Drilling a Well | OEUK Environmental Legislation

Drilling a Well – Consent Requirements

An Environmental Statement is required for any drilling in near shore or sensitive areas. Drilling associated with a new development is also likely to require an ES. If unsure whether an ES is required or not, discussions should be held with DESNZ or a Drilling Operations Application (DRA) can be used to seek a dispensation from the requirement of an ES. If at all unsure, time should be allowed for preparation of an ES.
ES Required		No ES Required	Action Needed
12+ months		–		If required, submit DRA to determine requirement for an Environmental Statement. This step can be skipped if it is clear that an ES is or is not required.
				Undertake Environmental Impact Assessment (EIA) and prepare ES.
				Identify if proposed drilling occurs in vicinity of any habitats or protected species under EU Habitats Directive. Additional measures and Habitats Regulatory Assessment may be required.
				If no asset-wide Oil Pollution Emergency Plan in place, prepare OPEP.
4 months		4 months
3 months		3 months		Prepare Chemical Permit SAT (DRA) and environmental information sections , include any chemical use/discharge associated with well cleanup if applicable.
		–		Submit ES along with Application for Consent (PON16).
2 months		2 months		Submit OPEP to DESNZ for approval.
3-5 weeks		3-5 weeks		If reinjection of cuttings planned offsite, submit application for reinjection under FEPA.
28 days		28 days		Submit Chemical Permit SAT (DRA). (Note: Ensure chemicals selected are registered with CEFAS and those of high environmental risk are replaced as far as possible).
				Submit PON4 (Consent to Drill Well).
				Make application to DTLR for Consent to Locate for rig. (as part of DRA application)
				If Deposit of Stabilisation and Protection Materials required, submit application Direction under EIA Regulations to deposit material on the seabed. (as part of DRA application)
				If drilling through pay-zone and reservoir hydrocarbon contamination of drill cuttings for overboard discharge expected, apply for Oil Discharge Permit. . Oil Discharge Permit may also be required if OBM well cleanup is expected or any oil contamination of WBM/SBM cleanup.
1 week		1 week		Any radioactive sources will need a Certificate of Registration.
Spud Date

Key Compliance During Drilling

	Ensure compliance with any licence, exemption or consent permit conditions, including any commitments made in ES.
	Ensure any required spill prevention and oil spill response procedures are introduced to rig personnel and appropriate equipment is in place.
	Use only the permitted chemicals and mud system.
	If reinjecting cuttings, ensure alternative legal disposal methods are in place as back up if CRI fails.
	Routinely monitor base fluid use and discharge and sample and analyse the cuttings for oil content during drilling. Report findings of the sampling and analysis to DESNZ.
	Use technology and other techniques to prevent or reduce discharges of all chemicals. Monitor all use and discharge of chemicals and report quantities via EEMS reporting.
	Ensure compliance with Oil Discharge Permit consider the implications of well cleanup and the need to minimise the possibility of reservoir hydrocarbon contaminated fluid being discharged. If discharging cuttings overboard ensure no contamination with oil from the payzone unless appropriate Oil Discharge Permit is in place.
	Undertake any seabed environmental surveys as required by DESNZ.
	Report any accidental discharge of oil, including OBM or SBM, to DESNZ.
	Report any accidental discharge of chemicals, including drilling muds, to DESNZ.
	Undertake all statutory reporting and EEMS reporting for each activity.
	Ensure renewed permit is in place if planned well is to continue beyond expiry date of initial permit.

Rig Compliance (Non-Drilling)

			It may be necessary to undertake a pre-mobilisation audit of the drilling rig to ensure environmental compliance for drilling operations and other non-drilling routine operations.
			Machinery space drainage. Ensure oil content of discharge meets legal performance standard of 15 ppm (oil in water). Ensure Oil Record Book maintained.
			Diesel engines and generators. Maintain record of fuel use.
			No limits on sewage and cooling water discharges.
			No garbage (including plastic) to be disposed of overboard. Only comminuted food waste to be discharged.
			Ensure compliance with all waste disposal licences, garbage management plan and waste transfer documentation requirements for scrap metal and non-hazardous waste. Reuse or recycling is the preferred option.
			Ensure compliance with legislation for disposal of drill cuttings, including reinjection , overboard disposal (WBM only) or transfer to shore .