Reinjection of Mud and Cuttings

Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:

Related Legislation:
Guidance Notes: Offsite Injection Guidance

Consent Needed: Onsite reinjection A formal consent is not needed for OBM/SBM cuttings reinjection onsite. An application must however be made to BEIS to obtain approval.Export for reinjection at another field

For export of cuttings for reinjection at another field, a FEPA licence will be required. The first flush from well clean-up can also be exported for reinjection (see the Snippets tab).

Oil Discharge Permit (for reservoir hydrocarbon contaminated cuttings)

If cuttings are contaminated with reservoir hydrocarbons, a permit will be required under the OPPC Regulations (see OPPC Summary Table).

Chemicals

If any chemicals are used, e.g. in pre-treatment of cuttings prior to reinjection, these will need to be subject to a chemical permit under the Offshore Chemicals Regulations. Pre-treatment at the site of disposal will need to be covered by a permit for the disposal installation, pre-treatment at the site of waste production will need to be covered by a chemical permit for the producing installation facility (see Drilling Chemicals).

How to Apply: Onsite reinjection To obtain BEIS approval for OBM/SBM reinjection apply by letter to BEIS stating intention and providing details.Export for off-site reinjection at another field

A web based application form can be downloaded from BEIS Website along with Guidance Notes.

In addition to routine administrative information, you must provide a method statement detailing where the wastes originate, how you propose to transport them to the disposal site, whether you intend to undertake any additional pre-treatment prior to reinjection and how you propose to undertake the reinjection operation. The latter should include a technical case to support the safe injection and containment of any disposed material. You must additionally provide an assessment of the alternative means of disposal to demonstrate that offsite reinjection is the Best Practicable Environmental Option (BPEO).

Where disposal by reinjection will be at a site operated by a 3rd party, additional considerations will be required for any transhipment of wastes and the appropriate authority should be contacted to discuss the proposals prior to any formal application.

Applications that may have the potential to affect a designated European Site will also be subject to the provisions of the Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001.

Oil Discharge Permit (for reservoir hydrocarbon contaminated cuttings)

Applications for a permit under the OPPC Regulations must be made on the new PETS system where an Oil Discharge permit can be raised as a Subsidiary Application Template against the appropriate MAT. This is done on the UK Oil Portal.

Guidance Notes on the OPPC Regulations and Permit Application are available for download from DECC.

Who to Apply to: Reinjection at same field BEIS, via the UK Oil Portal.Export for off-site reinjection at another field

For off-site injection operations in offshore waters adjacent to Scotland (i.e. excluding Scottish controlled waters), contact:

Environmental Management Team
DECC Licensing and Consent Unit (LCU-OED)
Atholl House
86/88 Guild Street
Aberdeen AB11 6AR
(emt@decc.gsi.gov.uk).

 

For off-site injection operations in English and Welsh waters (both near-shore and offshore waters), contact:

Marine Consents and Environment Unit
Ergon House
Horseferry Road
London SW1P 2AL
(marine.consents@mceu.gsi.gov.uk)

Off-site injection is unlikely to take place in Scottish controlled waters (within three miles of the territorial seas baseline), where the FEPA Part II licensing authority is:

Environmental Protection Group
FRS Marine Laboratory
PO Box 101
375 Victoria Road
Torry
Aberdeen AB11 9DB
(enquiries@marlab.ac.uk).

Oil Discharge Permit (for reservoir hydrocarbon contaminated cuttings)

Application under the OPPC Regulations to be submitted electronically by email to offshore.inspectorate@decc.gsi.gov.uk.

BEIS plan to incorporate this application system into UK Oil Portal, once this is in place, all applications will be made via this system.

When to Apply: Reinjection at same field For reinjection of OBM cuttings letter of application should be made 4-5 weeks before spud date.Export for off-site reinjection at another field

Applications normally take eight to ten weeks to process, but may take longer.

Oil Discharge Permit (for reservoir hydrocarbon contaminated cuttings)

Applications must be submitted at least 28 days before the permit is required.

Limitations on Reinjection:

The licensing authorities will take account of any local sensitivity that could be adversely affected by the waste transport and disposal activities. Although applications will be considered on a case-by-case basis, it is considered unlikely that injection would normally be approved within three miles of the territorial seas baseline.

Permit Requirements: Disposal of cuttings generated offshore by reinjection is allowed both onsite and offsite under revised BEIS guidance (April 2003). Cuttings for reinjection may originate from any offshore field including those operated by other parties.Disposal of cuttings from onshore is not permitted. Disposal of LSA is currently still under consideration and not currently permitted. Disposal of cuttings recovered from cutting piles is also still under consideration, although is likely to be considered sympathetically. Such applications will still require full consideration as part of an approved Decommissioning Programme.Any chemicals contained in the waste for disposal requires a permit under the Offshore Chemicals Regulations. Any chemicals used during pre-treatment of cuttings will also require a permit either through a permit applicable to the waste generation site if this is where chemical use occurs or a chemical permit application for the disposal site if chemical pretreatment occurs here. In both cases it would normally be appropriate to include the chemicals in the installation production chemical permit (see Production Chemicals), although there could be occasions when chemicals used for pre-treatment at the site of production of the waste would be included in a term drilling chemical permit (see Drilling Chemicals).Pretreatment of cuttings at the site of waste production is accepted (e.g. treatment of cuttings to convert to slurry). However it will not be permissible to mix the wastes with surplus unused material, other operational waste streams such as well intervention fluids, or materials such as sewage or domestic waste.Pretreatment of cuttings at the reinjection site is accepted, and unlike at the site of waste production, includes mixing of waste with other waste streams generated at the disposal installation including drill cuttings, produced water or well intervention waste streams. However, as with waste production sites, it will not be permissible to mix the wastes with surplus unused material or materials such as sewage or domestic waste.

All applications for reinjection permits will be considered on a case by case basis taking into account any environmental sensitivities. It is unlikely that reinjection would normally be approved within 3 miles of the territorial seas baseline due to groundwater and water abstraction considerations.

Reinjection There are no sampling or monitoring requirements where cuttings are being reinjected (see OPPC Sampling Summary Table – Well Operations). If alternative discharge routes are used because of unavailability of reinjection, reference should be made to alternative consent/reporting requirements as appropriate.
What to Report: No reporting requirements.
Who to Report to: N/A
When to Report: N/A
Chemical Permits: See Drilling Chemicals.
Oil Discharge Permit: Non-compliance would include discharge or reinjection of reservoir contaminated hydrocarbons without a valid permit being in place.Any non-compliance must be reported using the OPPC non-compliance notification form, which can be downloaded from BEIS website along with appropriate Guidance Notes.
Offshore Inspection: The BEIS (then DECC) Offshore Oil and Gas Environment Unit Enforcement Policy sets out the general principles that Inspectors shall follow in relation to enforcement including prosecution.
When to Renew Consent/Exemption: An application to reinject cuttings should be made for each well/group of wells for which reinjection is planned.
Proposals for an Integrated Framework of Environmental Regulation: The proposals outlined by SEPA will deliver a simpler legislative framework which will enable SEPA to focus greatest effort on the environmental problems that matter most. It will provide a more consistent range of enforcement tools so that proportionate and effective action can be taken against those who would damage the environment. The consultation that has been undertaken built on previous consultations focusing on changes to the structure of environmental protection legislation in order to create a new, integrated framework for the permissions (licences, permits, rules, etc.) which will be used to control activities which could harm the environment.
Shipping Cuttings/Well Clean-up Fluids for Offshore Reinjection: Drill cuttings and the first ‘flush’ from well clean-ups can be shipped to another offshore site for reinjection. Supplementary advice from Derek Saward advised that BEIS had decided the first ‘flush’ from the well can be transported as it is deemed to still be part of the drilling process. Subsequent flushes are a new operation and could not be transported.Note: This process must be as continuous as possible – any undue delay may be deemed by BEIS as a break in the process and would remove the possibility of shipment and reinjection.
Transfrontier Shipment: There are still a number of issues to be resolved with respect to the transfrontier shipment of wastes for disposal by injection. Operators considering transfrontier shipment of wastes for disposal by injection should therefore contact the relevant consenting authorities (either BEIS and SEPA, or MCEU and EA), to discuss the proposals prior to submission of the formal applications.