PON15E
THE OFFSHORE CHEMICALS REGULATIONS 2002 (THE CHEMICAL REGULATIONS)
PETROLEUM OPERATIONS NOTICE 15E
SEEKING A TERM PERMIT FOR THE USE AND
DISCHARGE OF CHEMICALS DURING
DECOMMISSIONING OPERATIONS
DATA ON THIS FORM MAY BE RELEASED TO THE PUBLIC
The PON15E is an electronic form that permits the applicant to apply for a permit for the use and
discharge of chemicals during decommissioning operations under the Chemical Regulations.
Submission of an application for a chemical permit replaces the requirement to apply for a licence to
discharge chemicals during decommissioning operations under the Food and Environment Protection
Act (FEPA) 1985, Part II Deposits in the Sea.
The regulator and consultees will be automatically notified that the undertaker has submitted a
completed PON15E form. At this point assessment of the application can begin. It is the responsibility
of the undertaker to ensure that applications for other approvals or permits directly relating to the
application e.g. discharge permits under the Offshore Petroleum Activities (Oil Pollution Prevention
and Control) Regulations 2005, are submitted at the same time as the PON15E application, as
appropriate.
Up-dates and variations to the PON15E can be made by revising the appropriate sections of the current
PON15E. All the changes must be listed in the text box provided (submissions will be automatically
compared with the original forms, to confirm that the list is complete). The regulator and consultees
will be automatically notified that an up-date or variation has been submitted. Application up-dates
will retain the same reference number, and will replace the previous submission. Requests for permit
variations will be automatically assigned an amended reference number, by adding a suffix, e.g. /1, /2,
/3 etc, to the original reference number.
The PON15E can be used to apply for a number of chemical permits relating to the decommissioning
of the named facility or facilities, and details of further operations involving chemical use and/or
discharge can be added to the form as the need arises. The procedure will be similar to that used to
request a permit variation, but it will be necessary to revise relevant entries in Sections A – D inclusive,
and to complete a new Section E.
Any queries relating to the PON15E form, or a specific application, should be addressed to:
Department of Energy and Climate Change
Offshore Environment and Decommissioning
Atholl House, 86-88 Guild Street
Aberdeen AB11 6AR
Tel: 01224 254045 or 254050
Fax: 01224 254019
e-mail: emt@decc.gsi.gov.uk
PON15E
Section A: GENERAL INFORMATION
Reference No:
Is this an application to up-date or vary an existing PON15E
(a variation will relate to an already determined application,
e.g. where a Chemical Permit has already been issued)?
Yes / No
Is this an application for a further Chemical Permit for a
decommissioning operation that has already been the
subject of a Chemical Permit?
Yes / No
(New applications, including requests for further chemical permits, will be automatically assigned a
unique reference number when the form is submitted to DECC. If the application relates to the
variation of an existing permit, a suffix will be added to the original reference number when the
amended form is submitted to DECC).
Name of undertaker
Contact name
Address
Tel:
Fax:
E-mail:
Operator
Quadrant
Block No.
Block awarded in Round (No. of Round)
(If the subject of more than one award, enter the number of the latest round)
Is the proposed activity included in the Decommissioning Plan?
Yes / No
If “Yes”, what was the DECC Project Number?
Has the proposed activity, or similar activities been the subject
of a previous PON15E?
Yes / No
If “Yes”, what was the DECC Project Number?
Project name
Project location
Latitude
(Please include N and W / E designations)
Longitude
Distance to nearest UK coastline
km
Which coast?
England / Wales / Scotland / NI
Distance to nearest transboundary line
km
Which line?
UK/
Have consultations been carried out with:
Marine Scotland / SEERAD
CEFAS / DEFRA
JNCC
NE (English waters)
CCW (Welsh waters)
SNH (Scottish waters)
EHS (Northern Irish waters)
Yes / No / Not Applicable
Yes / No / Not Applicable
Yes / No / Not Applicable
Yes / No / Not Applicable
Yes / No / Not Applicable
Yes / No / Not Applicable
Yes / No / Not Applicable
Details of the outcome of the consultation should be included in Section B.
PON15E
Section B: JUSTIFICATION
A summary of the proposed chemical use and/or discharge during the decommissioning operation, and
a justification for the request for chemical permit, must be submitted in the following text box.
Reference should be made to the information included in other sections of the form, particularly
Section E, Chemical Usage. Where the proposal has been the subject of an Environmental Statement
or a Decommissioning Plan, it will only be necessary to include information that is relevant to the
chemical risk assessment.
The information provided should include a brief description of the proposed chemical use and
discharge during the decommissioning operation; the significance of any effects (including
transboundary effects, if any) of the proposed chemical use and discharge on the environment (taking
account of the requirements of the Offshore Petroleum Activities (Conservation of Habitats)
Regulations 2001); and any measures to mitigate or avoid such effects. Applications should
additionally include a chemical risk assessment and, if appropriate, the rationale for chemical selection.
For example, if a chemical’s Hazard Quotient ranking or revised OCNS group indicates a significant
toxic potential, or the chemical is a potential candidate for substitution, additional information must be
provided to justify use of the product. This additional information could include modelling of any
proposed discharge(s); a description of the factors that would reduce the toxicity or the exposure
concentration; a justification based on unique formulation characteristics; and/or a comparative
assessment of alternative products.
Further information on chemical risk assessment, including a question and answer section, can be
found on the DECC website at
http://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/ocr/ocr.aspx .
Insert text here:
PON15E
Section C: FACILITY INFORMATION
Chemical permits can be issued to cover chemical use at more than one facility, providing all the
chemical discharges will be made within 500 metres radius of an individual facility (the main facility).
Section C1 should therefore be completed for the main facility. If the chemical permit will cover more
than one facility, separate copies of Section C1 should then be completed for each additional facility.
Section C1: Facility Details
Name or Identifier of Facility:
Type of Facility:
Platform / FPSO / FPU / FSU / Other (specify)
Primary Licence Holder Details:
Primary Licence Holder
Application
contact
Company
position
Telephone
number
E-mail address
Telephone
number
E-mail address
Telephone
number
E-mail address
Operator Details (if different from Primary Licence Holder):
Operator
Application
contact
Company
position
Decommissioning Contractor Details (if different from Operator):
Contractor
Application
contact
Company
position
Section C2: Tied-back Facilities
Please provide details of any facilities that are tied-back to the facilities identified in Section C1, but
will not be covered by the chemical permit. (It should be noted that chemical permits are required to
cover all chemical use or discharge during decommissioning operations. It will therefore be necessary
to obtain additional permits to cover chemical use and discharge during decommissioning operations at
tied-back facilities that have not been included in Section C1. Responsibility for obtaining those
permits will rest with the operator of the tied-back facilities.)
Name or identifier of
tied-back facility
Type of facility e.g. platform,
subsea satellite etc
Will there be separate chemical
use and/or discharge at the
tied-back facility
Yes / No / Not Applicable*
Yes / No / Not Applicable*
Yes / No / Not Applicable*
Yes / No / Not Applicable*
Yes / No / Not Applicable*
Yes / No / Not Applicable*
* Not applicable because there will be no chemical use or discharge, or because the facility is not
being decommissioned.
PON15E
Section D: ENVIRONMENTAL INFORMATION
If there are any protected sites (e.g. SPA / SAC / RAMSAR / SSSI), or candidate protected sites, within
40 km of the facility, please list them below
Site
Designating feature(s)
Distance to project
Is the facility in a fish or shellfish spawning area
Yes / No
If yes, what species and at what time of year?
Species
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
S = Spawning, N = Nursery, J = Juveniles, NS = No documented sensitivity, Blank = No data
(more than one code can be entered)
Are there times of the year when seabirds in the vicinity of facility
are more vulnerable that at other times of the year?
Yes / No
Please detail seabird vulnerability at the facility location, and in adjacent blocks.
Quad / Block
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Nov
Dec
1 = Very High, 2 = High, 3 = Moderate, 4 = Low, Blank = No data
Are there times of the year when sea mammals (e.g. seals, porpoises,
dolphins, whales etc) in the vicinity of the facility are more abundant
than at other times of the year?
Yes / No
If yes, what species and at what time of the year?
Species
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
1 = High Density, 2 = Moderate Density, 3 = Low Density, Blank = No data (if data source is not UK
D-Map, supporting information should be provided in Section B)
Sources of information
Fish/Shellfish
Seabirds
Mammals
Please give details of any other outstanding or unusual environmental features in the vicinity of the
facility (e.g. seasonal algal blooms, sessile benthic species and geological or archaeological features) in
the following text box.
Insert text or file attachment here.
PON15E
Section E: CHEMICAL USAGE
All chemicals (with the exception of machinery chemicals such as fuels and engine lubricants,
domestic and accommodation chemicals, and laboratory reagents) being used and/or discharged during
the course of the decommissioning operations to be covered by the chemical permit should be listed in
the following tables (excluding any chemical use and/or discharge already covered by a term or
production permit). If in doubt as to whether to include a particular chemical, please check the relevant
section in the Guidance Notes or contact the Department for clarification.
Chemical permits may be required to cover decommissioning operations involving the discharge of
residual chemicals that cannot be off-loaded for onshore disposal, the discharge of the contents of
formerly-sealed vessels or equipment that cannot be off-loaded for onshore disposal, the use and
discharge of tank and pipe-work cleaning and flushing chemicals and the discharge of aqueous ballasts
containing treatment chemicals. Where necessary, a series of applications can be submitted to cover a
series of activities, or events, at the same facility, or facilities, using the same application form
(revising relevant entries in Sections A – D inclusive, and creating new tables in Section E). For
example, it may be necessary to submit an application to cover tank and pipe-work cleaning operations,
followed by a subsequent application at a later date to cover de-ballasting discharges during facility
removal. In other cases, it may be possible to submit a single application to cover the series of events.
If in doubt as to whether it is necessary to apply for a chemical permit for a particular event, please
check the relevant section in the Guidance Notes or contact the Department for clarification.
Chemical use and discharge during the course of pipeline decommissioning operations must be the
subject of a PON15C application, and should not be included on this form.
Unforeseen chemical use that is not included in an application must be the subject of an application
up-date or a request for a chemical permit variation.
Applications for chemical permits and permit variations must be supported by a chemical risk
assessment (see Section B). At the present time, it is unlikely that you will be able to use CHARM to
calculate Risk Quotients for decommissioning discharges, although some of the CHARM algorithms
may be useful. The risk assessment should therefore be based on the physical, chemical and
toxicological properties of the chemicals, and the proposed method of use and/or discharge. If risk
assessment software is used to model the discharges, any parameters that are required to run the
software and are not included in the tables, e.g. product density, discharge stream density, product
concentration in discharge, discharge rate etc, must be detailed in Section B, together with supporting
information to justify use of the selected software. The name of the software (including version
number) must also be specified in the following text box.
Insert text here:
Separate copies of Sections E1and E2 should normally be completed for each event involving the use
and/or discharge of chemicals during the decommissioning operations. There will, however, be
situations when use and/or discharge information will be relevant to more than one event. For
example, the data may cover a series of contemporary discharges. Under such circumstances, Sections
E1 and E2 can be completed to cover more than event, providing all the entries in the tables are
relevant to every event. One copy of Section E3 should be completed for all the chemicals to be used
and/or discharged during the course of the events to be covered by the chemical permit.
Further copies of Sections E1, E2 and E3 can be completed at a later date, to cover chemical use and/or
discharge during subsequent events. For example, it may be necessary to seek chemical permits to
undertake cleaning operations, followed by a separate request to undertake de-ballasting operations.
Guidance in relation to the completion of Sections E1, E2 and E3 is detailed below.
Event(s): The following event codes should be used to confirm the nature of the activity (more than
one code may be necessary):
USE
DBO
Chemical use only, e.g. if systems are “mothballed” prior to decommissioning
De-ballasting operations
PON15E
GWO
PCO
PFO
RCD
SSD
TCO
TFO
OTH
General washing operations
Pipe-work cleaning operations
Pipe-work flushing operations
Residual chemical discharge
Sealed system discharge
Tank cleaning operations
Tank flushing operations
Other (if this code is used, an explanation must be provided in Section B)
If necessary, additional information can be provided to supplement the codes, to more clearly indicate
the nature of the activity, e.g. SSD (firewater system), SSD (heating system) etc. Where the use and/or
discharge information relates to more than one activity, you should enter all the appropriate event
codes, e.g. PCO / TCO (oil / water separators). The event codes, and any additional information
provided to supplement the codes, should clearly relate to the entries in Section E1, Section E2 and
Section E3.
Proposed dates of chemical use and discharge: The proposed date of chemical use (e.g. date of
“mothballing” or commencement date of cleaning operations), and the proposed date of chemical
discharge, should be confirmed. The period of validity of the chemical permit will normally
commence immediately prior to the proposed date of chemical use, and terminate one month after the
proposed date of chemical discharge. If a permit is required for a longer period, this should be
explained in Section B. It should be noted that applications for chemical permits must be approved
prior to chemical use.
Sites of chemical use and discharge: The site of chemical use (e.g. Platform XXX), and the site of
chemical discharge (e.g. Platform XXX), should be confirmed.
Locations of use and discharge: The geographical location (latitude and longitude coordinates) of the
site of chemical use, and the geographical location of the site of chemical discharge, should be
confirmed.
Distance from discharge site to nearest UK coastline: The location of the site of chemical discharge
in relation to the nearest UK coastline should be confirmed (e.g. 120 km, Shetland Isles).
Distance from discharge site to nearest transboundary line: The location of the site of chemical
discharge in relation to the nearest transboundary line should be confirmed (e.g. 50 km, Norway).
Distance from discharge site to any protected, or candidate protected, areas: The location of the
site of chemical discharge in relation to any protected, or candidate protected, areas should be
confirmed (e.g. 120 km, East Coast SSSI).
Water depth at discharge site: The water depth at the discharge site should be confirmed. This can
be obtained from surveys, or from Admiralty Charts
Mean residual current at discharge site: The mean residual current at the discharge site should be
confirmed. Residual current data can be obtained from surveys. It may also be possible to obtain data
from the British Oceanographic Data Centre, at www.bodc.ac.uk; or, in some cases, to derive the data
from Admiralty Charts. Where data are available for the entire water column, the mean of the sea
surface and seabed values should be entered in the table. Where data are only available for the sea
surface or sea bed, that value should be entered. (Where data are available for any of the proposed
discharge depths, this information should be entered in Section B, and only the mean, surface or seabed
value should be entered in Section E2).
Chemical name: Chemical names are detailed in the ranked lists of approved chemicals on the
CEFAS website at www.cefas.co.uk. All chemicals that are scheduled for use during the course of the
decommissioning operations must be on the approved lists. However, there may be chemicals that
have already been used on the facility that will have to be discharged during the course of the
decommissioning operations, and some of those chemicals may no longer be on the approved lists. If a
chemical is no longer on the approved lists, you should enter the chemical name and complete as many
of the column entries as possible. You should also provide any additional data that you hold in relation
to the chemical in Section B. If the information provided is considered to be insufficient to permit an
assessment of the proposals, the department may insist upon appropriate environmental testing prior to
determination of the chemical permit application.
PON15E
Chemical function group: The chemical function groups are detailed in the ranked lists of approved
chemicals on the CEFAS website at www.cefas.co.uk. You must enter the group name detailed in the
lists, and should not enter a numeric function code. If you are uncertain about the correct function
group, please contact CEFAS for clarification.
Chemical label codes: The chemical label codes include whether a substance is on the OSPAR
PLONOR list; whether it is a candidate for substitution; and detail any relevant product warnings The
following chemical label codes should be used to summarise relevant properties (more than one code
may be necessary).
PLO
SUB
As
Cd
Cr
Cu
Pb
Hg
Ni
O-VII
O-P
O-Sn
P
Zn
ED
Taint
PLONOR (Automatic OCNS Group E)
Candidate for substitution
Arsenic warning
Cadmium warning
Chromium warning
Copper warning
Lead warning
Mercury warning
Nickel warning
Organo-halogen warning
Organo-phosphorous warning
Organo-tin warning
Phosphorus warning
Zinc warning
Endocrine disrupter warning
Taint warning
If you are uncertain about the correct label codes, please contact CEFAS for clarification.
Estimated use and discharge: Estimated total use and discharge should be confirmed.
Dosage: The dosage should be stated as mg/l dosage stream. Where chemicals will be diluted prior to
discharge, the dosage should indicate the concentration at the point of discharge.
Dosage stream: The nature of the treated medium should be confirmed, e.g. freshwater, seawater,
crude etc. Where undiluted chemicals will be used to fill the pipe-work, vessel etc., please enter
“Undiluted chemical”.
HQ value: Hazard Quotient (HQ) values are generated using the latest version of CHARM, and can be
obtained from the chemical supplier. Although the HQ values are not required to complete the
application forms, they provide a useful indication of the potential hazard. Chemicals will usually be
ascribed a single HQ value (apart from drilling chemicals, which will be ascribed three HQ values, for
different sections of the well), although they may appear in the ranked lists of approved chemicals
more than once to reflect different chemical functions, and the HQ value may differ for each function.
Chemicals are ranked according to their worst-case HQ, and the ranking group (as below) should be
entered in the tables. CHARM algorithms cannot be used for all chemicals. Where HQ values cannot
be generated using CHARM, chemicals continue to be ranked according to their revised OCNS group,
and this ranking group (as below which also includes temporary and provisional categories, etc) should
be entered in the tables.
HQ Colour Band
Gold
Silver
White
Blue
Orange
Purple
OCNS Category
A
B
C
D
E
Provisional A-E
Temporary A-E
If you are uncertain about the HQ or OCNS ranking group, please contact CEFAS for clarification.
PON15E
Discharge code: The following codes should be used to confirm the method of disposal:
DCW
DOF
ZEX
ZSS
ZWR
OTH
Discharge to controlled waters (i.e. waters within the territorial waters baseline and
waters within the three mile limit measured from the territorial waters baseline).
Discharge to offshore waters (i.e. outwith controlled waters)
Zero discharge, exported to onshore facility
Zero discharge, transferred to installation / rig / vessel for shipping ashore
Zero discharge, waste (re-)injection
Other discharge method (details must be provided in Section B)
Discharge volume: The total volume of the discharge should be confirmed (including the dosage
stream).
Discharge depth: The discharge depth should be confirmed in relation to the level of the sea surface,
e.g. a discharge made from caisson terminating 30 metres above the sea surface should be entered as
+30 m; a discharge made at the sea surface should be entered as 0 m; a discharge made 15 metres
below the sea surface should be entered as -15 m; and a discharge made at the sea bed should be
entered as -XXX m (sea bed).
Discharge rate: The discharge rate should be confirmed.
Further guidance can be found on the DECC website at
http://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/ocr/ocr.aspx.
Section E1: Use information
This section must be completed. It will normally be necessary to complete separate copies of
Section E1 for each activity, or event, involving the use of chemicals. Where the use information
relates to more than one event, this must be clearly indicated.
Event(s)
Proposed date of chemical use (e.g. date of mothballing)
Site of chemical use (e.g. facility name)
Location of use (latitude and longitude coordinates)
Full details of the proposed events, including the background to the requirements for chemical use,
should be included in the chemical risk assessment in Section B.
Section E2: Discharge information
It will normally be necessary to complete separate copies of Section E2 for each activity, or event,
involving the discharge of chemicals. Where the discharge information relates to more than one event,
this must be clearly indicated. If the chemical use summarised in Section E1 will not involve any
discharge to the marine environment, it will be unnecessary to complete Section E2.
Event(s)
Proposed date of chemical discharge
Site of chemical discharge (e.g. facility name)
Location of discharge (latitude and longitude coordinates)
Distance from discharge site to nearest UK coastline (km)
Distance from discharge site to nearest transboundary line (km)
Distance from discharge site to any protected, or candidate
protected, areas (km)
Water depth at discharge site (metres / m)
Mean residual current at discharge site (metres per second / ms-1)
Full details of the proposed events, including the background to the requirements for chemical
discharge, should be included in the chemical risk assessment in Section B.
PON15E
Section E3: Chemical information
This section must be completed. One copy of Section E3 should be completed for all the activities, or events, to be covered by the chemical permit. Separate entries are
required for each chemical and for each event. Thus, the same chemical may require more than one entry, if it will be used and/or discharged during more than one event.
Where the same chemical requires more than one entry, the event codes (and any additional information provided to supplement the codes) should clearly relate the entries to
the events listed in Sections E1 and E2.
Event
Chemical name
Chemical
function
group
Chemical
label code
Estimated
use (kgs)
Estimated
discharge
(kgs)
Dosage
(mg/l)
* Enter the HQ ranking (gold, silver, white etc) or, if not appropriate, the revised OCNS group.
Dosage
stream
HQ*
Discharge
code
Discharge
volume (m3)
Discharge
depth (m)
Discharge
rate (m3hr-1)
PON15E
Section F: UP-DATES AND VARIATIONS
Please record PON15E changes in the following text box. Applications for further Chemical Permits
will involve the completion of a separate (new) Section E, and it is unnecessary to record the details in
the text box.
Insert text here.
Example:
Date: 2nd May 2009
Section: E1, Event: Tank cleaning, (oil / water separators), Tank wash 141 (200 mg/l): Total usage
and discharge increased from 20 to 30 kg, Discharge volume: Increased from 100 to 150 m3.
Section G: SUMMARY REVIEW
For DECC use only
Application for Chemical Permit under the Chemical Regulations:
Section H: APPROVAL PROCESS
Following the review of the applications, you will be advised of the outcome by email, fax or surface
mail.