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.
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
“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.
Shell’s decommissioning plans also involve leaving an unnamed number of pipelines and steel jacket footings in place plus other debris including drill cuttings
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), Â then they have the potential to affect the next 40 generations of Scots whose offshore environment can be polluted for 1000 years!
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?
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?
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?
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!
Editor’s Note
Professor Alex Russell is Chair of the Oil Industry Finance Association. Peter Strachan (@ProfStrachan) is Professor of Energy Policy, Robert Gordon University.
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Rob Peters says
After careful reading, the obvious flaws and contradictions of the authors lead to the conclusion that this piece is really about Scottish nationalism, dressed-up as concern about the marine environment.
For example, the authors write “…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”, but then criticise Shell for not wanting to move parts of the Brent rigs at all, thus reducing exactly the sorts of risks that the authors claim to fear.
As for the role of the Scottish people in deciding the fate of these platforms, I’m a UK resident and enjoy holidays in Scotland but I’ve had no say in the erection of wind turbines that you could argue despoil the natural landscape – based on the logic of the authors, I and my fellow English and Welshmen should be consulted on Scotland’s renewable energy infrastructure, especially considering that it is supported with subsidies that I and other non-Scots help to fund. Will us non-Scottish residents be consulted by the wind farm operators when they start to decommission their assets and who are bound to want to leave the 300 tonne concrete footings for each turbine in the ground in order to avoid the costs of digging them up and disposing of them?
No, of course not.
If you believe in Scottish independence, fine, but say so – but don’t hijack the energy and environmental debate to further your cause with such fatuous arguments.
Hugh Sharman says
Right on, Rob Peters!
The authors also seem oblivious to the fact that each platform, over the years, has become a major marine haven. Or if they do know it, which they should, are unwilling to balance their highly charged and emotional rhetoric with any of the many arguments in favour not repeating the mistakes of Brent Spar.
Anne-Mette Jørgensen says
Though I am very pleased to see that someone is finally bringing the topic of offshore decommissioning to the public agenda again, I think there are a number of points that need correction in this story.
First of all, OSPAR Decision 98/3 itself grants very specific and particular room for derogations for concrete GBS and the footings of ultra-large steel jackets (jackets weighing more than 10,000 tons in air) and this (Brent) request for derogation is certainly not the first one. Since 1998, derogations have been granted for several large structures, incl. Frigg, Ekofisk, North-West Hutton, Miller and Murchison. To my knowledge, many oil and gas operators in fact base their decommissioning cost estimates on the assumption that they will be granted derogation for all structures that meet these criteria. Whether that is wise, is a different question, as the criteria for derogation are reviewed every 5 years and hence may be adapted over time.
Secondly, I’m not sure the Scots should – or would – in fact be very enthusiast about the idea of having to handle these huge amounts of polluted sludge and concrete on shore. What would you actually have to do with these materials? Presumably, they are neither suitable for recycling nor for incineration, so they would eventually have to be landfilled. That means that the environmental legacy is simply being moved from far offshore to somewhere on shore – a process that is associated with a significant risk that pollutants may leak from the storage tanks underway, possibly somewhere near the coast, where they may have a much larger environmental impact than further ashore. For these reasons, the Norwegian government concluded some years ago that it is generally speaking better for the environment to leave concrete GBS offshore than to take them onshore.
Thirdly, there is a significant amount of scientific evidence suggesting that offshore structures over the years have become home to a variety of valuable species that are under severe threat from especially bottom-trawling and other intensive fisheries elsewhere in the North Sea. In the Gulf of Mexico, some 400 clean, disused oil- and gas rigs have been succesfully converted into reefs and a solid legal fraework been developed for how to do this in a responsible manner. In theory, this could work in the North Sea, too.
The underlying discussion, indeed, is about moral responsibility and about who benefits from the cost-savings associated with decommissioning programmes, where parts of a structure is left offshore. I wonder what would have happened if Shell had proposed to invest a major part of their cost-savings in restoration of natural reefs, investments in renewable energy off the Scottish coast or in innovations that would help the Scottish fishing fleet make the transition to sustainable and profitable fishing practises?
Stanley Brown says
This is such an angry, confused and imbalanced article, I am amazed it was written by such eminent authors. More than a little nationalist outrage reverberating in the background for sure. Maybe use some of the extra Scotland gets under the Barnett formula to remove the legs?
Seriously, Shell has made a huge contribution to our public services and welfare state for years, as well as employing thousands and providing us with essential oil from the ocean depths. It should not be required to pursue removals that are unnecessary or unsafe, with costs that could run into billions. It would also be particularly bad for future investment in the North Sea – which the Scottish government holds as a top priority. In any case, evidence is increasingly suggesting that sub-sea structures are good for marine life, rather than bad.
Surf says
“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!”
If the author did he research he would have found that most of the radiation is from radon gas. Radon gas is created when naturally occurring uranium decays. The radon comes out of the ground with the oil and gas. in a few seconds to day that decays to another atom which again decays quickly to another atom. This process continues for at most 24 years until a stable non radioactive atom of lead is created. In short in 200 years about 99% of this week radiation is permanently gone.
As to any oil and organic materials in the cells it is now exposed to surface bacteria. Although it is a slow process the oil will slowly be consumed by the bacteria. When it was underground it was protected from bacteria. Now it isn’t. When the cells permanently disintegrate in a 1000 years there will not be much if anything left to create an environmental hazard.