Questions regarding Markwells Wood plugging and abandoning

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Dear Health and Safety Executive,

I have a series of questions relating to the Plugging and abandonment of Markwells Wood -1 in Forestside , West Sussex.

It is understood that he well was drilled through a very vulnerable hydrogeological zone which would not be currently allowed. Since it was drilled pre 2013 change in regulatory regime, we are concerned that the P& A may not be scrutinised in the manner it requires.

Due to the extreme sensitivity of our karstic aquifer, and the potential risk to the public health of those in the water catchment, which provides drinking water to over 250,000 people, we have some serious concerns about protocol for P&A at this site.

QUESTIONS REGARDING PLUGGING & ABANDONMENT OF MARKWELLS WOOD-1
AND PUBLIC HEALTH /WATER RISK
Forestside, West Sussex

Research since the well was capped in 2011/12 indicate that the zoning around Markwells Wood is most likely to be Source Protection Zone 1 and therefore very vulnerable to contamination.

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?
• Is there currently any regulation /permitting involved for P & A practice in a
SPZ1 or equivalent? If so, please list.
• Is the HSE aware that the MW-1 well is in a vulnerable hydrogeological zone?
• Is there a case for bespoke regulation with regard to Markwells Wood-1 well?
• 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.
• 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.

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?
• If there is no permit needed how will the waste be managed, stored and
transported?
• Who is the independent well examiner following the process through
abandonment?
• 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)?
• 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?
• 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.
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?
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?

Thank you for your time and consideration of the above questions.
Kind Regards,
Emily Mott
Markwells Wood Watch
Weald Action Group

Health and Safety Executive

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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 

 

 

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References

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Health and Safety Executive

1 Attachment

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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Yours sincerely

 

Dave

 

Dave Salmon / OSDR Competent Authority Office / 

Energy Division ED7.1

 

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