This post has updates from the start of a public inquiry in Scunthorpe into plans by Egdon Resources to produce oil for 15 years at its site nearby at Wressle.
North Lincolnshire Council has refused planning permission three times for the scheme and the proposal was rejected by a planning inspector after an earlier public inquiry two years ago.
The scheme has attracted controversy because Egdon proposes to use hydrofluoric acid to stimulate the well and increase oil production. The inquiry is expected to focus on whether this and other operations at the site will contaminate ground water or local streams.
The inquiry will hear from representatives and consultants of the company, as well as local residents. North Lincolnshire Council decided in July not to defend its refusal of planning permission and is not calling witnesses.
Reporting from this inquiry was made possible by individual donations from DrillOrDrop readers. This is not a verbatim or official record.
- Egdon’s proposed proppant squeeze needs a hydraulic fracture plan – Egdon consultant
- Inspector should assume other regulators will operate effectively – Egdon consultant
- Upgrades planned to well platform, oil storage bund and tanker loading
- 2.15 million barrels of oil classed as recoverable from Wressle – Egdon MD
- Wressle scheme will help UK avoid imports – Egdon MD
- Wressle plan is “technically fracking” but legal loopholes avoid regulations – opponent
- Egdon errors and oversights revealed only by public scrutiny and council consultants – opponent
- Risks from acid, seismicity, emissions – opponent
- Objections don’t justify refusal – Egdon barrister
“Hydraulic fracture plan needed”
Evidence from Jonathan Foster for Egdon Resources
Jonathan Foster, a consultant specialising in regulation of the UK onshore oil and gas industry, tells the inquiry that the planning inspector “should assume” that other regulators, such as the Environment Agency, will operate effectively.
He says the Environment Agency (EA) issued a permit for the operations proposed at the Wressle site and made no objection to Egdon’s planning application. He said
“It is my professional judgement that significant weight should be attached to the EA’s expert opinion as to the acceptability of the likely emissions to air, land and water.”
He says public objections to the Wressle scheme in his area are all concerns that would be considered by the EA and other industry regulators. Little weight should be given to them, he says.
Hydraulic fracture plan
Mr Foster says the proposed proppant squeeze would need a hydraulic fracture plan. But he says the regulations require less information in the plans for hydraulic fractures using smaller volumes of fluid.
He says Egdon proposes to inject 150m3 of fluid during the proppant squeeze. This is 15% of the volume per stage defined for high volume hydraulic fracture in the 2015 Infrastructure Act
Consents at Wressle
Mr Foster says planning permission to drill the Wressle well was granted in June 2013. The EA granted an environmental permit in March 2014. Work on the site began in May 2014 and drilling began in July 2014. The rig was demobilised in August 2014 after data revealed the presence of oil and gas at three levels of the well.
He describes how Egdon applied to vary the permit in July 2014 in order to test the well. Changes were granted in October and December 2014. Testing began in January 2015 and was completed in two phases in September 2015. The well was then suspended, Mr Foster says.
He says during drilling and testing, the EA made 13 visits to the site over the period of less than one year to monitor compliance with the permit and no issues were raised.
Egdon applied for planning permission for long-term oil and gas production at Wressle in June 2016. It also sought to vary the permit for production operations. The EA issued the permit changes but planning permission was refused in January 2017.
Mr Foster says Egdon appealed against the planning refusal in April 2017 but a planning inspector dismissed the appeal after public inquiry in November 2017. Planning permission was again refused in November 2018, leading to another appeal and a second public inquiry.
Mr Foster reviews the objections to the Wressle site.
Well failure Mr Foster says the steel tubes of completion casings “will degrade over time due to erosion corrosion. He says they can be replaced and degrading of these tubes do not constitute a loss of well integrity.
“It is a foreseeable event, which the design and construction of the borehole safely accommodates.”
Flaring Mr Foster says the application includes a ground flare. This meets the EA’s assessment of best available technology, he says. The permit requires monitoring of the flare to “protect the environment and community health”, he says.
Unproven technology Opponents of the application have raised concerns about the use of acid at the Wressle site.
Mr Foster says the near wellbore treatments “have been used extensively onshore UK”. He says the EA has assessed the chemicals to be used in the acid squeeze as “non-hazardous” to groundwater.
Mine workings Objectors have also criticised drilling for oil and gas in a former mining area. Mr Foster says boreholes of more than 30m in a mining area have to notify the Health and Safety Executive. The HSE and regulations should be assumed to operate effectively, he says.
Seismic activity Mr Foster repeats that Egdon will have to submit a hydraulic fracture plan to the Oil & Gas Authority for approval. This regime should be assumed to operate effectively, he says.
Health risks Mr Foster says the regulations have a duty to protect health and control oil and gas developments by setting emissions limits and monitoring for noise, air quality and water quality.
Upgrades to site
Evidence from Mark Barwood for Egdon Resources
Mark Barwood, a civil and structural engineering consultant, gives evidence for Egdon Resources.
He tells the inquiry that after Egdon’s appeal at the first public inquiry was dismissed the company decided to redesign the wellsite.
Egdon commissioned Opus to do a geotechnical investigation in February 2018. Six boreholes were drilled to 4-5.5m below ground level. Tests were also carried at 0.8-0.9m below ground level.
A topographic survey and design review were also commissioned, he says.
Upgrades to the Wressle site
The review proposed upgrades to:
- wellsite platform
- oil storage bund
- access and tanker loading area
- extension to existing wellhead platform
- wellsite platform drainage
Mr Barwood gives more details of the work planned at Wressle.
He says the existing 300mm aggregate cover, which was criticised at the last inquiry, will be removed from the active part of the wellsite and stockpiled.
Two layers of the the geotextile will be removed, exposing the original impermeable site liner. Tests will be carried out the load bearing of the site.
Mr Barwood says a new geotextile liner will be installed, along with a high-tensity polyethylene fully welded impermeable membrane. The former aggregate will be placed on top.
He says he is satisfied that the platform is adequate to support the required loads.
A new bund will be constructed around the area where produced oil and formation water is stored, he says. It will be created from reinforced concrete, a bed of aggregate and covered with a damp-proof membrane.
Reinforced concrete will be used for the access way and tanker loading bay to give extra protection to the impermeable membrane.
A french drain will be constructed to deal with surface rain water falling on the active area of the wellsite, Mr Barwood says. This will be formed by lining the existing perimeter ditches.
The new drainage system will be constructed so that it will discharge clean rain water run-off via the interceptor to the Ella Beck at a maximum volume of 5 litres per second.
“Wressle scheme will help secure UK energy and avoid imports”
Evidence from Mark Abbott, Egdon Resources
Mark Abbott, managing director of Egdon Resources, tells the inquiry the Wressle well was drilled in 2014 to a depth of 2240m. It was tested in 2015, confirming oil and gas in three separate reservoirs. Since then the site had been maintained on a “care and maintenance” basis, he says.
He says there are an estimated 14.18 million barrels of oil in place at Wressle. Of this, 2.15 million barrels are classified as recoverable. There is likely to be enough gas to support the generation of electricity at the site, he says.
Mr Abbot says the planning application seeks to:
- Install security facilities
- Install a new high density polyethylene impermeable membrane
- Install production facilities and equipment
- Install two new water monitoring boreholes
- Replace completion tubing
- Carry out acidisation, proppant squeeze or side-tracing drilling to enable production of oil and gas
- Produce oil and gas for 15 years
- Install gas engine to generate electricity to grid connection
- Well decommissioning and site restoration
Need for well treatment
Mr Abbott says the natural flow from the Ashover Grit sandstone reservoir has been impaired. He says this can be resolved by a range of well treatments.
Acidisation: a dilute acid dissolves fine particles in the natural pores of the rock
Proppant squeeze: gelled fluids and sand-sized ceramic beads (proppants) are pumped through perforations at pressure to create small fractures in the rock on either side of the wellbore. This allows oil to flow into the well. Mr Abbot says
“The proppant squeeze is definitely not High Volume Hydraulic fracturing for shale gas or oil, although there are similarities between the two techniques.
“The proposed operation is significantly smaller in scale and the term “proppant squeeze” has been used to differentiate between fracking and the operation proposed at Wressle”
Sidetrack drilling: this would be used if the other techniques don’t work. A 25m long borehole would be drilled from the existing well to intersect the hydrocarbon reservoir.
Mr Abbott addresses objections to the Wressle proposals.
Seisicity: he says there is no evidence that the development would induce seismic activity
Subsidence: “there is no credible mechanism which could lead to subsidence at the Wressle site”
Egdon’s track record: “Egdon is proud of its excellent record in relation to health, safety and environmental management”
Precedent: The development would not create a precedent for the proliferation of similar schemes or processes, according to the inspector at the previous inquiry, Mr Abbott says.
Water use and waste: Water volumes would be small, Mr Abbott says and supplied from an existing mains connection. Waste volumes would also be small and would be transferred to a licensed waste treatment facility.
Insurance: Egdon has appropriate insurance, including third party cover, Mr Abbott says.
Mr Abbott says oil and gas are essential sources of energy and will continue to contribute to the UK energy mix even in a net zero CO2 future. Energy security will remain a key issue for the UK.
“Oil from Wressle will help in a small way to provide the UK with secure energy supplies, reducing the need for higher emission imported oil”.
“Complex and experimental plan”
Statement by opponent: Elizabeth Williams
Mrs Williams says:
“The people of North Lincolnshire, through their representatives on the planning committee, through Broughton Town Council and through the United union at British Steel, have says no to this risky, untried , untested and unregulated development over and over again.”
She says suspicions about what was planned at Wressle were first raised in 2016 when the company’s chief executive referred to a minifrac.
Since then, Ms Williams says, people had discovered that what was planned at the site was “far from small scale and conventional”.
“It is a complex and experimental plan”
Mrs Williams says the public and planners were not made aware at the site’s exploration stage of the proposed processes and procedures, which was why no objections had been raised then.
The Environment Agency recommended Egdon be more transparent and not “veil their plans by using terms such as proppant squeeze and acidisation”, she says.
Mrs Williams says Egdon intends to carry out a process that is technically fracking, though not high volume fracking of shale). She says the site’s environmental permit refers throughout to hydraulic fracturing. The company’s non-technical summary refers to proppant squeeze alternated with acidisation. The proposed operation will require a hydraulic fracture plan.
“This involves novel and therefore unconventional methods to recover oil. The permit for the site describes hydraulic fracturing for conventional oil alternated with hydrofluoric acid squeeze.”
She says the proposed trade name Duofrac intended at Wressle is a process used to recover difficult and hard to access sandstone reserves. It involves high pressure hydraulic fracturing to stimulate flow in spent or had to access sandstone reservoirs.
Egdon had previously said it proposed to carry out acid matrix stimulation, she says. “This is not a routine acid wash”.
The company produced evidence at the first public inquiry of the use of hydrofluoric acid at the Crosby Warren well site, Ms Williams says. But that was a mud acid wash, she says, not acid stimulation. Where is the evidence that acid stimulation has been used onshore in the UK?, she asks.
She urges Egdon “for absolute clarity” to state what form of acidisation it intends to use at Wressle.
Mrs Williams says community groups in Lincolnshire, Sussex, Surrey and Hampshire have been calling for urgent changes to regulations to address legal loopholes over the use of acid in the oil and gas industry.
Legal constraints that apply to hydraulic fracturing for shale do not apply to the proposed operations in the sandstone at the Wressle well – or there’s ambiguity about whether they apply, Mrs Williams says.
The Oil & Gas Authority does not clearly define when a hydraulic fracture plan is required, she says.
The Environment Agency has failed to clarify the difference between acid stimulation and well maintenance techniques using acid.
Site inspections are mandatory for high volume fracturing for shale but are not required for other forms of hydraulic fracturing and acid stimulation.
The definition of hydraulic fracturing in national planning policy guidance lacks clarity and is too narrow in its definition of hydraulic fracturing, she says.
Mrs Williams raises concerns about the use of hydrofluoric acid.
“If hydrofluoric acid is lethal at relatively small amounts how can this be ruled de minimis here at Wressle? Won’t site workers and the surrounding communities be subjected to extraordinary and unknown risks?”
She says the local fire and rescue services may be unaware of the proposed activities planned for Wressle.
The company proposes to use a “modified” hydrofluoric acid. What is this and do the regulators have any experience of it?, she asks.
Mrs Williams says it was only members of the public and consultants working for North Lincolnshire Council that errors and oversights came to light at the first public inquiry. These include environmental pollution mitigations not properly constructed or installed as recommended and water monitoring boreholes that were too few, too shallow and in the wrong place.
“The site demonstrably has not been kept on a ‘care and maintenance’ footing. It is derelict and overgrown and the protective bunding riddled with holes.”
Mrs Williams says North Lincolnshire has historic ironstone mining and there are ongoing measures to shore up the subsurface.
“To begin hazardous chemical and mechanical processes in the location places Broughton and the surrounding communities at risk of catastrophic seismic activity and threat to the area’s hydrogeology.”
She asks how the community can trust the company to carry out complex and hazardous activities if previous relatively straightforward above-surface operations were not carried out satisfactorily.
“Can we respectfully urge our planners and producers and investors to make radical choices and decisions to move away from fossil fuels with immediate effect?
“In this room there is technological and business acumen to make such brave movements. Please let’s do it.”
Mrs Williams presented to the inquiry a legal briefing commissioned by Brockham Oil Watch Acid stimulation – Fracking by stealth
“Risks to local people, environment and investors”
Statement by opponent: Jean Turner of the scheme
Mrs Turner, who lives in the Isle of Axholme, says she has been investigate the onshore oil and gas industry for eight years and eight months.
She raises concerns about problems of mining for iron ore and coal at Dragonby and Santon near a major fault. She says the mine roofs were unstable and sink holes had occurred.
The local area suffered from earthquakes, at least two a month. In 2008, there was a 5.2ML quake that was felt over a large areas.
Mrs Turner says this situation would be compounded by the proposed injection of fluid under pressure at the Wressle site. This would generate new cracks and fractures. As these grew and spread, she says, they would be accompanied by the failure of brittle rock and lead to more microseismic events.
She says the quakes affect the area of the proposed lorry route to the Wressle site. A large gas pipeline runs alongside a minor road, to be used by site traffic. The pipeline needs to be protected from the prospect of heavy traffic travelling to the site for a period of 15 years, she says.
Mrs Turner says the Wressle application is the first onshore to use hydrofluoric acid. She says the Environment Agency has no records of its use at any site.
Standard rule permits for the use to acid in oil and gas sites originally included hydrofluoric acid, Mrs Turner says. But it was removed after evidence from Professor Lawrence Dunn, of Southbank University.
Mr Turner asks for evidence that ammonium bifluoride, which will be used to make hydrofluoric acid in the well, could be used safely.
How does Egdon know what they were doing when there was no track record of using hydrofluoric acid in onshore oil and gas the UK?, she asks.
She asks for evidence that the material in the blowout preventer is resistant to hydrofluoric acid and what would happen if there is an uncontrolled blowout of a well treated with the acid.
She also asks about what training would the well crews and Health and Safety Executive staff have in working with hydrofluoric acid and what studies have been carried out on the radioactive components in formations treated with hydrofluoric acid.
Mrs Turner warns that the health effects from chronic exposures may not be appear until many years later.
On the proposed gas flaring at Wressle, she says, volatile compounds, oxides of nitrogen, carbon monoxide and other toxins will be discharged into an atmosphere which, she says, regularly had inversion conditions where any pollution did not blow away. If gas is converted to electricity, there will still be emissions from the gas engine, resulting in more air pollution.
Research by the British Heart Foundation concluded there was no safe level for the particulate 2.5, she says. One of the researchers said “we can’t expect people to move home to avoid pollution”.
Other research by Queen Mary University of London and University of Oxford concluded that for every microgram increase in the level of particulate, the heart enlarged by 1%. Enlarged hearts could not pump as much blood around the body, increasing risk of heart attack, heart failure or death.
Mrs Turner says Scunthorpe is in the top 15 towns for illegal levels of pollution.
She refers to a government-commissioned report on the impacts of oil and gas developments on air quality, the release of which had been delayed. Any industrial process at a local level will have an impact on air quality, she says quoting the chair of the Air Quality Expert Group, which produced the report.
Mrs Turner asks for information on the local licensed facilities that would treat any radioactive waste that will be brought to the surface.
She also raises concerns about the financial viability of the oil and gas industry. She says councils had invested large sums of money in energy companies.
“This is a risky business for ratepayers and tax payers to fund.”
“Objections ill-founded, irrelevant or unjustified”
Opening statement by Egdon Resources
Egdon’s barrister, Hereward Phillpot QC, tells the hearing that this second inquiry is taking place in very different circumstances than the first, which opened almost exactly two years ago.
“There is more detailed understanding of the appeal site and its characteristics. We have used knowledge to design and incorporate into the development a significantly different and more complex system of tertiary containment and environmental protection.”
He says there is now no dispute between the company and North Lincolnshire Council that the proposed development is acceptable and the effects can be suitably controlled through conditions.
“It is unfortunate that the appellant has been put to the trouble and expense of pursuing this appeal in order to reach an agreed position with the council because nothing material has changed.”
Mr Phillpot says an assessment by consultants for the council concluded that the main weaknesses identified by the inspector at the first inquiry appear to have been addressed or can be addressed in planning conditions.
The consultants’ advise was accepted by professional planning officers who recommended planning permission should be granted, when the application was discussed by councillors in November 2018.
But councillors rejected the clear advice of their own experts and professional officer, he says.
“It is plain that they had no proper or reasonable grounds on which to do so.
“[There is] a substantial level of misunderstanding of what was proposed and of the evidential position.”
Mr Phillpot says the council and the company now agree on the following:
- The Wressle scheme complied with the relevant parts of the development plan
- It constituted sustainable development (in terms of the National Planning Policy Framework)
- The principle of hydrocarbon development was accepted
- It would deliver national and local economic benefits
- There would be no significant landscape or visual impacts
- There were unlikely to be any adverse impacts on protected species or habitats
- Short temporary impact on the setting of Thorholme Priory from the drilling rig would be slight/moderate and no mitigation was needed
- Risk of adverse impact on air quality was very low
- Conditions would ensure no unacceptable noise effects
- Mitigation incorporated into the site design was acceptable
- There was no material risk to groundwater supplies, local water courses, or the British Steel borehole at Clapp Gate
- Vehicle movements would not have unacceptable adverse effects on the highway
- There was no evidence the site would induce seismic events
Mr Phillpot says there are no objections from the Highways Agency, Natural England, Environment Agency or British Steel. Considerable weight should be given to the views of the Environment Agency, he says.
None of the objections by third parties raised any points that could justify refusal, he says.
“Inspector’s concerns addressed”
Mr Phillpot says the water contamination concerns of the inspector at the first inquiry – who dismissed Egdon’s appeal – have been addressed by triple containment measures.
- Oil and water would be contained in pipes and tanks
- Pipes and tanks would be contained in a sealed bunded area
- A new liner would be installed under the whole site
The existing liner will be retained and repaired but will no longer relied on it, Mr Phillpot says. This overcomes the previous inspector’s concerns.
The residual risks to surface and groundwater are now assessed as ranging from low to none.
“Planning permission should be granted”
Mr Phillpot says because the proposed development accorded with the development plan there is a statutory presumption that planning permission should be granted unless material considerations indicted otherwise.
There are no other material considerations capable of outweighing this presumption, he says. Indeed, all other mat considerations point to supporting the grant of planning permission.
The scheme supported UK energy policy by making a contribution to maintaining the UK’s security of energy supply, reducing dependence on oil imported from abroad.
It is also consistent with the economic growth plan for North Lincolnshire, he says. This aims to foster the growth and diversification of the Humber chemical and energy cluster. These are locally-important industries, he says, that rely on the availability of hydrocarbons. Local sources of supply has advantages in reducing carbon emissions associated with transport.
Mr Phillpot says the application is for conventional oil and gas. The near wellbore treatments proposed would not result in any material harm. Impacts could be controlled or were acceptable. Fossil fuels has a role to play in the transition to a low carbon economy, he says.
No government policy supports a reduction of emissions by restricting the domestic production of hydrocarbons. The net zero goal does not envisage no production or consumption of hydrocarbons, he says.
Domestic production does not increase overall emissions but is likely to reduce them. It should be regarded as a small but important part of a more sustainable low carbon future, he adds.
Grant planning permission will deliver “significant economic, social and environmental benefits”, Mr Phillpot says. It will generate employment, taxes and additional business for local suppliers. Great weight should be attached to these benefits, he says.
“Residual adverse effects will not be significant and can be controlled.”
Referring to opposition from local people, Mr Phillpot says:
The objections are either ill-founded, irrelevant and/or not capable of justifying the refusal of planning permission.
“Many of the objections constitute objections to current government policy or proceed from misunderstandings or mistaken assumptions as to the nature and characteristics of what is proposed.”
He calls on the inspector to allow the appeal and grant planning permission.
The planning inspector, Phillip Ware, opens the inquiry.
He explains that the council has withdrawn from the inquiry and will not be calling witnesses or cross-examining representatives for Egdon Resources.
This means the hearing is now expected to take about two or three days, he says, instead of the original six that had been scheduled.
Mr Ware says members of the public can make statements to the inquiry and ask questions of Egdon Resources’ witnesses. Two residents are due to speak today and one tomorrow.
The inspector says he will make a site visit towards the end of the inquiry.
He says the key issues for the inquiry are whether the operation at Wressle will contaminate the groundwater or surface streams.