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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
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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.
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DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA
What are we talking about?
Why dismantling?
How?
What about Insurance?
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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
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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
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DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA
What are we talking about?
Why dismantling?
How?
What about Insurance?
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DECOMMISSIONING: WHY TO DECOMMISSION?
Geological / Reservoir Trigger: Technical feasibility Financial Trigger: Oil Barrel Price
Decommissioning
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DECOMMISSIONING: REGULATORY REGIME
Three levels: International/local/Regional
(National and sub-national
are examples only)
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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
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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
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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
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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)
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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?
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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
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DECOMMISSIONING: TRANSFER OF LIABILITY
Principle
Risk Assessment
Minimum Requirements
Petroleum Act: Liability for Decommissioning
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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
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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
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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
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DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA
What are we talking about?
Why dismantling?
How?
What about Insurance?
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DECOMMISSIONING: WORKERS
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DECOMMISSIONING: LIFTING
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DECOMMISSIONING: TOOLS & MACHINERY
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DECOMMISSIONING: FROM OFFSHORE TO SHORE
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DECOMMISSIONING: WHICH CONTRACTORS??
Decommissioning Contractors: as per construction
Few Words on Pioneer Spirit Vessel: Allseas
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DECOMMISSIONING: Future Risks to be Considered in Advance AGENDA
What are we talking about?
Why dismantling?
How?
What about Insurance?
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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
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DECOMMISSIONING:WHAT ABOUT INSURANCE ?
Physical Loss or Damage: Really ???
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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
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DECOMMISSIONING: INSURANCE ISSUE
What will be needed :
Removal of wreck / dropped objects
Liability
Extra cost and expense
Contract objects
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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
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Gracias por su atencin
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