DANISH ENERGY AGENCY S GUIDELINES ON SAFETY- AND HEALTH RELATED CONDITIONS ON OFFSHORE INSTALLATIIONS, ETC. HEALTH & SAFETY CASES

Transcription

1 DANISH ENERGY AGENCY S GUIDELINES ON SAFETY- AND HEALTH RELATED CONDITIONS ON OFFSHORE INSTALLATIIONS, ETC. HEALTH & SAFETY CASES REV. 0 December 2012

2 TABLE OF CONTENT TABLE OF CONTENT... 2 DOCUMENT CONTROL INTRODUCTION LEGISLATION DEFINITIONS Offshore installations Mobile offshore installations Fixed offshore installations Permanently manned offshore installations Non-permanently manned offshore installations FPSO (floating production, storage and offloading unit) FSO (floating storage and offloading unit) Pipelines Vessels and facilities being used for accommodation Special vessels Offshore vessels for other applications The ALARP-principle Safety critical elements Major accidents/injuries Health & Safety Case (HSC) FIELD OF APPLICATION General Particular conditions for non-permanently manned offshore installations TARGET GROUP HEALTH AND SAFETY CASES General Content of and structure of HSC Fixed offshore installations Mobile offshore installations Changes of fixed and mobile offshore installations Pipelines Vessels and facilities being used for accommodation Special vessels PAGE 2

3 7 LIST OF ABBREVIATIONS Summary Description of the installation Detailed description of the management system Assessment of risks for major accidents and demonstration of compliance of the ALARP principle Evacuation analysis and contingency plan Assessment of other risks and demonstration of compliance of the ALARP principle Assessment of other health related conditions and demonstration of problem solving Summary Description of the pipeline Description of the management system Risk assessment and demonstration of compliance of the ALARP principle Contingency plan PAGE 3

4 DOCUMENT CONTROL Revision Amendment Date 0 New guideline December 2012 PAGE 4

5 1 INTRODUCTION The guideline describes the provisions for Health & Safety Cases for offshore installations and on vessels and other facilities covered by law. The guideline is not binding on the companies or others, but is based on rules of the legislation, which is binding. Some places in the guideline the wording 'must' is used. This means requirements from rules and regulations, which the company must follow. The guideline is published only electronically and is available on the Danish Energy Agency s website. The guideline has been acceded by the two sides of industry in the offshore area. Further information can be obtained at Danish Energy Agency s Offshore safety unit on telephone or ens@ens.dk. This guideline is published only electronically and is available on the Danish Energy Agency s webpage at where the legislation, stated in section 2, can be found. 2 LEGISLATION The guideline includes the following legislation: 3, subsections 2, 3, 5 and 6 and 22-26a in the Danish Offshore Safety Act 1 Executive Order No. 509 of 11 May 2011 on extension of the field of application for the Danish Offshore Safety Act of Executive Order No. 729 dated 3 July 2009 on control of safety and health on offshore installations (referred to as Styringsbekendtgørelsen ) as amended 1 Act No dated 21 December 2005 on safety etc. for offshore installations for exploration, production and transport of hydrocarbons (The Danish Offshore Safety Act ) as amended PAGE 5

6 3 DEFINITIONS 3.1 Offshore installations Offshore installations are defined in 2, subsection 1 of the Danish Offshore Safety Act. Paraphrased the definition is: 1) Platform or another type of installation (in the law it is called facility), from which exploration or production of hydrocarbons from the subsoil below the seabed is carried out. 2) Platform or another type of installation being used for accommodation of persons. 3) Platform or another type of installation being used in connection with transport of hydrocarbons and other substances and materials between offshore installations or between offshore installations and installations onshore. An example of such platforms or constructions is plants for increasing the pressure in the pipeline (pumping stations). Pipelines, linking to and from the offshore installation, are not covered by the definition. 4) Platform or another type of installation being used for storing and loading of hydrocarbons produced from an offshore installation which is permanently connected to another offshore installation. Offshore installations can have more of the above functions at the same time. As an example, a drilling rig (see the definition of mobile offshore installations below) can be used for both drilling and for accommodation of persons who are not working on the rig, but on another offshore installation. Vessels are not covered by the definition. An exception from this is drilling vessels, floating production-, storage- and offloading units (FPSO units) and floating storage and offloading units (FSO units) considered offshore installations. Subsea wells are considered to be covered by the definition, as the term 'type of installation' does not take a position on its external appearance, including that it concerns an installation above sea level Mobile offshore installations PAGE 6

7 By a mobile offshore installation is meant an offshore installation, which can be moved from one position to another, either by its own power or by towage, and which is intended to be used in several different positions during its lifetime. The definition shall apply regardless of use. In Denmark, there are mobile offshore installations in the form of mobile offshore drilling units (MODUS) and accommodation units. MODUs are also named as drilling rigs or drilling platforms Fixed offshore installations By a mobile offshore installation is meant all other offshore installations than mobile offshore installations regardless of use. I.e. a floating installation, which is not intended to be moved from one position to another, is also considered a fixed offshore installation. It might be an FPSO. A subsea production well is also considered a fixed offshore installation. In Denmark there are fixed offshore installations in the form of installations for production of hydrocarbons, installations being used in connection with pipelines (pumping stations) and installations for storage and loading of oil produced from an associated offshore installation. Fixed offshore installations, which are interconnected by bridges and which are operated by the same operating company, are considered one installation. Examples hereof are the following, which are permanently manned installations operated by Maersk Oil and Gas AS on behalf of DUC (Danish Underground Consortium): Skjold Harald Tyra East Tyra West Dan B Dan F Halfdan B Halfdan A. Gorm, which is operated by Maersk Oil and Gas AS, is considered one offshore installation, even if Gorm A-D are operated on behalf of DUC, and Gorm E is operated on behalf of DONG Energy, who owns the platform. Gorm E is a pumping platform linked to the oil pipeline to shore. PAGE 7

8 3.1.3 Permanently manned offshore installations Offshore installations, being planned to be used for accommodation, are also named manned offshore installations. These include also offshore installations which are manned only for periods Non-permanently manned offshore installations Offshore installations, which are not permanently manned offshore installations. On such installations, accommodation can take place only in the shape of emergency overnight stay, e.g. due to weather conditions. These are also named unmanned offshore installations FPSO (floating production, storage and offloading unit) An FPSO is a floating unit, generally a vessel, from which hydrocarbons are produced, stored and shipped FSO (floating storage and offloading unit) An FSO is like an FPSO, although hydrocarbons are not produced and processed on this. Instead, oil typically comes from a neighbouring production platform. 3.2 Pipelines In the Danish Offshore Safety Act pipelines are not defined, therefore it does not appear, when pipelines are considered part of an offshore installation or part of the pipeline leading away from the installation. The operator and the owner of the pipeline define jointly in each case the delimitation between what is considered part of the offshore installation and what is considered part of the pipeline. 3.3 Vessels and facilities being used for accommodation Vessels and facilities, which are used for accommodation of persons, who work on an associated offshore installation and not covered by the definition of an offshore installation. Some of the rules in the Danish Offshore Safety Act and regulations according to the law shall, however, apply to the accommodation on these vessels and arrangements, cf. 3, subsection 3 and 4 of the Danish Offshore Safety Act. PAGE 8

9 3.4 Special vessels By special vessels are meant vessels and facilities, which are used directly or indirectly in connection with exploration and production of hydrocarbons and which are not covered by the definition of an offshore installation. Some of the rules in the Danish Offshore Safety Act and in Executive Orders according to law shall, however, apply for the activities with related workplaces, accommodation facilities and equipment in the special vessels, cf. 3, subsection 5 of the Danish Offshore Safety Act. Well stimulation vessels, well intervention vessels, crane vessels and pipe-laying vessels are examples of special vessels. The latter have not previously been covered by the Danish Offshore Safety Act, but this was changed at the latest amendment in Offshore vessels for other applications Offshore installations, where activities in addition to exploration or production of hydrocarbons are carried out, are covered by the Subsoil Act. Some of the rules in the Danish Offshore Safety Act and in Executive Orders according to law shall apply for such activities, cf. 3, subsection 6 of the Danish Offshore Safety Act. Storage of CO 2 from an existing offshore installation, from which hydrocarbons are also explored or produced, is an example of this. Installations, which are solely used for other activities than exploration or production of hydrocarbons, are thus not covered by the Danish Offshore Safety Act and related regulations. 3.6 The ALARP-principle ALARP stands for "As Low As Reasonably Practicable ', cf. 2, No. 8, in Styringsbekendtgørelsen. To follow the ALARP principle means that a) no measurable risk or risk determined by measurable indicators must exceed the highest acceptable risk level and that b) all risks according to item a), which exceed the generally acceptable risk level must be reduced as much as is reasonably possible, or c) where the risk cannot be measured, either directly or by indicators, which could be the case by physiological or psychological strain, the work must be planned in such a way that the harmful impacts are reduced as much as is reasonably practicable. In 2, nos 5 and 7, in Styringsbekendtgørelsen the following is defined: PAGE 9

10 The highest acceptable risk level: The highest risk level where the activities may be carried out. General acceptable risk level: The risk level, where further application of ALARP is unnecessary. 3.7 Safety critical elements Safety critical elements are defined in 2, subsection 12 of Styringsbekendtgørelsen as installation parts, equipment or components (including computer programs) a) which by failure may be the cause of or contribute significantly to major accidents or b) whose purpose is to prevent or limit the consequence of such accidents. Examples of safety critical elements are: Flame-, smoke-, gas- and H 2 S detectors. Alarms. Firefighting equipment. Emergency power supply ESD equipment (Emergency Shut Down) Rescue equipment Supporting structures Escape routes Muster area 3.8 Major accidents/injuries By major accidents/injuries is meant, cf. 2, No. 9 of Styringsbekendtgørelsen : a) fire, explosion or spill of a hazardous substance causing fatality or severe personal injury, b) an incident, causing serious damage to the offshore installation or parts hereof with immediate risk of fatality or severe personal injury, c) helicopter collision with the offshore installation or PAGE 10

11 d) any other incident which causes fatality or severe personal injury by five or more persons. 3.9 Health & Safety Case (HSC) Documentation, which explains the company's management of the health- and safety related risks on the offshore installation. The documentation corresponds to the health- and safety document in the European Directive 92/91/EEC. In English, the Danish Energy Agency has chosen to name the SSR Health & Safety Case (HSC), as the requirements on the documentation resemble the requirements on a British Safety Case. PAGE 11

12 4 FIELD OF APPLICATION 4.1 General The regulations on Health & Safety Cases include: Construction, arrangement, equipment, operation and changes of fixed and mobile offshore installations. Moreover, application of the installation for other activities, such as storage of CO 2 or natural gas, is not covered, cf. 3, subsection 6 of the Danish Offshore Safety Act. Construction, operation and equipment of pipelines. This applies to pipelines being used for transport of hydrocarbons or other substances and materials between offshore installations and installations onshore or between more offshore installations. Transit pipelines are thus not covered, cf. 3, subsection 2 of the Danish Offshore Safety Act. Accommodation facilities on vessels and other facilities, where persons work on an offshore installation, are accommodated. The use is limited to the health- and safety related conditions for the accommodated persons, cf. 3, subsection 3 of the Danish Offshore Safety Act. The activities carried out from special vessels and on the equipment used, cf. 3, subsection 5 of the Danish Offshore Safety Act. For fixed offshore installations and pipelines, the regulations cover the life cycle of the complete installation and pipelines: Overall design Detailed project engineering Construction, if this is taken place onshore Transport of installation or parts of installation to the installation site offshore Installation offshore Hook-up and commissioning, HUC Operation Change of the physical and operational conditions of the installations or pipelines Dismantling. PAGE 12

13 With regard to transport of installations of parts of installations to the installation site offshore, it covers only the part, which is of importance to the safety of future installations or future pipelines. Lift of the installation, the pipeline or parts thereof from the transport vessel on the installation site is considered part of the installation. The operator must ensure that the transport of the installation, the pipeline or parts thereof takes place safely and must keep appropriate check on this. Some sections of the regulations may have a scope, which does not include everything stated above. If so, this will appear clearly. It is of no importance whether a specific mobile offshore installation is registered in Denmark or in another country, or whether it is Danish operated or Danish-owned, as long as it operates in Danish territorial sea or continental shelf area. 4.2 Particular conditions for non-permanently manned offshore installations The regulations shall apply in full to non-permanently manned offshore installations. 5 TARGET GROUP Primarily, the guideline addresses to those whom according to the Danish Offshore Safety Act are obliged to draw up a Health & Safety Case (HCS) It is: Operators Operating companies. Moreover, the guideline is of interest to members of the safety organisation on offshore installations, who shall be involved in drawing up of an HCS and to consultancy companies and other who draw up HCS on behalf of the companies. 6 HEALTH AND SAFETY CASES 6.1 General The Danish Offshore Safety Act makes demands that a Health & Safety Case (HSC) is drawn up. PAGE 13

14 HSC accounts for management of the safety- and health related risks. Through the life cycle of a fixed offshore installation and a pipeline, i.e. from project engineering through operation to dismantling, including simultaneous use for other purposes, e.g. storage of CO 2, In connection with operation of mobile offshore installations and activities from special vessels, or On associated vessels being used for accommodation of persons who work on the offshore installation. HSC must be an auditable document, i.e. based on the HSC, an auditor shall be able to trace the documentation which forms the basis of the HSC. HSC must be updated if changes are made of the offshore installation, etc., its arrangement, equipment or operational conditions which have an impact on the risk of major accidents and risks of occupational injuries/accidents (LTI/LTAs) and occupational diseases, cf. 25, subsection 1 of the Danish Offshore Safety Act. The update should thus not only be made in connection with application for change permissions according to 29 of the Danish Offshore Safety Act. HSC or parts thereof may include more fixed offshore installations, which have the same operator. HSC can be common to conditions which are similar on the offshore installations, e.g. parts of the management system. Any subsequent updates of HSC during operation may also be common. This requires, however, that the installations have the same operating company. The latter does not specifically appear from the regulations, but the Danish Energy Agency interprets the provisions so that the operating company is responsible for the update during operation, cf. 25, subsection 1 of the Danish Offshore Safety Act. HCS must be available on the offshore installation, electronically or in hard copy, for the management and employees of the installation and for the supervising authority. PAGE 14

15 6.2 Content of and structure of HSC The legislation has not stipulated formal requirements for HSC. HSC can be structured as an independently collected controlled document or as a system of documents. An example of the latter is illustrated in Figure 1. The elements of the figure correspond to the items in Appendix 1 and 2, describing what an HSC for an offshore installation and a pipeline, respectively, must include. Not all elements are relevant to an HSC for a pipeline and do not appear from Appendix 2. Summary Description of the offshore installation Risk assessment Other risks + ALARP demonstration Evacuation analysis and parts of contingency plan Risk assessment Major accidents + ALARP demonstration Description of management system Assessment of other health conditions + problem solving, if any Fig.1. Example of structure of an HSC 6.2 Fixed offshore installations The operator is responsible for preparation of an HSC for a fixed offshore installation, cf. 23, subsection 1 of the Danish Offshore Safety Act. The operating company is, however, responsible for updating the HSC during operation of the installation, cf. 25, subsection 1 of the Danish Offshore Safety Act. The HSC must be drawn up already in relation to preparation PAGE 15

16 of the overall design of the installation. At the time, all the details in relation to the facilities and operation of the installation are not known; that is why only the overall risks can be dealt with at the time. The HSC must be updated concurrently with provision of health and safety related conditions by project engineering, construction and installation until the time of commissioning and dismantling of the installation, cf. 23, subsection 3 of the Danish Offshore Safety Act. According to 25, subsection 2 of the Danish Offshore Safety Act, it must be substantiated in the Health and Safety Case, if it is planned that operation of a fixed offshore installation shall be carried on after expiry of it design life, that safety related risks arising from the supporting structures of the installation during the planned period of operation are identified, assessed and reduced as much as reasonably practicable. The length of the planned period of operation must appear from the health and safety case. 6.4 Mobile offshore installations For mobile offshore installations, the operating company is responsible for the preparation of an HSC. HSC must be prepared before commissioning of the installation. Precautions to be taken in connection with the operation to reduce the health and safety related risks must be set and documented prior to commissioning of the installation. The operator is responsible for obtaining an operating permission for the mobile installation from the Danish Energy Agency. Consequently, the operator should ensure that an updated HSC is available before a contract is signed with the operating company for a mobile installation. The updated HSC must be attached to the application for an operating permission. 6.5 Changes of fixed and mobile offshore installations HSC must be true in relation to the health and safety conditions on the installation, including the risks arising from changes of the physical or operational conditions. Therefore, the operating company must update the HSC in case of changes of the health and safety related conditions, cf. section 6.1. Particularly, it shall be stated that even if changes are not made to the health and safety related conditions that justify a change of the HSC per se, it must be demonstrated in the HSC that a renewed risk assessment has been carried out on the supporting structures of a fixed PAGE 16

17 installation, if continued operation of the installation is expected beyond the design life, which was originally set. In practice, this will not require extraordinary precautions if the operating company, through the regular maintenance, has ensured that the strength of the supporting structures remain in compliance with the requirements made. This must appear from the HSC. At the same time, duration of the expected operating period must appear from the HSC. By combined operations, the HSC of the individual installations shall be updated and as a minimum a description shall be available of how the involved installations management of the health and safety related risks are coordinated in the form of a bridging document or interface document which describes the responsibilities of each of the operating companies and the responsibilities which are common for the companies with the combining operation. 6.6 Pipelines The operator must ensure that a Health and Safety Case with the content described in Appendix 2 is drawn up. 6.7 Vessels and facilities being used for accommodation The safety- and health related conditions for the persons, who are accommodated on a vessel or facility associated to an offshore installation, shall be part of the HSC for the offshore installation on which the persons in question work. 6.8 Special vessels The operating company of the special vessel must draw up an HSC including the elements stated for an offshore installation, cf. Appendix 1, but only comprising the activities attached directly or indirectly to exploration or production of hydrocarbons. If the special vessel is attached to an offshore installation, the HSC for the attached offshore installation shall be updated so that it includes the risks which the activities from the special vessel involve. PAGE 17

18 7 LIST OF ABBREVIATIONS ALARP As Low As Reasonable Practicable EF (EC) European Community EU European Union EØF (EEC) European Economic Community FPSO Floating Production, Storage and Offloading. Floating unit for production-, storage and/or offloading of hydrocarbons. HSE Health, Safety and Environment or Health & Safety Executive HS&E Health, Safety and Environment HSC Health & Safety Case. English designation of SSR. HUC Hook-up and Commissioning. Connection of parts of an offshore installation and commissioning. IADC International Association of Drilling Contractors MODU Mobile Offshore Drilling Unit. SSR (/HSC) Health & Safety Case (Safety- and Health Report). PAGE 18

19 APPENDIX 1 CONTENT OF A HEALTH- AND SAFETY CASE FOR OFFSHORE INSTALLATIONS In the following is described which elements an HSC for an offshore installation shall include under the law. More detailed guidelines on each item are available in IADC s guidelines for health- and safety cases for drilling rigs (HSE Case Guidelines for MODUs) 2. The HSC and thus each of the following elements must reflect the specific safety- and health related conditions in the various stages of a fixed offshore installation. 1. Summary The summary should include an overview of the company, installation and the assessments made and a brief description of the below mentioned elements in HSC. 2. Description of the installation Detailed description of the installation s construction, arrangement and equipment and operational conditions, including maximum and minimum staffing and transportation to and from the installation. The following must specifically be included in the description: 1) In which areas surveillance equipment is installed, which automatically and continuously measure gas concentrations at particular locations, automatic alarms and devices that automatically switch off electrical installations and devices which automatically stop combustion engines. 2) Which necessary measures have been taken to prevent occurrence and formation of a potentially explosive atmosphere, and where danger of explosion exists which necessary measures to be taken to prevent ignition of the potentially explosive atmosphere. 2 HS&E Case Guidelines for Mobile Offshore Drilling Units. Version 3.3. International Association for Drilling Contractors, December 2010, and Appendix 1-4 i HS&E Case Guidelines for Offshore Drilling Contractors Issue International Association for Drilling Contractors, February PAGE 19

20 3) Which measures have been taken to prevent, detect and combat the outbreak and spread of fire. 4) How a system for remote control in emergency systems for ventilation has been made for emergency stop of equipment which may cause ignition to prevent spill of flammable liquids and gases, for fire protection, for control of drillings, etc. 5) To which extent permanently manned offshore installations are equipped with: a) an acoustic and optical system, which - if necessary - can transmit alarm signals to all manned sections of the offshore installation, b) an acoustic system which can be heard clearly everywhere on the sections of the offshore installation where persons are frequently present and c) a communication system which enables constant connection to the coast and to the emergency services. The above information will be based on the results of the risk assessment and the subsequent demonstration that the safety and health related risks are reduced according to the ALARP principle. 3. Detailed description of the management system It must appear whether the management system is structured according to a recognised standard (indicating which), whether it is certified according to the standard or whether it is structured according to another similar arrangement. The description must include an overview of the document system in the management system and the organisation chart of the part of the company being responsible for health and safety on the offshore installation at all levels including brief description of responsibilities. From the description it must appear how the management system works (policy and objective, setting of requirements for health and safety, implementation, control, audit, review) and how continuous improvement of the safety and health related conditions is ensured. It shall furthermore appear from the description to which extent the installation and its equipment/systems is/are subject to investigations and verification of a recognised third party, proved by certificates. PAGE 20

21 It should also appear how it is ensured and documented that the legislation is complied with both in normal and critical situations. Specifically, reference shall be made to the individual parts or to the individual items of another similar arrangement of the standard used (the latter by the management system s use during the operational phase). 4. Assessment of risks for major accidents and demonstration of compliance of the ALARP principle Here, the documentation for the assessment of risks of major accidents and the demonstration that the risks have been reduced according to the ALARP principle, shall appear, cf. 7 of Styringsbekendtgørelsen. 5. Evacuation analysis and contingency plan Here, the documentation for the evacuation analysis shall appear, cf. 21, subsection 3 of Styringsbekendtgørelsen Moreover, the main content of the contingency plan shall be described. 6. Assessment of other risks and demonstration of compliance of the ALARP principle Here, the documentation for the assessment of the other risks and the demonstration that the risks have been reduced according to the ALARP principle, shall appear, cf. 7 of Styringsbekendtgørelsen. By other risks are meant health and safety related risks, which are not risks of major accidents. Typically, these risks will be work-related risks such as the risk of occupational injuries/accidents LTI/LTAs and occupational diseases. The assessment of these is also called workplace assessment by some operating companies. 7. Assessment of other health related conditions and demonstration of problem solving Here, the documentation for the assessment of the other health related conditions and demonstration that any problems are solved satisfactorily, shall appear, cf. 19, subsection 4 of Styringsbekendtgørelsen. PAGE 21

22 By other health related conditions are health related conditions which are not related to work. These may, e.g. be hygienic conditions, quality of drinking water and utility water, indoor environment in the accommodation and impact from tobacco smoke, but also the conditions in the accommodation in general, including conditions for overnight stays. PAGE 22

23 APPENDIX 2 CONTENT OF A HEALTH- AND SAFETY CASE FOR OFFSHORE PIPELINES In the following the content of an HSC for pipelines is stated. HSC and thus each of the below mentioned elements shall reflect the specific stage of installation and operation of pipelines. 1. Summary The summary should include an overview of the company, the pipeline and the assessments made and a brief description of the below mentioned elements in HSC. 2. Description of the pipeline Detailed description of the pipeline informing about design basis, connecting points, medium to be transported and a schedule for establishment and operational conditions, including inspection and maintenance. 3. Description of the management system It must appear whether the management system is structured according to a recognised standard (indicating which), whether it is certified according to the standard or whether it is structured according to another similar arrangement. The description must include an overview of the document system in the management system and the organisation chart of the part of the company being responsible for safety of the pipeline at all levels including brief description of responsibilities. From the description it must appear how the management system works (policy and objective, setting of requirements for health and safety, implementation, control, audit, review) and how continuous improvement of the safety and health related conditions is ensured. It shall furthermore appear from the description to which extent the pipeline and its equipment/systems is/are subject to investigations and verification of a recognised third party, proved by certificates. PAGE 23

24 It shall also appear how it is ensured and documented that the legislation is complied with both in normal and critical situations. Specifically, reference shall be made to the individual parts or to the individual items of another similar arrangement of the standard used (the latter by the management system s use during the operational phase). Please see guidelines on the management system if further information is needed. 4. Risk assessment and demonstration of compliance of the ALARP principle Here, the documentation for assessment of risks of loss of the pipeline integrity and demonstration that the risks have been reduced according to the ALARP principle, shall appear, cf. 7 of Styringsbekendtgørelsen. 5. Contingency plan Here, the main content of the contingency plan shall be described to meet the consequences of loss of the pipeline integrity. Contingency plan for meeting oil spill from a pipeline is not included. Requirements on this appear from the Marine Environment Law and are managed by the Danish Environmental Protection Agency in cooperation with the Ministry of Defence. PAGE 24

25 ENERGISTYRELSEN (THE DANISH ENERGY AGENCY) AMALIEGADE 44 DK-1256 KØBENHAVN K TELEPHONE TELEFAX WEBSITE ISSUED: DECEMBER 2012 LAYOUT: ENERGISTYRELSEN IS PUBLISHED ONLY AT ENERGISTYRELSEN S WEBSITE PAGE 25