Offshore​ ​Decommissioning​ ​and​ ​Beyond:

Reuse​ ​Case

Deki​ ​Djokic​ ​and​ ​

​ ​Team

“​When  things  do  not  go  your  way,  remember  that  every  challenge  —  every  adversity  —​ ​contains​ ​within​ ​it​ ​the​ ​seeds​ ​of​ ​opportunity​ ​and​ ​growth​” ​ ​-​ ​Roy​ ​T.​ ​Bennett

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©​ ​2017​ ​Concept​ ​Design​ ​Marine​ ​Pte.​ ​Ltd.,​ ​all​ ​rights​ ​reserved. Feel​ ​free​ ​to​ ​use,​ ​share​ ​and​ ​distribute​ ​this​ ​work​ ​in​ ​it’s​ ​original​ ​form. Quoted​ ​material​ ​and​ ​images​ ​are​ ​copyrighted​ ​material​ ​of​ ​their​ ​right​ ​holders.

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About​ ​CDM History Market​ ​Value More​ ​history​ ​-​ ​Shell​ ​Brent​ ​Controversy Decommissioning​ ​Operation Schedule​ ​and​ ​Budget Legislation,​ ​Regulations​ ​and​ ​Consultations Oil​ ​Companies​ ​Present​ ​position Afterlife​ ​of​ ​the​ ​Platform Infrastructure Inventory Instead​ ​of​ ​Removal

Environmentally​ ​friendly Sustainable Marketable "Easy"​ ​to​ ​implement

Adding​ ​value​ ​to​ ​the​ ​local​ ​community True​ ​end​ ​of​ ​life

Lower​ ​risk​ ​level​ ​of​ ​the​ ​new​ ​asset CDM​ ​Reuse​ ​Proposals SeaFarm

Ocean​ ​Cleaning​ ​Facility Offshore​ ​Supply​ ​Hub Desalination​ ​plant Sanity​ ​check

Decision​ ​Tool​ ​(Matrix) Oil​ ​Company​ ​Role References Further​ ​Reading Images Companies​ ​Mentioned 3

Assets​ ​Mentioned

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About​ ​CDM Concept Design Marine is a company, established by seasoned Engineers and Naval Architects from Oil & Gas Industry. We’re looking for the opportunity to make a mark in the usage of new technology in Marine and Offshore O&G or to use well-known solutions in a number​ ​of​ ​different​ ​ways. Some​ ​of​ ​our​ ​solutions,​ ​patented​ ​in​ ​2015​ ​&​ ​2016: ● ● ● ● ●

elCAT-0,​ ​hybrid​ ​workboat,​ ​powered​ ​by​ ​wind,​ ​solar​ ​and​ ​thermal​ ​energy​ ​sources SeaFarm,​ ​way​ ​to​ ​use​ ​Ocean​ ​surface​ ​to​ ​grow​ ​aquatic​ ​and​ ​non-aquatic​ ​culture Jumbo​ ​Jack,​ ​heavy​ ​lifting​ ​vessel,​ ​capable​ ​to​ ​lift​ ​over​ ​50,000​ ​t​ ​in​ ​one​ ​lift FluidLink,​ ​inexpensive​ ​and​ ​environmentally​ ​friendly​ ​solution​ ​for​ ​Oil​ ​&​ ​Gas​ ​terminals PowerMakers, using the elCat-0 hybrid platform to produce electrical energy “from kWs​ ​to​ ​MWs”.

For more information, check our web-page ​www.cdm-consultants.com or contact us on [email protected]​.

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History The first submerged oil well was drilled in the Grand Lake St. Marys in Ohio (fresh water!) around 1891. Well was drilled from a platform built on piles. Real offshore oil exploration is dated to 1945 when US President Harry Truman issued the Executive Order, extending American territory to the edge of the continental shelf and, effectively, ending “3-mile limit” regime. Very first oil well, drilled “out of land sight”, is Ship Shoal Block 32 well, drilled by Kerr-McGee Oil Industries (now: Anadarko) as the operator for partners Phillips Petroleum (now:​ ​ConocoPhillips)​ ​and​ ​Stanolind​ ​Oil​ ​&​ ​Gas​ ​(BP)​[1]​.

Fig.​ ​1 Maunsell Forts, pictured above, built by British during World War II, are considered as the direct predecessor of modern offshore platforms. Platforms were floated to the location and placed on the bottom of the Thames and Mersey estuary​[2]​. Their use, obviously (considering the​ ​time​ ​they​ ​have​ ​been​ ​built),​ ​was​ ​defense,​ ​not​ ​Oil&Gas. Since that time, Oil companies are building better, more safe, more automated, more efficient,​ ​more​ ​expensive​ ​and...bigger​ ​and​ ​heavier. Some​ ​of​ ​the​ ​biggest​ ​oil​ ​platforms​[30]​​ ​are: 6

● ● ● ● ●

Berkut,​ ​located​ ​of​ ​Russian​ ​Pacific​ ​Coast,​ ​designed​ ​to​ ​withstand​ ​subpolar​ ​conditions Perdido,​ ​operated​ ​by​ ​Shell​ ​in​ ​Gulf​ ​of​ ​Mexico​ ​and​ ​installed​ ​in​ ​2,450​ ​m​ ​of​ ​water Petronius,​ ​installed​ ​in​ ​Gulf​ ​of​ ​Mexico Hibernia​ ​installed​ ​off​ ​the​ ​coast​ ​of​ ​ ​Canadian​ ​North​ ​Atlantic Mars-B​ ​(Olympus),​ ​operated​ ​by​ ​Shell​ ​is​ ​the​ ​largest​ ​deep-water​ ​floating​ ​platform.

Some​ ​of​ ​the​ ​deepest​ ​stable​ ​(non-floating)​ ​oil​ ​platforms​ ​and​ ​compliant​ ​towers​ ​are​[1]​: ● ● ● ● ● ● ● ● ●

Petronius​ ​Platform,​ ​535​ ​m​ ​(1,755​ ​ft) Baldpate​ ​Platform,​ ​502​ ​m​ ​(1,647​ ​ft) Troll​ ​A​ ​Platform,​ ​472​ ​m​ ​(1,549​ ​ft) Bullwinkle​ ​Platform,​ ​413​ ​m​ ​(1,355​ ​ft) Pompano​ ​Platform,​ ​393​ ​m​ ​(1,289​ ​ft) Benguela-Belize​ ​Lobito-Tomboco​ ​Platform,​ ​390​ ​m​ ​(1,280​ ​ft) Gulfaks​ ​C​ ​Platform,​ ​380​ ​m​ ​(1,250​ ​ft) Tombua​ ​Landana​ ​Platform,​ ​366​ ​m​ ​(1,201​ ​ft) Harmony​ ​Platform,​ ​366​ ​m​ ​(1,201​ ​ft)

Exploitation of Oil & Gas on the some of the fields those platforms are serving became uneconomical. It is time for closing offshore facilities and return Ocean Surface, as per the most​ ​of​ ​the​ ​lease​ ​contracts,​ ​to​ ​its​ ​original​ ​state.

​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​Fig.​ ​2

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Market​ ​Value Expected spending on decommissioning projects will increase from US$ 2.4 billion in 2015 to US$ 13 billion-per-year by 2040; additional 2000 projects to be decommissioned between 2021 and 2040. Total expenditure in a period from 2010 to 2040 will reach amount of US$ 210​ ​billion.​ ​During​ ​next​ ​5​ ​years,​ ​about​ ​600​ ​projects​ ​are​ ​expected​ ​to​ ​be​ ​disposed​[3]​. Different reports and articles are offering different figures, but the market is huge. Just for comparison, as per Guardian, the estimated amount paid by Oil & Gas companies as a tax since production begins in UK Sector of the North Sea is 300 billion pounds. The money spent on decommissioning attracts tax relief, as rebates, up to 70% of the costs​[4]​. A significant​ ​impact,​ ​not​ ​only​ ​for​ ​oil​ ​companies​ ​but​ ​for​ ​the​ ​taxpayers​ ​as​ ​well. Some figures are available for Norwegian and UK sectors of the North Sea in period 2016-2025​[24]​:

South​ ​East​ ​Asia​ ​and​ ​Australia​​ ​[25]​:

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Age​ ​profile​ ​of​ ​platforms​ ​in​ ​SEA​ ​and​ ​Australia​​ ​[25]​:

Same​ ​source​ ​is​ ​mentioning​ ​weight​ ​of​ ​the​ ​rigs​ ​in​ ​the​ ​region: "The heaviest offshore installation in the region is the Malampaya platform in the Philippines that weighs 102,500 tonnes. The Malampaya platform consists of a deck supported by a concrete​ ​gravity​ ​substructure​ ​(CGS)​ ​and​ ​is​ ​in​ ​43​ ​m​ ​of​ ​water. Australia also has two large gravity-base structures: the Tuna West GBS weighing 102,000 tonnes and the Wandoo B weighing 88,000 tonnes. The Tuna West GBS is in 61 m of water and​ ​has​ ​a​ ​topsides​ ​weighing​ ​7,000​ ​tonnes. In the region, 53.8% of the offshore installations weigh[t] 2,000 tonnes or less and are in shallower​ ​waters."

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Some analysts estimate that 30-45% of the total amount used for decommissioning will be spent on Plug & Abandonment of the wells. Remaining 55-70% should be used for putting assets​ ​and​ ​equipment​ ​"out​ ​of​ ​commission"​ ​and​ ​removal. Some indications of the costs associated with removal can be found in decommissioning of 27 platforms, located in California coastal waters - saving by not performing complete removal (jackets toppled on site - "rigs to reef”) were estimated to $500 million. Not surprising, keeping in mind that jackets was 1200 ft in height ("deep")​[5]​. As mentioned, newer​ ​platforms​ ​are​ ​bigger.​ ​More​ ​precise​ ​data​ ​will​ ​be​ ​given​ ​later.

Fig.3 Below diagram is showing worldwide decommissioning spending until 2040 per project type [33]​ :

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“While North America is the largest market for decommissioning, the European region has the highest level of offshore decommissioning spending, based on size and volume of the structures being commissioned in the North Sea, including concrete gravity-based structures (GBSs),’ says Grigorij Serscikov, Senior Manager for Upstream Oil Gas at IHS Markit for Petroleum​ ​Review,​ ​February​ ​2017​[33]​.

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More​ ​history​ ​-​ ​Shell​ ​Brent​ ​Controversy One of the most productive oil fields in the North Sea is Brent Oilfield, operated by Shell UK. The field is located in the East Shetland Basin, 186 km (116 miles) from Lerwick, at the water depth of 140m (460 ft). Production on the field started in the November 1976, with a massive overhaul, worth 1.3 billion pounds in mid 1990. The field production facilities were consisting of four platforms - three off being concrete legged and fourth sitting on the steel jacket. The fifth facility, Brent Spar, or Brent-E, was added in the early phase of the field development to serve as storage and export buoy. Once the Brent field being connected with Sullom Voe oil terminal by pipeline, Brent Spar continued to serve the field, but at 1991 had been​ ​considered​ ​redundant​[6]​. Brent Spar was massive structure - 147 m (480 ft) in height, 29 m (95 ft) in diameter, with a displacement of 66,000 tonnes, constructed from 20 mm (0.7 in) thick steel plate. Oil tanks were​ ​designed​ ​to​ ​hold​ ​300,000​ ​barrels​ ​of​ ​crude.

Fig.​ ​4 Brent-E moved to the public spotlight in 1995, once British government announced their support for Shell's plan to dispose structure in deep Atlantic waters at North Feni Ridge (approximately 160 mi (250 km) from the west coast of Scotland, at a depth of around 2.5 km​ ​(1.6​ ​miles). Greenpeace, working since 1980-ies, against dumping of the waste in the Ocean (biggest issues at the time: radioactive waste and titanium dioxide based waste) and, at the time lobbying​ ​for​ ​OSPAR​ ​convention​ ​opposed​ ​this​ ​plan,​ ​with​ ​following​ ​issues​​ ​[6]​: 1. That there was a lack of understanding of the deep sea environment, and therefore no​ ​way​ ​to​ ​predict​ ​the​ ​effects​ ​of​ ​the​ ​proposed​ ​dumping​ ​on​ ​deep​ ​sea​ ​ecosystems. 12

2. The documents which supported Shell's license application were "highly conjectural in nature", containing unsubstantiated assumptions, minimal data, and extrapolations from​ ​unnamed​ ​studies. 3. That dumping the Brent Spar at sea would create a precedent for dumping other contaminated structures in the sea and would undermine current international agreements.​ ​The​ ​environmental​ ​effects​ ​of​ ​further​ ​dumping​ ​would​ ​be​ ​cumulative. 4. The dismantling of the Brent Spar was technically feasible and offshore engineering firms believed they could do it safely and effectively. The necessary facilities were already routinely in use and decommissioning of many other oil installations had already​ ​been​ ​carried​ ​out​ ​elsewhere​ ​in​ ​the​ ​world. 5. To protect the environment, the principle of minimizing the generation of wastes should​ ​be​ ​upheld​ ​and​ ​harmful​ ​materials​ ​always​ ​recycled,​ ​treated​ ​or​ ​contained. Being global organization, Greenpeace mounted a massive campaign, resulting in a boycott of Shell's gas station by the public, and letter from German government against offshore disposal. In the wake of the campaign, sales of Shell's products and shares dropped. Although supported by Oil Companies, main industry players in the construction sector were opposing​ ​the​ ​original​ ​plan,​ ​hoping​ ​to​ ​bank​ ​from​ ​the​ ​potential​ ​project. As a result of the campaign, Shell abandoned original plan and temporary moored Brent Spar in Norwegian waters. In January 1998, Shell announced a plan to reuse Brent E for the construction​ ​of​ ​the​ ​new​ ​harbour​ ​near​ ​Stavanger,​ ​Norway. In the wake of the "media war" between Shell and Greenpeace, the reputation of the both sides was affected. At the end of the day, Greenpeace admitted that their team "grossly overestimated" amount of the oil residues in tanks of the Spar. Shell, on the other hand, was forced to change original plan but remained firm that original proposal is the best from HSE perspective. During the dismantling of the Brent Spar large quantities of endangered cold water corals had been found growing on the subsea portion of the hull. Experts suggested to leave such structures​ ​in​ ​place​ ​in​ ​the​ ​future,​ ​but​ ​Greenpeace​ ​opposed​ ​that​ ​idea​​ ​[10]​.

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Decommissioning​ ​Operation Decommissioning​ ​operation​ ​can​ ​be​ ​divided​ ​into​ ​following​ ​phases: 1. 2. 3. 4. 5. 6. 7. 8. 9.

Permits,​ ​planning,​ ​and​ ​consultations; Hydrocarbon​ ​purging​ ​and​ ​removal; Plug​ ​and​ ​Abandon​ ​(P&A); Topside​ ​removal; Substructure​ ​removal; Removal​ ​of​ ​subsea​ ​facilities; Site​ ​clean-up; Close​ ​out​ ​report; Periodical​ ​surveys.

1. Permits, planning, and consultations​, where operators must submit their plan to the regulatory bodies, other stakeholders, and the public, together with updated surveys. In the case of the Brent Delta, as mentioned earlier, this process took 10 years and 180 [8] different groups​ ​had​ ​been​ ​consulted. 2. Hydrocarbon purging - all equipment and systems containing hydrocarbons and other hazardous fluids should be cleaned and flushed. It applies to asset (platform) and subsea facilities​ ​(subsea​ ​piping​ ​etc). 3. Plug and Abandon - all wells should be clean out and plugs installed into each well. Plugs​ ​should​ ​be​ ​pressure​ ​tested​ ​and​ ​results​ ​documented​ ​before​ ​moving​ ​to​ ​the​ ​next​ ​phase. Responsibility for P&A is not end-up with the end of the activities, not even with the sale of the asset. If well leaks, field operator will be requested to repair the well and remediate the site​[9]​. The study, published recently, showing that about one-third of the well's abandoned in the North Sea releasing between 3 and 17 thousand tonnes of methane each year[14]. Methane is more potent greenhouse gas than Carbon Dioxide. It is not clear from the report if​ ​wells​ ​are​ ​only​ ​"abandoned"​ ​or​ ​plugged​ ​and​ ​abandoned. 4. Topside removal - topside should be removed by cutting in the pieces or removed as one piece and disposed in safely and environmentally friendly manner on the shore. Method of the​ ​removal​ ​depends​ ​on​ ​topside​ ​size​ ​and​ ​availability​ ​of​ ​heavy-lifting​ ​vessels. In the case of Brent Delta, 24,000-tonne topside, Shell opted for "one piece" removal by using mighty Pioneering Spirit. To strengthen topside structure 500 workers were employed on​ ​installation​ ​of​ ​the​ ​new​ ​steel​[8]​.

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5. Substructure removal - substructure should be removed by cutting, usually, 5-6 meters below mud line and removed. Cutting is performed either by severing with explosive or by abrasive​ ​cutting.​ ​Some​ ​tests​ ​took​ ​place​ ​recently​ ​trying​ ​to​ ​perform​ ​cutting​ ​by​ ​the​ ​laser​ ​beam. Brent Spar was, eventually, dismantled by cutting rings of it tubular structure and removing piece by piece. In a case of Brent Delta platform, Shell is hoping to remove the only topside and leave the concrete base, with the weight of over 270,000 tonnes, almost 170 m (540 ft) in​ ​height​ ​in​ ​place​[11]​. Canadian Natural Resources (CNR) has submitted a draft of a decommissioning plan for its Ninian North Platform (NNP) in the North Sea to the UK’s Oil and Gas Authority (OGA). CNR's proposal is to remove topside immediately, with partial removal of the substructure (steel jackets). The risers and umbilicals attached to the jacket structure will be separated at the derogation height and that the jacket legs will remain in place at a height between 52.5 and 63.5 meters from the seabed. The time frame for topside and partial jacket removal is 2019-2020,​ ​with​ ​final​ ​removal​ ​of​ ​remaining​ ​jackets​ ​by​ ​2032​​ ​[13]​. Smaller topsides and substructures can be removed in "one go" like Scaldis have done with Horne​ ​&​ ​Wren​ ​platform​[12]​. Supporting structure - be it a jacket, spar, gravity type,... - is partly on the boundary between ocean and air, in a wave “splash zone” and partly (deep) under the sea surface. Due to its location, it is very difficult to do proper maintenance; due to its function can be more wide at the base than at the top and more “tall” than wide. In other words, not easy to manage. Industry developed tech to turn the piece in the air or in the water. In spite of the size and lifting capacity of the vessel, a piece of the size of Brent Spar (floater!) is very difficult to handle in this way. We do not have data for Ninian North Jacket - it is located in approx. 136 m​ ​of​ ​water​ ​depth,​ ​which​ ​can​ ​lead​ ​to​ ​over​ ​150​ ​m​ ​in​ ​total​ ​height. Support legs of the Brent Delta each 65 ft in diameter, made of 4 ft thick concrete is almost impossible to manage [11] ​ - and those were not designed for removal. Truth is, actually, opposite - substructure is designed to keep topside in place, on a fix location, for an extended period of time - over 20 years and to do it against all possible and impossible "environmental loads", even against one of the more basic chemical process in nature - rust. Think about Hurricane Rita and, recently, Harvey - how many substructures collapsed? Do not​ ​count​ ​damage​ ​to​ ​the​ ​topsides​ ​and​ ​process​ ​equipment. 6. Removal of subsea facilities - subsea pipes, subsea cables, templates and alike should be removed from the seabed. Templates and bigger pieces of the equipment are removed by "reverse installation"; subsea pipes and cables can be removed either by reeling, cutting and removed "piece by piece", or trenched into the seabed. Piles are a bit more complicated as​ ​air​ ​hammers​ ​to​ ​make​ ​them​ ​"loose"​ ​may​ ​be​ ​required. 7. Site cleanup - site survey is performed to identify any debris that remains after decommissioning​ ​operations.​ ​All​ ​debris​ ​should​ ​be​ ​removed. 15

8. Close out report - final statement that decommissioning had been done in line with approvals and permit. Part of the report are Seabed Clearance report, Independent Verification​ ​Certificate,​ ​and​ ​Waste​ ​Transfer​ ​Note. 9. Periodical surveys - periodical surveys of the site may be required to confirm that there are​ ​no​ ​leaks​ ​from​ ​the​ ​wells​ ​or​ ​remaining​ ​portion​ ​of​ ​subsea​ ​piping. Removal​ ​as​ ​"reverse​ ​installation":​ ​myth​ ​or​ ​reality Removal as reverse installation is a phrase often mentioned in the past. Although for some operators is working fine, like in the case of the Horne & Wren platform, for many is not working - depending on the size and location of the topside and substructure. In general, in the​ ​North​ ​Sea,​ ​is​ ​not​ ​working,​ ​due​ ​to​ ​size​ ​of​ ​the​ ​assets. We do not consider it as a serious technical solution for the majority of the platforms, but as a "wit phrase", designed to cut further discussion short, during initial design of the platform. It worked as such 20 years ago, though, when decommissioning was just distant future. To give a credit where it is due - in the meantime (last 20+ years) lot had been changed in legislation, requirements, our understanding of decommissioning process, and our relation to the​ ​environment.

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Schedule​ ​and​ ​Budget According to the study, conducted for the North Sea in 2013 by Turner & Townsend [23]​ ​ , the time between cessation of the production and final removal is somewhere between 10 and 15 years. Decommissioning operation on the site usually takes around 150 months from the "hydrocarbon​ ​free"​ ​to​ ​the​ ​end​ ​of​ ​removal. In a case of Brent Field Shell spent about 10 years just in the planning phase and expected to​ ​spend​ ​another​ ​10​ ​years​ ​in​ ​actual​ ​decommissioning​ ​operation​​ ​[8]​. The oil company can not expect any profit out of decommissioning activities. Even oil companies are companies, established and "trained" to earn some profit for their shareholders. At the best, oil company can expect some "tax return", in a form of rebates money they have already paid. In a case of the Brent Delta alone, Shell estimates that total cost of dismantling operation is in a range of "single digit billion pounds". During the lifetime of the field, Shell paid about 24 billion pounds as a tax. "Oil companies get between 40% and 75% tax relief on their clean-up costs, and analysts Wood Mackenzie estimated that will land the UK government with a £ 24bn bill, or 45% of the total future decommissioning cost for​ ​the​ ​North​ ​Sea."​​ ​[8] Turner & Townsend found that key driver of the cost is the weight of the facility - function, water depth and distance from the shore are influencing costs to much lower degree. Turner & Townsend haven't found any correlation between costs of decommissioning and time of inactivity of the asset. However, inactivity of the platform can load operator's books with other​ ​costs. Some other, interesting facts emerged from the same report - keep in mind that it is published​ ​in​ ​2013,​ ​with​ ​prices​ ​applicable​ ​at​ ​the​ ​time: 1. Project Management and Detail engineering costs are approximately 22% of the total decommissioning costs. Project management costs mounts for 8% of total cost (prices​ ​in​ ​2013!); 2. Disconnection and removal costs are around two-thirds of the total decommissioning costs. Some insight of costing break-down is given in Oil & Gas UK’s Decommissioning Insight Report​[24]​,​ ​for​ ​UK​ ​Sector​ ​of​ ​the​ ​North​ ​Sea:

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Same source is giving forecast of the spending of the Decommissioning Expenditure on the UK​ ​Continental​ ​Shelf​ ​by​ ​Work​ ​Breakdown​ ​Structure​ ​Category,​ ​until​ ​2025:

As seen from above, largest “spender” within UK Continental Shelf is P&A operation, which accounts for 56% of total cost, in average. On project basis, P&A takes between 33% and 75% of the total budget. Removal takes “modest” 30% of total decommissioning cost (estimated​ ​value). 18

The Norwegian Petroleum Directorate estimates that annual expenditure will average at around £1 billion each year until 2020​[24]​. We were not able to find detailed costs breakdown for​ ​Norwegian​ ​Continental​ ​Shelf​ ​at​ ​the​ ​time​ ​of​ ​this​ ​writing.

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Legislation,​ ​Regulations​ ​and​ ​Consultations All phases of decommissioning should be done in accordance with requirements of "regulatory" bodies (laws and conventions) and aligned with an expectation of different "interest"​ ​groups​ ​(stakeholders).​ ​Note​ ​that​ ​there​ ​are​ ​three​ ​main​ ​categories​ ​of​ ​regulations: 1. 2. 3. 4.

International​ ​regulations Regional​ ​regulations National​ ​regulations Local​ ​Regulations

In the Gulf of Mexico, regulations are the key factor for starting Decommissioning projects. The North Sea, hosting some of the biggest platforms in the World, is well regulated (OSPAR). Some other regions are not "blessed" with clear regulations or those are in process​ ​of​ ​developing​ ​and​ ​implementing. Let us try to make a ​list of regulations, conventions, and guides which operator in the UK sector​ ​of​ ​the​ ​North​ ​Sea​ ​should​ ​follow​ ​during​ ​decommissioning: 1. Petroleum​ ​Act​ ​1998 2. Energy​ ​Act​ 2 ​ 008 3. Department of Energy and Climate Change, Guidance Notes - Decommissioning of Offshore Oil and Gas Installations and Pipelines under the Petroleum Act 1998, URN 09D/734,​ ​Version​ ​4,​ ​August​ ​2009 4. 1998 Ministerial Meeting of the OSPAR Commission, Sintra, Portugal on 22 – 23 July 1998,​ ​OSPAR​ ​Decision​ ​98/3,​ ​Date​ ​of​ ​Adoption​ ​1998,​ ​Sintra 5. OSPAR Recommendation 2006/5 on a Management Regime for Offshore Cuttings Piles. 6. Oil & Gas UK, Guidelines for the Suspension and Abandonment of Wells, Code WEL03,​ ​2009. 7. 1992 OSPAR Convention, Convention for the Protection of the Marine Environment of​ ​the​ ​North-East​ ​Atlantic,​ ​22nd​ ​September​ ​1992. 8. Offshore​ ​Installations​ ​(Safety​ ​Case)​ ​Regulations​ ​2005,​ ​SI​ ​2005​ ​No​ ​3117 9. Oil​ ​&​ ​Gas​ ​UK,​ ​Fisheries​ ​Sensitivity​ ​Maps​ ​in​ ​British​ ​Waters,​ ​1998 10. OSPAR Commission (2000). Quality Status Report 2000, Region II – Greater North Sea,​ ​OSPAR​ ​Commission,​ ​London 11. Department of Trade and Industry, Guidance Notes on the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999, Version​ ​15,​ ​14​ ​November​ ​2003 12. Department of Energy and Climate Change, Strategic Environmental Assessment of the “Mature Areas of the Offshore North Sea”, SEA 2, Consultation Document September​ ​2001

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13. Offshore Installation and Wells Design and Construction Regulations, SI 1996 No 913 14. UNCLOS.​ ​The​ ​United​ ​Nations​ ​Convention​ ​on​ ​the​ ​Law​ ​of​ ​the​ ​Seas,​ ​1982,​ ​Article​ ​60 15. 1972 London (Dumping) Convention (and the subsequent 1996 protocol, with new guidelines​ ​adopted​ ​in​ ​2000) 16. IMO resolution A.672 (16) “1989 Guidelines and Standards for the Removal of Offshore Installations and Structures on the Continental Shelf and Exclusive Economic​ ​Zone” 17. Offshore Petroleum and Greenhouse Gas Storage Act, 2006 (Cth) (OPGGSA), Commonwealth 18. Environmental Protection and Biodiversity Conservation Act (EPBC Act), Commonwealth. Above list is, most likely, incomplete. For complete list refer to UK Oil & Gas Authority Regulatory​ ​framework​[32]​. IMO regulations are interesting to mention as 1989 IMO guidelines require the complete removal of all structures in water depths shallower than 100 m and jacket weight lighter than 4,000 tonnes. It allows partial removal of installations in deeper waters, leaving a minimum 55 m of clear water for navigation safety. All structures installed after Jan. 1, 1998, must have​ ​a​ ​design​ ​that​ ​allows​ ​for​ ​complete​ ​removal.​ ​Some​ ​exceptions​ ​are: ●

The installation will serve a new use if it is permitted to remain partially or wholly in place.

●

Complete removal is not feasible technically; however, installations after Jan. 1, 1998,​ ​should​ ​have​ ​a​ ​design​ ​that​ ​allows​ ​for​ ​a​ ​technically​ ​feasible​ ​complete​ ​removal.

●

Complete removal would involve extreme cost or extreme risk to personnel or the environment.

For our case is interesting UNCLOS, that permits partial removal of structures provided that the​ ​International​ ​Maritime​ ​Organization​ ​(IMO)​ ​criteria​ ​are​ ​met.​ ​This​ ​came​ ​into​ ​force​ ​in​ ​1994. Brent Oilfield started production on 11-Sep-1976 and the very first tanker was loaded on the 13-Dec-1976 [7]​. Design of the Brent field and associated platforms, probably, started a decade or so earlier - good 20 to 30 years before some of above regulations were adopted. That is justifying credit given in one of the previous sections to the author(s) of the phrase "removal​ ​as​ ​the​ ​reverse​ ​installation". In a case that anyone is seeing number of the regulations in the North Sea as challenging operators in some other parts of the world are much more challenged by ​not having regulations. Problem here - mostly West Africa and South East Asia - is to comply with regulations​ ​which​ ​doesn't​ ​exist.

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South East Asia start moving fast with legislation work, most notably Indonesia and Thailand​[25]​. Indonesian Government preparing its first abandonment and site restoration regulation, which sets out procedures to propose abandonment and site restoration operations, provision of the relevant fund, and technical standards required. Thailand introduced in 2016 regulation, requiring a detailed decommissioning plan to be prepared by the concession holder, for the estimated costs of decommissioning activities to be audited and​ ​for​ ​the​ ​concession​ ​holder​ ​to​ ​provide​ ​securities,​ ​in​ ​various​ ​forms. “. In facing up to the decommissioning issue a country such as Brazil, for example, has yet to put the appropriate regulatory structure in place. Operators must prepare themselves without knowing quite what will be required of them. Even in the North Sea, where cost and approach are now an urgent focus, ‘we need to change the technology we use and we need to​ ​bring​ ​a​ ​new​ ​mindset​ ​to​ ​the​ ​market’,​ ​says​ ​Fairfield​ ​Energy’s​ ​Sharp.”​[33] A number of stakeholders and interest groups can vary from region to region. In the case of the Shell's Brent field decommissioning in the North Sea, there are 180 "stakeholders" to consult​[8]​. In spite of submitting decommissioning program on 3,000 pages, Shell's Brent program​ ​had​ ​been​ ​rejected​ ​by​ ​environmental​ ​groups​[16]​.

​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​Fig.​ ​5

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Oil​ ​Companies​ ​Present​ ​position The present position of the oil companies related to decommissioning can be summarized (with​ ​a​ ​lot​ ​of​ ​simplifications)​ ​as​ ​follows: ● ● ● ● ● ● ● ● ● ● ●

Low​ ​oil​ ​price​ ​environment Low​ ​number​ ​of​ ​new​ ​projects Constant​ ​loss​ ​of​ ​"know​ ​how"​ ​through​ ​layoffs​ ​and​ ​inability​ ​to​ ​attract​ ​new​ ​talents​[17]​ [​ 31] Service​ ​companies​ ​offering​ ​low​ ​prices​ ​(break-even?)​ ​in​ ​order​ ​to​ ​survive​[16] Offshore​ ​vessels​ ​day​ ​rates​ ​are​ ​break-even​ ​or​ ​close​ ​to​ [18,​ ​ ​ ​19​,​ ​20] Aging​ ​assets​ ​are​ ​expensive​ ​to​ ​maintain Complicated​ ​and​ ​time-consuming​ ​compliance​ ​process Significant​ ​shore-based​ ​infrastructure​ ​is​ ​required Significant​ ​capital​ ​required,​ ​partly​ ​paid​ ​by​ ​taxpayers​ ​through​ ​rebates ROI​ ​doesn't​ ​exist​ ​in​ ​decommissioning Decommissioning​ ​operation​ ​is​ ​serious​ ​HSE​ ​risk.

Some of the above points can be beneficial for decommissioning operation, others are, obviously, not. Low oil price is a direct driver for a low number of the new projects and know-how loss. At the same time, low oil prices and a low number of new projects are "pushing" prices of the service companies and offshore vessels day rates down, which in short-term can be beneficial for decommissioning operations. Loss of know-how and the inability of the industry to attract new talents will, eventually, start working against lower costs of decommissioning operations - note that market predictions, as mentioned earlier in this​ ​text,​ ​are​ ​covering​ ​the​ ​period​ ​of​ ​the​ ​next​ ​20-ish​ ​years,​ ​until​ ​2040. It is our firm belief that a number of decommissioning projects will improve shore-based facilities in regions other than the North Sea and the Gulf of Mexico. How fast that will happen depends, partly, on oil prices and confidence of investors to put their money in oil-related​ ​activities. There is a trend, mostly in Southeast Asia, where International Oil Companies are looking for "clean break", seeking an opportunity to sell their aging assets to Local companies​[25]​. In such cases, sellers are trying to allocate risks, liabilities, and costs of decommissioning to buyers, either through sale and purchase agreement seller warranty clauses or through indemnity mechanisms. Buyers are aware of such attempts - they can mitigate liabilities, to some extent, by due diligence or contractually, by requesting a greater range of asset related warranties, including maintenance of decommissioning funds. As per Ashurst's analysis​[25]​,​ ​a​ ​number​ ​of​ ​such​ ​transactions​ ​are​ ​lower​ ​than​ ​expected.

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Afterlife​ ​of​ ​the​ ​Platform The complexity of the removal, is the best pictured by the costs of the operation: two-thirds of the total cost. Whichever option for removal operator is allowed/negotiated to choose, be it partial​ ​or​ ​complete,​ ​it​ ​requires​ ​facilities​ ​for​ ​disposal. AF Offshore Decomm UK and UK Forth Ports announced in Aug-2017 their intention to establish joint venture AF Dundee, with idea to lay foundation for creation of North Sea Oil and Gas Decommissioning Hub​[21]​. In a first phase, Port of Dundee, which is owned by UK Ports, invest 10 million pounds in "quay extension which will feature the UK’s strongest quayside, specifically designed to equip the port to handle the large-scale loads demanded during decommissioning operations"​[21]​. Both parties are betting on position of the Port of Dundee and present infrastructure - rails, roads, port facilities - and proximity of the assets doomed​ ​for​ ​decommissioning.

Infrastructure AF Grouppen, "mother company" of AF Offshore Decomm UK, runs AF Vats Environmental Base in Norway, facility for decommissioning offshore assets and they, for sure, knows scale of​ ​the​ ​task​ ​they're​ ​facing. Let us make short and not necessary complete inventory list of the materials used in construction​ ​and​ ​operation​ ​of​ ​the​ ​stable​ ​platform.

Inventory Solids​: ● ● ● ● ● ● ● ●

Steel​ ​-​ ​Carbon​ ​Steel​ ​and​ ​Alloy​ ​Steel Concrete Aluminium Copper Zinc Rubber Wood Fabric 24

● ● ●

Plastic - there are many types of synthetic materials, generally categorized as “plastic” Oil​ ​scale “Other”​ ​materials​ ​like​ ​Cotton,​ ​Formica,​ ​Cork,​ ​Ceramics,​ ​Glass,...

Appropriate units of measuring are metric tons - depending on the size of the field and unit in thousands for steel to tens of tons for plastic and fabric. Some of “other” materials are Arsenic, Bismuth, Cadmium, Indium, Lead, Silicon, Titanium,.., usually found in a “traces” up to few kilograms. Asbestos, presumably, if used “once upon a time”, was removed decade​ ​or​ ​so​ ​earlier. Fluids​,​ ​removed​ ​during​ ​"flushing"​ ​phase: ● ● ● ● ● ● ● ● ●

Fuel​ ​Oil Helifuel Methanol Scale​ ​inhibitor Demulsifier Antifoam Biocide O2​ ​scavenger Corrosion​ ​inhibitors

Appropriate units of measurement are cubic meters - from thousands for Fuel Oil to few cubic​ ​meters​ ​for​ ​Biocide,​ ​Scavenger​ ​and​ ​Inhibitors. Agencies, acting in behalf of Regulator often requesting precise accounting of removed materials for each phase of decommissioning process, usually divided to categories - drill cuttings,​ ​decommissioning​ ​waste,​ ​operational​ ​waste. Drill cuttings are a category for itself. If well is drilled with Water Based Mud (WBM) and that mud is disposed on a seafloor, high pressure jetting may be sufficient. If well or portion of the well is drilled with Oil Based Mud (OBM) or Low Toxicity Oil Based Mud (LTOBM) it is most likely​ ​removed​ ​during​ ​the​ ​drilling​ ​operation. Waste​ ​management​ ​options​ ​are​ ​set-up​ ​in​ ​order​ ​of​ ​preference:

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Unused fluids and consumables are a relatively easy problem - send them to another unit or resell​ ​to​ ​the​ ​other​ ​operator.​ ​What​ ​about​ ​other​ ​materials? The usual statement in Decommissioning Program documents, related to disposal and reuse is​ ​something​ ​like: "All equipment and material retrieved from the facility and seabed will be returned to the land for reuse, recycling, or treatment and disposal as appropriate by suitably licensed facilities. Movement of any Hazardous Waste will comply with the consignment requirements of the XXX​ ​(as​ ​appropriate)​ ​Regulations". A key phrase in above sentence is "suitably licensed facilities". Those facilities should have "appropriate"​ ​capacities. In​ ​a​ ​case​ ​of​ ​the​ ​Brent​ ​Spar,​ ​estimations​ ​of​ ​material​ ​inventory​ ​is​ ​available​ ​online​[6]​:

In a case of dismantling Brent Delta topside, hazardous materials, including 9,800 tons (9,900 tonnes) of, presumably absent, asbestos should be removed first​[11]​. As per the same source:

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"With an average washing machine weighing 150 lb, a rough estimate would suggest there is potentially enough steel in Brent Delta to make more than 200,000 washing machine cases." Note that production of one tonne of steel generates almost two tonnes of the CO​2​[22]​. As we have seen above, in the North Sea “suitable licensed facilities” are existing and capacity is building up. Some other regions of the world can be less "lucky" with the availability​ ​of​ ​infrastructure. With legs of Brent Delta is a bit different: built in 270,0000 tonnes of concrete, they should remain in place as per original plan. Study, conducted by Shell, predicting that parts remaining above sea surface will collapse after 150-200 years; underwater sections will last for another 300-500 years; storage cells on the very bottom of the leg structure will remain upright​ ​around​ ​1,000​ ​years​[11]​.

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Instead​ ​of​ ​Removal "Recent" development in decommissioning of California's 27 platforms located in state controlled waters give some hope, though​[5]​. Partly removed platforms are reused as a part of the state sponsored "rigs to reef" program with a significant saving of the time, costs, and CO​2 emissions. State of California passed the law AB 2503 in order to accommodate the solution. Oil companies have done their job, sharing savings on partial removal of the platforms​ ​to​ ​ ​Ocean​ ​Conservation​ ​Fund. Let us assume that imaginary oil company finished with first three phases of the decommissioning program - Planning, Hydrocarbon Purging and Plug & Abandon - and that they're facing removal phases of the program. Options they're facing are given in the following​ ​diagram:

As you can see from above diagram, nobody argues against the removal of the topside. Shell demonstrated with a removal of Brent Delta mega-topside of 24,000-tonne that such operation is possible and safe. As discussed earlier, removal of substructure portion of the platform​ ​is​ ​far​ ​more​ ​difficult​ ​and​ ​comes​ ​with​ ​the​ ​risks. "Rig to reef" is a valid option in some cases, mostly if water is deep enough to accommodate "one more" reef. On the other hand - do we need that many reefs as we have platforms now? We're talking big numbers here - several hundreds of potential reefs, some of them located in relatively shallow water, on, or close to, fishing grounds or in the vicinity of shipping routes. Modern ships are bigger, with more payload and deeper draft - reefs can become​ ​an​ ​obstacle. Reusing legs to construct hotel or resort on the top is the one "not so new" idea. Possible, good for some areas of the world - tropical or sub-tropical, although, I can not imagine 28

myself having vacation constrained on several hundred square meters footprint. For some people, it probably works. As earlier asked, is there any need for several hundred hotels, located in different areas of the World Ocean, sometimes in the hostile environment? And what land-based infrastructure should be developed on a helicopter flight or medium-duration​ ​boat​ ​ride​ ​from​ ​the​ ​hotel?​ ​International​ ​airport? There are some other ideas, though, but before we talk about them let us examine conditions​ ​such​ ​structure​ ​should​ ​meet: 1. 2. 3. 4. 5. 6. 7.

Environmentally​ ​friendly; Sustainable; Marketable; Relatively​ ​"easy"​ ​to​ ​implement; Bringing​ ​additional​ ​value​ ​to​ ​the​ ​local​ ​community; Relatively​ ​"easy"​ ​to​ ​handle​ ​at​ ​the​ ​"final​ ​end​ ​of​ ​life" Lower​ ​risk​ ​level​ ​comparing​ ​to​ ​risks​ ​associated​ ​with​ ​oil​ ​platforms.

Environmentally​ ​friendly Why change one potential polluter for the other one? Oil platforms, at the moment, are environmentally safe - tragedies like Maccondo Well blowout and Deepwater Horizon​[26] disaster which followed are "just" incidents - on a big scale. Through the history of oil exploration, oil companies developed mechanisms to share "lessons learned" from such incidents and legislators built them in the rules and regulations. Thanks to disasters like Maccondo, the oil industry is becoming environmentally "friendlier" each day, even though it is​ ​handling​ ​potentially​ ​dangerous​ ​goods. Obviously, a successor of the offshore platform must be environmentally friendly, all environmental risks of new usage should be understood and mitigated. One of the key drivers in this field is our evolving perception of environmental protection - before Al Gore global warming lived, probably, in scholarly circles and debate rooms, only. Nobody can predict today what will be environmentally correct in 20-years. So, do it correctly from the beginning.

Sustainable

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The oil industry is facing massive spending, in the form of the costs for removal and disposal of the offshore platforms. The task in front is new "kid on the block", as there is no incentive in it. For the first time in the history, oil companies are entering into the big projects without expected ROI. One can not expect from the industry to start another project where expected ROI​ ​is​ ​null,​ ​just​ ​for​ ​the​ ​sake​ ​of​ ​not​ ​removing​ ​substructure​ ​of​ ​the​ ​platform.

Marketable A new asset shall produce goods or offer services - such services and goods should have a market​ ​now,​ ​or​ ​at​ ​least,​ ​in​ ​foreseeable​ ​future. The obvious example is hydrogen gas, used as the fuel. Forced and controlled chemical reaction produces energy out of the hydrogen and product of the reaction is - water. The market, at the moment, is relatively small - London converted 80-ish buses to use hydrogen, even though, at the time, they were forced to import gas from Holland; China, at the time of this writing, doing a similar thing on the much bigger scale. Volvo using, for years, small-power fuel cells to heat up cabins of their tracks. Successful implementation of such projects will drive prices of equipment (fuel cells) lower. A new advancement in producing hydrogen from the water, not by reformatting hydrocarbons, will eventually drive to wider adoption​ ​and​ ​bigger​ ​market.

"Easy"​ ​to​ ​implement The new asset should take the same footprint as "old" topside - no additional legs, complex substructure and subsea work - additional templates, subsea cables, and pipes etc. In other words, new topside as support for the production of goods and services should be lighter than​ ​existing​ ​one​ ​-​ ​it​ ​can​ ​be​ ​beneficial​ ​to​ ​the​ ​fatigue​ ​life​ ​of​ ​the​ ​substructure.

Adding​ ​value​ ​to​ ​the​ ​local​ ​community The societal impact of cessation of the production on the oil platform can be serious and can not be neglected. In some areas of the world, whole communities are engaged in "supporting roles" of oil production - from works in an onshore base to benefitting of crew change and helicopter flights. Once oil platform stopped producing, such jobs are lost, and in some cases, the community is doomed. It happened before - think about Gold Rush Towns on Alaska and Whaler's stations. If it happened earlier, most likely will happen again​[34]​. Social and​ ​human​ ​impacts​ ​of​ ​economic​ ​migrations​ ​are​ ​well​ ​documented. The new asset should be such to create a positive impact on the local communities, by offering otherwise lost jobs, developing new infrastructure and boosting local business to transform​ ​themselves​ ​to​ ​non-oil​ ​related​ ​production. 30

True​ ​end​ ​of​ ​life The new asset should be designed in a manner to be a friendly for future removal - true end of life. No matter when it will come - in the case of Brent Delta in next 150 years. Part of the equation here is less weight of the topside and "clean" subsea portion, but, in general, substructure​ ​remains​ ​a​ ​problem. The oil industry and its offshore rigs are in public spotlight at the moment. Reasons for that are, partly, a public image of the industry as a "bad guy", and, partly, our limited knowledge and​ ​understanding​ ​of​ ​the​ ​interaction​ ​between​ ​ecosystem​ ​and​ ​structure. Prolonged life of the substructure should give us an opportunity to better understand the impact of the final removal on local eco-system. Rigs to reef program in California will, perhaps,​ ​give​ ​some​ ​clues​ ​to​ ​the​ ​rest​ ​of​ ​the​ ​industry.

Lower​ ​risk​ ​level​ ​of​ ​the​ ​new​ ​asset Risks​ ​of​ ​oil​ ​production​ ​can​ ​be​ ​simplified​ ​as​ ​follows: 1. 2. 3. 4.

Complexity​ ​of​ ​the​ ​equipment​ ​and​ ​man-machine​ ​interaction; Geological​ ​and​ ​Oceanographic​ ​hazards; Hazards​ ​posed​ ​by​ ​oil​ ​reservoirs​ ​-​ ​pressure,​ ​temperature,​ ​formation,​ ​etc; The​ ​sensitivity​ ​of​ ​ecosystem​ ​to​ ​hydrocarbons.

The new asset should "beat" oil platform in all four categories to be considered "safe and clean". Almost all of the risks are mitigated during flushing, P&A and topside removal phases. Oceanographic hazards are remaining as a new asset is working in the marine environment​ ​-​ ​such​ ​risk​ ​is​ ​partly​ ​lower​ ​due​ ​to​ ​the​ ​lower​ ​weight​ ​of​ ​the​ ​new​ ​asset. The complexity of the equipment and man-machine interfaces depends on a type of the production which takes place on the new asset and should be mitigated as per marine standards​ ​as​ ​well​ ​as​ ​per​ ​standards​ ​of​ ​the​ ​applicable​ ​industry.

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CDM​ ​Reuse​ ​Proposals At the beginning of the present oil price "downturn", Concept Design Marine have been approached by the client with a request to create proposals for converting his jack-up units into something which can generate revenue. Worth mentioning here that client built several units on pure speculation. We have developed several proposals, but at the end, nothing came out of it as the client was not able to service his payments to the rig builder. Soon afterward​ ​the​ ​client​ ​went​ ​out​ ​of​ ​the​ ​business. It was a valuable hint for us - we start thinking to implement some of the ideas on, at the time, coming decommissioned offshore platforms. Our team developed 15-ish proposals and concepts for which are safe, sustainable, environmentally friendly, and can make a societal impact of cessation of oil production more bearable for local communities. Understandably, we shall not present all proposals here, just a few, and we shall try to "judge" them against conditions for reuse set in previous pages. Some of the presented solutions are protected by patents,​ ​some​ ​are​ ​not. Note that our proposals are "covered" by UNCLOS. The United Nations Convention on the Law of the Seas, 1982, Article 60, which is permitting partial removal of the offshore structure if IMO conditions are met (see "Legislation" chapter). IMO regulations are permitting​ ​leaving​ ​the​ ​installation​ ​partly​ ​or​ ​wholly​ ​in​ ​place​ ​if​ ​it​ ​serves​ ​a​ ​new​ ​use. Let us go back, to the main topic of this chapter. Note that listed below are just a few out of 15-ish solutions. There is nothing new in these solutions - it is well-known technology from the land solutions, implemented in Marine Environment, and in a few cases, merging few solutions​ ​in​ ​one.​ ​Some​ ​of​ ​our​ ​proposals,​ ​like​ ​SeaFarm,​ ​are​ ​patent​ ​protected;​ ​some​ ​are​ ​not.

SeaFarm Non-pollinated vegetables, mushrooms, poultry, insects, fish, oysters, different eatable kinds of seaweed and alike can be produced on a site of decommissioned offshore installation. In a case of production of non-pollinated vegetables, “vertical farming technique” should be used and combined with the production of mushrooms. It is possible to grow “organic food”, as there is no need for insecticides and plants are grown in the isolated and controlled environment. Insects​ ​shall​ ​be​ ​produced​ ​as​ ​a​ ​source​ ​of​ ​proteins​ ​and​ ​used​ ​as​ ​fish,​ ​chicken​ ​and​ ​pet​ ​food. Source of the energy for Food Production operation could be renewables, thermal, hybrid or provided through existing subsea cable - due to the small requirement, the capacity of the

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subsea cable is not critical. SeaFarm can supply food to consumers on land or to other offshore​ ​assets​ ​nearby.

Ocean​ ​Cleaning​ ​Facility A lot of solid debris floating on the and nearby Ocean surface, mostly plastics. There are technologies in development, using ocean current and traditional fishing technique to collect such debris. If there is the intention of the wider community to clean the ocean surface, decommissioned offshore facility may be used as collection and preprocessing/processing plant​ ​for​ ​debris.

Offshore​ ​Supply​ ​Hub A decommissioned structure can be used as Offshore Supply Hub, accommodating workshops and warehouses for surrounding installations, giving operator possibility to manage stocks from one centralized location near the active units. Highly flammable fluids, like Aviation Fuel, can be stored in the Hub, which is acting as the refueling station, lowering risks on still active installations. The interface between shore and supply hub can be maintained by slower and smaller ships; the interface between the hub and other assets can be maintained by smaller OSVs. As per Clarkson's Outlook, published in May 2012​[28]​, the average​ ​distance​ ​of​ ​the​ ​wells​ ​from​ ​the​ ​shore​ ​is​ ​126​ ​km.

Desalination​ ​plant 33

The desalination plant, either based on well-established technology or based on new technology, where a membrane is installed near sea bottom, reducing power consumption can​ ​be​ ​utilized. Industrial water can be delivered to surrounding assets or consumers either by subsea piping​ ​or​ ​tankers.​ ​Potable​ ​water,​ ​if​ ​produced,​ ​can​ ​be​ ​bottled​ ​and​ ​delivered​ ​to​ ​the​ ​consumers.

Sanity​ ​check Let us check, without going to much in depth, how above 3-4 proposals are fulfilling conditions​ ​listed​ ​in​ ​the​ ​previous​ ​chapter:

In the above table, sign "+" denotes that condition is satisfied, sign "-" that condition is not satisfied​ ​and​ ​sign​ ​"+​ ​/​ ​-"​ ​denotes​ ​that​ ​condition​ ​is​ ​partly​ ​satisfied. In a similar manner we can produce table, taking into account simplified risks we mentioned in​ ​the​ ​previous​ ​chapter:

If we look into Brent Delta leftover legs, seems that some of the listed solutions may be "perfect match". SeaFarm is an especially good candidate, keeping in mind that legs will last another 100 years or so, and size of the farming topside which is possible to install. The market for food, which is not polluted with insecticides (regulations in some areas are strict regarding a definition of "organic food"), is growing rapidly. There is some obstacle, though Brent Delta legs are located approximately 200 km (115 miles) offshore, in the demanding North​ ​Sea. How to decide between options - there is no "one solution fits all structures"? We have covered​ ​that​ ​aspect​ ​of​ ​reuse​ ​of​ ​the​ ​offshore​ ​structures​ ​in​ ​the​ ​following​ ​chapter. 34

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Decision​ ​Tool​ ​(Matrix) There is no “one solution fits it all” we have developed Decision Tool (Matrix), a multi-attribute analysis tool, to “measure” proposed solution against real structure in hands. Decision Tool (Matrix) can be used for comparative analysis of several solutions (not limited to CDM's proposals), based on the real asset on real location or for analysis of only one option. The​ ​tool​ ​consists​ ​of​ ​over​ ​100​ ​criteria/variables,​ ​divided​ ​into​ ​8​ ​categories:

Initial swing weight factors​[29] are, set equal (1/7 = 0.14285...) as they should be “client's choice”. Category “1-Existing Asset (Rig)” is not used in the further analysis as it is there to set​ ​boundary​ ​conditions. Reuse option(s) are captured in "decision node" (rectangular symbol) labeled as "Conversion"​ ​in​ ​diagram​ ​below:

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Two​ ​kinds​ ​of​ ​results​ ​are​ ​presented: Native,​ ​without​ ​weight​ ​factors​ ​-​ ​“Result”,​ ​red​ ​on​ ​the​ ​diagram​ ​above; Results​ ​of​ ​swing​ ​weight​ ​analysis​ ​-​ ​“swResult”,​ ​green​ ​on​ ​the​ ​diagram​ ​above. It is looking like "snake oil" on the first glance. So, for the purpose of this text, let us see how it​ ​works. We'll try to compare two solutions - Wind Farm and one of CDM's proposals for reuse of decommissioned offshore platforms, SeaFarm. More about SeaFarm you may find here. Location and existing asset are “imaginary”. We shall unlock one node - “2-Location” and, for brevity​ ​sake,​ ​in​ ​detail​ ​discuss​ ​“Metocean”​ ​criteria​ ​of​ ​the​ ​Location​ ​category. “Blue” ovals, with captions “2-Location”, “3-Regulations”,... are categories containing, in total, over​ ​100​ ​variables.​ ​Some​ ​categories​ ​are​ ​divided​ ​into​ ​the​ ​sub-categories:

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Metocean​ ​subcategory​ ​model:

“Weather” node is, mathematically, modeled as “Probabilistic Table”, where weather patterns and​ ​their​ ​occurrences​ ​are​ ​defined​ ​as:

In​ ​reality,​ ​weather​ ​patterns​ ​should​ ​come​ ​from​ ​Metocean​ ​Data​ ​Study​ ​for​ ​the​ ​given​ ​field. We used the approach that “lower value is better”(1 is the best, 5 is the worst) - it is possible to​ ​use​ ​opposite​ ​approach​ ​(“higher​ ​value​ ​is​ ​better”). Few explanations - “Storm” and “Swell” can affect SeaFarm to some degree as goods it's producing are perishable - long swell can disrupt loading of produced goods. On “Severe Storm” wind turbines cease production (“cut-off wind speed”), while SeaFarm can continue producing, with the delivery of perishable products disrupted. On the other hand, the probability​ ​of​ ​wind​ ​speed​ ​to​ ​reach​ ​“cut-off​ ​speed”​ ​of​ ​the​ ​turbine​ ​is​ ​low​ ​(0.01)​ ​in​ ​this​ ​case.

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Results of the analysis, given in the above diagram, showing that WindFarm is a much better solution for a weather pattern on the field than SeaFarm. It is in line with our expectation as SeaFarm is producing perishable good, which delivery to consumers can be disrupted by weather​ ​conditions. Results​ ​of​ ​the​ ​full​ ​analysis​ ​are​ ​as​ ​follows:

“Raw results” are close to each other. Some of the conclusions are based on estimations and “preliminary” calculations -it is a time to perform “sensitivity analysis”, by using “swing 39

weight”. Swing weight factors are based on decision maker's preferences - ranking results per​ ​importance​ ​he​ ​wants​ ​to​ ​assign​ ​to​ ​each​ ​category:

To make a better decision, our imaginary client wants to check what will happen if Liabilities weight factor is set between 40-80%; Conversion operation weight factor in the range 50-100%​ ​and​ ​“New​ ​Asset”​ ​is​ ​a​ ​random​ ​number​ ​between​ ​80-100%. Results​ ​(Mid​ ​Value)​ ​are​ ​given​ ​in​ ​following​ ​tables​ ​for​ ​SeaFarm​ ​and​ ​WindFarm,​ ​respectively:

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Obviously, SeaFarm is a better fit in this case, as expected. Wind "Farm" consisting of one turbine is not the sustainable solution. One of our solutions is "Wind Farm with the twist", which​ ​can​ ​better​ ​utilize​ ​available​ ​space​ ​-​ ​use​ ​it​ ​or​ ​not​ ​depend​ ​on​ ​the​ ​condition​ ​of​ ​the​ ​legs. Decision​ ​Tool​ ​(Matrix)​ ​can​ ​analyze​ ​any​ ​kind​ ​of​ ​the​ ​solutions,​ ​not​ ​only​ ​our​ ​15-ish. Perhaps, it is a good time to mention software tool we used - it is, at the moment, Analytica 101, which is available from Lumina website. Python, Excel, Octave and other programming languages​ ​can​ ​be​ ​used​ ​as​ ​well.

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Oil​ ​Company​ ​Role In previous chapters of the document, we tried to explain why the decommissioning process is complicated and why we consider that reuse of offshore structures is an option - at least, for some parts of the structure. We very briefly mentioned some of the 15-ish reuse solution Concept Design Marine developed in the recent years. As there is no "one solution fit it all", we have developed Decision Tool (Matrix), multi-attribute analysis tool to show how proposals​ ​are​ ​working​ ​for​ ​real​ ​asset​ ​and​ ​at​ ​the​ ​real​ ​location. An oil company can argue that there is no value in previous chapters for them, as we told them what they know about decommissioning and that second part, related to reuse, is not in​ ​"their​ ​scope".​ ​Those​ ​points​ ​are​ ​valid​ ​from​ ​traditional​​ ​company's​ ​point​ ​of​ ​view. Traditional Oil Company, so far, attacked a problem they had with "brute force": if they need the hole drilled, they hire drilling contractor; if they need maintenance of the well, they hire Well Intervention contractor; if oil company needs FPSO, they contract it. The complexity of the field operation(s) and associated liabilities are dictating such approach. Imagine what would happen to BP if Maccondo well and Deepwater Horizon were their sole responsibility and​ ​liability. A similar approach is working for decommissioning: oil company will hire several contractors during the process - flushing and cleaning specialist, P&A specialist, removal specialist, disposal specialist,... Those contractors may hire a subcontractor for some specific task. Again, the complexity of the operation, resources required, and liabilities are dictating such approach. What is about reuse? Can the Oil Company simple sell the asset, or remaining portion of it, and move on? Well, take a moment and have a look of Brent Spar photo​[6]​. Would you put your money in it? And there are many platforms which look even worst. In spite of the look, what​ ​will​ ​happen​ ​with​ ​liabilities​ ​once​ ​"true​ ​end​ ​of​ ​the​ ​life​ ​come"? During development of our reuse concepts, Concept Design Marine, have a lot of "grapevine" talks with smart and nice people from different industries. Some were interested in​ ​our​ ​solutions,​ ​some​ ​were​ ​not.​ ​Prevailing​ ​concerns​ ​were: 1. Operation​ ​in​ ​Ocean​ ​Environment; 2. Maintenance​ ​and​ ​present​ ​status​ ​of​ ​the​ ​reused​ ​(sub)structure; 3. Liabilities​ ​at​ ​"true​ ​end​ ​of​ ​life". Let us put ourselves in the shoes of someone who has an idea to install farming topside on the top of the remaining substructure and operate SeaFarm. Presumably, such company knows their business of the Agriculture - how to grow vegetables, what kind of the veggie is best suited for the area, how to maintain farming equipment,... What they need is knowledge 42

of Ocean and experience in operation of the offshore asset. It is experience oil companies gained and shared (partly due to contractor model) last 40-50 years. Oil companies should step​ ​there​ ​and​ ​offer​ ​knowledge​ ​they​ ​gained​ ​to​ ​the​ ​new​ ​operator. We shall think, as well, about "presenting" asset or part of it to the potential buyer. Nobody wants to put his money, and, for some, future, in pile of the rust - be it buying a second-hand car, tractor or second-hand offshore structure (or part of it). I still have a good memory when I stepped on the deck of the unused floater and my foot went through the deck. Have few scars to remind me. Making part of installation "presentable" doesn't mean to splash fresh paint on the top of the heavily corroded steel or presenting "doctored" fatigue life reports - I saw them in the past, too. The oil industry is mastering "life extension" program and can guide​ ​the​ ​new​ ​operator​ ​through​ ​the​ ​process. Liabilities concern of the new operator is understandable - in 10 years they may find themselves in the same position oil companies are facing today. It may be even worse as oil companies are having the knowledge to deal with the situation - agriculture company doesn't have such knowledge and do not have time to gain it. We are talking about 10-20 years’ time span, depending on the state of the original structure. The offshore company should offer "deal sweetener" to the potential buyer, probably through the access to the part of remaining decommissioning funds. It worked in the case of the rigs in California​[5]​, where the saving of approximately $500 million US was split between the oil companies and the Ocean Conservation​ ​Fund. In other words, oil companies, in this case, should transform themselves from their present position​ ​as​ ​"project​ ​main"​ ​to​ ​the​ ​service​ ​or​ ​consulting​ ​role. Question someone at oil company may ask is simple - why to bother? If saving in cash is not enough incentive, consider environmental benefit by not releasing thousands of tons of the CO​2 during removal and disposal phases, and societal benefits by preserving some jobs and boosting businesses in the local communities. In some areas of the world, the absence of "appropriate" infrastructure for disposal and recycling may be prevailing. In 10-20 years infrastructure and our understanding of the impact of decommissioning on the environment will​ ​be​ ​much​ ​better.

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References [1]​ ​https://en.wikipedia.org/wiki/Oil_platform [2]​ ​https://en.wikipedia.org/wiki/Maunsell_Forts [3] http://www.osjonline.com/news/view,decom-market-growing-in-size-and-complexity-but-provi ders-too-fragmented_45672.htm [4] https://www.theguardian.com/commentisfree/2017/apr/08/north-sea-oil-death-throes-rigs-dec ommission-industry [5] http://lumina.com/case-studies/energy-and-power/a-win-win-solution-for-californias-offshoreoil-rigs/ [6]​ ​https://en.wikipedia.org/wiki/Brent_Spar [7]​ ​https://en.wikipedia.org/wiki/Brent_oilfield [8]​ ​https://www.theguardian.com/business/2017/feb/06/shell-decommissioning-brent-oil-rigs [9] http://gekengineering.com/Downloads/Free_Downloads/Plug-and_Abandonment_Basics.pdf [10]​ ​https://www.iaea.org/nuccomtoolbox/documents/Brent_Spar_Case_Study.pdf [11] http://www.dailymail.co.uk/news/article-4493586/How-dismantle-mother-Meccano-sets.html [12]​ ​http://www.heavyliftnews.com/news/scaldis-decommissions-horne---wren [13]​ ​http://www.offshoreenergytoday.com/cnr-submits-decom-draft-for-ninian-north-platform/ [14] https://www.desmog.uk/2017/09/04/abandoned-north-sea-wells-may-be-emitting-significantamounts-methane-study-warns

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[15] http://www.subseaenergy.org.au/offshore-de-commissioning-is-it-really-becoming-a-new-fron tier/ [16] http://www.offshoreenergytoday.com/environmentalists-reject-shells-brent-decom-plan/?utm _source=emark&utm_medium=email&utm_campaign=daily-update-offshore-energy-today-2 017-04-11&uid=96615 [17]​ ​http://www.bbc.com/news/uk-scotland-41122892 [18]​ ​https://fromthesouthsea.com/2017/08/04/fire-in-the-dsv-market-literally/ [19]​ ​https://fromthesouthsea.com/2017/08/15/offshore-and-shipping-recovery-cycles/ [20] https://fromthesouthsea.com/2017/08/21/dsv-valuations-in-an-uncertain-world-love-isnt-all-y ou-need-credible-commitment-is-more-important/ [21] http://www.offshoreenergytoday.com/uk-north-sea-decommissioning-hub-in-store-as-new-joi nt-venture-takes-shape/ [22]​ ​http://news.mit.edu/2013/steel-without-greenhouse-gas-emissions-0508 [23] http://analysis.decomworld.com/structures-and-maintenance/last-some-visibility-north-sea-d ecommissioning-costs [24] http://oilandgasuk.co.uk/wp-content/uploads/2016/11/Decommissioning-Insight-2016-Oil-Ga s-UK.pdf [25] https://www.ashurst.com/en/news-and-insights/insights/oil-and-gas-ma-in-the-asia-pacific-re gion [26]​ ​http://ccrm.berkeley.edu/pdfs_papers/bea_pdfs/dhsgfinalreport-march2011-tag.pdf [27] https://en.wikipedia.org/wiki/Al_Gore [28] https://www.marinemoney.com/sites/all/themes/marinemoney/forums/houston12/presentatio ns/OSV_OUTLOOK%20Clarksons.pdf

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[29]​ ​https://wiki.ece.cmu.edu/ddl/index.php/Swing_weighting [30] https://www.petro-online.com/news/fuel-for-thought/13/breaking-news/6-biggest-oil-rigs-in-th e-world/32360 [31] https://www.bloomberg.com/news/features/2017-09-25/in-world-s-hottest-oil-patch-jitters-mo unt-that-a-bust-is-near [32]​ ​https://www.ogauthority.co.uk/decommissioning/overview/ [33] http://www.opec.org/opec_web/static_files_project/media/downloads/press_room/Energy%2 0Petroleum%20Review%20Feb2017.pdf [34] http://www.rigzone.com/news/oil_gas/a/151863/Oil_Ghost_Towns_Dot_the_Landscape_in_ Texas_Other_Shale_Patch/?all=HG2

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Further​ ​Reading http://www.ogj.com/articles/print/volume-108/issue-10/Technology/study-assesses-asia-pacif ic-offshore-decommissioning-costs.html https://www.mactechoffshore.com/what-is-offshore-decommissioning/ Politics,​ ​Economics​ ​and​ ​Ecology​ ​of​ ​offshore​ ​decomm​ ​(part​ ​-​ ​California​ ​rigs​ ​to​ ​reef): http://ocpc.msi.ucsb.edu/pdfs/WTPap6/WP6.pdf Oil​ ​Rig​ ​Disposal,​ ​Post​ ​note​ ​issued​ ​by​ ​UK​ ​Parlamentary​ ​Office​ ​of​ ​Science​ ​and​ ​Technology, 1995,​ ​https://researchbriefings.parliament.uk/ResearchBriefing/Summary/POST-PN-65 Disposal​ ​of​ ​disused​ ​oil​ ​paltforms,​ ​UK​ ​Parlament,​ ​Science​ ​and​ ​Environment​ ​Section,​ ​1995, http://researchbriefings.files.parliament.uk/documents/RP95-77/RP95-77.pdf Abandonment​ ​of​ ​offshore​ ​installations​ ​and​ ​pipelines​ ​under​ ​the​ ​Petroleum​ ​Act​ ​1987​ ​: guidance​ ​notes​ ​for​ ​industry​ ​:​ ​consultative​ ​document,​ ​May​ ​1995,​ ​UK​ ​Oil​ ​&​ ​Gas​ ​Office, https://books.google.com.au/books/about/Abandonment_of_Offshore_Installations_an.html?i d=fbzqSAAACAAJ&redir_esc=y International​ ​And​ ​Eu​ ​Regulation​ ​Of​ ​Oil​ ​Rigs​ ​And​ ​Other​ ​Offshore​ ​Activities​ ​Analysis​ ​And Proposals​ ​For​ ​Reform,​ ​UK​ ​Parliament, https://publications.parliament.uk/pa/cm201011/cmselect/cmenergy/450/450we09.htm https://www.petro-online.com/news/fuel-for-thought/13/breaking-news/6-biggest-oil-rigs-in-th e-world/32360 An​ ​independent​ ​review​ ​of​ ​Offshore​ ​Platforms​ ​in​ ​the​ ​North​ ​Sea, http://www.divinglore.com/Offshore_Platforms.htm DecommWorld​ ​interview​ ​with​ ​Mr.​ ​Razeen​ ​Khalid,​ ​analyst​ ​with​ ​Frost​ ​&​ ​Sullivan http://analysis.decomworld.com/projects-and-technologies/malaysias-decommissioning-mark et-ramp-24-months http://www.totaldecom.co.uk/download/i/mark_dl/u/4011990064/4608976226/Ashurst%20Tot al%20Decom%20-%20NOR%20oil&gas_nuclear%20legal%20framework%20slides.pdf

Faber,M.H.,​ ​Kroon,​ ​I.B.,​ ​Kragh,​ ​E.,​ ​Bayly,D.,​ ​Decosemaeker,P.​ ​(​ ​2001).​ ​Risk​ ​Assessment​ ​of Decommissioning​ ​Options​ ​using​ ​Bayesian​ ​Networks,​ ​ ​20th​ ​Offshore​ ​Mechanics​ ​and​ ​Arctic Engineering​ ​Conference,​ ​Rio​ ​de​ ​Janeiro,​ ​Brazil

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Climate​ ​and​ ​Pollution​ ​Agency.​ ​"Decommissioning​ ​of​ ​offshore​ ​installations",​ ​Oslo,​ ​2010 Offshore​ ​Oil​ ​&​ ​Gas​ ​Decommissioning​ ​Decision-making​ ​guidelines,​ ​Australian​ ​Petroleum Production​ ​&​ ​Exploration​ ​Association,​ ​July​ ​2016 Decommissioning​ ​of​ ​offshore​ ​man-made​ ​installations,​ ​Taking​ ​an​ ​ecosystem​ ​approach, European​ ​Marine​ ​Board,​ ​April​ ​2017 Decommissioning​ ​offshore​ ​infrastructure:​ ​a​ ​review​ ​of​ ​stakeholder​ ​views​ ​and​ ​science priorities,​ ​Western​ ​Australian​ ​Marine​ ​Science​ ​Institution The​ ​International​ ​Comparative​ ​Legal​ ​Guide​ ​to​ ​Oil​ ​&​ ​Gas​ ​Regulation​ ​2016:​ ​A​ ​practical cross-border​ ​insight​ ​into​ ​oil​ ​and​ ​gas​ ​regulation​ ​work,​ ​Published​ ​by​ ​Global​ ​Legal​ ​Group,​ ​in association​ ​with​ ​Ashust​ ​LLP, https://www.loyensloeff.com/media/5312/iclg_oil__gas_regulation_2016_11th_edition.pdf

Images Fig.​ ​1,​ ​Maunsell​ ​Sea​ ​Forts,​ ​https://en.wikipedia.org/wiki/Maunsell_Forts Fig.​ ​2,​ ​Valhall​ ​A,​ ​https://commons.wikimedia.org/wiki/File:Valhall_A_oljeplatform.jpg Fig.​ ​3,​ ​Ekofisk, https://commons.wikimedia.org/wiki/File:Ekofisk_2-4_K_(DEX_KF_000635).jpg Fig.​ ​4,​ ​Brent​ ​Spar​ ​(Spar​ ​E),​ ​https://en.wikipedia.org/wiki/Brent_Spar Fig.​ ​5,​ ​Troll​ ​A,​ ​https://commons.wikimedia.org/wiki/File:Oil_platform_Norway_new.jpg

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Companies​ ​Mentioned Anadarko,​ ​as​ ​Kerr-McGee ConocoPhillips,​ ​as​ ​Phillips BP,​ ​as​ ​Standolind​ ​Oil​ ​&​ ​Gas Shell Canadian​ ​Natural​ ​Resources Scaldis Wood​ ​Mackenzie Turner​ ​&​ ​Townsend AF​ ​Dundee AF​ ​Groupen AF​ ​Decomm​ ​UK AF​ ​Vats​ ​Environmental IHS​ ​Markit

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Assets​ ​Mentioned Berkut Perdido Petronius Hibernia Mars-B Petronius Baldpate Troll​ ​A Bullwinkle Pompano Benguela-Belize​ ​Lobito-Tomboco Gulfaks​ ​C Tombua​ ​Landana Harmony Brent​ ​Spar​ ​(Brent​ ​E) Brent​ ​Delta Ninian​ ​North Horne​ ​&​ ​Wren

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