Yesterday, a public hearing took place aiming at discussing a proposal to regulate decommissioning of oil production installations, with the participation of the Brazilian Institute for Environment and Natural Renewable Resources (IBAMA), at the Federal Oil, Gas and Biofuels Agency central office (ANP) and the Brazilian Navy.
The proposal brought by IBAMA, ANP and the Navy, together with other authorities and major stakeholders aims at promoting the useful life of oil and gas fields and the recovery of reservoirs, as well as defining technical environmental requirements for decision making and implementation of decommissioning activities and environmental issues linked to the measure.
During the hearing – which happened after the receipt of contributions and comments from companies, authorities and consultants, including the firm – ANP, IBAMA and the Navy presented the results of the work which generated the regulation proposal and the revision of Resolutions No. 27/2006, 28/2006 and 25/2014, besides receiving additional contributions from other parties that participated in the hearing.
From an environmental point of view, it is worth mentioning that IBAMA presented 57 contributions, which were approved by ANP, besides having reiterated on the importance of the environmental guidelines on decommissioning as established by IBAMA’s Technical Notice No. 31/2019 – COPROD/CGMAC/DILIC.
Among the environmental topics which caused great discussions:
(i) studies to justify decommissioning;
(ii) studies on risk assessment;
(iii) environmental recovery plan and post-decommissioning monitoring;
(iv) management and final disposal of wastes generated from decommissioning activities, besides the participation of state authorities in these activities.
IBAMA’s Technical Notice No. 31/2019 – COPROD/CGMAC/DILIC shows the position IBAMA has on waste, radioactive ones included, and bioinvasor exotic species (including coral-sol), besides the conclusions listed below:
1) The applicable standard for all submarine system components considers total removal, with exceptions being expected, when partial or total remain at seabed is allowed;
2) Total or partial remain must be expressly authorized by IBAMA, in a way such remain does not extinguish the operator liability for damages, after the end of the activities;
3) Obligation of the environment recovery project and respective post-decommissioning environmental monitoring; 4) IBAMA’s prospect for the inclusion of the proposal on environmental proper disposal of generated waste onto the plan.