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Decommissioning: Future Risks to be Considered in Advance Caroline HAQUET - SCOR Latin American Natural Resources Conference Buenos Aires, 6 th 7 th February 2017

Decommissioning: Future Risks to be Considered in Advance · DPR Petroleum Act Egaspin (1969)

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  • Decommissioning: Future Risks to be

    Considered in Advance

    Caroline HAQUET - SCOR

    Latin American Natural Resources

    Conference

    Buenos Aires, 6th 7th February 2017

  • 2 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

  • 3 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    Decommissioning Round Table: Operators/Contractors/Regulators/Insurers Are we all on the same page? Lloyds Old Library 9:30, Thursday 15th September

    About the Round Table:

    The round table has gathered the major industry players who have shared their views, needs and experience

    of Oil&Gas Decommissioning

    Roger Esson, Chief Executive of Decom North Sea has addressed the North Sea regulatory regime

    related to decommissioning obligations

    Olivier Leblond, working in the insurance risk management team of Total did a focus on the financial

    aspect of the decommissioning

    Andr Steenhuis from Allseas has highlighted the technical challenges of offshore decommissioning

    Euan Nicholson, Head of Upstream & Offshore Construction of AON was representing the

    insurance/market

    Short lively presentations were followed by a round table discussion chaired by Caroline Haquet in an open

    Q&A session.

  • 4 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA

    What are we talking about?

    Why dismantling?

    How?

    What about Insurance?

  • 5 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: THE SURFACE FACILITIES

    Fixed Steel

    Concrete

    Self erected (jack-up type)

    Floating Semi-submersible

    (associated with subsea

    wells)

    On seabed Pipelines & flowlines

    Umbilicals

    Xmas-trees & templates

    Fixed platforms

    Subsea

    systems

    Floating Production

    Storage Offloading

    Floating systems

    FPSO SPAR TLP

    Compliant

    tower

    Steel

    platfo

    rm

    Concrete

    platform Tension Leg Platform

    Semi Submersible

  • 6 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: THE INVENTORY

    More than 7 000 fixed

    platforms including

    4 000 in the Gom

    500 in Europe

    2 500 in Middle East/Asia

    200 in Africa

    More than 100 floating

    platforms

    millions of tons to be

    dismantled

  • 7 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA

    What are we talking about?

    Why dismantling?

    How?

    What about Insurance?

  • 8 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: WHY TO DECOMMISSION?

    Geological / Reservoir Trigger: Technical feasibility Financial Trigger: Oil Barrel Price

    Decommissioning

  • 9 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: REGULATORY REGIME

    Three levels: International/local/Regional

    (National and sub-national

    are examples only)

  • 10 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: INTERNATIONAL CODE

    Geneva Convention on the continental Shelf (1958)

    requires to remove all installations

    London Dumping Convention (1972) & Protocol

    (1996)

    prohibits dumping of wastes into the sea

    except 7 categories including platforms

    UN Convention on the Law of the Sea UNCLOS (1982)

    accepts partial removal of platforms

    IMO Guidelines & Standards (1989)

    Gives rules for partial removal of facilities

    (>4 000 tons) & requires that new installations

    to be totally removable

  • 11 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: OSPAR (OSlo PARis) CONVENTION (1992 & 1998)

    Signed in 1992, in force in 1998. The 1992 Oslo Convention for the

    Prevention of marine pollution by Dumping from Ships and Aircraft.

    The 1974 Paris Convention for the Prevention of Marine Pollution from

    Land-Based Sources.

    Presumption for removal of all facilities with possible derogation for:

    Concrete structures

    Footings of jackets weighing more than 10 000 tons

  • 12 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING & DISMANTLING DISUSED PIPELINES & CABLES

    Permission to be leave in place can be granted when no significant

    fishing activity is taking place or when pipelines and cables are properly

    trenched and covered

  • 13 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: NATIONAL LAWS AND REGULATIONS

    Norway Petroleum Act (1985)

    NPD guidelines (1990)

    UK Environment Protection Act (1990)

    DTI Guidelines (1998)

    Nigeria DPR Petroleum Act Egaspin (1969)

    Australia Petroleum and Submerged Lands Act 1967 (PLSA)

    replaced by the Offshore Petroleum Act (OPA)

  • 14 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    Approximately 7,000 offshore oil & gas installations currently exist worlwide. Of these 340 are

    located in South America

    South America depicts the lack of both decommissioning policy and actual state practice

    Regional sea programs and projects do not include offshore oil and gas

    Joint development agreements for hydrocarbon resources do not include provisions on

    decommissioning

    In the past, Brazil (70 fixed platforms, 26 floating production systems and various subsea

    equipment) and Peru (80) have supported the sea disposal option within the London Convention

    Venezuela on the other hand has its structures in Lake Maracaibo which are inland waters and

    thus not subject to any international regime

    Offshore extraction mostly the responsability of national oil companies

    New obligations introduced to accelerate decommissioning activity in Argentina by national

    regulators: Resolution 5/1996 issued by the Energy Secretariat establishing the rules applicable to

    the abandonment of inactive wells for example

    DECOMMISSIONING: WHAT ABOUT South America?

  • 15 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING MUST BE THOUGHT AT THE VERY EARLY STAGE OF A PROJECT

    Engineering: Conceptual and Development studies include site restitution

    Financing: Decommissioning Security to be provided before start-up of

    production

    Accounting: Liability booked before or at First Oil

  • 16 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: TRANSFER OF LIABILITY

    Principle

    Risk Assessment

    Minimum Requirements

    Petroleum Act: Liability for Decommissioning

  • 17 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    FINANCIAL DECOMMISSIONING SECURITIES

    Acceptable securities (depending on the countries):

    Cash (escrow account)

    Bond / Letter of Credit from a bank or an insurance company

    Parent Company Guarantee

    Trust Fund

  • 18 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    FISCAL ASPECTS OF DECOMMISSIONING: THE UK EXAMPLE

    Provisions are not tax deductible

    But tax relief on decommissioning costs is available as and when the

    expenditure is incurred (subject to cap)

    There is a Carry back mechanism to offset tax losses on the tax basis

    from the previous years

    There has always been industry concern around the certainty of tax relief

    To address this concern, the UK government has adapted legislation in

    2013 by introducing a Decommissioning Relief Deed (DRD) which

    provides:

    Certainty over the rate of relief

    Ability to claim a shortfall payment if the level of relief is not achieved

    Guarantee of tax relief if the corresponding taxes were to be abolished

  • 19 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    ECONOMIC CHALLENGES IN DECOMMISSIONING

    Great uncertainty about timing and costs of decommissioning

    Availability of Rigs to plug and abandon wells vs. use of rigs for

    development matters

    Limited capabilities from contractors for dismantling &

    decommissioning, especially for cutting and lift operations

    Disposal strategy between Energy Recovery, Recycle, Reuse and

    Landfill

  • 20 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA

    What are we talking about?

    Why dismantling?

    How?

    What about Insurance?

  • 21 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: WORKERS

  • 22 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: LIFTING

  • 23 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: TOOLS & MACHINERY

  • 24 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: FROM OFFSHORE TO SHORE

  • 25 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: WHICH CONTRACTORS??

    Decommissioning Contractors: as per construction

    Few Words on Pioneer Spirit Vessel: Allseas

  • 26 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA

    What are we talking about?

    Why dismantling?

    How?

    What about Insurance?

  • 27 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    INSURANCE MARKET PERSPECTIVE KEY DECOMMISSIONING EXPOSURES

    The risks:

    Balance : Project cost overrun

    Third party liability for property damage and bodily injury

    Existing property exposure (proximity agreements, etc)

    Removal of wreck

    Damage from pollution

    Onshore disposal liabilities

    Increase cost of works following an incident

    Regulatory Risk

  • 28 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING:WHAT ABOUT INSURANCE ?

    Physical Loss or Damage: Really ???

  • 29 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    Standard Insurance Solutions: is it enough ?

    Operator Contractor

    Traditional Operating Policy

    Extended for removal of

    Wreck?

    Dropped object cover

    Protection & Indemnity:

    Pre-existing Fault

    Claims directly against

    platform Operator and not the

    vessel

    Contract Work Exclusion even

    when Specialist

    Operations cover

    Traditional Liability Policy Traditional Liability Policy

    O.I.L.:

    Dropped Object cover?

    Cover for Contractors and

    Sub-contractors

    Welcar 2001

    Need for Offshore Dismantling & Removal Policy Wording

  • 30 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: INSURANCE ISSUE

    What will be needed :

    Removal of wreck / dropped objects

    Liability

    Extra cost and expense

    Contract objects

  • 31 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    INSURANCE ISSUE: Policy wording to be clarified

    Policy period

    From the dismantling and removal contract

    Until the property is safely unloaded at the

    Contractors dock

    Additional onshore cover if required

    Market appetite: strong appetite in liability and energy market

    Marine Warranty Surveyors MWS

    Limits, Deductibles

    Adequate premium

  • 32 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    DECOMMISSIONING: TAKE AWAY

    Different scale of offshore dismantling & removal Projects : from the

    disposal of a single platform through the removal of all the structures in

    an entire field:

    Emerging risk category

    Analysis and understanding of the clientss exposure: one risk matrix for

    each dismantling scenario

    Currently there are several decommissioning wordings not a

    standard one

    Tailor made solution

    The next step belongs to us all of us

  • 33 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017

    Gracias por su atencin

  • 34 Latin American Natural Resources Conference, Buenos Aires, 6th 7th November 2017