Environmental statement - Flyndre and Cawdor - Maersk Oil

Flyndre and Cawdor Environmental Statement
Section 1 Introduction
The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (&
Amendments 2011) have been designed to encourage operators to continue to reduce the quantities
of hydrocarbons discharged during the course of offshore operations. The 2011 OPPC Regulations
update the definition of oil, introduce a permitting system for oil discharges and strengthen the
powers to inspect and investigate oil discharges. The issue of permits under these Regulations is the
mechanism used to implement OSPAR Recommendation 2001/1. In line with OSPAR
Recommendation (2001/1), the UK (DECC) has introduced regulatory requirements to reduce the
permitted average monthly oil discharge concentration to 30 mg/l.
OSPAR Recommendation 2001/1 also requires a 15% reduction in the discharge of oil in produced
water from 2006 measured against a 2000 baseline; controlled by the issue of permits to each
installation. The permits replaced the granting of exemptions under the Prevention of Oil Pollution
Act 1971 and are issued under the Offshore Petroleum Activities (Oil Pollution Prevention and
Control) Regulations 2005. This target has been met and maintained by the industry as a whole.
The Offshore Petroleum Activities (Oil Pollution Prevention and Control) (Amendment) Regulations
2011 have introduced a number of changes to the Regulations. This includes a new definition of
"offshore installation" which encompasses all pipelines ‐ some of which were not previously covered
by the OPPC Regulations. The amending OPPC Regulations also include the concept of "release" to
cover all unintentional emissions of oil that occur through accidental spills / leaks or non‐operational
discharges. Intentional emissions are now clarified as discharges. However, given that the OPPC
Regulations already covered oil spills and leaks, the concept of "release" is being incorporated by the
amending Regulations solely for the purpose of conformity with the Offshore Chemicals
(Amendment) Regulations 2011.
The draft OSPAR Recommendation for produced water discharges (yet to come into force) requires
operators to follow a risk based approach to the management of PW discharge from offshore
installations. The implications of the Recommendation for discharges of PW into the UKCS are not
yet defined, however, in alignment with the Recommendation it is likely that requirements will
comprise undertaking risk characterisation; either on substances based approach or a whole effluent
approach, or a combination of the two.
The Marine and Coastal Access Act (MCAA) came into force in November 2009. The Act covers all UK
waters except Scottish internal and territorial waters which are covered by the Marine (Scotland) Act
(2010), which mirrors the MCAA powers. Licensing provisions in relation to MCAA came into force on
1 st April 2011. The MCAA will replace and merge the requirements of FEPA Part II (environment) and
the Coastal Protection Act (navigation). The following activities are exempt from the MCAA as they
are regulated under different legislation;
activities associated with exploration or production / storage operations that are authorised
under the Petroleum Act
additional activities authorised solely under the DECC environmental regime, for example,
chemical and oil discharges.
Therefore, activities which are not regulated by the Petroleum Act or under the DECC environmental
regime, and decommissioning operations require an MCAA licence since April 2011.
Oil Pollution Emergency Plans (OPEPs) are required under the Merchant Shipping (Oil Pollution in
Preparedness, Response and Co‐operation Convention) Regulations 1998. The regulations require the
arrangements for responding to incidents which cause or may cause marine pollution by oil to be in
place and the consequence of incidents to be assessed including the potential environmental and
socio‐economic impacts.
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