Safety zones and decommissioning in situ/artificial reefing in the Australian regulatory context: a net environmental benefit analysis-based comparative assessment (NEBA-CA) intergenerational value proposition
Nicholas A. Nelson A * , Joseph P. Nicolette A , Alex N. Testoff A and Alison Duguid BA Montrose Environmental Solutions, 400 Northridge Road, Suite 400, Sandy Springs, GA 30350, USA.
B GHD Group, 999 Hay Street, Perth, WA 6000, Australia.
The APPEA Journal 62 S327-S333 https://doi.org/10.1071/AJ21112
Accepted: 18 March 2022 Published: 13 May 2022
© 2022 The Author(s) (or their employer(s)). Published by CSIRO Publishing on behalf of APPEA.
Abstract
Australia’s oil and gas sector expects approximately 56 billion (AUD) to be expended for decommissioning costs over the next 50 years. The view of the National Offshore Petroleum Safety and Environmental Management Authority is that the designated decommissioning approach must provide equal or better environmental outcomes when compared to full removal of the infrastructure (considered the ‘best case’ expectation under current legislation) and meets as low as reasonably practicable (ALARP) levels of risk. Decommissioning alternatives are generally evaluated through a comparative multicriteria assessment approach, for example, a net environmental benefit analysis-based comparative assessment (NEBA-CA). Decommissioning options cover a range of possibilities, from full removal to leaving subsea structure in situ (in part or in whole). NEBA-CAs we have conducted suggest that some subsea structures are projected to generate significant ecological and social value over multiple generations to come. Thus, in these cases, management in situ can provide greater benefits to the public when compared to full removal. During operation, oil and gas assets typically incorporate a safety zone. If subsea structure is selected to be managed in situ, a question that arises is, should the safety zone be maintained or removed? Our experience indicates that if the safety zone is removed after decommissioning an asset that is left in situ, there may likely be a greater adverse impact on ecological and social values, depending upon the asset location. This abstract showcases the value of the use of safety zones to maximise environmental value while managing risk.
Keywords: artificial reef, exclusion zone, National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA), net environmental benefit analysis-based comparative assessment (NEBA-CA), oil and gas (O&G), Rigs-to-Reef, safety zone.
Nicholas (Nick) Nelson is a Scientist at Montrose Environmental Group. He earned a Bachelor of Arts degree in International Management with Minors in Applied Mathematics and Environmental Science from Franklin University Switzerland in 2018 and will graduate with a Master’s of Science degree in Biodiversity, Wildlife, and Ecosystem Health from the University of Edinburgh in 2023. He has conducted and co-authored multiple net environmental benefit analysis-based comparative assessments (NEBA-CAs) as applied to offshore oil and gas infrastructure decommissioning. Mr Nelson’s primary experience is in ecological service valuation using the Habitat Equivalency Analysis, Resource Equivalency Analysis, and commercial and personnel risk assessment. Mr Nelson has led and supported decommissioning projects in the North Sea, Gulf of Mexico, and Western Australia, and has experience conducting assessments in the regulatory climates associated with each. |
Joseph Nicolette is the Vice President of Planning and Ecosystem Consulting at Montrose Environmental Solutions. He holds a Bachelor of Science degree in Environmental Resources Management from Pennsylvania State University, and a Master of Science degree in Fisheries from the University of Minnesota. Mr Nicolette has over 30 years of experience in environmental consulting across 15 countries, with a career focus on site risk management, remediation, natural resource damage assessment (NRDA), aquatic ecology, and ecosystem service valuation. Mr Nicolette co-authored the first formalised framework for net environmental benefit analysis (NEBA), focusing on site remediation and restoration, recognised by the United States Environmental Protection Agency (USEPA), the USEPA Science Advisory Board, and the National Oceanic and Atmospheric Administration. Mr Nicolette pioneered the habitat equivalency analysis (HEA) methodology used in ecological service valuation before HEA became codified into NRDA regulations. He also provides strategic advice grounded in quantitative sciences on offshore decommissioning projects to balance and manage site risks and benefits (social, environmental, economic, technical, and safety) associated with competing alternatives. |
Alex Testoff is a registered professional Environmental Engineer and Senior Consultant at Montrose Environmental Solutions. He holds two degrees in environmental engineering: a Bachelor’s of Science degree from Ohio State University and a Master’s of Science degree from John’s Hopkins University. Mr Testoff has 8 years of experience in contaminated site assessment and remediation consulting in the United States, primarily practicing in the CERCLA (Superfund) and RCRA regulatory areas, and in application of net environmental benefit analysis-based comparative assessment (NEBA-CA) and habitat equivalency analysis (HEA) in decision-making associated with competing decommissioning strategies for international offshore oil/gas developments. Mr Testoff has unique capabilities in quantitative ecological risk characterisation and terrestrial ecological studies, and has developed an approach to quantitatively assess the potential for ecological impairment due to microplastics exposure resulting from long-term degradation of plastic-containing structures in offshore oil/gas developments. |
Alison Duguid is GHD Pty Ltd’s offshore decommissioning comparative assessment project lead with experience in delivery of multiple studies assessing the net impact and benefit of different decommissioning options. Her role included leveraging of previous experience in safety risk and climate risk assessment to provide a fresh perspective on alternative decommissioning activities. Using her Masters in Professional Engineering (majoring in Chemical Engineering), Alison has also been involved in numerous projects from hydrogen energy feasibility studies to end-of-life material recovery and circular economy-based principles. |
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