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Good morning Emily

I have passed your e-mail to the local customer team who will deal with
your request.

The Freedom of Information Act and Environmental Information Regulations
state that a public authority must respond to requests for information
within 20 working days, but we aim to respond to all enquiries as quickly
as we can. 

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the link below:- 

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Please quote your enquiry reference 200131/ALC09 in any correspondence
with us regarding this matter.  

Customer and Engagement

Environment Agency

Solent and South Downs Area

Guildbourne House

Chatsworth Road

Worthing

West Sussex

BN11 1LD

Regards

Environment Agency - National Customer Contact Centre

Part of National Operations Services

Tel: 03708 506 506

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Dear Emily,        

Thank you for your email of 30 January.  Please see the below response
from our technical team: 

·       Please can you send me records demonstrating compliance with rule
1.1.1. of the Standard Rules SR2014 No 4 Accumulation and disposal of
radioactive waste from the NORM Industrial Activity of the production of
oil and gas

In December 2019, IGas Energy Enterprise Limited applied to the
Environment Agency for a bespoke permit to allow them to receive,
accumulate and dispose of radioactive waste in the form of naturally
occurring radioactive material at the Singleton site. This application is
still being assessed and the permit has not yet been issued. The Singleton
site has not had a Standard Rules SR2014 No 4 permit. IGas Energy
Enterprise Limited withdrew their application for a standard rules permit
and instead applied for a bespoke environmental permit.

The management system that the operator intends to use is detailed in the
documents submitted in support of their permit application. These
documents can be viewed here:
[1]https://consult.environment-agency.gov.u...

·       Please can I see a copy of monitoring and measurements taken
during maintenance of systems and equipment which demonstrates compliance
with these rules

As the establishment does not currently have an environmental permit to
allow them to receive, accumulate and dispose of radioactive waste in the
form of naturally occurring radioactive material, the Radioactive
Substances Regulation team do not hold this information.

·       Please can I see a copy of the permit Standard Rules SR2014 No 4

As mentioned above, the site does not hold a Standard Rules SR2014 No.4
permit. However, the permit template can be found here:
[2]https://www.gov.uk/government/publicatio...

·       Please can I see a copy of the records of the following records of
radioactive waste showing:

(a) the radionuclide present, the date on which accumulation began and the
activity on that date;

(b) so far as is reasonably practicable its location on the premises;

(c) if it has been removed from the premises, the date of removal, the
activity on that date and the name and address of the person to whom it
was transferred; and

(d) the total activity and volume of radioactive waste present on the
premises.

As the establishment does not currently have an environmental permit to
allow them to receive, accumulate and dispose of radioactive waste in the
form of naturally occurring radioactive material, the Radioactive
Substances Regulation team do not hold this information.

Please be advised that because we do not hold this information, we are
refusing your request and, as a public body, are required to provide a
formal letter of notice (attached) that gives an explanation for the
reasons for this refusal. 

This information is supplied subject to the notice which can be viewed via
the following link:
[3]http://www.nationalarchives.gov.uk/doc/o...

Please get in touch if you have any further queries or contact us within
two months if you would like us to review the information we have sent.

Kind regards

Customers & Engagement Team

Environmental Planning and Engagement | Solent and South Downs Area | 
Environment Agency | Guildbourne House, Chatsworth Road, Worthing, West
Sussex, BN11 1LD

[4][email address]

National Customer Contact Centre 03708 506506

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Thank you for your email.

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in distress, dumping of hazardous waste etc then please call our freephone
24 hour Incident Hotline on 0800 80 70 60.   

For more details about incident reporting please see our website:
[4]https://www.gov.uk/report-an-environment...

Kind regards

Customers & Engagement Team
Solent and South Downs Area
Environment Agency | Guildbourne House, Chatsworth Road, Worthing, West
Sussex, BN11 1LD
[5]ssd[Environment Agency request email]
External: 020 302 57278
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Dear Emily,      

Thank you for your follow-up email of 17 February – please see the below
response from our technical team:

1.     IGAS have said that they are applying to do the same activity that
they have done onsite previously. If they have in the past received,
accumulated and disposed of solid and aqueous radioactive waste / NORM
then how was this regulated?

o   As legislation and industry practices change, the Environment Agency
consistently reviews our regulatory approach. From 1 October 2013, we
required all operators of Oil and Gas facilities to have environmental
permits in place for all phases of operation from exploration through to
production. The environmental permit that is currently being determined
will, if issued, allow the operator to accumulate and dispose of solid
NORM waste, reinject produced water that contains NORM and inject produced
water from other sites that contains NORM.

The site operator has told us that they currently and have in the past,
reinjected their own produced water from the Singleton site and very
occasionally injected produced water imported from other sites, but this
hasn’t been done on a routine basis. They also told us that although
equipment and pipework is regularly checked, they have not accumulated or
disposed of solid NORM waste at the Singleton site.

The operator does not require a Radioactive Substances Permit to re-inject
produced water from the same site to encourage further hydrocarbon
production even if the produced water contains NORM at a concentration
above the out of scope values
([1]https://www.gov.uk/guidance/onshore-oil-...).

The injection of produced water imported from other sites has not been
regulated previously.

2.     More specifically, under which regulations did these activities
fall and who was responsible for monitoring the NORM and solid radioactive
waste? Where would the NORM waste have been stored?

o   The operator has told us that no solid radioactive waste has been
accumulated on site. Produced water has been stored in bunded tanks prior
to reinjection.

3.     Is there any data anywhere that concerns the solid and aqueous
radioactive waste that has been received, accumulated and disposed of at
the Singleton site from 1988-present?

o   The Radioactive Substances Regulation team do not hold any data that
has been received, accumulated or disposed of at the Singleton site from
1988 to present.

Please be advised that because we do not hold this information, we are
refusing your request and, as a public body, are required to provide a
formal letter of notice (attached) that gives an explanation for the
reasons for this refusal. 

This information is supplied subject to the notice which can be viewed via
the following link:
[2]http://www.nationalarchives.gov.uk/doc/o...

Please get in touch if you have any further queries or contact us within
two months if you would like us to review the information we have sent.

Kind regards

Customers & Engagement Team

Environmental Planning and Engagement | Solent and South Downs Area | 
Environment Agency | Guildbourne House, Chatsworth Road, Worthing, West
Sussex, BN11 1LD

[3][email address]

National Customer Contact Centre 03708 506506

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