Any well test with a total flow duration of >96 hours or which produces a total of more than 2,000 tonnes of oil is classed by DECC as an Extended Well Test. This requires Consent for Test Production.
Consent for Test Production must be obtained in accordance with the requirement of the Model Clauses of the relevant Petroleum Production Licence (as consolidated by the Petroleum Act 1998).
There may be a requirement for an Environmental Impact Assessment (EIA) under the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (see Performance Standards).
Any chemical use proposed will require a Chemical Permit under the Offshore Chemicals Regulations 2002 (see Drilling Chemicals or Production Chemicals).
Operators will need to assess the risks to the environment, which might arise from their particular chemicals use and discharge. For some chemicals e.g. those on the OSPAR PLONOR list, assessment will be straightforward. Others will require a formal process of risk assessment, such as can be done using CHARM software. In this process, the predicted environmental concentration (PEC), determined from a knowledge of individual substance or product chemistry and the conditions of use, is compared with the Predicted No-effect Concentration (PNEC) determined from toxicity tests conducted to agreed protocols. This allows more informed assessments of risk to local sensitivities to be made in particular use and/or discharge scenarios. The use of the CHARM model is compulsory for calculating the Hazard Quotient (HQ) but other risk assessment models may be used to calculate the Risk Quotient (RQ) provided comparability with CHARM can be demonstrated.
Note: A permit/exemption is no longer required for potential oil fall-out from flaring under the OPPC Regulations. However, any oil fall-out must still be reported as an oil spill via the PON1 (see Oil Spill Reporting). |