Well Abandonment and Suspension

Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:

Guidance:

These guidelines guidelines have been developed to share current good industry practice and relate respectively to the operation of subsea blowout preventer (BOP) systems, well integrity throughout the well life cycle, well suspension and abandonment and the qualification of materials used for suspension and well abandonment.

Oil and Gas UK has published an update of their Well Life Cycle Integrity Guidance – The updated guidance reflects regulatory changes, including those resulting from the Offshore Safety Directive, introduced in July 2015.

Consent Needed: ChemicalsThere may be chemical use/discharge requirements during well abandonment. These may be applied for by a Well Intervention Permit or covered within the drilling chemicals permit (Drilling Operations permit) for the operation or by an installation-decommissioning permit (Production Operation permit or Decommissioning Operation permit).Oily DischargesAny deliberate release of oil (reservoir hydrocarbons only) planned during a well suspension or abandonment must be subject to an Oil Discharge permit. Application will be via an oil discharge permit (see below)Deposits to SeabedA licence under the Marine and Coastal Access Act or Marine (Scotland) Act will be required.

Explosives

A licence under the Marine and Coastal Access Act or Marine (Scotland) Act will be required.

If there are intentions to use explosives in abandonment operations, discussions must be held with BEIS and JNCC to ensure that consideration is given to any habitats or species protected under the Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001. See JNCC Guidance on Use of Explosives (PDF document). Information contained in the Habitats Regulatory Assessment and European Protected Species licencing pages may also be of use.

Consent to Locate

See Navigational Interference.

How to Apply: Well Intervention PermitA Well Intervention Permit 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 (PETS applications) will be required unless BEIS wishes to discuss the use and/or discharge of a particular chemical.
  • Potential incidental oil releases. This will trigger the issue of an Oil Discharge 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 BEIS determines that there could be significant adverse effect and therefore a FEPA licence may be required, or a Marine Licence for deposits on the seabed

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

MCAA Licence

MCAA licences area applied for as a standalone application in the new PETS system via the UK Oil Portal. Draft guidance can be found here (PDF document).

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

Who to Apply To: Well Intervention PermitsTo be submitted electronically to BEIS via the UK Oil Portal. Operators will need to be registered with BEIS for access to the Portal. To set up a UK Oil Portal Account, contact the BEIS OED Environmental Management Team at ukop@decc.gsi.gov.ukMCAA LicenceMCAA licences are applied for as a standalone application in the new PETS system via the UK Oil Portal. Draft guidance can be found here (PDF document).
When to Apply: Well Intervention PermitAs soon as the need for well suspension or abandonment is known. Permit must be in place before well abandonment.MCAA LicenceMCAA licences area applied for as a standalone application in the new PETS system via the UK Oil Portal. Draft guidance can be found here (PDF document).If explosive use is planned, discussions should be held with BEIS/JNCC as early as possible.

 

 

General:

The 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.

Use of Explosives: JNCC Guidance on Use of Explosives (PDF document) includes a series of mitigation measures to be considered and agreed:

  • Visual Monitoring by Marine Mammal Observers
  • Passive Acoustic Monitoring (PAM)
  • Use of PAM as mitigation
  • Pre-detonation search for marine mammals
  • Delay of 30 minutes if a marine mammal is detected within the Mitigation Zone
  • Sequencing of the explosive charges
  • Acoustic Deterrent Devices (ADDs)
  • Post-detonation search
  • Communication

 

Monitoring Post Abandonment: None known.
What to Report: ChemicalsNo reporting required under well intervention permits. Separate chemical reporting will be required if chemical use/discharge for the abandonment operation has been included in a separate PETS chemical permit (see Drilling Chemicals or Decommissioning Chemicals).Oily DischargesAny incidental release of oil (not covered by the Oil Discharge permit) must be reported to BEIS via the PON1 (Word document).ExplosivesReports detailing the marine mammal mitigation activities (MMO report) should be sent to the JNCC, or appropriate nature conservation agency, after the explosives operation has been completed. Ideally the MMO report should be sent to the JNCC by e-mail to seismic@jncc.gov.uk.

Additional

Depending on other BEIS requirements, there may be additional reporting requirements that will be detailed in the permit.

Chemical Permit: If a chemical permit is in place, BEIS (then DECC) Permit Condition non-compliance Notification Form (Word document) 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 are not limited to:

  • Identified over use of chemicals
  • 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 BEIS of any other applicable notifications specifically as required with the chemical permit conditions as appropriate.

Oil or Chemical Spill: Any spill of oil or chemicals must be reported to BEIS via a PON1.
OPPC Permit: 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 BEIS using the OPPC non-compliance notification form (Word document), which can be downloaded from BEIS website along with appropriate Guidance Notes (Word document). 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.
  • Wilfully obstructing a BEIS inspector.

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

Offshore Inspection: The BEIS (then DECC) Offshore Oil and Gas Environment Unit Enforcement Policy sets out the general principles that Inspectors shall follow in relation to enforcement including prosecution.
MCAA Licence Renewal and Variation: Licences will be valid for a maximum period of one year, but operators will be able to apply to renew licences that cover a range of activities.
None at present.
Offsite Reinjection of Fluid From Conductor Cutting: 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.
Radioactive Sources: SEPA has requested full details of all sources to be left behind following well abandonment and platform decommissioning. If record keeping is poor this will involve considerable time and effort.