of tanks, process equipment and
pipelines.
The end of the analysis is defined by the material endpoints of all the
decommissioned and input materials.
o For leave in-situ options, it is envisaged that the monitoring and surveying of
all in-situ material is ongoing. The financial liability from any ill effects from
this material is included in the summary outcome matrices, although not
quantified, because in the absence of any clear specification of these effects it
has not been possible to estimate them.
o For the recovery option, this will be when the material has been returned to its
recycled and usable form, or treated as waste and financial liability has been
transferred to a third party (typically a landfill site owner).
o For all decommissioning options, the end point of the fuel inputs is the
gaseous emissions of CO2, SO2 and NOx only. Methane (CH4) emission
factors are not available for the onshore processing of metals and these
emissions are therefore not included in the analysis.

There is no limit to the time period over which the impacts (and non-financial outcomes) of
decommissioning are in principle considered relevant for this study.

2.2 SPATIAL BOUNDARY

There is some uncertainty whether the recovered material would remain within the UK or
even within Europe, although current legislation requires certain waste streams to be dealt
with in their country of origin. Similarly the impacts of decommissioning may occur inside
or outside the UK. Therefore the spatial boundary of the analysis is not restricted to the UK
and is defined by the earths outer atmosphere. This very wide definition of the spatial
boundary of the analysis allows the between-country distributional implications of the
impacts to be considered.

2.3 ECONOMIC AND FISCAL SCOPE

This analysis only looks at the financial expenditures incurred in decommissioning and does
not assess quantitatively the wider economic impacts. Significant non-financial outcomes,

7
which may have economic implications, are identified and qualitatively assessed relative to
the reference case (see Section 5).

Decommissioning expenditures should be viewed as normal industry capital and operating

expenditures. However, because of the tax regime applied to offshore oil and gas operators in
the UK sector of the North Sea, it is also the case that, because decommissioning
expenditures can be offset against tax liability in the normal way, some proportion of them
can be regarded as effectively public expenditure (because of the tax revenues foregone).
This is identified as an important, but little appreciated, distributional implication of
decommissioning, which makes decommissioning relevant to public as well as private
spending priorities, and this point is stressed in what follows. However, quantitative
assessment of the wider fiscal implications of the decommissioning options (for example,
considering the sources of alternative tax revenues required due to such tax offsets) is beyond
the scope of this study.

When assessing the value of material flows, the market value of material endpoints is
provided. This does not however capture the entire value of this endpoint to society. For
example, the gate fee charged to landfill material does not fully capture the impacts of the
landfill on local people or the reduced opportunity future generations have to use the land in
the way they wish. These wider and non-financial outcomes are considered separately as part
of the non-financial component of the assessment.

2.4 SCOPE OF THE ANALYSIS

The analysis includes the material, energy and financial implications of the transportation,
dismantling and processing of structural materials. Therefore, the analysis for a removal
decommissioning option will include:

The diesel requirements of all ship and lorry transport from the offshore site to a
landfill/smelting facility;
The material, energy, financial, emission and other implications of dismantling the
structure;
The energy and emission implications of smelting the metallic material from the
structure.

For options that leave the structure offshore, the analysis includes the material, energy and
financial implications of so doing, plus the implications of producing the same endpoints in
terms of useful material onshore, as discussed above.

2.5 SOURCES FOR THE ANALYSIS

Decommissioning of offshore structures in the North Sea is in its relative infancy. Relatively
few structures have so far been decommissioned. No large fixed steel structures have so far
been decommissioned.

It is not surprising that, to date, the great majority of study and analysis of the impacts and
different options of decommissioning have been carried out by the industry. In fact, this

8
study would not have been possible had the industry not given access to the project
researchers information from industry sources, which had not been previously available.
Much of this information comes from recent intensive work relating to the decommissioning
(which is still in its pre-consultation phase) of a large steel structure which is here called
Case Study A.

Two other bodies of work have provided useful material for this study:

Studies relating to the decommissioning of Maureen, a steel-based re-floatable platform

structure. (Phillips UK 1999)
Studies relating to the decommissioning of Ecofisk I, a planned 15-year decommissioning
programme for thirteen steel platform facilities as well a storage tank in the Norwegian
North Sea. (ConocoPhillips 1999). For ease of reference in some tables, this has
sometimes been called Case Study B.
The UKOOA-led Joint Industry Project (JIP), a major programme of research seeking the
best way of tackling the historical legacy of accumulated drill cuttings beneath offshore
installations in the North Sea (UKOOA 2002).

9
3. OPTIONS FOR DECOMMISSIONING

3.1 INTRODUCTION TO THE ISSUES

This introductory section tackles a number of general issues associated with

decommissioning. Three subsequent sections tackle the principal components of
decommissioning offshore oil and gas facilities in more detail. These are:

Decommissioning of the topside, jacket and footings (Section 3.3);

Decommissioning of pipelines (Section 3.4); and
Tackling the piles of drill cuttings at the foot of structures (Section 3.5).

Section 3.2 discusses the issues related to the choice of a reference case against which the
chosen decommissioning options can be compared.

3.1.1 Introduction to offshore oil and gas structures

Figure 3.1 shows what Watson (2001, p.27) calls a typical North Sea deep-water platform.
The structure consists of:
A topside, the actual platform above the surface of the sea on which offshore
activities take place.
A jacket, a structure largely of tubular steel which supports the topside.
Footings, the lowest and heaviest section of the jacket, which are considered
separately for decommissioning purposes. The footings include pile clusters to aid
piling of the structure into the seabed, and a drilling template, through which the
wells are drilled.
A pile of drill cuttings on the seabed beneath the platform, consisting of drilled rock
particles and drilling fluids arising from drilling the wells.

Figure 3.1 gives some details and dimensions of this typical structure.

3.1.2 Introduction to regulatory issues

More detailed information about the regulatory framework for decommissioning is given in
Annex 1. In this section material is only included if it is immediately necessary for the
understanding of the decommissioning options that are to be assessed.

The regulatory framework for the decommissioning of offshore structures in the North Sea is
provided by the OSPAR treaty. There is currently a presumption under the OSPAR
convention that all offshore structures will be entirely brought to shore for decommissioning,
with only limited possibilities for derogation. In particular, OSPAR Decision 98/3 (taken in
1998) requires the following:

All topsides of all structures are to be removed and brought to shore for reuse, recycling
or disposal;

10
 All sub-structures or jackets weighing less than 10,000 tonnes must be totally
removed and brought to shore for re-use, recycling or disposal;
For sub-structures weighing over 10,000 tonnes, there is a presumption to remove
totally but with the potential of a derogation being agreed on whether the footings might
be left in place; and
Derogation may be considered for the heavy concrete gravity based structures as well
as for floating concrete installations and any concrete anchor-base.

11
Figure 3.1: Typical North Sea Deep Water Platform
Source: Watson 2001, p.27

12
At the UK level, the DTIs Guidance Notes for the decommissioning of offshore facilities
and pipelines detail how all components of the decommissioning process should be dealt
with including drill cutting piles and pipelines (DTI 2001). The regulatory regime with
regard to the approval procedure is a two/three-stage process. The first stage consists of
submission to the DTI of a first draft of a proposal setting out how the operator intends to
decommission the installation with supporting evidence as to how the different elements of
the proposal were decided on. Then there is a process of dialogue between the operator and
the DTI until a revised second draft, including an Environmental Impact Assessment, can be
published and opened for public consultation. However, the DTI guidelines make clear that
stakeholder dialogue should be taking place in advance of the publication of the second draft.
Any OSPAR derogation requires formal international consultation and is to be undertaken by
the relevant government. In the case of UK regulated waters, the relevant governmental body
would be the DTI. The studies relating to Case Study A were commissioned by an operating
company as part of the process of preparing the first draft of the submission to the DTI of
proposals to decommission a large steel structure.

3.1.3 Decommissioning experience and industrial legacy

There has been a range of structures of various types which have either been
decommissioned or have been approved for decommissioning. A list of these structures is
provided in Annex 2. As noted in the previous section, much of the content of this report is
based on a number of studies commissioned to inform planned decommissioning
programmes concentrating on larger structures, including:

Brent Spar A steel floating storage facility;

Maureen A steel-based re-floatable platform structure;
Ekofisk I A planned 15-year decommissioning programme for thirteen steel platform
facilities as well as a storage tank;
Case Study A A large steel structure such as that illustrated in Figure 3.1.

Actual decommissioning of Brent Spar and Maureen and the assessment outcomes of the
Ekofisk structures are shown in Table 3.1.

Table 3.1 Examples of Actual Decommissioning Carried Out or Agreed

Installation component Maureen1 Brent Spar2 Ekofisk I3

Topside
Onshore Onshore Onshore
Jacket
Footings Re-floated onshore - -
Tank - Onshore In-situ
Pipelines Leave buried Outstanding Leave buried
Cuttings In-situ (with review) - In-situ
1
Decommissioning involved removing the whole structure to shore for re-use or recycling, but leaving the pipelines and
drill cuttings in situ.
2
This outcome followed the unsuccessful attempt by Shell in 1995 to dispose of Brent Spar at sea.
3
This plan for decommissioning has been approved by the Norwegian authorities but has not yet been completed.
Sources: Maureen: Phillips UK 1999, Brent Spar: Parmentier 1998, Ekofisk: ConocoPhillips 1999.

13
None of the 33 large fixed steel structures on the UK Continental Shelf (UKCS) has yet been
decommissioned. Many of these larger structures will be eligible for derogation under the
current OSPAR arrangements and could apply to leave their jacket footings in-situ. Table 3.2
lists all the various types of structures on the UKCS. The extent to which the data for Case
Study A is typical of other large steel structures is discussed in Section 7.

Table 3.2 The Number of Each Type of Platform on the UKCS (2001)

Type of platform1 Number

Small steel 196
Large steel 33
Concrete gravity based structure 11
Floating production facility 22
Steel self-elevating production jack-up 1
Steel tension leg platform 3
Total 266
Source: DTI 2002, Annex 2A, p.44.
1
While the broad thrust of this classification is widely accepted, the industry might classify somewhat differently some of
the less common structures

3.1.4 Health & safety

The decommissioning of offshore structures poses significant health and safety challenges,
even for an industry accustomed to managing high-risk offshore operations. Estimates are
made on the statistical probability of serious and fatal accidents occurring during the
decommissioning process. For example, the Ekofisk I planning process estimated that the
Potential Loss of Life (PLL) of decommissioning the structure (all 13 jackets and the tank)
was 8% (i.e. there was an 8% probability of a fatal accident) for the largely in-situ scenario,
and 29% for the total removal decommissioning scenario (ConocoPhillips 1999, p.19).

However, these figures are summations of risk over extensive and diverse operations, some
of which may be particularly risky, while the total risk may not be higher than the permitted
risk in comparable industrial activities in other sectors. It may therefore be more appropriate
to consider these risks individually for particular operations in relation to the thresholds
accepted for these other activities, rather than summing them over the whole operation. This
may be especially important when the different decommissioning options have different
quantities of man-hours involved, as well as varying distributions of risk.

3.1.5 Economics of decommissioning

Cost of decommissioning

Figure 3.2 shows the estimated cost of decommissioning all of the structures associated with
the UKCS. It shows that the cumulative cost of total removal was an estimated 8.4 billion in
2001, which had increased in real terms to 8.8 billion by 2002. Watson (2001, p.6) estimates
that the costs of total removal of the North Sea structures (i.e. also including Norwegian and
Dutch structures) may be 13-20 billion. This illustrates the enormous economic
uncertainties still associated with decommissioning, especially of the large steel structures in
deep water, of which there is as yet no experience. Moreover, while the structures may be
similar, they are not identical, and differences in detailed design, coupled with differences in

14
the nature and extent of wear and tear over their lifetimes in the harsh North Sea
environment, mean that the decommissioning of each one will need to be approached on a
fresh basis.

Figure 3.2 The Cumulative Costs of Decommissioning from Two Surveys

Fiscal regime

The governmental contribution to the decommissioning of UK offshore structures via tax

relief will be between 30-70% depending on historical levels of Petroleum Revenue Tax
(PRT) paid1. Based on present cost estimates, the cost to the taxpayer of decommissioning all
of the structures on the UKCS associated with oil and gas is estimated to be 4.6 billion in
the years 2001-2030 (Kemp et al 2001, p.31, medium exploration scenario), though clearly it
could be higher if the higher cost estimates presented in the previous section are closer to the
outcome. On average, therefore, current estimates would seem to be that the UK taxpayers
contribution towards the total cost of decommissioning through lost tax revenues will be
about 50% of the total cost.

Residual liability

All those with a financial interest in an oil and gas installation have a residual liability for
anything left in-situ. In the event of the ownership being passed on, perhaps to new entrants
and smaller operators (DTI 2001, p.34), new owners may be asked to give financial security
to old owners, because, in the event of new owners going out of business, liability can revert
to former owners. Under the Petroleum Act 1998, a party with relevant interests in an

1
This compares with the Norwegian Government paying two thirds of the cost of decommissioning the Ekofisk
structures, and a potential Government contribution of up to 80% in other cases, depending on the past tax
treatment of the companies concerned (Osmundsen & Tvetars, p.1584)

15
offshore installation may be obliged to submit and carry out a decommissioning programme,
and ultimately be individually liable to do so even in the event of others in the partnership
defaulting (joint and several liability). If a party wishes to end their liabilities in the asset, this
will only be agreed to by the Government if appropriate external financial security is agreed
within the partnership (DTI 2001, Annex F). However, financial liability of
decommissioning activities and the material endpoints of materials brought to shore is largely
passed over to contractors as the materials are returned to the wider economy. In addition to
formal legal liability, residual materials may be a potential liability in terms of reputation, for
a certain time and for the larger oil companies at least.

3.1.6 Brief description of decommissioning options

The detailed assessment of decommissioning options in this report is based on case studies
that have been available to this project for this purpose. The extent to which these case
studies may be taken as broadly applicable to a large range of the structures found on the UK
Continental Shelf (UKCS) is discussed in Section 7. The case studies considered relate to:

1. Large steel production platforms which are fixed to the seabed with jackets of greater
than 10,000 tonnes (based on a case study of a structure in the middle of the size
range of large steel structures);
2. Large mostly concrete structures (based on a tank case study);
3. Pipelines, based on a case study which looked jointly at an oil and at a gas pipeline of
sufficient size for decommissioning not to be straightforward;
4. Large drill cuttings piles of about 40,000 tonnes with some cuttings containing oil-
based drilling muds.

A large part of the analysis in this report focuses on large steel structures, based on data for a
particular structure, here identified as Case Study A, which contains approximately the
amount of materials set out in Table 3.3:

Table 3.3 Materials Contained in a Mid-Size Large Steel Structure1

Totals Steel Aluminium Copper Non-metals

t t t t t
Topside 20,520 20,000 20 200 300
Jacket 10,200 9,000 500 700
Footings 11,300 10,000 300 1,000
Total structure 42,020 39,000 820 200 2,000
1
It should be noted that the tonnages of materials in such structures will vary and these figures should be
regarded as no more than indicative of the kinds of masses involved.

The purpose of this report is to present a comparative analysis of the possibilities for
decommissioning of various offshore oil and gas structures which have come to the end of
their useful lives. It is assumed that a thorough investigation of the various possibilities will
have been undertaken within the oil and gas sector and this report is largely based on the
results of these investigations.

16
The range of decommissioning options for oil and gas structures in general can be briefly
described as follows:

Leave in situ Leaving the structure in situ after the cleaning of all hydrocarbons.
While leaving individual component parts of the structure (e.g. topside, jacket etc.)
can be considered separately, obviously lower components have to be left in situ for
this to be considered for a higher component.
Monitoring Leaving the structure in situ with a programme of on-going monitoring
of the fate of the abandoned structure and associated materials (e.g. pipelines and drill
cuttings piles).
Toppling Doing the minimum required to topple the structure so that it simply lays
on its side at the site.
Shallow disposal Dismantling the structure and depositing it onto the seabed
around the site of the operational structure.
Deep-sea disposal The removal and transport and of the structure for depositing at
a deep ocean disposal site where it would be effectively impossible for there to be any
further human interaction with the material comprising it.
Recovery The removal and transport to shore, and dismantling and re-processing or
landfilling, of all the components of the structure.

In the North Sea, not all these options are legal, and therefore currently relevant to the
industry in practice under the present regulatory framework, an issue that is discussed further
in Section 3.2. Apart from this issue, three of the above options have not been analysed
further in the report, for the following reasons:
Monitoring Appropriate monitoring will need to be part of any option that leaves
any materials in situ, and it has therefore been included in the discussion of the
options that envisage this, rather than considering it as a separate option.
Toppling There has been no or very little work done on this option relevant to the
larger steel structures being analysed in this report. Piper Alpha was toppled on safety
grounds after a serious explosion and fire made the structure unusable and dangerous.
These circumstances would make any data from the event of little more general use.
If it was discovered to be a technically feasible option for fixed steel structures,
toppling would have many similarities to the shallow disposal option but with
moderately lower material, energy and financial requirements. It would also have
very similar non-financial outcomes.
Deep-sea disposal There has been little work done on this option since the OSPAR
regulations made it effectively illegal, making it rather difficult to provide accurate
analysis of its cost and material basis. As discussed in Section 3.3, deep-sea disposal
is considered to have a significantly greater total energy requirement than shallow
disposal (154% of the toppling option), without having additional benefits, and it is
therefore excluded from further analysis on these grounds. This does not prevent
future analysis of the option using this methodology if it was later felt that there were
benefits unique to such an approach to decommissioning.

Table 3.4 presents an overview of the various decommissioning options considered later in
this report. For all of them, the assumption is that basic clean up (of hydrocarbons from the

17
structures oil and gas systems), well decommissioning and the clearing of debris from the
immediate surface of the seabed (i.e. not including the drill cuttings pile) will be undertaken
separately to decommissioning. Therefore these activities are not further considered here.
The Leave in situ options for the structure (T1, J1, F1, CON1) assume that nothing else is
done beyond these activities. Options T2, J2 involve shallow disposal of the structure. T3, J3,
F2, and CON2 entail recovery of the structure and its removal to shore for reprocessing or
disposal of its constituent materials. Option F2 (recovery of footings) has two possible
variants (F2a & F2b) depending on whether
F2a: the drill cuttings are left in place
F2b: the drill cuttings are removed.
This is important as the removal of the footings with the drill cuttings left in situ could
disrupt the drill cuttings with resulting release of hydrocarbons into the water column. This
difference will be apparent in the description of the approach to drill cuttings rather than in
the description of F2 itself. Hybrid options would be to cut the footings at the level of the
drill cuttings, which then might or might not be covered; or to dredge (using a suction
dredge) only those cuttings round the footings, so that the footings could then be removed.
The dredged cuttings could then be disposed of as discussed below, and the rest left
undisturbed, or covered, as desired. Because of lack of data, these options have not been
explored in detail, but they will be considered in the relevant place in the conclusions in
Section 8.

18
Table 3.4 Summary of Decommissioning Options

Decommissioning Options

Structure Component

Re-inject cuttings

Remove and treat

Excavate & cover
Excavate & leave
Shallow Disposal

cuttings onshore
Remedial action
Structure type

Cover cuttings
Bury pipelines

cuttings onsite
Leave in situ

Recovery

Re-inject
cuttings

cuttings

off-site
Topside T1 T2 T3
Jacket J1 J2 J3
Large
fixed steel Footings F1 F2(a, b)

Concrete Tank CON 1 CON 2

Pipelines P1 P2 P3 P4

Drill Cuttings C1 C2 C3 C4
Note: Only unshaded boxes contain options that are considered in detail below, for reasons that are given in
the text

There is little problem with removing small pipelines to shore, and only decommissioning of
larger pipelines is considered here. Pipelines may be left in situ (P1), recovered and removed
to shore (P2), subjected to remedial action (P3), which entails carrying out additional
activities (which might include a combination of: mechanical trenching, burying with sand or
rock, or removal and recovery of selected lengths of pipelines) to ensure long-term integrity
of the pipelines (Case Study A, ENV 02, p.16) or buried (P4). These options are all described
in more detail in Section 3.4.

With regard to drill cuttings, these may be left in situ (C1), covered (C3, with or without the
lowest part of the footings left in situ, as noted above) or removed and treated onshore (C4).
One further possible process for their removal is referred to as excavation. This entails
subjecting the drill cuttings pile to a low velocity, high volume flow of water which raises it
into suspension. Re-suspended material is dispersed into the surrounding water and carried
from the site with the prevailing current or tide and redeposited over a much larger area.
Following excavation, the site of the pile may be left (C2) or an attempt could be made to
cover the much larger area over which the cuttings have been deposited. However, this latter
option is not further considered here, because it would require an impracticable volume of
sand and gravel (estimated to be more than 8 million tonnes of sand and gravel combined).
Other options for drill cuttings are their re-injection into a well, at the same or a different site.
Some information on the re-injection of cuttings is presented below, but it is not one of the
options analysed in detail in this report, because it was not assessed in relation to Case Study
A and the available data relating to it is therefore not comparable to the data that has been
used for the other options. However, it will be assessed more generally as an option where
appropriate.

19
By referring to Section 3.1.2 and Annex 1, it will be noted that not all the decommissioning
options to be analysed in subsequent sections are currently permitted under the OSPAR
regulatory framework. In particular, T1,2 and J1,2 are not permitted under this regulatory
framework. They are therefore at present only theoretical, rather than available, options for
the North Sea and the rest of the OSPAR area.

It is at least part of the purpose of policy analysis to investigate the outcomes and
implications of current regulatory practices to see whether they appear to be appropriate. This
is the reason why currently prohibited decommissioning approaches have been included in
the analysis of this project, despite their only theoretical application to the OSPAR area. It is
hoped that the results of the analysis may be useful in ongoing discussions on the OSPAR
regulatory framework, or in relation to the regulation of other offshore oil and gas producing
areas.

However, it is also important that analysis of this kind should not be misunderstood,
especially in an area as politically sensitive as that of decommissioning. Because the rest of
this report is focused exclusively on the North Sea area, the various decommissioning
approaches to be analysed will be called scenarios rather than options, to emphasise that
their inclusion in this analysis does not imply either that they are currently available
approaches for the industry (which some of them obviously are not) or that they necessarily
should be available options. Some insights as to their desirability or otherwise may emerge
during the course of the analysis, but certainly no assumptions are being made about this in
advance.

3.2 THE REFERENCE SCENARIO

As noted above the purpose of this study is to compare, using flow analysis, various
decommissioning scenarios in respect of their material, energy, financial, environmental and
other non-financial outcomes. Such a comparison needs to be made against a common
reference scenario. Two factors seem important in the choice of such a scenario.

First it should be the analytically logical choice. If the purpose of the methodology being
employed is to enable comparisons to be made between the outcomes of the different
scenarios, then the important thing from this perspective is that the reference scenario is the
best in terms of the transparency with which it allows the comparisons to be made.

Second, the reference scenario should be as little as possible open to misunderstanding and
misinterpretation. While in fact the choice of a reference scenario says nothing at all about
this scenarios desirability, this may not always be perceived to be the case. In particular,
choosing the current North Sea regulatory framework as the reference may, from different
perspectives, be seen as an attempt either to reinforce or undermine it. Similarly, choosing a
different position from among the range of perceived possible alternatives may be seen as
making some statement about the desirability of the current regulatory position or about the
alternative being considered.

From an analytical point of view, the reference scenario should provide a common baseline
on which all the other scenarios can build. This then ensures that their outcomes can be

20
compared in as direct a way as possible, without having to add or subtract different elements
in order to arrive at comparable positions. From an interpretative point of view it is desirable
that the reference scenario is clearly an analytical construct so that it is obviously
differentiated from those decommissioning approaches which may be perceived as possible
social choices.

The reference scenario which has been chosen for this study is the starting point from which
any decommissioning takes place i.e. the structure (comprising the topside, jacket and
footings), pipelines and drill cuttings have only had the basic clean-up and clearance of the
surrounding area as described above. The structure, pipelines and drill cuttings themselves
are left in situ, with no further monitoring or maintenance, and this is how the term leave
in situ should be understood in what follows. This is not an option that is being proposed by
any of those who are involved in the debate about North Sea decommissioning. Moreover,
owners of rigs are not likely to be willing to accept ongoing liability for an un-maintained
structure which would eventually topple as the structure disintegrates. Furthermore, because
total topside clean-up would not be practical offshore2, leaving the topsides in situ would
ultimately lead to the depositing of hazardous materials into the marine environment, most
noticeably asbestos3. For all these reasons the reference scenario chosen here is not, and
should not be interpreted as, a realistic decommissioning scenario. It is simply a reference for
the purpose of comparison between other scenarios.

However, it is not necessarily the case (as is recognised by the current regulatory framework)
that some parts of the structure (e.g. the footings) or other materials involved in
decommissioning (e.g. the pipelines and drill cuttings) could not be left in situ as part of
decommissioning. Where a scenario envisages that any materials are left in situ, the
implications for the ongoing monitoring of these materials will be discussed under the
scenario concerned.

3.3 TOP SIDE, JACKET AND FOOTINGS

3.3.1 Energy assessment experience

The Institute of Petroleums guidelines for the calculation of estimates of energy use and
gaseous emissions in the decommissioning of offshore structures (IP 2000) considers the
direct energy in the recovery process as well as the energy used by other sectors to replace
the materials not recovered. The results of an assessment which includes the energy
requirement for replacing the material are shown in Table 3.5.

The report by Environment and Technology Ltd. (ERT 1997) took toppling as its baseline
scenario, because it had the lowest overall energy requirement of all the decommissioning
scenarios considered there. Table 3.5 shows that with the exception of the complete deep-
water disposal scenario, the total energy required for the decommissioning scenarios are

2
Industry sources, decommissioning interest network meeting of November 28th, 2003.
3
Industry estimates are that the ongoing maintenance of an abandoned topside would range from 1.5 - 5m per
annum.

21
comparable and within 14% of the baseline scenario and within the uncertainty surrounding
the energy requirement assessments (ERT 1997, p.10).

Deep-sea disposal of steel structures (originally proposed for the decommissioning of Brent
Spar) was revealed by the ERT study as the most energy-requiring scenario. Table 3.5 shows
its energy requirement to be 154% of the toppling (baseline) scenario if total energy
requirement is considered, including the energy requirement of replacing the materials not
recovered. Given that the extra energy requirement was greater than the estimated 30-40%
uncertainty in the assessment, deep-sea disposal of such structures was therefore shown by
these figures to be more energy-intensive than other scenarios. It should however be noted
that this result should not be applied directly to the Brent Spar case, because Brent Spar
differed greatly from the structures being considered here in that it contained a high
proportion of concrete and was a floating structure.

It is important when considering assessment of decommissioning scenarios that the level of

scenario development is considered. For example, the original assessment of scenarios for
Brent Spar decommissioning (1994/5) compared the relatively developed deep-sea disposal
scenario, with the mostly unknown conceptual scenario of onshore disposal (Brindley 1997).

Table 3.5 Comparative Energy Costs For Various Decommissioning Scenarios for
Steel Structures

% of Total energy
(Compared with toppling as baseline)
Scenario Replace- Recycling Direct Marine Total
ment Support
Toppling (Baseline) 53 9 16 22 100
Partial ashore and partial in-situ 37 17 16 31 101
Partial removal with partial in-situ and
59 5 17 25 106
creation of reef in other location
Complete removal ashore 11 29 21 53 114
Complete removal to deep water 58 7 21 68 154
Source: ERT 1997, Page 11 table 4
Note: Only the partial ashore/partial in-situ and the complete ashore scenarios are permissible under current
OSPAR regulations

3.3.2 Material, energy and value chain analysis

The analysis of offshore structures in this paper uses flow analysis, following the materials
through the decommissioning process, and looking at the energy inputs and the value of the
materials as their location and composition change through the recovery process. The
analysis to consider the energy requirement of decommissioning includes energy inputs such
as fuel used in support ships and cutting material, as well as the energy required to replace
the materials not recovered. Table 3.6 shows the kind of figures that could be used in such a
calculation.

22
In material flow analysis, a mass balance methodology is used to ensure that the sum of the
material inputs are accounted for in the outputs. This approach is paired with energy and
value chain analysis so that an assessment can be undertaken as to the value of the product
and waste material outputs, relative to the value of the material and energy inputs.

Table 3.6 Energy Requirement for Metal and Recycling Processes

Production Recycling from scrap

Metal GJ/T GJ/T
Page Page
(IP 2000, Table (ERT 1997) number
(IP 2000, (ERT 1997) number
6) GJ/T (ERT Table 8) GJ/T (ERT
1997) 1997)
Standard steel 25 20 5 9 10 6

Low alloyed steel 32 - - 9 - -

High alloyed steel 56 - - 9 - -

Aluminium 215 215 6 15 14 6

Copper 100 58 7 25 30 7

Zinc 65 - - 10 - -

General Approximately 15% of material designated for recycling will prove unsuitable. 11

Sources: IP 2000 & ERT 1997

For illustration, if a simplified example of whether to leave in-situ a single tonne of steel
from an offshore location is considered, the materials outcomes of the two basic
decommissioning scenarios, excluding associated fuels and emissions and assuming that 15%
of materials are not recoverable, are:

In-situ = 1 tonne on seabed + the raw materials associated with the generation of 0.85
tonnes of steel (e.g. iron ore)

Recovery = 0.15 tonnes of steel landfilled + 0.85 tonnes of recovered steel
Therefore the leave in situ scenario needs to consider the additional generation of 0.85 tonnes
of steel onshore.

The energy requirements in the two scenarios would be (adapted from IP 2000):

In-situ = energy required to generate 0.85 tonnes of steel replacement

Recycle = retrieval energy for 1 tonne of steel + energy required to recycle 0.85
tonnes of steel + energy required for the landfill of 0.15 tonnes.
The total energy requirement (TER) is the total energy required to return the materials to the
common material endpoint of the scenarios. Therefore, if the (retrieval energy + landfill
energy) < 8.5 GJ [0.85*(20-10) (assuming ERT 1997 figures)], then in energy terms at least
it would make sense to bring the structure onshore for recycling.

The value outcomes associated with such material flows would be:

In-situ = the value of the in-situ structure
(Possible financial benefits such as increase in fish stocks due to a fishing exclusion
zone, less the market valuation of residual liability)

Recycle = market value of 0.85 tonnes of recycled steel

23
The value of the landfilled steel is assumed to be zero as it no longer has any use and there
has been a financial transfer (the gate fee) associated with the transfer of liability and
therefore of any required monitoring. There will however be a non-financial (negative) value
associated with the impacts of landfill, which is not fully captured in the gate fee. This non-
financial component includes the value of the loss of landfill void space to future
generations, due to the additional landfill in the recovery scenario.

The 85% rate of recovery used in the example is merely used to illustrate the point. In reality
this picture would be far more complex with each of the various material flows having
different material and financial outcomes with different degrees of recoverability. The rate of
recovery of each material will be determined by what form the materials are in, as well as the
relative value of the material. For example, steel is used as a structural material and will
therefore be in a relatively pure form and therefore have a high rate of recovery. Copper on
the other hand, may well be dispersed within wires and therefore might have a relatively poor
rate of recovery, if it were not for its relatively high value.

If there are parts of the structure being re-used for purposes other than as oil or gas facilities,
the savings in energy and materials required to replace the materials used in the re-use have
to be considered carefully. For example, if parts of a structure are cut-up and used as a quay
or as sea-defence, the energy, materials and value which could be attributed to such a
structure would be equal to the energy materials and value of a structure which would most
likely have been built for such a use in the absence of the re-used materials.

3.3.3 Footings
For sub-structures weighing over 10,000 tonnes (out of the water), there is a possible
derogation from the OSPAR Conventions principle of removal of all structures from the sea.
Footings are defined as the jacket below the highest point of the piles. This derogation was
introduced as many of the large steel structures typical on the UKCS were not designed with
removal in mind, and there was some doubt about the technical feasibility and health and
safety implications of doing so. Under the terms of the derogation, it is the OSPAR member
country that is responsible for conducting a multinational stakeholder consultation for a
derogation to be granted. Once the footings have been cut and lifted onto a ship or barge, the
material and energy flow implications of decommissioning the footings can be considered in
a similar way to the topside. However, the energy used in association with cutting the
footings including any support ships would be included in the analysis. Any footings left in-
situ would still need to leave 55 metres below low-water surface level to ensure safe
navigation as set out in the International Maritime Organisation (IMO)s Guidelines (see
Annex 1). This requirement would therefore override the footings removal derogation offered
under OSPAR (although footings of a size to be eligible for derogation are most unlikely to
be in shallow water).

There is a further complication when the decommissioning of the footings is being

considered, concerning their interactions with the cuttings piles. Many of the cuttings piles
settled around the footings as they were discharged from the installation during drilling
operations. If it were decided to leave the cuttings pile in-situ, some, disturbance of the
cuttings piles would be inevitable when cutting the footings from the seabed (in a worst case

24
scenario 100% of the cuttings could be dispersed into the surrounding water and re-settle
over an area of several hectares, see Table 5.6). However, it was found to be possible to
remove the cuttings around the in-situ footings during the dredging trials around North West
Hutton (UKOOA 2002, Final Report, p.21, Q.53). Another possibility is to cut the footings
where they meet the cuttings pile with little disturbance to the pile more generally. The
interaction between footings and cuttings piles may therefore be summarised as follows:
If it were decided to remove the cuttings piles, this would be technically feasible
whether or not the footings were being removed.
The footings could be accessed and removed by only removing the cuttings
immediately around them, thereby avoiding considerable disturbance of the
cuttings.
It would be possible to cut the footings at the level of the cuttings pile, leaving the
residual footing in the cuttings pile, which might or might not then be covered,
and removing the rest of the footings to shore.
These interactions between the footings and cuttings piles need to be borne in mind when
decommissioning scenarios for the footings and cuttings piles are being considered. The
technical challenges of all these operations, involving the cutting, excavation and removal of
large quantities of metals and others materials from the deep seabed, should not be
underestimated. Given that it has never yet been undertaken, there is obviously the possibility
of unforeseen complications and consequent economic (for example, in respect of costs),
social (for example, in respect of health and safety) and environmental (for example, in
respect of disturbance of the cuttings piles) impacts.

There is some evidence that at present the structure acts as refuge for fish and habitat for
cold-water coral, something that is discussed in more detail in Section 5.1.4. This effect
would obviously cease if the structure were to be removed and fishing in the area were to be
resumed (there is currently a 500m radius fishing exclusion zone around structures).
However, if left in-situ, the footings could pose a hazard to trawler fishing, and this would
probably prevent extensive trawling activities around the in situ footings. In the absence of
the footings the cuttings piles are more likely to be disturbed by trawler fishing activities.
The implications of disturbing the cuttings piles would be the potential release of oil-based
contamination into the marine environment.

3.4 PIPELINES

At present the decommissioning of pipelines is not regulated by the OSPAR Convention. A

framework for the decommissioning of offshore pipelines is provided under the 1998
Petroleum Act, and safety issues are covered by the 1996 Pipeline Safety Regulations (DTI
2002, par 10.1). The decommissioning of pipelines is considered case by case based on
comparative assessments of all scenarios. As noted above, small pipelines are removed fairly
easily to shore, so that it is only the decommissioning of larger pipelines that is considered
here.

3.4.1 Decommissioning scenarios

Important issues when assessing the decommissioning scenarios for oil and gas pipelines are
whether the pipeline is presently trenched or covered, and if so, the status of the coverings
and the prospects of the pipelines being uncovered in the future. This is important as exposed

25
pipelines can pose a risk to trawling operations. As discussed above (see Section 3.1.6) the
potential scenarios available are:

1. leave in-situ (P1);

2. leave in-situ and undertake remedial action including partial selective burial, covering or
removal to reduce the risk to fishing activities (P3);
3. trench and bury (P4); and
4. recover and take to shore (P2).

If recovery of pipelines is desired, for smaller pipelines this can be effected relatively easily
in a reverse process to that which laid them. This is by turning the pipeline around a very
large reel on the same type of vessel which laid the pipeline (AURIS 1995, page 5.12). For
less flexible pipelines, they may be cut and made buoyant and towed to shore, or cut and
lifted onto a vessel (AURIS 1995, page 5.12).

3.4.2 DTI guidelines

The DTI decommissioning guidelines (DTI 2001, pp.26, 27) set out the decision-making
framework for the consideration of the decommissioning of individual pipelines:

all feasible decommissioning scenarios should be considered and a comparative

assessment made;
any removal or partial removal of a pipeline should be performed in such a way as to
cause no significant adverse effects upon the marine environment;
any decision that a pipeline may be left in-situ should have regard to the likely
deterioration of the material involved and its present and possible future effect on the
marine environment;
pipelines can be left in-situ if due to structural damage or deterioration or for other causes
they cannot be recovered safely and efficiently; and
account should be taken of other uses of the sea.

3.4.3 Risk to trawling activities

An important potential impact of leaving any pipeline in-situ is the risk posed to the trawler
fishing fleet. A modelling exercise (AURIS 1995) was undertaken to try to estimate the
number and type of interactions with pipelines if all of the pipelines on the UKCS were
decommissioned by leaving them in-situ. The results of the assessment, shown in Table 3.7,
combines the modelled number of interactions with any pipeline (based on 1983 amounts of
fishing and assumed random fishing patterns) with estimates of the deterioration of the
decommissioned pipelines.

Table 3.7: Estimated Number of Interactions1 Between Fishing Gear and Pipelines
Per Year

Year 10 Year 30 Year 50

Any part of pipeline 36,000 36,000 36,000
Exposed sections 15,000 14,000 13,000
Spanning sections 500 1,200 1,300

26
Section with a break1 20 50 140
Source: AURIS 1995, p.6.28
1
Interaction in this context includes passage over buried as well as unburied pipelines.
2
As the pipelines age, decay and rust, breakages in the pipelines could occur, potentially leaving jagged edges.

It is important to note that by no means all interactions between fishing gear and pipelines
result in any noticeable impact. Indeed, only broken sections (or spanned sections which are
broken during the interaction), or very large uncovered pipelines could plausibly lead to a
snagging incident and therefore pose a safety hazard. It is also useful to put these interactions
in context with snagging hazards posed by and interactions with offshore objects, most
noticeably wrecks. These are shown in Table 3.8.

Table 3.8: Estimated Number of Interactions Between Fishing Vessels and Other
Objects on the Seabed

Object Potential interactions per year

Operational submarine cables 26,000
Wrecks 48,000 (likely to be more)
Pipelines 36,000
Source: AURIS 1995, p. 6.28

3.4.4 Material, energy and value assessment of pipeline decommissioning

The material, energy and value assessment of decommissioning pipelines is similar in form
to the assessment of the decommissioning of main structures. The key difference is that the
in-situ scenario may have significant material demands, if the pipeline is to be covered with
rocks (scenario P3). A 36 pipeline would need to covered by 0.5 metres of rocks, which
would require a pile 3 metres either side and therefore an estimated 4,000 m3 of material per
kilometre (AURIS 1995, page 5.14). A further consideration is the relatively dispersed nature
of pipelines, and whether the material, energy and value benefits of recovering such
dispersed material justifies the material, energy and financial cost associated with such
recovery. No energy analysis of the decommissioning of pipelines can be found in the
literature.

3.5 DRILL CUTTINGS

Drill cuttings piles are created by solid waste discharges onto the seabed during well-drilling
operations. Historically, the drilling muds used in the drilling process were oil based and
therefore the cuttings have hydrocarbon contamination, as well as often containing traces of
heavy metals, PCBs and radioactive material from the bed and cap rock. It is estimated that
there are 1.3 million cubic metres of cuttings accumulated on the North Sea seabed of the UK
and Norwegian continental shelves (Wills 2000, p.59).

Research undertaken in this area includes a research programme commissioned by UKOOA

(UKOOA 2002), which carried out a number of case studies, the most significant of which
were around the North West Hutton, Beryl A and Ekofisk 2/4A structures, in order to
identify the best available techniques and best environmental practice (BAT and BEP) for
these cuttings. Gerrard et al. (1999) also investigated as a case study the North West Hutton
pile which, with a volume of 25,225m3 and a mass of 42,126 tonnes, is one of the larger
piles.

27
The report, UKOOA 2002, is presented in question-and-answer format. The four main
decommissioning scenarios considered by the report were:

I. Dredging of the cuttings with offshore processing;

II. Dredging of the cuttings with onshore processing;
III. Covering and leave in-situ with monitoring; and
IV. Leaving in-situ with monitoring.

Table 3.9: Energy Requirement and Cost Estimates for Cuttings Piles Management
Strategies

Strategy Description Estimated energy Estimated cost

number
Related GJ per m3 Page, per m3 Page,
scenario Question Question
numbers numbers

Component Dredging of cuttings Required

0.07 20,50 300 20,49
of I & II (no treatment) for C4
Re-injection of slurry
IA 1.8 22,58 550-1,200 22,57
(Total)
Enhanced 2,650-
IB 122 17,30 17,31
bioremediation (Total) 5,000
IIA Landfill cuttings (Total) ~0.1 20,50 550 23,70
Onshore treatment of
IIB C4 6.7 23,66 ~1,500 23,65
cuttings (Total)
III Covering in-situ C3 5 19,44 240-1,000 19,43
C1 with
IV Leave in-situ negligible 16,21 25-100 15,20
monitoring
Source: UKOOA 2002

Table 3.9 shows the energy requirements and cost estimates for the different scenarios. Not
surprisingly, no treatment at all of the cuttings (IV) requires the least energy and entails the
lowest costs (as the only operation required would be monitoring). Next in energy
requirement is dredging and landfilling the cuttings, which costs five to twenty times as
much as leaving them in situ. Re-injection of the drill cuttings requires more energy, and
covering the cuttings in situ, or treating them onshore, requires more energy still, with re-
injection and onshore treatment being more expensive than the landfill scenario. Easily the
highest requirements, in terms of both energy and cost, are associated with the
bioremediation scenario. The next sections discuss the nature of drill cuttings piles and the
decommissioning issues raised by them, in more detail.

3.5.1 Characterisation of cuttings piles

There is an estimated 1.3 million cubic metres of cuttings piles in the North Sea as a whole
(Wills 2000, page 59, par 1). Gerrard et al. (1999, p.8) estimate that the total inventory of
hydrocarbons in cuttings piles is similar to the annual input into the North Sea from all
sources. It is estimated that the oil in the 6 largest oil-based mud piles represents 24% of the
total mass of oil in piles in the UK. An important finding of the sampling stage of the

28
UKOOA study was that the cuttings piles are highly heterogeneous both in shape and
content. However, the study was able to provide an indication of the nature and impacts of
legacy as it stands.

Task 2B of the UKOOA drill cuttings study (UKOOA 2002) assessed the environmental
impacts of oil-based mud (OBM) and water-based mud (WBM) drill cuttings piles. The
independent Scientific Review Group (SRG) for this study regarded this Task 2B as a well-
executed study, and noted and appeared to endorse its findings: The results indicate that
the present effects of existing piles are highly localised, and the spatial extent of the areas
affected is a small percentage of the total [UKOOA 2002 actually showed it to be about
1,000 km2 on the UKCS out of the total North Sea area of about 700,000 km2, which may be
compared with the 130,00-370,00km which is estimated to be trawled annually UKOOA
2002, Task 2B, p.2]. The total quantities of hydrocarbons in the piles are substantial (about
150,000 tonnes), but these are largely immobilised and are only being removed very slowly
by erosion, degradation and leaching (over several or many decades). The rate of release to
the wider environment is therefore small in relation to the amount of hydrocarbons from
other sources (e.g. rivers). (SRG 2002, p.8)

Water column and food chain impacts

Much of the evidence for impacts of the present cuttings pile is based on laboratory based
work. However, surveys carried out at the cuttings piles around Case Study A found the
presence of PAHs and PCBs at greater concentrations than their relevant Ecological
Assessment Criteria (EAC), where EACs are defined as the concentration of a substance in
the marine environment below which no harm to the environment or biota is expected (Case
Study A, ENV05, p.17). These concentrations of PAHs and PCBs therefore represent
theoretical risks of harm, extrapolated from known toxic concentrations. Also, octyl and
nonyl-phenols were found at relatively high concentrations close to the platform. These are
thought to have oestrogen-mimicking effects, and there have not so far been any no-harm
safety threshold concentrations set for these chemicals (Case Study A, ENV08, p.20). It will
be important to ascertain whether these potentially harmful concentrations of toxic chemicals
are found around other drill cuttings piles.

Task 2C of the UKOOA drill cutting research programme (UKOOA 2002) was designed to
investigate the water column and food chain impacts of drill cuttings piles, using a
laboratory-based bioaccumulation study, sediment analysis and toxicity testing. The
bioaccumulation study utilised an artificial ecosystem (mesocosm) representing the sediment
(either OBM drill cuttings material or reference North Sea sediment) and overlying water.
However, the report stated: It should be stressed that the laboratory toxicity tests are not
directly analogous to the in-situ conditions. In particular it may be noted that the laboratory
tests investigate disturbed sediment which is not necessarily the case in the field. A further
point to note is that a vast volume of seawater overflows the cuttings piles in the field
situation; therefore a negligible proportion of this overall volume will come in contact with
the cutting material (UKOOA 2002, Task 2C, Executive Summary).

29
The key findings of the UKOOA (2002) Task 2C study were broadly reassuring, finding that
none of the concentrations of potentially toxic substances (including PAHs [polyaromatic
hydrocarbons], metals, endocrine disruptors and NORM [Naturally Occurring Radioactive
Material]) appeared likely to result in an adverse effect on biota; that there was no
incremental bioaccumulation effect through the water column or through the sediment with
OBM versus reference sediment; that there was no biomagnification of the PAHs, heavy
metals, or NORM; and that there was no bioaccumulation in the fish species studied (turbot),
perhaps because due to the action of their known detoxification systems. There was a toxic
response in the OBM (but not WBM [water-based mud]) sediments, relative to the reference
sediment, but it seemed likely that this was due to a smothering effect from the total
hydrocarbon content (THC) rather than any physiological effects from the contaminants. The
toxicity results also indicate that the potential for water column effects, albeit on a very
minor scale in volumetric terms, exist if the OBM sediments are disturbed.

The Scientific Review Group (SRG) for the UKOOA (2002) study was not uncritical of the
way the Task 2C study had been carried out. It considered that the finding that hydrocarbons
tend to be assimilated by but not accumulated in the organisms to be not surprising, but
also considered that, in respect of other contaminants, further longer term and/or in situ
experiments will be required to resolve the matters satisfactorily (SRG 2002, p.9), where
the matters here refer to food chain contamination. This issue is referred to again in
connection with Case Study A in Section 5.1.4.

3.5.2 Dredging of cuttings scenarios

Strategies I and II as listed above rely on the dredging of the drill cuttings from the cuttings
piles. The favoured technology for this was found to be suction dredging the material. The
result of this is a slurry containing solids and seawater that would need to be dealt with using
strategies as described in the following two sections. The ratio of sea water to cuttings varied
greatly during the trials undertaken around North West Hutton. Ratios of 10:1 to 20:1 water
to solids were typically experienced (UKOOA 2002, Final report, Q46, p.19). It is believed
that, if operated in a real-life situation, further experience of the process, and its continuous
operation, would enable these ratios to be reduced.

During the dredging, there was little evidence of pollution of the water column beyond the
immediate plume, and no discernible impact at a distance of 100m (UKOOA 2002, Final
report, Q.48 p.20). There was however re-suspension during back washing of the suction
tube during times of blockages. The study also concluded that the cuttings could be removed
from around the footings whether or not these were going to be left in situ.

Strategy I Offshore processing:

A. Re-injection of slurry minimal treatment of the slurry to permit the re-injection into an
existing or dedicated well. Gerrard et al. (1999. p.10) found re-injection to have the
lowest environmental impacts of any disposal scenario, but acknowledged that on a large
scale it might be slow, and suffer from logistical difficulties. It might also increase energy
use and atmospheric emissions. In addition, this scenario may not presently be permitted

30
 (UKOOA 2002, Q.58, p.55) under the OSPAR convention due to the more general
restrictions on the dumping of waste at sea.
B. Enhanced bioremediation of cuttings (UKOOA 2002, Task 5a, p.51) relies on several
reactor vessels on the seabed with a supply of oxygen, bacteria and warm water, from
support operations either on the associated installation or a ship. The liquids would be
lifted to the surface and treated before being discharged offshore. The solids would be re-
deposited on the seabed after bioremediation. Gerrard et al. (1999, p.9) did not consider
that offshore bioremediation was practicable, but technology might have made it more so
in the interim. However, as noted above, this is a very costly scenario and requires by far
the largest consumption of energy (122 GJ per m3 compared to the next highest scenario
which is onshore treatment which requires 6.5 GJ per m3). Moreover, the process would
only operate in the summer, and could take 5 years for a 6,000 m3 pile and some 20 years
for some of the larger piles. (UKOOA 2002, Final report, p.18) It is not impossible that,
in the longer term, technological developments may reduce some of these obstacles to
bioremediation.

Both re-injection and enhanced bioremediation therefore face serious practical constraints at
the present time, which is why they have not been considered in the detailed practical
assessment in Section 6. However, were these constraints to be reduced or removed through
technological advances, and were their relatively high cost to be considered justified by their
environmental benefits, then they could become worthy of serious consideration, and this is
noted in Section 8.

Strategy II Onshore processing

These scenarios rely on the shipping to shore of either the liquefied slurry, or alternatively
just the solids if the water can be separated and treated offshore. The scenarios are:
A. Landfill of solids with minimal processing this offers the cheapest and simplest of
the onshore strategies both in terms of energy and cost. At present, there is only one
landfill site licensed to receive oily solids (Stoney Hill near Peterhead) (UKOOA
2002, Q.23, p.67). A dedicated site could be developed and if well maintained it
would not pose a significant environmental threat (UKOOA 2002 Qs.23, 68 & 69).
However, it is likely that the EU Landfill Directive will reduce the opportunity to
dispose of untreated, contaminated cuttings, some of which, if not the majority, will
be classified as hazardous waste in future (UKOOA 2002, Task 7, p.25).
B. Processing of solids contained within the contaminated sludge, with an aggregate-like
material as the material output, which might be used as a low-grade construction
material. This scenario was not thoroughly evaluated in the UKOOA study although
the Task 7 report (UKOOA 2002, p.57) does refer to and comment on it. Also it was
not made clear whether onshore bioremediation is proposed, in which case the sludge
would only contain heavy metals and possibly PCBs (and not hydrocarbons). It
should be recognised that if onshore and/or offshore processing became well-
established as part of a large-scale decommissioning programme, the processes
involved might well become relatively less costly. However, there are no estimates of
this in the Case Study A material, so these possibilities could not be considered in
detail.

31
Viability of all lifting scenarios

Task 7 (UKOOA 2002, 57) investigates the viability of the various combinations of
scenarios. It concluded that of the strategies described above, only Strategies IA and IIB (re-
injection of slurry and onshore treatment respectively) were considered viable. Strategy IA
would be viable for about 25% of the cuttings piles on the UKCS, due to the availability of
suitable wells, and would require a change in the restriction under the OSPAR convention on
the depositing of waste out to sea. Of the onshore scenarios, both Strategy IIA and IIB seem
legal at present. However there are a number of technological gaps and regulatory
uncertainties, with further uncertainties about the onshore environmental impacts.

3.5.3 Leaving in-situ scenarios

The alternative group of strategies avoids disturbing the cuttings piles and leaves them in-
situ. There is potential for some of the toxic aromatic compounds found in older cuttings
containing OBM to pass into some benthic organisms found on the seabed (UKOOA 2002,
Task 2c). Grant & Briggs (2002) found that the drill cuttings piles around North West Hutton
were a source of toxicity to two invertebrate benthic organisms. They further found that the
most important cause of the toxicity was hydrocarbons (with polar organics, sulphide,
ammonia and other water-soluble substances of much lower significance). However, as noted
above, if these entered the food chain, they would very largely be broken down by
vertebrates detoxification mechanisms (OPG 2002, p.1), so that they should not be passed
on through the food chain.

Strategy III Covering cuttings piles (UKOOA 2002, Task 5b, pp.54 & 55):

Covers can be placed using proven construction methods. They should comprise an initial
layer of sand followed by a gravel filter layer and an outer protective layer of armour stone.
The issues raised by such a scenario as are follows:
Development: At present, there is no proven method of construction underneath existing
installations although it is likely that methods could be developed.
Application: Covering is not considered viable for piles around the footings of structures
that are fully removed, because, as noted above, the removal process may disperse the
cuttings over too wide an area for covering to be feasible. It is however a possible
scenario for fully and partly removed steel structures (for example, if the footings were
cut off at the level of the cuttings pile) and, possibly, partly removed concrete structures.
Pile stability: Many piles may be only marginally stable. It is envisaged that there would
be a need to build-out steep concave pile slopes and to reduce the slopes of steep
conical piles by varying the thickness of the initial sand layer. This would ensure pile
stability and provide a suitable slope for armour stone of a size which can be placed using
existing plant. An alternative approach may be to remove the tops of some piles prior to
covering.
Construction leachate: short-term releases may occur during construction due to cuttings
disturbance when placing the initial sand layer. Leachate analyses and ecotoxicology tests
using samples recovered from the Ekofisk and Beryl A piles, in combination with

32
 estimates of potential rates of release during construction, indicate that dilution of the
released leachate will be rapid and that the risk of acute or chronic toxic effects will be
very low. Limited data from other cuttings piles suggests that this conclusion may apply
to a majority of piles.
Long-term stability: The armour layer will provide adequate short-term protection
against the impacts of severe storms, trawling and collapse of parts of partially removed
structures. It is not practical to provide guaranteed long-term protection against the
cumulative effects of trawling, emergency anchoring by large vessels and repeated
structure collapse events, particularly in the case of part-removed concrete structures.
Permeability of cover: In the long term, contaminants will be released due to chemical
migration and by pore water exchange caused by a pumping action induced by waves.
However, the volumes of contaminants associated with this rate of release is expected to
be negligible.
Monitoring and maintenance: both would be required, but the details are not as yet
determined.

A risk review (UKOOA 2002, Task 5b, p.12.1), investigating strategic and operational,
environmental and health and safety issues, concluded that, as long as the covering
succeeded in physically isolating the cuttings for the period during which they pose a threat
to the environment, it is generally a low-risk scenario. The integrity of the covering will be
determined by the size of disturbances rather than any predictable degradation process. The
degree of protection afforded by the covering (and therefore the degree of physical isolation
of the covering) were assessed to be: medium for trawling activities; moderate for the
eventual collapse of any in situ structure; and low for extremely rare emergency anchoring
impacts (UKOOA 2002, Task 5b, p.13.5). Furthermore, the industry believes it can be
achieved by developing proven methods of construction and with little or no adverse impact
on the marine environment (UKOOA 2002, Task 5b, p.13.5).

Strategy IV Leave cuttings piles in-situ in present form

This strategy, which is permitted under the DTI guidelines and which is not covered by
OSPAR, is taken as the reference scenario against which all other scenarios have been
compared.

The effects of in situ cuttings piles consist of changes in benthic and faunal communities
around installations as shown by reductions in indices of diversity (UKOOA 2002, Task 2b,
p.25). However, as noted above, the organic components of cuttings piles is thought to be
largely be broken down by vertebrates detoxification mechanisms, therefore limiting
bioaccumulation in fish. More recent work on the current state of drill cuttings piles, and the
implications of leaving them in situ, have been carried out in connection with Case Study A,
the drill cuttings pile of which is likely to be similar to other large piles in the same part of
the North Sea.

Historical surveys at Case Study As cuttings pile found that a diversity index value
considered to be typical of undisturbed communities in this area of the North Sea was
reached within:

33
 800-1200m from the centre of the pile in 1992;
400m from the centre of the pile in 1997; and
300m from the centre of the pile in 2002 after 10 years of natural degradation.
The recovery observed was a shift in species from opportunists to those which are
characteristic of less disturbed environments (Case Study A, ENV08, p.22).

The pile is expected to decrease in size by 40% over a 1,000 year time period, and there is
expected to be an approximate 36% degradation in the THC over the same time period. (Case
Study A, ENV01, p.10.44). However, this estimate remains very uncertain, as it is sensitive
to a number of parameters whose magnitudes are also uncertain (IRG, 2004, p.21). A factor
not considered in the modelling of the long-term fate of the cuttings pile at Case Study A was
that of the effect of the footings. The relevant report did speculate that, based on expert
judgement, local turbulence which may be seen around the footings when left in place may
reduce the entombment effect [crust] and cessation of biochemical activity at the pile. This
may reduce the predicted physical and chemical persistence of the pile in the long term.

Overall, the Independent Research Group (IRG) reviewing and commenting on the studies
undertaken for Case Study A in respect of drill cuttings piles left in situ concluded that:

The recovery processes will be confined to a thin surface layer and to the periphery of the
pile for a very long time, and the areas affected, which are quite small, should
realistically be accepted as being environmentally damaged for the foreseeable future.
There is no reason to regard cuttings piles as a major long-term threat to the environment.
They have caused significant damage to small areas of the seabed, which will persist with
only slow amelioration if they are not covered or removed.
Neither the levels of confidence achievable in quantitative predictions of the fate of the
seabed environment after decommissioning, nor the extent of difficulties in dealing with
cuttings which may be removed to shore, should be overstated. (IRG 2004, p.9)

34
4. ASSUMPTIONS FOR THE FLOW ANALYSIS

4.1 FINANCIAL EXPENDITURE ASSUMPTIONS

The financial expenditures required to recover and process a large steel structure considered
in this report are based on early estimates of decommissioning expenditures made for Case
Study A. These estimated financial expenditures only cover the costs of reprocessing a large
steel structure after well decommissioning and basic clean up (i.e. building on the reference
scenario), in line with the scope of the analysis. The extent to which Case Study A may be
considered typical of large steel structures is discussed in Section 7. Despite uncertainties it
was not possible to present the numbers as a range, as would have been desirable, and the
numbers have been cited as given in the source. This should not be taken to imply that they
are either certain or precise.

Table 4.1 (in which the costs are given in Norwegian kroner) shows that the costs attributed
to the removal of the topsides and jackets of Ekofisk (Case Study B) were 50% and 74%
respectively of the total removal, transport and demolition costs (highlighted in Table 4.1).
The estimated financial expenditures required to remove and deposit the topside and jacket of
large steel structures in shallow water are calculated by scaling down total recovery and
process costs estimates from Case Study A to these proportions4. Thus, in Table 4.2, the
shallow disposal of the topside is assumed to cost 50% (19m) of the total recovery costs
(37m).

Table 4.1: Proportionate Removal Costs

Topside Jacket
Removal Remove
Component Million kr % Million kr %
Project admin. and engineering
Preparations
Removal 820 50% 1,860 74%
Transport 550 33% 570 23%
Demolition 280 17% 95 4%
Total cost 1,650 100% 2,525 100%
Source: Case Study B, ConocoPhillips 1999

4
It is very likely the cost of removing a smaller platform would not be directly proportional to the cost of a
larger platform, and might vary by + or 10/20%.

35
Table 4.2 Summary of Financial Expenditure Assumptions [2003, million]

Decommissioning scenarios

(reference scenario)

Remove and treat

Excavate & cover
Excavate & leave
Shallow disposal

Re-inject cuttings

cuttings onshore
Remedial action

Cover cuttings
Bury pipelines
Leave in situ

Recovery

cuttings

cuttings
Structure
Structure type Component
Topside 191 37
1
Jacket 23 31

No expenditure
Large fixed steel
Footings 0.22 30
Total 42 98
Concrete Tank 3103
Pipelines Pipelines 15.2 1.8 2.5
Drill Cuttings ~40,000 t 54 10.2 39
Notes:
1
As noted in relation to Table 3.4, the shallow disposal of topsides and jackets is not permitted under the OSPAR
Convention
2
Shallow disposal of footings is not further considered here. It is assumed that the footings would be left in situ in a shallow
disposal decommissioning scenario.
3
The financial expenditure to reprocess the Ekofisk Tank was estimated to be 3,400 million 1998 Norwegian Kroner
respectively (ConocoPhillips 1999, p.137). This was converted into 1998 sterling (@12.50, Norges Bank) and then by use of
a UK GDP 1998Q1 2003Q1 deflator factor of 114% (ONS) the value of 1998 Kroner can be given in terms of 2003
sterling. This yields an overall conversion factor of 20030.0912 per 1998Kr.
4
The financial expenditures for the excavate and leave drill cuttings scenario is based on a ship day rate of 38,000 + the
cost of aggregates.

As noted in Section 3.2, leaving the whole structure in situ (the reference scenario) is not a
realistic decommissioning scenario (even if it were permitted under the OSPAR regulations,
which it is not). Table 4.2 shows that, compared to the reference scenario, the total costs of
recovering and recycling a large steel structure are estimated to be 98m. The cost of the
shallow disposal of such a structure would be 42m. The potential savings have to be
considered with reference to the value of the recoverable material, as well as any wider
benefits derived from recycling the structure. The financial expenditure involved in
recovering a large concrete tank is estimated to be 310 million at 2003 prices.

The financial expenditures involved in removing the pipelines relating to the large steel
structure of Case Study A are a little over 15m, for 26 km of pipelines (there is a total of
9,400 km of pipelines in the North Sea area [DTI 1999, Appendix 11). The financial
expenditures to manage the drill cuttings under the large steel structure of Case Study A
range from zero to leave the cuttings in situ, to 39m to recover, process and landfill the
cuttings onshore. This compares to the JIP estimate of 60m (UKOOA 2002, p.23, question
65), based on a per tonne cost estimate of 1,500. The drill cuttings pile investigated in Case
Study A was large at 40,000 tonnes and therefore the 39m estimate deriving from this case
study would suggest either the use of cheaper removal techniques, or considerable economies
of scale.

36
4.2 MATERIAL FLOW ASSUMPTIONS

The flow and endpoints of the materials being decommissioned determine the:

1. Overall cost of the decommissioning process;

2. Input materials required in the decommissioning process and therefore the energy,
emissions and the value of this input material; and
3. Material processing requirements, and therefore the corresponding energy, emission
and value implications of the onshore processes.

The rates of material recovery are derived from the study of Ekofisk (Case Study B), which
was clear in respect of the endpoints of the material (these figures are presented in Tables
4.3, 4.4). This comprises 13 smaller production platforms which do not have fixed footings
like the large steel platforms which are the main focus of analysis here. However, the
materials in the footings of large steel structures are of similar composition to those found in
the jacket. Therefore the rates of material recovery (for each metal type) found for the jackets
of Case Study B have been applied to both the jacket and the footings of large steel structures
(see Table 4.5).

Table 4.3 shows the summary totals from Table 4.4 of the amounts of different materials
involved in the decommissioning of the Ekofisk series of platforms, and the rates of recovery
(recycling for the metals) which were achieved. There was 100% recovery of steel,
aluminium, copper and ballast (aggregates). Overall 85% of both plastics and concrete was
also recovered. Of electrical materials (such as electrical articles, instruments, cables and
telecom equipment) in the topside, only 10% was recovered. No asbestos or marine growth
were recovered. The flows are dominated by the quantity of concrete from the tank, which, at
1 mt, comprised 77% of the total material flow. In total, 92% of the total material flow was
recovered, amounting to 1.2 mt of materials. The remaining 107,000 tonnes of material was
to be sent to waste disposal facilities; this is here interpreted as going to landfill.

Table 4.3: Summary of Total and Recovered Materials from Decommissioning of

Ekofisk

Total, t Recovered, t Waste, t % Recovery

Topside 103,670 96,463 7,207 93
Jacket 78,620 70,048 8,572 89
Tank 1,049,834 966,134 83,700 92
Pipelines 88,271 80,327 7,944 91
TOTAL (inc. 1,320,395 1,212,972 107,423 92
marine growth)
of which
Non-metals 1,069,015 972,292 20,423 91
(excl. marine
growth)
Source: Table 4.4

37
Table 4.5 then applies these rates of recovery for the different materials to the materials
involved in Case Study A, for the two main decommissioning scenarios, Leave in situ and
Recovery. In the former case, the material that would have been recovered has to be replaced
from other sources, as discussed above, and this is shown in the Replaced column.

Table 4.5 shows that 42,500 tonnes, 94%, of the structure of Case Study A is steel, which can
be recovered if the structure is returned to shore. In contrast, if the 40,000 tonnes of cuttings
are returned to shore, they all need to be landfilled.

Table 4.6 gives various estimates, from various sources, of energy and emission factors, and
the market values of energy and materials, which have been used in the assessment.

38
Table 4.4: Rates of Recovery from Ekofisk (Case Study B)

Topside Jacket Tank Pipelines

% Recovery

% Recovery

% Recovery

% Recovery
recovered t

recovered t

recovered t

recovered t
Waste t

Waste t

Waste t

Waste t
Total t

Total t

Total t

Total t
Steel 92,000 92,000 0 100% 63,000 63,000 0 100% 46,000 46,000 0 100% 35,000 35,000 0 100%
Aluminium 100 100 0 100% 920 920 0 100% 94 94 0 100% 9 9 0 100%
Copper 2,900 2,900 0 100% 2 2 0 100%
Zinc 25 25 0 100% 40 40 0 100% 590 590 0 100%
Concrete 770 547 223 71% 7,000 5,903 1,097 84% 520,000 440,000 80,000 85% 51,000 44,654 6,346 88%
Ballast 200 200 0 100% 480,000 480,000 0 100%
Electrical 1,300 130 1,170 10%
Plastics 925 786 139 85% 80 72 8 90%
Asbestos 260 0 260 0% 90 0 90 0%
Other 5,415 0 5,415 0% 475 0 475 0% 1,500 0 1,500 0%
Marine growth 7,000 0 7,000 0% 3,700 0 3,700 0%
Total non-metals
(excl. marine
growth) 8,670 1,463 7,207 17% 7,675 6,103 1,572 80% 1,000,000 920,000 80,000 92% 52,670 44,726 7,944 85%
Total 103,670 96,463 7,207 93% 78,620 70,048 8,572 89% 1,049,834 966,134 83,700 92% 88,271 80,327 7,944 91%
Source: Case Study B, ConocoPhillips 1999, various tables.

39
Table 4.5: Proportions of Materials from a Large Steel Structure Assumed
Recovered
Note: The table is derived from the material inventory provided by Case Study A, to which the rates of recovery
of different materials from the decommissioning of Ekofisk have been applied.

RETURNED TO SHORE AND PROCESSED LEFT IN SITU

Totals % Recovered Recovered Landfilled Left in situ Replaced
t % t t t T
Topside
Steel 20,000 100% 20,000 0 20,000 20,000
Aluminium 20 100% 20 0 20 20
Copper 200 100% 200 0 200 200
Non-metals 300 17% 51 249 300 51
Totals 20,520 99% 20,271 249 20,520 20,271
Jacket
Steel 9,000 100% 9,000 0 9,000 9,000
Aluminium 500 100% 500 0 500 500
Copper 0 0% 0 0 0 0
Marine growth 700 0% 0 700 700 0
Totals 10,200 93% 9,500 700 10,200 9,500
Footings
Steel 10,000 100% 10,000 0 10,000 10,000
Aluminium 300 100% 300 0 300 300
Copper 0 0% 0 0 0 0
Marine growth 1,000 0% 0 1,000 1,000 0
Total 11,300 91% 10,300 1,000 11,300 10,300
Pipelines
Steel 3,500 100% 3,500 0 3,500 3,500
Aluminium 50 100% 50 0 50 50
Copper 1 100% 1 0 1 1
Concrete 1,800 88% 1,576 224 1,800 1,576
Total 5,351 96% 5,127 224 5,351 5,127
Total excl cuttings
Steel 42,500 100% 42,500 0 42,500 42,500
Aluminium 870 100% 870 0 870 870
Copper 201 100% 201 0 201 201
Other 3,800 43% 1,627 2,173 3,800 1,627
Total 47,371 95% 45,198 2,173 47,371 45,198
Cuttings
Cuttings 40,000 0% 0 40,000 40,000 0
Total 40,000 0% 0 40,000 40,000 0

40
Table 4.6: Various Estimates of Energy and Emissions Factors, and Market Values
of Energy and Materials
Assumption Energy Value CO2 NOx SO2 Sources
Fuel GJ/t /t t/t of fuel input
Marine diesel (default) 43.1 237 3.2 0.0594 0.012 Dti
Road diesel 43.1 986 3.2 0.0594 0.012 Dti
Heavy oil 40.6 92 Dti
Aviation fuel 46.1 IP 2000
Iron and steel coal 29.4 IP 2000
Operation per t material GJ/t t/t material
Fabricating temporary
steelwork 0.22 Energy from electricity IP 2000
Hot cutting 0.05 0.0033 IP 2000
Hydraulic cutting 0.5 0.0368 0.0007 0.0001 IP 2000
Overall dismantling
operations 1.15 Energy from electricity IP 2000
Cuttings processing 1.52 3.19
Lorry transport 0.56 3.18 0.04 0.0028 IP 2000
Barge/bulkship transport 0.2 3.2 0.084 0.012 IP 2000
Train transport 0.36 3.17 0.059 0.001 IP 2000
Power GJ fuel/GJ
power t/GJ power out
1 GJ of Electricity large Emissions: NAEI
industrial consumers 2.46 8.85 0.0299 0.00024 0.00059 DTI 2003
Manufacture new GJ/t /t t/t
Standard Steel 25 300 1.889 0.0035 0.0055 IP 2000
Aluminium 215
1
931 3.589
1
0.0041 0.0249 IP 2000
Copper 100 1,125 7.175 0.02 0.2 IP 2000
Zinc 65 511 0.024 0.0003 0.0037 IP 2000
Concrete Cordah 2000
1 0.156 0.00096 0.00002 (UKOOA 2002)
"Plastics" Cordah 2000
74 1.479 0.0123 0.0104 (UKOOA 2002)
Sand 0.05 4 4.406 0.004 0 UKOOA 2002
Gravel 0.12 10 10.399 0.009 0 cardigansand.co.uk
Recycling GJ/t /t t/t
Steel 9 300 0.96 0.0016 0.0038 IP 2000
Aluminium 15
1
932 1.08
1
0.0013 0.017 IP 2000
Copper 25 1,126 0.3 0 0.12 IP 2000
Zinc 10 511 0 0 0 IP 2000
Concrete Cordah 2000
1 10 0.156 0.00096 0.00002 (UKOOA 2002)
"Plastics" Cordah 2000
18 1.479 0.0123 0.0104 (UKOOA 2002)
Landfill GJ/t /t t/t
Inert landfill gate fee (incl 2/t landfill tax) - NE
Scotland 17 Enviros 2000
Active landfill gate fee (incl 15/t post 2004
landfill tax) - NE Scotland 30 Enviros 2000
Hazardous landfill UK Not
known
1
The production of new aluminium from bauxite, compared to aluminium recycling, is an energy-intensive process. The
sources used indicate that the CO2 intensity of new aluminium compared to recycled is proportionately much less, but no
explanation for this is given

41
4.3 SUMMARY ASSESSMENT OF MATERIAL AND ENERGY FLOWS

For the summary outcome matrices in Section 6, it is necessary to develop a symbolic

representation for the relative resource use and rates of material recovery for the different
decommissioning scenarios.

Table 4.7 sets out a symbolic scheme for the relative energy use and emissions (P), and the
rate of materials recovery, for the different decommissioning scenarios (compared to the
reference scenario). For relative energy use and emissions, a proportion P greater than 167%
of the reference scenario scores - - -, and a P less than 33% scores + + +, with different scores
in between as set out in the table. For the rate of materials recovery (RR), this is the
proportion of the structure as currently standing which is usefully recovered (i.e. recycled),
rather than left in situ or landfilled. A rate of recovery (RR) of more than 85% scores + + +,
while one of less than 0.5% scores - - -, with different scores in between as set out in the
table. In the summary matrices in Section 6, the RR percentage for the recovery scenarios
may be calculated as the (Replaced material)/(Material left in situ) for the reference scenario.
The actual percentage is given in the Totals line, under % Recovery, for the scenarios
involving material recovery.

Table 4.7 Symbolic Scheme for Relative Energy Use and Emissions, and the Rate of
Materials Recovery, for the Decommissioning Scenarios

Assessment of the proportion of energy use and emissions in a scenario (P), compared to the
reference scenario where:
P 167% ---
Relative energy use (TER)
134% P 166% --
and emissions
101% P 133% -
P = 100% =
67% P 99% +
34% P 66% ++
P 33% +++
Assessment of the rate of recovery (RR) of materials from the structure as currently standing
(i.e. including any marine growth etc.) where:
RR 85% +++
Rate of recovery of
75% RR 85% ++
materials from present
51% RR 74% +
structure
RR = 50% =
25% RR 49% -
0.5% RR 24% --
RR 0.5% ---

42
5. NON-FINANCIAL OUTCOMES

As noted above, there are a number of outcomes from the decommissioning process which
are not fully captured by the flow of materials and energy, and the corresponding financial
flows. Section 5.1 defines and explains the methods used to assess each of these non-
financial outcomes in turn, and describes how the outcome will be assessed in relation to the
different decommissioning scenarios. Section 5.2 presents a summary of the evidence on the
outcomes, which is used in the assessments relative to the reference scenario. The
assessments themselves are presented in the text alongside the evidence, and summarised in
the summary outcome matrix tables in Section 6.

5.1 METHODS OF ASSESSING THE NON-FINANCIAL OUTCOMES

5.1.1 Clear seabed

There may be value in achieving a clear seabed, which goes beyond the financial
implications or the use value of a cleared seabed. The value arises from a desire for a marine
environment unmarked by industrial activities. The achievement of this desire is problematic
because for many years there have been significant activities in the sea surrounding the UK
which have had profound impacts on the marine environment. UKOOA (2001 Part 2B)
indicates a direct environmental impact on up to 50% of the surface area annually. These
impacts include shipping, marine aggregates extraction, oil and gas extraction, trawling and
onshore discharges of chemicals. The impacts include shipwrecks, very extensive alterations
to the seabed and its ecosystems, large reductions in fish stocks and the pollution of marine
waters.

Table 3.8 in Section 3.4.3 showed that there are currently many wrecks and operational
submarine cables, as well as oil and gas pipelines, on the seabed. The potential interference
of these objects with trawling is discussed in Section 5.1.8. The issue to be assessed here is
simply whether or not the seabed has been cleared of materials relating to the operations of
the offshore oil and gas industry. However, even if this were to be the case, the seabed would
still be very far from being in a condition that was unaffected by human activities. Moreover,
if clearing the seabed in this way resulted in a resumption of trawling over the area currently
protected by exclusion zones because of the presence of the oil installations, or removed
structures that were providing habitats to organisms (such as cold-water coral) then this
would certainly leave the affected ecosystems in a less productive and more degraded state
than they are in at the moment.

There is also no doubt that clearing the seabed of structures, pipelines and drill cuttings
would require financial expenditures and give rise to environmental impacts, which are
relevant to the desirability of this endpoint, although their relative importance will differ for
different stakeholder groups. The assessment of each of the decommissioning scenarios in
respect of whether or not it achieves a clear seabed is given in Section 5.2 and reported in the
summary outcome matrices in Section 6. It should be clear that a clear seabed assessment
for a scenario does not necessarily imply that the scenario has delivered net environmental
benefits.

43
 The assessment identifies three possible states of the seabed following decommissioning:
1. Clear of all oil-and-gas related material Clear
2. Any oil-and-gas related material is out of site and inaccessible Covered
3. Oil-and-gas related material is exposed in the marine environment Not clear

5.1.2 Health and safety

Decommissioning operations require complex and potentially dangerous activities including
the handling of extremely heavy structures, much of which is offshore. The oil and gas sector
in the UK is experienced in the management of hazards. Much of the work done for the
assessment of risks associated with decommissioning oil and gas structures makes
quantitative assessments of the probability of a fatal accident (ConocoPhillips 1999) and
represents the risk in terms of a sum of the component risks throughout the entire process.
Removal decommissioning scenarios involve a large number of relatively low-risk
operations, the risk from which is generally considered acceptable.They may also involve
two relatively high-risk operations: raising of large structures and divers operating at depth.
While doubtless increasing financial expenditures could reduce these risks, they are
intrinsically hazardous operations and would remain so however they were undertaken.

The standard approach to industrial risk management, as set out for example in reports from
the Health and Safety Executive (e.g. HSE 2001) and further explored in relation to the oil
and gas sector in UKOOA (1999), is tolerant of the exposure of workers to low-level risks
over long periods. Such risks tend to be considered a normal outcome of industrial activity.
Far greater efforts are taken to avoid high-level, short-term risks. It is for this reason that the
assessment of this issue here has put an emphasis on the two relatively high-risk activities
associated with decommissioning scenarios that seek to return structures and associated
materials to shore.

The assessment of health and safety provided in the summary outcomes matrix represents
an indication of high-risk activities beyond the scope of risks experienced in normal
heavy industry.
Raising of large structures --
Divers cutting at depth ---

5.1.3 Jobs in the UK

Clearly the more expensive scenarios would provide more direct employment. Some of this
employment could be in the UK, and, if it were in areas currently affected by unemployment,
it could make a significant to economic and social conditions in those areas.

However, the assessment of the total net impact on jobs in the UK is complex and a thorough
analysis is beyond the scope of this study. The key issues involved are:

1. The degree to which the decommissioning contracts would be captured by UK

companies A large proportion of the financial expenditure (up to 75%, Watson
2003) is required for offshore equipment. The location of the majority of the
structures and the nature of the industry would mean that there would be no particular
reason why the decommissioning contracts would be won by UK companies.
Furthermore, if the larger parts of the structure were to be returned to shore before
being dismantled, there may well not be a deep water ports in Scotland which could
44
 receive some of the larger barges used (Case Study A identified Teesside as the
nearest UK suitable port). For many of the structures the closest point could well be
Norway.
2. The degree to which the material processing would be captured in the UK Once the
structure is returned to shore and crudely dismantled, much of the dismantled parts
become a tradable commodity. The scrap steel market is international and is driven by
low shipping costs and different steel furnace technologies with differing scrap steel
capacities. This could lead to the dismantling and recycling processes taking place in
other countries if they could offer lower labour costs and a more favourable scrap
market for reprocessing these large steel components.
3. The degree to which any money saved in the decommissioning process (by choosing a
less expensive scenario) would go towards stimulating economic activity and
therefore jobs elsewhere in the economy This question needs to be largely framed in
terms of money expenditure avoided, as the OSPAR convention makes the
presumption that the structures will be removed and the industry (and possibly the
Treasury) have made financial allocation for these costs. Kemp et al (2001) estimated
that overall the UK taxpayer would in effect contribute 50% to the estimated 8.8
billion costs of decommissioning (UKOOA 2002) through foregone tax income. This
issue therefore has to be considered in two components:
The oil and gas industry - to what extent would any additional money be re-
invested within the UK, and how job intensive would this investment be?
The UK Treasury - what would be the UK job implications of any additional
money? If invested in the public sector services, the money would provide
both a high degree of job creation as well as directly providing public
services. If the money was to go towards tax cuts, however, the benefit would
be less direct but would still go towards stimulating economic activity, much
of it in the UK.

An overall assessment of the proportion of employment captured within Norway by the

decommissioning of the entire Ekofisk field (ConocoPhillips 1999) estimated that Norway
would capture between 36% and 52% of expenditure if all structures were returned to shore
and recycled. This has to be compared to the theoretical rate of financial retention and
conversion into jobs of any money not spent on decommissioning operations.

In broad terms, the UK and Norway are comparable in these terms as they are an
approximately equal distance from many of the structures and have a similar-sized oil and
gas infrastructure. The analysis quoted above is however an assessment of the goods and
services captured and does not represent the more complex assessment of the net impact of
employment as discussed above.

5.1.4 Impacts on the marine environment

Marine impacts of structures in situ
As noted earlier, the starting (and reference) point of the analysis for all decommissioning
scenarios is after shutdown, well decommissioning, and flooding and cleaning of tanks,
process equipment and pipelines, i.e. the structure is clean. The mere presence of such a
structure in the sea should therefore not cause significant negative impacts on the biological
environment and is considered as negligible in the assessment (its potential to protect or
provide a habitat for organisms is considered separately below). The impacts on users of the
sea as well as non-use values associated with in situ structures are considered in Sections
5.1.8 and 5.1.1 respectively.

45
The situation is different for drill cuttings piles, as noted in Section 3.5.3. Left uncovered in
situ, it is expected that these piles would remain sterile, and potential sources of hydrocarbon
emissions into the sea, for many centuries. Covering could allow recolonisation of the piles
by marine organisms. Covering would also slow down, possibly to negligible levels, the rate
of release of contaminants from the piles.
Impacts of marine operations
Operations to recover or monitor offshore structures will have some impacts on the marine
environment. Some of these may well be very minor, such as the movement of vessels in
transit or monitoring vessels. The marine impacts of any monitoring of structures left in situ
not requiring remedial activities are likely to be of this kind and are therefore not considered
further. Other pollution impacts are assessed according to the schema below.

A further impact to consider is the loss of any marine life attached to the structures
themselves, which would be lost in the event of removal from the marine environment. A
survey of Beryl Alpha and the Brent Spar structures revealed the presence of Lophelia
pertusa cold or deep-water coral colonies at depths of 70-100m (Roberts 2000). A
colonisation of this coral is found on the lower jacket of Case Study A. Such corals are
characterised by diverse associated fauna. L. pertusa colonies have CITES I (Convention on
International Trade in Endangered Species of Wild Flora and Fauna) listing and Annex I
status under the EC Habitats Directive. The European Commissions Habitats Directive
(92/43/ECC) requires the oil and gas industry to produce environmental assessments of the
impacts of their activities on cold-water corals in the vicinity of their facilities. The UK
Government also has an Action Plan for the protection of L. pertusa colonies within UK
territorial seas (Case Study A, ENV03).

However, Lophelia pertusa is the most abundant cold-water coral species in the north
Atlantic and its distribution extends to the Indian Ocean and Mediterranean Sea (Roberts
2000). Colonies on oil and gas structures represent opportunistic colonisations and are
unlikely to be considered of conservation importance (Case Study A, ENV01, p.1.1), though
they may provide useful opportunities for academic study. Even so, the loss in conservation
terms of small colonies of this kind, although not desirable, could not really be considered a
significant impact on the biodiversity of the marine environment of the North Sea. Further
possible impacts of decommissioning on biodiversity are considered in connection with fish
stocks in Section 5.1.9 below.

The following scheme will be used to assess the impact of any decommissioning scenario
requiring removal or remedial activities:

46
 Involves additional minor or short-term impacts
or disruption of the marine environment1 -
Involves continued sterility of seabed occupied by cuttings piles,
or localised disruption of ecosystems, larger fish or
marine mammals but not major or long-term physical damage2 --
Involves significant impacts on large marine organisms
or ecosystems, in extent or duration3 ---
1
Examples are concentrations of marine vessels under anchorage and working, and impacts from
covering or suction dredging cuttings piles
2
Examples include leaving uncovered cuttings piles in situ, and any significant underwater activity or
disruption of the seabed or loss of corals on decommissioned structures
3
Examples include extensive disruption of cuttings piles or the use of explosives underwater.

5.1.5 Conservation of stocks of non-renewable resources

A large part of the materials within offshore oil and gas structures are non-renewable; indeed
typically 90% by mass is steel. Much of this material could be recycled if returned to shore.
Any of this material left in situ (and therefore not recovered) would have to be replaced by
the extraction and processing of raw material, in the case of steel this is mostly iron ore and
coal.

The loss of any non-renewable stock of materials may be important in terms of sustainable
development and intergenerational equity. The present market price of materials does reflect
some of the scarcity value of non-renewable resources and provides some market signals of
the need for their conservation. This perception of scarcity is a perception of present market
actors, especially those who have property rights over the material reserves. It is useful to
make a distinction between the various different types of resource deposits:

1. The theoretical resource is the sum total of all the deposits of a given resource
including deposits not yet discovered. Estimates of these unknown deposits are based
on estimates of abundance informed by previous experience of exploration and
geological knowledge.
2. Known deposits are all deposits of a given resource which are known about,
including reserves.
3. Reserves are economically recoverable resources at present market prices and
extraction technology/costs.

As the trading in commodities is predominantly private, the value put on conservation is

discounted i.e. there are effectively no price signals provided for scarcity beyond private
financial valuation horizons. This is true for a large number of resources where any perceived
exhaustion is either hypothetical or not expected for many years. Reserves to production
(R/P) ratios provide commodity markets with information on how many years present
reserves will last if production continues at its present level and no further reserves are
added. Table 5.1 gives estimates for R/P ratios at different dates for different materials from
different sources.

47
Table 5.1: Estimated World R/P Ratios for Various Materials

R/P ratio years

Material 1970 1988 1990 1996 1998 2000 2002
Copper 36 32 36
Aluminium 100 1000 200
Lead 26 12 21
Mercury 13 - 22
Nickel 150 59 52
Tin 17 27 27
Zinc 23 500 20
Oil 42.2 40.9 39.9 40.6
Natural gas 62.1 63.0 60.7 60.7
Coal 224
Sources: Ekins 2000, p.20; Fossil fuel R/P ratios: BP 2003.
Note: Much of the variation in the R/P ratios between years could be due to the different sources

It can be seen that some R/P ratios have increased since concerns over the limits to growth in
the 1970s (Ekins 2000, p.20), despite increased production and consumption. This is due to
exploration and technical progress. However, if a market was to take a pessimistic view of
the outcomes of future exploration and technological improvements for a particular resource,
then the price of the resource could be expected to increase in accordance with the extent of
perceived future scarcity.

It may be noted that such a situation is most unlikely to arise in the foreseeable future for
iron, which is one of the commonest metals in the Earths crust. Of far more potential
concern is the availability, price and carbon content of the energy that is required to extract
and process it. Clearly countries like the UK which have no appreciable indigenous stocks of
some resources, like iron, depend on functioning international markets to gain access to
them. When confidence in these markets is low, this may give extra value to resources in use
that can be recycled at the end of their lives. However, this situation is both different from
resource scarcity itself and, in respect of iron ore at least, is not currently a significant
concern.

In the analysis of decommissioning scenarios, any stock change in respect of non-renewable

resources has to be assessed relative to the reference scenario, both in terms of the resources
that could have been recovered had the material been returned to shore (excluding temporary
steel which is only relevant to recovery scenarios and which is always recovered itself), and
in terms of the resources required to effect this recovery. The loss of non-renewable
resources in a scenario may therefore be expressed in terms of a resource stock ratio (RSR)
of the (useful) material recovered in a scenario, less the mass of fuel required to recover it, to
the initial mass of material. Therefore:
Useful material recovered (mass of input fuel use in recovery)
RSR = Starting mass of material

The RSR would therefore be 100% if all the material being considered in a scenario were to
be recovered without the need for any fuel use.

48
 Assessment of the resource stock ratio (RSR), the recovered useful material, less the
input fuel use, as a percentage of the total material in the structure where:

RSR 67% +++

66% RSR 34% ++
33% RSR 1% +
RSR = 0% =
-1% RSR -33% -
-34% RSR -66% --
-67% RSR ---
Note: The negative percentages will apply to those scenarios which use a mass of input fuel which is
greater than the mass of useful material they recover (e.g. return of drill cuttings to shore for
landfilling)

5.1.6 Impacts of resource extraction

The environmental impact associated with the extraction of material resources varies
depending on the material and the method of extraction. An important indicator of
environmental impact is the total amount of material which has to be moved to extract a
tonne of material.

Table 5.2 Material Multipliers for Resource Extraction and Market Value of
Resource Produced

Extraction multiplier
End (ratio of mass of materials moved in Market value
Extracted resource product extraction to mass of end product) (of end product)
t/t /t
Iron ores Steel 5.2 300
Copper ores Copper 450 1,125
Bauxite Aluminium 3 931
Zinc ore Zinc 32 510
Crude oil Diesel 1.02 237
Sand: 4
Aggregates Sand & gravel 1.4 Gravel: 10
Source: Ayres & Ayres 2002, Table A1, p.13
Metal prices: London Metal Exchange 2003, assuming 1 = $1.54

The price of a material will depend on the balance between supply and demand. A relatively
scarce material for which there is high demand, resulting in a high market price, will be
likely to have a higher extraction multiplier, because companies will have an incentive to
extract deeper or otherwise less accessible deposits. A large proportion of the price of the
material will then represent the value added in extraction. This is not the case if the value of a
high value material is mostly added at other stages of the material value chain, e.g. at the
exploration and development stage for oil and the refinery stage for aluminium, when the
extraction multiplier is likely to be lower.

49
 Assessment of the impacts of resource extraction will be through the extraction multiplier
(EM), the ratio of the mass of the total material moved to the mass of the end product
extracted:
EM 1.67 ---
1.66 EM 1.34 --
1.33 EM 1.01 -
EM = 1.0 =
0.99 EM 0.67 +
0.66 EM 34 ++
0.34 EM +++

5.1.7 Impacts of landfill

There are two different types of impacts from an additional amount of waste being landfilled:

1. The direct social and environmental impacts from leaving that particular waste in the
landfill site; as well as the
2. Loss of void available to future generations to landfill their wastes.
The social and environmental impacts of landfill are summarised in the Table 5.3.

50
Table 5.3: Impacts of Landfill Sites

Receptor Activity Potential Impact

Surface water Increase in surface run-off from ground compaction with rapid transfer
hydrology and Use of vehicles and machinery, of rainwater to watercourses via drains. Changes to flow regimes due to
channel and site drainage site drainage may cause deposition downstream, with increases to
morphology sediment loading, potentially increasing soil erosion and flood risk.

Surface water Leachate and materials Potential decrease in water quality from sudden releases, for example a
quality management failure in the landfill liner; or from gradual leachate seepage.

Groundwater
Physical presence of landfill Continued alteration of groundwater flow.
hydrology
Groundwater Leachate and materials Contamination due to sudden releases, from leachate seepage to
quality management groundwaters, and from spills or leaks of fuel and oil.
Contamination of soil from toxic or hazardous materials being disposed
Waste disposal, and use of
Soils of. Soil compaction, erosion and contamination from vehicle movements
vehicles and machinery
and road run-off.

Removal of geology following expansion of the site.

Geology Excavations

Local air quality

Releases of methane (landfill gas) to the atmosphere, contributing to the
greenhouse effect. Risk of explosion should the methane be contained
Regional / global Landfill gas generation
within a confined space, therefore flaring is required. Odours from the
air quality landfill gas emissions.

Waste disposal and materials

Aquatic ecology Risk of pollution to adjacent watercourses by leachate.
management

Alteration of site leading to loss of habitats. Operation of the site will

Physical presence of landfill,
lead to the attraction of vermin (a nuisance issue). There may be harm to
Terrestrial ecology landfill gas generation and
local species through the release of the landfill gas, and through
waste disposal activities
disturbance due to traffic movements.

Waste disposal operations and Risk of harm to humans from handling toxic and hazardous materials,
Health and Safety
the generation of landfill gas and through consumption of contaminated groundwater.

Increased HGV traffic resulting in increased emissions, dust, noise, and

Use of vehicles and machinery, mud on roads leading to the landfill site. There will be odours from the
Nuisance
and site management waste disposed and from the landfill gas emissions. Production of
unsightly litter, attracting vermin.

Source: Case Study A, E01, p.10.8

The key environmental impacts are leaching, landfill gas and the impact of lorries. These
impacts are discussed in more detail below (taken from Case Study A, E01, p.10.9):
Leachate is generated when rainwater percolates through the landfill, makes contact
with the buried wastes and extracts the soluble components. Depending on the
characteristics of the landfill and the wastes it contains, the leachate may be relatively
harmless or extremely toxic. Generally, leachate has a high biochemical oxygen
demand (BOD) with high concentrations of organic carbon, nitrogen, chloride, iron,
manganese, and phenols. Many other chemicals may be present, including pesticides,
solvents, and heavy metals. The nature of leachate is such that it can permeate into
adjacent water bodies and penetrate groundwater, and its effects can be detected
downstream and even across country boundaries.
Landfill gas (LFG) is composed of carbon dioxide and methane, both of which are
colourless and odourless. It is an important and relatively long-lived greenhouse gas,
having a global warming potential 31 times greater than carbon dioxide over a 100
51
 year time horizon. Decomposition of biodegradable wastes within landfill sites is one
of the major contributors to emissions to the atmosphere, contributing approximately
30% of anthropogenic methane emissions in the EU. However, the process of capture
of this LFG and its use as a source of fuel in power generation is an established
practice in many of the larger landfill sites in the UK. Furthermore, as the power
generated from LFG is eligible for Renewable Obligation Certificates (ROCs), LFG
is increasingly seen as an asset and the extent of LFG capture is set to increase. If not
captured, and if confined in spaces, LFG poses a significant risk of explosion or
asphyxiation. Landfill gas contains over 150 trace components which can cause other
local or global environmental effects such as odour nuisances, stratospheric ozone
layer depletion, and ground-level ozone creation.
There could well be increased movement of lorries during the onshore dismantling
and disposal process. There may by opportunities for the transport of bulk material by
barge (Case Study A, E01, p.9.10), although this would require a suitable water link
from dismantling site to landfill site. Any impact would be most marked with large
bulk structures such as concrete structures and large steel structures, and would occur
whether the material was reprocessed or not. If lorries were used, there would be
increased noise, pollution, disruption to traffic as well as heightened risk of accidents
to road users. Generally these impacts are tolerable in that they occur routinely,
although the use of small or rural roads may heighten the exposure in an inequitable
way to local residents. The net impact of lorries related to the recovery of oil and gas
structures is difficult to assess. If it is assumed that the impacts (such as road
deterioration and air emissions), and the exposure of people to them, caused by lorry
movements for the recovered material are the same as would be caused by the
movement of lorries for the movement of virgin material, then the additional impact
from lorry movements related to bringing a structure to shore would arise only from
the material that needs to be landfilled.
The loss of void space
The number of sites which are suitable and socially acceptable for the establishment of
landfill sites is increasingly limited. The loss of void space suitable for landfill can be
described as a loss of option value to future generations and therefore has value to the present
generation in terms of a bequest of a resource to future generations; the additional loss of
void is therefore a matter of intergenerational equity. This value is in some ways equivalent
to that of the loss of non-renewable resource as described in Section 5.1.5, as the loss of void
space to landfilling is in practice non-reversible. The future scarcity of landfill void would
potentially be communicated through market signals and therefore the gate fee charged by
the owner of the landfill site. However, due to the timescales involved and individual
discounting of future values, much of this signal fails to be reflected in the gate fee.

The landfill tax is in part an attempt to try to reflect this value and the environmental impacts
of landfill. In 2004-05 the landfill tax will be set at 2 and 15 for inert and biodegradable
waste respectively, with the latter due to rise by 3 per year until it reaches 35 per tonne (as
the vast majority of decommissioning of offshore structures will occur after 2004-05, this
increased tax will increase the costs of onshore disposal for those decommissioning scenarios
that generate non-inert materials for landfilling).

In this study, the non-financial outcome of landfilling (that value not captured by the gate fee
and landfill tax) is taken to be influenced by three factors:

1. The amount of waste to be landfilled;

2. Whether the waste arising is biodegradable or inert;
52
 3. Whether some part of the waste is classed as hazardous

The Landfill Impact Factor in the box below takes into account in an additive way the loss to
society of void space and of landfilled materials (MT), and the environmental impacts of
biodegradable and hazardous wastes (MB, MH).

Landfill impact factor (LIF) = [MT + MB + MH]

Where:
MT = Total mass of waste being landfilled in tonnes
MB = Mass of biodegradable waste being landfilled
MH = Mass of hazardous waste being landfilled

The assessment according to the landfill impact factor is as follows:

100 < LIF < 1000 -
1000 LIF <5000 --
LIF 5000 ---

It may be noted that this equation implies that tonne for tonne, the loss of void and resources,
biodegradability and whether the waste stream is hazardous are weighted equally. This is
obviously a fairly crude assumption about the relative social disbenefits arising from these
different impacts of landfill. In particular, it may seem a relatively low weighting for
hazardous waste. The weighting may be justified by the fact that hazardous wastes are
increasingly well managed in dedicated landfill sites and therefore much of the
environmental threat is dealt with and reflected in the higher gate fees (the gate fees may also
be expected to reflect the shortage or hazardous waste sites following the recent European
prohibition of co-disposing of hazardous wastes with other wastes). It would be possible to
change this assumption in sensitivity analysis if it seemed likely that landfill impacts of a
particular kind were of importance in a particular decommissioning scenario.

5.1.8 Impacts on the fishing industry

The fishing industry is an important stakeholder in what happens in the North Sea. However,
it should be noted that the fishing industry in the North Sea is not homogeneous, and the
different outcomes from decommissioning would affect different parts of the industry in
different ways. Thus, trawlers might be expected to favour a clear seabed approach to
decommissioning, to enable them to trawl without obstructions, whereas net setters might
favour residual structures if they perceive them to aggregate fish (as, for example, with
wrecks). However, in the Scottish sector of the UK Continental Shelf, there is a clear
consensus in favour of a clear seabed post-decommissioning5, and it is in relation to this that
impacts of the various decommissioning scenarios have been evaluated.

Historically, the fishing industry was entitled to fish in the areas where there are now
exclusion zones around oil and gas structures. The outcome from the different
decommissioning scenarios could impact on their business in the following ways:

I. If there are removal or remedial activities:

5
Personal communication, Michael Sutherland, Scottish Fishermens Federation, August 2004
53
 This could involve short-term restrictions on the movement of all non-operational
vessels in the operational area, typically lasting for a few weeks or months, and
would only be an additional restriction to fishing in the case of pipeline operations,
as there is an existing exclusion zone of 500 metres around all platforms during
their operational phase.
The removal processes would involve some short-term impacts on the local marine
environment. The most significant of these would be the use of explosives to
remove the footings if other removal methods proved to be unfeasible. This may
cause some disruption to the seabed, to drill cuttings piles (and resulting
contamination by the pollutants contained in them) if they had not already been
removed, and disturbance to fish and marine mammals (although it may also be
noted that quite effective techniques to mitigate against the shock waves from
explosives have been developed).
During the suction dredging of drill cuttings, there would be little pollution of the
water column other than the plume caused by the remotely operated vehicle (ROV)
whilst in contact with the cuttings pile. Using present technologies (the Breebot
crown cutter), if there was a blockage in the suction hose, it would have to be
cleared by back washing. This would lead to re-suspension back into the water
column of a proportion of the cuttings material which was present in the hose when
the hose was blocked. Little secondary pollution would be discernible at a distance
of 100 metres from the dredging operations, and no effects would be seen on the sea
surface. (UKOOA 2002, 20, Q48)

II. If any structure or cuttings pile is left in situ:

This would involve a certain impact on long-term trawler fishing activities in that
fishing vessels would need to avoid any in situ materials. It could be hazardous for
the trawler vessel in the case of footings, and potentially hazardous for the marine
environment in the case of cuttings piles for trawling activities to reoccur at the site
after decommissioning had finished:
a. The present exclusion (or safety) zones of 500 metres are automatically
created around above-surface installations under section 21 of Petroleum Act
1987 and will remain after decommissioning provided the structure still
protrudes above the surface. The Health and Safely Executive (HSE) could
take statutory action to cancel a zone and would probably not do so unless
someone requested it, e.g. fishermen6.
b. The footings of large steel structures left in situ would not automatically have
an exclusion zone as the existing zone would cease to exist as soon as a
structure no longer breaks the surface, so:
i. The DTI could make regulations under the Petroleum Act 1998
enabling it to create zones for any structure on the seabed. However,
the DTI currently feel this is unlikely to be justified given the current
advice from fishery and transport experts that marking on charts etc.
would be sufficient for the prudent mariner to avoid the obstacle7.
ii. There is a provision under Part 1 of the Food and Environmental
Protection Act 1985 for fishing exclusion zones to be created; this
could be used by the Food Standards Agency if there was concern
about the quality of fish caught when trawling through an old drill
cuttings pile left in situ after the removal of a platform. However, there
6
Personal communication, DTI oil and gas department, Keith Mayo, January 2004.
7
Personal communication, DTI oil and gas department, Keith Mayo, January 2004.
54
 is no evidence to suggest that demersal fish frequenting historic
cuttings piles have more hydrocarbon contamination than fish found
elsewhere, and there is no evidence that the nature of hydrocarbon
contamination in fish from cuttings piles is different from that of open
sea fish (Case Study A, E1, page 10.23). As noted in Section 3.5, there
is potential for some of the toxic aromatic compounds found in older
cuttings containing OBM to pass into some benthic organisms found
on the seabed (UKOOA 2003, Task 2C), but there is certainly no
evidence of these having been passed on through the food chain to
fish.
c. If all 44 fixed structures [33 large steel + 11 concrete (DTI 2002, Annex 2A,
p.44)] eligible for derogation were to have a 500 metre exclusion zone after
decommissioning, the total loss of fishing grounds would be 33 km2, or 0.01%
of the UK North Sea assuming that there is no overlap (updated from AURIS
1995, p. 6.3). Fishing activities would most likely continue around
decommissioned pipelines left in situ and therefore the risk to the fishing fleet
needs to be assessed. Table 5.4 reproduces information from Tables 3.7 and
3.8 which is relevant to risks to trawling from pipelines and other objects on
the seabed.

Table 5.4: Estimated Total Number of Interactions1 Between Fishing Gear and
Objects in the North Sea

Feature Potential interactions per year

Operational submarine cables 26,000
Wrecks 48,000 (likely to be more)
Pipelines 36,000
Level of pipeline deterioration Year 10 Year 30 Year 50
Any part of pipeline 36,000 36,000 36,000
Exposed sections 15,000 14,000 13,000
Spanning sections 500 1,200 1,300
Section with a break1 20 50 140
Source: AURIS 1995, p.6.28
1
Interaction in this context includes passage over buried as well as unburied pipelines.
2
As the pipelines age, decay and rust, breakages in the pipelines could occur, potentially leaving jagged edges.

It is important to note that by no means do all interactions between fishing

gear and marine features result in any noticeable impact. This is because:

The results in Table 5.4, derived from modelling, assume random fishing over
the pipeline network as it currently exists. However, pipelines posing more of
a hazard of spanning and breaking are more likely to undergo remedial action
or removal.
Any decommissioned pipelines left in situ would be charted and the use of
FISHSAFE will ensure proximity alarms are available to the Scottish fleet. In
the Southern North Sea, sand waves can cause the creation and movement of
sections of pipeline not in contact the seabed (spans). To reduce the chances
of trawlers interacting with spans, any pipeline left in the Southern North Sea
could have ongoing monitoring and updates on FISHSAFE on the
whereabouts of any spans.
There will be some self-burial of pipelines in the Northern North Sea not
already buried. One estimate suggested that eventually 70% of the diameter
55
 would be buried. (AURIS 1995, page 6.25). This would be different in the
Southern North Sea;
Only very large diameter pipelines, broken pipeline sections or spanned
sections which are broken during the interaction could plausibly lead to a
snagging incident and therefore pose a safety hazard;
Snagging is most likely to result from particular gear in particular
circumstances8.

These interactions should also be considered in context with other snagging hazards managed
by trawler skippers, most noticeably wrecks, the modelled frequency of which is shown in
Table 3.5.

A recent survey (Case Study A, S1 page 4-5) of fishing vessel skippers perceptions of the
impact of decommissioning on their activities found that:

The preference expressed by the trawling skippers was for the complete return of the
seabed to its original form.
Large objects like legs remaining would be considered as the worst situation feared
by skippers.
Concern was centred both on the risk of the loss of fishing gear as well as the risk to
the vessel and the crew.
There were mixed concerns on pipelines ranging from acceptance if they are buried
and regularly surveyed, to concern over safety and pollution if they are broken during
fishing activities.
The concerns around drill cuttings were largely centred on the possibility of the
banning of fishing.

As noted above, the impacts discussed in this section do not impact on all fishing activities.
Anglers, trappers, and long-line and net fishermen will not be affected in the same way by
any structure left on the seabed at such depths (typically 100 metres or more). In fact, the
protection of spawning grounds and local fish stock from trawling activities would have a
benefit for the activities of these fishermen (see next section).

For this assessment, two impacts on the trawler fishing industry seem important to include:
the risk of snagging and the desire of fishermen for the return of current exclusion zones to
fishing use. The assessment scheme for these impacts is given below.

8
Specifically: Snagging may occur where an Otter door (improperly oriented in a flat position) slips under a
span of insufficient height to allow a quick release. The result would most likely be a minor displacement of the
line, which might occur with non-adapted beam trawls using a single bridle attachment to the shoe (AURIS
1995, p.6.27).
56
 The risk of snagging:
o For the inconvenience of loss of gear
(with the potential to be compensated by the industry) -
o For the risk to crew -
The return of fishing grounds after the removal (or making safe)
of the structure or cuttings pile (relative to the reference scenario) +
Note: It may appear that the above assessment is putting equal weighting on the incidence of loss of fishing gear and
loss of life. This is not the case as by no means would all incidents of loss of fishing gear through a snagging incident
lead to the loss of life. Risks are calculated by the multiplication of the consequence of a particular risk event occurring
by the probability of that consequence actually occurring. The probability of the loss of life from a snagging incident is
very low compared to the probability of loss of fishing gear.

5.1.9 Impacts on fish stocks (and other marine life)

The steel jackets of oil and gas platforms in the North Sea already act as artificial reefs; the
densities of fish in and immediately around jackets is higher than that of the open sea away
from the jackets (Case Study A, page 10.22). If the footings [of large steel structures] were
left in situ it is very likely that the same effects would occur; the remaining structure would
act as an artificial reef. While the focus of this section is on fish, the comments below would
also apply to some extent to other marine organisms that are attracted the structures and that
take advantage of the protection from fishing and environmental disturbance from fishing
that these structures. In other words, the reef-effects can be beneficial to marine biodiversity
in general, and not just fish.

The footings of large steel structures found in the UKCS would typically extend to 30 or
more metres above the seabed and provide the type of open lattice-work structure that is
attractive to shoaling and bottom dwelling fish. Higher densities of fish would be found
within and around the footings than would be found in the open sea nearby. The density of
fish would fall very quickly at distances of more than about 20m beyond the footings.

The potential benefits of the creation of the reef focus largely on the effect that the reef will
have on attracting fish to the site and providing them with an environment that:

increases the carrying capacity of the local sea area, so allowing a higher density of
fish to live in that part of the sea;
permits the healthy growth of adults and juveniles;
protects the fish from the pressures of trawler fishing activities; and
protects areas of seabed from the impacts of mobile fishing gear trawling activities
can plough furrows up to 2m wide and 0.3m deep, inflicting great disturbance on the
sediment and the benthic communities inhabiting the seabed (Dayton et al. 2002,
p.26).

The greatest benefit in the long term will be derived by the aggregation of fish at the site, and
the eventual dispersal to the "open sea" of fish which have spent some time at the reef
(Kjeilen et al., 1995 p.53). Research suggests that there is some relationship between the
number of shoaling fish found at a platform and the volume of water enclosed by the
structure. An average figure of about 0.3kg wet weight of fish per cubic metre of enclosed
space has been estimated for platforms in the Central and North Sea in the UKCS (Case
Study A, E1, p.10.23).

57
 Footings: with a base area of about 4 hectares (Case Study A, E1, p.10.23) and a
height of 30-50m the volume enclosed by the footings of large steel structures could
be some 120,000-200,000m3. If the average mass of fish were 0.3kg/m3, the mass of
fish that may be found in and around the footings at any one time could be 36-60
tonnes. This is likely to be an over-estimate because the density of fish generally
decreases towards the base of steel platforms. If the footings were collapsed inwards
on top of the cuttings, the reef effect would be less marked. The enclosed space
offered by the mound of steel material would be less than that offered by the intact
footings. It is therefore likely that fewer fish would be found, and the species present
would be dominated by bottom dwellers such as ling and wolf fish that spend most of
their time resting on the seabed or on hard surfaces.
Jacket: If a jacket of a typical large steel structure was cut at 40 metre sections and
left as a reef, there would a total reef footprint of about 9 hectares. With an enclosed
volume of 350,000m3 (based on calculations from the dimensions of Case Study A,
E1, p.6.7), the mass of fish found in and around the created reef at any one time
would be approximately 100 tonnes. The edge of reef factor would be reduced
relative to the footings as the reef created by one piece of cut-up jacket put close to
another would have a lower perimeter to area ratio.
Topside: The topside from a large steel structure would have a reef volume of
approximately 150,000m3 and would contain fish of mass 45 tonnes at any one time.

If these estimates were extended for all 33 of the large steel fixed structures presently on the
UKCS, the total reef effect on fish stocks at any one time would be approximately 6,400
tonnes. It should be noted that such an enclosed space could act as a spawning or nursery
area for many generations of fish, which may then disperse to the open sea. Therefore, the
benefits to total fish stocks in the North Sea and therefore long-term catches will be greater
than this estimated mass of fish resident in the enclosed space at any one time. No reliable
estimate of the relationship between resident spawning stock and impact on catch, or of the
distribution of species, which will have different commercial values, is available, but it may
be surmised that any benefit to fish stocks could become of some benefit to the fishing
industry when fish leave the immediate protection of the structure.

As noted above, there is no evidence to suggest that demersal fish frequenting historic
cuttings piles have more hydrocarbon contamination than fish found elsewhere, and there is
no evidence that the nature of hydrocarbon contamination in fish from cuttings piles is
different from that of open sea fish (Case Study A, E1, p.10.23).

The benefits to fish stocks from the decommissioning scenarios which leave various
materials in situ have been assessed as follows:

Non-trawler area with little enclosed space +

In-situ footings or shallow deposit of topside ++
Jacket left in the marine environment +++

58
5.1.10 Summary of the assessments of non-financial outcomes

Table 5.5 summarises the various symbols which give the assessments of the material and
energy flows, and other non-financial outcomes, which have been explained above. These
symbols appear in the summary outcome matrices of Section 6. First, however, the evidence
on which the assessments are based needs to be presented. This is the subject of the next
section.

Table 5.5: Summary of Proposed Assessments of Non-Financial Outcomes

Non-financial outcome Proposed assessment Assessment score

Proportion of energy use and emissions in a scenario (P), compared to the reference scenario
where:
P 167% ---
Relative energy use (TER)
134% P 166% --
and emissions
101% P 133% -
P = 100% =
67% P 99% +
34% P 66% ++
P 33% +++
Rate of recovery (RR) of materials from the structure as currently standing where:
RR 85% +++
Rate of recovery of 75% RR 85% ++
materials from present 51% RR 74% +
structure RR = 50% =
25% RR 49% -
0.5% RR 24% --
RR 0.5% ---

Seabed clear of all oil-and-gas related material Clear

A clear seabed Any oil-and-gas related material is out of site and inaccessible Covered
Oil-and-gas related material is exposed in the marine environment Not clear

Raising of large structures --

Health and safety
Divers cutting at depth ---

Jobs in the UK No assessment in the summary outcomes matrices

Additional minor or short-term impacts -

Impacts on the marine
Localised disruption of ecosystems or components of them --
environment
Significant impacts on ecosystems or components of them ---

Where RSR is relative loss of non-renewable resources:

RSR 67% +++
66% RSR 34% ++
Conservation of stocks of 33% RSR 1% +
non-renewable resources RSR = 0% =
-1% RSR -33% -
-34% RSR -66% --
-67% RSR ---

59
 Impacts of resource extraction; extraction multiplier (EM) is the ratio of the mass of the total
material moved to the mass of the end product extracted:
EM 1.67 ---
1.66 EM 1.34 --
Impacts of resource 1.33 EM 1.01 -
extraction EM = 1.0 =
0.99 EM 0.67 +
0.66 EM 34 ++
0.34 EM +++

Where Landfill impact factor (LIF) = [MT + MB + MH]:

100 < LIF < 1000 -
Impact of landfill
1000 LIF <5000 --
LIF 5000 ---

Risk of loss of gear -

Impacts on the fishing
Risk to crew -
industry
Return of fishing grounds +

Non-trawler area with little enclosed space +

Impacts on fish stocks
In-situ footings or shallow deposit of topside ++
(and other marine life).
Jacket left in the marine environment +++

Note: It must be stressed that in any overall assessment of the scenarios, there can be no addition of the +
and - signs across the different issues, because they are incommensurate

5.2 EVIDENCE FOR THE ASSESSMENTS

Tables 5.6 and 5.7 give the evidence on the decommissioning of large steel structures that
has come from Case Study A, as it relates for different decommissioning scenarios to three of
the non-financial outcomes discussed above: the endpoint of the seabed (clear, covered or not
clear); the impact on the marine environment; and the amount of material recovered and
landfilled. The content of the three tables will be briefly described and summarised in turn.
The letters used for the decommissioning scenarios are taken from Table 3.4.

As discussed above (Section 3.2) the reference scenario (T1, J1, F1, CON1, P1, C1) against
which the other scenarios are to be compared entails leaving all the materials (structure,
pipelines and drill cuttings) in situ, after basic cleaning of the topside. T1 and J1 are currently
against the OSPAR convention and therefore are not being contemplated in practice. Were
this situation to change, and these to become practicable scenarios, the topsides and jackets
left in situ would need regular maintenance and monitoring to ensure that they did not pose
any risk to other users of the sea or the environment. The cost of a vessel to undertake such
monitoring is approximately 38,000 per day (Case Study A, Soc 05, p.11). However, T1 and
J1 are not further considered here as no stakeholders appear to consider them practicable
options in the North Sea context and their implications have therefore not been studied in any
detail.

F1 (with the topside and jacket having been removed to the regulated extent), although
requiring derogation under OSPAR, clearly is a practicable option, as are CON1, P1 and C1.
They are therefore considered in some detail below. In all these cases monitoring of any
materials left in situ would be required, at the kind of daily cost cited above, and some
indication of what this is likely to entail is discussed now.

For pipelines left on the seabed (P1) it has been estimated that they should be surveyed once
every ten years over 100 years (Case Study A, Eco 05, p.11). With about 9,400 km of
60
pipelines in the UKCS North Sea (DTI 1999, Appendix 11), if a substantial proportion were
left in situ, this could employ a survey vessel for approximately 25% of its offshore time9.

The environmental implications of drill cuttings left in situ (C1) have been discussed in some
detail in Section 3.5. The UKOOA study (UKOOA 2002, p.15) considered that a monitoring
program should be based on the protocol used for seabed monitoring at producing field sites,
but should also include sampling and analysis of the pile itself. A minimum of two
monitoring surveys should be undertaken at an interval of 3 years. The outcome of these
surveys should then be used as basis for considering the need for any further survey. For
Case Study A (ENV 02, p.39, UKOOA 2002, Final report, p.15), the energy calculations
allow 30 days (3-day survey every five years for 50 years) and therefore 150 tonnes of diesel,
for monitoring in situ cuttings piles.

The energy use from monitoring activities (for all the non-reference in-situ scenarios
involving structural elements, pipelines or drill cuttings) does not appear in the summary
matrices of decommissioning outcomes in Section 6, because the monitoring requirements
for these scenarios have not been sufficiently defined in the source documentation. Such
energy use should, however, be taken into account in any conclusions about the scenarios.

Sometimes, as a result of monitoring, a need for remedial action is respect of materials left in
situ will be revealed. The financial implications of such remedial action have not been
included in the assessment, but should be considered in connection with the ongoing liability
of the industry for materials left in situ.

5.2.1 Clear seabed

The reference scenario entails leaving the topside (T1) in situ after shutdown, well
decommissioning and the flushing and cleaning of tanks and process equipment. The jacket
(J1) and footings (F1) would be left in situ. If the footings were to be left on their own, they
would be cut from the jacket at the highest point of the piles. The pipelines would be cleaned
to minimise the oil content, and might either be flooded with sea water or filled with inert
fluid, containing less than 40ppm oil, sealed and left in place (P1). The drill cuttings piles
would remain undisturbed (C1). This scenario, in part or whole, obviously does not leave a
clear seabed.

In the shallow disposal scenario the topside (T2) would be deposited on the seabed at the
present location, and the jacket ( J2) would be cut into 8-10 sections and deposited on the
seabed around the present location. The footings would not be cut unless they were to be
removed to shore, either without the cuttings (F2a, in some cases for the cuttings the outcome
would be similar to C2, as up to 100% of the cuttings could be dispersed into the water
during the removal of the footings) or with them (F2b, C4). The shallow disposal of any part
of the structure also does not leave a clear seabed.

For removal of the structure to shore, the topside (T3) would be removed in 22 modules, and
reprocessed onshore, with some of the more hazardous material (e.g. asbestos) removed. The
jacket (J3) would be removed in 8 to 10 sections and reprocessed. The footings (F2a,b)
would be either cut at the level of the cuttings or detached from the seabed (perhaps requiring
the use of explosives), cut up and transported to shore, with or without the cuttings. This
would effectively leave a clear seabed as far as the structure was concerned.

9
Calculation based on assuming that a survey vessel can survey 13km of pipeline per day (Case Study A, Eco
05, p.11), and is offshore for 80% of its time.
61
For the pipelines a clear seabed would only be achieved by their removal to shore (P2). Other
scenarios are leaving them in situ with remedial action (P3, cutting or covering unstable or
spanning sections), or burying and leaving them. For the cuttings, again only their removal to
shore (C4) would leave a clear seabed. Other scenarios are covering the undisturbed pile with
layers of inert material such as sand, gravel and rock (C3), or excavating the pile (C2),
which entails using a propeller to direct a low velocity, high volume flow of water vertically
downwards onto the pile, which would scatter it in a thin layer over several hectares, leaving
the material to biodegrade over several years.

Only two scenarios for a concrete structure are considered: left in situ (CON1) and removed
to shore (CON2). Only the latter would leave a clear seabed.

5.2.2 Marine environmental impacts

Table 5.6 describes and assesses (in accordance with the method described above, Section
5.1.4) the impacts on the marine environment of the different scenarios. The table contains a
great deal of very detailed information, mainly from the Case Study A. The outcomes may be
summarised as follows.

The impacts of the reference scenario are described in the first column. In the normal course
of events, and with the exception of the drill cuttings piles, the impacts of leaving all this
material offshore will be small, although the eventual collapse of the topside and jacket
might disturb the cuttings piles in due course. The cuttings piles would render the relevant
area of the seabed sterile for many centuries, but would very gradually biodegrade, and some
material would leach out into the environment. The overall impact of this is assessed as
medium (- -).

All the other decommissioning scenarios (for the structure and pipelines) cause a greater
impact on the marine environment than the reference scenarios, because:
The shallow disposal of the topside (T2) and jacket (J2) would disturb the cuttings
pile. Their removal would give rise to localised disturbances to the environment and
the loss of corals on the decommissioned structures.
The removal of the footings with the cuttings in situ (F2a) could scatter up to 100% of
the cuttings over a wide area, with an impact assessed as - - -. The impacts would be
less, and the same as for the jacket (- -), if the cuttings were removed with the
footings (F2b) (this assessment might also apply to the hybrid options described in
Section 3.1.6, just removing those cuttings around the footings, or cutting the footings
at the level of the cuttings, but it was not possible to assess these options in detail). If
explosives were used to sever the piles from the seabed, there could be damage to
marine organisms (although there are techniques to mitigate this). This would make
the impact assessment for these scenarios more negative.
For the pipelines all the non-reference scenarios involve some damage to the marine
environment, but it is localised and not long term (- -).

For the drill cuttings, covering them (C3) would encourage the re-establishment of a healthy
seabed community, with only short-term environmental disturbance, and is therefore assessed
as -, or positive (+) compared to the reference scenario. Removing the cuttings (C4) with
a suction dredge would also only cause short-term impacts, and is also assessed as -, or
positive (+) compared to the reference scenario. The excavation scenario (C2) involves
significant environmental damage, possibly resulting in a surface oil slick, with an impact on

62
seabirds and sea mammals, and the smothering of benthic organisms over a wide area. To
reflect this, C2 is assessed as - - -, or - (- -) compared to the reference scenario.

5.2.3 Landfill impacts

Table 5.7 gives the evidence for the assessment of landfill impacts, with the assessment
carried out according to the method described in Section 5.1.7. The total landfill impact of
removing the structure and pipelines to shore is relatively small, with 2,173 tonnes of
material landfilled in all, with a total Landfill Impact Factor (LIF) of 3,439. For drill cuttings
it is a very different story. The nearly 40,000 tonnes of cuttings has an LIF of more than
115,000, considerably more than that which the 80,000 tonnes of concrete would have if it
were to be brought ashore.

63
Table 5.6: Evidence for the Assessment of Marine Impacts
Note: In the table the A references, followed by another letter/number refer to documentation from Case Study A. B references refer to Case Study B.
Description and assessment of environmental marine impacts
Structure Component

Assessment relative to

Assessment relative to
reference scenario

reference scenario
Structure type

Assessment

Assessment
Reference scenario Shallow disposal Removal and reprocess (T3 & J3)
(T1, J1 & F 1, CON 1, P1 & C1) (T2 & J2) (Also used in shallow disposal)

A, E01, 12.3:
Most A, E01, 12.3: There would be no
A, E01, 10.5: Disturbance of the pile
Topside

impacts planned discharges of oil or

[resulting from the depositing of the chemicals to sea other than those

-
would be
topside and jacket] would result in the from the normal operations of
very
re-suspension of contaminants into the vessels.
localised and
water column and onto the surrounding
short-lived,
Interactions with cuttings A, E01, 12.4: The long- seabed. A, E01, 10.3: The effects on
and similar
term presence and eventual collapse of the the water column would be localised
to those that A, E01, 12.3: The jacket legs
[structure] would have a bearing on the fate and and temporary because contaminants
arise during and members do not contain any
long-term impacts of the cuttings pile were it to be would be rapidly dispersed and
Jacket

the normal oil or chemicals, and the bulk of

--

--

--

--
left in situ. A, E01, 10.5: Disturbance of the pile diluted.
offshore material that would be handled
would result in the release of contaminants into the
Large fixed steel

activities. is steel and sacrificial anodes

water column and onto the surrounding seabed.
made of aluminium alloy.
Following such disturbance, contaminants are likely
to be bioavailable to marine organisms in the water Removal with cuttings in situ (F2a) Removal with cuttings also removed (F2b)
column and benthos. A, E01, 10.5: Disturbance of
the pile [resulting from the depositing of the topside
A, E01, 12.3, A, Tec 10, p.6:: A
and jacket] would result in the re-suspension of
proportion [in a worst case scenario up
contaminants into the water column and onto the
to 100%] of the drill cuttings pile As with the removal of the topside and jacket,
surrounding seabed. A, E01, 10.3: The effects on
A, E01, 12.4: Over would be re-suspended. The effects on there would be no planned discharges of oil or

---

---
the water column would be localised and temporary

--

--
the water column would be localised
Footings

time the steel because contaminants would be rapidly dispersed chemicals to sea other than those from the normal
structure would and temporary because contaminants operations of vessels.
and diluted.
corrode, but the would be rapidly dispersed and
corrosion products diluted, but the cuttings could re-settle
would be largely over a wide area
inert and not bio-
available, and would It is possible that explosives may be used underwater to sever the piles. Underwater explosions cause pressure waves
not impact the local and loud noises that can be damaging or fatal to marine mammals, finfish and plankton. Some measures to mitigate
benthic or pelagic against this are available.
communities.

64
 Description and assessment of environmental marine impacts (cont.)
Structure Component

Assessment relative to

Assessment relative to

Assessment relative to
reference scenario

reference scenario

reference scenario
Structure type

Assessment

Assessment

Assessment
Reference scenario Leave in situ with remedial action (P3) Removal and reprocessing of pipelines (P2) Bury and leave pipelines (P4)

A, E01, 12.9: A small area of the

A, E01, 12.9: The
A, E01, 12.9: Would result in a small seabed along the length of the
presence of
number of minor impacts to the seabed pipeline would be disturbed, and the
Pipelines

[decommissioned A, E01, 12.9: A small area of the

General

and benthic communities immediately benthic communities there would be

pipelines left in situ] and seabed where remedial action is
adjacent to the pipeline. Where pipelines destroyed. Where pipelines are

--

--

--

--
its slow degradation required would be disturbed, and the

--

would not result in any
significant impacts to the
seabed or the pelagic or
benthic communities.
--
are buried by part of the cuttings pile, buried by part of the cuttings pile,
benthic communities there would be
some contaminated sediments would be some contaminated sediments would
destroyed.
dispersed into the water column, but these be dispersed into the water column,
impacts would be localised and transient. but these impacts would be localised
and transient.

Excavate & leave (C2) Cover (C3) Removal operations (C4)

A, E01, 12.6: The covering operation

A, E01, 10.7: Excavation of the pile
would result in the re-suspension of small A, E01, 12.7: A limited plume may
would create a surface slick of oil that
amounts of cuttings and oil into the water be generated. Some operational
Cuttings

would be evident for the duration of

General

column and the subsequent resettlement upsets, such as a back-flush event

operations, and could impact seabirds
--

of cuttings onto the seabed. It is possible from the suction dredge, may result
- (- -)

A, E01, 12.5: The pile

---

and sea mammals in the area. The

+
-

-
+
would remain in existence, that some clean areas of seabed could be in the discharge of cuttings into the
resettlement would have measurable
and ecologically impacted by the resettlement of oily water column and this could cause
effects on the benthos by smothering
essentially sterile, for at cuttings, and that chemical and biological limited impacts to benthos and
organisms and reducing the diversity
least 1,000 years. perturbation resulting from the presence pelagic organisms.
of communities over a wide area.
Presently, the piles are of the cuttings pile could be increased.
causing only a minimal
impact in the adjacent Reference scenario (CON 01) Remove and reprocess (CON 02)
water column and
surrounding benthos, but
A, 108: The expected scale of the
storm events could cause a
Concrete

environmental impacts of releases of

Tank

faster
B, 106: release
There of
are considered to be no, or no significant, effects of leaching from the concrete and the reinforcement rods of the Ekofisk

--
seawater and gravel/rock connected

--
contaminants.
Tank into the sea and ground. The overall environmental impact of discharges to the sea is assessed as small and negative.
with removal of the Tank is assessed
as small.

65
Table 5.7: Evidence for the Assessment of Landfill Impacts

Footings
Material, tonnes (t) Mass, M MH MB LIF
Cement grout 650 0 0 650
Marine growth 350 0 350 700
TOTAL 1,000 1,350
Jacket
Material, tonnes (t) Mass, M MH MB LIF
Marine growth 700 0 700 1,400
TOTAL 700 1,400
Topside
Material, tonnes (t) Mass, M MH MB LIF
Inert landfill 33 33
Active landfill 211 0 211 422
Hazardous 5 5 0 10
TOTAL 249 465
Whole large steel structure
Material, tonnes (t) Mass, M MH MB LIF
Cement grout 650 0 0 650
Marine growth 1,050 0 1,050 2,100
Inert landfill 33 0 0 33
Active landfill 211 0 211 422
Hazardous 5 5 0 10
TOTAL 1,949 3,215
Pipelines
Material, tonnes (t) Mass, M MH MB LIF
Concrete 224 0 0 224
TOTAL 224 224
Cuttings
Material, tonnes (t) Mass, M MH MB LIF
Cuttings 38,587 38,587 38,587 115,762
TOTAL 38,587 115,762
Concrete structure
Material, tonnes (t) Mass, M MH MB LIF
Cuttings 80,000 0 0 80,000
TOTAL 80,000 80,000
LIF = Landfill Impact Factor (see Section 5.1.7)

66
6. SUMMARY OUTCOMES

6.1 INTERPRETATION OF SUMMARY OUTCOME MATRICES

There now follow summary outcome matrices for each of the decommissioning scenarios
that has been analysed in any detail. These matrices are complex. They are interpreted
verbally in the text in subsequent sections, which accompany the matrices. However, some
preliminary remarks about the matrices may serve to clarify them.

Three colours (in addition to black) have been employed in the matrices:
Material flows are in red.
Energy flows are in blue.
o The Total Energy Requirement (TER) is the total of all the energy
requirements, including the energy required to generate the material to replace
any material left offshore, which would have been recycled if returned to
shore.
o As noted above, TER does not include any energy that might be required for
monitoring in the non-reference scenarios that leave material on the seabed.
o The electricity required to dismantle the structure onshore is solely considered
in the TER column, as electricity is not a direct material input. Therefore, the
sum of the energy inputs shown in the summary matrices do not equate to the
TER for return to shore scenarios requiring dismantling.
Financial expenditures are in green.
o Gross expenditure of scenario is the total cost of the entire decommissioning
scenario to the partnership of owners of the facility.
o Expenditure net of recovered materials is the gross expenditure of the
scenario less the value of any recovered material.
o Additional cost to UK tax payer is the foregone direct tax revenues to the
UK Treasury relative to the reference scenario, which is estimated to be 50%
of the additional expenditure of the scenario.
The assessments of non-financial outcomes are in the form described in Section 5.
o These refer to impacts not captured by any of the financial expenditures.
o The assessments are relative to the reference scenario. The exception to this in
each scenario are the columns under the heading Endpoints of structural
material, which describe the quantities of material left in situ, replaced or
recovered (and associated energy use), with the rate of recovery, where
relevant.
o Some of the assessments are made for impacts which are partly captured by a
financial expenditure, and are partly a non-financial outcome (e.g. landfill);
this assessment is for that proportion of the impact not captured by the
financial expenditure.
o All symbols in the summary matrices are aligned vertically rather than
horizontally.

67
 An implicit valuation of all the non-financial outcomes relative to the reference
scenario is provided by the additional expenditure of a scenario, were it to be adopted
by society. This is discussed in each case in the text accompanying the matrices. It
may be stressed again that the + & - assessments cannot be summed across the
different issues as they are incommensurate.

6.2 SUMMARY OUTCOMES FOR TOPSIDE OF LARGE STEEL STRUCTURE (SEE TABLE 6.1)

The reference scenario for the topside (T1) of a large steel structure is to leave it in situ. This
involves abandoning 20,520 tonnes (t) of materials, of which 20,271t have to be replaced,
with an energy use of 12,523 toe, with associated emissions of CO2, NOx and SO2 as shown
in the table. The non-financial outcomes are the reference against which the other scenarios
are compared. The cost of T1 is taken to be 0, but there is an unquantified residual financial
liability to the owners for the structure and other materials left in situ.

Scenario T2 (removal and shallow disposal of the topside) leaves the same amount of
material from the structure in the sea, but requires 3,790t of diesel and 1,188t heavy fuel oil
(to provide power to run the topside during the decommissioning process), and 1,200t of
temporary steel, as well as 5,060 toe of energy, to carry it out. The 1,200t temporary steel
(which is left in the sea) is added to the material which has to be replaced on shore, so more
energy is required for recycling. The TER has increased by 5,776 toe (46%) over T1, with
proportionately higher associated air emissions. The seabed is not clear (as it was not in T1),
and the outcomes for health and safety, marine impacts, conservation and extraction of
resources and the fishing industry are all more negative than in T1. The landfill outcome is
the same, and fish stocks are likely to have benefited (because the topside was not previously
acting as a reef). The additional expenditure of this scenario is 18.6m (9.3m to UK
taxpayer), and the financial liability to the owner for the materials and structure left in the sea
remains.

Scenario T3 (removal to shore and reprocessing of topside) uses 7,071t (7,279 toe) more
diesel fuel than T1 and 1,188 tonnes (1,152 toe) more heavy fuel oil, but saves 7,839 toe by
recovering, rather than having to replace, the material. 244t of material (211t of which is
active waste) needs to be landfilled in non-hazardous landfill facilities, at a cost of 6,888.
There is an additional 5 tonnes of hazardous waste consisting of such material as LSA (low
specific activity) radioactive material, PCBs and an estimated 4 tonnes of asbestos which
would need to be dealt with by specialist contractors and disposal firms. Cost estimates for
managing these waste streams are not available from Case Study A, and would be difficult to
predict with any level of certainty without more certain knowledge of how it will be
managed, but there is no residual financial liability to the owners for any of this landfilled
material. The TER includes electricity used in onshore dismantling of the topside, which is
not included in the material inputs column. Therefore, as noted above, the TER in this and
the other matrices does not necessarily equal the sum of the energy inputs across the row of
the matrix. Of the other non-financial outcomes relative to T1, T3 produces a clear seabed,
and clear benefits in terms of the conservation and extraction of resources, and to the

68
trawling fishing industry. However, T3 is clearly worse than T1 in respect of fish stocks, and
seems marginally worse in terms of landfill and impacts on the marine environment. The
additional expenditure of T3 is 30.4m (15.2m to UK taxpayer).

6.3 SUMMARY OUTCOMES FOR JACKET OF LARGE STEEL STRUCTURE (SEE TABLE 6.2)

The reference scenario for the jacket (J1) of a large steel structure is to leave it in situ. This
involves abandoning 9,500t of steel and aluminium, all of which has to be replaced, with an
energy use of 7,942 toe, with associated emissions of CO2, NOx and SO2 as shown in the
table. The non-financial outcomes are the reference against which the other scenarios are
compared. The cost of J1 is taken to be 0, but there is an unquantified residual financial
liability to the owners for the structure and other materials left in situ.

Scenario J2 (removal and shallow disposal of the jacket) leaves the same amount of material
from the structure in the sea, but requires 3,122t of diesel and temporary steel and 2,600 toe
of energy, to carry it out. The 600t temporary steel (which is left in the sea) is added to the
material which has to be replaced on shore, so more energy (358 toe) is required for
recycling. The TER has increased by 2,958 toe toe (37%) over J1, with air emissions
increased by an even greater proportion, because of the relative emission intensity of the
diesel. The seabed is not clear (as it was not in J1), and the outcomes for health and safety,
marine impacts, conservation and extraction of resources and the fishing industry are all
more negative than in J1. The landfill outcome, and that for fish stocks, are the same. The
additional expenditure of this scenario is 23m (11.5m to UK taxpayer), and the financial
liability to the owner for the materials and structure left in the sea remains.

Scenario J3 (removal to shore and reprocessing of the jacket) uses 4,339t more materials and
3,852 toe more energy than J1 in the removal, but saves 5,699 toe by recovering, rather than
having to replace, the steel and aluminium. 700t of material (marine growth) needs to be
landfilled, at a cost of 21,000, but there is no residual financial liability to the owners. The
TER of J3 is only 80% that of J1, but it produces more air emissions, because the emission
intensity of offshore diesel use is higher than that of onshore refining. Of the other non-
financial outcomes relative to J1, J3 produces a clear seabed, and clear benefits in terms of
the conservation and extraction of resources, and to the fishing industry. However, J3 is
clearly worse than J1 in respect of health and safety, fish stocks, landfill and impacts on the
marine environment. The additional expenditure of J3 is 27.7m (13.8m to UK taxpayer).

6.4 SUMMARY OUTCOMES FOR FOOTINGS OF LARGE STEEL STRUCTURE (SEE TABLE 6.3)

The reference scenario for the footings (F1) of a large steel structure is to leave them in situ.
This involves abandoning 10,300t of steel and aluminium, all of which has to be replaced,
with an energy use of 7,512 toe, with associated emissions of CO2, NOx and SO2 as shown
in the table. It may be noted that the replacement of the materials for the footings requires
less energy than for the jacket (J1), despite the greater quantity of materials involved,
because the footings contain less energy-intensive aluminium. The non-financial outcomes of
F1 are the reference against which the other scenarios are compared. The cost of F1 is taken

69
to be 0, but there is an unquantified residual financial liability to the owners for the footings
left in situ.

Scenario F2a (removal of the footings but leaving the drill cuttings in situ, with no distinction
made between cutting the footings at the level of the cuttings and removing them entirely)
requires 4,201t of diesel and temporary steel and 3,608 toe of energy to recover the materials,
but saves 5,104 toe by recovering, rather than having to replace, the steel and aluminium.
1,000t of material (cement grout and marine growth) needs to be landfilled, at a cost of
21,550, but there is no residual financial liability (for the footings, though that for drill
cuttings will remain) to the owners. The TER of F2a is only 85% that of F1, but it produces
more air emissions. Of the other non-financial outcomes relative to F1, F2a does not produce
a clear seabed (because the cuttings are left in situ), and is clearly worse than F1 in terms of
health and safety, impacts on the marine environment, landfill and fish stocks. However, F2a
is clearly better than F1 in terms of the conservation and extraction of resources, and in
respect of the fishing industry. The additional expenditure of F2a is 26.5m (13.3m to UK
taxpayer).

The material and energy outcomes of Scenario F2b (removal of the footings and the drill
cuttings to shore) are taken to be the same as F2a, the extra materials and energy required to
remove the cuttings being assigned to the cuttings decommissioning scenario. A difference
between F2b and F2a is that in F2b there is no residual financial liability to the owners for
either the footings or drill cuttings. The TER of F2b is the same as that of F2a. The other
non-financial outcomes of F2b are similar to F2a, except that now there is a clear seabed (the
fate of the cuttings is considered under the cuttings decommissioning scenario), and more
benefits to the fishing industry. The additional expenditure of F2b is the same as that of F2a.

6.5 SUMMARY OUTCOMES FOR ENTIRE LARGE STEEL STRUCTURE (SEE TABLE 6.4)

The reference scenario for the entire large steel structure is to leave it in situ, combining the
three in situ references scenarios for the individual components of the structure (T1, J1, F1).
This involves abandoning over 40,000t of metals, all of which has to be replaced, with an
energy use of 27,976 toe, with associated emissions of CO2, NOx and SO2 as shown in the
table. The non-financial outcomes are the reference against which the other scenarios are
compared. The cost of this reference scenario for the whole structure is taken to be 0, but
there is an unquantified residual financial liability to the owners for the structure (and any
other materials left in situ).

The next whole-structure scenario to be considered is the removal and shallow disposal of the
topside and jacket (T2, J2), while leaving the footings in situ (F1). This leaves the same
amount of material from the structure in the sea, but requires 9,300t of diesel and temporary
steel and 7,760 toe of energy, to carry it out. The 1,800t temporary steel (which is left in the
sea) is added to the material which has to be replaced on shore, so more energy is required
for recycling. The TER has increased by 8,734 toe (31%) over the whole-structure reference
scenario, with proportionately higher associated air emissions. The seabed is not clear (as it
was not in the reference scenario), and all the other non-financial outcomes are worse than in

70
the reference scenario, except for landfill, which is the same, and fish stocks, which benefit
from the reef effects of the shallow disposal. The additional expenditure of this scenario is
41.6m (20.8m to UK taxpayer), and the financial liability to the owner for the materials
and structure left in the sea remains.

Removal of the whole structure to shore for reprocessing (T3, J3, F2a,b) uses 17,998t more
materials and 15,896 toe more energy than the whole-structure reference scenario (TI, J1,
F1), but saves 18,642 toe by recovering, rather than having to replace, the metals. 1,949t of
material (the sum of that from T3, J3, F2a,b) needs to be landfilled, at a cost of 49,348, but
there is no residual financial liability to the owners. The TER of this scenario is only 94%
that of the whole-structure reference scenario, but it produces more air emissions. Of the
other non-financial outcomes relative to this reference, this scenario produces a clear seabed,
and clear benefits in terms of the conservation and extraction of resources. It is also positive
for the fishing industry. However, the scenario is clearly worse than the reference in respect
of health and safety, fish stocks, landfill and impacts on the marine environment. The
additional expenditure of the scenario is 84.6m (42.3m to UK taxpayer).

6.6 SUMMARY OUTCOMES FOR A MOSTLY CONCRETE STRUCTURE (SEE TABLE 6.5)

The reference scenario (CON1) for the mostly concrete structure is to leave it in situ. This
involves abandoning over 1mt of materials, 46,134t of which are metals, while the rest is
ballast and concrete. Most of this has to be replaced onshore, with an energy use of 30,649
toe, with associated emissions of CO2, NOx and SO2 as shown in the table. The non-
financial outcomes are the reference against which the other scenarios are compared. The
cost of this reference scenario for the whole structure is taken to be 0, but there is an
unquantified residual financial liability to the owners for the structure (and other materials
left in situ).

The scenario CON2 entails removing the structure to shore for reprocessing. This uses
61,204t (63,005 toe) more diesel fuel than CON1, but saves 20,718 toe by recovering, rather
than having to replace, the materials. 83,700t of material (80,000t of which is concrete, the
rest being marine growth) needs to be landfilled, at a cost of 1.47m, but there is no residual
financial liability to the owners. The TER of CON2 is 189% more than that of CON1, and air
emissions are also much greater (though less than proportionately), due to the high energy
requirement of recovering the materials. Of the other non-financial outcomes relative to this
reference, CON2 produces a clear seabed, and clear benefits in terms of the conservation and
extraction of resources. It is also positive for the fishing industry. However, the scenario is
clearly worse than CON1 in respect of health and safety, fish stocks, landfill and impacts on
the marine environment. The additional expenditure of the scenario is 286.7m (143.4m to
UK taxpayer).

71
6.7 SUMMARY OUTCOMES FOR PIPELINES (SEE TABLE 6.6)

Outcomes for four decommissioning scenarios for large pipelines are summarised in Table
6.6. The reference scenario (P1) is to leave them in situ with no remedial action. This
involves abandoning 5,351t of materials, 5,127t of which have to be replaced onshore, with
an energy use of 2,386 toe, with associated emissions of CO2, NOx and SO2 as shown in the
table. The non-financial outcomes are the reference against which the other scenarios are
compared. The cost of this reference scenario for the whole structure is taken to be 0, but
there is an unquantified residual financial liability to the owners for the materials left in situ.

The scenario P2 entails removing the pipelines to shore for reprocessing. This uses 2,046t
(2,107 toe) more diesel fuel than P1, but saves 1,578 toe by recovering, rather than having to
replace, the materials. 224t of concrete needs to be landfilled, at a cost of 3,808, but there is
no residual financial liability to the owners. The TER of P2 is 28% more than that of P1, but
air emissions, especially of NOx, are proportionately much higher than this, because of the
NOx intensity of burning the diesel. Of the other non-financial outcomes relative to P1, P2
produces a clear seabed, and clear benefits in terms of the conservation and extraction of
resources. It is also positive for the fishing industry, and no worse than P1 for health and
safety and fish stocks. There is a small negative outcome in respect of landfill and impacts on
the marine environment. The additional expenditure of the scenario is 19.9m (10m to UK
taxpayer).

The scenario P3 entails leaving the pipelines in situ with remedial action. This uses only 259t
(267 toe) more diesel fuel than P1, but leaves the same amount of material in the sea, and the
same amount to be replaced, and leaves residual financial liability for owners. The TER of
P3 is 11% more than that of P1, but extra NOx are again proportionately much higher than
this (though less than in P2). Of the other non-financial outcomes relative to P1, P3 is only an
improvement in respect of the fishing industry, is the same in respect of health and safety,
fish stocks and landfill, and is worse in respect of natural resources and the marine
environment. The additional expenditure of P3 is 1m (m to UK taxpayer).

The scenario P4 entails trenching and burying the pipelines. It is very similar to P3, leaves
the same amount of material in the sea, and the same amount to be replaced, although the
pipelines are now covered, and leaves residual financial liability for owners. It uses 920t (947
toe) more diesel fuel than P1. Its TER is 40% more than that of P1, with higher emissions,
with extra NOx again proportionately much more increased. Air emissions are also greater
than P3, though less than P2. The other non-financial outcomes are the same as for P3. The
additional expenditure of P4 is 25m (12.5m to UK taxpayer).

6.8 SUMMARY OUTCOMES FOR DRILL CUTTINGS (SEE TABLE 6.7)

Outcomes for four decommissioning scenarios for drill cuttings are summarised in Table 6.7.
The reference scenario (C1) is to leave them in situ with no covering. This involves
abandoning 40,000t of materials, but the great majority of these are waste materials, and only
1,413t of recoverable waste oil (contained in the cuttings) have to be replaced onshore. There

72
is no energy use or air emissions in C1. The non-financial outcomes are the reference against
which the other scenarios are compared. This is the only reference scenario which is given a
negative impact on the marine environment (- -), because of the long-term ecological
sterility of the cuttings pile and the continuous low-level leaching of contaminants from
it.The cost of this reference scenario for the whole structure is taken to be 0, but there is an
unquantified residual financial liability to the owners for the materials left in situ.

The scenario C2 entails excavating and leaving the cuttings. This uses only 772t (794 toe)
more diesel fuel than P1, but leaves the same amount of material in the sea, and the same
amount to be replaced, and leaves residual financial liability for owners. The TER and air
emissions of C2 are obviously higher than the zero in this category of C1. Of the other non-
financial outcomes relative to C1, C2 is the same in respect of health and safety, landfill, the
fishing industry and fish stocks, but worse in respect of natural resources and the marine
environment. The additional expenditure of C2 is 5.1m (2.6m to UK taxpayer).

The scenario C3 entails covering and leaving the cuttings (with or without the base of the
footings left in place). This uses 4,004t (4,122 toe) more diesel fuel than C1, and about
166,000t of sand and gravel. The same amount of material is left in the sea, and the same
amount has to be replaced as in C1, although the cuttings are now covered, perhaps reducing
the financial liability for owners. C3 produces far more air emissions than the zero emissions
of C1, but also nearly six times the CO2, and higher other air emissions, than C2. Of the
other non-financial outcomes relative to C1, C3 is the same in respect of health and safety
and landfill, better in respect of the fishing industry, fish stocks and the marine environment,
but worse in respect of natural resources, with especially high resource extraction impacts
because of the amount of sand and gravel used. The additional expenditure of C3 is 10.3m
(5.1m to UK taxpayer).

The scenario C4 entails removing the cuttings to shore for reprocessing. This uses 9,073t
(9,340 toe) more diesel fuel than C1, which is partially offset by the 1,413t (1,370 toe) of
recovered oil. 38,587t of material needs to be landfilled, at a cost of 655,984, but there is no
residual financial liability to the owners. The TER of C4 is 8,036 toe more than that of C1,
with correspondingly high air emissions. Energy use is nearly twice, and air emissions are
more than twice, those of C3. Of the other non-financial outcomes relative to C1, C4
produces a clear seabed, and benefits in respect of the fishing industry, fish stocks and the
marine environment. It is the same for health and safety. However, it is very much worse
than C1 in terms of landfill (assuming the cuttings cannot be processed into an inert
construction material), and also negative in terms of resource extraction, and resource
conservation (because of the extra diesel use). The additional expenditure of the scenario is
38.9m (19.4m to UK taxpayer).

The information and evidence in this section about the different decommissioning scenarios
has relied most heavily on one case study, here called Case Study A, with evidence drawn
from a limited number of other studies. This reflects the fairly limited experience with
decommissioning, especially of large steel structures, in the North Sea to date and therefore
the limited availability of relevant data. However, it is clear the conclusions to be drawn from

73
the evidence in this study will only apply to decommissioning in the North Sea more widely
if Case Study A, and to a lesser extent the other case studies, are representative of other
structures to be decommissioned, or other aspects of decommissioning. The next section,
following the summary matrixes, explores the extent to which this might be the case.

74
Table 6.1: Summary Outcomes for Topside of Large Steel Structure

75
Table 6.2: Summary Outcomes for Jacket of Large Steel Structure

76
Table 6.3: Summary Outcomes for Footings of Large Steel Structure

77
Table 6.4: Summary Outcomes for Entire Large Steel Structure

78
Table 6.5: Summary Outcomes for a Mostly Concrete Structure

79
Table 6.6: Summary Outcomes for Pipelines

80
Table 6.7: Summary Outcomes for Drill Cuttings

81
7. ASSESSMENT OF THE WIDER APPLICABILITY OF RESULTS

In making its assessment of the different decommissioning scenarios, this study has
presented information on the following issues:

Assessed quantitatively (Section 4)

15. Material inputs;
16. Material endpoints (of the material being decommissioned);
17. Total energy requirement (TER);
18. Total gaseous emissions;
19. Financial expenditures;
Assessed qualitatively (Section 5)
20. A clear seabed;
21. Health and safety of personnel directly involved in the decommissioning process;
22. Jobs in the UK;
23. Impacts on the marine environment;
24. Conservation of non-renewable resources;
25. Impacts of resource extraction;
26. Impacts of landfill;
27. Impact on the fishing industry; and
28. Impacts on fish (and other marine life).

The purpose of this section is to explore to what extent the results obtained from a limited
range of case study material might be more generally applicable to decommissioning in the
UK sector of the North Sea as a whole.

7.1 ASSESSMENT OF THE GENERIC NATURE OF THE LARGE STEEL STRUCTURE RESULTS

This report has relied on a few case studies, and there is little other detailed information
about North Sea decommissioning in the public domain. However, it is hoped that the
conclusions from this report will be relevant to more structures than just the ones studied.
This section explores the extent to which this may be the case.

A key group of structures facing decommissioning in the next few years are the larger steel
structures which are typically found in deeper water in the Northern North Sea, with footings
fixed to the seabed. Those with jackets with masses of greater than 10,000 tonnes (10kt) are
eligible to apply for derogation to leave the footings in situ under the rules of the OSPAR
convention. Case Study A from this group of structures provided much of the information for
this report. Figure 7.1 shows the distribution of jacket masses for all such eligible steel
structures, and Case Study As place within the distribution. It can be seen that Case Study A
is centrally placed (ranked 13th) in the group of 25 structures with jacket masses between
10kt and 20kt. A further 8 structures have masses of over 20kt.
Figure 7.1: Distribution of Jacket Masses: UK Structures Eligible for OSPAR
Derogation 98/3

50
Jacket mass (kt)

40

30

20

10

0
A
11

15

17

19

21

23

25

27

29

31

33
1

y
ud
st
e
as
C

Structure

Source: UKOOA 2001, Appendix II, Page 23

Note: The heaviest structure (ranked 33rd) is beyond the range of the Y-axis at 88kt as it has a large quantity of concrete
within the jacket.

Figure 7.2: Distribution Of Jacket Depth: UK Structures Eligible For OSPAR

Derogation 98/3
200

180

160
Case study A
140
Water depth (m)

120

100

80

60

40

20

0
1 4 7 10 13 16 19 22 25 28 31

Structure

Source: UKOOA 2001, Appendix II, Page 23

Note: Data on water depth is not available for one of the 33 large steel structures on the UKCS

83
Figure 7.2 shows that in terms of water depth Case Study A, in about 140m of water, is
ranked 23rd out of the 32 eligible structures on the UK Continental Shelf (UKCS) for which
data is available. 20 structures (ranked 9-28) are in 120-160m of water, and Case Study A is
in the middle of this mid-depth distribution. Only 4 structures are in deeper water than 160m.

Figure 7.3 combines the data for jacket mass and depth for large steel structures on the
UKCS. It shows that the great majority of structures including Case Study A have a mass of
between 10kt and 20t and stand in 80-160m of water. Case Study A is at the upper end of the
section of the distribution showing a broadly linear, but shallow, relationship between mass
and depth. If anything, Case Study A has a low mass in relation to its depth.

Figure 7.3: Jacket Mass Against Depth of Water for Large Steel Structures on the
UKCS

50
45
40
Jacket mass (kt)

35
30
25
20
15 Case study A

10
5
0
0 50 100 150 200
Depth (m)

Source: UKOOA 2001, Appendix II, p.23

Note: A single data point (Harding) has been removed as it stands-out from the rest of the dataset due to its high proportion
of concrete, and therefore the results presented in the report are not considered applicable to the decommissioning of the
jacket or footings of this structure.

The extent to which results for Case Study A are relevant to other structures is a complex
matter, and is determined by a wider set of characteristics than just its mass and water depth,
some of which are explored further below. However, these two parameters show that Case
Study A can be considered as a mid-range structure in terms of mass and water depth. The
topsides of all these structures will tend to be similar in terms of their decommissioning
requirements as their design was constrained by the carrying capacity of the lifting vessels
available. Clearly there may be important differences in the construction of large jackets, the
structures may have worn and weathered differently during their service lives, and additions
or modifications will have been made to some of them. Detailed plans for decommissioning

84
will obviously need to made for structures on a case-by-case basis, but there is nothing in the
basic nature of the structure studied in Case Study A to suggest that the kind of overview
results that have been derived for this report would not be more generally applicable to large
steel structures other than Case Study A. In fact, this studys findings would certainly seem
to be highly relevant to those structures of similar weight and depth to Case Study A (the
majority of large steel structures), although one might expect differences for structures in
shallower water or structures that are significantly heavier (see Figure 7.3). The particular
nature of the drill cuttings pile in relation to the footings is the key factor that may lead to
different conclusions, as discussed in the next section. This conclusion is borne out by the
analysis of some further characteristics below.

7.2 ASSESSMENT OF THE GENERIC NATURE OF DRILL CUTTINGS PILE RESULTS

The only available parameter against which the generic nature of the drill cuttings pile results
can be assessed is the volume of the pile. A comprehensive comparison of the toxic
composition of the cuttings piles would involve a far more complex exercise of interpreting
sampling data, which does not exist for the vast majority of cuttings piles on the UKCS.
Therefore the hazards particular to each cuttings pile will need to be assessed on a case-by-
case basis when decommissioning is being considered. However, the energy, material and
financial expenditures required for decommissioning drill cuttings piles are comparable for
all cuttings piles of broadly the same size.

Table 7.1: Comparison of Volumes of Case Study Drill Cuttings Pile with Other
Cuttings Piles in the Northern and Central North Sea

Northern North Sea Central North Sea Central and Northern North Sea
Total Volume (m3) 503,218 787,500 1,290,718
Average Volume (m3) 13,978 9,488 11,733
Case Study A (m3) ~25,000 ~25,000
Maximum Volume (m3) 45,000 41,233 45,000
Minimum Volume (m3) 801 252 252
Source: Source: UKOOA 2002, Phase 1, Determination of the Physical Characteristics of Cuttings Piles, using Existing
Survey Data and Drilling Information

Table 7.1 shows that the Case Study A cuttings pile, with a volume of about 25,000 m3, is
about twice the average volume of piles in the Central and Northern North Sea.

Figure 7.4 shows that the cuttings pile volume of Case Study A is ranked 37th out of the 46
structures listed in the source, and is about at the mid-point of the 22 piles larger than 10,000
m3, and there are 24 piles smaller than this. So Case Study A can be considered as towards
the upper end of the volume distribution of drill cuttings piles found on the UKCS.

In comparison with smaller cuttings piles, the management of the cuttings pile of Case Study
A seems likely to provide economies of scale (although it has not been possible to quantify
them in this report) in terms of:

1. Any fixed testing, administrative and monitoring costs;

85
 2. Material required to cover the cuttings pile and therefore the costs and energy
requirement of this material; and
3. More general economies of scale associated with handling larger volumes of cuttings.

Similarly, further economies of scale might be available in respect of these factors for the
cuttings piles larger than that of Case Study A, but it has not been possible to estimate these.

Figure 7.4: Mapped North Sea Cuttings Pile Volumes (000's m3)

50
Mapped pile volume (000's m 3)

40

30
Case study A

20

10

-
1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45
Cuttings piles

Source: UKOOA 2003, Phase 1, Determination of the Physical Characteristics of Cuttings Piles, using Existing Survey Data
and Drilling Information - Table 1&2
Notes: Data only available for 46 of the 124 facilities listed.

7.3 COMPARISON OF FINANCIAL EXPENDITURES

In Section 4.1 it was noted that the financial expenditures related to the structure, pipelines
and drill cuttings of Case Study A, and the concrete tank of Ekofisk (Case Study B). Because
of differences between the structures, and their current condition, extension of these financial
expenditures to other structures should be done with great caution and only very broad
conclusions drawn from the results. In respect of Case Study A, the calculations for the
pipelines costs especially may not representative of the North Sea as a whole. Because
Ekofisk is a very particular structure, no extension to other structures has been considered
possible, so it has been excluded from Table 7.2.

Table 7.2 shows the expenditures that have been calculated in relation to Case Study A, and
has scaled these up for the North Sea as a whole to give a very rough estimate of what the
various decommissioning scenarios would cost if they were applied to 32 large steel
structures (one large steel structure has been excluded, because it is exceptional in containing
a large mass of concrete) across the North Sea.

86
It can be seen that, with the exception of pipelines (for which trenching and burying is the
most expensive scenario), the highest cost scenarios are for removal to shore. If applied
across the North Sea, these could entail a total expenditure of 12.2bn (of which over 7bn
relates to pipelines10), of which, as has been noted before, around 6bn would be provided by
the UK taxpayer through foregone tax revenues. Leaving the footings, pipelines and drill
cuttings in situ would save 9bn of this total expenditure, even once monitoring had been
provided for. These figures are very rough, but they are of the same order as the 8.8 billion
cost for decommissioning estimated by UKOOA and cited in Section 3.1.5, especially when
the uncertainty involved in the scaling up of the pipeline estimates for Case Study A is taken
into account. Both numbers give an idea of the enormous resources involved in
decommissioning and the importance, to both the industry and the public exchequer, of the
decisions about derogations of footings, pipelines and drill cuttings that will need to be taken
in the not-too-distant future.

Table 7.2: Decommissioning Expenditures for the Different Scenarios Scaled Up

Across the North Sea

Scenario Net Case Study Relevant parameter Total for Scaled up Remove all
A expenditure in scenario parameter in expenditure for to shore
compared to North Sea1 North Sea, m scenarios, m
reference, m
T2 18.6 20.5 kt materials 720 kt 653
T3 30.4 20.5 kt materials 720 kt 1,068 1,068
J2 23.0 10 kt materials 353 kt 812
J3 27.7 10 kt materials 353 kt 978 978
F2a 26.5 11 kt materials 397 kt 956
F2b 26.5 11 kt materials 397 kt 956 956
P2 19.9 26 km pipelines 9,400 km 7,195 7,195
P3 1.0 26 km pipelines 9,400 km 362
P4 25 26 km pipelines 9,400 km 9,038
C2 5.1 25 km3 cuttings 1.3 million m3 265
C3 10.3 25 km3 cuttings 1.3 million m3 536
C4 38.8 25 km3 cuttings 1.3 million m3 2,018 2,018
1 For the structural components (topside, jacket, footings) the total mass of 27 large steel structures
(1.24mt) was taken from Infield Systems 2000, scaled up by the mean mass to 1.47mt for 32 structures,
and divided between topside, jacket and footings according to the ratios for the Case Study A
structure

7.4 COMPARISON OF TOTAL ENERGY REQUIREMENT

Tables 7.3a, b compare the decommissioning results for the TER for the total removal
scenario for a large steel structure from this study with the results from Case Study A and
experience with the decommissioning of Ekofisk. The results from this study are similar to
the Case Study A results, not surprisingly, because they are generated by broadly the same

10
Note the earlier remark about the pipeline calculations being particularly specific to Case Study A. The
results from scaling up should be treated with special caution in this case.

87
model with a similar data set. The Ekofisk results are derived from an aggregate of the
decommissioning estimates for 13 smaller steel structures (with no footings), which in total
have a greater TER, and greater TER per tonne of material, than the large steel structure
represented by Case Study A. For pipelines the situation appears to be different, with the
Ekofisk estimates showing its pipeline decommissioning less energy-intensive than those for
Case Study A. There are many possible reasons for these differences, including differences in
removal techniques or economies of scale (of decommissioning one large structure over 13
smaller ones). Perhaps more significant is the fact that the estimates do not vary by more than
about 50%. Comparing the drill cuttings results from this study and Case Study A with those
from UKOOA (2002) leads to a similar level of variation in estimates. Perhaps the most
important conclusion from this analysis is that not much weight should be attached to
differences in energy outcomes from scenarios applied to different kinds of structure if these
are less than 50%, because these would seem to be within the possible margin of error of the
data.

Table 7.3a Comparison of Different Estimates of Total Energy Requirement (TER)

for the Removal of a Large Steel Structure and Associated Pipelines and Cuttings

Energy toe This Study Case Study A Scaled Ekofisk UKOOA JIP
Footings 6,351 6,692
Jacket 6,391 6,670 7,654
Topside 13,717 14,333 20,612
Large steel 26,459 27,695
Pipelines 3,062 2,837 2,317
Cuttings 8,036 9,538 6,401

Table 7.3b Comparison of Different Estimates of Total Energy Requirement (TER)

per Tonne of Material Removed for the Removal of a Large Steel Structure and
Associated Pipelines and Cuttings.

Energy toe/t This Study Case Study A Ekofisk UKOOA JIP

Footings 0.56 0.59
Jacket 0.63 0.65 0.75
Topside 0.67 0.70 1.00
Large steel 0.63 0.66
Pipelines 0.57 0.53 0.43
Cuttings 0.20 0.24 0.161
1
The UKOOA JIP cuttings TER is based on an estimate of 6.7 GJ/tonne (UKOOA 2002, p.23, and Question 66)

7.5 COMPARISON OF OTHER NON-FINANCIAL OUTCOMES

As noted above the other non-financial outcomes that have been assessed (qualitatively) in
this study are: clear seabed (or otherwise); health and safety of personnel directly involved in
the decommissioning process; jobs in the UK; impacts on the marine environment;

88
conservation of non-renewable resources; impacts of resource extraction; impacts of landfill;
impact on the fishing industry; and impacts on fish (and other marine life).

In respect of these issues, and taking account of the approach that has been taken to them, it
seems that Case Study A may differ from other large steel structures more obviously in
respect of its decommissioning impacts on the marine environment (and perhaps consequent
impacts from landfill), particularly from any decisions that might be taken over its drill
cuttings pile. As noted above, drill cuttings piles could vary widely between structures, and
each one will need to be the subject to its own analysis.

Having said that, none of the evidence submitted has suggested that Case Study As drill
cuttings pile is either particularly toxic, or particularly environmentally benign, compared to
other drill cuttings piles. There is therefore no reason for thinking that the results for Case
Study As drill cuttings are not a reasonable first estimate of what is likely to be involved in,
and the outcomes of, decommissioning drill cuttings piles, certainly until further evidence
becomes available. Clearly, however, the paucity of evidence in this area should hedge with
caution the kinds of conclusions to be drawn.

With regard to all the other non-financial outcomes listed above, there seems no reason not to
treat Case Study A as a reasonable point of departure for a broad comparison of outcomes
from different decommissioning scenarios as has been carried out here.

89
8. CONCLUSIONS

8.1 OVERVIEW OF DECOMMISSIONING ASSESSMENTS AND IMPLICIT VALUATIONS

Table 8.1 presents an overview of all the scenarios that have been discussed, with the non-
financial outcomes and the net expenditure of the scenario relative to the reference scenario.

8.1.1 Total energy requirement (TER)

The first broad conclusion, from the TER column, is that taking account of the energy needed
to replace materials left in situ makes a difference. Indeed, it is decisive in terms of net
energy use for both J3 and F2, which remove the jacket and footings respectively to shore
and which use less energy than the reference scenario (because of not having to replace from
virgin sources the metals recovered from offshore).

8.1.2 Air emissions

The second conclusion is that air emissions from all the scenarios are worse than in the
reference case. This is because offshore diesel use is emission-intensive (especially of NOx -
see the summary matrices in Section 6 for the detail of the actual emissions), so that even
those scenarios (J3, F2) which use less energy than the reference, produce more emissions.

8.1.3 Clear seabed and resource conservation

A third clear conclusion that emerges from Table 8.1 is the correlation between the scenarios
that produce a clear seabed and those that produce positive results in terms of conservation of
the stock of non-renewable resources and resource extraction. This is not surprising, as much
of the material removed to shore is recyclable metals. The exception is C4, because the drill
cuttings contain very little useful material for recycling (the data was not available to the
project to assess the possibility of converting the drill cuttings into an inert cionstruction
material).

On the other hand, the scenarios that produce a clear seabed also tend to be associated with
negative environmental impacts from landfilling, which can be considerable (especially
CON2 and C4, as evaluated).

8.1.4 Impact on the marine environment

A fourth clear result is that, compared to the reference, and with the exception of the drill
cuttings, all the scenarios have a negative impact on the marine environment, and with some
(F2a, C2) this is pronounced. This is because most of the structural material and the pipelines
are inert. Leaving it in situ therefore has few implications for the marine environment.
Removing it to shore, however, involves extensive industrial activities offshore that can
cause environmental disturbance, though in most cases these are only of medium or small
scale and are short-lived. The drill cuttings piles are different, because of their long-term
ecological sterility and slow leakage of contaminants (with the potential for faster leakage if
disturbed) if left in situ uncovered (C1). Both covering (C3) ad removal (C4) are assessed as
being relatively positive (compared to the reference scenario) for the marine environment.
Excavation (C2) is worse, and is likely to be unacceptable on environmental grounds alone.

90
Table 8.1: Overview of Non-financial Outcomes from Decommissioning Scenarios and Associated Net Expenditures (cost),
Compared with Reference Scenario

Scenario TER CO2 NOx SO2 Clear Residual Health Marine Stock of Resource Land Fishing Fish Net cost, m
seabed financial & impacts resources extraction -fill industry stocks1 (50% UK
liability safety taxpayer)
T2 -- -- --- -- Not clear Yes = - - - = -- ++ 18.6 (9.3)
T3 - - --- - Clear No = -- +++ +++ - + = 30.4 (15.2)
J2 -- -- --- -- Not clear Yes -- - - - = -- = 23.0 (11.5)
J3 + - --- -- Clear No -- -- ++ +++ -- + --- 27.7 (13.8)
F2a + - --- -- Not clear Yes --- --- +++ +++ -- ++ -- 26.5 (13.3)
F2b + - --- -- Clear No --- -- +++ +++ -- ++ -- 26.5 (13.3)
T2,J2,F1 - - --- - Not clear Yes -- -- - - = -- ++ 41.6 (20.8)
T3,J3,F2 + - --- - Clear No --- --- +++ +++ -- + --- 84.6 (42.3)
CON2 --- --- --- --- Clear No -- -- +++ +++ --- + --- 286.7
(143.4)
P2 - -- --- --- Clear No = -- ++ +++ - ++ = 19.9 (10.0)
P3 - -- --- - Not clear Yes = -- - - = ++ = 1.0 (0.5)
P4 -- -- --- -- Covered Yes = -- - - = ++ = 25 (12.5)
C2 --- --- --- --- Not clear Yes = - - (-) - - (- -)2 = = = 5.1 (2.6)
C3 --- --- --- --- Covered Yes = - - +2 = + + 10.3 (5.1)
C4 --- --- --- --- Clear No = -- - +2 --- + + 38.8 (19.4)
1.1.1.1.1.1 1 Also includes some other aspects of marine biodiversity 2 Compared with the C1 impact of - -

1.1.1.1.1.2 Key to Scenarios

All 1 scenarios are reference scenarios Leave in situ
T: Topside T2 Removal and shallow disposal; T3 Return and reprocess on shore (applicable to all structures)
J: Jacket J2 Removal and shallow disposal J3 Return and reprocess on shore (applicable to large steel structures)
F: Footings F2a Remove with cuttings left in situ F2b Remove with cuttings taken to shore (applicable to large steel structures)
CON: Mostly concrete structure CON2 Return and reprocess onshore (applicable to concrete structures)
P: Pipelines P2 Remove and reprocess onshore P3 Leave in situ with remedial action P4 Trench and bury
C: Drill cuttings C2 Excavate and leave C3 Cover and leave C4 Remove and treat onshore

91
8.1.5 UK Employment
No conclusions have been drawn about whether the decommissioning scenarios will provide
net employment in the UK. This is not because there is any doubt as to whether
decommissioning will employ people in itself. Obviously any major programme of
expenditure will directly generate jobs. One issue is that, with an international activity like
decommissioning, there is no knowing in advance what proportion of these jobs will be in the
UK. The other issue is that the net employment effect of decommissioning will depend not
only on the number jobs it directly generates, but the comparison of that number with the
number of jobs that would be created by the likely alternative use of decommissioning
expenditures (in both the private and public sectors, if some decommissioning expenditures
represent foregone tax payments), if decommissioning were not to be carried out. There is no
way of knowing what this alternative use of the money might be, nor, in the case of private
expenditures, whether they would be spent in the UK. Speculation on these matters has been
avoided.

8.1.6 Costly scenarios

Easily the most expensive scenario is CON2, the return to shore of a large, mainly concrete
structure. The resources reclaimed are overwhelmingly concrete and ballast, which are not
scarce non-renewable resources, although the impacts associated with their extraction can be
considerable. This provides the first opportunity for an implicit valuation of a
decommissioning outcome. The net environmental benefits of this scenario are a clear
seabed, the reclamation of nearly 1mt of materials (920 kt of which were aggregates) and the
avoidance of the environmental costs of their extraction, net of the extra air emissions,
impacts on the marine environment and fish stocks, and significant extra landfilling involved.
While valuations of these environmental impacts may vary between stakeholder groups, it is
by no means certain that the net environmental benefits are positive. Other non-financial
impacts are a small benefit to the fishing industry and a worse outcome on health and safety.
If society were to choose CON2, it would be equivalent to saying that overall it considered
these net benefits to be worth 287m in total, and 143m in terms of public expenditure.

The next most expensive single scenario is C4, the return of cuttings to shore. This would
deliver a clear seabed, with the re-establishment of an ecosystem, in place of the largely
sterile and contaminated drill cuttings pile. There would also be a small benefit to fish stocks
in terms of the removal of a possible source of toxic contamination. There would also be a
benefit to the fishing industry in opening up new grounds to trawling (a development which
would certainly remove the direct benefit of this scenario to fish stocks). The environmental
costs of this scenario, compared to the reference scenario, are substantial: large scale energy
use and air emissions, and maximum negative scores in terms of landfill and resource
extraction. Some stakeholders may feel that the achievement of a clear and regenerating
seabed is worth both these environmental impacts and the nearly 40m it would cost in the
case of this one cuttings pile. Clearing the UKCS of cuttings piles would, as noted above (see
Table 7.2), be likely to cost nearer 2bn. Others might feel that the seabed gain is outweighed
by the other environmental and the financial costs, that the money, including the roughly
50% of expenditure that would come from the UK taxpayer, could be better spent.

92
8.1.7 Covering pipelines
The benefits of covering pipelines (P4) go entirely to the fishing industry, there are a number
of negative environmental impacts and it is relatively expensive. P2 is slightly worse in terms
of SO2 emissions and landfill, but has clear advantages in terms of resource extraction and
the stock of non-renewable resources, achieves a clear seabed and is 20% cheaper. P2 on this
assessment therefore seems superior to P4 both environmentally and financially (though it
should be remembered that the Case Study A structure to which it applies may not be
representative of pipelines around other structures, which may be smaller in diameter and
therefore less costly to cover).

8.1.8 Decommissioning the structure

A final set of comparisons can be made in respect of the components of the large steel
structures, between those scenarios which envisage their removal to shore (T3, J3, F2a,b) and
those that do not (the reference scenarios T1, J1, F1 and the shallow disposal scenarios, T2,
J2). The pattern of relative benefits between these scenarios is quite clear. Those that involve
removal to shore achieve a clear seabed, conserve the stock of resources and reduce the
resource extraction to produce from virgin sources the material that has been recovered. They
also benefit the fishing industry. For the jacket and footings the removal scenarios (J3,
F2a,b) also conserve energy, although they have more emissions, because of the high relative
emission intensity of offshore diesel use. On the negative side, their health and safety
implications, and their impacts on the marine environment and in terms of landfill are worse
than the in-situ scenarios, which also benefit fish (except for T3) rather than the fishing
industry.

The removal scenarios are, not surprisingly, more expensive, by 20-30m for each of the
three components, or by about 85m overall, compared to the reference scenarios, but by
much less (only 4.7m between J2 and J3) compared with shallow disposal. Moreover, all
the in-situ scenarios involve some degree of monitoring, which, as noted above, is a cost and
has a small environmental impact which have not been included in the assessment. A
financial (though unquantified) benefit of all the clear seabed scenarios, as far as the industry
is concerned, is that they extinguish any residual financial liability. It may well be that the
industry would be prepared to pay its share (on average around half) of the cost of the
removal scenarios in order to be free of any future liability. Whether this consideration
counts as much for the UK taxpayer, who may prefer to live with the liability while it is not
proving problematic, and put the taxation revenues to another use, is another matter.

8.1.9 Deciding on Drill Cuttings Piles

As noted earlier, it is only in respect of the drill cuttings piles that the reference scenario (C1)
may result in a significant negative effect on the marine environment. Excavation (C2) will
have an even greater negative effect on the marine environment and is not likely to be
seriously considered on these grounds alone. Both C3 (covering) and removal (C4) have been
assessed as having a positive effect on the marine environment compared with C1. The major
environmental impact associated with C3 is the very large quantity of aggregates (166,000t)
that is required. This produces a large negative impact in terms of resource extraction. It may
also be noted that this material is not included in the definition of the resource stock ratio
(RSR, see Section 5.1.5), according to which the entry under Stock of resources in the

93
summary outcome matrices is calculated. Had it been so, then C3 would have scored a - - -
in this category as well. The small benefit of C3 to fish stocks would, as with C4, be swiftly
removed by the fact that it would open up the area to the fishing industry. C3 has clear
environmental benefits over, for example, C2, because the cuttings are covered rather than
excavated (blown away). Its marine environmental benefits are comparable to that of C4
(removal); it uses less fuel and has no landfill implications, but requires far more aggregates;
it is also less than a third of the cost of C4. The implicit valuations in relation to the drill
cuttings scenarios may therefore be summarised as follows:
C1: this would place a value of less than 10m on the net C3 environmental benefits, and
less than 39m on the net C4 environmental benefits
C3: this would imply that the C3 seabed benefits (compared to C1) less the negative
impacts of the extra fuel use and aggregates extraction were worth at least 10m
C4: this would imply that the C4 seabed benefits (compared to C1) less the negative
impacts of the extra fuel use and landfill were worth at least 39m

8.2 THE DIFFERING PERCEPTIONS, PREFERENCES AND PRIORITIES OF DIFFERENT

STAKEHOLDERS

8.2.1 A spectrum of views

The difference in preferences and priorities noted in the previous paragraph is an example of
the many such differences that are undoubtedly involved in the issue of decommissioning,
which is one of the reasons why any attempt to give unique money values to the different
impacts and outcomes is likely to be unsatisfactory, and why there is unlikely to be a full
social consensus on the best decommissioning scenario.

Watson (2004) has expressed the opinion that there are at least seven different kinds of
consideration which will influence the attitude to decommissioning of different stakeholders:
technical feasibility, safety, cost, environmental impacts, the regulatory framework,
reputation and the political environment.

As noted earlier (Section 1.1), the attitude of Greenpeace (2004) to some of these issues was
that any full consideration of decommissioning also needs to take account of broader issues
such as the established international trend against dumping, the cumulative damage and
the potential precedent that could be set by dumping individual installations on a case-by-
case basis, the need for industry to take responsibility for the products it creates, the
precautionary principle and the need to protect the environment from harm. While the views
of Greenpeace may not be representative of other environmental groups, or of society at
large, it is certainly the environmental group that has exerted most influence on the UK
decommissioning debate and on decommissioning policy, which is why its views have been
singled out for consideration here. Greenpeace (2004) considers that full removal of all
materials to shore is technically feasible (and cites the contractors who would get the work to
that effect), and that risks to personnel in the activities involved can be mitigated. This
contrasts with those in the industry who consider that the limited decommissioning
experience to date has shown that significant technical difficulties remain (Watson 2001,
p.28) and, of course, dangerous activities remain potentially dangerous whatever risk
mitigation measures are taken, and accidents happen. In any case, driving risks down to very
low levels, in a context of considerable technical uncertainty in the first place, is bound to

94
increase costs, perhaps very substantially, above the already uncertain estimates that have
been quoted here.

No evidence has been found that Greenpeace is concerned about the high costs of
decommissioning, which, as noted extensively above, will be shared between the industry
and the UK taxpayer (from foregone tax revenues, as explained earlier). Rather it tends to
stress the need to reinforce the international trend against dumping and the need for the
industry to take responsibility for its products, implicitly whatever the cost.

In contrast, the industry is certainly likely to worry about costs, but this will not be the only
consideration. It might well be prepared to pay its (half) share of the costs of the removal
scenarios, in order to remove any question of future liability and protect its reputation. The
Government (and taxpayer) may have a different view as to whether this is the best use of
public money. Industry will also tend to worry more about safety (it is easy to say that risks
must be mitigated, but, as noted above, accidents happen and are also bad for reputation) and
about the technical feasibility of removing tens of thousands of tonnes of material from
relatively deep water. Contractors will tend to be optimistic about this feasibility, because
they will be paid to solve any problems that may arise. The industry is bound to worry about
the time and cost uncertainties that may be involved. There is also the possibility that, again
for reasons of reputation, the industry may not wish to challenge the current regulatory
framework, again preferring to pay its (half) share of the bill for total removal to buy political
peace. Again, it is not clear, on the basis of this assessment, that such an outcome would be
in the public interest, either environmentally or for the taxpayer.

The environmental outcomes from the various decommissioning scenarios are mixed. No
scenario can be said to be definitively superior from an environmental point of view. The
total removal scenarios can only be justified environmentally if a relatively high value
(though differing for different scenarios) is put on a clear seabed, benefits to the fishing
industry, the conservation of the stock of resources and the impacts of resource extraction
(although the last two considerations do not apply to drill cuttings), and a relatively low value
is put on fish (for all the scenarios), energy use and air emissions (for the concrete structure
and drill cuttings), impacts on the marine environment (for all the removal scenarios except
drill cuttings) and landfill (especially for the drill cuttings). It is not clear that this would be
the relative valuation accorded to these issues either by the range of environmental groups
concerned about the marine environment, or by society more widely. It is also not clear what
action might be most in line with the precautionary principle, which Greenpeace has said
needs to be taken into account. Avoiding the negative environmental impacts from the
removal scenarios may be as important in this regard as achieving a clear seabed and
recycling metals none of which can be regarded as scarce.

8.2.2 The authors assessment

In the view of the authors, a balanced and independent assessment of the considerations
above might arrive at the following tentative conclusions.

Topsides
For the topside, all parties seem agreed that removal to shore (T3) is the only scenario worthy
of serious consideration, and the assessment shows this to have fewer environmental trade-
offs than some other removal scenarios. It still involves expenditure of some 30m (15m

95
from the taxpayer) for a single large steel structure, 12m more than the shallow disposal
scenario (T2).

Jackets of large steel structures

For the jacket, the same arguments seem to apply, except that the difference in cost between
the removal (J3) and shallow disposal (J2) scenarios is significantly less.

As has been noted throughout, both the reference (T1, J1) and shallow disposal (T2, J2)
scenarios are illegal under the current DTI regulations deriving from the OSPAR 1998
Decision. This assessment shows the implementation of these regulations to be far from
cheap, for the industry or the UK taxpayer, but, although mixed environmentally, the
regulations are at least not obviously counter-productive, and they implement the desire
articulated by Greenpeace (which may well have support more widely among the UK and
European public) that industry should clean up after itself and take responsibility for its
products. It is possible that the use of a decommissioned structure as an artificial reef could
be sanctioned as a legitimate use of the structure, rather than its disposal, but there is little
doubt that any attempt to obtain such a sanction would be widely seen as a challenge to the
OSPAR 1998 Decision, for which at present there seems to be little appetite in any quarter.

Footings of large steel structures

The footings are a different matter, largely because of their difficulty of removal, causing
both environmental impacts and safety concerns, the former of which are complicated by the
footings interaction with drill cuttings. The major impact of leaving them in situ is on the
fishing industry. Their removal across the UKCS could cost nearly 1 billion (see Table 7.2),
of which about one half would be paid by UK taxpayers. It is not at all clear to the authors
that this expenditure would represent good value for money.

Large concrete structures

Unlike the large steel structure, there are strong arguments, environmental and financial, for
not removing large concrete structures to shore (CON2), and few environmental arguments
for doing so. The taxpayer expenditure alone on this scenario (143m) would not, in the view
of the authors, be justified by the benefits that would result11.

Drill cuttings piles

The situation with drill cuttings is the most complex of the components of decommissioning
studied, as has been clearly shown by the assessment and implicit valuation in Section 8.1.9.
Excavation (C2) may be rejected on environmental grounds, but both the removal (C4) and
covering (C3) scenarios also have significant environmental impacts of their own, and
require substantial expenditures from both the industry and the taxpayer. For some people,
this expenditure, in order to clear the seabed of materials that are affecting around 0.15% of
the seabed of the North Sea, and the ongoing pollution risk which seems rather small, this
expenditure will seem excessive. The UKOOA Joint Industry Project (JIP) Report, which has
already been extensively cited, stated that, as long as the rate of loss of hydrocarbons from a
cuttings pile to the water column was less than 10 t/year, and the area of seabed with

11
This was the view also taken by the Norwegian Parliament in 2002, when it approved the ConocoPhillips plan
for decommissioning Ekofisk, involving the in-situ disposal of the large Ekofisk tank, which was the subject of
the financial calculations above. The plan also entails the removal of the 14 steel topsides of the Ekofisk
complex (including that of the tank), and the leaving in situ of the buried pipelines and drill cuttings
(ConocoPhillips 2002)
96
hydrocarbon concentrations of greater than 50mg/kg over time was less than 500km2years,
allowing the natural degradation of cuttings piles would the best environmental strategy
(UKOOA 2002, Final report p.36). For the two cuttings piles examined in the project (Beryl
A and Ekofisk 2/4 A) the rate of loss of hydrocarbons to the water column was around 5
t/year (UKOOA 2002, Final report, p.26), which clearly satisfies at least the first condition
for natural degradation to be the best environmental strategy. The independent Scientific
Review Group (SRG) of the UKOOA JIP was more equivocal and advocated a case-by-case
approach for each drill cuttings pile: We support the conclusion that the most suitable
options are removal, covering, and leaving in place to allow natural degradation, and that the
balance of advantage between these will depend on the specific characteristics and the
environment of individual cuttings piles. (SRG 2002, p.4) The SRG then recommends the
re-injection of drill cuttings in cases where removal is the preferred option. However, in
Section 3.5 this was shown to be as expensive as onshore processing and to be potentially
problematic both logistically and in relation to OSPAR prohibitions against dumping at sea.

The conclusions of the Independent Review Group (IRG) of the Case Study A work in this
area were quoted at some length in Section 3.5 and will not be repeated, except to note that
they were no more definitive than those of SRG. The Case Study A work did not allow this
project to assess the options of re-injection, bioremediation or processing into an inert
construction material in detail. However, on the basis of the information and technologies
currently available, a very high value would have to be put on a clear seabed, and a low value
on the negative environmental impacts of the alternatives, for the preferred scenario not to be
leaving the cuttings in place, with a monitoring programme (see below) to keep their
condition and any pollution from them under review.

Pipelines
For pipelines the situation is similar to that for footings. Recovering them (P2) clears the
seabed, conserves resources and reduces the impacts of resource extraction, but with some
environmental impacts, and at a cost of 20m (a figure which, as noted above, is specific to
Case Study A and may not be representative). The main beneficiaries of this expenditure, as
with clearing footings, would be the fishing industry. Covering the pipelines (P4) is even
more expensive and has little environmental justification over removal. Leaving them, with
remedial action to make them safe for fishing if necessary, would be the preferred scenario,
unless a very high value was put on a clear seabed and the resources they comprise.

Monitoring material left in situ

As noted above (Section 5.2), all scenarios with material left in situ would require
monitoring, the financial and (small) environmental implications of which need to be added
to the relevant scenarios. This monitoring, and the financial implications of any remedial
action which it revealed to be necessary, would, in the first instance, be the responsibility of
the industry, in view of the ongoing liability for materials left in situ which it would retain. It
was outside the scope of this project to investigate the institutional design of any monitoring
programme (for example, who should take the decisions about the frequency of monitoring,
or what conditions would trigger a requirement for remedial work on, perhaps, the drill
cuttings piles). However, the very existence of such a monitoring programme raises the
possibility of this monitoring being combined with marine monitoring for other purposes,
which in turn broadens the scope of consideration beyond decommissioning.

97
8.3 PUTTING DECOMMISSIONING INTO A WIDER CONTEXT

Decommissioning is not the only activity in the marine context with environmental
implications. Indeed, according to OSPAR, the offshore oil and gas industry is not
responsible for any of the six human pressures on the marine environment to which it gives a
Class A (highest impact) grading (three of the six pressures come from fishing [removal of
target species, seabed disturbance, effects of discards and mortality of non-target species],
two of them are trace organic contaminants from land and shipping, and one is inputs of
nutrients from land) (OSPAR 2000, Table 6.1, p.113). In this context, any decommissioning
scenario that preserves areas from fishing (as the oil and gas structures have done) seems
likely to have additional environmental benefit (as noted above). Put another way, if a seabed
clear of drilling materials resulting from decommissioning means that trawling again takes
place over the area, the seabed will very soon become clear of most marine environmental
interest as well.

One response to marine environmental degradation, and the loss of fish stocks, has been
proposals to establish marine protected areas (MPAs, RCEP 2004, Gell & Roberts,
forthcoming). OSPAR itself is currently engaged in efforts to complete by 2010 a joint
network of well-managed marine protected areas that, together with the Natura 2000
network, is ecologically coherent. (OSPAR 2003, para.11). MPAs established to conserve or
rebuild fish stocks would need to be substantially larger than those currently being
considered for nature conservation purposes. However, were these larger MPA to include the
current sites of oil and gas installations, this would remove the risk of any drill cuttings piles
left in situ being disturbed by trawling operations, with a consequent release of pollution, and
would permit any covering of these piles, to enable ecosystem regeneration on the seabed, to
be far less robust. The present simultaneous concern with both decommissioning and MPAs
would seem to open up a significant opportunity for marine environmental protection that
embraces both issues.

One of the factors that militate against MPAs is the expense of monitoring them. Monitoring
is necessary both to ensure that their status and regulations (e.g. no fishing) are being
observed, as well as to determine scientifically whether protecting the area is having the
desired environmental results. It is here that the potential synergies with some
decommissioning scenarios exist.

It has been noted above that, in respect of footings, pipelines and drill cuttings at least, the
net environmental benefit of removing all materials to shore is uncertain, while the cost is
very large. If these materials were to be left offshore, they would need monitoring. This
monitoring would be paid for by the industry as part of the decommissioning scenario. If the
area to be monitored was included in an MPA, it could be a relatively simple task to devise a
scheme whereby the monitoring also included scientific work and surveillance of MPAs. The
potential problem of in-situ decommissioning scenarios, in relation to interfering with fishing
gear, would then also not arise, because fishing boats would be excluded from the relevant
areas. In time, it might even be that the well-attested reef effects created by the shallow
disposal of structures (see Section 5.1.9 for an account of these effects in respect of the
existing standing structures) would, in the context of a MPA, make this scenario more
publicly acceptable for jackets or topsides, provided that some of the monies saved over their
removal to shore were also channelled into monitoring or other marine environmental
protection activity related to the MPA.

98
It has been noted above that one of the issues relating to in-situ decommissioning scenarios,
which makes them unattractive to the industry, is that they involve residual financial liability
for the materials left offshore. It may be that, in addition to making a contribution to
monitoring, the industry would be prepared to contribute to a marine environmental
protection fund, to reduce or share this liability with the Government, which would provide
even more resources for marine environmental protection. There can be little doubt, on the
basis of the evidence in the assessment above, that using these resources for direct marine
environmental protection, especially if this was related to MPAs, would yield far more
environmental benefit than the removal of thousands of tonnes of non-scarce materials to
shore.

The serious consideration of such a proposal would require the various parts of OSPAR
(those relating to decommissioning and MPAs) to start bringing these issues together with a
view to finding joint solutions to decommissioning and the wider protection of the marine
environment. Then there is the added difficulty that fishing is outside the remit of OSPAR
altogether, and is handled in the North Sea area by the European Commission, through the
Common Fisheries Policy, for EU Member States, and by individual countries otherwise.
This introduces great institutional complexity into any potential discussions about a strategy
that involves conserving fish as well as the marine environment. However, it should also be
noted that such discussions are already taking place in the context of attempts to agree at the
EU level a Marine Thematic Strategy, which, among other things, is proposing the
establishment by 2010 of Eco-Region Marine Environmental Protection Plans (European
Commission 2004). It would seem highly desirable that out of these discussions emerge an
effective mechanism to look at such overlapping issues as the possible relationship between
decommissioning outcomes and MPAs .

The difficulties of establishing such a mechanism should not be underestimated. The reason
for attempting to overcome them is that utilising resources from the offshore oil and gas
industry that were made available for marine environmental protection as part of a package
that combined decommissioning with MPAs for habitat protection and the regeneration of
fish stocks could transform the prospects for marine environmental conservation. It is hoped
that this report will make a contribution to discussion of these issues.

99
9. REFERENCES

1. Andrew Acland Associates, December 1999, Scopeing Report: UKOOA

Decommissioning dialogue process FINAL DRAFT, CO/05/00.

2. AURIS Environmental August 1995, An assessment of the environmental impacts of

decommissioning options for oil and gas installations in the north sea, Report
produced for UKOOA.

3. Ayres and Ayres 2002, A Handbook of Industrial Ecology: Material flows due to
mining and urbanization, Ian Douglas and Nigel Lawson, Edward Elgar, Cheltenham
UK, 351-364.

4. BP 2003, Statistical Review of World Energy 2003 -

http://www.bp.com/subsection.do?categoryId=95&contentId=2006480

5. ConocoPhillips 1999, Ekofisk I disposal:Impact Assessment Environmental and

Societal Impacts, Phillips Petroleum Company Norway 22 October 1999 -
http://phillips.netpower.no/index.asp?iLangId=1

6. ConocoPhillips 2002 Parliament approves in-place disposal of Ekofisk Tank,

Epoke, Information on the Ekofisk I Cessation project, www.phillips.no/cessation,
No.12, October,
http://phillips.netpower.no/FileArchive/86/Epoke%20okt%20e2002.pdf

7. Cordah 2000, Determination of the Physical Characteristics of Cuttings Piles, using

Existing Survey Data and Drilling Information, R & D Programme 1.1, A Report for
the UKOOA Drill Cuttings Joint Industry Project, Phase one report, January 2000.

8. Dayton, P., Thrush, S. & Coleman, F. 2002 Ecological Effects of Fishing in Marine
Systems of the United States, Pew Oceans Commission, Arlington VA
http://www.pewoceans.org/oceanfacts/2002/10/25/fact_29889.asp

9. Det Norske Veritas 1997, ODCP Peer Review of Decommissioning of offshore

Structures Energy use consideration, Report No.97-3343 Revision Number. 01

10. DTI 1999 Oil and Gas Resources of the United Kingdom 1999, Department of Trade
and Industry 1999, Electronic Publication by Data by Design Ltd 1999 -
http://www.dbd-data.co.uk/bb1999/

11. DTI 2001, Offshore Decommissioning Unit Department for Trade and Industry,
August 2001, Guidance Notes for Industry: Decommissioning of offshore
installations and pipelines under the Petroleum Act 1998,
http://www.og.dti.gov.uk/regulation/guidance/decommission.htm

12. DTI 2002, Energy its impact on the environment and society, Annex 2A:
Decommissioning of offshore oil and gas installations, Pages 43-64. Department of

100
 Trade and Industry.
http://www.dti.gov.uk/energy/environment/energy_impact/impact_booklet.pdf

13. DTI 2003 Digest of UK Energy Statistics (DUKES), Generation. Fuel used in
generation, DUKES Table 5.4,
http://www.dti.gov.uk/energy/inform/energy_stats/electricity/dukes5_4.xls

14. E & P Forum 1996 Platform Decommissioning: An outline for in-house

presentations by oil and gas companies May.

15. Ekins, P. 2000, Economic Growth and Environmental Sustainability: The Prospects
for Green Growth, Routledge, London and New York

16. Enviros 2000 Local Authority Waste Management Costs Study, Enviros Aspinwall
Scottish Executive Central Research Unit 2000 -
http://www.scotland.gov.uk/cru/documents/lawm-05.asp

17. European Commission 2004 The European Marine Strategy: Meeting of the
Working Group on Strategic Goals and Objectives (SGO), document SGO (2)
04/4/1, May, European Commission, Brussels

18. ERT 1997, Decommissioning of offshore Structures Energy use consideration:

Final Report, Environment & Technology Ltd (ERT 97/016).

19. Gell, F. & Roberts, C. forthcoming Benefits Beyond Boundaries: the Fishery Effects
of Marine Reserves, Trends in Ecology and Evolution

20. Gerrard, S., Grant, A., Marsh, R. & London, C. 1999 Drill Cuttings Piles in the North
Sea: Management Options During Platform Decommissioning, Research Report
No.31, Centre for Environmental Risk, University of East Anglia

21. Grant, A. and A.D. Briggs, 2002, Toxicity of sediments from around a North Sea oil
platform: Are metals or hydrocarbons responsible for ecological impacts? Marine
Environmental Research, 53, 95-116

22. Greenpeace 2004 The Role of Science in Abandonment Policy,

http://archive.greenpeace.org/dumping/noticeboard/reports/sciencerole.html,
consulted 2.3.04

23. Harker . K et al, August 1997, Socio-economic impacts of varying decommissioning

options, European Centre for Economic Research and Strategy Consulting: Prognos.

24. HSE (Health and Safety Executive) 2001 Reducing risk, protecting people; HSEs
decision making process, Copyright Unit, Her Majestys Stationery Office, London

25. Infield Systems 2000 Database of North Sea Oil and Gas Structures, April 25th,
Infield Systems Ltd., http://www.infield.com

101
26. IP 2000, Guidelines for the Calculation of Estimates of Energy use and Gaseous
Emissions in the Decommissioning of offshore structures, The Institute of Petroleum,
February 2000 ISBN 0 8593 255 3.

27. IRG (Independent Review Group, Shepherd, J.G., Wilkinson, W.B., Bakke, T.,
Cowling, M., Dover, W., Rullkotter, J.) 2004 Report of the Independent Review
Group (IRG), Case Study A Decommissioning Project, April,
http://www.bp.com/liveassets/bp_internet/globalbp/STAGING/global_assets/downloa
ds/S/Scotland_N_W_H_IRG_Final_Report_26_April_2004_1.pdf

28. Kemp. G & Stephen. L, May 2001, Economic aspects of filed Decommissioning in
the UKCS, North Sea Occasional Paper No. 81: University of Aberdeen Department
of Economics.

29. London Metal Exchange 2003, London Metal Exchange website taken on 27 August,
http://www.lme.co.uk/downloads/daily_prices_2003(7).xls

30. Michaelis, P., and Jackson, T. 2000, Material and energy flow through the UK iron
and steel sector. Part 1: 1954-1994, Resources, Conservation and Recycling, Volume
29, Issues 1-2, May, Pp.131-156.
http://www.sciencedirect.com/science/article/B6VDX-4090SHN-
7/2/adacd6fb7c5ffd2f389457b405bffc60

31. NAEI (National Air Emissions Inventory) 2002 UK Emissions of Air Pollutants 1970
to 2000, http://www.airquality.co.uk/archive/reports/cat07/naei2000/index.html

32. NERC (Natural Environment Research Council) 1996 Scientific Group On

Decommissioning Offshore Structures: First Report, A Report By The Natural
Environment Research Council for the Department of Trade and Industry, April

33. ODCP May 1997, Briefing note on Best Practicable Environmental Option (BPEO),
The Offshore Decommissioning Communication Project (ODCP) (E&P forum,
UKOOA, OLF).

34. OGP January 2002, Aromatics in Produced water: Occurrence, fate & effects, and
treatment, The International Association of Oil and Gas Producers (OGP), OGP
report No: 1.20/324.

35. Osmundsen, P. & Tveters, R. 2003 Decommissioning of petroleum installations

major policy issues, Energy Policy, Vol.31, pp.1579-1588

36. OSPAR, September 1992, The Convention for the Protection of the Marine
Environment of the North-East Atlantic
http://www.ospar.org/eng/html/welcome.html

37. OSPAR 2000 Quality Status Report 2000: Region II Greater North Sea, OSPAR
Commission, London

102
38. OSPAR 2003 Bremen Statement, following the Ministerial Meeting of the OSAPR
Commission, Bremen, June 25th, http://www.ospar.org/eng/html/welcome.html

39. Parmentier, R. 1998, Brent Spar: Sound Science, Sound Economics and Sound Policy,
Greenpeace Archive,
http://archive.greenpeace.org/~odumping/oilinstall/monitorbs/remisound.html#remi

40. Phillips UK 1999, Maureen Decommissioning Programme, Section 2, Executive

Summary, http://www.phillips66.com/maureen/decommprog/pdfs/sect02.pdf

41. RCEP (Royal Commission on Environmental Pollution) 2004 Turning the Tide:
Assessing the Impact of Fisheries on the Marine Environment, 25th Report, Cm 6392,
December, The Stationery Office, London

42. Roberts, J.M., 2000, The occurrence of Lophelia pertusa and other conspicuous
epifauna around an oil and gas platform in the North Sea. Scottish Association of
Marine Sconce,

43. SRE 1993/4, Abandonment - A Reassessment, Offshore Business Number 43.

44. SRG (Scientific Review Group) 2002 Final Report of the Scientific Review Group,
UKOOA Drill Cuttings Initiative, January, available on CD as described under
UKOOA 2002, UKOOA, London

45. Tilling, G. 2002, Marketing and Re-use of large North Sea Platforms, presentation
26th - 27th February, Bergen, Norway

46. UKOOA 1999, Industry guidelines on: A framework for risk related decision support,
issue No. 1, May, UKOOA, London

47. UKOOA CO/101/01, August 2001, UKOOA working group OSPAR 2003: Issues
Summary Paper.

48. UKOOA (UK Offshore Operators Association) 2002, UKOOA Drill Cuttings
Initiative: Final Report, Joint Industry Project (JIP), Research and Development
Phases 1 and 2, 2000, CD re-released in 2002, UKOOA, London
http://www.oilandgas.org.uk/issues/drillcuttings/pdfs/finalreport.pdf, also see
UKOOA website a, http://www.ukooa.co.uk/issues/decommissioning/links.htm

49. Watson, T. 2001 The Environment and the Decommissioning of Offshore

Installations, MA Dissertation, Greenwich Maritime Institute, University of
Greenwich, London

50. Watson, T. 2003 Removable Feast: New Business Opportunities Through

Decommissioning, EEEGR Event, November, Newmarket Racecourse, Suffolk,
http://eeegr.com/eventmaster/pix/20.

51. Watson, T. 2004 Personal communication, February 25th

103
52. Wills, J. 2000 Muddied Waters: A Survey of Offshore Oilfield Drilling Wastes and
Disposal Techniques to Reduce the Ecological Impact of Sea Dumping, for
Ekologicheskaya Vahkta Sakhalina (Sakhalin Environment Watch), 25th May 2000 -
http://www.alaskaforum.org/other/muddiedwaters.pdf

104
ANNEX 1: THE REGULATORY FRAMEWORK

Note: The following information about the current regulatory framework in respect of
decommissioning has been largely taken from the UKOOA website12.

The process of decommissioning is regulated by international, regional and national

legislation.

The distinction between the removal and disposal of disused offshore oil and gas installations
is important as they come under very different types of legislative frameworks. Whilst
interlinked, the legal requirements for removal are primarily concerned with safety of
navigation and other users of the sea. The disposal of structures comes under the pollution
prevention regulatory framework.

International frameworks and conventions

Geneva Convention
The current regulations have evolved from earlier conventions such as the 1958 Geneva
Convention on the Continental Shelf, article 5 (5) of which called for the total removal of all
marine based structures. This international convention came into force long before deep-sea
structures were ever emplaced.
UNCLOS
The Geneva Convention was superseded by the UN Convention on the Law of the Seas 1982
(UNCLOS), Article 60 (3) of which permits only partial removal of offshore structures
provided IMO criteria are met.
IMO
Headquartered in London, the International Maritime Organisation (IMO) sets the standards
and guidelines for the removal of offshore installations world-wide. The 1989 IMO
Guidelines require the complete removal of all structures in waters less than 100 metres
(since January 1998 previously it was 75 metres) and substructures weighing less than
4,000 tonnes. Those in deeper waters can be partially removed leaving 55 metres of clear
water column for safety of navigation13. All new structures installed after 1 January 1998
must be designed so as to be feasible for complete removal.
The London (Dumping) Convention (London Convention)
The London Convention (LC) is based at IMO headquarters in London. The new Guidelines
for the Assessment of Wastes and Other Matter that may be Considered for Dumping were
finalised in September 2000. These Guidelines have been reviewed by a LC Working Group
and have now been adopted. The 1972 London Convention made provision for generic
guidance for any wastes that can be dumped at sea. These new guidelines provide specific
guidance for different classes of waste, including platforms and other man-made waste.

12
http://www.ukooa.co.uk/issues/decommissioning/framework.htm. The DTI Guidelines themselves are
available on http://www.og.dti.gov.uk/regulation/guidance/guidenote.doc.
13
This requirement is partially linked to defence requirements. Submarines require a depth of 55m to be able to
remain submerged. The requirement does not apply to structures that are not removed and are left protruding
above the water line.
105
Regional conventions

In addition to the international legislative framework, there are a number of regional

conventions which govern marine disposal in specific areas. The North East Atlantic is
governed by OSPAR (the area reaches from the east coast of Greenland to the west coast of
continental Europe and stretches from the Arctic down to the southern most tip of Europe at
Gibraltar). Similar conventions govern other seas such as BARCOM for the Mediterranean
and HELCOM for the Baltic Sea.
OSPAR
OSPAR is an international convention drawn up in 1992 and which came into force in March
1998. It replaced the 1972 Oslo Convention (on dumping from ships) and the 1974 Paris
Convention (on discharges from land) to protect the marine environment of the Northeast
Atlantic from pollution. The Conventions main roles are to control disposal of all waste at
sea and discharges from land. There are 16 contracting parties including the UK, and the EU
in its own right.

Until June 1995, the OSPAR Convention did permit, under certain circumstances, the
disposal at sea of parts or all of disused offshore installations. After the Brent Spar affair in
June 1995, a moratorium on all disposals at sea of offshore structures was instated (although
not formally signed-up to by the UK and Norway).

The OSPAR Convention framework works alongside international legislation governing the
removal of structures. Therefore, prior to the change to the OSPAR regulations in February
1999, the OSPAR guidelines were only called upon for structures over the IMOs required
size for total removal (ie structures in waters deeper than 100 metres and weighing more than
4,000 tonnes). This accounted for some 80% of the structures in the North Sea.

In July 1998, at the OSPAR Ministerial meeting in Portugal (Sintra), the section of the
Convention governing the disposal of offshore installations was reviewed and a new
regulatory framework Decision 98/3 now exists which no longer permits any disposal at
sea of offshore structures.

OSPAR Decision 98/3 now requires the following:

all topsides of all structures must be removed to shore;

all sub-structures or jackets weighing less than 10,000 tonnes must be totally removed
and brought to shore for reuse, recycling or disposal ;
for sub-structures weighing over 10,000 tonnes, an assessment will be made on a case
by case basis as to whether they should be totally removed or whether the footings might
be left in place; and
derogation may be considered for the heavy concrete gravity based structures listed in
Annex 1 of the Decision as well as for floating concrete installations and any concrete
anchor-base which results, or is likely to result, in interference with other legitimate users
of the sea.
exceptions can be considered for other structures when exceptional and unforeseen
circumstances resulting from structural damage or deterioration or other reasons which
would prevent the removal of a structure

106
National and Local Legislation

The legislation governing the decommissioning of offshore structures on the UK continental

shelf involves a number of different government departments and bodies. All Government
departments concerned with decommissioning and with the issuing of any permits or
consents co-operate to ensure that their procedures are compatible. The international laws
described above are enshrined in the UKs national legislative framework.

The principal legislation for decommissioning comes under the Petroleum Act 1998 which is
administered by the DTI and which provides a framework for the decommissioning of
disused offshore installations and pipelines on the UKCS.

The DTI also provides operators with guidelines on how to undertake the process of
decommissioning. These are described in the DTIs Oil & Gas Directorates draft Guidance
Notes for Industry Decommissioning of Offshore Installations and Pipelines under the
Petroleum Act 1998.

107
ANNEX 2: APPROVED DECOMMISSIONING PROGRAMMES

Source: DTI - http://www.og.dti.gov.uk/upstream/decommissioning/programmes/approved

Copied from DTI website: 26th February 2004.
Field / Operator at Operator Main Installations Approved Year of
Installation time of following Decommissioned Decommissioning Approval
Approval licence / Option
company
change

Piper Alpha Occidental Talisman Fixed Steel Platform Toppling 1988

Crawford Hamilton BHP Floating Production, Removal to shore 1991

Facility (FPF)

Catenary Anchor Removal to shore

Leg Mooring
(CALM) Buoy

Subsea Facilities Removal to shore

Argyll, Hamilton BHP Floating Production, Removal to shore 1992

Duncan and Facility (FPF
Innes
Catenary Anchor Removal to shore
Leg Mooring
(CALM) Buoy

Pipelines Removal to shore

Blair Sun Oil AGIP Pipelines 1 x Re-use 1992

1 x Decommissioned in
situ

Angus Amerada Floating Production, Re-use 1993

Hess Storage and
Offloading (FPSO)
Vessel

Forbes AW Hamilton BHP Fixed Steel Platform Removal to shore 1993

Esmond CP BHP 2 x Fixed Steel Removal to shore 1995

& CW Platform

Gordon BW BHP Fixed Steel Platform Removal to shore 1995

Emerald MSR FPSO Re-use 1996

Pipelines Decommissioned in situ

Frigg FP Elf Norge TotalFinaElf Flare Column Removal to shore 1996

Norge

Leman BK Shell Fixed Steel Platform Removal to shore 1996

Staffa Lasmo Pipelines Removal to shore 1996

Viking Conoco 4 x Fixed Steel Removal to shore 1996

Platform
AC, AD, AP
& FD

Brent Spar Shell Oil Storage and Re-use as part of quay 1998
Loading Facility extension

108
Donan BP FPSO Re-use 1998

Fulmar Shell Single Anchor Leg Removal to shore 1998

SALM Mooring Buoy

16" Pipeline Decommissioned in situ

Blenheim Talisman FPSO Re-use 2000

and Bladon
Pipelines Removal to shore

Durward and Amerada FPSO Re-use 2000

Dauntless Hess
Subsea Facilities Removal to shore

Maureen and Phillips Large Steel Gravity Removal to shore for 2000
Moira Platform re-use or recycling

Concrete Loading Removal to shore for

Column re-use or recycling

Pipelines 2 x removal to shore

1 x decommissioned in
situ

Camelot CB ExxonMobil Fixed Steel Platform Re-use or removal to 2001

shore for recycling

Revision to Approved Year of

Decommissioning Revised
Option: Approval:

Removal to shore for

dismantling and
recycling 2002

Durward and Amerada Pipelines Decommissioned in situ 2002

Dauntless Hess

Hutton Kerr-McGee Tension Leg Re-use 2002

Platform

Pipelines 1 x removal to shore

1 x decommissioned in
situ (with future
monitoring programme)

Forbes and BHP Billiton Infield Pipelines Decommission in situ - 2003

Gordon retrench any area of
Infield pipeline with less than
Pipelines 0.4m depth of cover

Frigg TP1, Total E&P Treatment Platform Concrete substructures 2003

QP & CDP1 Norge AS 1 (TP1), Quarters to remain in place,
Platform (QP) and Concrete topsides to be
Concrete Drilling removed to shore, Steel
Platform 1 (CDP1) installations to be
removed to shore,
Infield Pipelines to be
removed to shore

109