Germany objects to Shell’s UK-approved North Sea decommissioning plans

14 May 2019

According to Energy Voice, the German government has made a formal objection to Shell’s plans to decommission the Brent field in the North Sea. Germany’s environment ministry commissioned a report on the plans from an Aberdeen-based consultancy which has highlighted major issues with Shell’s assessments.

Brent A,B,C & D platforms - Image: Shell

In February 2017, Shell lodged plans with the Department for Business, Energy and Industrial Strategy (BEIS) to undertake the decommissioning of offshore petroleum installations in the Brent Field, located in the North Sea, north east of the Shetland Islands.

This included the removal of the topsides of the four Brent platforms, each weighing between 16,000 and 31,000 tonnes. Three of the Brent installations (Bravo, Charlie and Delta) have concrete legs, known as ‘Gravity Based Structures’ (GBSs), which vary between 290,000 and 340,000 tonnes.

In its detailed decommissioning plan, Shell recommended that the three GBSs remain in place, since they could only be refloated with difficulty. This was seen as the best option based on technical, safety and cost grounds. Shell proposed to remove the top of the installations and seal the GBSs with concrete caps, and fit navigation aids.

This was the approach adopted for the decommissioning of Total’s massive MCP-01 concrete platform in the late 2000s. The 386,000 tonne substructure of MCP-01, situated east of Orkney, was left in place while the topsides and other removable equipment were taken ashore to be recycled.

On this project, risk assessments showed that leaving the legs in place during decommissioning carried a worker fatality probability of 1%, against 47% for the alternative plan to refloat the concrete substructure and bring it ashore for disposal. The predicted number of major injuries was respectively estimated at 0.3 and 30.

The UK and Germany are both part of OSPAR, an international agreement between several European countries to protect the marine environment.

The report by Aberdeen consultancy Scientia et Sagacitas concludes that Shell’s case for approval is “weak” due to breaches in OSPAR regulations, and what it describes as a “biased” decision-making process.

Germany has now issued a formal objection to the OSPAR Secretariat following the report’s publication. Issues identified included the potential for the concrete legs to collapse over time, the release of oil waste and the hazard to maritime traffic.

The report said Shell’s assessment process was not fit for purpose and largely based on “flawed” government guidelines which create a bias towards any option that has minimal decommissioning costs.

According to Greenpeace, the German government warned in November 2018 that Shell’s plans failed to properly account for long term risks to the environment and ship traffic.

The environmental lobby group said that as a result, the UK government has written to all the OSPAR nations asking them to comment on its decision to endorse Shell’s plans.

The Anglo-Dutch energy major said its plans are both safe and environmentally sound. It argues the safety risks associated with trying to remove the concrete structures for the Brent Bravo, Charlie and Delta platforms outweigh the “minimal environmental benefit”.

A Shell spokesperson confirmed that the company had meetings with the German government last year, in which the company went through its comparative assessment process and explained how it arrived at its recommendations.

Shell said it was confident about the proposals, which were only submitted after producing more than 300 studies on its decommissioning plans and establishing an independent group of scientists to review the findings.

Energy Voice, part of the Aberdeen Press and Journal group, interviewed an offshore legal expert on the topic. Professor John Paterson of Aberdeen University’s law school said other countries could require “intense discussions” through OSPAR, but could not veto what the UK ultimately decides to do.