Decommissioning Plan - Kinsale Head Petroleum Lease (OPL 1) Consent Application No.3 - Kinsale Area Decommissioning Project
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Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) Consent Application No.3 253993-00-REP-28 | 30 September 2021
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Contents Page Glossary of Terms i 1 Introduction 4 1.1 Introduction 4 1.2 Background 4 1.3 Consent Applications 6 1.4 OPL-1 11 1.5 Overview of Facilities 11 1.6 Summary of Statutory Background 13 1.7 Methodology 13 1.8 Overview of Decommissioning Plan 14 1.9 Objective of Decommissioning Project 15 2 Facilities Description 16 2.1 History of Operations 16 2.2 Inventory of Facilities 17 3 Cessation of Production 27 3.1 Summary 27 3.2 Technical and Economic Evaluations 27 3.3 Other Uses Considered 27 4 Decommissioning Options 28 4.1 Pipelines and Umbilicals 28 5 Decommissioning Project Management 29 5.1 Project Management Approach 29 5.2 Organisation 30 5.3 Resources 30 5.4 Costs 31 5.5 Reporting 31 6 Decommissioning Activities and Schedule 32 6.1 Consent Application No. 3 Decommissioning Activities 32 6.2 Decommissioning Schedule 33 6.3 Materials and Waste Management 35 6.4 Health and Safety 35 7 Post-Decommissioning Phase 38 7.1 Post Decommissioning Status 38 7.2 Post Decommissioning Survey 38 7.3 Decommissioning Close-out Reports 38 253993-00-REP-28 | Issue 1 | 30 September 2021 | Arup
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 7.4 Post Decommissioning Monitoring 38 8 Environmental Assessment 40 8.1 Environmental Baseline and Sensitivity 40 8.2 Environmental Assessment Methodology and Identification of Potentially Significant Effects 40 8.3 Management of Residual Effects and Conclusions 44 8.4 Conclusions of the Appropriate Assessment Screening 46 9 Stakeholder Engagement 47 9.1 Introduction 47 9.2 Stakeholder Engagement Activities 47 9.3 Further Stakeholder Engagement 48 Tables Table 1: Lease details........................................................................................................................... 11 Table 2: Key National, European and International legislation relevant to the KADP ....................... 13 Table 3: Summary of proposed decommissioning options for the OPL-1 Facilities (Consent Application No.3) ................................................................................................................................ 14 Table 4: Summary of Development History for the Kinsale Area Fields............................................ 16 Table 5: Pipelines to be decommissioned ............................................................................................ 22 Table 6: Umbilicals to be decommissioned ......................................................................................... 25 Table 7 Estimated rock placement requirements for in situ decommissioning options ...................... 32 Table 8 Estimated vessel timings (days) for pipeline and umbilical decommissioning ...................... 33 Table 9: Summary of potential significant environmental effects for each Consent Application ....... 41 Table 10: Summary of commitments and actions................................................................................ 44 Figures Figure 1: Location of the Kinsale Area fields and facilities ............................................................... 10 Figure 2 Kinsale Area Facilities .......................................................................................................... 12 Figure 3: Overview of the Kinsale Head Facilities .............................................................................. 17 Figure 4 Ballycotton Infrastructure ...................................................................................................... 18 Figure 5: Overview of Southwest Kinsale and Greensand .................................................................. 20 Figure 6: PETRONAS Project Management System for decommissioning projects .......................... 29 Figure 7: Project Team – Execution Phase .......................................................................................... 30 Figure 8: Indicative Project Schedule .................................................................................................. 34 Appendices Further Information Appendix A1: Relevant International Conventions and European Legislation Appendix A2: Layout Drawings 253993-00-REP-28 | Issue 1 | 30 September 2021 | Arup
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Glossary of Terms Term Explanation AA Appropriate Assessment ALARP As Low As Reasonably Practicable AHV Anchor Handling Vessel Buoyancy tank An enclosed air-filled section of a boat or ship designed to keep it afloat and prevent it from sinking Bunkering Supply of fuel for use by ships in a seaport CA Comparative Assessment Cantilever Structural element anchored at only one end to a support from which it is protruding CCS Carbon Capture and Storage Concrete A series of concrete blocks usually connected by polypropylene ropes mattress resembling a rectangular mattress, used for the weighting and/or protection of seabed structures including pipelines CoP Cessation of Production: the stage at which, after all economic development opportunities have been pursued, hydrocarbon production ceases. CRU Commission for Regulation of Utilities CSV Construction Support Vessel DAA Dublin Airport Authority DCCAE Department of Communications, Climate Action and Environment DCENR Department of Communications, Energy and Natural Resources DECC Department of the Environment, Climate and Communications DECC(UK) Department of Energy & Climate Change (UK) Decommissioning Planned shut-down or removal of a building, equipment, plant, offshore installation etc., from operation or usage offshore. Diesel A low viscosity distillate fuel DSV Diving Support Vessel DTTAS Department of Transport, Tourism and Sport ER Environmental Report EIA Environmental Impact Assessment EPA Environmental Protection Agency FEAS Marine Institute’s Fisheries Ecosystems Advisory Services Flowline Pipeline carrying unprocessed oil/gas within the oil or gas field area Freespan A free span on a pipeline is where the seabed sediments have been eroded, or scoured away leaving a void under the pipeline so that the pipeline is no longer supported on the seabed Grout Particularly fluid form of concrete used to fill gaps, generally a mixture of water, cement, and sand GSRO Geoscience Regulatory Office HES Health, Environment and Safety 253993-00-REP-28 | Issue 1 | 30 September 2021 Page i
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Term Explanation HFCs Hydrofluorocarbons HWM High Water Mark HLV Heavy-Lift Vessel IALA International Association of Marine Aids to Navigation and Lighthouse Authorities IMO International Maritime Organisation In situ In the original place. Interconnector Structure which enables energy to flow between networks, refers to international connections between electricity and natural gas networks IOSEA Irish Offshore Strategic Environmental Assessment IWDG Irish Whale and Dolphin Group Jacket The structure comprising the “legs” of the offshore platform connected together by horizontal and diagonal trusses and usually made of welded tubular steel. The jacket is typically secured to the seabed by piles KA Kinsale Alpha platform KADP Kinsale Area Decommissioning Project KB Kinsale Bravo platform KPIs Key Performance Indicators km Kilometre: 1,000m, equivalent to 0.54 nautical miles LPP Layer Polypropylene Manifold A pipe or chamber branching into several openings. MARPOL The International Convention for the Prevention of Pollution from Ships MRCC Marine Rescue Co-ordination Centres Natura 2000 sites Natura 2000 is a network of nature protection areas in the territory of the European Union. It is made up of Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) designated respectively under the Habitats Directive and Birds Directive. NIS Natura Impact Statement nm Nautical Mile (1852m = 1 minute of latitude = 1/60 degree of latitude) NPWS National Parks and Wildlife Service NUI Normally Unmanned Installation: an installation with minimal facilities which is not permanently crewed and is controlled from a remote location (e.g. other platform or shore) OGUK Oil & Gas UK OSPAR Oslo and Paris Convention P&A Plug and Abandon (wells) PAD Petroleum Affairs Division of the Department of Communications, Climate Action and Environment PEP Project Execution Plan PETRONAS Petroliam Nasional Berhad PLEM Pipeline End Manifold 253993-00-REP-28 | Issue 1 | 30 September 2021 Page ii
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Term Explanation PSV Platform Supply Vessel PUDAC Permit to Use or Discharge Added Chemicals ROV Remotely Operated Vehicle: a small, unmanned submersible used for inspection and the carrying out of some activities such as valve manipulation SAC Special Area of Conservation: established under the Habitats Directive Seafastening Action of fastening/securing cargoes on ship with the aim of preventing them from movement while the ship is in transit Semi-submersible A floating mobile drilling rig supported on a number of pontoons, and typically rig anchored to the seabed while on station SFPA Sea Fisheries Protection Authority Shears Cutting instrument in which two blades move past each other SPA Special Protection Area: established under the Birds Directive Subsea manifold Large metal piece of equipment made up of pipes and valves, designed to transfer oil or gas SWK South West Kinsale TEG Triethylene Glycol Tie-backs Link between a satellite field and an existing production facility Topsides The collective name for the many drilling, processing, accommodation and other modules which when connected together make up the upper section of the platform which rests on the jacket Umbilical Cable and/or hose which supplies required electrical power and chemicals for subsea well control WDC Western Drill Centre Wet Gas Any gas with a small amount of liquid present 253993-00-REP-28 | Issue 1 | 30 September 2021 Page iii
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1 Introduction 1.1 Introduction PSE Kinsale Energy Limited (Kinsale Energy) is progressing with the decommissioning1 of the Kinsale Area gas fields and facilities (incorporating the Kinsale Head gas fields and facilities and the Seven Heads gas field and facilities), which have come to the end of their productive life. Gas production from the wells ceased on 5 July 2020. The decommissioning of the entirety of the Kinsale Area gasfields and facilities is collectively referred to as the Kinsale Area Decommissioning Project (KADP). The entire KADP plan consists of: • Facilities preparation: disconnect and degas process plant and pipelines (all pipelines displaced with seawater). • Wells: plug and abandon all platform and subsea wells and removal of any surface component of these wells, including wellhead structures and platform conductors. • Platform topsides: complete removal in accordance with OSPAR Decision 98/3. • Subsea structures: (e.g. manifolds, wellhead protection structures): full removal in accordance with OSPAR Decision 98/3, including the removal of connecting spool pieces, umbilical jumpers and associated protection materials. • Platform jackets: complete removal in accordance with OSPAR Decision 98/3. • Offshore pipelines and umbilicals: rock cover of freespans and pipeline ends. • Export pipeline (offshore and onshore section): fill onshore section with grout and rock cover of freespans in offshore section. • Decommissioning the Inch Onshore Terminal (full removal and reinstatement to agricultural use, as per the terms of the site planning permission, Cork County Council planning reference 2929/76). 1.2 Background Pursuant to section 13 of the Petroleum and Other Minerals Development Act 1960 as amended (1960 Act), a petroleum lease was granted in respect of the Kinsale Head gas fields and facilities in May 1970 (Offshore Petroleum Lease No. 1 (“OPL-1”)). The Kinsale Head Plan of Development was submitted and agreed with the then Minister for Communications, Climate Action & Environment (as he then was, now the Minister for the Environment, Climate and Communications) (the “Minister”). This was in respect of the Kinsale Head gas fields and facilities pursuant to the terms of the OPL-1. A petroleum lease was granted in respect of the Seven Heads gas field and facilities in November 2002 pursuant to Section 13 of the 1960 Act (“Seven Heads Petroleum Lease”). The Seven Heads Field Plan of Development (“Seven Heads Plan of Development”) was submitted and agreed with the then Minister in respect of the Seven Heads gas field and facilities in accordance with the terms of the Seven Heads Petroleum Lease. Kinsale Energy submitted, and is now submitting further plans for decommissioning to the Minister for approval pursuant to Section 13 of the 1960 Act), as addenda to the existing plans of development relevant to the Kinsale Area and Seven Heads Petroleum Leases. 1 Meaning the removal, part removal or leaving in place of any installation or facility. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 4
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1.2.1 Previous Applications To reflect project scheduling requirements and to facilitate studies on the potential for any re-use options for the Kinsale Area facilities, a two stage consent application process for the Decommissioning Plans was originally proposed by Kinsale Energy. Decommissioning Plans covering the first stage (Consent Application no. 1) were submitted on 28th June 2018 covering the following works: • Facilities preparation: disconnect and degas process plant and pipelines (all pipelines displaced with seawater). • Wells: plug and abandon all platform and subsea wells and removal of any surface component of these wells, including wellhead structures and platform conductors. • Platform topsides: complete removal in accordance with OSPAR Decision 98/3. • Subsea structures: (e.g. manifolds, wellhead protection structures): full removal in accordance with OSPAR Decision 98/3, including the removal of connecting spool pieces, umbilical jumpers and associated protection materials. Consent Application no. 1 was approved on 26 April 2019. For Kinsale Head only, a subsequent application (Consent Application no. 2) was submitted on 8th August 2019 to cover the removal of the Kinsale Alpha and Bravo jackets. Consent Application no. 2 was approved on 26 February 2020. At the time of the previous consent applications, there were ongoing studies by others which could potentially have resulted in future re-use of one or more of the subsea pipelines. No future re-use potential has been identified within the timeframe of the KADP. Therefore, this application (“Kinsale Head Consent Application no. 3” and “Seven Heads Application no. 2”) is being made in relation to the decommissioning of the pipelines and associated umbilicals. In accordance with section 13A of the 1960 Act, an Environmental Impact Assessment Report (EIAR) was prepared to accompany Consent Application no. 1. The EIAR was updated, by way of Addendum, for Consent Application no. 2. The EIAR has again been updated, by way of Addendum, for this application. Any reference to EIAR shall mean a reference to the entire of the EIAR and these two Addendums, together. The EIAR provides an assessment of all likely significant environmental impacts of the decommissioning of the Kinsale Area gas fields to enable the Minister to undertake an Environmental Impact Assessment to determine whether the proposed decommissioning of the offshore and onshore facilities associated with the Kinsale Area fields would or would not be likely to have significant effects on the environment. In accordance with regulation 42 of the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended) (“the 2011 Regulations”) and Section 13A of the 1960 Act, an Appropriate Assessment Screening Report (“AA Screening Report”) was prepared to accompany the Consent Application no. 1. The AA Screening Report was updated for Consent Application no. 2, and is again updated for this consent application . The AA Screening Report informs the competent authority, the Minister, in carrying out its screening for Appropriate Assessment as to whether or not the Project is likely to have any significant impacts on any European sites, either alone or in combination with other plans and projects, taking into account their conservation objectives in light of the best scientific knowledge in the field. At the time of Consent Application no. 2, Section 5 of the Dumping at Sea Act 1996, as amended, did not yet apply to “offshore installations”2. 2Pursuant to Section 1 of the Dumping at Sea Act offshore installations means “any man-made structure, plant or vessel or parts thereof, whether floating or fixed to the seabed, placed in the sea for the purpose of 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 5
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Under Section 5 of the Dumping at Sea Act 1996, the Environmental Protection Agency (the “Agency”) has the power to grant a permit that allows the offshore pipelines and umbilicals to remain in situ. Section 5(12) postponed the legal effect of Section 5, so that the power did not apply to “offshore installations” pending an order of the Government. The necessary order of the Government was made on 2 March 2021 within the Dumping At Sea Act 1996 (Section 5(12)) (Commencement) Order 2021 (SI No. 92 of 2021). That Order appointed 1 April 2021 as the day on which Section 5 came into operation as respects offshore installations. With effect from 1 April 2021, Section 5 does now apply to offshore installations, including any offshore pipelines and umbilicals that had been placed in the sea for the purpose of exploitation of gaseous hydrocarbons. 1.2.2 Current Applications Applications to the Minister under the 1960 Act and the Continental Shelf Act, to leave the pipelines and umbilicals in situ, are now being made, as outlined in Section 1.3 below. A separate application is being made to the Agency under the Dumping at Sea Act. The application to the Minister under the Continental Shelf Act 1968 (as amended) relates only to acts of construction, alteration or improvement of the existing pipeline and umbilical structures from the outer limit of the State’s territorial seas, generally 12 nautical miles, to the wells. The application applies to the use of new engineering materials to preserve the pipelines and umbilicals in-situ. The application does not apply to leaving the offshore pipelines, umbilicals and any content within to remain in-situ. The application to the Agency under the Dumping at Sea Act relates only to the parts of the pipeline and umbilicals within the “maritime area”, so does not extend onshore beyond the line of high water of ordinary or medium tides. Also, the application to the Agency applies only to the defined act of “dumping”. The deliberate disposal in the maritime area of an offshore installation, by leaving the offshore pipelines, umbilicals and any content within to remain in situ, satisfies that definition. The defined act of “dumping” does not apply to the use of engineering materials to protect the pipelines and umbilicals in situ. The controlled installation of protective rock berms over pipelines and umbilicals to avoid and/or reduce hazards to fishing, shipping etc. is a construction activity with an engineering purpose. This use of engineering materials is not an act of disposal, as the materials are used to fulfil a specific function. The same logic applies with equal force to existing in situ protection (including protection mattresses). No application to the Minister for Housing, Local Government and Heritage (or the Minister for State with responsibility for Planning and Local Government to whom relevant functions have been delegated) for lease, licence, approval or consent under the Foreshore Act 1933 (as amended) is required. The pipeline and umbilicals on the foreshore are the subject of a foreshore licence granted by the Minister on 14 September 1978, and amended on 27 March 1997. The foreshore licence requires the pipeline to be maintained to avoid injury to navigation, which requires the use of engineering materials to preserve the pipelines and umbilicals in situ. 1.3 Consent Applications The facilities to be decommissioned under the various consent applications for the KADP are set out below. offshore activities”. Offshore activities is defined in Section 1 as meaning “activities carried out in the sea for the purpose of the exploration, appraisal or exploitation of liquid and gaseous hydrocarbons”. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 6
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1.3.1 Previous Applications Consent Application no.1 - Kinsale Head Petroleum Lease (OPL 1) This application was submitted to the Minister on 28 June 2018 and Ministerial Consent was received on 26 April 2019 and includes the following: • The Kinsale Alpha (KA) and Kinsale Bravo (KB) topsides, • All infield subsea infrastructure associated with the OPL-1, including the subsea manifold, PLEMs, valve skid, intermediary tee skid, pipeline/umbilical terminations and associated protection materials. • All OPL-1 subsea and platform wells including the wellhead structures, • 3 previously abandoned exploration wells • Consent for this application was granted by the Minister on 26th April 2019 Consent Application no.1 - Seven Heads Petroleum Lease This application was submitted to the Minister on 28 June 2018 and Ministerial consent was received on 26 April 2019 and includes for the following facilities under the Seven Heads Petroleum Lease: • Five Seven Heads Field subsea development wells including the wellhead structures • One previously abandoned exploration well • All infield subsea infrastructure associated with the Seven Heads gas field, including the subsea manifold, pipeline/umbilical terminations and associated protection materials. • Consent for this application was granted by the Minister on 26th April 2019. Consent Application no.2 - Kinsale Head Petroleum Lease (OPL 1) This application was submitted to the Minister on 8 August 2019 and Ministerial consent was received on 26 February 2020 and includes the following facilities under the Kinsale Head Petroleum Lease: • The Kinsale Alpha (KA) and Kinsale Bravo (KB) jackets. • Consent for this application was granted by the Minister on 26th Feb. 2020. 1.3.2 Current Application Consent Application no.3 - Kinsale Head Petroleum Lease (OPL 1) (this Decommissioning Plan) This application seeks consent to decommission the following facilities under the Kinsale Head Petroleum Lease: • To leave in situ all infield pipelines and umbilicals associated with the Kinsale Head gas fields • To leave in situ the 24” export pipeline (offshore and onshore section) and to fill the onshore section with grout 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 7
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 • To use engineering materials (Rock Placement) to protect the pipelines and umbilicals in situ Kinsale Energy is now making two separate applications under the relevant legislation with respect to pipeline and umbilical decommissioning as follows: 1. Application for approval of an addendum to Kinsale Head Field Plan of Development under Section 13 of the 1960 Act As noted previously, the Kinsale Head gas fields have come to the end of their productive life. Gas production from the wells ceased on 5 July 2020. Kinsale Energy is applying to the Minister for approval for an addendum to the Kinsale Head Plan of Development for the decommissioning of certain facilities as set out in this document. Kinsale Energy has prepared this Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application no. 3 (the “Decommissioning Plan”) which sets out the details for the decommissioning3 of certain facilities in the Kinsale Head gas fields. In accordance with section 13A of the 1960 Act, an EIAR accompanies this application. An AA Screening Report has also been prepared to accompany this application. 2. Application for Consent under Section 5 of the Continental Shelf Act 1968 (as amended) Pursuant to Section 5(2) of the Continental Shelf Act 1968, as amended, the consent of the Minister is also sought by Kinsale Energy to alter and improve certain facilities within the area designated pursuant to Article 2 of the Continental Shelf Designated Areas Order 1993 SI 92 of 1993. The application to the Minister under the Continental Shelf Act 1968 relates only to acts of construction, alteration or improvement of the existing pipeline and umbilical structures from the outer limit of the State’s territorial seas, generally 12 nautical miles, to the wells. The application applies to the use of engineering materials to protect the pipelines and umbilicals in situ. The application does not apply to leaving the offshore pipelines, umbilicals and any content within to remain in situ. These, and the related applications, are the final applications being made to decommission the KADP. 1.3.3 Related Applications A separate application is being submitted to the Department of Environment, Climate and Communications for the following: Seven Heads Petroleum Lease – Consent Application no. 2 • All infield pipelines and umbilicals associated with the Seven Heads gas field • The 18” Seven Heads export pipeline and umbilical As noted above separate applications are also being made to the EPA for consent under Section 5 of the Dumping at Sea Act 1996 for the leaving in situ of pipelines and umbilicals within the maritime area. 1.3.4 Environmental Assessment As outlined above in Section [1.2 (Background)], , in accordance with section 13A of the 1960 Act, an EIAR was prepared to accompany Consent Application no. 1. The EIAR was updated, by way of Addendum, for Consent Application no. 2. The EIAR has again been updated, by way of Addendum, for this application. The addendums (253993-00-REP-24 and 253993-00-REP-27) have been produced to reflect the additional information provided to the Minister on 14th November 2018 and 12th December 2018 during the Consent 3 Meaning the removal, part removal or leaving in place of any installation or facility. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 8
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Application No. 1 process and for Consent Application 2, as well as any additional relevant environmental information which has been published in the interim. Any reference to EIAR shall mean a reference to the entire of the EIAR and these two Addendums, together. The EIAR should be read in conjunction with the Decommissioning Plan which have also been submitted as part of this consent application process. The EIAR has been prepared to identify, describe and assess the likely significant environmental impacts of the entirety of the proposed decommissioning of the Kinsale Area gas fields and facilities including the decommissioning of the Inch onshore gas terminal. As outlined above in Section [1.2 (Background)], in accordance with regulation 42 of the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended) and Section 13A of the 1960 Act, an AA Screening Report was prepared to accompany the Consent Application no. 1. The AA Screening Report was updated for Consent Application no. 2, and is again updated for this consent application. The AA Screening Report informs the competent authority, the Minister, in carrying out its screening for Appropriate Assessment as to whether or not the entirety of the proposed decommissioning of the Kinsale Area gas fields and facilities, including the decommissioning of the Inch onshore gas terminal, is likely to have any significant impacts on any European sites, either alone or in combination with other plans and projects, taking into account their conservation objectives and in light of the best scientific knowledge in the field. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 9
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Figure 1: Location of the Kinsale Area fields and facilities 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 10
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1.4 OPL-1 The Offshore Kinsale Head Petroleum Lease No. 1 (OPL-1), details are summarised in Table 1 below. Table 1: Lease details Commencement Area Participants Lease Block No. % Interest Date (km²) (* = Operator) Offshore 7 May 1970 48/20, 48/25, 1,003.03 *PSE Kinsale 100% Petroleum Lease 49/16 & 49/21 Energy Limited No. 1: 1.5 Overview of Facilities The Kinsale Area contains several natural gas fields as shown in Figure 2 below. The Kinsale Head, Southwest Kinsale, Greensand and Ballycotton gas fields are all located within the area leased under Kinsale Head Petroleum Lease (OPL-1). The adjacent gas field, Seven Heads gas field is located within the area leased under Seven Heads Petroleum Lease. The Kinsale Head facilities were installed between 1977 and 2003 with gas production commencing in 1978 and seasonal gas storage operations taking place between 2001 and 2017. The fields ceased production on July 5 2020. See Section 2 for details of the facilities. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 11
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Figure 2 Kinsale Area Facilities 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 12
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1.6 Summary of Statutory Background Table 2 below summarises the relevant key National, European and International legislation and the associated consents and requirements for decommissioning of infrastructure relevant to the KADP. Details of all relevant International Conventions and European Legislation is included in Appendix A1. Table 2: Key National, European and International legislation relevant to the KADP Relevant Legislation Consents / requirements for Decommissioning Section 13 of The Petroleum & Other Application to the Minister is being made pursuant to Section 13 Minerals Development Act 1960 (as for decommissioning. amended) Section 5 of The Continental Shelf Act Application to the Minister is being made for the consent to 1968 (as amended) “alter/construct/improve” works or structure in ‘or remove any object or material from’ the Continental Shelf designated area. Section 5 of the Dumping at Sea Act Application to the Agency is being made for permit that allows 1996 (as amended) the offshore pipelines and umbilicals to remain in situ Part IIA of the Electricity Regulation Act Section 13D renders the decommissioning of petroleum 1999 (as amended) infrastructure and the abandoning of any well as a “designated petroleum activity”. Section 13E requires a safety permit to carry out designated petroleum activity. Section 3 of the Petroleum Kinsale Energy’s current safety permit includes (Exploration and Extraction) Safety Act decommissioning. 2010 (as amended) Approval of Safety Case received for decommissioning. Energy (Miscellaneous Provisions) Act Minister shall not approve abandonment without consent of 1995, Section 17 Minister of Marine. European Communities (Birds and Screening to be undertaken by competent authority to determine Natural Habitats) Regulations 2011 (as whether actions will affect European site. Screening report to be amended) submitted to competent authority. Transposes Habitats Directive (92/43/EEC) and Birds Directive (2009/147/EC) into Irish Law. Application is accompanied by an AA Screening Report. Environmental Impact Assessment EIA Screening, and EIA if required, to be undertaken by Directive 2011/92/EU amended by competent authority. Directive 2014/52/EU Application is accompanied by an EIAR. Decisions 98/3, OSPAR (1998) The dumping, and leaving wholly or partly in place, of disused offshore installations is prohibited within the OSPAR maritime area. Foreshore Act 1933 (as amended) No application to the Minister for Housing, Local Government and Heritage (or the Minister for State with responsibility for Planning and Local Government to whom relevant functions have been delegated) for lease, licence, approval or consent under the Foreshore Act 1933 is required. Kinsale Energy is entitled to surrender the existing licence, upon payment of a specified fee. 1.7 Methodology This Decommissioning Plan has been prepared in line with the legislation as detailed in Section 1.6, and in the absence of specific decommissioning guidance documents in Ireland, taking cognisance of the following guidance documents for decommissioning projects: 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 13
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 [1] PAD (2004). Rules and Procedures Manual for Offshore Petroleum Production Operations Rev 4.4, 2004, Petroleum Affairs Division, Department of Communications, Marine and Natural Resources, Dublin. [2] PAD (2011), Rules and Procedures Manual for Offshore Petroleum Exploration and Appraisal, 2011, Petroleum Affairs Division, Department of Communications, Marine and Natural Resources, Dublin [3] DMNR (1992). Licensing Terms for Offshore Oil And Gas Exploration, Development & Production 1992, Department of the Marine and Natural Resources, Dublin [4] EPA (2014). Guidance on assessing and costing environmental liabilities 2014. [5] DECC (UK) (2011). Decommissioning of Offshore Oil and Gas Installations and Pipelines under the Petroleum Act 1998. Version 6, 134pp. [6] OGUK (UK) (2013). Long-term degradation of Offshore Structures and Pipelines Decommissioned and left in situ. Commissioned by Oil & Gas UK, 41pp. 1.8 Overview of Decommissioning Plan This Decommissioning Plan details the selected option for the decommissioning of certain facilities within the Kinsale Head gas fields. A number of options were initially considered to carry out the decommissioning of the facilities, including the consideration of alternative uses of the facilities (refer to Section 3.3), as well as a number of different options to carry out the physical decommissioning (refer to Section 4). No feasible alternative uses for the facilities have been identified and the different methods to carry out the decommissioning have been assessed, which resulted in the identification of a number of preferred methods for the decommissioning of each facility. The broad scope of work involved in decommissioning the facilities (covered by this Decommissioning Plan) is the leaving in situ of the pipelines and umbilicals, and rock cover of freespans and remaining in situ protection materials. Table 3 sets out a summary of the decommissioning alternatives initially considered. Refer to Section 4 of this Decommissioning Plan for further detail on the alternatives considered. Table 3: Summary of proposed decommissioning options for the OPL-1 Facilities (Consent Application No.3) Decommissioning Alternatives Initially Comment Facility Considered Pipelines, • Full Removal Full removal and partial removal were Umbilicals • Partial Removal initially considered as alternatives for and protection pipelines, umbilicals and protection materials • Leave in situ materials. Refer to Appendix E of the EIAR (Comparative Assessment) which considered the safety, environmental, technical, social and cost aspects of the various alternatives and which identified leave in situ as the optimal option. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 14
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 1.9 Objective of Decommissioning Project The objective of this Decommissioning Plan is to ensure that the decommissioning is undertaken in a safe, environmentally friendly and cost efficient manner. The Kinsale Area Decommissioning Project will ensure minimum impact on the environment. The Decommissioning Plan will ensure that the necessary measures are identified, managed and monitored to lead to successful decommissioning. The criteria which define the successful decommissioning of the facilities are as follows: • Compliance with the Minister’s consent requirements. • All decommissioning activities completed safely and with due regard to the environment. • All activities undertaken in compliance with laws and regulations. • All works carried out in accordance with good oilfield practice. • All facilities will be safely decommissioned using standard procedures and appropriately licensed contractors. • All disposal of wastes, materials and substances will comply with regulatory requirements. • All records relating to decommissioning and the disposal or recycling of wastes, materials and substances retained throughout the closure process and made available for inspection thereafter through the DECC. • Hazards and environmental risks addressed and the Minister satisfied that the Kinsale Area has minimum impact on the Environment. • An Environmental Management System in place and actively implemented during the decommissioning period. • Residual (post-decommissioning) risks reduced to a satisfactory level. • Appropriate funds in place to cover the costs. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 15
Kinsale Area Decommissioning Project Section 2 Facilities Description
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 2 Facilities Description 2.1 History of Operations The Kinsale Head Gas Field was discovered in 1971 and was brought on-stream in 1978 under a Plan of Development approved by the then Department of Industry and Commerce. The Kinsale Head field was developed with two fixed steel platforms (Kinsale Alpha and Kinsale Bravo) with gas exported by pipeline from Kinsale Alpha to the onshore Inch Terminal. The discovery of the field was the basis for the development of the natural gas industry in Ireland and Kinsale Head was Ireland’s only source of gas until the installation of an interconnector pipeline from Scotland in 1993. Following the Kinsale Head discovery, there was extensive exploration of the Celtic Sea with ~90 wells drilled, the last was the Midleton well in Block 49/11 drilled by Kinsale Energy in 2015. However, despite the intensive exploration effort, no other large fields have been discovered, although a number of smaller gas fields have been commercially exploited as subsea tie-backs to Kinsale Head, including the Seven Heads field, which was the last development in the area. The Kinsale Area fields and infrastructure are summarised in Table 4, for information. Table 4: Summary of Development History for the Kinsale Area Fields No. of Date/First Lease Field Facilities Status (2021) Wells Production OPL-01 Kinsale Head 14 Kinsale Alpha 1978 (Manned Platform with Wells abandoned; production, drilling & platform demanned accommodation) 7 x Platform Wells Kinsale Bravo 1979 (Manned Platform with Wells abandoned; production, drilling & platform demanned accommodation) 7 x Platform Wells Ballycotton 1 1 x Subsea Well 1991 Shut-In; well abandonment imminent Southwest 3 3 x Subsea Wells 1999 – 2001 Wells Abandoned Kinsale * Greensand 1 1 x Subsea Well 2003 Well Abandoned Seven Seven Heads 5 1 x Subsea Manifold 2003 Heads 5 x Subsea Wells Shut-in; well Abandonment ongoing The Seven Heads field was developed by a group led by Ramco Energy in 2003; Ramco’s interest (86.5%) was subsequently acquired by Marathon in 2006 and is now operated by PSE Seven Heads Limited, a subsidiary of PSE Kinsale Energy Limited. A separate Decommissioning Plan is being submitted for the Seven Heads facilities. The development of the fields involved the installation of a number of pipelines, initially for the export of gas from the two production platforms and subsequently for the tie-back of various satellite fields, including the last development, the Seven Heads field in 2003. Subsea electro-hydraulic umbilicals were also installed to allow control of the satellite gas fields form the platforms. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 16
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Details of the pipelines and umbilicals which are the subject of this Consent Application are given in Section 2.2 below. All of the pipelines have been degassed and displaced to seawater as part of the decommissioning activities under Consent Application 1. 2.2 Inventory of Facilities The facilities to be decommissioned, relevant to this Decommissioning Plan, are illustrated (Figures 3 to 5) and summarised in Table 5. This Decommissioning Plan is only for the pipelines, umbilicals and protection materials associated with the Kinsale Head Lease. Layout drawings of all facilities within OPL-1 are included in Appendix A2. 2.2.1 Kinsale Head Development Figure 3: Overview of the Kinsale Head Facilities Export pipeline The main export pipeline from KA to the Inch Terminal consists of a 55.57km, 24” concrete coated pipeline installed in 1977. The pipeline is mainly surface laid but with some buried sections and rock placement at strategic locations. The pipeline is buried from 2km seaward of the landfall to the landfall and for the 1.2km inland from the landfall as far as the Inch Terminal. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 17
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 The pipeline was displaced to seawater in March 2021 and was subsequently disconnected (cut) at a point 55m from the base of the KA jacket in August 2021. KA to KB pipelines Two pipelines connect the KA and KB platforms, a 24” concrete coated pipeline (4.96km) and a 12” three layer polypropylene (PPL) coated pipeline (5.11km). The pipelines were installed in 1977 and 2001 respectively and are both surface laid, with rock having been placed at strategic locations along the 24” pipeline. The 24” pipeline was displaced to seawater in February 2021 and the line was subsequently disconnected (cut) at the base of each platform in May 2021 2.2.2 Ballycotton Subsea Development Figure 4 Ballycotton Infrastructure The 12.69km 10” Ballycotton pipeline was installed in 1991, and connects well 48/20-2 to KB and is trenched and buried throughout most of its length though with some exposed sections, and mattress protection, particularly at the wellhead end, which is extensively protected. The umbilical (control cable) is trenched separately to the pipeline and is of similar length (13.00km). There are two infield crossings of the Ballycotton pipeline close to KB by the Seven Heads pipeline and umbilical, each of which is protected with concrete mattresses. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 18
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 There is a 500m exclusion zone, for other sea users, around the Ballycotton well 48/20-2 (ref S.I. No 226/1991). The pipeline was displaced to seawater and subsequently disconnected (cut) from the well in October 2020. The well was isolated pending permanent abandonment. The flowline end spool and PLET (pipeline end termination valve skid) were removed in August 2021. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 19
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 2.2.3 Southwest Kinsale and Greensand Subsea Development Figure 5: Overview of Southwest Kinsale and Greensand The Southwest Kinsale (SW Kinsale) development is connected to the KB platform via a 6.96km, 12” pipeline installed in 1999, which is partially trenched and buried, and rock covered where required trenching depths could not be reached. Concrete protective mattresses cover both ends of the pipeline, on its approach to the SW Kinsale valve skid and at its connection with KB. The SW Kinsale valve skid is tied into well 48/25-3 and an intermediate tee skid which connects the Western Drill Centre (WDC) extension. The WDC extension is a similar 12” pipeline 1.16km in length installed in 2001, which is rock-covered along its length. The WDC pipeline terminates at the WDC Pipeline End Manifold (PLEM) and is connected via spool pieces to the 48/25-4 and 48/25-5 wells. A subsea well completion (Greensand) in the “A” sand zone of SW Kinsale was installed in 2003 and the infrastructure is immediately adjacent to that of SW Kinsale. The 7.02km 10” pipeline is rock-covered along its length to KB with the exception of a short section approaching the Greensand PLEM. Spool pieces connect the Greensand PLEM to well 48/25-6. There is an exclusion zone, for other sea users (ref S.I. No. 6/2003), bounded by a line which is 500m at all points from a straight line joining the SW Kinsale well 48/25-3 and a point at the WDC wells. This results in an elongated 500m exclusion zone around the Southwest Kinsale, Western Drill Centre and Greensand wells. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 20
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 The South West Kinsale, Greensand and Western Drill Centre pipelines were displaced to seawater and subsequently disconnected from their respective wells in October 2020. The wells were isolated pending permanent abandonment. All subsea structures related with this infrastructure were removed in August 2021. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 21
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 2.2.4 Summary of OPL-1 Lease Facilities (Consent Application 3) Tables 5 and Table 6 summarises the OPL-1 facilities to be decommissioned as detailed herein. Table 5: Pipelines to be decommissioned Length Pipeline (km) Description Year installed Status Tie-in spools pieces Protection materials Comments Kinsale Head, Southwest Kinsale, Greensand & Ballycotton Inch Terminal to 1.20km 24″ X60 steel, 1977 Shut-in; Inch Terminal pipeline 25mm concrete coated Inch Beach coal-tar epoxy displaced to entry buried with Inlet section from the vegetation landfall export seawater; Stop Valve P149 in pit zone above the beach to pipeline 150m from Lowest Astronomical Tide (LAT) Inch Beach 54.37km 24″, X60 steel, 1977 Shut-in; 50mm concrete coated Intermittent grout bag Number of non-critical landfall to coal-tar epoxy and displaced to tie-in at KA. supports at 11 locations. freespans detected. Kinsale Alpha concrete coated seawater; Rock cover totals 5.8km, Cumulative freespan export pipeline disconnecte covering a number of length 1,822m d at KA strategic locations. Kinsale Alpha 4.96km 24″ X52 steel, 1977 Shut-in; 50mm concrete coated Rock cover totals 96m, 12 non-critical (KA) to Kinsale coal-tar epoxy and displaced to tie-in at KA and KB. covering a number of freespans detected. Bravo (KB) concrete coated seawater; strategic locations. Cumulative freespan export pipeline disconnecte length 205m d at KA and KBi 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 22
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Length Pipeline (km) Description Year installed Status Tie-in spools pieces Protection materials Comments KA to KB 5.11km 12″ X52 steel, 2001 Shut-in; 25m spool underneath No pipeline protection. 8 non-critical pipeline 3LPP coated displaced to each jacket, 40m spool 2 support ramps of grout freespans detected. seawater connecting pipeline at KA bags at KA and KB tie-in Cumulative freespan end. spools. length 188m 34 mattresses (6x3x0.15m) used at each tie-in location at KA and KB. Southwest 6.96km 12″ X52 steel, 1999 Shut- 36m spool at KB, vertical Rock cover totals 2.6km. No freespans Kinsale pipeline 3LPP coated in;displaced leg to riser end. Single 4 mattresses (5x3x0.15m) at identified to seawater; spool between valve skid SWK end and 20 mattresses disconnecte and 48/25-3 tree. (5x2.2x0.15m) at the KB end. d at well Tie-in spools include 6 location and mattresses (5x2.2x0.15m) at KB KB and 8 mattresses (6x3x0.15m) at SWK. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 23
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Length Pipeline (km) Description Year installed Status Tie-in spools pieces Protection materials Comments Extension 1.16km 12″ X52 steel, 2001 Shut-in; 2 x 6” spools to WDC Rock cover along entire No freespans pipeline to 3LPP coated displaced to 48/25-4 and 48/25-5 length. identified Western Drill seawater; trees. 8 mattresses (5x3x0.15m) at Centre disconnecte 34m long spool between WDC on PLEM to tree d at well skids at SWK. spools. location 6 mattresses (5x3x0.15m) on spool between skids at SWK. 4 mattresses (5x3x0.15m) at SWK on pipeline end. 4 mattresses (5x3x0.15m) at WDC on pipeline end. Greensand 7.02km 10″ X52 steel, 2003 Shut-in; Two 10″ spools at KB. Rock cover along entire No freespans pipeline 3LPP coated displaced to Two 6″ spools between length. identified seawater; the Greensand well 10 mattresses (6x3x0.15m) disconnecte (48/25-6) and PLEM and at Greensand pipeline end d at well one 10″ spool connecting and 13 mattresses at KB location the PLEM to the pipeline end. greensand pipeline. Spools with groutbag support at KB. KB spool protection includes 9 mattresses (6x3x0.15m). Well spool protection includes 13 mattresses (6x3x0.15m). 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 24
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Length Pipeline (km) Description Year installed Status Tie-in spools pieces Protection materials Comments Ballycotton 12.69km 10″ X52 steel, 1991 Shut-in; 30m tie-in spool to 48/20- 44 mattresses used for 8m freespan identified. pipeline 0.5mm FBE coated displaced to 2 tree and 20m tie-in pipeline protection. seawater; spool at KB. Groutbag support at disconnecte Ballycotton tree and KB d at well spools. location and Grout bag berm 8m long at KB tee spool. 4 kennel-type protection tunnel for 20m on tree tie-in spool along with 3 mattresses (5x3x0.15m). 105 mattresses on pipeline end at tree. 9 stabilisation mattresses (2.5x1.5x0.15m) on pipeline end at KB. Source: Genesis (2011), Xodus (2016c), Anatec (2017), Kinsale Energy’s as-built data Table 6: Umbilicals to be decommissioned Current Burial Status / Umbilical Diameter Length Protection materials Comments Installation Method Southwest Kinsale 82mm 6.96km Partially trenched. 8 mattresses (6x3x0.15m) at KB end and umbilical Laid alongside 12” South West 20 mattresses at the SWK tree end. Kinsale pipeline, sharing the Grout bags used to support a crossing same protection materials. with the SWK pipeline near KB. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 25
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 Current Burial Status / Umbilical Diameter Length Protection materials Comments Installation Method Western drill 82mm 1.16km Laid alongside 12” South West Rock cover along majority of length. 8 centre umbilical Kinsale extension to Western mattresses (5x3x0.15m) and 6 mattresses Drill Centre, sharing the same (5x2x0.15m) cover the umbilicals to the protection materials. trees. 24 mattresses (6x2x0.15m) cover the umbilical between the SWK tree and the pipeline rock placement. Ballycotton 98.2mm 13.00km Trenched The Seven Heads pipeline and umbilical 9m freespan identified umbilical cross over the Ballycotton umbilical. Crossing includes 3 mattresses (5x3x0.15m). 12 mattresses cover the umbilical to the tree and 3 mattresses cover the umbilical to KB. Source: Genesis (2011), Xodus (2016c), Anatec (2017), Kinsale Energy’s as-built data 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 26
Kinsale Area Decommissioning Project Section 3 Cessation of Production
PSE Kinsale Energy Limited Kinsale Area Decommissioning Project Decommissioning Plan – Kinsale Head Petroleum Lease (OPL 1) – Consent Application No.3 3 Cessation of Production 3.1 Summary The Kinsale Area gas fields were in production since 1978 (Kinsale Head) and gas reserves were exhausted by 2020. A cessation of operations permit in accordance with section 8.8 of the PAD Rules & Procedures Manual for Offshore Petroleum Production Operations was submitted to and consented by DCCAE, with final CoP occurring on 5th July 2020. 3.2 Technical and Economic Evaluations Kinsale Energy also separately submitted to the Minister a report detailing the technical and economic evaluations that supported the CoP timeframe. 3.3 Other Uses Considered The Kinsale Area facilities (including pipelines and umbilicals) were designed for dry gas production and processing, and the majority of the facilities are now close to or beyond their original design lives. Nevertheless, parts of the facilities may have been suitable for re-use, depending on the service, particularly the main Kinsale and Seven Heads export pipelines.. Three potential re-uses have been considered at a high level. These are hydrocarbon production, carbon capture and storage (CCS) and offshore wind energy production. An assessment of the alternatives and other uses are outlined in full at Sections 3.3 and 3.4 of the EIAR. Following discussions with DECC regarding potential future use of the pipelines, it was the position of the Department that Consent Application 3 should be submitted on the basis that arrangements are not to be made to provide for the future use of the pipelines. Kinsale Energy is proceeding with decommissioning on the basis that none of the pipelines or umbilicals will be re-used. 253993-00-REP-28 | Issue 1 | 30 September 2021 Page 27
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