§ 69 Formation testing, clean-up and start-up of wells
The operator shall plan and conduct the activity at the formation testing, clean-up and start-up of production wells to minimize emissions to air and sea, cf. Section 11 of the Framework Regulations. The evaluations of method selection, and technical solutions and measures to minimize emissions, shall be documented.
If the activity causes flaring or burning over the burner boom, combustion shall be optimized to ensure high combustion efficiency, so that air and sea emissions are minimized.
The operator shall take the necessary measures to limit potential damage to the external environment when oil spillage from the burning of hydrocarbons causes visible oil on the sea surface. The obligation to take action relates to measures that are in a reasonable proportion to the damage and inconveniences to be avoided.
Oil-containing water from the activity to be released to the sea from the facility shall be handled in accordance with Section 60a.
Oil and chemical-containing water from clean-up and start-up of production wells can only be shipped with the production flow to shore if the recipient on land is authorized to receive such water and has capacity and is suitable in each case to accept. When such water is shipped with the production flow to shore, the operator shall optimize the dosage of chemicals added to the export flow so that the potential for environmental damage at receiving plants is minimized, cf. Section 64, first subsection.
The operator shall have permission under Chapter 3 of the Pollution Control Act (in Norwegian only) for formation testing, clean-up and start-up of wells.
Section last changed: 01 February 2019
The operator must obtain a permit from the Norwegian Environmental Agency for petroleum activities under Chapter 3 of the Pollution Control Act (in Norwegian only). Application for permit under the Pollution Control Act is subject to Chapter 36 of the Pollution Control Regulations (in Norwegian only), and a fee is fixed for the Environmental Agency’s processing relating to applications for permits pursuant to Chapter 36 of the Pollution Control Regulations (in Norwegian only).
The regulations’ general requirements for the petroleum activities on the continental shelf apply to all operators. The permits under the Pollution Control Act will normally contain conditions that are specific and adapted to each activity. Chapter 36 of the Pollution Control Regulations (in Norwegian only) gives further provisions on the processing of permits under the Pollution Control Act. The Norwegian Environment Agency has described further expectations for the content of applications and expected processing time in the Guidelines for applications regarding offshore petroleum activities, TA-2847-2011. Chapter 39 of the Pollution Control Regulations (in Norwegian only) gives provisions for fees for work with permits.
By formation testing, this section refers to testing of a single well's production or injection properties for a maximum of ten days of flow, cf. the Regulations relating to Resource Management in the Petroleum Activities (Resource Mangagement Regulations) Section 3.
By clean-up of of wells, this section refers to activity carried out on producing wells where hydrocarbons and other liquids are brought to the surface to clean the well and perforations before the well is put into production or back into production.
Minimization as mentioned in the first and second subsections, shall be understood as minimization given that the purpose of the activity is achieved and the measures are in a reasonable proportion to the damage and inconveniences to be avoided.The assessment of the choice of method and planning of the activity should include energy consumption, emission components and emission amounts to air and sea, chemical use, generation and handling of waste and risk of acute pollution, both at sea and with any handling on land. The time and place of the activity in conjunction with the presence of vulnerable environmental values should also be included in the assessments.
Measures to minimize emissions may include access to tanks with sufficient storage capacity and continuous testing of the test facility to ensure optimal combustion.
Measures as mentioned in the third subsection, may include monitoring of oil and seabirds, or mechanical dispersion to remove oil from the sea surface.
The test facility, including equipment for the separation of water, oil and gas and flares, shall comply with the requirements for the use of best available techniques (BAT), cf. the Framework Regulations Section 11, second paragraph, cf. the Facilities Regulations Section 5 and 10.
Well clean-ups and start-up of production wells can lead to operational challenges and the risk of reduced cleaning efficiency in the production water treatment plant to a greater or lesser extent. These are activities that are planned and where operational challenges and disturbances in the treatment plant can be prevented, including through good planning based on knowledge of expected content and amounts of chemicals in the fluid flow, impact on the treatment plant and the establishment of methods for operating the processing plant in various operations.
If oil and chemical-containing water from clean-up and boilers are landed, the colour categories and chemical assessments used for offshore petroleum activities cannot be transferred directly to the operations on land. The environmental significance may be different from land discharges, in shallow waters with other natural resources and recipient conditions. This also applies to chemicals in the green category, which are considered not to present a risk of damage to open-sea discharges.
If oil and chemical containing water is sent to recipients on land outside Norway, the operator is obliged to ensure that the treatment of the water at the recipient is legal, but the requirement for permit will not always be relevant.