Regulation

Regulators accused of “extraordinary hands-off” approach to South Downs oil well

Markwells Wood 5 Ann Stewart

Markwells Wood site before the start of decommissioning. Photo: Ann Stewart

An oil exploration well in one of the most sensitive parts of the country has lacked scrutiny because of legal loopholes.

The site at Markwells Wood is in an area of the South Downs National Park that feeds springs which supply drinking water to Portsmouth.

Local people have discovered that drilling fluid was lost during well construction in 2010. They also commissioned a report which showed that pollutants could travel rapidly underground through chalk channels to the springs.

But Markwells Wood was drilled before onshore oil and gas wells required an environmental permit. This means the Environment Agency (EA) has had no responsibility for on-site monitoring and regulation of operations.

The site is now being decommissioned and the lack of a permit means the EA has no role in that process either.

Responsibility has passed instead to the Health and Safety Executive (HSE) but this will last only until the site stops being a workplace. Then no regulator will, apparently, check what happens.

The community group, Markwells Wood Watch, told DrillOrDrop:

“We are astounded that this major operation of decommissioning in such an environmentally-sensitive location can take place with so little scrutiny. An independent well integrity test, prior to plugging, is the minimum that the community would expect to have been carried out.”

Group member, Michael Harbour, who has investigated the role of the regulators at Markwells Wood, said:

“It seems extraordinary that, despite the significant loss of drilling fluids and an independent hydrogeological report that pointed to the vulnerability of the aquifer beneath Markwells Wood, the EA and the HSE adopted a ‘hands off’ approach. No on-site monitoring, no analysis of well stimulation methods and no proper risk assessment of the vulnerability of the hydrogeological zone were carried out by either the EA or the HSE.

“The criteria for plugging and abandoning wells may be of the highest standard, but without on-site supervision there is no guarantee that the work will be completed satisfactorily. Should it be done badly, and pollutants enter the water supply, the damage could be irreversible.”

Markwells Wood Watch has called for permit regulations introduced in 2013, which post-date drilling the Markwells Wood well, to be applied immediately to all older onshore oil and gas sites. It also said site inspections should be conducted during all phases of operations.

The group said there should be “meaningful collaboration” between the regulators. Local planning authorities should also require financial security for decommissioning and aftercare of wells to avoid taxpayers having to fund clean-ups if an operator went out of business.

Investigations reveal regulatory loopholes

Through a series of questions to the EA and HSE, Markwells Wood Watch uncovered legal loopholes that have left the well largely unregulated.

No permit

The EA told Markwells Wood Watch:

“The EA were never in receipt of an application for a Permit for this site.”

No site visits

Asked whether the EA had visited Markwells Wood, the agency said:

“As this well was drilled prior to 2013, this information was not a requirement and as a result we do not hold any information on this.”

No monitoring

Asked about whether there would be monitoring of the site after abandonment, the EA told Markwells Wood Watch:

“As an application was never made, we did not issue a Permit. As no Permit is in place for this site, we have no monitoring requirements or parameters to monitor against. The only potential permitting implications would be if the Operator were carrying out a groundwater activity during this process. We have requested and received information and have assessed it accordingly and have deemed that no groundwater activities are taking place and a Groundwater Permit will not be required.”

Michael Harbour said:

“It is unacceptable that the EA has relied on the operator to confirm that there was no groundwater activity in the decommissioning of the well. There could have been contaminants on or around the membrane that covered the surface of the site, as a result of the drilling works or from the storage and transport of hazardous wastewater, which could have leached into the soil.”

No EA role in decommissioning

Usually, operators have to demonstrate to the EA that a site has been decommissioned safely and returned to its original condition. The EA will not allow an operator to surrender its environmental permit until it is satisfied that the well has been decommissioned according to requirements and that no pollution has occurred.

On decommissioning at Markwells Wood, the EA said:

“A permit was never issued by the EA for the Markwells Wood site and therefore we do not have any regulatory remit for it.

“As a result, the plugging and abandonment of this site will fall under the regulatory remit of the Health and Safety Executive.”

The EA added:

“We have not received any formal notification from UKOG as to the activities at the site.

“The decommissioning and plugging and abandonment activities of the well will fall under the remit of the HSE who will assess any programme of works proposals and assessments of the integrity of the well. Any Planning requirements/conditions will fall to the Local Planning Authority to control.  This may include the reinstatement of the site.

“As the site was never granted a Permit, the EA have no provisions to inspect the decommissioning/monitoring of any plugging and abandonment activities.”

Markwells Wood Watch criticised the regulators for “a rigid bureaucratic approach to their roles” and questioned why the EA had not been prepared to consider extraordinary permitting.

The EA said it had issued a Regulatory Permission Statement for decommissioning oil and gas wells drilled onshore before 2013. This required operators to, among other things, “make sure there’s no evidence of pollution”. Operators must also not carry out a groundwater activity, cause risk to water, air, soil, plants or animals, cause a nuisance from noise or smells, or “adversely affect the countryside or places of special interest”.

Markwells Wood Watch said the permission statement offered “no assurance that proper standards were being met” because the EA relied on operators to confirm that they had complied.

 

 

Questions to the HSE

Markwells Wood Watch also put a series of questions to the HSE about its responsibilities for the oil site.

The HSE and EA produced a Memorandum of Understanding in 2000 to ensure regulation of sites and processes were coordinated. In 2012, they produced a joined policy statement called Working together to regulate unconventional oil and gas developments.

Markwells Wood Watch said the responses to its questions suggested that the two regulators had not worked closely at Markwells Wood.

Work place only

The HSE confirmed in response to a Freedom of Information request the limits of its responsibility:

“Once the abandonment process is complete and the site ceases to be a workplace HSE has no further jurisdiction (or vires) to regulate.” source

No remit

In response to questions on post-abandon monitoring, legacy plans, risks to the chalk aquifer and contingency if UKOG went out of business, the HSE said

“This is not within HSE’s remit” source

No inspections

The HSE confirmed

“HSE has no records of any site monitoring or inspections of the Markwells Wood-1 and Horndean well sites [a neighbouring oil site] carried out by us” source

No risk assessments

Asked about risk assessments, the HSE said:

HSE had “not conducted any risk assessments regarding well integrity at any of the wells at the Horndean, Singleton and Markwells Wood. HSE does not carry out risk assessments on behalf of operators, but may inspect assessments carried out by them” source

No details

The HSE also told Markwells Wood Watch it could not provide information on well stimulation, the process to improve the flow of a well, or the independent well examiner for the site:

“HSE does not hold any data or details of the well stimulation methods used at Markwells Wood or Horndean with regard to well operations.” Source

And

“Under regulation 18 of DCR it is the well operator’s duty to make arrangements for the examination of the well by an independent and competent person. There is no duty placed on the well operator to provide HSE with the name of that person and this information is not held by HSE.” Source

 

 

“Risk of severe consequences”

Markwells Wood was drilled and operated by Northern Petroleum until 2014. The current operator, UK Oil & Gas, has provided notifications to the HSE of its intention to decommission the site. But Markwells Wood Watch said the company had not informed the EA, South Downs National Park Authority (the local minerals authority) or local people – nor was it required to do so.

The National Park Authority has required no financial security for restoration and aftercare of Markwells Wood in case the operator becomes unable to restore the site.

Michael Harbour said:

“In the long term there is an issue about who will monitor the integrity of orphaned wells in the UK. Under current legislation there are many such sites that fall outside the remit of the EA and that pose potential risks to the environment.

“All organisations develop their own cultures – ‘how we do things here’ – some good and some bad. Without independent challenge and scrutiny bad practice can become the norm.

“Our investigations at Markwells Wood revealed that the regulators (EA and the HSE) relied on the operators to self- monitor and to report that they had complied with all regulations concerning well design, operation and decommissioning.

“We find this to be unsatisfactory. Such a system would not be tolerated in the inspection of schools or hospitals and should not be accepted in the minerals industry where poor workmanship could result in severe consequences for public health and for the environment.”

32 replies »

  1. Shambles ” Without independent challenge and scrutiny bad practice can become the norm” These companies are running on fumes , if they had to do things properly it wouldn’t be profitable.

  2. No indication that they are not doing things properly. Plenty of wells drilled and then land re-instated in the UK before 2013 without any issues.

    All based upon speculation.

    Surely there is something a little stronger to keep excitement going over the weekend? Why not actually look at the recent RNS from UKOG? Oh, sorry-it actually showed something the antis had previously speculated wouldn’t happen. Can’t have that identified.

    Reality V speculation. Interesting which takes precedence.

    • You obviously do not live within a few hundred metres of the South Downs National Park like we do and you clearly have no regard for the water quality of the millions who live within the South Downs catchment area. Banging on about Venezuela when the truth about “gold standard regulation in the UK for over a century” is laid bare.
      You really don’t like people in this country do you?

      • Don’t I?

        You really don’t know what you are commenting about, do you?

        But, maintaining some reality-please inform me of any water quality issues from any of the oil wells around the South Downs. For example-a real one, not some sort of fabrication-last time I looked the trout and salmon were still enjoying one of the world’s most pristine and “gold standard” rivers at Stockbridge. Oh, and down the other end of the river, Fawley Oil Refinery helps to clean the water in the Solent assisting the salmon on their way to spawn. Wytch Farm, Europes largest on shore oil field, has had no issues and has been largely admired and appreciated by its neighbours over many years and is used as an example of how industry and the environment can co-exist synergistically by certain Universities.
        You will find many water quality issues recorded due to agricultural around the South Downs, but you will struggle to find any to do with oil exploration. If you want to see a real water quality issue reference oil, try Giggling Torrey Canyon. Your comments would indicate you are willing to see more of that to “protect” your own back yard. But, I shouldn’t bang on about importing/transporting oil because that has to be removed from sight as it is inconvenient to the antis. (Fortunately Venezuela is not on the UK shopping list as we can get plenty of oil from US fracking-currently 372k barrels per day! Netherlands 425k per day! A lot of potential there for Torrey Canyon repeats, and a nice bit of tax income for Donald. Good job some of the other financial benefits in US are being invested in HUNDREDS of new chemical plants being built to replace older, more polluting ones.)

        I like many of the people in this country, but those who speculate and fabricate to further their own agendas I am not so keen on, whether in this country or elsewhere. Fortunately, that means I have the majority to befriend!

          • Good for them, John. Hope that if within the SCC catchment area they do not find their council tax rises dramatically to compensate for revenue from local business being constrained.

            A bit more connected than living in France and writing about there being no oil able to be extracted from the Weald!

            But, to make them feel welcome and safe, I can let them know I have spread loads of muck (literally) on the South Downs and no water polluted, and without supervision from the EA. However, like many in that area they may find their water is not of a quality that does not require treatment-more water softening treatment installations than most other parts of the country.

            Meanwhile, Chevron to invest $50 BILLION to get further exposure in the Permian in USA. “Rising oil prices and the prospect of a SECOND boom in US shale oil has raised expectations for big merger and acquisition deals”. So, UK imports of oil and NGL products from US likely to increase further.

      • What MCfly fails to see, or deliberately deflects from, the woeful lack of responsibility and accountability with very real risk to public drinking water here. As if the oil and gas industry has never been responsible for onshore pollution anywhere in the world. Try and tell that to the Ogoni people in Nigeria, one of many horrendous examples suffered by indigenous people. Of course the industry can’t be as blatant in this country, but they’re certainly pushing the boundaries of bad practice:

        • What real risk, Destroy? Is that the same sort of risk as run off from UK motorways polluting water sources, where they are constructed to mitigate that risk? Strange. Yet the southern motorways seem to be valued by the antis to shop for cakes in the middle of the night!

          I suggested someone should identify some instances in UK of water being polluted from UK oil exploration. So you come up with-NIGERIA! Yep, it happens, as it does in Venezuela. But, still no reference for UK.

          But, then, as many antis would prefer for UK to import oil from such foreign sources, I think “shooting yourself in the foot” is rather appropriate. If any contamination did occur in this country we have the resource to identify and sort it quickly and efficiently. In some other countries this simply results in severe health problems and mortality. Not a lot of compassion for others within the anti camp. Seems collateral damage is just a necessary extra on the not so moral high ground.

          • Again you fail to see the more direct risk to public drinking water at this site. Are you saying Portsmouth Water opposed the oil and gas industry for the sake of it? They saw very real risks in this environmentally sensitive area. The last thing it needs is the oil and gas industry. The fact the regulatory authorities allowed there to be self-policing at this sensitive site is completely unacceptable. The industry has already been slow to restore the site as directed. The distrust and worry is perfectly understandable. The fact there may not have been contamination onshore in the UK yet, is a red herring. It is still a possibility with increasing risks and especially at this site. Once a groundwater aquifer is contaminated the damage is irreversible. [Edited by moderator]

            Your blind trust in the authorities is very foolish MCfly.

            Although the SDNP did highlight this: https://www.southdowns.gov.uk/markwells-wood-new-breach-condition-notice-issued/

            The oil and gas industry really fills people with trust doesn’t it?

            As for oil and gas from abroad, the majority of sensible people want to see the end of that as well, it’s not mutually exclusive to the local problems. Avoid Shell, BP, Exxon Mobil, etc whenever you can. That’s why activists want an end to oil and gas completely and electrified transport from renewable energy, heat pumps to replace oil and gas in homes, etc and is possible now. No inconsistency here at all and in full solidarity with communities across the world blighted by the oil and gas industry. Oh but the UK is supposedly superior to everywhere else and it could never happen here….fossil fools.

            • DestroyTPNP

              I do not think that your assertion is always correct that once a groundwater aquifer is contaminated, that it is irreversible.

              It depends what is the contaminant, how much there is and the type of aquifer.

              The South Downs aquifer is already contamination with nitrates ( as an example ) and indeed anything else that is deposited on the chalk and is washed into it. This contamination is known and strategies already developed and enacted to improve the situation.

              https://www.southdowns.gov.uk/wp-content/uploads/2016/12/South-Downs-News-September-2017.pdf

              The key issue for that aquifer, if the chalk is managed, is extracting too much and allowing saline ingress at the margin, which would irreversible contaminate that part of the aquifer affected.

              http://ea-lit.freshwaterlife.org/fedora/repository/ealit:3208/OBJ/20001372.pdf

              [Post edited at commenter’s request]

                • Ok H62, so what are the irreversible contaminants – benzene, toluene, ethylbenzene, xylenes….? So, the typical chemicals used, and produced fluids, etc, from the oil and gas industry? What concentrations, would you suggest, are safe for aquifers supplying drinking water for human ingestion in this case?

                • DPNP – fracking for shale gas is very safe – it is not going to poison drinking water – that might happen in your imagination but not in reality. Maybe you should try and be a bit broader in your google searches and then you’ll realise is that most of what you write has no factual basis.

                • JG, not just in my imagination, according to the following scientific studies it is very real, as well as for the people who’ve been harmed since the fracking companies turned up on their doorstep. Why would they provide people with water buffaloes if they weren’t responsible for contaminating their water and silencing them with legal gagging orders, if they had nothing to hide?

                  https://www.scientificamerican.com/article/fracking-can-contaminate-drinking-
                  – water/https://www.sciencedaily.com/releases/2012/08/120806093929.htm
                  https://www.propublica.org/article/scientific-study-links-flammable-drinking-water-to-fracking
                  https://news.stanford.edu/2016/03/29/pavillion-fracking-water-032916/
                  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3100993/

                  The EPA also finally confirmed it happens: https://www.ecowatch.com/epa-fracking-water-contamination-2144968213.html

                  It also concludes it’s a threat to water supplies unfortunately: https://www.propublica.org/article/epa-concludes-fracking-a-threat-to-u.s.-water-supplies

                • DestroyPNP

                  You have made an unsupported statement and now ask me to disprove it by giving concentrations of chemicals which may, or may not constitute horndean oil or whatever is left onsite at Markwells Woods, the discharge of which into a chalk reservoir would not be diluted sufficiently at a point of extraction to make the water not potable. Quite a task.

                  However, acceptable levels of a number of contaminants you mention can be found in page 3 of the link below which may answer your query.

                  http://planning.allerdale.gov.uk/portal/servlets/AttachmentShowServlet?ImageName=130521

                  Carrying on ….

                  You say that once a groundwater aquifer is contaminated, it is irreversible, which is not true it seems.

                  I am guessing that your reply that you consider that contamination by Markwells oil well or site could contaminate the chalk aquifer to the extent that it would be irreversibly contaminated?

                  But the point is not about how much oil from the horndean reservoir ( or any contaminants remaining on the well site ) would be required to make the water not potable at the point of extraction, rather, once contaminated is the effect irreversible?

                  Meanwhile, the aquifer has demonstrated some resilience as noted in the DOD report above. It says drill fluids were lost to the formation and that they were noted by Mr Harbour as ‘a significant amount’. This significant amount of drill fluid has not contaminated the aquifer it would seem, despite being in it.

                  I have no argument with the decision to reject the UKOG application for drilling at the site given the concerns raised by the water authority.

                • Except, Destroy, fracking has never been the intention at this site!

                  Oops-set the trap and see who falls in!

                  But, if you think oil within a naturally fractured strata, in an area subject to seismic events, could be an issue regarding drinking water then the quicker the oil is removed the better! The good old precautionary principle so loved by the antis, should mean that UKOG get a Gold Award!

                • H62 I am not asking you to disprove anything with an unsupported statement, I was merely asking what could POTENTIALLY be irreversible contamination, eg. the typical chemicals you would find around the oil extraction process (I wasn’t talking about fracking btw MCFly, I was responding to your beloved JG, who brought up fracking herself when she butted in, as she does, on my question with H62 – you should really learn to stop being so reactionary! You make too many schoolboy errors when you are). Anyway H62, thank you for providing the link to some evidence base and attempting to answer my questions.

                • DPNTP

                  Thanks. Yes, aquifers can be irretrievably contaminated ( in our human timescale ) so we need to look after them.

                  My own particular interest is in the Bunter Sandstone aquifer under my feet, well raddled with oil boreholes as well as mine shafts ( many sunk by pumping as fast as you can while installing cast iron tubbing, grouting behind after ). Also the consequence of mine water control as pumping stops in the Notts Coalfield.

                  Plus the potential damage from past industrial activity, such as old coal gas ( gasometer sites ) sites on the Sandstone.

                  The link below gives a useful oversight to various issues for our aquifers.

                  http://www.groundwateruk.org/downloads/industrial_and_urban_pollution_of_groundwater.pdf

                  However, in my opinion, one well through the chalk is not major concern, nor is the drill site due to its function ( one exploratory well with minimum production ) well rained on as it has been over the years. The EA and water authorities may have bigger fish ( legacy issues ) to fry.

            • Portsmouth Water cope with oil extraction within their area already, Destroy. Not an issue. The two can live side by side without an issue. Even geothermal not an issue.

              But nobody has noticed the antis are not able to actually identify water contamination in the UK from oil and gas exploration. Oh yes they have. Nice of you to admit there has been no problem, though. But there is a risk! Well, I shall avoid getting up in the morning, crossing the road or anything where there have been recorded problems, as that is obviously even more dangerous!.

              By the way, I often speak to those in the Portsmouth Water area and I have yet to find any who have any concern about using oil and gas or with it being produced locally. Many of them have friends or relations working at places like Fawley Oil Refinery and appreciate the reality rather than the fiction. Others have visited existing oil sites and are very supportive.

              Scaremongering from the antis based upon the square root of absolutely nothing.

              “Activists want an end to oil and gas completely” as you type that out on your plastic keyboard!! Oops.

              “Communities across the world blighted by the oil and gas industry”. Tell that to the Norwegians. Oops.

              Careful, you are almost out of toes now.

              • Yet you still avoid the fact that Portsmouth Water was opposed to fossil fuel extraction at this site, because of the serious risks to drinking water, DUH! They say it themselves here: https://investigatingbalcombeandcuadrilla.files.wordpress.com/2016/10/portsmouth-water-comment-on-markwells-wood-application.pdf

                Quoting their response to this consultation: “Based on the groundwater sensitivity and the nature of the proposed works, Portsmouth Water would object to this application until the Groundwater Risk Assessment and Environmental Statement (Section 9.0 – Ground Condition & Groundwater) ……..Portsmouth Water is concerned that the application in its current format does not identify all potentially significant effects that the proposed works may have on groundwater or, how adverse effects will be mitigated.

                No site specific data is incorporated in the risk assessment and there have been limited attempts to present the catchment dynamics within the Source Protection Zone 2 of the Havant and Bedhampton Springs. If the Havant and Bedhampton Springs public water supply source is impacted as a result of this application there would be significant effects on the population of the City of Portsmouth and surrounding area.”

                Are you completely deluded?

                You condemn yourself with your own words MCfly, I quote you above: “…many antis would prefer for UK to import oil from such foreign sources, I think “shooting yourself in the foot” is rather appropriate. If any contamination did occur in this country we have the resource to identify and sort it quickly and efficiently. In some other countries this simply results in severe health problems and mortality. Not a lot of compassion for others within the anti camp. Seems collateral damage is just a necessary extra on the not so moral high ground.”

                So it seems you, yourself, have little compassion for those suffering from the oil and gas industry abroad. I can’t imagine you are not using your imported gas to heat your home, nor committed to avoiding filling up any vehicles you drive, with fuel supplied by Shell, BP, etc, all those lovely companies responsible for toxic oil spills around the world. As well as using fossil fuels from this “collateral damage”, you have the audacity to support bringing some of this collateral damage to your own country, as well as supporting child labour and environmental pollution abroad! At least the activists/protectors are campaigning to completely cut it out locally and globally and support alternatives like AD renewable gas from inedible food and organic agricultural waste, waste collection of used cooking oil from town and city centre restaurants for re-use as a bio-fuel for transport (no extra land required), solar panels used to charge up electric buses, stored for later use, etc, etc….ad infinitum.

                Talk about “shooting yourself in the foot”, you’ve just shot it off!

  3. This government wants to remove requirement to apply for planning permission!!!!! Sue government are complicit in a race to the bottom of regulations.

  4. Or, CPR, you could just continue to import oil from far and wide!

    Wonder if Venezuela has even heard about planning permission and reinstatement?

    Environment controls seem collateral damage to some-if they are over the horizon. Shame that is the way most of the plastic gets into the oceans as well.

    Oil and plastic-two good examples of how UK production and management is so much better than relying upon areas overseas we have no control upon. In UK we can enjoy youngsters campaigning. Overseas they are often dying through toxicity of their local production or employed as child labour to rake though heaps of our rubbish.

    But, the UK Nimbys are content.

    • David

      My guess is that the losses are the same as noted in both UKOG data and the report sponsored by Markwells Wood Watch, being losses in either or both aquifers drilled through.

      A point of interest would be that these losses have not contaminated the aquifer ( as the reports note that such an event would lead to contaminants turning up in short order at the spring line ), or if they have, no one noticed, as the company drilling used appropriate drilling fluids to drill through both aquifers ( as UKOG said they would if they were given permission to drill ).

      http://www.markwellswoodwatch.org/uploads/8/4/1/6/84169426/hydrogeological_report_warren.pdf

      So, the loss of drill fluids is a red herring it seems in this case.

  5. The third paragraph in the report seems to link two issues

    The first issue is loss of drill fluid ( which would be whatever fluid the drilling company were using ) as noted in the report ( total loss ). Is this loss in addition to the losses in the chalk noted in UKOG information and the Fowler report, or the same one? ( post casing the well and drilling 542 to 1081ft incurring losses ).

    The second is a report which notes that surface spills could enter the chalk and get to the springs in short order ( the Fowler Report ).

    How do these two issues link?

  6. Thanks to Markwells Wood and Drill Or Drop for once again highlighting the shocking lack of regulation of the onshore oil and gas industry. We have seen this so many times – how can anyone still refer to ‘gold standards’?

  7. Maybe time to get a prohibitory injunction against these companies being able to say they are operating to gold standards.

  8. It remains to be seen what UKOG actually do to ensure that this site is restored properly. If, as is likely, they choose to ‘half-arse’ it then they can be held accountable during consideration for other sites that they they think they are going to be operating within and the lack of a professional restoration here will go against them elsewhere – Isle of Wight where they are hoping to drill, for example. UKOG – the watchword for tat!

    • Chrisjohnt

      We will be able to compare the restoration with the Tinkers Lane site I guess. That site is to be returned to farmland. I am not sure what Markwells Wood is supposed to look like post restoration, an area of newly planted trees?

  9. This is David Kesteven of The Fracking Farmhouse and details the move by Concerned Health Professionals of the United Kingdom (CJPUK) to organise and tell the truth about the dangers of fracking and its related avoidances of the word in the UK and across the world.

    CJPUK website:

    http://chpuk.co.uk

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