Environmental statement - Flyndre and Cawdor - Maersk Oil

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Commissioning and Operations Issue Legislation Regulator and Requirements Discharges of linefill and hydrotest fluids Displacement water Chemical use and discharge Dangerous goods Flyndre and Cawdor Environmental Statement Appendix A - Register of Environmental Legislation The Petroleum Act 1998 Regulator: DECC supported by Marine Scotland and CEFAS and within territorial waters Scottish Government Marine Directorate The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended 2011) (as amended by the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010) Offshore Chemicals Regulations 2002 (as amended 2011) (as amended by the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010) PON 15 c, d and f The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 Deposits in the sea, including liquid discharges, were regulated through the MCAA but, as stated above, as a result of the Petroleum Act 1998 this does not apply to anything done: (a) for the purpose of constructing a pipeline as respects any part of which an authorisation (within the meaning of Part III of the Petroleum Act 1998) is in force; or (b) for the purpose of establishing or maintaining an offshore installation within the meaning of Part IV of that Act. Discharges of linefill and hydrotest fluids are permitted under the Petroleum Act 1998 and this is incorporated and permitted within the PON 15c process. Regulator: DECC The discharge of oil requires an OPPC permit which are issued by DECC. The 2011 amendments to the regulations extend permits requirements to pipelines as well as installations. Specific monitoring and reporting requirements will be included on each permit. Reporting is via the EEMS. Regulator: DECC Under these Regulations, offshore pipeline installations need to apply for permits to cover both the use and discharge of chemicals. Under the 2011 amendments, permits now apply to both operational and accidental releases. Types of permit required for the operations would be: PON15 c for use and discharges from pipelines PON15 d for use and discharges during operations PON15 f for use and discharges during workovers /intervention operations The permits are applied for through the PON15 online application form (UKoilPortal). The application requires a description of the work carried out, a site specific environmental impact assessment and a list of all the chemicals intended for use and or discharge, along with a risk assessment for the environmental effect of the discharge of chemicals into the sea. The permit obtained may include conditions. Note: Permits now extend to carbon sequestration activities under the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection) Order 2010. Regulator: Maritime and Coastguard Agency The regulations require that dangerous goods and marine pollutants are labelled and packed according to the International Maritime A ‐ 16 D/4114/2011
Flyndre and Cawdor Environmental Statement Appendix A - Register of Environmental Legislation Chemical data sheets and labelling Machinery space drainage from shipping Radioactive sources Produced water The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (revoked by the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009) The Merchant Shipping (Prevention of Oil Pollution) Regulations 1996 (as amended 2000 and 2005) (as amended by the Merchant Shipping (Implementation of Ship‐Source Pollution Directive) regulations 2009) Dangerous Goods (IMDG) code and that dangerous goods declarations are provided to vessel masters prior to loading. Regulator: Health and Safety Executive The transport of chemicals to and from offshore fields is principally by road to shore base and then by sea. These regulations (commonly known as CHIP 3) specify safety data sheet format and contents and required packaging and labelling of chemicals for supply. The 2009 regulations, CHIP4, consolidate all amendments made to the Chemicals (Hazard Information and Packaging for Supply) Regulations since 2002. Regulator: Maritime and Coastguards Agency The Merchant Shipping (Prevention of Oil Pollution) Regulations 1996 (as amended) implement Annex I of MARPOL into UK legislation. Within a ‘Special Area’ ships which are 400GT or above can discharge water from machinery space drainage providing the oil content of the water does not exceed 15ppm. Vessels must be equipped with oil filtering systems; automatic cut offs and oil retention systems. All vessels must hold an approved Shipboard Oil Pollution Emergency Plan (SOPEP) and must maintain a current Oil Record Book and the ship must be proceeding on its voyage. All vessels must hold a UKOOP certificate or an IOPC certificate for foreign ships. Installations can obtain a temporary exception from MCA under an informal agreement between the UKOG and the MCA, however new installations need to demonstrate their ‘equivalence’ to other offshore installations where temporary installations are being issued and they are unlikely to obtain a certificate unless they fully comply with the requirements. Note, if all machinery drainage is routed via the hazardous or non‐hazardous drainage systems this will fall under OPPC and not require a UKOOP certificate. MARPOL 73/78 also defines a ship to include "floating craft and fixed or floating platforms" and these are required where appropriate to comply with the requirements similar to those set out for vessels. The amendments made under the Merchant Shipping (Implementation of Ship‐Source Pollution Directive) Regulations 2009 close an existing loop hole, where some large oil and chemical spills were not open to prosecution under MARPOL. Radioactive Substances Act 1993 Regulator: SEPA or Environment Agency (EA) The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended 2011) (as amended by the Energy Act 2008 A certificate, issued by SEPA or EA is required for any new sources brought onto installations. The application must refer to all temporary or permanent radioactive sources taken offshore. The certificate must be displayed or be easily accessible to those whose work activity may be affected. Amendments to the Act are scheduled to come into force in October 2011 (see pending legislation). Regulator: DECC Discharge limits under OPPC are: A monthly average oil‐in‐water concentration of 30mg/l; D/4114/2011 A ‐ 17
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Environmental statement - Flyndre and Cawdor - Maersk Oil

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