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. It’s far more likely that these requirements were known about by the company (they have of course been in liaison with all relevant bodies), are being catered for, and there is no further delay from their intended operations.

    Good ol’ DoD spin…

    • “they have of course been in liaison with all relevant bodies”? Really??
      So how come the EA says Angus Energy had “not provided required information, despite several requests”?

      • Read ALL the documentation again and you will see they have been in communication with the relevant bodies.

        This non-story is DoD yet again trying to put a spin on things to suit their crumbling anti O&G propaganda campaign.

        EA permit issued with pre-conditions, as is very normal for O&G sites.

        Water re-injection pertaining to the Portland is neither here nor there. It’s dry oil in the Kimmeridge that they are targeting for the upcoming phase of work – the same dry oil that is flowing freely at Horse Hill.

  2. Angus Energy epic fail, how can anyone have faith in a company with such a bad track record? I guess they won’t be doing anything anytime soon.

  3. DoD – all you need to compete with the Express is a few more capital letters in your headlines. Why not try “Angus faces new CONTROLS over GAS, acid and reinjection at Brockham OIL SITE”

  4. I seem to remember Paul Vonk and the other fella who shall remain nameless saying back in 2017 “We / Angus have all permits and licences ” Seems kinda familiar ? Maybe they can sue the EA when they get round to suing SCC 😀

    • Jono…they had an EA permit before and they have one now. Maybe you don’t understand what, “We are now in a position to issue the new environmental permit….we have taken the decision to issue the permit now” means?

      I realise you’re getting all worked up about it, but the reality is that pre-conditions are quite normal and regularly met by O&G companies. Just as they were at Balcombe, they will be met at Brockham (and certainly won’t be ‘news’ to the operator).

      Total straw-clutching, non-story and attempt by the dwindling minority to stir up excitement where none is needed.

  5. I think I’ve missed something – are people really worried about sending weak acid down a borehole? Should I be worried about putting vinegar on my chips?

    • As long as your chips are not cooked in lard i.e. Vegan – you will be okay on this BB to add Vinegar……But please give up drinking water, using household cleaners, don’t buy any PVC products, no swimming in pools, no leather, no additives like fructose, citric acid and hydrolyzed vegetable protein, and of course please don’t digest your food…….

  6. Another sensational headline which means absolutely nothing in the overall scheme of things but it fools the gullible into believing they have achieved something

    • What utter dangerous rubbish you lot do speak.

      Look up hydrofluoric acid and its requirement for extreme chemical protection procedures if you think it is so safe.

      It is not.

      You should be very worried about putting hydrofluoric acid on your chips, I would not recommend such a suicidal notion.

      Result:

      No chips…..

      No fingers…..

      and…..

      No stomach.

      Don’t try this at home folks and don’t let anyone else force you to allow the mere hint of one of the worst caustic acids under your home either.

      Vinegar indeed?

      What utter bilge.

      • Phil C – But normally it’s 10-15% HCl that is used, which reacts with carbonates extremely quickly. HF is generally not preferred as it will react with carbonates to produce insoluble minerals such as fluorspar, which clog up the pore spaces and reduce flow rates. Anyhow, don’t let little things such as facts get in the way of your scare stories

        • If you want to put hydrofluoric acid on your chips Judith, that is your look out, but i would stress again, that i would not recommend such a suicidal insanity. I would also suggest if you do succumb to such an uncontrollable irrational and terminal urge, that you ring the ambulance first, they should reach you in a couple of days, by which time the result would be a large bubbling puddle, and perhaps it might also be necessary to contact the local men in white coats to bring one of those little jackets without sleeves?

          Are such activities common place on Mars? Perhaps that would explain the state of the place wouldn’t it? How is Elvis by the way? Still dead?

          • Phil – I think I wrote hydrochloric not HF. A 10% HCl solution is pretty tame – I regularly used to spill it on my hands without any problems. After a few seconds in contact with CaCO3 then it’s pH would reduce close to neutral and the solution would simply be composed of CaCl2 – i’ve never eaten that – maybe it would be an improvement to NaCl

            • What you do, or imbibe, in the privacy of your Martian home is your concern Judith, however i would not recommend such an action to anyone reading this.

              Also as for what is done here and at Brockham and elsewhere, under the guise of “old permissions” without any requirement for keeping records or even notification of what is being done, then that is very much our concern. This attitude of “nothing to see here, move along please” is simply not acceptable nor appreciated, it is clearly an attempted whitewash by the anti anti Paunch and Judith sock puppets.

              You may want to read this Drill Or Drop report of 14th June 2018, and i don’t want to see any disingenuous and insulting remarks about Ruth and Paul at Drill or Drop, that is unacceptable, it is rude and insulting and you should know better.

              (apologies for the extract Ruth and Paul, but as you see, it is necessary)

              https://drillordrop.com/2018/06/14/residents-uncover-regulatory-loophole-at-surrey-oil-site/

              “A resident’s group in Surrey has discovered a loophole in oil and gas regulations that allow some wells to be stimulated or used for reinjection without specific controls.

              Brockham Oil Watch uncovered the regulatory gap when it put a series of questions about its local drilling site to the Environment Agency.

              During the correspondence, it emerged that the site at Brockham near Dorking, operated by Angus Energy, was still using an old-style environmental permit.

              Despite frequent government claims that the UK has a world class regulatory system, the EA said that under the old environmental permits, operators were not required to collect or maintain details on well stimulation or fluid reinjection.

              The old permit also has no restrictions on how much acid could be used in a well and at what concentration. Nor does it require air or groundwater monitoring.

              The Environment Agency (EA) began updating permits for existing oil and gas sites in 2013 and the process is still underway. The EA told DrillOrDrop there were still 38 old style permits in place. They are part of the review, which is due to be completed by the end of summer 2018, the EA said.

              At Brockham, there was a public consultation in July 2017 on the company’s application for a new style permit. Since then, the EA has asked Angus Energy for more information, with a deadline of last week. The requested information included answers to whether stimulation was proposed at the site and what fluids would be reinjected.

              Any final decision on the new permit would be made only after all the outstanding information had been submitted and assessed and after a further public consultation.

              A spokesperson for Brockham Oil Watch said:

              “We have worked closely with the EA over the past year. We appreciate their openness and taking our concerns seriously. They are working hard, regulating and monitoring multiple sites, and working on areas other than oil & gas as well. They can only operate within the remits of the regulatory framework and that’s why we feel the loopholes in the framework need to be highlighted and hopefully closed.”

              The group said:

              “Until the new permit is in place, the site operates under the old-style permit.

              “This means that Angus can carry out stimulation (with acid or hydraulic fracturing) so long as the volumes of fluids injected are below the levels specified as associated hydraulic fracturing in the Infrastructure Act 2015, and they will not even need to notify the EA of what they are doing.

              “This is all the more worrying because there is no groundwater monitoring in place at the moment, even though it will be required going forward because of the risk of pollution from re-injection.

              “There is no air quality monitoring in place either, but this will also be required as part of the new permit.

              “Until then, monitoring of site activities can only be carried out via site inspections and verbal interaction with Angus staff.”

              The group added:

              “Given the track record of Angus Energy, we are very concerned about this.”

              So you see there are no conditions as to concentration or use of what ever acid Angus intend to use, without restriction records or notification

              “This means that Angus can carry out stimulation (with acid or hydraulic fracturing) so long as the volumes of fluids injected are below the levels specified as associated hydraulic fracturing in the Infrastructure Act 2015, and they will not even need to notify the EA of what they are doing.

              Volumes, you will note, not concentration or type of acid are prescribed, so i am afraid to say, concentrations or types of acid are no where restricted at Brockham.

              I suggest you anti antis curtail the present rude disingenuous and insulting tirade against Ruth and Paul at Drill or Drop, or i might forget to pull my verbal Punches….or Judiths for that matter?

            • Phil C – it just seems like typical nit-picking from DoD. In terms of HSE, it doesn’t matter if it’s a new or old permit – drilling operations such as these are about as risk-free as its possible to get. The only people who seem to have an issue with them are people who’s views on fracking have been formed and who now suffer from confirmation bias.

            • Yes it does.and you are still being rude to Ruth and Paul at Drill or Drop.

              “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”.

              “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”

              Not required to comply until 22nd December to August 2019 and still no requirement to specify type or concentration of acids in any combination.

              “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”.

              Angus are still avoiding the question it seems.

              Again, volume is mentioned, but not type or concentration, that is plain for all to see.

            • “what do you not understand about acid wash not being the slightest bit hazardous?”

              Prevarication wont make it go away Judith. What is this last worditis?

              What is it about the words

              DANGER ACID

              CAUSTIC

              That do you not understand Judith? Your suggestion that it is no more dangerous than putting vinegar on your chips is totally irresponsible and you know it.

              Your words, not mine.

              I would urge everyone else that such a failure to appreciate the dangers of acids would be rather rapidly suicidal.

              Don’t you have a duty to all here to stress the dangers of handling acids and not make silly comments about chips?

              I dont know about Martian physiology though Judith, maybe Elvis can help you?

              On Earth we are a bit more careful.

              Perhaps that was why Elvis died on the crapper?

              Acid on his chips?

            • Phil C – you antis are apparently good at research so why not just do a bit of background reading about the reaction kinetics of HCl with carbonates and then tell us how long such solutions are likely to stay caustic for.

            • Still prevaricating?

              If you anti antis are so good at research, go do your own and try not to make totally irresponsible rubbish comments about acid being no worse than vinegar on chips.

              Still no last word?

              Awww dear, shame?

  7. Dear me i see the entire Paunch and Judith show sock puppet gang has escaped from the bottom of the wash basket again making such an ugly noise?

    Its the strong bleach and the heavy duty wash cycle again isnt it.

    They cant expect to come on DoD being so rude and being so disengenuous like that?

    No manners or gratitude it seems? I dont know what the frackers were brought up on, there will be tears before bed time.

    In they go with a dose of the strongest detergent, to wash their silly little puppet mouths out. Round and round they go, what comes out no one will know? Just a few bare threads i suspect?

    That’s the way to do it!

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