Decommissioning of Subsea Facilities in Brazil

Brazil is entering the age of decommissioning, with aging offshore fields that have been in operation for more than 25 years. Brazil has migrated from an operator’s monopolistic environment (with the state owned oil company, Petrobras) to a new reality in which many companies, national and international operate in Brazilian waters. As part of this new reality, Brazil has established government organizations whose aim is to coordinate the exploitation of Brazil’s natural resources with the intent of optimizing activities while protecting the environment in an ever increasingly complex eco-system management. Traditionally, offshore projects follow basic phases such as conceptual, front end engineering and design (FEED), detail design, construction and commissioning. Cost allocation and schedules for these phases are all associated with production estimates and return on investment estimates. In many instances, internationally, planning for decommissioning has been deferred to an unforeseen future. Finally that far off horizon has become a reality, and domestic and foreign operators in Brazil are going through a new decommissioning awareness phase. It is the author’s opinion that operators wish to comply with a well-defined frame of Brazilian and international regulations. In general, this paper aims at examining the existing regulatory environment and make recommendations on a path forward for:Clear-cut requirements so that the permitting process flows with a minimized review cycle;A clear set of rules, defining what abandonment options exist (e.g. complete removal vs. partial removal, on-site abandonment rules for topsides and subsea infrastructure);A clear set of rules defining fines and sanctions for environmental violations The objectives of this paper are to 1) Gather basic information on the current status of the Brazilian Rules and Regulations, 2) Help non-government entities work together to accomplish the goals set forth by Brazilian lawmakers and officials, and 3) Develop a roadmap for convergence of the environmental agency and project stakeholders. Laws, rules and regulations, and international treaties of which Brazil is signatory are part of this environment.