4. Radioactive substances activity permits
When you need a radioactive substances activity permit for onshore oil and gas activities, types of radioactive waste and out of scope naturally occurring radioactive material (NORM) values.
If you are flowing (producing) oil or gas, you will need to apply for a bespoke radioactive substances activity permit if there is no standard rules permit that covers your activities. You need the permit to manage any radioactive waste produced by your activities.
The Environment Agency will define your activities as producing oil, gas or both if you:
- provide facilities to handle and store oil, gas or both at the wellhead
- combust, flare or vent gas
You will also need a radioactive substances activity permit to use:
- wireline well logging equipment containing radioactive sources – if you employ a service company to do this work, they must have the correct permits
- radioactive tracers to carry out environmental investigations such as determining the extent of shale bed fracturing – contact the Environment Agency early as these permits need special consideration
In some circumstances, you may also need a radioactive substances activity permit if you want to re-inject produced water. See section 11 Produced water and flowback fluid: re-injection and reuse.
A radioactive substances activity permit allows you to accumulate, dispose of or receive radioactive waste that may arise from oil or gas production.
Waste from the oil and gas industry usually contains concentrations of NORM that are higher than the out of scope values for NORM. Out of scope means levels at which NORM is not hazardous.
Radioactive waste could be:
- waste equipment that contains or is contaminated with NORM - such as pumps, process vessels or pipework
- waste water – often called ‘produced water’ or ‘flowback fluid’
- waste solids you have removed from process vessels - such as sand, sediment, scales and sludges
- NORM-contaminated well stimulation fluids left underground and no longer of use
- NORM in any gas you will burn or vent on site - the gas stream may contain entrained liquids or solids containing NORM
These values are specified in Schedule 23 to the Environmental Permitting (England and Wales) (Amendment) (No. 2) Regulations 2018.
This table has examples of out of scope NORM content values. You will need to consider all of the NORM radionuclides present in the waste.
| Radionuclide | Solid (becquerels per gram) | Aqueous Liquid (becquerels per litre) | Gaseous (becquerels per cubic metre) |
|---|---|---|---|
| Ra-226+ | 1 | 1 | 0.01 |
| Pb-210+ | 5 | 0.1 | 0.01 |
| Po-210 | 5 | 0.1 | 0.01 |
| Ac-227+ | 1 | 0.1 | 0.001 |
| Th-232sec | 1 | 0.1 | 0.001 |
| Th-232 | 5 | 10 | 0.001 |
| Ra-228+ | 1 | 0.1 | 0.01 |
Becquerel (Bq) is the international System of Units for a unit of radioactivity.
If you think your operation will not generate waste containing or contaminated with NORM above the out of scope values, you will need to provide evidence. You must do this before you apply for your permit – at the pre-application stage.
You must have a radioactive substances activity permit before you start producing oil and gas. If you do not, and your operations generate waste containing NORM above the out of scope values, the Environment Agency will take enforcement action against you.
You do not need a radioactive substances activity permit to accumulate or dispose of:
- NORM contained in wastes generated before the production of oil and gas (drilling muds and drill cuttings)
- NORM wastes below the out of scope values
- NORM wastes covered by the conditions in the exemptions to the regulations – see the provisions relating to solid and NORM waste in the Guidance on the scope of and exemptions from the radioactive substances legislation in the UK
- radon, which is naturally present at low concentrations in all natural gases – but the Environment Agency will consider the radiological impact from exposure to radon from radioactive waste when they assess (determine) a permit application