Well Test

Consent Needed: 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).
How to Apply: N/A (see Drilling Chemicals or Production Chemicals for Chemical Permit application process).
Who to Apply to: N/A
When to Apply: N/A
Flaring Best Practice:
  • 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.
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 can 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

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 (PDF)

HSE Safety Notice Bulletin Number OSD 3-2010.

Monitoring During Flaring:
  • Monitoring of operation at all times.
  • Cessation of operations if oil is seen on sea surface.
What to Report: 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).
Who to Report to According to the two types of possible reporting, report contacts are as follows:

  1. For accidental oil spills – BEIS, 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.
When to Report 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.
What to do if in Breach of Consent/Authorisation: Breach of consent may comprise failure to stop operations in the event of sea surface pollution. In the event of this, immediate reporting to BEIS will be required.
Offshore Inspection: The BEIS (then DECC) Offshore Oil and Gas Environment Unit Enforcement Policy  (PDF document) sets out the general principles that Inspectors shall follow in relation to enforcement including prosecution.
Renewal: N/A
None known at present.
None at present.