New rules came into force today which could delay production from the Kimmeridge oil well at Angus Energy’s site at Brockham in Surrey.
An updated environmental permit, published this morning, requires more information on the management of any gas before production and appraisal can begin at the site near Dorking.
The new permit does not currently allow any use of acid at the site. There is also no permission for the reinjection of water into the rock formation, further drilling or any stimulation of the oil reservoir. The company must additionally update its site and procedures.
The Environment Agency (EA), which granted the permit, said it had imposed some of the controls because Angus Energy had not provided required information, despite several requests. The company had also failed to assess adequately some risks to groundwater and had not proposed appropriate techniques, the EA said.
The Brockham site had been operating under an old-style permit with more relaxed controls over activities and few requirements for monitoring. Some residents had described this as a regulatory loophole.
The process to transfer Brockham to a modern permit has been going on for about two years. DrillOrDrop reported last month on a petition calling for a stop to operations at Brockham until a modern permit had been granted.
Angus has said it expects to start appraisal and production within weeks from the sidetrack oil well drilled into Kimmeridge Clay formation at Brockham in 2017.
The EA said today it had decided to grant the permit before these new operations began. As a result, there would not be the usual public consultation carried out when it was “minded” to issue a permit.
The EA said:
“This will mean that the permit is issued in advance of these new activities commencing to ensure they are effectively controlled under the new conditions”.
The residents’ group, Brockham Oil Watch, said:
“We welcome the news that the Environment Agency issued this new permit, responding to our concerns, shared by many local councillors and thousands of people who have signed our petition.
“The EA acknowledged that they didn’t have the required controls over activities at Brockham, and with work on a new geological layer and using a new extraction process planned to start imminently, it seems that putting a new permit in place was the right course of action to impose better regulation and monitoring.
“But, one might ask why the sudden haste, and why has the EA not issued the new permit (or a draft of it) before now, when they’ve been working on it for the better part of two years, and why do they now have to abandon the usual public consultation on a draft of it?”
The group said it was relieved that reinjection of water would no longer be allowed at Brockham. It added:
“There are a number of conditions that the operator needs to fulfil before they can start the new work, including additional assessments of emissions to air and detailed proposals on the use of acid and other chemicals.
“We will be following this process closely. In the meantime, we have started our own air monitoring regime and collected surface and groundwater samples to establish baseline environmental data before work on the unconventional Kimmeridge shale and micrite layers begins. “
DrillOrDrop invited Angus Energy to comment. This report will be updated with any response. The company tweeted on 27 November 2018:
“New EA Permit for Brockham orderly process and transition with the EA. We are compliant with all the new requirements from the EA. Always in communication with our regulators”.
New controls at Brockham
The EA has imposed three conditions which must be met before certain operations can begin production at Brockham. There are also nine improvement conditions on the site and how it is operated, as well as requirements for monitoring and reporting.
Angus is not permitted to begin appraisal or production activities from the Kimmeridge Clay formation at Brockham until it has provided details of how it would deal with any gas produced along with the oil.
The company wants to generate electricity from the gas using an engine on the site. In an emergency, the gas could be burned briefly in a flare before the well was shut down.
But the EA said the level of detail on equipment and procedures provided by Angus was “insufficient” and the company had not complied with requests for more information.
A pre-operational condition in the new permit requires Angus to provide an updated gas management plan one month before the start of appraisal and production.
This would include an assessment of all air emissions from the site, including new proposed equipment, and a full list of emergency situations in which the flare could be used.
Use of acid
The possible use of acid at Brockham had concerned some local residents. The petition called for full disclosure of the type and quantity of acids.
Acid may be used to open or create fractures in surrounding rocks, known as matrix acidisation and acid fracturing. At Brockham, Angus Energy did not apply for consent to do this and the EA said these operations were not included in the permit. If the company wanted to carry out these activities it must apply for a variation to the permit.
Acid may also be used to clean a well, called an acid wash, before production begins. This process is often regarded by the Environment Agency as a minor operation, with no risk to groundwater, and is excluded from the controls in a permit.
But at Brockham, the EA said “insufficient and inadequate information” had been provided in the application on acid washing for it to decide that the operation did not need to be controlled.
The company had said:
“There are no plans to acid wash, unless the wells unless (sic) they do not flow, and hence the volume of acid required has not been calculated”.
But according to the EA, Angus Energy had “not fully comprehended the risk to the groundwater” of the process. The EA concluded:
“We are therefore not satisfied that the information submitted allows us to determine that there is an exclusion from the definition of groundwater activity.”
The EA said acid wash could not be carried out until a pre-operational condition had been met. This requires Angus Energy to provide information on why it wants to carry out the operation, the rock formation it would be used in, the volume, concentration and details of chemicals, their material safety data sheets and the frequency of the operation.
Angus also failed to provide enough detail about another pre-production technique, known as hot oiling, the EA said. This involves heating crude oil and circulate it between the production casing and the well tubing to clean any deposits. The company must also provide the required information on this technique before it can be carried out, the EA said.
Data from the Oil & Gas Authority confirms that since April 2018 Angus Energy has been disposing of the water that is produced along with hydrocarbons using a reinjection well at Brockham.
The company applied to continue reinjecting this produced water into the Portland Sand formation at Brockham through the reinjection well, known as BRX3.
But the EA said the reinjection techniques proposed by Angus Energy were not appropriate and the company had not provided enough information about the integrity of the reinjection well.
The EA said Angus Energy was not proposing to install groundwater monitoring boreholes or carry out groundwater monitoring at Brockham. The regulator therefore needed information to be sure that the produced water could not get into groundwater through well integrity failures. It also wanted assurances that the process would be monitored correctly.
This information had not been provided, the EA said. It checked with the Health and Safety Executive and this agency identified further concerns. The EA concluded:
“the operating procedures for the Brockham site are not up to the required standard. They lack appropriate detail, do not demonstrate that appropriate management systems are in place and do not clearly show procedures that demonstrate that the integrity of the well is being maintained and the reinjection of fluids is behaving in the manner it is expected to during and post every re-injection event.”
“We are not satisfied that the risks to groundwater have adequately been assessed and the proposed activities are not likely to have an adverse impact on the hydrological features in this area.”
As a result, the EA added:
“No groundwater activity is allowed in the new environmental permit for this site. Any subsequent proposals for a groundwater activity to re-inject produced water will require the applicant to apply for a variation to their environmental permit.”
The EA has required Angus to meet nine improvement conditions, with deadlines ranging from 22 December 2018 to August 2019. These include:
- Improvements to the containment bunds around the site
- Site condition report
- Leak detection and repair plan
- Gas management improvement plan to reduce emissions
- Surface water management plan
Monitoring and reporting
Under the new permit, Angus Energy is required to monitor the ratio of gas to oil recovered, the volume of gas fed to the generator and the use of the emergency flare.
The company is required to report emissions to air and surface water, the results of surface water monitoring, the gas feed rate to the flare and the findings of process monitoring.
Updated 27/11/2018 to include tweet from Angus Energy