Well Test

• Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005

These Regulations came into force on the 20th August 2005. These Regulations introduce a permitting system for oil discharges . Under the OPPC Regulations, a permit will no longer be required for possible flare drop-out.

Following the introduction of high-efficiency burners, it is considered unnecessary to permit discharges of oil from this source under the OPPC Regulations. As incidental discharges relating to flaring will not be covered by an oil discharge permit, any incidents that do result in a discharge of oil to sea will need to be the subject of a PON1 submission (See Oil Spill Contingency and Reporting).

• Convention on the Protection of the Marine Environment of the North East Atlantic 1992 (OSPAR Convention)

Under the OPPC Regulations, there is no requirement for a permit for incidental discharges related to flaring during well tests.

Any chemical use proposed will require a Chemical Permit under the Offshore Chemicals Regulations 2002 (see Drilling Chemicals or Production Chemicals).

N/a (see Drilling Chemicals or Production Chemicals for Chemical Permit application process).

• Design the well test so that oil and gas flaring is kept to the minimum that is technically and economically justified.
• Give careful consideration to the need for well test flaring.
• Use efficient burners if flaring is required.
• Monitor discharges at all times.
• Operation to cease if any visible oil seen on sea surface.

Operations giving rise to 'oil contaminated fluids' include well clean-up, cementing, mud pit cleaning and operations where well bore fluids become contaminated with oil based mud, crude oil or condensate. In addition, fluids from rig floor drains and other tank cleaning operations could also be included.

Backloading of slops must meet the requirements of MCA and HSE Guidance Notes:

Good Practice for the Carriage of Oil Contaminated Cargoes for Transportation by Offshore Supply Vessel (PDF)

Marine Guidance Note (MGN 283(M)) Dangerous Goods - Guidance on the Back Loading of Contaminated Bulk Liquids from Offshore Installations to Offshore Supply/Support Vessels.

HSE Safety Notice Bulletin Number OSD 3-2010

• Monitoring of operation at all times.
• Cessation of operations if oil is seen on sea surface.

There are two separate reporting requirements in relation to well test flaring:

1. If there is fall-out and sea surface pollution, this must be reported as an oil spill. In this case, the report should be made on PON1 pro forma. This is a statutory requirement (see Oil Spill Contingency and Reporting).

2. The well test emissions should be reported under the voluntary atmospheric emissions reporting in the atmospheric emission inventory EEMS system (see Atmospheric Emissions Reporting). 

According to the two types of possible reporting, report contacts are as follows:

1. For accidental oil spills – DECC, JNCC, Coastguard, MCA and other contacts as relevant and as set out in the PON1 and installation Oil Pollution Emergency Plan (OPEP).

2. EEMS reports are submitted electronically to the EEMS website.

According to the two types of possible reporting, timing of reports are as follows:

1. Immediately for oil spills.

2. For EEMS submissions, before 1st March for production platforms as part of the annual submission and 28 days after each well for MODUs.

Breach of consent may comprise failure to stop operations in the event of sea surface pollution. In the event of this, immediate reporting to DECC will be required.

The Consultation closes on 16 October 2009. Further information is available on the DECC Website.

DECC has published its responses to the consultation exercise and the responses can be found on the DECC website. The responses supported the need for the amending Regulations and after a meeting with industry in May 2010 all points raised were
resolved.

The principle aim of the proposed amendments - to be introduced via the Offshore Chemicals (Amendment) Regulations 2010 and the Offshore Petroleum Activities (Oil Pollution Prevention and Control) (Amendment) Regulations 2010 ("amending Regulations") is to make unlawful unintentional releases of chemicals and oil that arise through accidents / non-operational discharges by broadening accordingly the definitions of "offshore chemical" and "discharges" and incorporating a new concept of "release" so as to: (a) differentiate between intentional discharges and other releases; and (b) create a new offence in respect of releases, or allowing a release to continue. Consequently, in making releases unlawful, it will be possible to provide for suitable enforcement actions, including the ability to serve notices to prevent releases occurring and specify actions to be taken to remedy any pollution caused by a contravention and potentially prosecute in the event of any releases. Both sets of amending Regulations also contain a number of minor changes to clarify points which the Offshore Environment and Decommissioning (OED) Branch of DECC's Energy Development Unit (EDU) have identified through experience of administering the existing Regulations since they came into force.

None at present