Proposals by Angus Energy to protect the environment at its Brockham oil site in Surrey are inadequate, vague and subjective and raise doubts about the company’s competence, according to a local community group.
Brockham Oil Watch, which opposes Angus Energy’s operations at the site near Dorking, has called for extra safeguards, including an adequate level of insurance cover to clean-up any problems.
The group was responding to the Angus application to the Environment Agency for an environmental permit to allow oil production at the site.
The company is seeking permission for venting from oil storage tanks, well workover operations, including hot oil and acid washes, and the reinjection of produced water from the Brockham and Lidsey well sites.
A public consultation on the application ends tomorrow (7 September 2017). Link to consultation information
The proposed production well, called BR-X4Z, was drilled in January 2017. It remains the focus of a disagreement between Angus and Surrey County Council over whether drilling was covered by an existing planning permission. The county council also argues that the existing planning consent does not cover production, something Angus rejects.
Brockham Oil Watch (BOW) said:
“We feel that this history of challenging one of the regulatory bodies demonstrates that Angus Energy do not have the competence required of a responsible operator”.
Angus does not plan to flow test the wells before beginning production. BOW said:
“Many would consider this to be reckless”.
BOW added that it was concerned about the failure and outstanding debts of Angus Energy subsidiaries and predecessor companies.
This history, the group said, “doesn’t offer confidence in Angus Energy being a long-term player who would be committed to dealing with environmental consequences of a major incident such as a spill or well blowout”.
BOW also questioned whether the company had the necessary resources and staffing to ensure compliance.
“We believe that there must be considerable doubt as to whether Angus Energy can be considered a suitable and stable operator and the Environment Agency should seek further assurances before issuing an environmental permit.”
“Risk assessment subjective and vague”
Angus Energy said in its application that the risk of contamination to groundwater from activities at the Brockham site were “unlikely”. It said the site had been assessed to “have a low sensitivity” because it was “remote” from drinking water aquifers. Any risks could be mitigated through controls which aimed to “eliminate, reduce, isolate and control potential sources of contaminations”, the company said.
But BOW said Angus’s review of the threat to groundwater, the hydrogeological risk assessment, failed to quantify the size of the hazards and their probability. It said:
“The process is therefore entirely subjective, vague and remains open to interpretation and speculation”.
BOW described the Environment Management System (EMS) document, submitted with the application, as “inadequate”.
It was not prepared to a recognised standard, the group said, and was not subject to certification, third party review or audit by an accredited body. The document also did not include detailed arrangements for regular monitoring, corrective actions and sign-off.
“We believe that Angus should be required to have an Environmental Management System and to a recognised standard that is subject to regular audit by an accredited independent audit organisation.”
“Inadequate emergency plan”
Angus included proposals in the EMS for dealing with emergencies. The company said:
“The operations on site have established and will maintain procedures to identify the potential for and respond to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them.”
But BOW responded:
“We feel that this is inadequate. The operator should have an Emergency Action Plan in place and should submit it as part of the permit application”.
History of local flooding
Angus said in its application that the risk of flooding from rivers and the sea were “very low” and the site was “not prone” to groundwater flooding.
But BOW said Angus had ignored the local history of flooding events and failed to mention surface water flooding. The group said 10 houses in Old School Lane, the road nearest the well site, had been flooded from Tanners Brook at Christmas 2013. A further 80 houses had been flooded elsewhere in the village from surface water flooding.
“We think that Angus should be required to carry out a detailed study of the risk of surface water flooding at the wellsite and the immediate surrounding area.”
“Acid treatment plans implausible”
The group described as “implausible”, the company’s plans to stimulate oil production by only acid and hot oil washes.
“If it were possible to extract Kimmeridge oil through acid wash this would have been done by BP when the original Brockham-1 well was drilled in 1987.”
The Kimmeridge limestones which Angus wants to target are described as a tight formation, which some commentators believe need to be stimulated with acid or fracked.
BOW said it was concerned that Angus could carry out large-scale acidising (pumping acid and other chemicals below ground to dissolve rock and release oil) or even use fracking to extract oil at Brockham but evade environmental obligations in the Infrastructure Act by using less than the defined volume of fluid.
The group told DrillOrDrop it was concerned that acidisation was poorly regulated in the UK. It can be used to mean routine well maintenance. But it can also refer to matrix acidising or acid fracking, which are well stimulation treatments. BOW said:
“This confusion in definitions is part of the reason why we think that regulation is not good enough”.
BOW called on the Environment Agency to require:
- An adequate level of insurance to clean up any problems
- Quantitative risk assessments for key issues
- An exhaustive list and quantities of hazardous materials that will be stored on site
- A detailed study of risk of flooding, including surface water flooding
- Further assurances on company suitability
BOW also asked the Environment Agency to:
- Limit the permitted use of acid to acid wash only and not to permit any other kind of acid treatment
- Require a further public consultation on any request to extend the permit to include, for example, any other formers of acid treatment or injection of fluids
Invitation to Angus Energy
DrillOrDrop put the points in BOW’s submission to Angus Energy and invited it to respond. We also offered the company the opportunity to write a guest post. This post will be updated with any response.