MOF, Alm.del - 2022-23 (2. samling) - Endeligt svar på spørgsmål 20: Spm. om redegørelse for sagen om udledning af miljøfarlige stoffer fra RGS Nordics renseanlæg i Stignæs

Miljø- og Fødevareudvalget 2022-23 (2. samling)
MOF Alm.del
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09-04-2021

Anne Kolstad Morken ([email protected])

Import/Eksport (postkasse) ([email protected])

NO 500083 Supplerende partshøring /Svar

2893517

Tor Søltoft

SV NO 500083 Supplerende partshøring (MST Id nr. 2620920)

15. jun 2021

MOF, Alm.del - 2022-23 (2. samling) - Endeligt svar på spørgsmål 20: Spm. om redegørelse for sagen om udledning af miljøfarlige stoffer fra RGS Nordics renseanlæg i Stignæs

-- AKT 2893517 -- BILAG 1 -- [ SV NO 500083 Supplerende partshøring (MST Id nr. 2620920) ] --

Til:

Cc:

Fra:

Titel:

E-mailtitel:

Sendt:

Import/Eksport (postkasse) ([email protected])

[email protected] ([email protected])

Anne Kolstad Morken ([email protected])

SV: NO 500083 Supplerende partshøring

SV: NO 500083 Supplerende partshøring (MST Id nr.: 2620920)

09-04-2021 15:55

Due to an ongoing enquiry and prequalification of Norwegian bidders for third party waste water treatment, we have

received information from SAR (prequalification only).

SAR, together with other bidders, has received information about the content of the waste water. I can confirm that

we have received prequalification answer from SAR. The process is still confidential, and I will come back with further

information as soon as this is available.

Best regards,

Anne Kolstad Morken

Fra:

Import/Eksport (postkasse) <[email protected]>

Sendt:

mandag 22. mars 2021 10:14

Til:

Hanne Seljelid <[email protected]>; Anne Kolstad Morken <[email protected]>

Kopi:

[email protected]; Pernille Lyngsie Pedersen <[email protected]>; [email protected]

Emne:

NO 500083 Supplerende partshøring (MST Id nr.: 2620920)

Notifikation NO 500083

Til Equinor Asa Avd Raffineri Mongstad

Att. Hanne Seljelid og Anne Kolstad Morken

E-mail:

[email protected], [email protected]

Kopi til:

Miljødirektoratet

Att. Vanja Sverdlilje

E-mail:

[email protected]

RGS Nordic A/S

Att. Pernille Lyngsie Pedersen, Ebbe Tubæk Naamansen

E-mail:

[email protected], [email protected]

At the 23rd of november 2020, we informed you of an issue with this notification, and of it being cause

for objection. The opinion was preliminary.

In your letter of 11th of january this year, you presented your documentation of the capacities of different

treatment facilities in Norway. We have assessed this information, and we have subsequently received

additional information regarding the capacity for waste water treatment in Norway, specifically at SAR

Mongstad. Please see description further below.

Based on our assessment of the new information we now object to the shipment. Notification validity

ceases within 10 working days (see below).

MOF, Alm.del - 2022-23 (2. samling) - Endeligt svar på spørgsmål 20: Spm. om redegørelse for sagen om udledning af miljøfarlige stoffer fra RGS Nordics renseanlæg i Stignæs

You have the possibility to provide your comments, and to provide any additional information. We

emphasize that the burden of proof is on Equinor.

We expect any new information within 10 working days from now. Due to weekends and public holidays,

this means at the latest by the end of the day on friday the 9th of April, after which notification validity

ceases.

We note that pursuant to the Regulation article 9, para. 5, issues must be resolved within 30 days following

the date of transmission of the acknowledgement of the competent authority of destination in accordance

with Article 8. This deadline has passed, and the 10 working days is to be seen as an extension of this

deadline.

If at a later time you still intend to carry out the shipment (and if the issues has been solved at such a later

time), a new notification must be submitted.

The new information we have received

At the 15

of January 2021 we contacted Miljödirektoratet in Norway to seek confirmation for the

information provided by you. Miljödirektoratet informed us at the 19

of January that they did not have

any comments to - or specific reservations against - the documentation provided by you.

On the 2

of February 2021 we contacted SAR Mongstad in order to obtain their confirmation of your

conclusion. SAR responded in a manner which could not confirm your conclusion. SAR described to us that

the volume treated in 2020 (approx. 100.000 tons) is not indicative of maximum capacity. Potentially, and

given the right circumstances, SAR may be able to treat all of the water from Equinor, or a smaller amount

such as 80%, depending on the content of the waste water. At least 20% would be possible to treat. SAR

needs more information about the content of the waste water to estimate how much of it may be viable to

treat. SAR also needs more information from Equinor in order to assess the commercial viability of a

contract. SAR informed us of a continuous dialogue between your companies.

Please see attached e-mail correspondence of the 2nd and 3rd of February 2021

At our meeting on the 3

of February 2021, we provided to you an early notice of this information from

SAR. At the meeting, you confirmed to us that you have had communications with SAR since December last

year, regarding their capacity for waste water treatment. You noted that salinity is important. We informed

you that we would respond to you in a more formal manner regarding our assessment of the case.

Danish EPA met again with Miljödirektoratet on the 15

of February 2021 concerning the new information

from SAR. Miljödirektoratet confirmed the view expressed by SAR; that it is plausible that SAR may have

capacity for treating volumes of waste water equivalent to the volumes produced by Equinor, and that

more information about the content of the waste water is necessary for SAR to evaluate whether the

particular type of waste water may be treated at their facility.

Danish EPA met again with Miljödirektoratet on the 22nd of March 2021. No new information was fielded.

Our assessment

On basis of the information we received from SAR it would seem at the outset that there is - or may soon be

acquired - the needed capacity for treatment in Norway. As far as capacity is a concern it seems SAR can

scale production to a level where it becomes possible to accept some or all of the water produced by

Equinor. SAR needs more information from Equinor in order to conclude in final.

In order to give consent, Danish EPA would require for it to be ascertained in a conclusive manner that

there is not the possibility of treating the waste water in Norway. We therefore note that the possibility of a

consent would at the least require for Equinor to provide any needed information to SAR, and for Equinor

MOF, Alm.del - 2022-23 (2. samling) - Endeligt svar på spørgsmål 20: Spm. om redegørelse for sagen om udledning af miljøfarlige stoffer fra RGS Nordics renseanlæg i Stignæs

to provide Danish EPA with a response to such information from SAR.

Further issues

If it should be concluded

that SAR has the technical capability to treat the waste water, we would then need

information about their current capacity as well as their ability to scale production and an expected

timeframe.

Furthermore, it is important to note that the criteria for import into Denmark are

-whether the exporting country has the means to treat the waste itself (and if such facilities exist but do not

have capacity, that is considered the equivalent of not having the means to treat the waste), and

-whether the waste is generated in such small amounts that the building of new facilities must be

considered uneconomical.

For practical reasons, we do not expect to go into detail with these issues unless you are able to provide

new information regarding the treatment possibilities at SAR.

Venlig hilsen

Tor Søltoft

Sagsbehandler | Cirkulær Økonomi & Affald

[email protected]

Sagsbehandlernes tlf. +45 23 72 92 28, alle hverdage mellem kl. 9:00 – 15:00

Miljøministeriet

Miljøstyrelsen

| Tolderlundsvej 5 | 5000 Odense C | Tlf. +45 72 54 40 00 |

[email protected]

www.mst.dk

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