Quality data is essential for calculations of expected leakage in wells post Permanent Plug and Abandonment (PP&A). Such data may come from surveys studying hydrocarbon leakage to the marine environment. However, recent literature suggests that current regulatory practices for environmental surveys are suboptimal, giving reason to question the assumption that wells have experienced zero leakage from the deep reservoir post PP&A on the Norwegian Continental Shelf (NCS). We investigate whether such an assumption is credible.

The credibility of the assumption of zero leakages is investigated through a review of literature addressing the integrity of wells post PP&A on the NCS, with particular emphasis on a 2021 report from the Norwegian Environmental Agency (NEA). Based on the review, the strength of knowledge supporting the assumption that no wells on the NCS have experienced leakages from their deep reservoirs is discussed. The implications of the uncertainty associated with the assumption of zero leakage on the NCS, the rationale for collecting more relevant data, and how these data may be obtained is also discussed in brief.

The NEA report details the current regulatory practice for environmental surveys on the NCS. This regulatory practice, as it is described in the NEA report, give limited support to a zero leakage assumption. Norwegian regulations require two environmental surveys post Cessation of Production (CoP). These surveys may however occur in the period between CoP and PP&A, and the closest test stations are generally located 250 meters from the wells. Environmental surveys carried out that far from the well, and possibly prior to PP&A, influence data quality. We argue that the environmental survey data claiming zero leakage, lack sufficient evidence. Thus, based on the reviewed literature outlining the current environmental survey practice, although PP&A well design on the NCS should build on sound principles, we are not able to conclude on the assumption of zero leakage.

The interest in risk-based PP&A approaches is increasing globally, and risk-based approaches rely on credible leakage calculations. The failure rates used in these leakage calculations should be based on quality data. The NEA report and other literature indicate that the quality of post PP&A leakage data on the NCS is questionable, and in some cases the data are non-existent. The paper includes suggestions on how to improve the regulatory practice related to environmental surveys.

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