Question 3.3.5
Should fundamental data be reported during the decommissioning and the blowdown phase, and if so, how?
During the decommissioning phase, there are no commercial contracts applicable, which is why the facility report values are zero. However, in some types of storage facilities, as part of the blowdown / decommissioning phase, cushion gas should be withdrawn from the storage and sold to the market.
Should fundamental data be reported until cushion gas is taken out? Or is transaction reporting for the sale of the cushion gas sufficient?
If fundamental data reporting is still necessary, our understanding is that the total volumes DTMTI, DTMTW, DTMTS, storages volume, injected daily volume und withdrawn daily volume should be zero. Should the daily withdrawal volume show the volumes of cushion gas and the other requested data be reported as zero only in case of a cushion gas takeout?
Answer: The cushion or base gas (permanent inventory in a storage reservoir) should not be counted as a normal working gas volume. The Agency’s understanding is that the removal of cushion gas is the last step of the decommissioning phase.
If there are no commercial activities during the decommissioning phase and cushion gas is still in a storage reservoir, the SSO should report zero values “0” in the fields: storage, injection, withdrawal, technicalCapacity, contractedCapacity, availableCapacity of Storage Facility Report until cushion gas is sold/taken out. When cushion gas is sold/taken out, the Agency’s understanding is that the SSO has to make nominations and report movements of gas via the “withdrawal” field in the Storage Facility Report. Fields storage, injection, technical, available and contracted capacity of the storageFacilityReport should be reported with zero values “0”.
If the SSO needs to, for example, inject gas for operational purposes during the decommissioning phase, the Agency’s understanding is that the SSO has to make nominations and report movements of gas via the “injection” field in the Storage Facility Report. Fields storage, withdrawal, technical, available and contracted capacity of the storageFacilityReport should be reported with zero values “0”.