PPC Regulations  Permit application shall be in writing and shall contain a description of the following:

• A description of the installation, its activities and its location
• The materials, substances and energy used in or generated by the installation
• The sources of emissions (release routes) from the installation
• The nature and quantities of foreseeable emissions from the installation into each medium as well as identification of significant effects of the emissions on the environment
• The proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation
• Where necessary, measures for the prevention and recovery of waste generated by the installation
• Measures planned to monitor emissions into the environment.

Information on new combustion installation(s) in new developments may be included in an Environmental Statement (ES), or otherwise attached to it by a reference in the main ES document. An application for a permit has to be made separately but a copy of the ES then need only accompany it with the covering letter indicating where the required information can be found.

The permit is based on a mass emissions approach for each of the main pollutants. As oil/gas production declines over field life, emissions will not be constant. It is envisaged that during the study phase, the operator will prepare yearly predictions of each emissions and these will form the basis for negotiation of the overall permit mass emissions (tonnes) for each pollutant. A pro forma of a typical permit application is given in Annex 1 to the Department for Energy Security and Net Zero (then DECC) Guidance Notes (PDF document).

MARPOL Annex VI

MODU or others registered as a ship will be inspected by the MCA.

Fixed installations will be insepcted by the Department for Energy Security and Net Zero.

EU Emissions Trading Scheme

See EU ETS Topic.

Annex VI only applies to diesel engines over 130 KW and does not apply to turbines. Emissions arising directly from the exploration, exploitation and associated offshore processing of seabed mineral resources are exempt from Annex VI, including the following:

• Emissions resulting from flaring, burning of cuttings, muds, well clean-up Emissions and well testing.
• Release of gases entrained in drilling fluids and cuttings.
• Emissions from treatment, handling and storage of reservoir hydrocarbons.
• Emissions from diesel engines solely dedicated to the exploitation of seabed mineral resources.

In addition, Regulation 13 concerning NOx does not apply to emergency diesel engines, engines installed in lifeboats or equipment intended to be used solely in case of emergency.

Any PPC Permit granted by the Secretary of State will have conditions relating to the following (amongst others) in place:

• Required pollution prevention measures in particular through the application of Best Available Technology (BAT)
• Requirement that the production of non-gaseous waste is avoided where possible by using clean technologies or using waste minimisation/waste recovery technologies
• Energy is used efficiently
• Necessary measures are taken to prevent accidents and limit their consequences in relation to the environment
• Necessary measures are taken to ensure any liquid or solid wastes are recovered for onshore recycling or disposal or offshore disposal in accordance with any other relevant legislation
• Necessary measures are taken upon cessation of activities to avoid any pollution risk and to decommission and remove the combustion installation
• Emission controls are in place in the form of emission value limits or equivalent parameters or technical measures or a combination of the two
• Monitoring and measurement requirements to enable verification of compliance with the permit
• Provisions on the minimisation of long-distance and transboundary pollution
• Measures relating to conditions other than normal operating conditions, e.g. process upsets and start-ups

If the application includes a plan to reduce pollution from the combustion installation, then the Secretary of State may allow the condition to achieve energy efficiency to lapse but only for six months starting with the date the permit is issued.

The Department for Energy Security and Net Zero’s preferred approach is to consider the direct mass emissions of combustion pollutants from the entire platform or floater, rather than emissions quantified in terms of mass emissions per unit volume of exhaust gas from each item of combustion plant. In an offshore context, it is considered that this will enable Operators to devote more resources to emissions from the bigger sources (e.g. main power generation turbines), which dominate the releases offshore.

The requirement to undertake an energy assessment is a condition of most offshore PPC permits. The energy assessment should incorporate three main elements:

• Independent review of emissions of Greenhouse Gases (GHG) and other atmospheric pollutants and investigation and quantification of any potential opportunities to reduce emissions
• Independent review of the energy usage on an asset, and investigation and quantification of any potential opportunities to avoid energy wastage
• Demonstration to the Department for Energy Security and Net Zero’s satisfaction that the whole plant is being operated in the most energy efficient manner that is financially viable.

Guidance is now available on the methodology for undertaking an energy assessment (see the Guidance section under the Legislation tab)

The Public Participation Directive (PPD) requires a number of aspects of public notification and consultation, and the Offshore Combustion Regulations have been amended to incorporate these:

1. An outline of main alternatives (if any) should be included in permit applications.
2. The public should be notified and made aware of any decisions making available relevant consents and permits with the reasons and considerations on which decisions have been based.
3. Public notification must be at the earliest possible time where the information can be provided on the nature of possible decisions.
4. Making available within time-frames the necessary reports, advice issued to the regulator in accordance with legislation when applications were made and information relevant to a decision which only became available after advertisement of an application.

Where possible, direct measurements should be taken for emission reporting or generation of machine specific factors for emission calculations. Although there are inherent inaccuracies in the measurement of emissions in an exhaust stack, it is considered by BEIS to be an acceptable method of determining the emissions from a machine.Pollutant gases and the thermal efficiency of the plant have to be monitored and reported. The main pollutant gases that will need monitoring are:

1. Oxides of nitrogen and other nitrogen compounds.
2. Sulphur dioxide and other sulphur compounds.
3. Carbon monoxide.
4. Unburned Hydrocarbons – UHC*.

(* In practice, it is expected that only UHC as an overall ‘total hydrocarbons’ will be measured/monitored, rather than each individual hydrocarbon gas, although an indication of the ratio between methane and other hydrocarbon gases should be estimated).  BEIS published The Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013 – Offshore Emissions Monitoring Guidance in 2016 (PDF document.

In order to establish an emissions baseline, direct measurement of combustion plant exhausts must be carried out. Priority should be given to monitoring of the principal emitters, i.e. the gas turbines. Monitoring of any remaining combustion plant, which has not been included in the first phase, should be conducted thereafter.

Predictive Emissions Monitoring Systems (PEMS) are considered an acceptable means of monitoring emissions from turbine exhausts as well as offering machine management benefits. However, direct measurements must be carried out initially to verify the emissions estimate from the PEMS.

More information on measurement and monitoring requirements can be obtained from Offshore PPC (Combustion Plant) Monitoring Guide (PDF document), in particular information on frequency of measurements required.

The monitoring programme must be agreed with DECC before commencing the programme, and the initial survey must be completed within twelve months of first permit issue or first oil and gas. Monitoring reports must be submitted directly to DECC at emt@decc.gsi.gov.uk within 3 months of completion of each survey or by any other deadline given in the PPC permit. The frequency and scope of ongoing monitoring surveys will be reviewed following an assessment of the results of each survey.

BEIS has revised and updated the Offshore PPC (Combustion Plant) Monitoring Guide (PDF document), to provide clearer guidance to operators on what constitutes ‘Best Practice’ with respect to offshore emissions monitoring. The principle objective was to detail the minimum requirements for valid initial baseline measurements, and to outline how these can be achieved.

Any non-compliance with PPC permit conditions, issued under the Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013, as amended, should be reported to OPRED through the submission of a PPC NCN on the Integrated Reporting Service (IRS) on the UK Energy Portal. If the IRS system is unavailable, a PPC non-compliance notification form should be sent to OPRED. Examples of non-compliance may include, but are not limited to:

• Exceeding total annual emissions of polluting substances from combustion equipment authorised under the permit
• Failure to carry out and/or submit monitoring programme survey and findings, independent energy audits, cost benefit analysis or improvement programmes if requested by the Department.

It is suggested that applicants prepare a PPC application detailing before and after emission profiles, and use this, together with an examination for significant environmental impact, as the basis for discussion with the Department for Energy Security and Net Zero. The Department for Energy Security and Net Zero will enter into dialogue with the applicant and will give its decision as to whether the change is considered “substantial”. If substantial change is deemed likely to occur, then the initial study work can be used as input to a formal IPPC application.Any queries regarding ‘Substantial Change Assessment’ should be directed at the appropriate Environmental Manager within the Department for Energy Security and Net Zero Team. The Department for Energy Security and Net Zero EIA Guidance (PDF document) details the following as a guide for evaluating substantial change.

• If there is an increase between 40,000 – 100,000 tonnes of CO2 at the host installation then this may constitute substantial change under the PPC Regulations. An application to vary the PPC permit will be required.
• If as a result of the propopsed activity there is an increase of >100,000 tonnes CO2, a new PPC application would be required.