Regulation

Angus faces new controls over gas, acid and reinjection at Brockham oil site

Brockham well Brockham Protection Site

Drilling at Brockham in 2017. Photo: Brockham Protection Camp

Updated  27/11/2018

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”.

Brockham night working Brockham Protection Camp

Night working on the Brockham sidetrack, January 2017. Photo: Brockham Protection Camp

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”.

181127 Angus Energy tweet

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.

Managing gas

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.

brockham-170109-8-jon-ohouston

Deliveries to the Brockham oil site in January 2017. Photo: Jon O’Houston

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.

Brockham lorry 2 Brockham Protection Camp

Photo: Brockham Protection Camp

Water reinjection

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.”

It said:

“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.”

Improvement conditions

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.

Links

Notice of permit for Brockham oil site

Decision document on the environmental permit for the Brockham oil site

Permit details for the Brockham oil site

Updated 27/11/2018 to include tweet from Angus Energy

 

 

 

58 replies »

  1. I thought that there was no regulation in the UK, as claimed by protesters everywhere. ‘Gold Standards regulations?? Ha ha ha’ is a constant protester theme.

    It would appear that these regulations are in place and are being enforced. Same as at Markwells Wood. Permission was denied due to an inadequate water management plan. So why do protesters go on about a lack of regulation?

    • It’s much like them claiming the countryside will be littered with thousands of O&G wells, whilst at the same time claiming there’s no oil or gas to be recovered.

      Or claiming that O&G sites are secret burial sites for radioactive waste.

      Or calling out the fire brigade for rainwater running off the back of a lorry, claiming it was a toxic leak.

      Totally ‘kin clueless and forever clutching at straws.

    • Yes, Anon; it seems the protestors concerns have been listened to; no protestors, no upgrade; well done to the protestors 🙂

        • Glad you like it, we are all happy then. Yay!
          Well done to BOW for the sustained pressure.
          Now, which other sites need upgraded permits?

    • It’s perhaps not surprising that the report you link to has “no issues and no problems”, as it is labelled Advertorial, so presumably paid for by Angus, who will therefore have a say in the article’s content.

      • Paul, at it again. I appreciate this site is biased anti but please if you are moderating comments great but you are not a poster… It weakens the anti argument when you chip in…

        • That mirror playing up again kish? Yet another loose sock puppet it seems? It weakens the anti anti argument when you chip in…..

      • How can anyone believe a thing that Angus say? Track record isn’t good, still haven’t heard what happened with Tideswell dodgy dealings, how can punters keep putting cash into this Micky Mouse company? Coming up on 2 years since the disputed drilling of BRx4z, the one that was promised to be in production by March 2017.

      • Hi Paul Seaman, the post subject appears to indicate that what is being imposed upon Angus at Brockham by the EA, is the “new style” permission, or is there yet another type?

        And why was that not a blanket imposed permission to be complied with today in all possible conditions, and not this long 10 month “comply or else” get out of jail free permission that is not permission at all, and that may not even be achieved even then if there is non compliance?

        But what is being said by the EA is that there is a rolling requirement to comply at various stages from 22nd December 2018 to August 2019? That is not permission granted is it? It is some sort of non compliance intermediate stage.

        What appears to be being stated, is more of a “comply or else” warning to Angus, that a new style permission must be achieved in all its respects by August 2019, and is not a permission as such at all yet, nor will it be for 10 months or so, depending, one assumes of whether, or if, Angus actually complies to these staged conditions in time or not as the case may well be? And what will the compliance term be before permissions are withdrawn one wonders? More months? Years? Never?

        We have always assumed that these new style permissions were just that, immediate compliance on threat of withdrawal of permission?

        Do you have any information on how many other sites are still operating under the old permission, and how many are in this, intermediate stage that doesn’t require compliance until some much later date?

        Are any sites fully compliant?

        How many are not?

        • Dear Phil. Thanks for your comment.Earlier this year, the Environment Agency told DrillOrDrop there were 38 oil and gas sites operating under old style permits (https://drillordrop.com/2018/06/14/residents-uncover-regulatory-loophole-at-surrey-oil-site/). Under the old style permit at Brockham, the operator was not required to collect or maintain details about well stimulation or fluid reinjection and there were no restrictions on how much acid could be used in a well and at what concentration. The Environment Agency began updating permits on existing oil and gas sites in 2013 and it appears that the process is nearing completion. Under the new permit at Brockham, the operator has to comply with three pre-operational conditions (relevant operations cannot be carried out until the conditions are complied with) and nine improvement conditions with varying deadlines. Some of the improvement conditions appear to be more urgent than others – the containment bund condition has to be met within a month – and some are likely to need more time. From what I have seen, the conditions in the updated permits vary from site to site, depending on operations and the site condition. I hope this helps.

          • Thanks Ruth, yes it does help, and thank you for replying.

            I do wonder if there are any penalties to be applied to operators such as Angus in the event of non compliance or failure to meet the rolling compliance targets of the new style permissions? And also how many other sites of the 38 are now, or soon will be, in the same 10 month rolling compliance situation so to speak? One would assume that it is all of them?

            I suspect as i said before, that we had all naturally assumed that compliance was an immediate requirement on the day 1 condition and only compliance is subject to achieving those conditions and hence the permissions.

            A 10 months rolling conditions requirement is much much longer than either i had anticipated or i suspect others had expected from the new style permissions and is still in effect no better than the old style permissions until compliance is achieved, and therefore cannot be considered permissions yet as such, regardless of today’s notification, until in this case at least, full compliance is achieved and operational?

            It would perhaps be of great interest to those who have expressed an interest, such as Brockham Oil Watch, and others to see such compliance or otherwise displayed by the EA as soon as deadlines come and go, so that we might see just how well the new style permissions are operating in defined limits,

            The new style permission can only presumably be only be granted in the 10 respective months per 38 sites.

            Or not? As the case may be?

  2. Fake News Ruth Hayhurst.Non biased journalism .Pull the other one This Will Not delay production in Next weeks .BOOM

    • Another fracking industry Paunch and Judith sock puppet that needs a good detergent scrubbing, there is always one loose sock isn’t there?

    • Rubbish, those who criticise DoD should remember where Angus’s failings were reported this time 2 years ago, you deniers said the same thing then. I would be asking questions of Angus if I were losing so much of my investment, not just coming here to cry over it. Merry Christmas 🤶

    • But not the use of Winchester repeating rifles liberated by the local protesters in defence of their village?

      Angus last stand perhaps?

      Two Cheyenne women asserted they had pierced George Custer’s ears with knitting needles so he could hear better in the afterlife.

      The Greasy Grass Guardian.

      Perhaps Angus would benefit from an extra pair of knitted ears before such a procedure becomes an urgent necessity?

  3. I’ve given up reading them, Judith-except when I get extremely bored, which is not that often. When the antis suggest the intellectual capacity of their own group in such a way, it is rather revealing.

    • But you do read them Martin, we established that a long time ago, in spite of denials and prevarications, but maybe your failing intellectual capability is not up to such an act of extreme effort any more martin?

      As for your own “contributions” lets look at this one shall we?

      “It’s okay folks. The new permit precludes the use of arrows”–The Little Big Horn Gazette.”

      Well that was a monumental intellectual edifice to be treasured wasnt it? Do you want me to quote more of your “contributions” to illustrate my point?

      i think that would be insulting to Ruth and Paul wouldnt it? That does seem to be your most intellectually mind strethcing pursuit effort so far?

      Awww, sad!

    • Martin – but that won’t satisfy the antis. They won’t be happy until all the oil and gas production in the UK is stopped and were buying all of our hydrocarbons from Qatar and Russia

    • Of course martin, Angus are still avoiding providing sufficient information and have no requirement to do so until the EA has required Angus to meet nine improvement conditions, with deadlines ranging from 22 December 2018 to August 2019.

      Are we meant to assume that this a “new style” permit? Or are the EA just a tightening up of requirements because Angus failed to produce any sufficient information?

      • Phil…as you know, the EA have been seeking to introduce new permits across multiple sites for several years. You campaigned for them to implement such protocols and they are doing so. You claim ANGS are “avoiding” providing information whereas it’s crystal clear for everyone else that ANGS WILL be providing the requisite information in order to proceed with their planned schedule of works.

        I know how much it aggravates you to see companies comply with the very standards you’ve asked them to…but maybe it’s time to accept the compliance, as is assessed by regulatory bodies

        [edited by moderator]

            • Ooh! Was that Martian wit? Or Martin wit?

              No wonder they are extinct?

              Deeper than the deepest ocean,

              Wider than the sky

              Warmer than the warmest sunshine

              Softer than a sigh

              Brighter than the brightest star

              That shines every night above

              And there is nothing in this world

              That can ever change my love

              For Martian sock puppets

  4. The Environment Agency has issued new modern permits to Angus Energy plc for production at its Brockham site in Surrey.
    The new permits bring the site into line with the current regulations for oil and gas sites to provide a high level of protection to the environment. This is part of the Environment Agency’s review of all oil and gas permits granted prior to October 2013.

    https://www.gov.uk/government/news/environment-agency-issues-brockham-oil-site-permits

    • Not for 10 months will the conditions be applied on a rolling monthly requirement John. The EA has required Angus to meet nine improvement conditions, with deadlines ranging from 22 December 2018 to August 2019.

      That is not permission, that is a conditional requirement that has a gradual status dependant upon a staged compliance and even then, if the stages are not completed, then those stages will presumeably be delayed until such conditions are complied with?

      There is also no information on penalties or sanctions dependent upon those compliance conditions.

      That is quite clear, a putative label of a new style permission does not imply compliance of the rolling conditions until such time as such compliances are completed and operational.

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