ENVIRONMENT REPORT
2015
page 52
a. The Hydrocarbons BREF
The EC Environment Directorate-General (DG ENVI) has proposed the development of a Best Available Techniques
(BAT) Reference document or BREF on hydrocarbon exploration and extraction. The overall objective is to support
the Commission in identifying the Best Available Techniques for risk and impact management for the hydrocarbons
exploration and extraction sector. This is intended to assist licensing and permitting by Competent Authorities
of Member States. Oil & Gas UK continues to engage with the EC, industry and government to ensure that the
BREF does not have any unintended consequences for the environmental and safety regimes already in place on
the UKCS.
b. The Implementation of the EU Offshore Safety Directive
On 28 June 2013, the EC published the Directive 2013/30/EU on the safety of European offshore oil and gas
operations. The objective is to set minimum requirements to reduce as far as possible the occurrence of major
accidents related to operations and to limit their consequences. The Directive was transposed into UK law on
19 July 2015.
The Directive has placed additional requirements on oil and gas companies to include further details in their
Oil Pollution Emergency Plans (OPEP) on oil spill response equipment, oil spill response effectiveness, alignment
with national plans and monitoring. The Directive also requires consideration of the potential environmental
consequence of a major accident event to be included in the offshore Safety Case and additional demonstration
of financial, technical, safety and environmental management capability at the time of licence application.
Oil & Gas UK has been actively working with its members in the past year to understand the new requirements
and provide supporting materials to help operators meet their obligations, aimed at adopting a standardised
approach and minimising any additional administrative burden. Examples in 2015 include
Guidelines on Oil Spill
Response Effectiveness in UK Waters
51
and technical notes on financial responsibility for production assets and
environmental critical elements.
c. The Large Combustion Plant BREF
The Industrial Emissions Directive (2010/75/EU) is implemented through the Offshore Combustion Installations
(Pollution Prevention and Control) Regulations 2013 and is applicable to combustion installations of
50 Mega Watts thermal (MWth) or over. The Directive requires the development of BREF documents.
The Large Combustion Plant BREF has been largely drafted in 2015 and sets BAT Associated Emission Limits (AELs)
for NO
x
and CO and suggests that Dry Low NO
x
(DLN)
52
is the BAT for offshore turbines. Application of the original
BREF recommendations in UK permits would have required refit or renewal of a significant number of turbines
on the UKCS, with the potential for forcing early cessation of production for some platforms and impacting the
industry’s ability to maximise economic recovery on the UKCS.
51
The
Guidelines on Oil Spill Response Effectiveness in UK Waters
are available to download at
http://oilandgasuk.co.uk/product/the-oil-spill-response-effectiveness-in-uk-waters/52
A technical note on DLNs is available to download at
http://bit.ly/1MwT4jI