Environmental Statement - Maersk Oil

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A ‐ 10 Drilling Issue Legislation Regulator and Requirements Rig Movements HSE Operations Notice 6 Reporting of Offshore Installation Movements HSE Operations Notice 3 Liaison with other bodies HSE Operations Notice 14 on Coastal Protection Act. Muds, cuttings and chemical use and discharge Deposits in the Sea (Exemption) Order 1985 (as amended (England and Wales only) 2010) The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended 2011) (as amended by the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010) (replacing Prevention of Oil Pollution Act 1971 (as amended)) Balloch Field Development Environmental Statement Appendix A – Review of Legislation Under Operations Notice 6 a rig warning communication must be issued at least 48 hours before any rig movements Notice 6 should be read in conjunction with Operations Notice 3 Liaison with other bodies and Operations Notice 14 Guidance on Coast Protection Act ‐ consent to locate and the marking of offshore installations. Regulators: DECC supported by Marine Scotland and Centre for Environment, Fisheries and Aquaculture Science (CEFAS) Deposits in the sea were regulated through FEPA, which, as of April 2011, was subsequently replaced by the MCAA (2009). Discharge of drill cuttings and muds during drilling are specifically excluded from the licensing requirements of FEPA by the paragraphs 14 and 15 of Schedule 3 or the Deposits in the Sea (Exemption) Order 1985: 14. Deposit on the site of drilling for, or production of oil or gas, of any drill cuttings or drilling muds in the course of such drilling or production. 15. Deposit under the seabed on the site of drilling for, or production of, oil or gas of any substance or article in the course of such drilling or production. Deposits in the Sea (Exemptions) (Amendment) (England and Wales) Order 2010 came into force in April 2010 in England and Wales only, making minor amendments to the Deposits in the Sea (Exemption) Order 1985, however, the above still applies. Although the discharge of drilling muds and cuttings is exempt from FEPA/MCAA, the export of drilling cuttings and produced water for re‐injection still requires a FEPA licence. Regulator: DECC Under OPPC it is illegal to discharge reservoir hydrocarbons and cuttings to the marine environment without an exemption from the Secretary of State. The Paris Commission decision 92/2 established a maximum oil on cuttings concentration of 1% by weight for discharge of cuttings to sea. The contamination of cuttings by muds comes under the Offshore Chemical Regulations 2002 (as amended), but discharges/cuttings contaminated with reservoir oil fall under the OPPC regulations. A permit is required for discharge of oil to sea and is obtained from DECC. Under the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010 permits now extend to CCS activities
Balloch Field Development Environmental Statement Appendix A – Review of Legislation Offshore Chemicals Regulations 2002 (as amended 2011) (as amended by the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010) PON 15b Implementing the requirements of OSPAR Decision 2000/2 on a Harmonised Mandatory Control System for the Use and Reduction of the Discharge of Offshore Chemicals (as amended by OSPAR Decision 2005/1) and associated Recommendations. OSAPR Recommendation 2006/5 on a management scheme for offshore cuttings piles The Offshore Petroleum Activities (Oil Pollution Prevention and Control) (Amendment) Regulations 2011 came into force on March 30 th 2011. These amendments include a new definition of “offshore installation”, which now includes pipelines. This ensures that all emissions of oil from pipelines used for offshore oil and gas activities and, under the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010, gas storage and unloading activities will now be controlled under the OPPC regulations. Regulator: DECC Under these Regulations, offshore drilling operators need to apply for permits to cover both the use and discharge of chemicals. The permits are applied for through the PON15b online application form (UKoilPortal). The application requires a description of the work carried out, a site specific environmental impact assessment and a list of all the chemicals intended for use and/or discharge, along with a risk assessment for the environmental effect of the discharge of chemicals into the sea. The permit obtained may include conditions. These Regulations amend the Deposits to Sea (Exemptions) Order 1985 to make the discharges of chemicals to sea exempt from requiring a licence under FEPA (subsequently replaced by the MCAA) when the discharge has a permit under the Offshore Chemicals Regulations 2002 (as amended 2011). Under the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010, permits extend to CCS activities. The Offshore Chemicals (Amendment) Regulations 2011 also came into force on March 30 th 2011. The key change is to ensure that enforcement action can be taken in respect to non‐operational emissions of chemicals, such as accidental leaks or spills. Under the 2002 regulations a permit can only be granted in respect of discharge of chemicals which occur during day to day oil and gas production, as a discharge is limited to “an operational release of offshore chemicals.” Therefore, it is not an offence to emit chemicals other than in the course of normal operations, for example, as a result of leaks or spills. The 2011 amendments remedy this. Under the regulations, a “discharge” now covers any intentional emission of an offshore chemical and a new definition of “release” has been inserted which catches all other emissions (regulation 4(a) and (h) of the amendments). Under the 2011 amendments, well suspension and abandonment also requires a formal permitting process and will usually require approval under the MCAA licensing regime. Both of which are administered by DECC’s Environmental Management Team. These requirements are in addition to the PON15 consent to abandon a well. OSPAR Recommendation 2006/5 outlines the approach for the management of cuttings piles offshore. The purpose of the Recommendation is to reduce to a level that is not significant, the impacts of pollution by oil and/or other substances from cuttings piles. The Cuttings Pile Management Regime (outlined by the Recommendation) is divided into two stages: Stage 1 involves initial screening of all cuttings piles. This should be completed within 2 years of the Recommendation taking effect Stage 2 involves a BAT and/or BEP assessment and should, where applicable, be carried out in the timeframe A ‐ 11
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Environmental Statement - Maersk Oil

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