Displacement Water

Consent Needed: Oil Discharge PermitAn oil discharge permit is required under the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 for discharge of Displacement Water.For production operations, a Life Permit that covers all routine oil to sea discharges/re-injection operations can be applied for, and includes:

How to Apply: Applications for an Oil Discharge Permit must be made via the UK Oil Portal (UKOP). To obtain access to the UKOP contact UKOP@decc.gsi.gov.uk. Oil Discharge Permit applications are made on a Subsidiary Application Template (SAT) in the UKOP Portal Environmental Tracking (PETS) system. The SAT application is initiated from the relevant Master Application Template (MAT).Guidance Notes (PDF document) on the OPPC Regulations and Permit Application are also available.A permit to discharge oily discharges from a producing facility is likely to be issued as a Life Permit. Non-routine or one-off discharges will be issued as a time limited Term Permit.
Who to Apply to: All application made under the OPPC Regulations need to be submitted via UKOP PETS.
When to Apply: Applications must be submitted at least 28 days before the permit is required.
Definition of Oil:

The definition of oil has been updated under the OPPC Regulations and is defined as “oil means any liquid hydrocarbon or substitute liquid hydrocarbon, including dissolved or dispersed hydrocarbons or substitute hydrocarbons that are not normally found in the liquid phase at standard temperature and pressure, whether obtained from plants or animals, or mineral deposits, or by synthesis”. This definition is designed to capture all produced hydrocarbons, including condensate, and all uses of oil in the course of offshore exploration and production activities.

However, the OPPC Regulations do not apply to hydrocarbons or substitute hydrocarbons that are designated as chemicals for the purpose of the Offshore Chemicals Regulations 2002.

Limits Placed on Displacement Water Discharges: The monthly average concentration of dispersed oil in displacement water must not exceed 40 mg/l. The maximum concentration of dispersed oil must not exceed 100 mg/l at any time.
Location of Discharges:

Discharges of displacement water may only take place from those locations and at the depths specified in the schedule attached to the OPPC permit.

Oil in Water Analysis: From 1 January 2007 the approved oil in water analysis reference method is the OSPAR GC-FID Method as per OSPAR Agreement 2005/15. The BEIS IR method may be used as an alternative offshore method but this will need to be correlated with the OSPAR GC-FID method as per OSPAR Agreement 2006/06. The OSPAR GC-FID method is the reference dispersed oil in water analysis method for both oil and gas facilities and oil in water figures reported to BEIS will be reported against this method. BEIS Guidance on the Sampling and Analysis of Produced Water and Other Hydrocarbon Discharges is available on the BEIS website.
Displacement Water Sampling (Hydrocarbon Concentration and Volumes): Oil Discharge Permit Sampling and measurement/calculation requirements are as summarised in the Oil Discharge Permit Sampling Requirements Table.The schedule to the Oil Discharge Permit Permit will specify the exact sampling strategy. However, as a minimum at least one sample will be required to be taken during each discharge. If discharge continues for >12 hours, sampling will be required at least twice per day at equal intervals at sample points detailed in permit schedule.Volume of displacement water discharged shall be measured or calculated to +/- 10% accuracy on volume.Samples should be analysed as per current BEIS standards (see the Performances Standards tab). BEIS has issued Guidance on the Sampling and Analysis of Produced Water and Other Hydrocarbon Discharges (Word Document).

The following records must be maintained by the laboratory and retained for 2 years:

  • Date and time of sampling
  • Hydrocarbon concentration of each sample (mg/l)
  • Name of person undertaking each sample analysis

The following records must be retained on the offshore installation for 2 years:

  • Date and time of sampling
  • Dispersed oil in water concentration for each sample (mg/l)
  • Volume of displacement water discharged between each sample
  • Total volume of displacement water discharged each calendar month
  • Total weight of dispersed oil discharged each calendar month (tonnes)
  • Monthly average dispersed oil concentration (mg/l)
  • Total weight of dispersed oil discharged each calendar year (tonnes)
  • Total volume of displacement water discharged over the calendar year
  • Average dispersed oil concentration over the calendar year (mg/l)

Arrangements must be in place to ensure the accuracy and correctness of records. Where records are maintained solely in electronic form, secure systems shall be provided so that all changes are recorded and the original entries are not deleted. Where hard copies only are maintained, the person in charge of the operation shall sign a true copy of the records for the time period over which they have responsibility.

Staff Competency: Persons undertaking water sampling and analysis shall be provided with sufficient information and training to undertake the task. All training records must be maintained.
What to Report: A summary of the parameters measured/recorded (see the Sampling/Monitoring  Requirements tab) will be required to be submitted using the EEMS oil in water spreadsheet available on the EEMS website. Reported volumes will be cross referenced with OPPC permitted discharges. Information required to be reported includes:

  • Monthly average dispersed oil in water content (mg/l)
  • Total volume of displacement water discharged per calendar month
  • Total dispersed oil discharged per calendar month

Guidance on EEMS (PDF document) is also available.

Who to Report to: Reports to be submitted to BEIS via the EEMS reporting system using the EEMS oil in water spreadsheet. This can be downloaded from the EEMS website. Also see the  Non-Compliance tab.
When to Report: Submit EEMS oil in water electronically to the EEMS website by the 16th of each calendar month for each preceding calendar month.
What to do if in Breach of Consent/ Authorisation: In the event that the monthly average concentration of dispersed oil in displacement water discharged exceeds 40 mg/l, DECC must be informed within 2 working days of submission of the monthly returns using the Oil Discharge Permit non-compliance notification form (Word document). Oil Discharge Permit Guidance (PDF document) is also available. In the event that the maximum concentration of dispersed oil in displacement water discharged exceeds 100 mg/l, DECC must be notified within 6 hours using the Oil Discharge Permit non-compliance notification form (Word document).In addition, if at any time (even if permit conditions are not breached) >1 tonne of oil is discharged within a 12 hour period or an unusual sheen is formed extending beyond the 500 metre zone, then this must be reported to BEIS via the PON1. The BEIS website provides information on the PON1 (Word document) and Guidance Notes (Word document) are also available. PON1 reports are classed as OPPC non-compliance reports and are primarily intended to ensure the regulators are aware of an event which may give rise to further pollution, to reports from third parties or to public concern. Whilst not classed by BEIS in the same way as PON1s for spills, submission of the non-compliance PON1 report is every bit as vital to ensure compliance with the OPPC Regulations.
DECC Inspections: The OPPC Regulations give BEIS far greater and wider ranging powers to monitor and investigate all oil discharges whether lawful or unlawful. Inspectors may board an installation at any reasonable time and make such investigations as they consider necessary to investigate whether the requirements, restrictions or prohibitions imposed under the OPPC Regulations have been or are being complied with, or to monitor any discharge of oil. 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.
Enforcement and Prohibition Notices: BEIS, if of the opinion that the OPPC Regulations have been contravened, may issue an enforcement notice. This will specify the matters that constitute or are likely to constitute a contravention, steps required to rectify the matter and the time period within which these steps must be undertaken. If an enforcement notice is not addressed, BEIS may take action itself and recover reasonable costs back from the operator. If BEIS is of the opinion that the operation of an offshore installation involves an imminent risk of serious pollution as a consequence of any discharge of oil, BEIS may serve a prohibition notice. This will specify the pollution risk, the steps required to remove it and the time period, and may withdraw a permit wholly or in part until the prohibition notice is withdrawn.
Offences: Offences under the OPPC Regulations, include (but are not limited to) the following:

  • discharge of oil to sea without a valid and appropriate permit being in place
  • failure to comply with a prohibition or enforcement notice
  • failure to supply any information required under the terms of the permit, or
  • wilfully obstructing a BEIS inspector

A person found guilty of an offence will on summary conviction be liable to a fine not exceeding the statutory maximum.

Permit Renewal: Life Permits will be reviewed at a frequency stipulated in the permit schedule. The minimum frequency of review will be every three years. Permit holders have an obligation to continually review their oil discharge permits to ensure that they adequately cover their discharges. If any changes are required for example to take account of a process modification or to add additional activities/discharge streams, permit holders must apply for an oil discharge permit variation. This must be prepared by amending the original application with any changes clearly highlighted. Variations will be dealt with by BEIS as quickly as possible, but 28 days should be allowed for the assessment of any significant changes.
DECC Environmental Alert (001/2014)- PON1 Reporting: Issued by BEIS (then DECC) on 31 March 2014, this environmental alert (PDF document) highlights failures by a number of operators to comply with PON1 reporting requirements. Operators are reminded that in accordance with current reporting requirements PON1s must be reported within 6 hours to:

  • Aberdeen Maritime Rescue Coordination Centre (MRCC) in addition to immediate telephone notification to the nearest MRCC Coastguard Station.
  • Department of Energy and Climate Change (DECC) now the Department of Business, Energy and Industrial Strategy (BEIS); additional telephone notification is required to the Department for specific scenarios as detailed within the PON1 reporting guidance.
  • Joint Nature Conservation Committee (JNCC) and any relevant Statutory Nature Conservation Body (SNCB) in accordance with installation oil pollution emergency plan arrangements.