The Petroleum Safety Authority Norway, the Norwegian Environment Agency and the Norwegian Radiation and Nuclear Safety Authority (DSA) are proposing amendments to the following regulations and their guidelines:
- The Framework Regulations
- The Management Regulations
- The Facilities Regulations
- The Activities Regulations
- The Technical and Operational Regulations.
- The proposals were submitted to the members of the Regulatory Forum for review and comment prior to public consultation.
The DSA’s recommendation to incorporate the Act on Radiation Protection and Use of Radiation into the list of governing laws for the regulations is set out in the attached letter.
Concerning the Norwegian Environment Agency’s proposed amendments
The Norwegian Environment Agency sees a need to take a more active role in the early phase of petroleum activities. We therefore propose a new requirement to notify us in the early phase of petroleum activities in Section 26 of the Framework Regulations. The message will be concise, but form a basis for allowing us to request more detailed information about the planned activity if necessary.
Section 64 of the Activities Regulations proposes exemptions for environmental assessments for certain chemicals, and it is proposed to legalise the use of emulsion breakers during action to combat acute pollution in Section 66 of the Activities Regulations.
Furthermore, we propose that requirements for measurement and calculation be more widely legislated through statutory regulation. They have been regulated in part as conditions attached to permits, but the requirements are not activity-specific, and we consider it more appropriate for them to be regulated by statute. This will also help make the requirements more predictable for the industry. The proposed changes are included in Section 70 of the Activities Regulations, and beyond the requirements for measuring and calculating NOx emissions, our assessment is that the amendments do not entail material changes in the regulation. For proposed changes in the requirements for measuring and calculating NOx emissions, the consequences of the proposal are described in a separate annex.
For injection, we also propose a greater degree of statutory regulation to make the requirements more predictable for the industry. Proposals for statutory regulation have been included in Section 71 of the Activities Regulations. The proposed amendments do not, in our view, entail material changes in the regulation.
The Norwegian Environment Agency proposes a new section, Section 72a of the Activities Regulations, on the abandonment of waste, equipment and other material to cover both waste (moveable) and fixed equipment (which is not waste). This will cover the aspects of abandonment that are currently processed by the Norwegian Environment Agency, and meet both the rules in the Pollution Control Act concerning the leaving of waste that may cause damage or nuisance to the environment and the prohibition in OSPAR (decision 98/3) against the leaving in place of equipment from drilling that rises above the surface of the sea-bed. The proposed amendments do not, in our view, entail material changes in the regulation.
The justification and assessment of any financial and administrative consequences of the specific proposals are given in the attached consultation document.
The consultation deadline is 1 October 2020.
Please send comments by e-mail to firstname.lastname@example.org.