Regulation

Interview: Planning for emergencies and accidents at oil and gas sites

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Cuadrilla’s Preston New Road shale gas site in Lancahsire preparing for fracking, 8 August 2018

As Cuadrilla prepares to frack the UK’s first horizontal shale gas well, DrillOrDrop talked to the Health and Safety Executive about the organisation’s role in keeping workers and local people safe.

180308 Pickering Tony Almond edit

Tony Almond, HSE oil and gas policy team. Photo: DrillOrDrop

The risk of fire and explosion are our main concerns, Tony Almond of the HSE’s oil and gas policy team said in an extended interview. Incidents “that could cause death or injury to a number of people”. Transcript of  interview (pdf)

How the HSE and the other regulators seek to prevent or deal with these emergencies is coming under scrutiny as fracking approaches at Cuadrilla’s Lancashire shale gas site.

Some residents and campaigners are calling for a halt to operations at Preston New Road until they have details about what would happen if something went wrong (links here and here).

So what is the HSE’s role in planning for emergencies at oil and gas sites?

Operators are required by regulations to produce an emergency plan of the site, Mr Almond said.

“As part of our site visits, or as part of our other inspections, we may inspect the Health and Safety document which includes the emergency plan.”

But this document may not cover land or properties outside the site boundary. Mr Almond said:

“There are no geographical limits set down, so it’s a risk-based thing. The operator needs to think about the impact and plan accordingly. Sites should be located and be of suitable size and layout so as to allow hazards to be confined within the site boundaries.”

Asked if the operator’s onsite emergency plan would include evacuations of neighbouring homes, Mr Almond said:

“If they [the operator] thought that was appropriate, yes.”

The HSE would take enforcement action if an emergency plan was not acceptable, Mr Almond said. But asked if the HSE had ever been unhappy with an emergency plan, he said:

“Not that I’m aware of. If we’d taken any enforcement action, that would have been made public, and I’m not aware of that happening.”

Mr Almond said the risk assessment, also required of operators, may not go beyond the site boundary. He said:

“There’s no set distance. It really depends on the well and the risk associated with it and what is present on the site.”

Asked to give an example of how far the HSE’s responsibility might go beyond the site boundary, Mr Almond said:

“I don’t think I can give you a distance. What it says in the regulations is that as far as they can, the operator should ensure that the health and safety risks are restricted to the site boundary so we would check the operator is working to that protocol.”

The emergency services and local authorities also have a role in planning for emergencies at industrial sites. This is carried out through the Local Resilience Forum (LRF).

In Lancashire, the LRF has assessed that Cuadrilla’s Preston New Road site has a “medium” risk (link). This means it does not warrant specific planning and can be covered by generic arrangements.

On the HSE’s role in local emergency planning, Mr Almond said:

“We will liaise with the emergency services and the local authorities if we’re approached.”

Asked whether Local Resilience Forums had been in touch with the HSE about any fracking or big oil and gas sites, he said:

“No. Although we have liaised with the local authorities so the people on the Local Resilience Forums know who we are.”

Mr Almond said the HSE had a role in emergency planning for COMAH [Control of Major Accident Hazard] sites. These are usually sites that store large volumes of chemicals or fuels. But he said “oil and gas sites are not generally COMAH sites so we will assist if we are approached”.

Asked if it had been approached recently, he said:

“Not to my knowledge”.

There are no public details of Cuadrilla’s emergency plan or the Lancashire LRF risk assessment for Preston New Road.

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Cuadrilla’s drilling rig being dismantled in advance of fracking, 27 July 2018. Photo: Ros Wills

Is regulation good enough?

Opponents of onshore oil and gas argue that current regulation of the industry would not prevent accidents or damage. They criticise what they say is inadequate resourcing of regulators, a lack of unannounced visits and what is described as the industry “marking its own homework”. So is this criticism fair?

Mr Almond said the wider onshore sector had demonstrated “a high level of control of major accident hazards”. There has been no formal enforcement on any recent wells drilled onshore and no prosecutions of onshore operators in the past 10 years, he said.

“I think the Health and Safety at Work Act, which brought the HSE into existence has played a large part in helping to make Great Britain, by and large, one of the safest places to work in the world. The regulations that we’ve got in place under the act, in lots of sectors including this one, have got a proven track record of being effective.

“We’ve got regulatory powers, so we can stop the operations if we needed to, we can prosecute or we can issue Improvement Notices, which are legal documents requiring the operator to manage the risks in a more appropriate way.”

What does the HSE regulate?

Mr Almond said the HSE gets involved when an oil or gas site operator is planning the design of the well. It ends when the site is no longer a workplace.

The operator must comply with two main sets of regulation:

  • The Borehole Sites and Operations Regulations 1995 This requires operators to notify the HSE about the design, construction and operation of wells and to produce a health and safety plan of how risks would be managed.
  • The Offshore Installations and Wells (Design and Construction etc) Regulations 1996 This requires the operator to ensure there are no unplanned releases of fluids from the well. The operator must also provide the HSE with regular reports of any activities on the well and appoint an independent well examiner to undertake regular assessments of well integrity.

Checking the operator

The HSE’s approach to an operator is shaped by the risk, Mr Almond said.

“the people who we were less confident in would be the ones that would get more site visits, they would get more scrutiny from our perspective.”

He said the HSE would meet the operator to build information on its level of competence, experience and health and safety record.

“We would ask to talk to the key people within their drilling team. We would look at what sort of qualifications they have got, where they have been before.

“We would then start to talk to the other regulators as well.

“we would maybe talk to the Environment Agency about that particular company and what their experience has been.”

“Our intervention plan, what we will do around a particular well or a particular operator, is based upon that intelligence – what the operator’s performance is, what their level of competency is – and then we would start to look at how complex the well they are designing and constructing is.”

Who’s who? Well examiners and inspectors

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Equipment delivery to Cuadrilla’s shale gas site at Preston New Road, 27 July 2018. Photo: Ros Wills

The regulations require an operator to employ a well examiner. They have experience in the industry and may look after several wells around the country. They don’t necessarily work on site.

Mr Almond said:

“There’s no requirement in the regulations that they must visit the sites, but they can do.

“Their role is to ensure that the well is being designed and constructed satisfactorily … from the design stage right through to decommissioning.

“They will look to ensure the right industry standards are being met, the operator’s own standards are being met and the regulations are being complied with.

“They’re not a regulator, more like quality control.”

The HSE inspects the well operator’s examination scheme “periodically” and interviews the well examiner, Mr Almond said.

The other key figure is the well inspector, who also has industry experience.

Unlike the well examiner, inspectors are employed by the HSE. Their role is to inspect the well notifications and the weekly operations reports sent to the HSE. They also meet well operators and carry out site inspections.

At the time of the interview, Mr Almond said the HSE employed 10 well inspectors for the UK’s onshore and offshore wells. There are about 250 onshore wells (source: UKOOG) and around 300 offshore installations (source: HSE/DECC 2016).

Mr Almond acknowledged:

“They’re not a big team, but it’s not our job to be on site all the time.

“The regime that we’ve got, the notifications, the operations reports, the scrutiny of each well at key points during the activity that’s taking place on it, what we do at the beginning and continue to do throughout with building intelligence about each of the operators gives us a level of assurance that these things are being done in the right way.”

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IGas shale gas site at Tinker Lane, Torworth, Nottinghamshire, 30 July 2018. Photo: Tinker Lane Protectors’ Camp

Site visits

The HSE is required to visit any site that will be hydraulically fractured, Mr Almond said.

The frequency of visits to all sites is based on an assessment of the operator (see Checking the operator) and the work programme.

Asked about operators in which the HSE had a lot of confidence, he said:

“It’s possible that they wouldn’t get a site visit very often, but they would get a site visit at some stage.”

Site visits are pre-planned and usually announced, Mr Almond said.

“Unless there was a good reason we wouldn’t turn up on a site unannounced and that’s because we want the right people to be available.”

HSE staff would also want to see particular operations or activity being carried out. He added:

“For us, site visits are important, but only important for how they fit in to our overall regulatory approach.”

“Marking their own homework”

That overall approach includes the notification of the well design, which the operator sends to the HSE.

“We scrutinise that in order to be content that the operator has got the design of the well right”, Mr Almond said.

During well construction, the operator also has to send weekly reports to the HSE, prompting accusations that the industry is self-regulated.

Mr Almond said:

“[The reports] contain information on how far they’ve drilled, how far they’ve cased, the drill fluid density of the well, what’s the weight of the mud so we can tell what the pressures are like. It’s a summary of all the activity on the well for that week.

“That comes in on an email on whatever day of the week is agreed and it allows the inspector to go back to the notification, and we can then say OK, this looks like it’s going on track or hang on a second, there’s something that’s not going according to plan here.  We need to go back and talk to them.

“When the inspector goes for a site visit, they will be verifying the onsite records to make sure they match with what we’re being told.

“If we had any doubt about the veracity of the information that was being supplied to us then we would take action.”

Transcript of DrillOrDrop interview with HSE energy policy team (pdf)

More interviews

This piece is part of a series of extended interviews by DrillOrDrop. You can catch up here with other interviews:

Ken Cronin, UK Onshore Oil and Gas

Lynn Calder, Ineos Upstream

Paul Foster, Barton Wilmore

Tom Pickering, Ineos Upstream

Right Reverend Graham Cray

Kevin Hollinrake MP

Balcombe interviews

48 replies »

  1. Good regulatory system. It has kept the N sea safe for decades in a very hazardous environment. The biggest risk there are the helicopters.

    No real issues with a shale gas well. Its not like its an overpressured H2S well like Deepwater Horizon (Macondo 1) . The well is as dead as a dodo until its fracked so no serious issues for any driller. Not that that will reassure the ‘we are going to die’ brigade…

    • Dream on Ken. A system which restricts itself to what goes on inside the site boundary is NO regulation. Only an idiot would think the issues here are related to HSE,s limited role and ex perience off shore . Just who do you think you are kidding, your comments are totally irresponsible nonsense.

      • Alan t

        The regulations governing well sites are not limited to those regulated by the HSE.

        But regulating the cause of an event ( such as a blowout ) is a good place to start. Prevention not a bad idea.
        But, should there be such an event then those working on the site would be the first affected, and also subject to the regulations. So the intelligent observer may wonder what is in place in the UK to prevent an event, before moving on to what the consequence of the event may be to those not working on the site?

        Those further away from the site are in less immediate danger, and, for emergencies, covered by the council and blue light ER plans.

        For continual emissions ( going over the fence ) check out what the EA does.

        The HSEx expertise also covers onshore drilling, COMAH sites, Mines, etc and is not specific to offshore drilling and the handling of Hydrocarbon risk.

      • Alan t
        Having now read the interview, happy to report that the HSE do not say that their system is restricted to what goes on inside the boundary. The inspector notes that ‘there are no geographical limits set down’.

        • Precisely why this non-story fails to achieve any credibility. Once again the antis shooting themselves in the feet by twisting the facts.

          • Not sure what facts are being twisted here R8 LMX.

            The idea behind this interview was to give an insight into how one of the regulators, HSE, view their role. Since it quotes Mr Almond extensively, and the full interview transcript (agreed with HSE) is available to read, it’s difficult to see how this piece lacks credibility.

            • Paul…you know perfectly well how DoD applies creative license when presenting pieces like this.

              The purpose of this piece is to create the impression that the HSE’s role is inadequate in relation to ensuring safety at O&G sites and their surroundings. Much focus is given to the notion that the site boundary is where the Health & Safety documentation and HSE’s remit may end, but Mr Almond states quite clearly that, “There are no geographical limits set down, so it’s a risk-based thing.” and “there is no set distance”.

              Allow me to adopt some similar creative license…I note on this site the claim that, “DrillOrDrop takes no money from advertising, industry, regulators or campaign groups.” yet I would suggest it’s impossible for you to know exactly who may be funding you and equally impossible for you to prove how clean any donations may be. Monies can easily be paid by proxy and you’d be none the wiser as to who the source donor is. I could even go as far as to say that “It’s possible that DoD is subsidised by Russian money”. You can’t rule it out and with a few carefully typed words, it is ruled in as a plausible possibility.

              • Well R8, Mr Almond’s quote “There are no geographical limits set down” is given plenty of prominence, coming high in the piece.

                There have been concerns from some local people about the state of emergency planning around oil and gas sites, so it seems perfectly reasonable to explore how HSE see their role in all this and where the responsibility of one regulator ends and another begins.

                As any project manager will tell you, having different people or agencies responsible for different stages of a process can cause problems, either because there is a “gap”, with each party thinking the other is responsible for a particular stage, or because of an overlap, where parties may take conflicting actions to manage an issue. The piece didn’t set out to prove there was a problem, but to explore with one regulator where they saw their responsibility ending.

                Regarding DrillOrDrop funding, I think you miss the point of our statement. We don’t knowingly take money from the sources listed, and therefore our output is not influenced in any way by the views of our very generous donors.

            • Paul…i think you missed the point…can you state categorically that none of the donations DoD has received have originated from Russia, irrespective of whether that be knowingly or otherwise? You can’t rule it out.

            • R8…i think you missed the point…that can be turned around with the same “smear fear logic”.

              Can you state categorically that none of the ohandgee investments the industry has received and is receiving, have originated from Russia, irrespective of whether that be knowingly or otherwise?

              You can’t rule it out.

              Its just the usual Novachok smear logic. Easy isnt it?

    • Just read what KatT has written Ken! Have ABSOLUTELY no faith in what the Government give the go-ahead for..we will NOT be safe..MONEY talks!

    • There are 8 times more fatal accidents in the US oil and gas industry than the national average for all other industries.

      Compare that to the UK the oil and gas industry which is the second safety working environment.

      I think the HSE are maybe getting something’s right.

    • YES, BUT KEN,

      Pressures of up to 15,000 PSI are used during the Fracking process.

      Ladies and Gentlemen as a comparison, your car tyre will probably have around 32 PSI pressure in it ( check your handbook.)

      NOW FOR THIS NEXT QUESTION you will need the assistance of your 5 year old grandchildren……. Where do you think the many Millions of gallons of Frack fluid will go when pumped underground at pressures up to 15,000 PSI ?????

      • Jack
        The frack fluid either stays in the shale or comes back out as return frack fluid says the 5 year old grandson.

        • NOW, NOW Hewes62

          You know as well as my 5 year old grandson that there is NO perfect piece of shale rock on this planet …..

          Weaknesses, impurities , fractures, varing densities and integral strengths of the rock ( gas bearing formation ) will ALL play a part in exactly where this Frack fluid will disperse when put under pressures of up to 15,000 PSI within the fracked rock .

          When you also consider that the laterals can extend UP TO 3000 metres, that’s 1.86 MILES …. No person, or fracking company on this planet can know exactly where those toxic Fracking chemicals will end up …..

          There is though one good thing for the Fracking companies , that is that no one else will also know where those toxic fluids have gone …..

          The toxic legacy will of course be left underground for future generations to deal with .

            • YES , hewes62,,

              I very much welcone the humour, alternative twist and firey debates that members both for, against and somewhere in the middle bring to the forum .

              It’s brings to life, what normally would be considered for many to be a dull topic.

              Please continue .

  2. A five minute search of the internet and you can find explosions and fires on fracking sites. Sadly several workers have died and others have been burned. Some of these sites are apparently close to dwellings and people report their homes shaking, many people have had to be evacuated (some for over a week) and plumes of thick back smoke can be seen in the air. So it looks to me there are plenty of risks for workers and residents near these sites.

    https://www.wsj.com/articles/oklahoma-blast-may-be-deadliest-since-start-of-u-s-shale-boom-

    1516735845https://stateimpact.npr.org/pennsylvania/

    https://uk.reuters.com/article/us-exxon-xto-natgas-ohio/exxons-xto-caps-leaking-ohio-gas-well-20-days-after-blowout-idUKKCN1GJ355

    • What’s a film of an oil well fire got to do with gas wells? You won’t get black smoke from a gas fire. If Cuadrilla get 50mmscfd from their well, it will be champagne corks exploding.

      • AI It states natural gas wells. Not oil wells, unless you have additional information? It could be diesel storage on site or other materials that have caught fire causing black smoke. So it would seem this is exactly the sort of incident that could occur.

        • Kat

          Belmont county ( lower example ) has the Utica Shale, which is liquids / condensate rich ( see energy in depth et al , or google Ohio Utica Shale Ethane ). This would produce a smokey fire as shown. So likewise the first picture I guess.

          However, the issue may be …..is this likely ( blowout rate ) and what were the affects outwith the site, allied to UK experience ( as noted in the interview with the HSE ), for an industry intending to supply us with something we use?

  3. [Edited by moderator]

    ….Will HSE step up to the mark and sort out Evacuation plans before Cuadrilla fracks at Preston New Road?….

    [Edited by moderator]

        • ‘without gas central heating this winter…’

          Their back again with their freezing pensioners and lights going out suggestions.

          That may be correct if the North sea disappeared, Norway was nuked, and all our modern state of the art LNG terminal workers couldn’t make it to work.

          Relax guys. Your boilers will fire up and the lights will not go out. We have a superb diverse range of supplies giving us excellent energy security.

          Not heard much about our reliance on Russian gas recently or Jim turning off the North sea taps. Maybe give it another go. It’s been awhile so maybe worth another round of preposterous nonsense to try and catch a few newcomers.

          • John your childish head in the sand we’ll never run out and the lights will always stay on…

            You do realise how short of gas we were during the Beast from the East period, and yes it was Russian LNG from Yamal into Milford Haven that helped us out.
            We have hardly any gas storage now rough is closed and we buy gas as and when we need it costing more as I’m sure you’ve experienced the hike in your energy bills…
            If you think we have excellent energy security why do we rely on Norway, Russia, Qatar, U.S.A, Holland etc etc for our energy needs?

    • Elaine
      The evacuation plan is owned by the Council and the emergency services, not the operator.
      Would you want Cuadrilla to turn up and evacuate you?
      Typically, the site operator inform the emergency services and the county plan is put into motion if required.
      This evacuation plan is generic.
      The HSE will know of that plan.

      Up to you guys as to why you do not know all this….it’s your council,

  4. We NEED to protest on mass and bring it to the attention of the Government in a much more PRO-ACTIVE way…WHO is with ME??!

    • Blue

      Better to email the council who have the ER plan into which the cuadrilla plan dovetails.
      If you ever get to see the plan, then it will inform you, not just for a potential event at a drilling site which may produce gas, but more actual risks within the county ( multiple car crashes, chemical spills, fuel station fires, warehouse fires etc etc ).

  5. Paula-try visiting a motorway service station and reading the hazard plates! Not as much fun as collecting train numbers, but you will spot quite a few.

    Some of them might just be lorries transporting cobalt for the “alternative” energy businesses. Or even “red” diesel on it’s way to a farm to assist in the production of our breakfast cereal.

    Not me, either, Blue.

  6. You decided to open with: “The risk of fire and explosion are our main concerns…”

    And you wonder why you struggle to secure interviews with anyone other than hardened antis….?

    • Jeff
      As I read it, the HSE were the first to say ‘fire and explosion’ which is indeed a major concern of theirs for drill site. However it may not be the highest risk due to low probability.

  7. LIVING IN THE SACRIFICE ZONE…… Airborne Pollution

    THE FACTS…………

    Pollutants from fracking could pose health risk to children, warn researchers

    https://www.theguardian.com/environment/2017/oct/25/pollutants-from-fracking-could-pose-health-risk-to-children-warn-researchers

    Doctors Release New Comprehensive Fracking Impacts Report & Deliver Over 100 Recent Studies to Governor Wolf

    http://concernedhealthny.org/category/press-releases/

    DO YOU LIVE IN A SACRIFICE ZONE AREA ???? ……….. Then this article from 27/08/2018 will be of interest to you,

    Air pollution causes ‘huge’ reduction in intelligence, study reveals

    https://amp.theguardian.com/environment/2018/aug/27/air-pollution-causes-huge-reduction-in-intelligence-study-reveals

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