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Decommissioning of a FSO Containing Hazardous Waste: A SuccessfulStoryClaude-Henri Chaîneau, Jean-Claude Bourguignon, Guillaume Goubard, Pierre Bang, Total E&P, Philippe JeanPJN consulting, Benoit Lefebvre, SITA France, Tom Peter Blankestijn, Sea2Cradle and Emmanuel Tambe Ayuk,SNH

Copyright 2012, SPE/APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production

This paper was prepared for presentation at the SPE/APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production held in Perth, Australia,11–13 September 2012.

This paper was selected for presentation by an SPE/APPEA program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper havenot been reviewed by the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association Limited and are subject to correction by the author(s). The materialdoes not necessarily reflect any position of the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association Limited, its officers, or members. Electronicreproduction, distribution, or storage of any part of this paper without the written consent of the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association

Limited is prohibited. Permission to reproduce in print is restricted to an abstract of not more than 300 words; illustrations may not be copied. The abstract must contain conspicuousacknowledgment of SPE copyright.

AbstractThe Serepca-1 was a Suezmax type oil tanker, built in 1974, and converted into a floating storage and offloading unit (FSO)in 1984. She was moored off the coast of Cameroon and ceased her oil storage activities in 2007. The end-of-life of any

tanker has economic, environmental and social implications. Various environmental surveys were made to identify hazardous

materials and to produce the ship's Green Passport. The FSO was a significant source of raw material and contained waste

that could turn her dismantling into both a human health and environmental hazard. An initial decontamination prior to shipexport for dismantling was performed offshore. A specialised contractor removed, conditioned and safely stored hazardous

materials such as mercury and PCB containing transformers. These wastes were exported to European waste disposal

facilities under Basel Convention regulations. It was revealed as the best technical and regulatory approach and was made

possible thanks to the Green Passport. The ability of several international shipyards to dismantle the FSO, and dispose ofother hazardous wastes in conditions ensuring human health and environmental protection, was evaluated through technical

and HSE audits. The shipyards included those listed by the European Commission Directorate and other yards evaluated by

international organisations and having demonstrated a proactive approach in terms of environmental protection, occupationalsafety, health care and dialogue with the local population. Finally, the FSO was exported to a Chinese shipyard under Basel

Convention regulations.

This paper's objective is to present the environmental approach applied to this FSO's end-of-life, and explains the choices

behind her offshore decontamination and subsequent dismantling in China. Total E&P chose a transparent pro-active project

communication strategy. The company contacted and regularly discussed the project with the Ship Dismantling Platform, amajor NGOs active in the area of ship dismantling.

IntroductionThe Serepca-1 tanker’s oil storage activities ceased in May 2007, and it is in this context that a full decommissioning projectwas set up. The Serepca-1 was a former oil tanker, built in 1974. In 1984, she was converted into a floating storage unit (or

FSO), and positioned in the Biafra bight, off the coast of the Republic of Cameroon. Its 14 tanks stored Kolé crude oil,extracted from the Rio del Rey oil field. However, given the oil tanker’s age, Company Rules, the company has decided toreplace her.

The end-of-life of any ship, and particularly that of an oil tanker, has economic, environmental and social implications

(Knapp et al. 2008; Chang et al. 2010). Given the large quantity of steel contained in her structure, an oil tanker constitutes a

significant source of raw material. The elimination strategy selected, however, can turn such a tanker and the various polluting, toxic or inflammable substances onboard, into both a human health and an environmental hazard (Chang et al.

2010). The greatest difficulties are encountered with the oldest ships, as they contain many substances that are now

forbidden, such as asbestos or PCBs (Polychlorobiphenyls). Other examples of hazardous materials often found onboard

include the heavy metals contained in paints, ship-born chemicals, hydrocarbons, gases and the residues contained in ship’stanks. Several decontamination phases must be carried out in perfect sequences prior to any dismantling operation in order to

prevent environmental and human health risks. When one looks at the international situation, one sees that, during the last

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two dozen years, most of the world’s commercial and war ships have been sent to developing countries, to be dismantled in

conditions damaging to the environment and human health. The evolution of environmental regulations in the OECD

countries during the 1980s caused the cost of hazardous waste disposal operations to increase in industrialised countries. As aresult, hazardous wastes have been exported to developing countries where environmental regulations were less thorough. It

is in reaction to this situation, that the international community implemented the Basel Convention on the Control of

Transboundary Movements of Hazardous Wastes and their Disposal (1989). The United Nations Environment Program

(UNEP) administered the Convention. The Basel Convention has nonetheless proved insufficient in the case of ship

dismantling as there is debate as to whether the concept of « waste » can be applied to a ship (Moen 2008). Consequently,each year, between 200 and 600 large “end-of-life” ships are dismantled and recycled on the tidal beaches, with damaging

impacts upon the environment and local populations (DNV 2000; ILO 2001; Tewari 2001; ILO 2004; Gökdemiz et al. 2012a,2012b). Indeed, the absence of safety and environmental protection measures, led to large numbers of accidents on the

dismantling sites, significant health risks for workers and neighbouring populations, and pollution of coastal areas (DNV

2000; ILO 2001; Neser et al. 2012a, 2012b). Various international authorities have produced « guidelines » that provide

recommendations for ship dismantling (DNV and Appledore Int. 2000; EPA 2000; COWI and HHI 2007). However, none of

these guidelines were legally binding. In 2007, a draft convention, (future Hong Kong International Convention for the Safeand Environmentally Sound Recycling of Ships, 2009), was currently under preparation by the International Maritime

Organisation (IMO) to remedy this situation and to provide an appropriate legal framework. This convention was then

adopted during the diplomatic conference held in Hong-Kong, China from the 11th to the 15th of May 2009.

Ship dismantling issues have never been as sensitive as they are now, and this is a time of significant regulatory shifts. It is inthis context that the Rio del Rey partnership, represented by Total E&P Cameroun, envisaged the Serepca-1 tanker’s end-of-

life. Five alternatives were initially considered: sale of the ship « as is, where is », conditional sale, conditional sale followingremoval of specific hazardous materials, agreement of a dismantling contract with a yard, and immersion. This paper’s

objectives are to demonstrate how the decommissioning project analysed these alternatives in the light of several criteria, in

particular environmental and social impacts and, in accordance with the good practices and standards and, how the Project

implemented the best strategy to dismantle the FSO in a sound way. The project started in 2007 and ended in 2009, with the

deconstruction of the Serepca-1.

Materials and methodology

The Serepca-1

The Serepca-1 (SR1) was built in 1974 by Howalds Werke Deutsche Werft AG (Hamburg, Germany). The ship, registered inPoland under the name «Kasprowy Wierch », first intended use was as an oil tanker. She was a single hull, Suezmax type

ship with a 284 meters overall length (LOA), a 21380 tons lightweight, and a 15.7 meters maximum draft. The vessel had a

storage capacity of 956000 barrels and provided accommodation for up to 65 passengers. Her central section was occupied,

from the main deck to the bunker, by 14 storage tanks (4 central tanks, 5 port tanks and 5 starboard tanks), the purge tank(water cell) and the slop tank. There was no separate tank for ballast waters (Fig. 1).The ship was acquired in August 1983 by the Société d’Etudes et de REcherches Pétrolières du CAmeroun (Serepca

company). Serepca became Elf Serepca in 1958, and then Total E&P Cameroun following the merger between TotalFina and

Elf Aquitaine in 2000. The ship was registered under the Republic of Cameroon’s flag. In 1984, the Compagnie Marseillaise

de Réparation (CMR) converted the ship into a Floating Storage Offloading unit (FSO), registered as the « Serepca-1 ».TheSerepca-1 was moored (with eleven 4-inch attachment hooks fixed onto rammed pilings) in the Rio del Rey offshore

production basin, in the Biafra Bight, off the coast of the Republic of Cameroon. The Rio del Rey Basin is situated 80nautical miles from Douala, and 10 nautical miles south of the Bakasi peninsula, next to the Nigerian border. Its surface area

is 600 km². Seawater depth is approximately 4.5 meters to the north of the basin, 35 meters to the south, and 22 meters

beneath the Serepca-1. FSOs are generally used in offshore oil fields, as an alternative to the routing of oil to the coast via

pipelines. Production platforms transferred the crude oil to the FSO for storage until it could be unloaded in a commercial

tanker.

In 1998, the SR1 underwent major transformations performed by the ship repair company Lisnave (Portugal) during drydocking operations. At that time it was decided to remove its propulsion units because the FSO was anchored all time and

operations did not require her to move. The activities for crude oil storage ceased completely in May 2007. Up until the end

of 2007, the ship provided accommodation for the teams working in the Rio del Rey Basin. Crude was then rerouted from the production platforms to a new Suezmax tanker for storage.

Regulatory framework within the 2007-2009 period

The ship dismantling regulatory framework was not precisely defined in the 2007-2009 period, even though various

authorities have produced several ship dismantling studies (Hamzah 2003; Moen 2008). Several « guidelines », from the

International Maritime Organisation (IMO), International Labour Organisation (ILO), the Conference of Parties to the BaselConvention (BC), the International Chamber of Shipping (ICS) and from the Draft of the 2009 IMO Convention, have

proposed objectives (ILO 2004; IMO 2003, 2004, 200,5 2006; Commission of the European Communities 2007, MEPC

2007). However, none were legally binding. Significant efforts were made to reach an international consensus on a common

convention providing the legal framework for sound ship recycling (Moen 2008; Chang et al. 2010). However, many areas

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which a transboundary movement commences to the point of disposal.

- Any Party can impose additional requirements if they are consistent with the provisions of the Convention.

The Annex I of the Convention defines the categories of wastes that must be controlled. These include:

- Y8: Waste mineral oils.

- Y9: Waste oils/water, hydrocarbons/water mixtures, emulsions.

- Y10: Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs) and/or

polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs).

- Y20 to Y31: Anything containing heavy metals.- Y36: Asbestos (dust and fibres).

- Y41: Halogenated organic solvents.

Any Party can add wastes classified as hazardous by their national legislation to this list. In addition, in 1995, Parties also

agreed to the Basel Convention Ban Amendment, or « Ban amendment » (Decision III/1). This amendment proposed a banon transboundary movement of hazardous wastes intended for final disposal. The amendment also proposed a ban, as of

January 1998, on transboundary movement of hazardous wastes intended for reclamation and/or recycling from what are

known as Appendix VII States/countries (members of the Organisation for Economic Co-operation and Development

(OECD), of the European Community or Liechtenstein) to non-Annex VII States/countries (all other Parties to theConvention). In the absence of sufficient ratifications, neither this amendment, nor Annex VII, has yet entered into force in

international law. However, both are legally binding for European Community (EC) Member States, as they have been

integrated into EC regulations, in particular into Regulation (EC) n° 1013/2006 of the European Parliament and of theCouncil (cf. Annex I). On the African Continent, the sister convention is the Bamako Convention on the Ban of the Import

into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa. This

Convention was signed on January 30th, 1991 in Bamako in Mali, and entered into force on March 10 th, 1999. The Republic

of Cameroon signed the Convention on March 1st, 1991, and ratified it on December 21st, 1995.

Protection of the marine environment from pollution. The 1982 Montego Bay United Nations Convention on the Law of the Sea

(UNCLOS), in force since 1994, is the most universal convention in place today for cooperation on the law of the sea and

related issues, such as the protection of marine environments against polluting activities associated with navigation. The

Convention proposes a thorough legal framework for a wide range of issues relating to the marine environment (exploitation,

preservation, international cooperation, scientific research, education, technology transfer to developing countries, etc.) andthereby overlaps with other conventions on biological diversity and maritime pollution (MARPOL, OILPOL, Ramsar 71,

etc.). The 1972 London Convention and its 1996 Protocol, is in force since 1975. Its objective is to prevent pollution caused bywaste dumping at sea. The Convention bans the dumping of certain wastes, listed in its Annex I (oil/petroleum, mercury,

cadmium, radioactive wastes...), and requires a prior special permit for the dumping of a number of other substances listed in

its Annex II (wastes containing arsenic, nickel, pesticides, etc.). Ship immersion is authorised if such ships are first cleaned,

and all onboard hazardous substances/materials removed. The London Convention has been amended several times, in

particular in 1993. These amendments concern the phasing out of the dumping at sea of industrial wastes, incineration at sea,and the dumping at sea of radioactive wastes and other radioactive materials. The Protocol to the London Convention,

adopted in 1996 by the Contracting Parties, represents a major change of approach. The definition of "sea" is modified: until

then limited to marine waters, it now also includes the marine soil and subsoil. The lists of banned materials and tolerated

materials requiring a permit no longer apply. Indeed, the Protocol prohibits all dumping and incineration of wastes or matterat sea, with the exception of those listed in its Annex I: dredged material, sewage sludge, fish waste, or material resulting

from industrial fish processing operations, vessels and platforms or other man-made structures at sea, inert, inorganic

geological material, organic material of natural origin, etc. The Convention requires that studies be performed to addresswaste generation minimization and to evaluate carefully the alternatives to waste dumping at sea. The Protocol has not yet

entered into force. MARPOL Convention 73/78 is an international convention for the prevention of pollution from ships. This

combination of two treaties adopted in 1973 and 1978, provides an international regulatory framework for the prevention of

pollution from ships transporting oil (Annex I), chemical products in packaged form (Annex II) or in bulk (Annex III), as

well as from ship sewage (Annex IV), garbage (Annex V) and air emissions (Annex VI). The Convention entered into force

in 1983. Only its Annexes are compulsory. Certain activities are regulated according to their distance from the coastline

Towards a new international dismantling convention

The Q790 case illustrated the controversy surrounding the Basel Convention’s interpretation and its application to end-of-lifeships (CESM 2006; Greenpeace 2006). Debate, however, goes beyond the definition of “waste” (Moen 2008; Chang et al.

2010). While it is now agreed that a ship can be considered as waste, when exactly a ship becomes a waste is a question that

remains unanswered. Must there be manifested intention to discard the ship? While such intention is very apparent for state

ships or merchant ships that are abandoned or unfit for navigation following accidents at sea, this is not the case for the

majority of ships. Thus, the decision to dismantle a ship, as long as she is still fit to navigate and/or reparable, only becomesfinal once the dismantling contract is signed. Furthermore, the Basel Convention lays heavy responsibilities upon the waste

exporting State. However, as it is complex to determine when exactly the transfer begins, it is also difficult to identify the

exporting State. Moreover, the exporting State most often has no power over the ship owner. Furthermore, several studies

have concluded that the Basel Convention is not adapted to end-of-life ships. Indeed, the convention’s application is impeded

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in practice by several factors, one major obstacle being the limited dismantling capacity available in OECD countries

(insufficient yards, yards of insufficient capacity, access difficulties, lengthy waiting lists…). In addition, ship dismantling

activities bring economic benefits to the developing countries, as labour is cheap, people need to work, and the demand forraw materials is strong. Metal and equipment retrieval from end-of-life ships feeds these countries’ economies, which

explains why their dismantling sites are financially attractive (Knapp et al. 2008).

Debate concerning the Basel Convention’s interpretation and the non-legally binding nature of the main international

authorities’ directives has very clearly demonstrated the need for a regulatory framework adapted to ship dismantling. The

IMO’s Environment Council, convened on June 24th 2005, consequently pronounced itself in favour of the negotiation of alegally binding instrument within the IMO framework. A Convention was in preparation at the time of the SR1 project. This

convention should guarantee a level of protection equivalent to that enforced by the Basel Convention, whilst resolving the problems associated with waste transfers and with the Basel Convention’s application to global maritime economics.

The IMO Convention was expected to bring about the following improvements:

- Enforcement of regulations that should facilitate ship dismantling. These applied to the design and construction ofships, their operation, and their preparation for recycling (in particular the Green Passport requirement).

- Certification of the ship recycling facilities that respect environmental and human health standards.

- Establishment of an appropriate enforcement mechanism enabling flag, port and recycling States to control the end-

of-life process in a safe and environmentally sound manner.

This Convention was set up in 2009, the Hong Kong International Convention for the Safe and Environmentally Sound

Recycling of Ships. In the interim period until 2012, the European Union has defined a series of actions to be taken within theEU. These are presented in the «Commission Green Paper on Better Ship Recycling» (2007). The objective of this Green

Paper was to define precisely the ship recycling measures outlined in the EU’s Maritime Policy Green Paper.

The management of ballast waters were also a key subject (IMO 2004). Significant volumes of water had to be managed inaccordance with the existing regulations. The project used IMO regulations as basic roadmap: According to IMO resolution

A 868 (20), ballasts waters should be changed during international voyages. Despite this resolution was not recognized by

China and Cameroon, it was scheduled to change these waters during the final trip to the yard.All along the initial phases of the decommissioning project, the team faced the difficulty linked to the absence of a firm and

reliable legal structure so a specific set of requirements have then to be set up and approved by Partners in order to meet all

the expectations from a legal point of view and from implicated stakeholders (Table 1).

Stakeholders are of importance in the decommissioning of ships

The project’s stakeholders are persons, groups or organisations who can be impacted positively or negatively, either directly

or indirectly, by the project and/or can impact the project positively or negatively, either directly or indirectly. The number ofstakeholders is high, as ship dismantling raises a wide range of issues (economic, environmental and/or social). Stakeholders

are both international, like those concerned with the transboundary movement of waste (international organisms, NGOs, etc.),

and national or local (service sector companies, industry, local authorities, etc.). The international authorities responsible forthe regulations were also potential project stakeholders. Here are listed below some of the key stakeholders implicated all

along the project.The global ship dismantling industry: a positive stakeholder. Several recent studies including the Ship Dismantling and Pre-

cleaning Study performed for the European Commission and a report produced by the French Interdepartmental Committee

on the Dismantling of Civilian and Military End-of-Life Ships (Mission Inter-ministérielle portant sur le démantèlement desnavires civils et militaires en fin de vie), both performed in 2007 have drawn up inventories of the dismantling yards

currently available in OECD countries. There are yards in operation both in Europe (Belgium, Netherlands, Italy,

Lithuania…) and in other non OECD countries (Turkey, Norway, USA). European yards have limited capacity. Furthermore, both the accessibility and size of Europe’s naval yards limit the dimensions of the ships that they can receive. European yards

deal mainly with fishing boats and inland water ships, and deal marginally with small military ships and merchant vessels (up

to 150 m long and 10 to 12 m draft). There are several dismantling sites in the USA, however American legislation does notcurrently permit foreign ships to access these sites. The largest recycling capacity in the OECD was found in Turkey. There

are yards in Turkey that satisfy international management standards (ISO 9001, ISO 14001 and OHSAS 18001). However,

some European Union member states have expressed their concern regarding Turkish recycling procedures, as the voluntary

ship beaching often performed is not generally considered acceptable. Outside the OECD, most of the dismantling yards with

internationally recognised human health and environmental certifications are in China. China has worked hard to modernise

her yards, putting an emphasis on dry dock facilities. The Jiangsu, Zhong Xin and Shuangsui yards in particular haveupgraded their facilities and methods in order to satisfy Western environmental and occupational management standards (ISO

14001 and OHSAS 18001). Certifications have been delivered by various agencies, including the China National Institute ofStandardisation (CNIS). Indian dismantling yards have undergone a vast certification process, initiated by the Gujarat

Maritime Board. Indeed, the certification of 22 sites has been reported in the press. International Certification Services (Asia)

Pvt. Ltd has certified most of the yards. The RINA certification company has certified others. A few yards that already satisfy

the ISO 9001, ISO 14001 and OHSAS 18001 standards are investing in personal protective equipment and worker trainingand, following the example of the Shree Ram Vessel yard, are in the process of modernising their production tools (cranes,

mechanised shears). The yards also provide hazardous waste treatment (individual containers and equipment for asbestos

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disposal, waste storage in treatment centres). The Indian Supreme Court is examining the recommendations put forward by a

technical committee on the regulations that should be enforced in the Alang dismantling yards. Non-governmental organisations (NGOs): a powerful stakeholder. The Clemenceau affair demonstrated the interest taken by associations and NGOS in ship dismantling, and the resulting importance of transparent communication with these

stakeholders, and their involvement in dismantling projects. The action organised by Greenpeace, Ban Asbestos and the

FIDH in the Clemenceau affair is not a one-off occurrence. Since 1998, a number of international ship dismantling projects

have been singled out and contested. In February 2001, for example, the Sandrien oil tanker was immobilised in the port of

Amsterdam by the Dutch Environmental Inspection Services, as she was about to leave for Asia to be dismantled. The nextyear, the State Council of the Netherlands ruled that exporting the tanker, which contained hazardous materials including

asbestos within her structure, would violate European waste movement regulations (Basel Convention). This rulingestablished a precedent in the Netherlands. Greenpeace has continued to exert pressure on various countries including

Belgium (the Forthbank in 1999 and the Silver Ray in 2003), Turkey (the Sea Beirut in 2004), and India (the Hesperus in

2003). Other organisations also monitor the situation closely. The NGO Shipbreaking Platform is active on shipbreaking. The

NGO is composed by several NGOs. The main ones are as follows:- BAN, Basel Action Network, is focused on confronting the excesses of unbridled free trade in the form of “Toxic Trade” (trade

in toxic wastes, toxic products and toxic technologies) and its devastating impact on global environmental justice. Working at thenexus of human rights and environment, BAN confronts the issues of environmental justice at a macro level, preventingdisproportionate dumping of the world's toxic waste and pollution on our global village's poorest residents. Further, BAN

promotes sustainable and just solutions to our consumption and waste crises.

- Ban Asbestos is a network of local organisations monitoring anti-asbestos legislation where it exists and litigating for theabolition of asbestos where anti-asbestos legislation is lacking.

- Bellona Foundation is a multi-disciplinary international environmental NGO based in Oslo, Norway. Founded in 1986 as a directaction protest group, it has since become a recognised technology and solution oriented, environmental defender with offices ontwo continents. Altogether, some 40 ecologists, nuclear physicists, engineers, economists, lawyers, advisors and journalists work

at Bellona.

- European Federation for Transport & Environment, founded in 1989, is Europe's principal environmental organisationcampaigning on sustainable transport. T&E’s primary focus is on European policy and its work is supported by 45 NGO member

organisations working in 21 countries to promote an environmentally sound approach to transport. The T&E secretariat inBrussels works closely in various ways together with the European institutions, while member organisations have close contactswith national decision-makers and campaign at national level.

- FIDH, the International Federation of Human Rights, was created in 1922. It now includes 141 national human rights NGOs fromall regions of the world. FIDH has a generalist mandate and consequently works on all human rights be they civil, political,economic, social, or cultural rights. FIDH carried out fact-finding missions on shipbreaking in India and Bangladesh, which

resulted in the publication of a mission report in 2002 entitled ‘Labour Rights in Shipbreaking Yards in South Asia, Where do thefloating dustbins end up?’. In 2005 FIDH, Greenpeace and YPSA released a report entitled ‘End of Life Ships – The Human Costof Breaking Ships’.

- Greenpeace is an international non-governmental organisation founded in 1971, working on global and environmental problems.Greenpeace started its shipbreaking campaign by highlighting this environmental and human rights disaster in 1998. Since then

the environmental organisation has been working for a global solution be it through the Basel Convention, the IMO (InternationalMaritime Organisation) and the ILO (International Labour Organisation) as well as in the shipbreaking countries such as Indiaand Turkey.

- IBAS, the International Ban Asbestos Secretariat, is an independent body dedicated to the worldwide eradication of thecontinuing use of asbestos and the minimisation of dangers from asbestos products already within society. IBAS works to obtaina universal ban on the future use of all forms of asbestos. The organisation also provides information that will assist asbestosvictims seeking redress and financial compensation from employers, asbestos manufacturers, governments and others who may

have caused their diseases.

The NGO Robin des Bois is also an active NGO but it is not a member of the Platform on Shipbreaking. Created in 1985, its

objective is to bring together, both on a national and an international level, all people and corporate bodies wishing, by meansof non-violent actions, to participate in the protection of the environment and humanity, the defence of endangered species,

the safeguard of natural habitats, and the promotion of rational and equitable natural resource management. The NGO’s

ambition is not simply to protest, but to propose solutions. When able to, it provides voluntary assistance to citizens, and putsall its energy into upholding dialogue with all persons or corporate bodies. Since 1988, Robin des Bois has participated in

ministerial and interministerial working groups to carry its objectives forward in the places where decisions are taken. The NGO holds official positions in certain authorities, is member of working groups and has played the role of observer for three

international conventions. Robin des Bois has published, since 2006, a regular ship demolition information and analysis

bulletin entitled « alacasse.com ». The NGO is in favour of the development of dismantling yards in Europe, and the

improvement and consolidation of partnerships and bilateral agreements with Asian yards. Local stakeholders: In Cameroon the local stakeholders mainly consisted in Institutions such as:

- Société Nationale des Hydrocarbures du Cameroun (SNH) is a public institution directly attached to the Secretary-General’sservice of the Republic of Cameroon’s President. It is a financially independent industrial and commercial institution. Created in

1980, its mission is to promote and manage the interests of the State in the oil and gas sector. It manages the promotion,development and monitoring of oil and gas activities throughout the country, and works with international companies. Its head-office is located in Yaoundé.

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- Environment and Nature Protection Ministry (MINEP), created in 2005, MINEP is responsible for the development, applicationand evaluation of the government’s environmental policy. MINEP was implicated in the Basel Conventions setting up.

- Industry, Mines and Technological Development Ministry, is the authority that supervises the Total E&P Cameroun Company. Itmanages mining in the country and monitors oil industry activities. It participates in the Technical Committee and the OperationsCommittees, and is responsible for the technical management of both the administrative and security aspects of the oil industry’s

activities.

- Economy and Finance Ministry: The Direction Générale des Impôts is Total E&P Cameroun’s main correspondent with regards

to taxation. A Direction Générale des Impôts’ executive is Administrator of Total E&P Cameroun. This executive participates in

contractual negotiations and performs tax audits.- Total E&P Cameroun Partners (SNH, Pecten, an affiliate from Shell) were important local stakeholders who had to approve the

decommissioning strategy and associated costs.

Total E&P met with members of the identified stakeholders. At national level, the abandonment of the SR1 was performed

under the Basel Convention regulatory framework. The involvement of the MINEP was then very important. At the

international level, the project team members met the NGO Platform on Shipbreaking to present the project and welcomed

constructive criticism. The meetings took place in Paris and in Brussels during the performance of the project at keymilestones: at the beginning, before strategy definition and before SR1 left Cameroon. During these meetings, the project’s

advancement and potential modifications were presented, with positive feedback from the NGOs. The NGO Platform

representatives globally appreciated the incorporation of environmental and social aspects into the project. In the presence ofrepresentatives of the NGO and the FIDH, the strategy of decommissioning was welcomed. No objection was made to the

selection of a Chinese yard, but recommendations and advice were given. In parallel, the NGO Robins des Bois made several

articles and web releases about the project in their quarterly reports (2008, 2009, 2010a, 2010b). The project had only a

limited communication with the organisation.

Results and key findings

The Green Passport of the Serepca-1: a complete waste audit

Total E&P Cameroun had the Serepca-1’s Green Passport prepared prior to all interventions. As explained above, the

International Maritime Organisation (IMO) advocates the preparation of a Green Passport in its « IMO Guidelines on ShipRecycling», adopted in 2003 (Resolution A.962(23)). The passport provided an inventory of the potentially hazardous

materials present onboard, and this inventory was used to assist the planning of the ship’s dismantling. The passport was also

updated before the SR1 left Cameroon during the dismantling process following specific decontamination operations. Annex3 of IMO Resolution A.962 (23) that provides a Green Passport format was used as a model. The hazardous materials

inventory was split into three parts, which reflected the origin of the substances’ presence onboard:

- Part 1: ship design, construction and maintenance (potentially hazardous materials in the ship’s structure and in both

her operational and more domestic day-to-day equipment).

- Part 2: ship operation/exploitation (operationally generated wastes).- Part 3: the stores required for day-to-day ship life and day-to-day crew life (stores).

The Serepca-1’s Green Passport identified, localised and quantified the potentially hazardous materials presented in the

whole boat. The independent expert company, Tecnitas, consulting subsidiary of the Bureau Veritas firm, prepared the first

Serepca-1’s Green Passport in 2007, following an onboard ship audit performed from May 30 th to June 5th, 2007. Beforedecommissioning, a final audit was performed by another third expert Van der Poel (m.a.r.c BV)), a member of the

International Ship Recycling Association. This audit was ordered by the recycling yard in 2008 under supervision of Maersk

Ship Recycling Services, (now Sea2Cradle). The non hazardous waste consisted in all material in the rooms of the FSO: bed, bathroom equipments, TVs, computers, papers etc…

The hazardous wastes were as follows (Table 2):

- Tank bottom sediments (approx. 226 m3).

- PCB (Polychlorobiphenyls):

o Inside electric transformers (16 t).

o Transformers (35 t).

- Mercury (approx. 19 kg).- Fluorescent tubes (approx.1350).- Ionizing materials like fire detectors (approx.160).

- Sealed gas: refrigerant (approx. 180 kg), SF6 inside 31 switches.

- Asbestos: non friable inside materials (floor coverings 2500 m2, joints), potentially friable, inside the suspended

ceilings (approx. 100 m²) and partitions (approx. 900 m²), doors (approx. 40 doors), flex sleeves of ventilation ducts.- Hydrocarbons: lubricating oil (approx. 3 000 litres), hydraulic oil (approx. 2 000 litres), diesel (several litres).

A good knowledge about what and where hazardous materials on board especially asbestos was essential to prepare the

decommissioning works. All major risks on board were to be identified in order to avoid unexpected situations, such as

workers health unsafe situations, unexpected cleanup costs, delays in transportation, loose of cargo, and liability claims. This

knowledge is not only essential for ship owners or management, but also for other workers who may come into touch withhazardous materials on board. To anticipate these questions, specific surveys were performed to quantify the quantity of

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asbestos material and to ensure whether or not asbestos dust was present especially in the ceilings which could create specific

problems during dismantling. In controlled conditions, in one specific room where asbestos was present, samples were taken

to determine whether asbestos dusts were settled or not and whether asbestos dust could be generated during the removal ofceilings. The analysed samples and the monitoring by third expert showed that in all sample, asbestos was not detected.

The Serepca-1 decommissioning strategy

The precise knowledge of waste inside a FSO was a key parameter that helped to determine the best disposal strategy.

Selection of ship’s end-of-life disposal procedures. Total E&P Cameroun has envisaged several disposal alternatives for the

Serepca-1 tanker during the early phase of the project: 1. Sale of the ship as is, where is.

2. Conditional sale as is (the dismantling site being specified in sales contract).

3. Conditional sale following decontamination.

4. Agreement of a dismantling contract with a recognised dismantling yard.5. Immersion.

Determining which of these 5 alternatives ensured the best Human Health and Environmental protection was the first step. A

multi-criteria analysis was performed to this end, using the ELECTRE software, which allows comparative assessment of the

different alternatives (LAMSADE 1994). This involved the definition of selection criteria and operational parametersdefining the conditions in which one alternative is preferred over another:

External Technical Criteria

- Technical feasibility with regard to planning constraints.

- Feasibility with regard to international regulations.

- Public perception and social acceptability.Social Criteria

- Socio-economic benefits.

- Negative impacts upon populations (other than HSE risks).

- Social and occupational conditions of decontamination operations.

- Social and occupational conditions of dismantling operations.

HSE (Health, Safety and Environment) Criteria

- Environmental impact.

- Pollutant transfer and disposal conditions (other than for ballast waters).

- Ballast water management.

- Management of the metallic scrap.

The ELECTRE software evaluated and ranked each alternative. The result of the assessment was that the dismantling in a

naval yard compliant with international standards was the alternative which best respected environmental and social

requirements. Note that the scenario 5 was quickly discarded due to legal reasons.The selections of the dismantling site and of the waste management company in charge of removal, treatment and disposal of

the waste were parallel processes with lot of cross implications. Determination of the transfer to the yard strategy: manned or not manned? The final trip of such FSO was not an easy task

because she had no propulsion units: no rudder and no propeller. The removal of anchors was highly sensitive because

without any anchors, the SR1 needed to be maintained by tow, otherwise she became a high hazard to the surrounding

tankers and operational platforms. It necessitated then a precise coordination between several involved external teams. Her

transfer to the yard involved the use of one tug boat that had to be refuelled to reach final destination. The SR1 had to bereballasted and deballasted during her final trip according to IMO guidelines. A ballast water management plan was then

prepared. Then, it was necessary to maintain on board a small crew that had to live on the FSO. To maintain the living

conditions in key parts of the FSO, electricity, safety equipments, fire detection had then to be maintained until the yard.These necessary items influenced drastically the waste management strategy.

Selection of the dismantling site. The dismantling of the Serepca-1 involved the manipulation of hazardous wastes such as

PCB from transformers, friable and non-friable asbestos, mercury, “democking” residues from tank (hydrocarbon-impregnated sediments), ballast waters, ionizing fire detectors… A Green Passport was then prepared in order to list, localize

and quantify all hazardous materials onboard. Audits evaluated the ability of a number of naval yards to dismantle the ship

and dispose of hazardous wastes in conditions ensuring human health and environmental protection.

Total E&P set up a complete audit team to visit and assess the capabilities to dismantle the SR1. A selection of different

naval yards was proposed based on the following criteria:- A yard in the ship’s flag State: the Republic of Cameroon.- Yards whose operators spontaneously tendered to Total for the contract.- Yards included in the inventory provided in the European Commission Directorate General for the Environment’s

June 2007 « Ship Dismantling end Pre-Cleaning of Ships» final report.- Yards evaluated by implicated international organisations and having demonstrated a proactive approach in terms of

environmental protection, occupational safety and dialogue with the local population.

- Yards in different geographical zones (Europe, Africa, Asia) in order to compare dismantling processes and

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practices, etc. Countries dismantling the most ships are India, China, Pakistan and Turkey (only OECD member

country). The Basel Convention’s Guidelines seem to consider that human health and environmental protection is

sufficient only in China and Turkey.The audit team focused on the following criteria:

1. Site: location, type (beach, dry dock..), Industrial equipments, "Green" experience, technical aspects…

2. Safety: Access of the personnel, Certification of equipments, specific Safety (PPE, Procedures …), Emergency

(in and out of the yard), Permitting /procedures (confined space….)

3. Waste management: Asbestos (removal, confinement, PPE, Monitoring) PCB / Mercury / Refrigerant Gas /hydraulic oil, Storage, follow up…

4. Waste treatment.Several yards were then selected (Table 3). Amongst these yards, some were discarded due to technical aspects, other

retained for visit and audits (Table 3, Fig.2). Here is below the most representative findings of representatives’ yards

involved in the decommissioning of ships: the Leyal yard in Turkey, Harland & Wolff yard in Ireland, the Changjiang yard in

China and the Leela yard in the Alang Bay in India. The Harland & Wolff (H&W) yard’s dry dock was well suited to this

type of activity (easy access from all sides, control of potential environmental impacts during hazardous material removalfrom the hull as the dry dock is by definition a confined area, etc.). Furthermore, the yard complied with regulations, which

correspond to European standards. This guaranteed the implementation of high waste management and occupational safety

standards. Waste treatment contractors complied with British regulations, and so conformed to European standards. Thanks

to its experience in the construction, transformation and repair of large offshore or naval structures, the yard was skilled inthe management of large projects, relying on a network of subcontractors with the required ability to execute a project.

However, H&W’s tanker dismantling know-how was very limited, and due to the absence of onsite or nearby treatmentfacilities, waste had to be transported by sea to England. Dismantling operation would take about one year. Finally, the site

had just one dry-dock for dismantling, and cannot therefore dock the Serepca-1 securely until this dock becomes available,

should the dock be occupied upon the ship’s arrival.

The Leyal yard located in Aliaga is surrounded by small companies dismantling ships directly on the beach. Dismantling

operations combined both afloat and land-based technologies. Tackles pulled the ship onto a waterproofed work area. As

there was almost no tidal zone, the delimitation between the dry working area and the sea was clear-cut. This normallyreduced the risk of debris discharged into the sea. In addition, during visit it was observed floating booms surrounding the

ship being dismantled, to control any accidental discharges of oil. The work area was equipped with a wastewater and storm

water drainage system. Cranes were used to displace large sections cut out from the ship to the onland cutting and materialsorting area, where structures were re-cut to enable their transportation by truck. Metals were then sent to a nearby

steelworks. Yard personnel were equipped with hardhats, steel-toed boots and gloves. Cranes also transported the personnel

that worked in the elevated areas of the ship…. These personnel were equipped with harnesses. Prior to each dismantlingoperation, onboard air quality and radioactivity were evaluated first by Leyal, and then by a team of certified, independent

experts. This team of experts established an inventory of the hazardous materials still present onboard and defines the wasteextraction and disposal procedures to be followed. The company had an authorisation to treat wastes including asbestos,

PCBs and hydrocarbons. The asbestos waste was stored in airtight packages in a delimited and marked area. Workers dealing

with asbestos were equipped with full-face cover-pressurised masks and full-body coveralls. The yard had 3 mobilesdepressurised chambers that provided airlocks between contaminated and non-contaminated zones. Contaminated zones were

confined (sealed windows, access through an airlock…). In addition, atmospheric concentrations of asbestos particles were

monitored. Asbestos removal procedures complied with the German TRGS 591 regulation. Hazardous wastes were stored indedicated concrete-capped areas. Liquid wastes such as oils and hydrocarbons were stored in drums on a concrete-capped bay

equipped with a drainpipe connected to an oil separator. Hazardous wastes were treated by nationally certified companies; in

particular the Izaydas household and hazardous waste incineration plant. Certified transportation companies managed thehazardous waste transportation. Finally, the site was awarded ISO 9001, ISO 14001 and OHSAS 18001 certifications in

2006. One weak point like the H&W’s yard was that it only handled one dismantling operation at a time. The SR1 would

need to wait for the yard to be available. The Leyal naval yard was then found to be apt to dismantle the Serepca-1 in a

manner respectful of the environment and in relatively good working conditions. However, safety improvements needed to bemade, in particular to vessel access, as access was poorly secured and inadequate in the case of an emergency evacuation.

Leyal clearly committed to retrofit its site and improving environmental and occupational conditions. Lastly, the length of thedismantling process was estimated at 1 year.

The Changjiang shipbreaking yard in China had a long experience to dismantle boats at quay. The company was created in

1998. The yard had a partnership with Maersk Recycling signed. The Maersk team on site was dedicated to the dismantlingof Maersk’s end of life chips but also aimed at providing supports to foreign companies. The yard operated 4 quays, with a

mean demolition capacity of 8 to 10 ships, each weighing about 20000 tons. The yard’s access canal was over 9 m deep, with

50 m air clearance (headroom) above the water. The yard dismantled about 20 ships a year, and could provide various wasteelimination services using specialised contractors. Chinese regulation did not impose an authorisation procedure for asbestos

removal. The naval yard removed asbestos using the following equipments: disposable coveralls and masks fitted for

asbestos removal, a mobile Dutch decontamination air lock given by Maersk and changing rooms equipped with showers.

However, the clean area and the contaminated area were not physically separated, as a room connected both areas. The

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threshold value for worker exposure to asbestos in China was 0.8 fibres per cm3 (0.1 in Europe). Airborne asbestos fibres

were not measured. Asbestos wastes were conditioned either in double heavy-duty polyethylene bags, or coated with plastic

and loaded onto pallets, and then sent to the Wuxi hazardous waste landfill. Hazardous waste was stored in closed, identifiedand well-maintained buildings. Third experts mandated by Total E&P performed audits of the waste disposal facilities. The

naval yard provided good ship deconstruction working conditions. Dismantling occurred at dockside, which facilitates the

access to the ship. The yard was large, clean and had an onsite incinerator and wastewater treatment system. Dismantling was

usually completed in a relatively short time (4 months). The yard was certified ISO 14001, 2004. Furthermore, the scale of

the yard and docks guaranteed that the Serepca-1 could be docked until she was dismantled. Audits concluded that someimprovements were needed in respect of the asbestos removal procedures. These includes: 1) the presence of a HSE

supervisor throughout the dismantling process, 2) the confinement of the asbestos removal zone, placed under negative pressure, 3) the use of assisted breathing filtering equipment and the use of European standards in term of worker exposure to

asbestos, 4) the redesign and modification of the changing room area and the measurement of airborne fibres by a certified

laboratory during works. A major issue concerned the PCB management in China. None of the visited incinerators were fitted

to treat these type of waste; no technology was identified to treat the transformers themselves even after cleaning. Finally, the

law did not authorize to import PCB in China. The yard was selected for bidding.The Leela Ship Recycling yard is located in India in the Alang bay. It is a site of a width of about 87 meters for an equivalent

length. It was located directly on the beach surrounded by numerous sites. The entry consisted of offices and technical

buildings. The storage of dangerous waste was in a concrete building with a roof divided in 5 parts. Each part was dedicated

to a defined type of product: asbestos / radioactive products / rubber / residues of painting / insulating wool. In the celldedicated to asbestos, some bags remained (simple) plastic blacks sealed by an adhesive tape identified with the mention

“asbestos”. The site was equipped with an incinerator potentially reaching 1200°C equipped with a 20m height chimney. Thisincinerator was installed in an old steel container. About 0,4 m3 could be burned by one loading. No drainage system was in

the storage section that stored the barrels of oily waste or toxic waste on standby for evacuation. The means of lifting

observed on site were very limited and consisted into an old crane (capacity of 35 T) and a telescopic crane van. A tractor

with trailer was used to convey the waste, equipment etc. The mechanical capacity was supplemented by 3 winches which

seemed simply lying on the sand. These winches allowed approaching progressively the boats on the beach and taking part in

the displacement of the blocks of steel to the cutting zone. The site had a partnership with an American company for theremoval of asbestos. This collaboration resulted in trainings for the site staff. An inspector visited the site before and after the

depollution to give the green light for the following phase. Once materials containing asbestos were removed from the boat,

they were transported in the dedicated area. There, under more or less effective controlled conditions of containment,asbestos was dissociated from the equipments with the help of a surface-active agent and put in plastic bags. These bags were

then transported to the landfill of the Alang area (located at 3 or 4 km from the yard), owned by GMB but operated by a

private contractor, GEPIL (Gujarat Enviro Protection Infrastructure Ltd). The landfill site was divided in three zones thataccommodated all type of waste. These areas of an approximate surface of 3000 m² had plastic liners for underground

protection. The rainwater could be collected at the bottom of the pit in a tank. No treatment facility for hazardous waste andinert waste were in the vicinity of the yard. No children or women in rags were observed during the visit on the sites and

many workers were equipped with a minimum of PPE. Asbestos was not burned on the beach. And, it was certain that

improvements took place in these last years. But in term of safety and environment, the practices still remained in 2007 below an acceptable level. No adequate means for the removal of materials (particularly of dangerous materials) between the

boat and the site where no possible access for the crane, no solution for a safe treatment of the PCB, mercury, cooling agents

etc.., the landfill for asbestos was too small and associated techniques were not adapted for a safe removal of asbestos for the personnel, the removal of large steel parts was performed by a non-controlled fall on the beach, lack of prevention of a

potential pollution of the beach; all these findings cannot be improved in a short period; The yard was then not selected. The

visits and audits pre-qualified, then, 3 yards (Figure 2): the Leyal yard in Turkey, Harland & Wolff yard in Ireland and the

Changjiang yard in China. The ELECTRE multi-criteria analysis tool was also used in parallel to determine which of theseyards best fulfil the technical, environmental and social requirements involved in the dismantling of a ship such as the

Serepca-1. The following criteria were selected

Environmental Criteria- Environmental protection measures.- Impact upon natural resources in the event of an accident.

- Experience and « green-experience ».

Technical Criteria

- Feasibility with regards to planning constraints.- Facilities and equipment.

- Equipment certification and maintenance.

Hygiene and Occupational Safety Criteria

- Worker access to ship.

- Occupational safety.- Emergency management within the naval yard.

- Emergency management outside the naval yard.

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- Work permits and procedures.- Asbestos worker protection.

Waste Management Criteria

- Asbestos waste confinement and management.

- PCB removal.- Mercury removal.- Refrigerant gases removal.

- Hydraulic oil removal.- Asbestos treatment.

- PCB contaminant treatment.- Mercury treatment.- Refrigerant gases treatment.

- Ionising fire detector treatment.

- Paint treatment.- Waste traceability.

- Naval yard treatment facilities.

The multi-criteria analysis ranks the Changjiang naval yard in China the highest; however the three naval yards were quite

close in rank. Discussions were then handled between the three yards to evaluate different waste removal scenarios (Fig. 2)

and to ascertain some critical findings such as how to improve the safety in the Turkish yard, or how to improve asbestosremoval in China. The two yards aimed at fulfilling Company recommendations. Based on a revised and optimal waste

management strategy, technical clarifications were then given by the bidders. By integrating the technical and commercial proposals, the Changjiang yard in China was then awarded.

Selection of the Waste Management Company. The initial objective of the Project was to perform a full offshore depollution

including the complete asbestos removal of the boat. 24 international companies were identified and contacted based on their

recognized capabilities to undertake such a work. Only 7 companies answered to the pre-qualification questionnaire and 17

companies declined. 4 companies were prequalified; 2 submitted a proposal to the Call for Tender, 1 declined, the others

made a joined proposal. Total E&P Cameroun organized site visits of the SR1 with the 2 bidders that passed successfully thetechnical aspects. The opening of the technical and commercial proposals showed that the full removal of asbestos could not

be safely undertaken offshore. The mitigations proposed by the bidders were technically almost impossible and lead to an

overall unrealistic budget. In parallel of this CFT process, the selection of the decommissioning yard was ongoing (see paragraph above) and results influenced the waste management strategy (Table 4). By integrating the findings of the audits of

decommissioning yards, the approved transfer strategy and the capabilities of waste management companies to perform such

a work in Cameroon, it was then decided that some waste were removed and treated in Cameroon, other were removed and

exported to Europe and finally, the remaining waste remained on board until the final yard to be removed and treated in thecountry (Table 4). At the end of CFT process, the French Sita company specialized in waste removal, treatment and disposal

was awarded. In Cameroon, Cometal Cpy removed the tank bottom sediments that were transferred and burned in a cement

factory after compatibility test.

Decontamination & Basel Convention n°1 to export to Europe some of the identified hazardous waste. Expert evaluations

revealed that performing an initial, optimal decontamination of the Serepca-1 prior to its export for dismantling was the besttechnical (facilities…) and regulatory (Basel Convention) approach. Ship decontamination planning was made possible

thanks to the ship’s Green Passport, and the consultant’s initial environmental audit of the ship. The Serepca-1 was partly

decontaminated offshore prior to towage. Sita employees with the help of local compagny’s workers removed, conditionedand safely stored hazardous materials on Total E&P Cameroun onshore Wouri base, in the interim prior to export to

European hazardous waste disposal facilities. Offshore decontamination had associated environmental risks, in particular for

the natural marine environment. The main hazard resided in waste transfer from the Serepca-1 to the tugboats navigating to

and from the port. Security measures were taken for the manipulation of hazardous products. Dedicated drip pans and lifting

tools were constructed in Cameroon for the transfers. In parallel of the works, Total E&P Cameroun teams with Sita teams prepared the needed documents for the export of waste. Once the several transfer notification documents (for the waste to

Belgium, and for the waste for France) had been approved by the various competent authorities (State of export, State of

import and States of transit), all removed wastes except tank “democking” residues (hydrocarbon containing mud andsediments) were exported to Europe to specialised treatment facilities (Table 5).

Decontamination & Basel Convention n°2 to export to China the hull containing some waste. In parallel of the waste

transfer to Europe, prior to towage, the Serepca-1 was granted a Cleaning and Gas Free Certificate, as well as authorisation

from all involved parties to leave Cameroonian territorial waters, in compliance with the Basel Convention. Furthermore, the

transformers with PCB and mercury decontamination of the ship were notified to authorities. Towage started when the

Chinese authorities approve the ship’s import conditions, as required by the Basel Convention.

Preparation of the SR1 for final trip, demooring, towage and arrival in China. Prior her departure, the SR1 had to be

prepared for her final destination. As some crew were maintained on board at departure until Cap de Bonne Esperance and

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from Singapore to the China; it was necessary to maintain living and operating conditions including electricity, safety

equipments including fire detection and fire fighting capabilities. In addition, as ballast waters had to renew three times,

pumps needed to be operational. As all transformers were removed, a new autotransformer without PCB was installed. Thetowing specialist Svitzer towed the ship, once her 11 moorings had been removed. Three tugs were necessary for the

demooring operations while one tug was used for towage. On the 18/03/2009, the SR1 final trip to China started. An Argos

beacon placed onboard the tug, emitted a signal each hour, so that the Serepca-1’s itinerary was followed continuously from

the Cameroonian coast to the Chinese naval yard. Total E&P Cameroun remained the ship owner until her arrival at the

Changjiang naval yard, upon which the ship became naval yard property. The objective here was to give insurance that theship would not be resold in a third party country during ship transfer. Three ballast water exchange operations were

performed during the trip. Towage lasted 105 days, with a port of call in Singapore to refuel the tug. The ship arrived inChina waters at the end of June 2009 but due to a typhoon and bad weather conditions, she could not enter the Yangtze River.

Finally, with the assistance of 5 more tugs, the main tug towing the SR1 started to enter the Yangtze River on the 02/07/2009.

On the 03/07/2009, the ship arrived in Jangyin. Upon the ship’s arrival, an inspection was carried out to verify ship

compliance with notification documents and ballast waters were sampled for analyses on the 26/08/2009 (Table 6).

The Serepca-1 decommissioning operations

Procedures for final decontamination and dismantling operational in the naval yard were in the ship recycling plan. Themajor steps of the dismantling are summarised as follows:

1. Upon the Serepca-1’s arrival, all material other than steel was removed from the ship. This included: furniture,

insulation material, asbestos, recyclable equipment, the residual fluids in piping, etc. Prior to ballast water discharge, biological and chemical analyses were performed after chlorine treatment in order to eliminate the risk of

introducing invasive species with the ballast waters (Table 6).2. The ship was cut up into several sections that were laid ashore in designated metal cutting areas. Metal cutting did

not begin until an inspector validated removal of all materials, as specified in operational procedure.3. During this time, materials were conditioned and sent to the appropriate storage or recycling units as defined in the

contract. These facilities were previously audited by third party experts for Total E&P Cameroun.

4. Waste traceability: The naval yard managed waste transfer and disposal, and provided the certificate delivered by

the various subcontractors at each step (transport, reception, and disposal).5. In order to ensure that this phase unfold in compliance with international recommendations and best practices,

Maersk Recycling team represented Total E&P Cameroun on site to assess that dismantling conditions fulfilled the

terms of the contract and reported on a regular basis to Total E&P Cameroun.6. Asbestos removal was supervised by independent professionals: specific trainings were delivered prior the work

then independent laboratory surveys ensured that the conditions for working and asbestos removal respected the

defined European standards

Asbestos removal training was performed on the 9th

2009 by Mr. Marc van de Poel of Sloopservice (Arnhem, The Netherlands). After theory, workers went to the SR1 to identify all asbestos containing materials (ACM) which wereidentified and marked in bold red spray paint thanks to the green passport results. All loose items were removed from the

vessel (furniture, flooring, …..). After this pre-cleaning phase, all the non-ACM insulation in bulkheads and deckheads was

removed. During this time, preparations were made for ACM removal. It started on the 08/08/09. Access to the vessel was

limited to the asbestos removal team wearing full protective clothing and all windows and outside doors were sealed. A 3chamber wooden cabinet fitted with the fans and filters was placed at both Port and Stdb main accommodation access doors.

This acted as the airlock and also kept the area of both stair wells under pressurized. Air testing was carried out by ETSTestconsult Ltd of Hong-Kong. Air monitoring samples were sent every day to Hong-Kong for analysis and results sent by

return. The ACM panelling in both stair wells was carefully removed and edges sealed with tape. These panels were the

stacked and sealed in double plastic layers. After both stairwells were cleared, new air lock was created at the entrance to the

ECR and panelling removed as per accommodation. The removal of the ACM was completed on 8 th September; it took about

40 days to remove the asbestos. Cleaning of non ACM continued until 13th September, then cutting started until the

26/10/2009. The implicated workforce consisted of 50 workers for pre-cleaning, around 10 workers for ACM removal and 80to 100 workers for steel cutting on ship and on site. On the 16/12/2009, the representatives of Maersk Recycling and of the

yard met together in Total headquarters in Paris to celebrate the end of the decommissioning of the SR1.

Conclusions and perspectives

Dismantling is the most sustainable process, as the materials contained within the ship, such as steel, can be retrieved and

reused. Natural resources can therefore be preserved and recycled and reclamation encouraged. Potential impacts were

reduced by the decontamination operations performed prior to towage thanks to the green passport audits. Though it wasunlikely that the Serepca-1 might sink during towage, the possibility was considered. Environmental impact could be

considered lowered since the most hazardous materials have been removed from the ship. The audits performed throughout

the project helped to significantly reduce environmental impacts. The environmental skills of all the removal, disposal anddismantling contractors were measured. The use of Basel Conventions ensured transparency in the whole abandonment

process. The Serepca-1 underwent preliminary decontamination prior to export and dismantling, in compliance with the

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Basel Convention. Hazardous waste management conditions have been designed to minimise environmental impact. Indeed,

the subcontractors selected for ship decontamination have proven their ability to dispose of wastes following certified and

environmentally monitored procedures. Waste treatment facility atmospheric emissions, effluent discharges, etc. in each caserespect applicable standards. Finally, as long as all operations (waste removal, waste treatment, dismantling, etc.) were

performed using existing infrastructures, they could be integrated into existing activities. Social impact could therefore be

considered positive as employment was maintained as long as possible and/or created. As long as contractor occupational

health and safety measures complied with international standards, human health risks could be kept under check.

Total E&P faced then a significant challenge in the decommissioning of the SR1. Reputation is of great importance in suchan abandonment project because the most important NGOs are implicated in the end of life ships. No one has forgotten how

the Brent Spar or more recently the Clemenceau abandonments turned out in highly emotional and uncontrolled situations.But by adopting a step wised approach, by engaging with the Ship Breaking Platform NGO through a constructive and

regular dialogue, by adopting the recommended best practices, the SR1 decommissioning project was a success at all levels.

Acknowledgements

Many people have contributed to this project and, whilst the following list is not exhaustive, it is representative of the

diversity of these contributions. The authors would therefore wish to thank all personnel met during the visits of yards. In

particular all the listed persons below have contributed to the success of the abandonment of the SR1 in particular:

Mrs Ingvild Jenssen from the NGO ShipBreaking Platform, Mr Li Hongwei and M. Yan Zhiping from ChangjiangShipbreaking Yard, Mr Kam Thomson from Maritime Delivery, Mr Wouter Rozenveld, M. Frank Fox, M. Wang Hua and

Mrs Shuk Mei Liu from Maersk Ship Management, Mrs Anais Guillou and Mrs Sophie Canovas from Agilon, Mr Thierry

Rojouan from DV Offshore, Mr Gilles Thomas from Giant Marine (Svitzer), Mr Jacques Corby and Mr François Lejustefrom Tecnitas, Mr Jean-Jacques Morge, Mr Yves Curtil and Mr Anthony Bosh from Sita, Mr Patrick Abijou from NeptuneVision, Mrs Claire Sauvaire from Elephant at Work, Mr Olivier Dubois from UGGC & Assoils, Mr Patrick Pelissie from

Apave, Mr Xavier Collet from Sogreah Magelis China, Mrs Christine Bossard from Robin des Bois, Mr René Quéau and its

crew team from the SEREPCA-1, Mr Bayiha Kodock, Mr Remi Boiton, Mr Benjamin Fabre, Mr Jacques Jutten, Mr Jean-Marc Mbila, Mrs Aurelie Clave, Mr Samuel Billong Bisseck, Mr Alain Messie, Mr Nicolas Tortelli, Mr Jean-Claude Vachet,

Mr Jean-François Lassale, Mr Hugh Brumpton, Mrs Sybille Fioroni, Mrs Catherine Sutton, Mr Laurent Cazes, Mr Jean-

Marie Perdu, Mr Louis Bon, Mr Xavier Ecomard, Mr Thierry Monmont, Mr Marcus Moore, Mr Marc Somon, Mrs Christiane

Eygun, Mr Jean-Michel Courrandier, Mr Mr Jacques Mine, Mr Michel Grandprat, Mr Hervé Lacamoire, Mr Roger Camps,

Mr Jean-Yves Durieux, Mr Jean-François Vidalie, Mrs Pascale Kromarek from Total E&P Cameroun and Total E&P SA.

References

Basel Convention on the Control of Transboundary Movements in Hazardous Wastes and Their Disposal. 1989. Adopted 22

March 1989, 28 ILM 657 (in force 2 May 1992), Geneva, CH; United Nations Environment Programme (UNEP).Available at: <http://www.basel.int>.

Centre d’enseignement supérieur de la marine (CESM). 2006. Brève marine n°39 : Ex- Clemenceau : en route pour l’Inde.

Chang, Y.C., Wang, N. and Durak, O.S. 2010. Ship recycling and marine pollution. Marine Polution Bulletin 60: 1390-1396.

Commission of the European Communities. May 2007. Green Paper on Better Ship Dismantling. COM (2007) 269 final,Brussels; 2007, 17pp.

Hamzah, B.A. 2003. International rules on decommissioning of offshore installations: some observations. Marine Policy 27:

339-348.

COWI, HHI. 2007. European Commission Directorate-General for the Environment. June 2007. Ship Dismantling and Pre-

cleaning of Ships. 172pp.

DNV, Appledore International. 2000. Commission of the European Communities. Technological and Economic Feasibility

Study of Ship Scrapping in Europe. Report n°2000-3527, 117pp.

DNV. 2000. Technical Report DNV RN 590. Decommissioning of Ships - Environmental Standards - Ship BreakingPractices /Onsite Assessment Bangladesh, Chittagong. Report n°2000-3158, 74pp.

Environmental Protection Agency. Summer 2000. A guide for Ship Scrappers- Tips for Regulatory Compliance. Reportn°315-B-00-001, 261pp.

Greenpeace. 2006. The Clemenceau Case: Potential Hazardous Material Assessment. Report n°2006-1010, 27pp.

Available at : <http://www.greenpeace.org/international/Global/international/planet-2/report/2006/2/the-clemenceau-case-

potentia.pdf>.

International Labour Organisation. 2004. Safety and Health in Skipbreaking: Guidelines for Asian Countries and Turkey.

Report n° MESHS/2003/1, 113pp.

International Labour Organisation, Aage Bjørn Andersen. February 2001. Worker Safety in the Shipbreaking Industries.,

Report n°WP.167, 70pp.

International Maritime Organization. 2003. IMO Guidelines on Ship Recycling (Res A962 (23)) London, UK: 5 December

8/13/2019 Spe 157017


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2003. As amended by IMO Resolution A.980(24). Amendments to the IMO Guidelines on ship recycling. London, UK, 1

December 2005, Publication n° I865E.

International Maritime Organization. 2004. Guidelines for the Development of Ship Recycling Plans (Circ 419).

International Maritime Organization. 2004. International Convention for the Control and Management of Ships' Ballast Water

and Sediments.

International Maritime Organization. July 2005. Implementation of the IMO Guidelines on Ship Recycling (Circ 466).

International Maritime Organization. July 2005. Promotion of the Implementation of the Guidelines on Ship Recycling (Circ.467).

International Maritime Organization. December 2005. Amendments to the Guidelines on Ship Recycling (Res A980 (24).

International Maritime Organization. December 2006. Ship Recycling - Developments and Issues.

Jézéquel S. and Déniela D. 2009. Epaves coulées, un bien pour la mer ? AE2D : Agir pour l’environnement et ledéveloppement durable. [Online]. [Consulted on April 24th 2009]. Available at: <http://www.ae2d.infini.fr>.

Knapp, S., Kumar, S.N. and Remijn, A.B. 2008. Econometric analysis of the ship demolition market. Marine Policy 32:

1023-1036.

LAMSADE Paris Dauphine University - Research Unit n°825 in association with the Centre National de Recherche

Scientifique D.Vallée, P.Zielniewicz. July 1994. Electre 3-4, Version 3.x, Methodology, Volume 1, Document 85.

MEPC 56/3/22. Recycling of ships. Examination of the practical of the draft of the international convention for the safe andenvironmentally sound recycling of ships, submitted by the United Kingdom. IMO, London; 2007.

Moen, A.E. 2008. Breaking Basel: The elements of the Basel Convention and its application to toxic ships. Marine Policy 32:1053-1062.

Neser, G., Kontas, A., Unsalan, D. et al. 2012a. Polycyclic aromatic and aliphatic hydrocarbons pollution at the coast ofAliaga (Turkey) ship recycling zone. Marine Polution Bulletin 64: 1055-1059.

Neser, G., Kontas, A., Unsalan, D., et al. 2012b. Heavy metal contamination levels at the coast of Aliaga (Turkey) ship

recycling zone. Marine Polution Bulletin 64, 882-887.

Robin des bois. 2008. Bulletin d'information sur la démolition des navires, September 2008, 18 pp, n° 13, du 7 juin au 21

septembre 2008, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_13.pdf>.

Robin des bois. 2009. Bulletin d'information sur la démolition des navires, April 2009, 37 pp, n°15, du 1 janvier au 3 avril2009, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_15.pdf>.

Robin des bois. 2010a. Bulletin d'information sur la démolition des navires, Janvier 2010, 37 pp, n°15, du 25 septembre au 31decembre 2009, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_18.pdf>.

Robin des bois. 2010b. Bulletin d'information sur la démolition des navires, Juillet 2010, 37 pp, n°15, du 5 avril au 1 Juillet

2010, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_20.pdf>.

Secretariat of the BASEL Convention - United Nations Environmental Program. 2003. Technical Guidelines for the

Environmentally Sound Management of the Full and Partial Dismantling of Ships. Basel Convention series/SBC No.

2003/2, 112pp.

Tewari, A., Joshi, H.V., Trivedi, H. et al. 2001. The effect of ship scrapping industry and its associated wastes on the biomass

production and biodiversity of biota in in situ condition at Alang. Marine Pollution Bulletin 42: 462-469.

UNEP. United Nations Environmental Program. 1992. Basel Convention on the Transboundary Movement of Hazardous

Wastes and their Disposal, adopted at the Conference of Plenipotentiaries on March 22nd, 1989, 126pp.

UNEP. Legal aspects of the full and partial dismantling of ships: Comments provided by Parties and others. Geneva, CH:

UNEP; 18 October 2004. Publication no. UNEP/CHW.7/INF/10/Add.1, p. 6. Available at:

<http://www.basel.int/meetings/cop/cop7/docs/i10a1e.pdf>.

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Fig. 1 - Drawings and photo of the Serepca-1.

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0

10

20

30

40

50

60

70

80

90

100

%

Yards

Waste treatment

Haz.waste removal

Safety

Site

? ? ? ? ? ? ?

Leela Changjiang Leyal Harland &Wolff

Fig. 2 - Results of the different evaluations of some visited yards for the decommissioning the SR1 ( : 100% waste

removal scenario at the yard ●: the new optimized waste management scenario (depollution offshore), : the new

optimized waste management scenario + HSE improvements from yards – (H&W had no possible area for more

improvements since its reached the best score i.e. 100)).

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TABLE 1 - SR1 PROJECT STANDARDS, IMPLICATIONS AND DELIVERABLES

Projects Standards Implications & Deliverables

1) SR1 hull was considered as a waste Basel conventions setting up

2) Green passport(s) has to be set up by third parties experts Field surveys by experts3) A Ship Recycling Plan had to be written Expertise and experience

4) Decommissioning yards had to fulfil HSE standards Audit, CFTs

5) Decommissioning yards had to demonstrate their willing to improve their way ofworking if discrepancies were pointed out during audits

Performance and positive attitude

6) A reliable and complete understanding of the waste management streams had tobe set up before any field works

Audits, reliability, Basel Conventions, CFTs,supervision

7) A Total E&P representative had to be present all along the dismantling phases toensure that the SR1 decommissioning was done in a sound way as per approvedspecifications

Yard acceptance, supervision

8) A stakeholder engagement had to be implemented through a positive andconstructive dialogue

Credibility, boldness, transparency

TABLE 2 - MAIN SUBSTANCES POTENTIALLY DANGEROUS IN THE SEREPCA-1

Pollutants Support Quantities

Asbestos containing material

Poop deck partition walls andsuspended ceilings

Approximately 960 m²

Flooring Some areas of flooring

Doors Approximately 40 doors

Ventilation system air trunking junction device

In all ventilated rooms

Paint additives

Grey paint on partition walls andbeneath poop deck bridges

(Lead)

Minimum 1800 m² (450 m² on 4 bridges)

Pain inside the front bridge Approximately 1800 m²

PCBs Askarel electrical transformers Approximately 10 tons

Gas

Refrigerants (R12/R22) Approximately 200 kg

CO2 Over 160 bottles

Sulphur Hexafluoride SF6 31 bottles

Mercury Measurement System Less than 10 kg

Radioactive substances Fire detectors Over 160 detectors

Tank bottom sludge Tanks Estimated 170 m3 (approximately 5 cm thickness)

Ballast waters Ballast waters 18 306 m3

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TABLE 4 - SR1 FINAL WASTE MANAGEMENT STRATEGY

Type of waste Management: Fate / Treatment / Location

Tank bottom sediments Removed offshore, shipped to Wouri base and incinerated in Cameroon

PCB Removed offshore, shipped to Wouri base and shipped to Europe for treatments

Mercury Removed offshore, shipped to Wouri base and shipped to Europe for treatment

Ionizing materialsPartially removed offshore , shipped to Wouri base and shipped to Europe for recycling

Partially kept to maintain the FSO operational during transfer, treated in China: transfer to theJiangsu Radioactive Environmental Monitoring Management Station

Sealed gasPartially removed offshore , shipped to Wouri base and shipped to Europe for incinerationPartially kept to maintain the FSO operational during transfer, treated in China (Extraction andincineration with smoke treatment) at the Wuxi facility

AsbestosRemoved at quay in China according to defined procedures in line with European legislation /landfilled in the Wuxi hazardous waste facility, in double heavy duty polyethylene bags

HydrocarbonsRemoved at quay in China: storage in special tanks, transportation to specialized subcontractor’sfacility for sale for reuse; possibly Reuse for energy reclamation by incineration

TABLE 5 - WASTE MANAGEMENT STRATEGY FOR THE WASTE EXPORTED TO EUROPE UNDER BASEL CONVENTIONPROCEDURE

TypeQuantityRemoved

Units Removed by Treated by Reception siteDisposal/Recycling

facilitiesType of process

Sediments 226 m3 COMETAL CIMENCAMFIGUIL

CameroonCIMENCAMCameroon

Incorporation incement process

PCB 16318 Kg SRA SAVAC SRA SAVAC

INDAVER

Anvers, Belgium

INDAVER

Anvers, Belgium Incineration

Transformers 34732 KgORTEC S.I.SRA SAVACFriedlander.

SRA SAVACSITA DecontaminationGrimbergen Belgium

SITA DecontaminationGrimbergen Belgium

Decontamination withsolvent extraction and

recycling metals

SF6 sealedgas switches

167 Kg SRA SAVAC SRA SAVACLRG

Lyon, FranceLRG

Lyon, FranceIncineration

Refrigeratingsealed gas

1 Bottle SRA SAVAC SRA SAVACLRG

Lyon, FranceArkemaFrance

Incineration

Fluorescenttubes

177 Ind. SRA SAVAC SRA SAVACSCORI

Frontignan, FranceLABOSERVICES

Givors, FranceRecycling (center

RECYCLUM)

Mercury 14.6 Kg SRA SAVAC SRA SAVACSCORI


Givors, FranceRecycling

Ionising firedetectors

82 Ind. SRA SAVAC SRA SAVACSIEMENS Building

TechnologiesBuc, France

SIEMENS buildingTechnologiesBuc, France

Recycling

Hydraulic oiland lubes

65 Kg SRA SAVAC SRA SAVAC SCORIFrontignan, France

- Heat valorisation

Batteries 470 Kg SRA SAVAC SRA SAVACSCORI


Givors, FranceRecycling

Acids solid &liquid

109 Kg SRA SAVAC SRA SAVACSCORI


Givors, FranceNeutralisation

Paint wastes 18.5 Kg SRA SAVAC SRA SAVACSCORI

Frontignan, France- Incineration

Sampling gascylinder

14 Cylinder SRA SAVAC SRA SAVACSCORI

Frontignan, France- Incineration

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TABLE 6 - SOME KEY EVENTS BEFORE AND AFTER THE DEPARTURE OF THE SR1

Year Date Events

2007

April End of crude oil storage operations

May - July Green Passport: survey and report

August - OctoberMarine Environmental Baseline Study: survey and report

Transfer of oil to Kingsway FSO,

September-December Democking: removal of tank bottom sediments + Hygiene audit

2008

January Democking completed

February Ballast water in tanks

February - AprilComplementary audit for Green Passport (specific points: Asbestos)

Laboratory analyses of ballast waters, sediments, ....

Mars - July Visits of international yards

2009

January-February Removal of hazardous waste to be exported to Europe from SR1 to Wouri base

March Removal of anchors

18 march Departure of SR1

03 July Arrival at quay Changyiang Ship Recycling YardCustoms clearance

07 July

Crew repatriated

Fumigation

Ballast waters treated with chlorine

Gas free certification

16 July Delivery ceremony in China with Total E&P, SNH, and Maersk

16 July

Start of pre-cleaning operations

Removal of furniture, loose items

Preparation of asbestos material removal

Asbestos material removal

Asbestos particles monitoring by third expert laboratory (ETS TestConsult Ltd, Hong-Kong)

26 August Ballast water sampling and analyses by Total E&P and external consultancy (Sogreah China).

08 September Asbestos removal completed / start of steel cutting and hot worksSite block cutting

17 September Final site clean up

26 October Demolition completed

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