premier oil uk limited 2015 environmental statement · premier oil uk limited 2015 environmental...

Premier Oil UK Limited 2015 ENVIRONMENTAL STATEMENT

2015 Environmental Statement

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TABLE OF CONTENTS ABBREVIATIONS .................................................................................................................3

1.0 INTRODUCTION ....................................................................................................5

2.0 OVERVIEW OF OPERATIONS ..............................................................................6

2.1 Production Operations – Balmoral Floating Production Vessel (FPV).....................6

2.2 Projects ..................................................................................................................7

(a) Solan ...............................................................................................................7

(b) Catcher ...........................................................................................................9

2.3 Drilling Operations................................................................................................ 10

(a) Solan Drilling ................................................................................................. 10

(b) Catcher Drilling .............................................................................................. 11

(c) Other Drilling Operations ............................................................................... 11

3.0 HSE & SECURITY MANAGEMENT SYSTEM ..................................................... 12

4.0 ENVIRONMENTAL PERFORMANCE .................................................................. 15

4.1 Oil in Produced Water .......................................................................................... 15

(a) Balmoral FPV – Total Volume of Produced Water ......................................... 15

(b) Balmoral FPV – Total Mass of Oil Discharged to Sea .................................... 16

(c) Balmoral FPV – Average Oil in Produced Water Concentration .................... 17

4.2 Chemical Use and Discharge ............................................................................... 18

(a) Balmoral FPV – Chemical Use and Discharge .............................................. 19

(b) Solan Drilling – Chemical Use and Discharge ............................................... 20

(c) Catcher Drilling – Chemical Use and Discharge ............................................ 22

4.3 Waste................................................................................................................... 23

(a) Balmoral FPV Waste ..................................................................................... 23

(b) Solan Drilling Operations Waste .................................................................... 24

(c) Catcher Drilling Operations Waste ................................................................ 26

4.4 Atmospherics ....................................................................................................... 28

(a) Balmoral FPV Atmospheric Emissions .......................................................... 28

(b) Drilling Operations Atmospheric Emissions ................................................... 29

5.0 INCIDENTS .......................................................................................................... 31

5.1 Unplanned Releases – PON 1 ............................................................................. 31

5.2 Permitted Discharge Notifications – PON 1 .......................................................... 32

5.3 Regulatory Non-Compliance (NC) ........................................................................ 32

6.0 ENVIRONMENTAL PERFORMANCE AGAINST TARGETS ............................... 34


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ABBREVIATIONS

Bbl/d Barrels of Oil per Day

CEFAS Centre for Environment, Fisheries and Aquaculture Science

CH4 Methane

CO Carbon Monoxide

CO2 Carbon Dioxide

DECC Department of Energy & Climate Change

ECE Environmentally Critical Elements

EU ETS European Union Emissions Trading Scheme

FPS Forties Pipeline System

FPSO Floating Production Storage and Offloading Vessel

FPV Floating Production Vessel

HSES Health, Safety, Environment and Security

ISO International Standards Organisation

IOGP International Association of Oil and Gas Producers

mg/l Milligrams per Litre

NCN Non Compliance Notice

NCR Non Conformance Report

NOX Nitrous Oxides

OCNS Offshore Chemical Notification Scheme

OCR Offshore Chemicals Regulations

ODP Oil Discharge Permit

OHSAS Occupational Health and Safety Assessment Series

OPEPs Offshore Pollution Emergency Plans

OPPC Oil Pollution Prevention and Control

OIW Oil in Water

OSD Offshore Safety Directive


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PDN Permitted Discharge Notification

PLO Poses Little or No Risk

PON Petroleum Operations Notice

PPC Pollution, Prevention and Control

ROV Remotely Operated Vehicle

RQ Risk Quotient

SOX Sulphur Oxides

SUB Chemicals Rated for Substitution

UKCS United Kingdom Continental Shelf

VOCs Volatile Organic Compounds


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1.0 INTRODUCTION

Premier Oil UK Limited hereafter referred to as Premier, is the UK subsidiary of the

publicly listed oil and gas company Premier Oil plc. Premier Oil plc is a leading

independent exploration and production company with oil and gas interests in the

North Sea, South East Asia, Pakistan, the Falkland Islands and Latin America.

Premier’s North Sea position was transformed with the acquisition of Oilexco North

Sea Ltd in 2009, adding a production base, including operatorship capability, and a

broader development and exploration portfolio in the UK North Sea. Since then,

Premier has discovered the Catcher Area fields, which are currently under

development, brought on-stream the Huntington and Solan fields and, most recently

in April 2016, acquired E.ON’s UK North Sea assets.

Under OSPAR (Convention for the Protection of the Marine Environment of the North-

East Atlantic) Recommendation 2003/5, the regulatory agency Department of Energy

and Climate Change (DECC) requires that all companies operating in the United

Kingdom Continental Shelf (UKCS) have systems and procedures in place to identify,

monitor and control the environmental aspects associated with offshore activities.

The Premier operated Balmoral Floating Production Vessel (FPV), worldwide drilling

operations, the Aberdeen office and onshore services are certified to the international

environmental management system standard, ISO 14001. Recertification of ISO

14001 was granted in 2014 and surveillance visits are undertaken annually.

This report provides information on Premier’s UK offshore operations in 2015, and the

environmental performance of these operations. For the purpose of this report, these

operations include all production and drilling activities undertaken by Premier in the

UKCS. Therefore, whilst an overview of Solan and Catcher is provided, only drilling

data is included as these fields did not produce during 2015. This report also

excludes information about the assets secured as part of the E.ON acquisition as

these were not part of Premier’s portfolio in 2015. Year-on-year comparisons

provided are factual however, in some cases, these do not represent like for like

comparisons. This is due to different operational modes on installations, start-up

dates and changes in regulatory reporting requirements.

This report is available via the Premier Oil website at;

http://www.premier-oil.com/premieroil/corporate-responsibility/environment-new


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2.0 OVERVIEW OF OPERATIONS

2.1 Production Operations – Balmoral Floating Production Vessel (FPV)

The Balmoral FPV (Fig. 2.1) is located in Block 16/21a in the Central North Sea -

approximately 125 miles north-east of the Aberdeen and 20 miles west of the

UK/Norway trans-boundary line in a water depth of approximately 147m (Fig. 2.2).

Figure 2.1 – Balmoral FPV Figure 2.2 – Balmoral FPV Location

First oil was produced from Balmoral in 1986. In 2009, Premier acquired operatorship

of the installation as part of the acquisition of Oilexco North Sea Limited in 2009.

Balmoral processes fluids from the Balmoral, Stirling, Brenda, Nicol, Burghley and

Beauly fields, with the crude oil transported to shore via the BP operated Forties

pipeline system (FPS) to the Kinneil reception terminal on the Firth of Forth.

Produced gas is used for power generation and gas lift, with excess gas flared from

the installation. The water phase is treated to meet the regulatory standard for oil in

water and is then discharged overboard under an Oil Discharge Permit (ODP) issued

by DECC.


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Figure 2.3 – Balmoral Field Schematic

2.2 Projects

(a) Solan

The Solan platform (Fig. 2.4) is a single steel jacket structure located in Block

205/26a of the UKCS, west of Shetland - 60 miles from the Scottish coast and 35

miles from the UK/Faroes median line in a water depth of approximately 138m

(Figure 2.5).

Figure 2.4 – Solan Installation Figure 2.5 – Solan Location

The facility is designed to process fluids from two production wells supported by two

water injector wells. It is capable of producing a peak flowrate of 28,000 Barrels of Oil

per Day (bbl/d) with separated crude accumulating in a Subsea Oil Storage Tank

prior to offloading to a tanker. Produced gas is used for power generation with excess


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gas flared from the installation. Produced and ballast water is treated and injected to

maintain reservoir pressure.

Figure 2.6 – Solan Field Schematic Figure 2.7 – Solan Oil Storage Tank

During 2015, Premier commenced offshore works in support of the Solan

Development Project, including:

• Commissioning activities on the platform

• Subsea operations including tie-in of the 1st Production (P1) and Water

Injection (W1) wells

• Drilling of the 2nd Production (P2) and Water Injection (W2) wells

• Tanker hook up and offloading trial completed

• Single Anchor Loading installation completed

At the time of writing, commissioning had been completed and First Oil achieved in

spring 2016.


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(b) Catcher

Located in Blocks 28/9a and 28/10c of the UK North Sea, the Catcher Area

Development Project is focused on three fields (Catcher, Burgman and Varadero),

collectively referred to as the Catcher Area Fields. Figure 2.9 illustrates the location of

the Catcher Area Fields - approximately 125 miles south east of Aberdeen and in a

water depth of approximately 90m.

Figure 2.8 – Catcher Hull Section Outload Figure 2.9 – Catcher Field Location

The facility is designed to produce a peak flowrate of 60,000 Barrels of Oil per Day

(bbl/d). The three reservoirs will each be tied back to a single centrally located

Floating Production Storage and Offloading (FPSO) processing and export facility

which is currently under construction.

Separated crude will be held in the vessels cargo tanks prior to being offloaded to a

tanker. When offloading cargo, tank blanketing will normally use LP fuel gas, this gas

being recovered via the flare gas recovery package. Initially, produced gas will be

used for power generation and gas lift, with excess being exported into the SEGAL

system.

In normal operations, Catcher flaring is restricted to HP flare purge gas only. The LP

flare system uses a Vapour Recovery Package to recover purges and vents sent to

the LP flare system. The LP flare is lit, as required, in process upset or ESD

conditions only. Produced water will be treated and then either re-injected or

discharged under an ODP issued by DECC.


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Figure 2.10 – Catcher Development Schematic

During 2015, Premier Oil commenced offshore works in support of the Catcher Area

Development Project, including:

• Mattress and rock placement at third party pipeline crossings

• Installation, trench and burial of the 62 km gas export pipeline between the

proposed Catcher FPSO location and the tie-in point into the Shell Fulmar gas

pipeline

• Installation of the first Catcher subsea and drilling related infrastructure

• Commenced the drilling of the first 4 x Catcher development wells at Catcher

Drill Centre Template

First oil is expected in 2017.

2.3 Drilling Operations

(a) Solan Drilling

During 2015, drilling operations continued on the Solan 2nd producer (P2) and water

injection (W2) wells. This work was undertaken by the Ocean Valiant semi-

submersible drilling rig.

Figure 2.11 - Ocean Valiant Drilling Rig Figure 2.12 – Location of Solan wells


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The W2 well was re-entered following suspension in 2013 and was subsequently

completed in 2016. The P2 well was also re-entered but mechanical problems were

encountered which resulted in the well being suspended during September. At the

time of writing, the Ocean Valiant was in the process of completing P2.

(b) Catcher Drilling

Drilling operations in the Catcher Field commenced during 2015 using the Ensco 100

jack-up drilling rig. Two wells were completed and tested successfully.

Figure 2.13 – Ensco 100 Drilling Rig Figure 2.14 – Location of Catcher wells

(c) Other Drilling Operations

The Ptarmigan well abandonment (severing and recovering the wellhead) operation

was also undertaken in 2015. The work was completed by the Skandi Constructor

Light Well Intervention Vessel (LWIV), operated by Helix Well Ops.

Figure 2.15 – Skandi Constructor Figure 2.16 – Location of Ptarmigan well


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3.0 HSE & SECURITY MANAGEMENT SYSTEM

‘Premier is focused on protecting the environment in line with our stated commitment

to reduce our impact to a level that is as low as reasonably practicable. This involves

ongoing assessment, monitoring and reporting on environmental impacts of all our

operations.’

The Premier Oil Health, Safety, Environment and Security Management System

(HSES-MS) exists to provide a systematic approach to the management of HSES

issues in order to protect people and the environment and comply with UK legislation.

Premier considers that health, safety, environment and security have equal status

with other primary business objectives and are of strategic importance to Premier.

Safe working practices and due consideration of environmental impact are vital to the

overall efficiency and continued success of the business. The HSES policy forms the

basis for the HSES-MS and is presented below.

Figure 3.1 Premier HSES Policy


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The HSES-MS has a hierarchical document structure as illustrated in figure 3.2. It is

based on the industry model prepared by the International Association of Oil and Gas

Producers (IOGP) and embraces the principles of quality management as found in

the ISO 14001 and Occupational Health and Safety Assessment Series (OHSAS)

18001 international standards.

Figure 3.2 shows the structure of the HSES-MS, which is comprised of;

• Premier’s HSES Policy;

• The Premier Corporate Expectations. These are owned by the CEO and

issued by the Group HSES manager. The corporate expectations apply to all

Premier Business Units;

• The tools to allow for implementation of the Corporate Expectations i.e.

Business Unit and Asset Specific procedures, contractor procedures and

bridging documents.

Figure 3.2 - HSES-MS Structure

The Premier HSES Management System has 10 individual Elements. Each Element

contains a set of concise expectations that are mandatory for implementation and

maintenance within all the constituent parts of the Premier Oil group of companies

(the Group). They define ‘what’ is expected by the Group in order to manage HSES

risk during execution of work activities.


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Figure 3.3 below shows the ten elements that make up the Premier Oil HSES

Management System.

Figure 3.3 - HSES-MS Framework


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4.0 ENVIRONMENTAL PERFORMANCE

Environmental performance for all operating assets is detailed below. Comparison

against 2014 data has been made where like for like comparisons are feasible due to

consistent and comparable operations being undertaken at the respective site.

4.1 Oil in Produced Water

During normal production, water is produced when extracting hydrocarbons from the

reservoir. On the Balmoral FPV, bulk separation of produced water is achieved in the

1st Stage Separator, 2nd Stage Separator and Test Separator vessels. The

separated produced water is routed to the hydro-cyclones and the tilted plate

separator for further removal of entrained oil. The treated produced water is then

discharged to sea via a dedicated caisson.

Despite treatment, produced water still contains traces of oil, and as such, produced

water discharge is controlled via a permitting system managed by the UK regulatory

authority, DECC.

The 2015 Oil Discharge Permit held by Premier for Balmoral allows the installation to

discharge produced water, provided the hydrocarbon concentration is within the limit

set out in the permit (a monthly average of 30 milligrams per litre).

(a) Balmoral FPV – Total Volume of Produced Water

Figure 4.1 shows the cumulative produced water discharges from Balmoral FPV

during 2015. The total volume of produced water discharged to sea from the Balmoral

FPV was 2,639,730m3 against the permitted volume of 3,122,145m3. This equates to

a discharge of 84.5% of the Balmoral FPV permit produced water volume limit and is

an increase in the total amount discharged as compared with 2014 (2,489,361m3).

When a comparison is made between daily average produced water values for 2014

and 2015, there has been average daily increase of 6%. However, as wells mature,

the percentage of water cut from the reservoir fluids naturally increases. It is

therefore expected that the produced water quantity will increase on an annual

ongoing basis.


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Figure 4.1 - Total Volume of Produced Water Discharged

(b) Balmoral FPV – Total Mass of Oil Discharged to Sea

Figure 4.2 shows the total mass of oil in produced water discharged to sea from the

Balmoral FPV in 2015 was 21.336 tonnes. This is 20.3% greater than the 17.74

tonnes discharged in 2014, but within the permitted volume of 28.099 tonnes for the

year.

This is in line with the increase in the total quantity of produced water discharged

(Figure 4.1). As wells mature, the percentage of water cut from the reservoir fluids

naturally increases. It is therefore expected that the produced water quantity will

increase annually.

Figure 4.2 - Total Tonnage of Oil Discharged in Produced Water

0

500000

1000000

1500000

2000000

2500000

3000000

3500000

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Pro

du

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Wa

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m3)

Cumulative Discharge Cumulative Permit Limit

0

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Oil

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(to

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Cumulative Oil Discharge Cumulative Permit Limit


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(c) Balmoral FPV – Average Oil in Produced Water Concentration

The yearly average concentration of oil discharged in produced water for Balmoral in

2015 was 8.1 mg/l. This compares favourably with the regulatory permitted monthly

average of 30 mg/l.

Whilst the 2015 average is 18.5% higher than in 2014, it is still significantly below the

permitted monthly average.

This continued good performance is down to the optimised management of the

produced water treatment equipment and the highly efficient chemicals used to

remove oil from the produced water before discharge.

Techniques used on Balmoral towards both lowering the concentration of oil in

produced water and reducing the amount of oil passed to sea continue to be

particularly effective.

Figure 4.3 presents the rolling monthly average oil in water concentration for Balmoral

in 2015.

Figure 4.3 – Average Oil in Water Concentration in Produced Water

0

5

10

15

20

25

30

35


Oil

in

Wa

ter

Co

nce

ntr

ati

on

(m

g/l)

Average Oil in Water Concentration Permit Limit


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4.2 Chemical Use and Discharge

Various chemicals are used offshore in drilling and production operations.

During production operations, chemicals such as scale dissolvers, corrosion

inhibitors, demulsifiers and biocides are used to assist with the separation of oil and

water, prevent damage to infrastructure such as pipelines, and to prevent ‘souring’ of

the reservoir.

In drilling operations these chemicals include fluids known as ‘drilling muds’, which

lubricate and cool the drilling bit, maintain downhole pressure and bring the drill

cuttings to the surface.

Any chemical used offshore must, in line with the Offshore Chemical Regulations

2002, first be approved by the Centre for Environment, Fisheries and Aquatic

Sciences (CEFAS). The chemicals are subject to robust environmental risk

assessment and once approved their use is controlled and monitored through a

permit granted by DECC.

Under the Offshore Chemical Notification Scheme (OCNS), chemicals are ranked

according to the assessed hazard to the environment and are given a lettered

heading E, D, C, B or A, with E representing the lowest and A the highest hazard

category.

Using the Chemical Hazard and Risk Management (CHARM) model, a colouring

band is used to show which chemicals pose the highest hazard. These bands are

Gold, Silver, White, Blue, Orange or Purple with Gold representing the lowest hazard

and Purple the highest.

Some chemicals are regarded as PLONOR (PLO), which means that they have been

determined to pose little or no risk to the environment.

Any chemicals which have been identified as posing potential environmental risks

(such as bioaccumulation or slow biodegradation) are subject to controls under which

their use must first be approved by DECC. This is backed up by a detailed

justification for use of the chemical. Such chemicals carry a ‘substitution warning’

(SUB) which aims to encourage the phase out of the use of these chemicals.

Premier Oil, its contractors and its chemical suppliers work on a continuous basis to

find suitable alternatives to replace the products with SUB warnings.


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(a) Balmoral FPV – Chemical Use and Discharge

A total of 5 chemicals with substitution warnings (SUB) were permitted for use on

Balmoral in 2015. These chemicals are detailed in Table 4.1. During 2015 however, 2

of these chemicals were replaced by products with better environmental credentials

i.e. without SUB warnings.

Chemical & OCNS Category Summary of Change Out Review

EC1231A, Nalco Ltd,

Corrosion Inhibitor, Gold, 2015

The chemical supplier and Premier are working to replace this chemical with a SUB free alternative.

EC6152A, Nalco Ltd,

Scale Inhibitor, Gold 2015

The chemical supplier and Premier are working to replace this chemical with a SUB free alternative.

EC6199A, Nalco Ltd,

Biocide, Gold, 2015

This chemical was used to treat the sludge/bilge tanks. This product was substituted with a biocide without a SUB warning during 2015.

FX2134, Nalco Ltd,

Demulsifier, Gold, 2015

Demulsifier breaks down the oil in water emulsions within produced fluids and helps to provide efficient separation to ensure minimal oil is discharged into the environment. FX2134 was substituted with a demulsifier without a SUB warning during 2015.

SCW85649, Baker Hughes Ltd,

Scale Inhibitor, Gold, 2015

This chemical is a scale inhibitor that is continuously injected downhole at the Burghley well. No return is expected and a worst case discharge of 1% has been assumed. These dosages generated RQs <1, indicating that the discharge of this chemical is not expected to pose a significant risk to the surrounding marine environment although review will continue to assess the feasibility of using of a SUB free alternative.

Table 4.1 - SUB Chemicals Permitted for use in Balmoral FPV operations

The change out of these two chemicals resulted in a 47% reduction in SUB chemical

usage during 2015 as compared to 2014, with the use of SUB chemicals equating to

18.6% (61,471 kg) of all chemicals used during the year.


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Figure 4.4 – SUB Chemical Use during Balmoral FPV operations

In figure 4.5 the chemicals used on Balmoral FPV during 2015 have been grouped by

OCNS category. This figure shows that 22% of all the chemicals used and discharged

are rated PLO. Due to the change out of the two SUB labelled chemicals during

2015, the use and discharge of SUB chemicals should also be significantly reduced

during 2016.

Figure 4.5 - Chemical Use and Discharge during operations, by OCNS Category

(b) Solan Drilling – Chemical Use and Discharge

Note: Chemical use and discharge information presented relates to all P2 well

operations undertaken in 2015. W2 well operations were also undertaken in 2015, but

were not completed that year and continued into 2016. The the chemical use and


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discharge data for the now completed W2 well operations will be reported in the 2016

report.

A total of 19 chemicals with SUB warnings were permitted for use during the Solan

P2 re-drill operations in 2015. Only 8 of these (making up 1.5% of total chemicals

use) were actually used and none were discharged.

Two of the chemicals with a SUB warning used during Solan drilling operations were

replaced with non-SUB (least harmful) products during 2015.

Figure 4.6 shows the percentage of SUB chemicals used relative to other chemicals.

Figure 4.6 – SUB Chemical Use during drilling operations

In figure 4.7 the chemicals used during the 2015 Solan P2 re-drill operations have

been grouped by OCNS category. This figure shows that 52% of all the chemicals

used and 92% of those discharged are rated PLO.


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Figure 4.7 - Chemical Use and Discharge during drilling operations

(c) Catcher Drilling – Chemical Use and Discharge

A total of 40 chemicals with SUB warnings were permitted for use during Catcher drilling

operations in 2015.

The amount of SUB Chemicals used fell by 24%, making up 0.38% of total chemical use.

None of these were discharged.

Figure 4.8 shows the percentage of SUB chemicals used relative to other chemicals.

Figure 4.8 – SUB Chemical Use during drilling operations


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In figure 4.9 the chemicals used during Catcher drilling operations have been

grouped by OCNS category. This figure shows that 73.6% of all the chemicals used

and 99.8% of those discharged are rated PLO.

Figure 4.9 - Chemical Use and Discharge during drilling operations by OCNS

4.3 Waste

Waste is generated from offshore operations and is transported onshore for re-use,

recycling, treatment or disposal.

On the Balmoral FPV and drilling installations, waste is segregated into categories

before back-loading. As much waste as possible is sent for recycling. This includes

wood, scrap metals, paper/cardboard, glass and plastics.

Waste that cannot be recycled is sent to landfill. Certain types of waste that are

harmful to the environment (Special Waste) are sent ashore to be processed and

disposed of by licensed handlers in accordance with the relevant legislation.

(a) Balmoral FPV Waste

A total of 165 tonnes of waste was disposed of from the Balmoral FPV in 2015

compared to 306 tonnes in 2014. Contributing to this 44% reduction in waste in 2015

was that there were no major shutdowns – work-scopes during shutdowns can

produce a lot of work related waste.

Balmoral recycled just under 59% of its waste during the year. The majority of non-

recycled waste was sent to landfill.

Figure 4.10 below shows the fate of waste produced from the Balmoral FPV.


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Figure 4.10 - Waste Disposal Routes

Premier continues to target areas where the amount of waste generated can be

further reduced. Initiatives such as reusing packaging and replacing bottled water

with water fountains together with continued staff awareness programmes have

contributed to a reduction in the amount of general waste being produced on the

Balmoral FPV.

(b) Solan Drilling Operations Waste

A total of 2471.2 tonnes of waste was disposed of from Solan drilling operations (P2

re-drill and W2 re-drill) in 2015. Of this figure, 2293.8 tonnes (92.8%) was drilling

waste (e.g. drill cuttings) and 177.4 tonnes (7.2%) operational waste (e.g. general

waste generated on the rig, scrap metal, wood etc.). About 24% of the drilling waste

(drill cuttings) was reused and 76% was sent to landfill. 49.6% of the operational

waste was recycled and 50.17% sent to landfill.

Figure 4.11 shows Operational Waste from the Drilling Rig working for Solan drilling

operations.

Recycling 58.98%

Waste to Energy 0.40%

Incinerated 4.91%

Landfill 31.41%

Other 4.30%


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Figure 4.11 - Operational Waste Disposal Routes

Recycling

49.60%

Landfill

50.17%

Other

0.23%


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Figure 4.12 below shows the Drilling Waste from the Drilling Rig used for Solan

drilling operations.

Figure 4.12 - Drilling Waste Disposal Routes

(c) Catcher Drilling Operations Waste

A total of 2,658.4 tonnes of waste was disposed of from Catcher drilling operations in

2015. Of this figure, 2,445.5 tonnes (92.4%) was drilling waste (e.g. drill cuttings) and

202.9 tonnes (7.6%) was operational (e.g. general waste generated on the rig, scrap

metal, wood etc.). 20.21% of the drilling waste (drill cuttings) was reused and 79.79%

was sent to landfill. 56.45% of the operational waste was recycled, 37.22% sent to

landfill, 6.01% converted to energy and less than 1% incinerated.

Figure 4.13 shows the Operational Waste from the Drilling Rig used for Catcher

drilling operations.

Re-use

23.99%

Landfill

76.01%


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Figure 4.13 - Operational Waste Disposal Routes

Figure 4.14 shows the Drilling Waste from the Drilling Rig used for Catcher drilling

operations.

Figure 4.14 - Drilling Waste Disposal Routes

Recycling

56.45%

Waste to Energy

6.01%

Incinerated

0.32%

Landfill

37.22%

Re-use

20.21%

Landfill

79.79%


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4.4 Atmospherics

Atmospheric emissions arise during offshore drilling and production operations

predominantly as a result of fuel combustion for power generation and gas flaring

activities.

There were some changes to reporting requirements for atmospheric emissions in

2015 (emissions factors changed). This mean that a comparison between 2014 and

2015 data is not like for like. The figures for 2015 are given in the following three

pages.

(a) Balmoral FPV Atmospheric Emissions

The Balmoral FPV is regulated under the Pollution, Prevention and Control (PPC)

Regulations as a large combustion installation. As such, the installation has set limits

on atmospheric emissions of nitrous oxides (NOx), sulphur oxides (SOx), carbon

monoxide (CO), methane (CH4) and volatile organic compounds (VOCs).

Figure 4.15 below shows the combustion emissions (excluding CO2) for 2015.

Figure 4.15 - Combustion Emissions

All emissions were within limits set by DECC in the Balmoral PPC Permit.

Balmoral is also regulated under the European Union Emission Trading Scheme (EU

ETS) Regulations, which regulate CO2 emissions for combustion sources, such as

turbines and flaring. Balmoral has no gas export route and as a result, produced gas

is used as fuel gas or is flared from the installation.

0

50

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NOx N2O SOx CO CH4 VOCs

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CO2 emissions as a result of combustion sources are presented in figure 4.16 on the

next page.

Figure 4.16 - CO2 Emissions: Combustion and Flaring

During 2015, 84,644 tonnes of CO2 were emitted from combustion and flaring on

Balmoral. Of these emissions, 69.6% were as a result of combustion for power

generation and the remaining 30.4% resulted from the flaring of excess gas.

CO2 emissions decreased by less than 1% compared to 2014 levels - this indicates

the energy efficiency initiatives implemented over the last couple of years have been

maintained by Balmoral. During normal operations, Balmoral FPV runs with one

turbine on fuel gas and one turbine on diesel.

(b) Drilling Operations Atmospheric Emissions

Atmospheric emissions during drilling operations are generated as a result of fuel

combustion for power generation and also during well test operations. There were no

well test operations related to Solan drilling during 2015, however, two well tests were

conducted during 2015 Catcher drilling operations.


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Combustion emissions from Solan drilling operations (excluding CO2) are shown in

figure 4.17. In addition 8,303 tonnes of CO2 were released during 2015.

Figure 4.17 - Combustion Emissions– Solan drilling operations

Combustion emissions from Catcher drilling operations (excluding CO2) are shown in

Figure 4.18. In addition 8,920.53 tonnes of CO2 were released during 2015.

Figure 4.18 - Combustion Emissions – Catcher drilling operations

0

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100

NOx N2O SOx CO CH4 VOC

Co

mb

ust

ion

Em

issi

on

s (T

on

ne

s)


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5.0 INCIDENTS

Premier strives to prevent the unplanned release of hydrocarbons and chemicals,

however, on occasion accidental releases do occur. All unplanned releases of

hydrocarbons and chemicals to sea from offshore oil and gas installations and

pipelines, regardless of size, are reported to DECC and other statutory agencies via

the Petroleum Operations Notice 1 (PON1) form. Permitted Discharge Notifications

(PDN’s) are also submitted using PON 1 forms when permitted discharges are in

breach of conditions / limits associated with the installations Oil Discharge Permit.

A number of processes are in place to prevent unplanned releases and these include

planned maintenance of equipment, asset integrity inspections, activity risk

assessment, area inspections, pre-acceptance drill rig and routine audits, procedural

controls and training and competency for individuals interacting with process plant.

Oil Pollution Emergency Plans (OPEPs) approved by DECC are in place covering all

operational assets including third party drilling installations. These plans are

exercised on a regular basis and followed in the event that an unplanned release

does occur, to ensure that the incident is reported in a timely fashion and that

contingency and mitigation measures are in place.

5.1 Unplanned Releases – PON 1

During 2015, there were a total of 12 releases from Premier offshore operations.

Seven of the releases resulted in the loss of a total of 0.76 tonnes of hydrocarbon to

the environment.

The remaining 5 releases resulted in the loss of 31,501 kg (31.5 t) of chemical to the

sea. The majority of this total release (31.42 t) resulted from three separate water

based subsea hydraulic leaks, the sources of which are often difficult to prevent.


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Figure 5.1 Unplanned releases from Premier Operations during 2015

Two releases from the Balmoral FPV involved the loss of 29.68 tonnes of Pelagic

100, a water based hydraulic fluid with an OCNS category of E (the lowest category

of chemical hazard). The potential environmental impact associated with this release

was identified and assessed, the conclusion being that the potential impact on local

sensitivities including areas of conservation, fish, shellfish, seabirds and mammals

was not expected to be significant.

A further 1.74 tonnes of water based hydraulic fluid was released from a diverter seal

failure during Catcher drilling operations. This failure of the seal was unforeseeable

but the fluid was unfortunately released via the rig drainage system. A full

investigation was undertaken in to the circumstance of the release which led to the

development of drilling company-wide procedure on how spills should be responded

to and lesson sharing across Premier Oil.

5.2 Permitted Discharge Notifications – PON 1

Two PDN’s were submitted in 2015, these notifications related to produced water

sheens resulting from operational upsets on the Balmoral FPV. The amount of oil

associated with these discharges equated to approximately 0.1 tonnes of

hydrocarbon.

5.3 Regulatory Non-Compliance (NC)

Premier submit notification to DECC in the event of any non-compliance against the

permits and consents in place that cover emissions and discharges. Notifications are

raised for any breaches of permit conditions associated with The Offshore Petroleum

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

Balmoral Solan Drilling Catcher Drilling Total

Ma

ss o

f H

yd

roca

rbo

n /

Ch

em

ica

l

Re

lea

sed

(T

on

ne

s)

Hydrocarbon Mass

Chemical Mass


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Production and Pipe-Lines (Assessment of Environmental Effects) Regulations 1999

(EIA), the Offshore Chemicals Regulations 2002 (OCR), the Offshore Petroleum

Activities (Oil Pollution Prevention and Control) Regulations 2005 (OPPC), and the

Offshore Combustion Installations (Pollution Prevention and Control) Regulations

2013 (PPC).

Table 5.1 Non-compliance notifications submitted during 2015

As shown in Table 5.1, five non-compliances were reported in relation to 2015

operations on Balmoral FPV. These notifications were primarily data administrative

errors, three being due to metering inaccuracies which have since been rectified, and

two relating to tracking and inaccurate reporting of chemical data which was

subsequently updated.

Installation EIA NC OCR NC OPPC NC PPC NC

Balmoral 0 2 3 0

Solan Drilling 0 0 0 0

Catcher Drilling 0 0 0 0


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6.0 ENVIRONMENTAL PERFORMANCE AGAINST TARGETS

Table 6.1 describes progress against UKBU objectives and targets set for 2015.

Objective/Target Progress

Compliance with new

standard / legislation

• UKBU Offshore Safety Directive (OSD) action plan/timeline

developed, implementation ongoing (e.g. Corporate Major

Accident Prevention Policy (CMAPP) Document and

Offshore Pollution Emergency Plans (OPEP) issued in line

with the OSD requirements.

• Energy Savings Opportunity Scheme requirements

completed by the UKBU on behalf of the Corporate

(Balmoral FPV identified as a major contributor)

requirements fulfilled.

• ISO 14001:2015 Transition work on-going.

Improved Environmental

Performance by increasing

environmental workforce

engagement

• Various environmental compliance awareness sessions,

during operations and prior to drilling and subsea

campaigns completed across the assets, involving internal

personnel and third parties.

• Tools to enable E-reps functioning provided to Balmoral

FPV.

Chemical Management • Chemical Management Standard and associated

procedures developed and rolled out across the assets to

ensure improved chemicals compliance process.

Management of Balmoral

Environmentally Critical

Elements (ECE)'s in

conformance with UKBU

Standard

• Balmoral FPV EUETS Performance Standard developed

and ECE’s integrated into the maintenance system.

Decommissioning Guidance

development

• Decommissioning Environmental Compliance Guideline

developed and issued.

Environmental Data

Improvement

• Software and procedural changes implemented to enable

more effective and user friendly tracking of the

environmental data to ensure compliance with the

legislative requirements.

Improve identification and

classification of

environmental incidents and

Balmoral aspects and

Impacts

• This action is deferred to next year to align the improved

identification of environmental aspects and impacts with the

on-going work-scope to fully comply with the OSD

requirements.

Waste Management

Improvement in the new

Aberdeen office

• Internal audit conducted to identify the onshore waste

management improvement opportunities.

Table 6.1 – Premier UKBU Environmental Performance against Targets

premier oil uk limited 2015 environmental statement · premier oil uk limited 2015 environmental...

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