Onsite reinjection A formal consent is not needed for OBM/SBM cuttings reinjection onsite. An application must however be made to the Department for Energy Security and Net Zero 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).

Onsite reinjection To obtain Department for Energy Security and Net Zero approval for OBM/SBM reinjection apply by letter to the Department for Energy Security and Net Zero stating intention and providing details.Export for off-site reinjection at another field

A web based application form can be downloaded from the Department for Energy Security and Net Zero 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.

Reinjection at same field the Department for Energy Security and Net Zero, 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.

The Department for Energy Security and Net Zero plan to incorporate this application system into UK Oil Portal, once this is in place, all applications will be made via this system.

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.

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.

Disposal of cuttings generated offshore by reinjection is allowed both onsite and offsite under revised Department for Energy Security and Net Zero 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.