Disclaimer - please note, the below opinon piece was submitted by our member, Lucion Marine and does not reflect the view of Decom North Sea.
IHM key to managing hazardous materials danger
Concerns voiced by a trade union over the state of the North Sea decommissioning industry are well-founded, says John Chillingworth, senior marine principal at Lucion Marine, who believes the UK can meet the specialist requirements of owners looking for cost effective and safe disposal of oil rigs.
Earlier this year, the RMT highlighted that work destined for Asia to scrap three semi-submersible drilling rigs, could have been undertaken safely in Britain, where there is ample capacity, skills and experience to bring in these often complex and potentially hazardous decommissioning projects. In addition, the owners would save £4 million each rig in towing costs to Asia.
Towing vessels more than 8,000 miles from the North Sea oil and gas fields to Asia also presents considerable risk. Tow lines can snap in heavy seas, leading to rigs, often unmanned and weighing more than 15,000-tonnes, drifting uncontrollably to shore with all the associated costs, dangers and engineering problems involved in attempting to re-float the structure. Not to mention the environmental impact on wildlife and coast lines - a situation which occurred in 2017 in Scotland with a rig under tow to Malta.
Recycling in Asia is a real concern. NGO reports indicate that Asian workers are regularly killed and injured in highly dangerous and poorly protected conditions in these places. Some of the yards in Alang have made major improvements in safety and environmental conditions but even now the NGO continues to highlight concerns.
While figures for the scrappage of oil rigs appear thin on the ground, as an indicator, more than 800 large ships are broken up each year, the majority on the shores of Asia. Vessel owners can potentially earn millions of dollars more per ship when selling to Asian yards via cash buyers, instead of opting for recycling yards with higher standards. This is driven primarily by the price of scrap steel.
Chittagong is now the world’s largest shipbreaking centre, recycling 230 ships in 2016 and generating 10m tonnes of steel – up to 60% of all the steel used in the country. Most of the scrappage work is carried out by gangs, working for several months to dismantle a large vessel, wielding only sledgehammers and metal cutters.
A more structured process in the UK for drilling platforms is being called for by the RMT in a move that could see the government commit to greater regulation of the decommissioning sector. This would contribute to protecting the interests of UK workers and the economy, while also reducing the number of vessels heading to Asia and, in the words of the union’s national secretary Steve Todd, stopping the “unethical exploitation of poor coastal communities in India, Pakistan and Bangladesh, when disposing of retired vessels”.
The North Sea behemoths recently moored in the Cromarty Firth could quite easily have been dismantled and recycled at local facilities in Scotland. Indeed, UK companies have a demonstrable track record working within the ship decommissioning sector, and can bring this expertise and experience to bear for rig owners and operators who work responsibly and to the highest standards.
And this includes the identification, control and (if necessary) safe removal of hazardous materials. The specialist skills and expertise companies such as Lucion possess are significant, enabling operators to cost effectively manage all kinds of unknown materials within their rigs, and ensure that work is completed to a high UK standard.
Inventory of Hazardous Materials
The types of hazardous materials found on rigs varies and may include asbestos, PCBs (polychlorinated biphenyl), lead and possibly naturally occurring radioactive materials (NORM) from the oil production process itself. These are usually contained in sludge in pipelines and must be blasted with frozen CO2 pellets to remove and collect the contaminated waste for safe disposal (as far as we understand the yards in the Far East and India are not equipped for this work).
Prior to sending the structure for dismantling, it’s therefore important that an Inventory of Hazardous Materials (IHM) should be carried out by a certified expert to allow the recycling yard to plan the safe dismantling and associated costs. Depending on what’s found along with quantity and location, will determine the cost of and most appropriate course of action for safe removal and disposal.
An accredited surveying company will carry out an inspection to verify the amount of hazardous materials onboard a rig. it’s important to engage the services of an ISO17020 accredited company, which has the experience and resources to undertake the work comprehensively. Then, if asbestos and other hazardous materials are discovered, a management plan can be developed by the recycler as with other hazardous materials.
The key word is proactive. Adopting such an approach for a rig at the beginning of its operational life can prevent potential litigation for claimed exposure to hazardous materials, protecting those involved in dismantling and scrapping the rig.
The IMO would be justified in modifying the SOLAS (Safety of Life at Sea) requirement for asbestos in ships to cover rigs, and institute a more manageable procedure that would contribute to securing greater safety. This modification would also spur owners into actioning the IHM inspections sooner rather than later.
Lucion, which has extensive experience undertaking Inventory of Hazardous Materials (IHM) surveys on rigs and ships, is one of only two organisations approved by the EU Commission to verify the capabilities and standards of recycling yards, ensuring that they come up to standard under the EU approved register of recycling yards.
The company has extensive capabilities in producing recycling plans in accordance with the EU regulations and can advise on the management of hazardous materials to both working and end-of-life rigs. The firm’s team of surveyors are experienced and accredited by both Lloyds Register for the completion of Inventory of Hazardous Materials documents and UKAS accredited for the inspection and testing of asbestos.
Case study – SBM Offshore
Lucion’s expertise and services has helped to ensure that SBM Offshore meets its requirements around the safe management and disposal of hazardous materials.
SBM Offshore is a leader in floating production systems, whose operations span the full product lifecycle for Floating/Production, Storage and Offloading (FPSO) vessels. Specifically, Lucion undertook work for SBM on the 278,000 DWT FPSO ‘Marlim Sul’, which was operating offshore Brazil before being decommissioned and sent for lay-up in Malaysia.
A team of BOSIET (Basic Offshore Safety Induction and Emergency Training) certified hazardous materials inspectors from Lucion spent several days onboard to undertake visual inspections and survey key sections of the vessel. They also completed a sampling exercise while the FPSO wound down operational activities.
The survey has been a key component in the preparation of an Inventory of Hazardous Materials (IHM), which is critical in helping to identify hazardous materials left over from the production processes undertaken by offshore vessels.
This work, which also helped to determine removal and disposal charges, allowed recycling yards to plan the safe dismantling and associated costs. It also ensured that IHM Parts I, II and III were comprehensively compiled for reference and maintenance purposes, contributing significantly towards full regulatory compliance.