Well Abandonment and Suspension

• Petroleum Act 1998
• Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005

These Regulations came into force on the 20th August 2005. These Regulations introduce a permitting system for oil discharges and replace the requirement for an exemption under POPA.

• Offshore Chemicals Regulations 2002
• Food and Environment Protection Act 1985 (FEPA)
• Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001
• The Offshore Petroleum Activities (Conservation of Habitats) (Amendment) Regulations 2007

If there are intentions to use explosives in abandonment operations, discussions must be held with DECC and JNCC to ensure that consideration is given to any habitats or species are required under the Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (as amended).

• Offshore Installation and Wells (Design and Construction etc) Regulations 1996

• PON5 - Application to Abandon or Temporarily Abandon a Well

The PON5 has been amended to include questions, which relate to environmental legislation.

Chemicals

There may be chemical use/discharge requirements during well abandonment. These may be covered within the drilling chemicals permit (PON15B) for the operation or by an installation-decommissioning permit (PON15D or PON15E).

If already covered within an existing chemical permit application, DECC will not require a separate PON15 application. However, in all cases, summary information must also be provided in the PON5 (see below).

Oily Discharges

Any deliberate release of oil (reservoir hydrocarbons only) planned during a well suspension or abandonment must be subject to an OPPC permit. Again application will be via the PON5 (see below)

Deposits to Seabed

In exceptional cases, a licence under Part II of FEPA may be required for deposits to the seabed (e.g. rock dumping to cover a wellhead), DECC is not intending to require FEPA licences for all suspension or well abandonment operations. Inclusion of information on the PON5 will enable DECC to make a decision whether a FEPA licence is also required.

Explosives

If there are intentions to use explosives in abandonment operations, discussions must be held with DECC and JNCC to ensure that consideration is given to any habitats or species protected under the Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001.

• PON5 Application

Part 2 of the PON5 must be completed for the proposed suspension or abandonment of a well, this should detail (amongst others):

• Potential chemical use/discharge. No further permit application (PON15) will be required unless DECC wishes to discuss the use and/or discharge of a particular chemical.
• Potential incidental oil releases. This will trigger the issue of an OPPC Permit.
• Potential temporary or permanent seabed deposits likely to be associated with routine well suspension or abandonment operations. No further action will be required unless DECC determines that there could be significant adverse effect and therefore a FEPA licence may be required.

If additional permits are required, DECC will contact the operator based on information provided in the PON5. This is expected to be unlikely except in exceptional circumstances.

As soon as the need for well suspension or abandonment is known. Permit must be in place before well abandonment.

If explosive use is planned, discussions should be held with DECC/JNCC as early as possible.

Well must be abandoned in such a way to ensure that as far as is reasonably practicable, there can be no unplanned escape of fluids from the well.

None known.

Chemicals

No reporting required under the PON5. Separate chemical reporting will be required if chemical use/discharge for the abandonment operation has been included in a separate PON15 chemical permit (see Drilling Chemicals or Decommissioning Chemicals).

Oily Discharges

Any incidental release of oil (not covered by the OPPC permit) must be reported to DECC via the PON1.

Additional

Depending on other DECC requirements (e.g. use of explosives or FEPA licences), there may be additional reporting requirements that will be detailed in the permit.

If a chemical permit is in place,DECC Permit Condition non-compliance Notification Form is to be used for reporting any identified non-compliances against Chemical Permit Conditions issued under the provisions of the Offshore Chemical Regulations 2002.

Examples of these may include, but not be limited to: identified over use of chemicals; or use and/or identified discharge of un-permitted chemicals following an internal review against permit requirements. In addition the form may be used to notify DECC of any other applicable notifications specifically as required with the chemical permit conditions as appropriate.

Non-compliance would include discharge of well fluids containing reservoir hydrocarbons without a valid permit being in place or at an oil in water concentration greater than 40 mg/l.

Any non-compliance must be reported to DECC using the OPPC non-compliance notification form, which can be downloaded from DECC website along with appropriate Guidance Notes.

Offences under the OPPC Regulations, include (but are not limited to) the following:

• discharge of oil to sea without a valid and appropriate permit being in place;
• failure to report an unpermitted discharge of oil;
• failure to comply with a prohibition or enforcement notice;
• failure to supply any information required under the terms of the permit; or
• wilfully obstructing a DECC inspector.

A person found guilty of an offence will on summary conviction be liable to a fine not exceeding the statutory maximum.

The oily fluid generated during conductor cutting cannot be reinjected offsite as the OSPAR agreement applies only to produced hydrocarbons and not to waste streams.