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Requesting information related to EPR/BL9763IN/V004

We're waiting for Ada Zaffina to read recent responses and update the status.

Dear Environment Agency,

1. Can I please request the following documents for the new environmental permit at Brockham (EPR/BL9763IN/V004):

- Latest WMP (Waste Management Plan)
- Latest HRA (Hydrological Risk Assessment)
- Any amendments to the WMP or HRA
- Registered De minimis exclusions
- CAR documents:
11 Dec 2018 Pre-Op 01
19 Dec 2018 Pre-Op 02
20 Dec 2018 Pre-Op 03
04 Dec 2018 site visit
13 Dec 2018 site visit
20 Dec 2018 site visit

2. The new permit prohibited the practice of water re-injection at Brockham of waste water produced at Brockham and Lidsey. I understand that the EA did not require the reporting of volumes, times and pressures or other details water of reinjected at Brockham, either from each source or total. Can I please also request clarification on:

a) when EA approved this practice originally for water produced at Brockham
b) when EA approved this practice originally for water produced at Lidsey
c) records of volume of water produced and injected shared on the OGA portal indicate that not all water produced was reinjected. Does the EA have knowledge of what happened to the water that was not reinjected?
d) has the EA carried out any tests of water reinjected at Brockham to check for NORM and toxicity?
e) which treatment facility is waste/produced water be tankered to from Brockham going forward? what reporting will the EA receive?

Yours faithfully,

Ada Zaffina

Enquiries, Unit, Environment Agency

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Good afternoon,

 

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
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Customers and Engagement
Environment Agency
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Endeavour Park
London Road
Addington
West Malling
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Kind Regards,

 

Colleen Buckley

National Customer Contact Centre

Environment Agency

 

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Dear Enquiries, Unit,

Further to my original request filed on 4th January, could you also please clarify:

Is the EA aware of the the identities of the chemical constituents of additives and the concentration of the additives and each chemical constituent in the well stimulation treatment fluids, such as PROTEKT 15?
Can you please share this information?

Yours sincerely,

Ada Zaffina

Enquiries, Unit, Environment Agency

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Thank you – the Environment Agency has received your email.

 

For information on what you can expect from us and our full service
commitment to you then please visit our website: 

[1]https://www.gov.uk/government/publicatio...

 

Freedom of Information Act and Environmental Information Regulations state
that a public authority must respond to requests for information within 20
working days however we always aim to provide an answer as soon as we can.
 

 

Usually we make no charge for providing information. In some cases we may
make a charge for licensed re-use of our data. Where this is the case, we
will notify you in advance.

 

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If your email was to report an environmental incident i.e. pollution, fish
in distress, dumping of hazardous waste etc. then please call our
Freephone 24 hour Incident Hotline on 0800 80 70 60.   For more details
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[2]https://www.gov.uk/report-an-environment...

 

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( Tel: 03708 506 506

: Web Site: [3]www.gov.uk/environment-agency

 

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Enquiries, Unit, Environment Agency

Dear Ada,

 

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.

 

You can find more information about our service commitment by clicking on
the link below:

 

[1]https://www.gov.uk/government/publicatio...

 

You can contact our customer team directly on the contact details below,
or call the National Customer Contact Centre on 03708 506506 who will
transfer you to the area team. 

 

Please quote your enquiry reference 190124/AC08 in any correspondence with
us regarding this matter.  

 

Customers and Engagement
Environment Agency
Kent,South London & East Sussex Area
Orchard House
Endeavour Park
London Road
Addington
West Malling
ME19 5SH

 

Yours sincerely,

 

National Customer Email Team

Customer Contact Centre

Environment Agency

( Tel: 03708 506 506

: Web Site: [2]www.gov.uk/environment-agency

 

 

 

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KSL Enquiries, Environment Agency

1 Attachment

Dear Ada

 

Thank you for your enquiry received on 04 January 2018, ref: KSL 112967.

 

We respond to requests for information under the Freedom of Information
Act 2000 and Environmental Information Regulations 2004.

 

Please find the response to your enquiry attached.

 

 

Regards

 

KSL Customers and Engagement Team

 

Customers and Engagement | Kent, South London and East Sussex
Environment Agency | Orchard House, Endeavour Park, London Road,
Addington, ME19 5SH

Tel:  0208 474 6848

Email: [1][email address]

 

 

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KSL Enquiries, Environment Agency

1 Attachment

Dear Ada

 

Thank you for your enquiry received on 21 January 2019, reference: KSL
113966.

 

We respond to requests for information under the Freedom of Information
Act 2000 and Environmental Information Regulations 2004.

 

Please find the response to your enquiry attached.

 

 

Regards

 

KSL Customers and Engagement Team

 

Customers and Engagement | Kent, South London and East Sussex
Environment Agency | Orchard House, Endeavour Park, London Road,
Addington, ME19 5SH

Tel:  0208 474 6848

Email: [1][email address]

 

 

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Dear KSL Enquiries,

Thank you for your response.

Yes, you have previously provided the De Minimis registration forms for Protekt 14 and 15, however they don't list all chemical constituents. For example, only one constituent of the corrosion inhibitor is listed (CAS 61791-39-7), and no constituents are listed for product PROTEKT 318 (please see below the relevant section of the Protekt 14-10 De-minimis registration).

Therefore, I believe that my question on whether or not the EA has the full list of chemical constituents of treatment fluids along with their concentrations remains valid.

" This is the assessment for PROTEKT 14-10 which comprises:
 10-11% acetic acid
 75-85% water
 1-4% corrosion inhibitor (see discussion below)
 1-2% PROTEKT 318 (a surfactant product previously assessed using the JAGDAG methodology as containing only non-hazardous ingredients)

The corrosion inhibitor includes the following substance:
 1H-imidazole-1-ethanol,4,5- dihydro-2-nortall-oil alkyl (CAS 61791-39-7)
The information on the corrosion inhibitor is insufficient to confirm that it can be classified as non-hazardous, with respect to the JAGDAG methodology, at present. As a result we have taken the precautionary approach, considering it as a hazardous substance.
The other ingredients have been classified as Non-hazardous."

Yours sincerely,

Ada Zaffina

KSL Enquiries, Environment Agency

1 Attachment

 

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Dear customer

 

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KSL Enquiries, Environment Agency

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Dear Ada

 

Thank you for your enquiry received on 13 August 2019, ref: KSL 138698.

 

We respond to requests for information under the Freedom of Information
Act 2000 and Environmental Information Regulations 2004.

 

Please find the response to your enquiry attached.

 

 

Regards

 

KSL Customers and Engagement Team

 

Customers and Engagement | Kent, South London and East Sussex
Environment Agency | Orchard House, Endeavour Park, London Road,
Addington, ME19 5SH

Tel:  0208 474 6848

Email: [1][email address]

 

 

 

 

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Dear KSL Enquiries,

Thank you for confirming the de minimis registration did not cover all chemicals. If there was more transparency in the EA's assessment process, there would be no need for my questions.

Thank you also for clarifying that the operator is not required to provide information to the extent of detailing the exact composition of each product including the individual chemicals and precise proportions within each product. Can you please clarify whether the EA receives this information from the product manufacturer instead?

Yours sincerely,

Ada Zaffina

Dear KSL Enquiries,

Apologies for multiple emails. In addition to my question on 30 September about whether you receive information on chemical composition of products from the manufacturers, I would also like to ask the following:

In your response to me you state:
"the operator must disclose information about the chemicals they will use in total and the maximum amount of each chemical. This includes information on discharges of chemicals which are subject to the ‘de minimis’ exclusion, that is, discharges that are so small in quantity and concentration, that they only pose an extremely low risk of polluting groundwater or associated environment."

Can you direct me to where I can find this information for the completion/acid wash activities (and any other activities following the drilling of wells) taking place or planned at Horse Hill? I have reviewed the WMP v.5.0 but it doesn't seem to contain this information ?

Yours sincerely,

Ada Zaffina

KSL Enquiries, Environment Agency

Dear Ada

 

Thank you for your enquiry received on 02 October 2019, ref: KSL 146365.
Apologies for our delay. We respond to requests for information under the
Freedom of Information Act 2000 and Environmental Information Regulations
2004.

 

To be sure that we have not misinterpreted your question, please would you
be able to clarify what information you were searching for in the waste
management plan?

 

Thank you in advance for your co-operation. Please be advised, until we
hear from you again, your enquiry will be placed on hold.

 

Regards

 

KSL Customers and Engagement Team

 

Customers and Engagement | Kent, South London and East Sussex
Environment Agency | Orchard House, Endeavour Park, London Road,
Addington, ME19 5SH

Tel:  0208 474 6848

Email: [1][email address]

 

 

 

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KSL Enquiries, Environment Agency

1 Attachment

Dear Ada

 

Thank you for your enquiry received on 30 September 2019, ref: KSL 146364.

 

We respond to requests for information under the Freedom of Information
Act 2000 and Environmental Information Regulations 2004.

 

Please find the response to your enquiry attached. Apologies for the
delay.

 

 

Regards

 

KSL Customers and Engagement Team

 

Customers and Engagement | Kent, South London and East Sussex
Environment Agency | Orchard House, Endeavour Park, London Road,
Addington, ME19 5SH

Tel:  0208 474 6848

Email: [1][email address]

 

 

 

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We don't know whether the most recent response to this request contains information or not – if you are Ada Zaffina please sign in and let everyone know.