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Eiffel Towers in the North Sea – Shell’s decommissioning plans another Brent Spar PR disaster?

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Alex Russell and Peter Strachan: from Robert Gordon University

TUESDAY, AUGUST 30, 2016

Shell is preparing to start the decommissioning of its four gigantic oil platforms in the famous Brent field in the Scottish part of the North Sea – a huge undertaking. Unfortunately, write Professor Alex Russell of the Oil Industry Finance Association and Professor Peter Strachan of Robert Gordon University, the company plans to dismantle only the topsides of the platforms. It wants to leave the Eiffel-tower sized legs, including 64 giant storage cells at the base of these structures, in place. They will take hundreds of years to disintegrate. Russell and Strachan call on the UK government and other North Sea governments to call a halt to these plans. They also demand that the Scottish government will have a say in the project.

Fancy a night or two in a police cell? If so, change your car oil, mix it up with mud, add some carcinogenic radioactive sludge and a menu of other waste products, wrap it in concrete, and then dump it in the North Sea. And when you are undergoing questioning by Mi5 to ensure you are not a terrorist, tell them the concrete is thick enough to last 1000 years and there’s nothing to worry about!

Sounds bizarre enough to form a story line for a new series for David Brent, star of the BBC’s iconic comedy the Office? Alas, fact can be stranger than fiction. For this is essentially what Shell is planning to do in the North Sea – but they might be able to get away with it.

‘Brent’ of course is also the North Sea oil industry’s iconic field and the price of Brent crude is a recognised international benchmark for oil. Shell has started on the decommissioning of the Brent Delta platform, one of four Brent Field platforms. Alpha, Bravo and Charlie will be decommissioned later. Delta has seen preparatory work, although the real decommissioning process has been delayed to 2017, according to Reuters.The decommissioning is a gigantic project. Across the Brent field 154 wells will have to be securely plugged with cement after removing the well control equipment. This process has been completed for Delta, which ceased production on 31 December 2011.

On its website Shell has explained in some detail, and justified to its own satisfaction, how it intends to handle the multibillion dollar decommissioning of the Brent installations and pipelines. In essence, the topsides of the platforms will be removed and transported down and past the east coast of Scotland to Able UK in Teesside where they will be brought ashore for dismantling, scrapping and recycling. It is reassuring to see this work is staying in the UK yet irksome it is not being done closer to Shetland where the vast profits from exploiting the UK’s resources in the Brent field were earned.

If the Scottish parliament truly had devolved power then logically control over all economic activity in Scotland’s borders would be the prerogative of Holyrood. Should decisions taken by global companies which affect Scotland’s economy and social fabric and which carry mind-boggling tax relief handouts, whereby the UK pays 50% of the decommissioning cost, not be subject to scrutiny by Holyrood? The promised unfettered devolution of control to Scotland by successive UK Prime Ministers (Cameron, Brown and Blair) is a myth without such transfer of power.

Moreover, as demonstrated by the recent grounding of the Malta bound drilling rig Transocean Winner on Dalmore in Lewis and the consequent spillage of thousands of gallons of diesel fuel, the less distances rigs and topsides have to travel the better from a safety and environmental perspective.

Future sets for alien films

More irksome still is the proposal by Shell that the huge gravity-based structures (GBSs) which pin the platforms to the seabed will be left in situ not only because it is clearly the cheapest option but because, according to Shell, this is also the most environmentally friendly option. Really? The GBSs consist of 3 or 4 concrete legs each the height of the Eiffel Tower (Shell’s analogy), around 165 metres tall and 18 metres diameter, and up to 25 metres above sea level. They have at their base some 64 concrete storage cells which are 20 metres in diameter and 60 metres high – taller than Nelson’s column (another Shell analogy). According to the Shell website, ‘over the years, 42 of the cells have been used for oil storage and separation. They are made of almost 1m thick concrete and reinforced with steel. Inside, they contain a mixture of attic oil, water, and a layer of sediment which has settled at the base.’

As a matter of fact, the contents of these storage cells have been so difficult to determine that Shell enlisted the help of NASA to scan and assess their contents. The first results from NASA for Brent Bravo were produced in May 2016. To be fair to Shell they have made strenuous efforts to clean out the storage cells but they acknowledge that the safest option based on scientific evidence is to leave the possible radioactive sludge entombed in the thick walled concrete pyramids. This argument forms the basis for Shell’s plans to leave the contaminated cells in situ at the base of the GBSs.

To exacerbate the situation, Shell’s decommissioning plans also involve leaving an unnamed number of pipelines and steel jacket footings in place plus other debris including drill cuttings that have accumulated on top of the GBSs. A director of future aliens films would be thrilled by the opportunities presented by this prospect but it is hard to see who else would applaud.

A sad legacy for 40 generations of Scots

Why is this a problem given that Shell has consulted experts who have supported the plans as being the most cost effective and indeed environmentally safest mode of dealing with the eye-sore structures?

It would be possible to write several PhD dissertations on why these plans should not be accepted. There are obvious flaws in the proposals. According to Shell, the concrete legs above sea level will take between 150 to 300 years to disintegrate.The legs below sea level will take up to an additional 500 years to fall apart. And the 64 storage cells? They can take up to 1000 years to disintegrate! In other words if the Shell proposals are given the green light by the UK Conservative Party Government and by OSPAR, a body set up to safeguard the North-Atlantic environment (named after the Oslo/Paris Conventions), then they have the potential to affect the next 40 generations of Scots whose offshore environment can be polluted for 1000 years!

Thus, Shell did not design them, apparently, to enable them to be re-floated and taken back to shore. Even if that were the case, surely, as the profits rolled in over the years and a common acceptance was established across the industry that there would be complete removal of redundant infrastructures at the end of an oil field’s life, plans and financial resources should have been established by Shell to deal with that situation.

Innovative advances in oil and gas technology?

The exportable technological inventions and innovations achieved by the UK oil industry in finding solutions to previously intractable oil extraction problems is constantly trumpeted by Oil and Gas UK and by the Oil and Gas Authority as a defining feature of the industry. If true, this technology should be deployed, regardless of cost, to deal with decommissioning of GBSs.

Will it occur to Theresa May to be proactive here and tell Shell to rethink their plans for creating a scrap yard in the North Sea? Does she realise that failure to do so may create another Brent Spar situation for Shell that will galvanise resistance not only in Scotland but across Europe? Or has Brexit excised her sensitivities to our European partners’ views? It was Germany’s reaction to the 1995 plans to topple the storage vessel Brent Spar into the depths of the North Sea that thwarted the plans of Shell and the UK government at that time.

Time for reflection by OSPAR

Shell aims to submit a detailed commission plan to the British energy ministry by the end of the year. After a consultation period, the minister will forward the plan to the OSPAR commission. OSPAR, which has 15 member countries plus the EU, will have a number of questions to consider.

OSPAR (decision 98/3) have a clear policy of requiring operators to restore the seabed to its original debris-free state once oil production has ceased. Shell point to concessions granted by OSPAR to other operators of GBS platforms to leave the GBSs in place with appropriate warnings to shipping and fishing interests.

Oil companies have resources and influence that more than match the might of most sovereign states. In the current low oil price environment cost-cutting by all means appears to drive decision-making by oil companies and is actively encouraged by the UK regulator, the Oil and Gas Authority. Is it acceptable for exceptions to OSPAR policy as stated above to be determined on a case-by-case basis?

Once one concession is granted that becomes the precedent for similar concessions and in the blink of an eye OSPAR policy has been shredded and the exception to a policy can easily become the norm. OSPAR needs urgently to look at the possible implications of granting exceptions for GBSs to their preferred policy. Just how littered do we want our oceans to become? Will developing nations shrug and say well if that’s good enough for Scotland yes topple whatever you like onto our seabeds? Is there an overarching moral imperative for multinational companies and powerful countries such as the UK to see the wider picture and take actions that protect less powerful countries?

Arguably, agreement with the Shell proposals by the UK government should not be granted without the Scottish government, or better, the Scottish people being happy with them. The plum economic contracts for topside recycling should be an issue Holyrood has an influence over, so that ways and means are found for decommissioning to be done as close as possible to where the oil platforms are situated. Given the prospect of Scotland’s fishing and shipping lanes – who knows where Trident submarines meander around – being threatened by the presence of ghostly concrete towers for 1000 years, the future decommissioning of topsides being undertaken outside Scotland smacks of rubbing salt into the wound.

Would anyone doubt that if a referendum were held in Scotland on the issue, then Scots would be unequivocal in requiring oil companies to restore the seabed to its original state? Does Theresa May and the Department of Energy and Industrial Strategy share that point of view or will they argue it’s only Scotland being littered so what’s the problem? The next independence referendum may be closer than Westminster cares to imagine!

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