Dear Environment Agency,
I made a Freedom of Information Request to the OGA on the 3rd May 2017 and was advised on the 19th May 2017 that they do not hold the information and that I should readdress the Request to the Environment Agency. I asked:-
Why does the information required by the OGA in an operator’s Hydraulic Fracture Plan (as part of Extended Well Tests) specify a range of detail needed in relation to induced seismicity, but fails to cover the prospect of the migration to the surface of fugitive toxic gases and fluids which are released but not captured during the fracking process?
Does the OGA intend to amend its guidance to operators to seek information regarding this prospect of migration through conduits and pathways presented by:
(a) vertical and inter-connecting fault lines in the rock strata,
(b) capped fracking wells, when over time steel casings will corrode and concrete linings shrink and crack, and
(c) around the head of disused conventional oil and gas wells located near to a fracking well?
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Dear Mr Wilkinson
Thank you for your request.
We are treating your enquiry as an Information Request under the Environmental Information Regulations 2004/Freedom of Information Act 2000.
Your request will be dealt with by our National Request Team under reference NR49215
The Environment Agency covers England only.
For Scotland, Northern Ireland and Wales, please see the links below:
The Environment Agency’s obligation under the relevant legislation is to provide you with the requested information within 20 working days from the date your enquiry is received, but we shall endeavour to respond as soon as we can.
In the meantime should you have any queries regarding this request please contact us at: [email address]
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03708 506 506
Dear Mr Wilkinson
Thank you for your enquiry. We are the environmental regulator for shale gas activities and can respond to your enquiry where your questions fall within our regulatory remit. Please note that the Hydraulic Fracture Plan will be submitted to both the OGA and the Environment Agency for our respective approval.
We have answered parts and a and c of your enquiry below. For part b we have provided a brief overview of the Health and Safety Executive’s (HSE) requirements. If you require further information on this subject please contact the HSE directly.
Answers to parts a and c:
One of our roles is to ensure operators manage the risk of fluid migrating along existing faults and affecting groundwater. Operators are required to provide information on faults near their proposed borehole trajectory from their desk study data, seismic exploration surveys, borehole logs and any other available sources.
While they are undertaking hydraulic fracturing, we require operators to monitor the growth of the hydraulic fractures. This is to provide us with evidence that the fractures are staying within the formation boundary set out in the environmental permit (and therefore there is no risk to groundwater).
This fracture monitoring will also give an indication if there has been a reactivation of an existing fault, leading potentially to fluid migrating beyond the formation boundary. Operators have to set out in their Hydraulic Fracture Plan how they would manage and report this if such an event were to occur.
If for any reason there was a breach of a permit condition, or any serious risk to people or the environment, the Environment Agency, through the Environmental Permitting Regulations, have a number of enforcement actions available to them; including the immediate suspension of the activities if the situation warrants this.
You also refer to the potential for migrations of gas and pathways to be created from former conventional and shale gas wells. We require groundwater monitoring as part of any environmental permit for a groundwater activity, in which we deemed groundwater may be at risk. This can be required before, during and after operations (the exact monitoring regime is determined on a site by sit basis depending on the risks at that particular site).
Our permit requires the operator to have in place a closure and rehabilitation plan, which should follow the Environment Agency’s good practice for decommissioning boreholes and wells, as well as HSE’s guidance. The Environment Agency will not allow the operator to surrender their permit until we are satisfied that either no pollution has occurred at a site, or if it has, that the site has been returned to its original condition.
Responsibility for meeting the obligations set out in the environmental permit rests with the permit holder and will continue to bind them until we accept the surrender of the permit.
Answer to part b:
Wells must be constructed and decommissioned in line with HSE’s guidance. An independent well examiner is responsible for ensuring the well is designed and constructed in line with HSE’s requirements. The operator is required to safely decommission the well when production ends and must supply HSE with weekly operational reports throughout the decommissioning and abandonment process. The law requires that after suspension or abandonment, so far as is reasonably practicable, there can be no escape of fluids or gases from the well.
The decommissioning required by the HSE must take into account any groundwater bearing units through which the borehole has passed and the design of the decommissioning works has to provide assurance that no release of this water can occur, or cross contamination with other groundwater bearing units can take place, after the well has been sealed.
If you require any further information about well construction and decommissioning please contact the Health and Safety Executive directly.
Onshore Oil and Gas team
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