The Norwegian Environment Agency reacts to an application for increased chemical use at Gullfaks without purification The Norwegian Environmental Protection Association

Equinor applied for changes in chemical use and discharge of chemicals in the red category at Gullfaks in connection with well stimulation where the company is applying for exemption from the requirement for collection and purification. The Norwegian Environmental Protection Association finds this completely unacceptable, which was also conveyed to the Green Warriors of Norway in our consultation statement of 24/04/2023;

Response to Hearing:
Equinor is applying for changes in chemical use and emissions at Gullfaks in connection with well stimulation at Gullfaks
satellites.

Hearing number: 2022/371
Changes are being requested in the chemical framework for substances in the red category in connection with well stimulation
on Gullfak's satellites.

Gullfaks is, after all, a well-known oil producer on the Norwegian shelf and has produced oil in
many decades already. This means that there is already a valid emission permit which
sought to be extended/dispensed. The Green Warriors of Norway (NMF) believes on the basis of the following points that
permission cannot be granted for the change requested as this will increase emissions from production by
The Gullfaks field.:

1: It is claimed from Equinors that collection of jet sand/proppant that returns over time does not
must be practically feasible for Gullfaks, which NMF finds very strange as we are aware that
this is done with existing technology in a number of places. Among other things at Gullfaks, and with good ones
results. We cannot therefore read anything else from the application other than that it is exclusively about
save expenses and that the only intention is to earn more faster. Should changes be made to
operations/routines at Gullfaks is the way we see it, it goes without saying that you follow BAT (best
available techniques) and that changes in operations, routines or methods exclusively lead to improvement
meeting emission targets. If a change leads to increased emissions of hazardous substances, the plans must be shelved.

Furthermore, we read that for well NO34/10-G1 application has been made for the use of 94 tonnes of resin-coated Proppants and
discharge of more than one tonne of substance in the red category. According to what NMF can find, most experiences indicate that
larger quantities always come back than first thought and that emissions are also often larger in practice.
Again, we will refer to already existing separation technology to collect the proppants and
avoid polluting discharges into the sea.

The proppants planned to be used said to be "Resin Coated Proppants", used for
well stimulation. According to the datasheet (attached) it is very clear that G2 Optiprop Coated Sinnerlite
is recommended to be captured, collected and stored in a safe manner. Furthermore, it is clearly stated that this should not
in the lake. A quick perusal of the data sheet also shows that the chemistry in the product contains a number of harmful substances such as Phenols and Formaldehyde. Substances you have very good knowledge of that are not
must be released and made available to the marine ecosystem.

The NMF cannot see that there is a basis to claim that emissions as a result of "Jetting" should be
necessary. There exist today (have existed for a long time) methods such as using separation technology
separates out sand, proppants and other fractions and thus separates these from the process and gives full
control and cleaning of the entire process on location. Separated masses are then sent ashore for
proper treatment. This is technology that is and has been in use at several of Equinor's facilities (also
Gullfaks) and should in no way be unknown to the applicant.

We will also refer to this statement, taken from the application:
“Collection of jet sand to capture the remaining small amounts of proppants that are produced
going back over time will not be practically feasible at Gullfaks".
We can hardly see this as anything other than deliberate cheating and trickery, as this has already been the case for a long time
done on the Gullfaks field, where separation solutions have been used to capture exactly proppants.
Such attempts to falsify reality should be severely cracked down on.

The NMF is afraid that this application may quickly turn out to be the first in a series where one wants to
drive the fields "harder" to extract more/the last remaining oil and that in order to achieve this they will try to circumvent
environmental considerations where this gets in the way of maximally efficient "final operation" of wells. This is in so
fall a development that cannot be tolerated, and the NMF recommends that no exemptions/extended ones are granted
emission permits of this type.

NMF hereby demands that the application be rejected and that this type of emission permits be consistently extended
emphasis is placed on whether they make the environmental impact greater or less and that it is laid down as one premise that all
new measures must have an environmental improvement effect.