Regulation

Brockham oil site breached permit condition, document reveals

Brockham well Brockham Protection Site

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

25 replies »

  1. Paul-yes, this is just a joke, in an attempt to nullify the false allegations made against Angus previously, which will shortly be exposed. Desperate stuff. BUT, it could have been radio-active! (Joke-until you look at the history at HH.)

    [Edited by moderator]

    • [Edited by moderator]

      Guys, guys, listen to reason, we don’t want a burned out polluted country you silly men, we want a clean unpolluted country where we can bring up our children while you are off conning “intelligent strippers” into a freebee, good cause or no?

      Time we took over, you men have messed up big time for far too long, and this “fracking” nonsense i ask you, what a waste of everyones time and energy? you cant even get that straight can you?

      Don’t trip over your testosterone on the way home tonight?

      • You have bigger problems than a few exploration wells in the UK.

        http://www.bbc.co.uk/news/world-us-canada-39415631

        President Donald Trump has signed an executive order rolling back Obama-era rules aimed at curbing climate change.

        The president said this would put an end to the “war on coal” and “job-killing regulations”.

        The Energy Independence Executive Order suspends more than half a dozen measures enacted by his predecessor, and boosts fossil fuels.

        Business groups have praised the Trump administration’s move but environmental campaigners have condemned it.

  2. “an attempt to nullify the false allegations made against Angus previously,”

    Eh? What are you trying to say Martin? I’m not able to make any sense out of that.

  3. Wow, three minutes after a post, someone wanted to get their comment in pronto, or presto, didn’t they?

    So EA breaches are not serious then? Only a level four?

    How about this? would you say that this is more of a serious breach? Something to “get serious” about?

    “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.”

    Perhaps this is one of those terminology problems, it seems that the planning authority think they have agreed to the written terms of a exploration site, but the industry operator apparently thinks they have agreed to something entirely different? However, no one seems to have told the planning authority that the words on the contract are not worth the paper they are written on and never were, it was all just another “game” played by the industry at the expense of the planners. Perhaps now we are all a lot wiser, time to screw down all possible loop holes isnt it?
    We would not wish to mislead the planners and the public…..would we? That would be unthinkable.

    Gold standards anyone? No? Perhaps not? nothing to see here, move along please.

    What level of breach is that? a nine? a ten perhaps? Maybe we should employ a scale for breaches? A Breach Scale? What about three strikes and you are out?

    Lets start a count for each site? That would be fair wouldn’t it? Anyone want to play “spot the breach”?

    What about the eminent body who regulates below ground activities btw, who are they? What is their remit? And are they cognisant of these above ground breaches? Perhaps they should prepare for a permanent on site presence and monitor every step of the way, its going to be a rough ride it seems.

  4. What a joke, the skip in the road near my house would be classed as a bigger breach than this. Get some perspective people!

    • Brockham had close to 100 vehicle movements in the wrong direction or out of hours. One incident a lorry which had lights on until they left the compound and would have crossed a public footpath on a private road without them had it not been for a pedestrian not walking along that footpath who thankfully happened to be spotted without getting knocked over.

      Not to mention working hours for 13 nights, releases into the atmosphere of a still unexplained gas and [edited by moderator] to the stock market… I’d say this is a level 9 breach; everything but environmental catastrophe.

  5. Just wait and see refracktion. Not sure it is within my capacity to help you make sense of anything, (I have tried with economics) but I suspect you are more aware of the realities than you want to admit to on this site, and others, who may not be, will be. Clear as waste mud?

    Mds don’t worry. Your share value has only halved if you sell. Otherwise it may be a good opportunity to buy-but don’t take my comments as advice-do your own research. A strange suggestion here, I know, but to be recommended. AGM tomorrow, chance for some clarity.

    Safety-assuming again! “Freebie”?? You make it up as you go along, but of course that would make me a grasping capitalist, together with my female students who helped make the arrangement, and that “sells”?? I have had a lifetime of negotiating with international purchasing managers and have always avoided having one change my statements to achieve their objectives. Good luck.

  6. Your article is factually incorrect. You state “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.” Incorrect. Angus has subsequently released the following Q&A on its website which are very clear http://www.angusenergy.co.uk/media/press-reports-faq/

    • Apologies if the original piece isn’t clear. “It has made no further statement since then” refers to Surrey County Council. Angus have indeed made a further statement as you point out.

  7. Thanks Ruth for your eagle eye reporting. It highlights one of the holes in the UK regulatory cover between EA and local planning authorities, also that Angus Energy was willing to exploit the loophole. It looks to me like Third Energy are also on this tack in N Yorks, They are applying to EA for permission to flare gas at the KMA site (includes KM8), at the same time as there is an explicit condition in the NYCC planning permission that absolutely no gas can be flared. In the 3-day Northallerton planning meeting last year in May, flaring was a big issue – when challenged on the technical arrangements for gas coming up from the well to be piped straight down to Knapton Generating Station, John Dewar emphatically stated that there would be no need for flaring. At that point in time he must have known that the technology must allow for at least emergency flaring or venting, but he chose to make it sound totally unnecessary. NOw Third Energy application to EA for a permit alteration and consolidation includes the notion that emergency flaring must be accommodated by a mobile covered flare. Planning committees are unaware when they first deal with fracking companies that they are slippery customers with a bag of tricks up their sleeves, and will take ground inch by inch.

  8. Well, refracktion, you can start with todays post by Ruth reference Brockham/Angus. Suggest you steer clear of unsubstantiated “comments” that become “fact” and may yet end up in litigation. Is this really that much of a surprise to you, after Horse Hill was termed the Gatwick Gusher by the media, and then they turned upon the exploration companies for making such an outrageous claim? (There was a clue in the word “gusher”. I am not sure why anyone with knowledge should need translation when they can just examine the words.)

    I suspect you are well aware of what is going on here. If I suggest that, it is not a rant, it might even be a compliment. I said “wait and see”. Bit more clarity now? Some more to come yet I am sure, but a little more waiting for that- like correction of Ineos economics.

    • No Martin – I just wanted you to explain the meaning of “an attempt to nullify the false allegations made against Angus previously” which still doesn’t make sense to me – how does Ruth’s piece here attempt to nullify (invalidate? cancel out?) any putatively false allegations “which will shortly be exposed”. Maybe it’s me being dense but I can’t make sense of that statement and wondered what you were trying to say.

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