Case study highlights decommissioning pitfalls

The Regulator 2022 - Issue 2

A recent investigation into a titleholder’s non-compliance with a direction has further highlighted the importance of titleholders undertaking proactive planning for decommissioning.

NOPSEMA issued a direction requiring the titleholder to plug and abandon the wells by the end of 2021.

The titleholder was already in the process of tendering for contractors to complete the decommissioning work. It subsequently became apparent that the chosen contractor would be unable to initiate decommissioning work in time to complete it within the deadline.

To their credit, the titleholder selected an alternative contractor who was ultimately able to safely complete the job. However, the alternative was not without challenges. Delays resulted in the titleholder’s failure to meet their deadline for decommissioning and led NOPSEMA to commence an investigation.

This case highlights the need for titleholders to recognise the variables and uncertainties associated with decommissioning, particularly decommissioning wells, structure and property that has not been in use for a considerable period and has not been subject to recent monitoring or adequate maintenance effort.

NOPSEMA’s Decommissioning Manager David Christensen said the case highlights the need for titleholders to recognise that decommissioning of wells and structures presents a range of unique technical challenges. “Removal of structures is not simply a reversal to installation – given degradation of material, there is the need for specialist equipment and expertise, and supporting studies and contingencies to effectively manage safety and environmental risks,” David said. “Additional time is often needed to safely and environmentally responsibly complete decommissioning activities.” Ultimately, proactive planning for decommissioning can reduce and limit many of these risks and variables.

Titleholders need to ensure that the decommissioning dates and timeframes included in their Environment Plans are achievable and begin planning for them as soon as practical.

For more information on how to begin proactive planning you can find the “Information Paper – Planning for Proactive Decommissioning” on the NOPSEMA website.