Oil Discharge Permit   A permit is required under the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 for both overboard discharge and reinjection of produced water.For production operations, a Life Permit (see OPPC Summary Table) can be applied for that covers all routine oil to sea discharges/reinjection operations, including:

• Produced water (discharge and reinjection)
• Displacement water
• Produced sand and scale discharges
• Hazardous and non-Hazardous drains

Note: For platforms that routinely use PWRI, a contingency discharge permit can be obtained to cover PWRI downtime events. Contingency discharge schedules will have similar monitoring/reporting requirements as for routine overboard discharges.

FEPA Licence – export to another field for reinjection

For export of produced water for reinjection at another field, a FEPA licence will be required.

The requirements for a FEPA licence do not apply for produced water from satellite subsea tie-backs to a host installation for subsequent treatment and reinjection. The requirements for a FEPA licence also do not apply if produced fluids are shipped to another installation for separation and then subsequent produced water treatment and reinjection, and an exemption will be issued

Oil Discharge Permit   Oil discharge permits must be applied for on the UK Oil Portal. Oil Discharge Permit applications are made on a Subsidiary Application Template (SAT) in the PETS system. The SAT application is initiated from the relevant MAT. Guidance Notes on the OPPC Regulations and Permit Application are available for download from the Department for Energy Security and Net Zero (PDF document).A number of discharge streams will require permits under the OPPC Regulations (see OPPC Summary Table). It is possible to submit one oil discharge permit application to cover a number of separate discharge streams containing oil. In fact, this method is actively encouraged by the Department for Energy Security and Net Zero. For example an installation’s oil discharge permit could include separate schedules for drainage discharges, produced water discharges and periodic discharges such as sand and scale.

Information required on the application form includes:

• Installation/facility details including any tie-backs
• Description of sources and types of hydrocarbons
• Description of any process/treatment system and any improvement programmes
• Estimated maximum and average production of the discharge stream and hydrocarbon content
• Details of method used to measure the volume discharged and details of discharge stream sampling facilities
• Details of discharge facilities

There is no public notice requirement or statutory consultation. However, the Department for Energy Security and Net Zero may take advice from third parties for example if the discharge is close to land or close to a relevant site under the Habitats Regulations, or where a sensitive fish spawning area is present.

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.

FEPA Licence – export to another field for reinjection

Following the introduction of the licensing provisions of the Marine and Coastal Act 2009, on 6 April 2011, it was dis-applied in English and Welsh waters and offshore waters adjacent to Scotland. However, FEPA Part II still applies in Scottish territorial waters, between the 3 NM Scottish controlled waters limit and the 12 NM Scottish territorial sea limit, where the Department for Energy Security and Net Zero will remain the licensing authority and the Marine (Scotland) Act 2010 is the relevant controlling legislation.

Application for a FEPA licence can be made using the Marine Licence application, handled by the UK Oil Portal. Enquiries can be sent to emt@decc.gsi.gov.uk

In addition to routine administrative information, you must provide a method statement detailing where the wastes originate, how you propose to transport them to the disposal site, whether you intend to undertake any additional pre-treatment prior to reinjection and how you propose to undertake the reinjection operation. The latter should include a technical case to support the safe injection and containment of any disposed material. You must additionally provide an assessment of the alternative means of disposal to demonstrate that offsite reinjection is the Best Practicable Environmental Option (BPEO).

Where disposal by reinjection will be at a site operated by a 3rd party, additional considerations will be required for any transshipment of wastes and the appropriate authority should be contacted to discuss the proposals prior to any formal application.

Applications that may have the potential to affect a designated European Site will also be subject to the provisions of the Offshore Marine Conservation (Natural Habitats &c) Regulations 2007 as amended by The Offshore Marine Conservation (Natural Habitats, & c.) (Amendment) Regulations 2012 (including sites proposed for designation).

Oil Discharge Permit   Application under the new OPPC Regulations to be submitted electronically to the UK Oil Portal as a SAT with the relevant MAT in the new PETS system.FEPA Licence – export to another field for reinjection

For off-site injection operations in offshore waters adjacent to Scotland (i.e. excluding Scottish controlled waters), contact:

Environmental Management Team
DECC Licensing and Consent Unit (LCU-OED)
Atholl House
86/88 Guild Street
Aberdeen AB11 6AR
(emt@decc.gsi.gov.uk).

For off-site injection operations in English and Welsh waters (both near-shore and offshore waters), contact:

Marine Consents and Environment Unit
Ergon House
Horseferry Road
London SW1P 2AL
(marine.consents@mceu.gsi.gov.uk).

Off-site injection is unlikely to take place in Scottish controlled waters (within three miles of the territorial seas baseline), where the FEPA Part II licensing authority is:

Environmental Protection Group
FRS Marine Laboratory
PO Box 101
375 Victoria Road
Torry
Aberdeen AB11 9DB
(ceu@scotland.gsi.gov.uk).

Oil Discharge Permit   Applications must be submitted at least 28 days before the permit is required.FEPA Licence – export to another field for reinjection

Applications normally take eight to ten weeks to process, but may take longer.

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.

From January 2007 the preferred method for oil in water analysis is the GC/FID method. This may not be suitable for use on all offshore installations and a Joint Industry Project (JIP) has been established to investigate how the new GC/FID method is implemented. Other oil in water analysis methods will have to be calibrated against the GC/FID method to ensure results are comparable.OSPAR GC-FID will be applied at all oil and gas facilities where oil in water figures are reported to the Department for Energy Security and Net Zero. Facilities may still use the Department for Energy Security and Net Zero IR method but it will require correlation with the GC-FID method. There are two ways that operators can accommodate the above:

• Install GC equipment offshore to meet new requirements.
• Continue to use IR method but send all samples onshore to a recognised laboratory for correlation against the GC-FID reference method.

The Department for Energy Security and Net Zero Guidance on the Sampling and Analysis of Produced Water and Other Hydrocarbon Discharges is available on the Department for Energy Security and Net Zero website.

For the purposes of the Produced Water Trading Scheme the Department for Energy Security and Net Zero has issued a written statement confirming that for the purposes of trading, operators will analyse produced water samples using the new GC-FID reference test method and report results against allocations issued (against original IR results). This system will be place for 2007-2009.

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 and reported to the Department for Energy Security and Net Zero:

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

(* Not required for produced water reinjection streams.)

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.

Results of any additional analysis (i.e. aliphatics, aromatics, heavy metals, etc.) undertaken bi-annually or during contingency discharges should be reported via EEMS within 2 months of the mid-year and 2 months of the year end.

Discharge volume measurement or calculation method validation should be reported to the Department for Energy Security and Net Zero annually.

NORM/OSPAR analysis

Reporting of activity and total quantities discharged (see the Sampling/Monitoring Requirements tab).

Produced water discharges and reinjection  Submit EEMS Oil in Water to the EEMS website by the 16th of each calendar month for each preceding calendar month.NORM analysis

Submit via the EEMS system on a quarterly basis within 28 days of the end of each quarter.

In the event that the monthly average concentration of dispersed oil in produced water discharged exceeds 30 mg/l or 100 mg/l at any one time, the Department for Energy Security and Net Zero must be informed using the OPPC non-compliance forms, accessed and submitted through the Integrated Reporting Service (IRS) on the UK Energy Portal. Guidance is available for this here.

All accidental/unplanned discharges to sea of oil (including crude oil, diesel oil, lubricating oil and hydraulic oil) or chemicals (including OBM), regardless of volume, must be reported by PON1. The details for reporting this are provided in Chemical Spills.

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 report an unpermitted discharge of oil
• Failure to comply with a prohibition or enforcement notice
• Failure to supply any information required under the terms of the permit
• Wilfully obstructing a Department for Energy Security and Net Zero inspector

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

DECC Environmental Alert (001/2014)- PON1 Reporting:

Issued by DECC (now the Department for Energy Security and Net Zero) 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 for Energy Security and Net Zero; 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.

Risk-Based Approach to the Management of Produced Water Discharges from Offshore Installations (fact sheet):

The OSPAR Commission has published a fact sheet (PDF document) detailing the Risk-Based Approach to the Management of Produced Water Discharges from Offshore Installations.

OPRED are currently preparing an update to this document, with the next upcoming cycle lasting from 2021 to 2024 (announced here).