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Thank you for contacting the Health and Safety Executive.

Dear Emily

Environmental Information Request Reference No: 201811322

Thank you for your request for information about:

Markwells Wood – 1 plugging and abandonment

Your request was received on 22 November 2018 and I am dealing with it in
accordance with the Environmental Information Regulations 2004. Under the
terms of the Regulations you are entitled to a response within 20 working
days of receipt.

If for any reason we are unable to meet this deadline we will keep you
fully informed of the reasons for this and will tell you when you can
expect a response.

Guidance on how the Health and Safety Executive deals with requests under
the Freedom of Information Act and Environmental Information Regulations
can be found on the HSE website at [1]http://www.hse.gov.uk/foi/index.htm

If you have any queries about this letter, please contact me. Please
remember to quote the reference number above in any future communications.

Yours sincerely

Dave

Dave Salmon / OSDR Competent Authority Office / 

Energy Division ED7.1

Health & Safety Executive, Lord Cullen House, Fraser Place, Aberdeen, AB25
3UB 

dangos adrannau a ddyfynnir

References

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1. http://www.hse.gov.uk/foi/index.htm

Dear Emily

Environmental Information Request Reference No: 201811322

Thank you for your request for information about: Markwells Wood plugging
and abandoning

Your request was received on 22 November 2018 and I am dealing with it
under the terms of the Environmental Information Regulations 2004.

I have taken each of your questions in turn below:

Different drilling methodology and abandonment procedures should apply to
each type of  aquifer.

• Does the HSE have any best practice models for plugging and abandoning
onshore oil wells in Source Protection Zones 1 and 2?

We inspect well abandonment details contained in BSOR notifications
against the UK Oil & Gas Guidelines on Well Decommissioning, issue 6, June
2018.  Meeting the guidelines is accepted as a good demonstration of
compliance with the relevant legislative requirements. 

• Is there currently any regulation /permitting involved for P & A
practice in a SPZ1 or equivalent? If so, please list.

HSE’s relevant legislation is:

 1. The Offshore Installations and Wells (Design and Construction, etc.)
Regulations 1996 (DCR), and
 2. The Borehole Sites and Operations Regulations 1995 (BSOR).

HSE does not operate a permissioning regime for onshore oil and gas wells.

• Is the HSE aware that the MW-1 well is in a vulnerable hydrogeological
zone?

This is not within HSE’s remit.

• Is there a case for bespoke regulation with regard to Markwells Wood-1
well?

No. HSE considers the existing regulatory regime to be suitable and
sufficient.

• Has there been a detailed evaluation of risks to groundwater and
mitigation measures at MW during P&A? Please send copy of any risk
assessment.

This is not within HSE’S remit. However, questions were raised to UKOG
addressing isolation of the water aquifers as part of our inspection of
the BSOR notification for plugging and abandoning the well.

• Has there been an assessment of chemical additives to be used in the
plugging of the well? Please send list of all chemical additives and
materials used.

This is not within HSE’s remit and should be addressed to the Environment
Agency.

Apparently wells drilled prior to 2013 will not require a mining waste
permit to manage the extractive waste generated.

• Will there be an exception at Markwells Wood where it has been accepted
that there is considerable risk involved due to our sensitive aquifer?

This is not within HSE’s remit and should be addressed to the Environment
Agency.

• If there is no permit needed how will the waste be managed, stored and
transported?

This is not within HSE’s remit and should be addressed to the Environment
Agency.

• Who is the independent well examiner following the process through
abandonment?

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.

• Have the authorities and Portsmouth Water been notified of works being
carried out at the site as of Nov. 19th?

• Has the EA and HSE and SDNP received a copy of the program for sealing
and abandoning Markwells Wood 1 (MW-1)?

HSE has received a BSOR abandonment notification made under regulation
6(1) of BSOR and our inspection of that notification has been completed.
HSE has no information on any other notifications that may have been
received by other authorities.

• We understand that UKOG has a duty under DCR to update the HSE each week
on the abandonment work so that activity can be checked against the plan
set out in the notification. Please can you send any updates to date?

No weekly operations reports have been provided as at the time of your
request. 

• Directional wells will have different gravitational effects compared
with vertical wells. MW-1 was deviated at an inclination of approximately
56 degrees. Please can we see a copy of the schematic indicating the angle
of the deviated well.

Directional survey and well trajectory are included in the BSOR
notification made under regulation 6(1) of BSOR and this information can
be disclosed to you and is attached.

Post abandonment:

• We understand that the operator is responsible for the well post
abandonment.

What procedure is put in place if UKOG goes out of business?

This is not within HSE’s remit. Once the abandonment process is complete
and the site ceases to be a workplace HSE has no further jurisdiction (or
vires) to regulate.

Studies reveal that no matter the quality of the cement job, after a
prolonged period of time, the cement will crack and erode and the steel
will corrode. This eventually can lead to toxic gases and well fluids
being released into the environment. In 2016, a ReFine study recently
found that in the UK, 30% abandoned wells studied have leaked
methane.https://drillordrop.com/2016/01/26/study...

65% wells abandoned onshore in the UK are no longer visible.

• How will the HSE ensure that MW-1 remain obviously visible in perpetuity
so that it can be monitored post abandonment?

• Do you have a legacy plan for Markwells Wood 1 ?

• How will Markwells Wood 1 be monitored post abandonment, considering it
is in a vulnerable hydrogeological zone?

This is not within HSE’s remit. Once the abandonment process is complete
and the site ceases to be a workplace HSE has no further jurisdiction (or
vires) to regulate.

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If you have any queries about this letter, please contact me. Please
remember to quote the reference number above in any future communications.

If you are unhappy with the decisions made by HSE you may ask for an
internal review within two calendar months of the date of this letter by
writing to me.

If you are not content with the outcome of the internal review you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 01625 545700

Fax: 01625 524510

Email: [3][email address]

Website: [4]http://www.informationcommissioner.gov.uk

Yours sincerely

Dave

Dave Salmon / OSDR Competent Authority Office / 

Energy Division ED7.1

dangos adrannau a ddyfynnir

References

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