Brockham oil site in Surrey during work earlier this year. Photo: Brockham Protection Camp
Angus Energy’s Brockham oil site – currently in a dispute over planning permission – breached a condition of its environmental permit earlier this year, the Environment Agency has confirmed.
A Freedom of Information response sent to a resident showed that Environment Agency staff recorded a permit breach after a visit to the Surrey site in January 2017. Environment Agency Compliance Assessment Report for Brockham 26 Jan 2017
The breach concerned the storage of waste in an uncovered skip, against a requirement of the waste management plan.
The site, near Dorking, is already at the centre of a planning dispute over a side—track well drilled earlier in January. Angus Energy strongly maintains that work at the site was covered by an existing permission. But correspondence shows Surrey County Council twice told Angus that it did not believe the permission covered a side-track.
DrillOrDrop invited Angus Energy today to comment on the permit breach but the company has not responded. This post will be updated with any future statement from the company.
Waste storage breach, leakage and stains
According to the FOI document, staff from Surrey County Council, the Environment Agency (EA) and Health and Safety Executive visited Brockham on 26 January 2017.
Following the visit, the EA issued a Compliance Assessment Report, which recorded:
“During the site inspection a large uncovered skip of extractive waste was observed to be stored on site (in front of the firewater tank, by the recycling and general waste skips). This is a breach of permit under the condition 2.3.1 (WMP Site containment 6.3).”
The WMP or Waste Management Plan requires:
“Only covered skips and enclosed tanks will be used for the temporary storage of extractive waste awaiting collection.”
The EA rated this breach as:
“A non-compliance which could have a minor environmental effect”.
Breaches are scored from 0.1 for the least serious to 60 for a major breach. The Brockham breach scored 4 and is regarded as a minor event.
The Compliance Assessment Report also recorded:
“A leakage was observed from the base of the skip onto the surface/made ground.”
“There were numerous stained areas onsite where oil has appeared to penetrate into the surface/made ground. These were particularly evident in areas in front of the tanker loading bay and another in front of the main tank bund.”
“It was noted that in another area oily pipes were laid on plastic tarpaulin to provide additional pollution prevention.”
Oil and gas sites are required to have an impermeable membrane to ensure that spills do not contaminate surface or groundwater.
However, at Brockham, the Compliance Assessment Report recorded:
“The extent of the impermeable membrane is not known on this area where the skip was held.”
Angus Energy was instructed to:
“Review the temporary storage of extractive waste on site to ensure that the storage is appropriate going forward and it is in an appropriately designated area.”
“Submit documentation to confirm the extent and integrity of the impermeable membrane on site.”
According to the document, the Environment Agency has previously asked for information about the impermeable membrane but this had not been supplied by the date of the visit. A deadline was set for 24 February 2017.
Other instructions
The company was also asked to:
- Ensure operations are undertaken in a manner that prevents any spills or leaks on site
- Ensure any spills are cleared as soon as possible
- Clear areas where surface/made ground is contaminated with oil
- Confirm that waste has been removed offsite to an appropriate facility (by 24/2/2017)
- Confirm the appropriate cement standard was used in operations on the well (by 24/2/2017)
- Provide a cement bond logging summary for the operations on the well (by 24/2/2017)
- Submit a summary of monitoring results for gas monitoring at the well head and well bore returns (by 24/2/2017)
- Investigate the integrity of part of the internal drainage ditch and seal any fractures as soon as possible (by 24/2/2017)
The Environment Agency told DrillOrDrop today no Compliance Assessment Reports had been issued from 24 February-28 March 2017.
Drilling the side-track well
The Compliance Assessment Report also provides more detail about the drilling operations at Brockham, which have concerned opponents of onshore drilling and some residents.
The report records:
“Verbal indication was provided on site that a sidetrack had been drilled off Brockham well 4, with work beginning 21/01/17.”
The Environment Agency confirmed that Angus Energy had an environmental permit for the side-track.
The report said:
“This operation is permitted under the Standard Rules Permit SR2015 No 1 (EPR EB3604MZ/ EAWML 403648). Operations were complete on site and equipment was being removed offsite on the day of inspection. The rig was due to come down imminently.”
However, in a letter granting the environmental permit on 14 November 2016, the EA told Angus:
“This permit does not, in isolation, provide you with all the permissions you need to carry out the drilling operations you have applied to undertake. It is your responsibility to ensure that you have all appropriate permissions in place before work commences.”
Environment Agency letter for Brockham permit 14 Nov 2016
On 9 March 2017, six weeks after the site visit, Surrey County Council said:
“We were extremely disappointed to find out that Angus Energy has acted without planning permission and contrary to our advice and guidance so we are meeting with them this week as a matter of urgency to resolve this.”
Up until then, the council had stated that the work at Brockham amounted to maintenance and was covered by the existing planning permission for production, granted until 2036.
Nearly a fortnight ago, the council said it had asked Angus to apply for retrospective planning permission for the side-track. But it has made no further statement since then.
Angus published information on its website about Brockham but has not issued an RNS, a statement to investors, on the site since 10 March 2017. A company bond issue, due on 23 March 2017, is now expected on or about 27 April 2017.
- Tomorrow (Wednesday 29 March 2017) Angus Energy is holding its first annual general meeting since it floated on the AIM stock market. The event is at 10am at the offices of Fladgate LLP, 16 Great Queen Street, London, WC2B 5DG. Details
Documents
Environment Agency Compliance Assessment Report for Brockham 26 Jan 2017
Environment Agency letter for Brockham permit 14 Nov 2016a
Categories: Regulation
DRILL OR DROP? 
“Angus Energy said today it had not been notified formally by Surrey County Council that it had breached planning permission at its oil production site at Brockham near Dorking.
The company remained adamant that it had done nothing wrong and said it would not apply for retrospective planning permission.”
Thanks for that Paul. I have to admit I do make the mistake that i believe some posters have a greater level of knowledge and awareness. Having watched the poor anti fracking lady “spokesperson” from the Greens on the Daily Politics I should have learned a lesson-took me back to Natalie Bennett and her performances on “explaining” economic policies. (I am not sure an appearance on those sort of programs should be relying upon a sympathy vote, but the BBC seem to think it entertaining.)
Surrey County Council are telling people that Angus did not have the required planning permission, Angus are officially stating that existing planning permission was valid for the sidetrack. So who is correct? I would have thought that SCC would have issued Angus something formal in writing? We shall see. But an uncovered skip is hardly a cause for concern.
The BBC appears to be run by, and full of, left wing green arts and social science graduates, who are anti business and anti oil & gas, and who don’t understand anything about industry and how it works.
Fascinating, here there be dragons, it seems that Angus Energy, The Environment Agency and Surrey County Council all think they have the only truth in their respective positions.
We seem to be in a situation where two agencies, being The Environment Agency and Surrey County Council, think this is a “class 10” breach of the regulations, in that no permission was granted, and Angus Energy think it is a “class 0” or no breach at all because Surrey County Council did not write an official letter, but did verbally tell them they had no permission to proceed?
This is another case of terminological inexactitude isn’t it?
Perhaps the real point here is who holds the regulatory authority here? Angus Energy? The Environment Agency? or Surrey County Council?
At a glance, assuming a regulatory scale of of 0-10 where 0=0%, ie, none at all, and 10=100%, meaning total authority, therefore it would be reasonable to state:
Angus Energy=0
Surrey County Council=10
The Environment Agency=10
Also I believe that a verbal instruction by a regulatory authority (100%) constitutes a legally enforceable notification in law.
Does that clarify the issue for you?
No Phil C, it does not. The EA issue is about an uncovered skip. The SCC issue is about a well sidetrack which the EA has confirmed was permitted.
Yes it does, avoiding the real issue wont change that. The real point is, that Surrey County Council are the regulatory authority regarding planning permissions, The Environment Agency are the authority on environmental grounds and technical issues, one cannot operate without the other. The Environment Agency cannot issue planning approval without Surrey County Councils approval.
Angus Energy cannot proceed on just The Environment Agencies technical approval, to do so makes a mockery of the whole process. Clearly Angus Energy do not have the planning permission from Surrey County Council to proceed, regardless of whether there is technical approval of sidetrack issues. The Environment Agency may well have given approval for a well sidetrack, but Surrey County Council still need to give their permission as to when it happens and what extra permission conditions are required before drilling starts. Clearly they have not done so and have said so. Angus Energy went ahead anyway regardless and have now said that they will not apply for a retrospective application, that is a typical display of contempt to Surrey County Council and that cannot be minimised by any other issue. That is the breach and that is fundamental. That is the point, logic chop it how you wish.
Its all about who thinks what has been agreed by who and to do what, when and how, and its no good Angus Energy sitting in the middle ignoring everyone and doing what they please by playing one off against the other.
It is a case of the now obvious operation of terminological inexactitude run riot, and that must now be tied down good and tight for every site, or we will end up with operational anarchy.
I also believed Paul, wrongly it seems, that reading is not an issue on this site! Can’t quite understand why Ruth continues to post information and some ignore the content and rant away about something else. Perhaps Ruth should produce a fantasy section where speculation and fabrication can run riot.
A gentle reminder that this is a site already with approvals for extracting oil, not an exploration site. I would suggest it is not helpful to continue fabrication around this “story”. I suspect someone’s career could be on the line here, so I, for one, will leave this one alone now until the facts are finalised. Sorry PhilC, but I am moving on. I am sure we will be able to have a debate in another section.
Hey! Great new strategy! Love the implied rant where there is none?
Did that emerge from the secret meeting? Respect! Sort of non confrontational, avoid the discussion, nothing to see here, move along please, no comment, and plead the 5th amendment all rolled into one, and then an added socially responsible guilt twist, a gentle fatherly apologetic reminder and side swipe (not a sidetrack, though it could be i suppose?) at Ruth and Drill or Drop who provided the forum for you in the first place?
All in one post, veeery impressive! way to go! High five! i reckon that must be a 9/10 at least?
Always an education martin.