Well Test – Extended

Consent Needed: Any well test with a total flow duration of >96 hours or which produces a total of more than 2,000 tonnes of oil is classed by BEIS as an Extended Well Test. This requires Consent for Test Production.Consent for Test Production must be obtained in accordance with the requirement of the Model Clauses of the relevant Petroleum Production Licence (as consolidated by the Petroleum Act 1998). There may be a requirement for an Environmental Impact Assessment (EIA) under the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (see the Performance Standards tab).Any chemical use proposed will require a Chemical Permit under the Offshore Chemicals Regulations 2002 (see Drilling Chemicals or Production Chemicals).Operators will need to assess the risks to the environment, which might arise from their particular chemicals use and discharge. For some chemicals, e.g. those on the OSPAR PLONOR list, assessment will be straightforward. Others will require a formal process of risk assessment, such as can be done using CHARM software. In this process, the predicted environmental concentration (PEC), determined from a knowledge of individual substance or product chemistry and the conditions of use, is compared with the Predicted No-effect Concentration (PNEC) determined from toxicity tests conducted to agreed protocols. This allows more informed assessments of risk to local sensitivities to be made in particular use and/or discharge scenarios. The use of the CHARM model is compulsory for calculating the Hazard Quotient (HQ) but other risk assessment models may be used to calculate the Risk Quotient (RQ) provided comparability with CHARM can be demonstrated.

Note: A permit/exemption is no longer required for potential oil fall-out from flaring under the OPPC Regulations. However, any oil fall-out must still be reported as an oil spill via the PON1 (see Oil Spill Reporting).

How to Apply: Application for Consent for Test Production are to be made by letter to BEIS. Application for a Consent for Test Production can also be made through the PETS application process for some operations (see Drilling Chemicals and Workover and Production Chemicals as appropriate). The letter should set out the timetable and objectives of the test and quantities of oil and gas to produced, saved or flared.
Who to Apply to: BEIS Oil and Gas Office Contacts for Extended Well Test Consents are as follows:Northern and Central North SeaCarol Campbell
Tel: 01224 254052Email: carol.campbell@decc.gsi.gov.uk

Southern North Sea and Onshore

Ivor Newman
Tel: 020 7215 5163

Email: ivor.newman@decc.gsi.gov.uk

If applying via PETS these must be submitted electronically to BEIS via the UK Oil Portal. Operators will need to be registered with BEIS for access to the Portal.

To set up a UK Oil Portal Account, contact the BEIS OED Environmental Management Team at ukop@decc.gsi.gov.uk

If you have any problems with PETS submission, contact the BEIS OED EMT by email at emt@decc.gsi.gov.uk

When to Apply: Application should be submitted at the same time as the PETS application for the chemical permit, i.e. at least 28 days prior to operation.
Requirement for an ES (see EIA): Where an activity is likely to exceed the thresholds (i.e. > 2000 tonnes of oil and/ or a flow period > 96 hours) indicated in the Guidance Notes on the Procedures for Regulating Oil and Gas Field Developments, it is necessary to consider whether either a PETS application or an ES will be required to be submitted. Extended well tests involving substantial production with or without the export of hydrocarbons will normally be subject to the full EIA process. This will be particularly true where the extended well test is to be carried out in what BEIS and its consultees consider to be a sensitive location, e.g. close to the coast, an SPA/SAC or a median line.
Limits Placed on Flaring and Production Volumes:

The primary objective of an Extended Well Test is to obtain essential field information and BEIS recognises that this may necessitate the flaring of substantial quantities of gas and possibly oil. The test should be designed 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 required.
  • Monitor discharge at all times.
  • Operation to cease if any visible oil seen on sea surface.

There are no strict criteria governing the maximum volume to be produced or the duration of an Extended Well Test and the duration may be extended if there is a technical justification. However, it should be noted that Extended Well Tests are not an alternative to production under an approved Field Development Programme.

Monitoring During Flaring:
  • Continuously monitor the production rates, water cut, downhole pressures and GOR histories.
  • Cessation if operations if oil seen on the sea surface.
What to Report: There are two types of reporting required for flaring. The first is statutory reporting to BEIS (which for the purposes of this procedure details the requirements of the Consent for Test Production, i.e. reporting flare volumes and associated details). The second is EEMS reporting of environmental emissions due to flaring.Extended Well Test ConsentReporting to BEIS every Monday during the period of the consent, the Operator shall fax the following information relating to the previous week:

  • Short technical summary of performance of gas handling plant, highlighting any features which have affected or could affect the operation of the plant.
  • Daily rates in respect to oil production, gas production, gas export, gas used for fuel and gas flared.
  • Cumulative average production for production and flare.
  • Weekly calculations of gas compression plant efficiency.

Some consents may include the provision that specific monthly flare reporting is not needed and that flare volumes are reported in the routine field reporting into the BEIS Petroleum Production Reporting system. In this case, specific flare reporting would be by exception only if flaring is out of consent.

Upon completion of the test, the operator must inform the Department of the results of the test and of their intentions for the future production status of the well.

EEMS Reporting

Complete relevant parts of applicable atmospheric emissions inventory EEMS pro forma, that can be found at the EEMS website.

Who to Report to: Extended Well Test Consent  BEIS’s Petroleum Production Reporting according to terms of consent.EEMS Reporting

Completed forms should be submitted electronically to the EEMS website where they can also be viewed, amended and updated.

When to Report: Extended Well Test Consent  Schedule of reporting will be established through consent. It varies widely according to stage of field production and between fields and operators.EEMS Reporting

Annually before 1st March if on production installation or 28 days following completion of well test on MODUs.

OPPC Regulations: A permit is no longer required for potential flare drop-out. However, if flare drop out does occur, a PON1 report must be submitted.
What to do if in breach of consent/ Authorisation: Failure to have a valid Test Production Consent in place when undertaking an extended well test, or failure to comply with the requirements of the consent may constitute a statutory offence and risk the licence.
Offshore Inspection: The BEIS (then DECC) Offshore Oil and Gas Environment Unit Enforcement Policy sets out the general principles that Inspectors shall follow in relation to enforcement, including prosecution.
Renewal: Towards expiry of existing consent.
None known at present.
Backloading of Oily Slops: 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: