Decoding decommissioning requirements when using new technology – Queensland’s petroleum wells code of practice

Abstract

Resources Safety and Health Queensland (RSHQ) is the independent regulator for safety and health in Queensland’s resources sector. The Petroleum and Gas Inspectorate administers safety and health regulation for the petroleum and gas industry. RSHQ uses a risk-based and data-driven approach to pursue its vision of zero serious harm for resource sector workers. The Code of practice for the construction and abandonment of petroleum wells and associated bores in Queensland (the Code) was introduced in 2011 to manage the expansion of well construction activities associated with the emerging coal seam gas (CSG) industry. The statutory application of the Code under the former Petroleum and Gas (Production and Safety) Regulation 2004 commenced 1 January 2012. Since implementation, the Code has been regularly revised with a single code adopted in 2018 for both CSG and petroleum wells. The Code is applied under sections 35 and 36 of the Petroleum and Gas (Safety) Regulation 2018. The Code directly addresses the highest level of controls in risk management of the identified high-risk areas for the construction, maintenance and decommissioning of petroleum and water bores. The Code permits alternative means of compliance (AMoC) against the stated means of compliance. Since commencement of the Code, approximately 87% of AMoC applications received by the Chief Inspector are related to well decommissioning activities. This paper evaluates the AMoC process under the Code, and considers its application and the regulatory challenges faced by Queensland operators during decommissioning of wells. The paper’s objective is to highlight the application of the AMoC process and identify potential areas for improvement to facilitate the adoption of new decommissioning technologies.