Seismic Activity at Preston New Road and Well Integrity -Tests and Reporting in October 2018

The request was refused by Health and Safety Executive.

Dear Health and Safety Executive,

Regulatory role of HSE

1) i) Is the HSE monitoring the operations at Preston New Road in real time? if yes,
ii) what job position is undertaking this task?
iii) by what system?

2) Once hydraulic fracturing has commenced:
i) please provide a document/ correspondence or link explaining the HSE regulatory position regarding the role of the
• HSE
• And/ or the Independent Well examiner
in checking the well integrity.
ii) is there a requirement for HSE/ independent Well examiner to make a site visit? If so, please state the date(s) of the visit(s) to Preston New Road by HSE and/ or the Independent Well examiner.
iii) Please confirm if a desktop examination of data sent by the operator to HSE is adequate to examine well integrity.

3) Please answer ‘yes’ or ‘no’ to this question.
Is there a requirement to run a Cement Bond Log Test for EVERY time the Seismic activity is measured at or above 0.5ML?

4) Is there a requirement for HSE/ independent Well examiner to make a site visit after seismic events at or greater than 0.5ML? If so, please state the dates of these visits to Preston New Road by HSE and/ or the Independent Well examiner.

5) Which of the following methods are permissible to satisfy the HSE that well integrity has been checked? Please state 'yes' or 'no' for EACH of the following procedures, and if any require additional measurements to be undertaken:
• Checking the annular pressure at the surface
• Pressurising the well with liquid nitrogen and checking for loss
• Running a Cement Bond Log
• As is stated in https://cuadrillaresources.com/wp-conten...
if a ‘vibration monitoring array’ be utilized to assess the impact.

6) I refer to the following document available at
https://cuadrillaresources.com/wp-conten... p23
i) Please state if HSE require the operator to provide them with Well Integrity testing after any seismic events occurring during pumping which have occurred within the 'amber zone' 0.0Ml- 0.5ML;
ii) Please state if HSE require the operator to provide them with Well Integrity Testing after any seismic events occurring during 'trailing events' where seismic activity 0.5ML:
https://cuadrillaresources.com/wp-conten...
‘A trailing event with magnitude >0.5 ML will require a well integrity check be performed and reported in the same manner as those events detected while pumping is taking place’.

Well Integrity Testing at Preston New Road
7) Please confirm who is checking the well integrity onsite?
Is it Cuadrilla, or their contractor (eg Schlumberger ), or another agency?

8) Please state 'yes' or 'no' if the well integrity was checked after each of the seismic events measured at or above 0.5ML during pumping:
• 0.48 ML on Wednesday 24th October
• 0.8 ML on Friday 26th October
• 0.8 ML on Saturday 27th October (deemed a trailing event by Cuadrilla)
and 1.1 ML on Monday 29th October
and provide the time of the testing along with a copy of each report.

9) Please provide a copy of all written communications from Cuadrilla to HSE from 22nd October 2018- 29th October 2018, to include a copy of all daily reports/ other reports made to HSE.

As each of these questions is numbered, I would be grateful if you could respond to each of these questions, utilising the same numbers for ease of reading.

I understand that all the documents I have requested are documents that relate to either your regulatory position, or documents that the operator should have provided you with at the time you receive this, as per their duties.
Should the operator have failed to do this completely, please advise me of this rather than delay the whole request; I am happy to accept any documents as additional responses.

Yours faithfully,

Helen Chuntso

Health and Safety Executive

Thank you for emailing the Health and Safety Executive. This is an automatic acknowledgement to tell you we have received your email.

Please note this email account is for the submitting of FOI requests via the 'whatdotheyknow' website only. For all other FOIs requests please refer to http://www.hse.gov.uk/foi/your-right-to-...

HSE publishes a comprehensive range of information and guidance on our website. You can find out what the health and safety law requires by searching under the relevant topic or industry section, and all of our publications are free to download. HSE does not operate a telephone helpline for general health and safety information. If you need to engage the services of a health and safety consultant, you may wish to visit the Occupational Safety and Health Consultants Register (OSHCR).

If your email is a request for advice, please visit http://www.hse.gov.uk/contact/informatio...

If your email is about a concern, please visit http://www.hse.gov.uk/contact/complaints...

If you wish to report an incident, please visit http://www.hse.gov.uk/riddor/index.htm

Thank you for contacting the Health and Safety Executive.

Health and Safety Executive

Dear Helen

 

Environmental Information Request Reference No: 201810442

 

Thank you for your request for information about:

 

Seismic activity at Preston New Road and well integrity – tests and
reporting in October 2018

 

Your request was received on 29 October 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

 

 

show quoted sections

 

 

References

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

Health and Safety Executive

Dear Helen

 

Environmental Information Regulations Request Reference No: 201810442

 

Further to your request for information under the Environmental
Information Regulations, which was received on 30 October 2018 by the
Health and Safety Executive (HSE), I am writing to let you know that the
time limit for response needs to be extended.

 

Although the Regulations normally require us to send a response within 20
working days, it is sometimes necessary to extend this limit in certain
circumstances.

 

In this case we will need to extend the response deadline by a further 20
working days because of the complexity of your request and the need to
consider the public interest

 

I hope to let you have a response by 24 December and I would like to
apologise for any inconvenience this delay may cause. In the meantime, if
you have any queries about this letter please contact me quoting the
reference number above.

 

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: [1][email address]

Website: [2]http://www.informationcommissioner.gov.uk

 

Yours sincerely

 

Dave

 

Dave Salmon / OSDR Competent Authority Office / 

Energy Division ED7.1

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

 

 

show quoted sections

 

 

References

Visible links
1. mailto:[email address]
2. http://www.informationcommissioner.gov.uk/

Dear Health and Safety Executive,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Health and Safety Executive's handling of my FOI request 'Seismic Activity at Preston New Road and Well Integrity -Tests and Reporting in October 2018'.

Or alternatively, please respond to the questions.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/s...

Yours faithfully,

Helen Chuntso

Health and Safety Executive

Thank you for emailing the Health and Safety Executive. This is an automatic acknowledgement to tell you we have received your email.

Please note this email account is for the submitting of FOI requests via the 'whatdotheyknow' website only. For all other FOIs requests please refer to http://www.hse.gov.uk/foi/your-right-to-...

HSE publishes a comprehensive range of information and guidance on our website. You can find out what the health and safety law requires by searching under the relevant topic or industry section, and all of our publications are free to download. HSE does not operate a telephone helpline for general health and safety information. If you need to engage the services of a health and safety consultant, you may wish to visit the Occupational Safety and Health Consultants Register (OSHCR).

If your email is a request for advice, please visit http://www.hse.gov.uk/contact/informatio...

If your email is about a concern, please visit http://www.hse.gov.uk/contact/complaints...

If you wish to report an incident, please visit http://www.hse.gov.uk/riddor/index.htm

Thank you for contacting the Health and Safety Executive.

Health and Safety Executive

1 Attachment

Dear Helen

 

Environmental Information Regulations Reference No: 201810442

 

Thank you for your request for information about:

 

Seismic activity at Preston New Road and Well Integrity Tests and
Reporting in October 2018

 

Your request was received on 29 October 2018 and I am dealing with it
under the terms of the Environmental Information Regulations 2004. Please
accept my apologies for the significant delay in responding to you. I have
answered each of your questions in turn below.

 

Regulatory role of HSE

 

1) i) Is the HSE monitoring the operations at Preston New Road in real
time? if yes,

ii) what job position is undertaking this task?

iii) by what system?

 

It is the operator’s responsibility to monitor operations at Preston New
Road. HSE ensures that risks are properly managed and that operators
comply with their legal duties in respect of those risks.

 

2) Once hydraulic fracturing has commenced:

i) please provide a document/ correspondence or link explaining the HSE
regulatory position regarding the role of the

•             HSE

•             And/ or the Independent Well examiner

in checking the well integrity.

ii) is there a requirement for HSE/ independent Well examiner to make a
site visit? If so, please state the date(s) of the visit(s) to Preston New
Road by HSE and/ or the Independent Well examiner.

iii) Please confirm if a desktop examination of data sent by the operator
to HSE is adequate to examine well integrity.

 

HSE’s ‘Shale gas and oil guidance for planners’ document explains most
aspects of HSE’s regulatory role in this area, and is located on our
website at [1]http://www.hse.gov.uk/offshore/shale-gas...

The Independent Well Examiner is neither an inspector nor a regulator but
performs an important quality control role for the operator. The Offshore
Installations and Wells (Design and Construction, etc) Regulations 1996
(DCR) require the well operator to set up a well examination scheme and
appoint a well examiner. This provides an extra independent verification
to ensure they are complying with the law. The well examination scheme is
for the complete lifecycle of the well, from design through to
abandonment.

The well operator must send the following documents to the independent
well examiner:

o the well construction programme and any material changes to it;
o reports on how the well is being constructed;
o reports on how the well is being monitored;
o at the end of the well’s life, a plan for how it will be plugged and
decommissioned.

 

The independent well examiner reviews these documents to ensure the well
is designed, constructed and operated as required by the regulations, in
line with the well operator’s policies and procedures, and following
industry good practice.

The independent well examiner may also undertake site visits to check the
progress of the work. This will allow them to examine well integrity and
fracturing operations in real time, especially during the early stages of
a development, to provide a further level of independent assurance.

HSE makes site visits based on the level of risk or after notification of
a reportable incident, depending on the circumstances.

Since 2012 we have had a Working Together Agreement
([2]https://www.hse.gov.uk/aboutus/howwework...)
in place with the Environment Agency that commits us to joint inspections,
and states:

 

“ For new and first time shale gas operators we will:

o meet and advise them of their duties under the relevant legislation
o conduct a joint inspection of the key operations, including:

o cementing and verification of cement
o mini hydraulic fracture 
o bleed back
o main hydraulic fracture

 

“These meetings and visits may include other licensing or statutory bodies
as appropriate. Any change to the process, such as hydraulic fracturing at
shallow depth or change of fracturing media may result in reviewing this
inspection schedule and may require permit modifications.”

 

3) Please answer ‘yes’ or ‘no’ to this question.

Is there a requirement to run a Cement Bond Log Test for EVERY time the
Seismic activity is measured at or above 0.5ML?

 

No. This is a decision for the well operator to make in order to ensure
well integrity for the life cycle of the well. The operator of an oil or
gas well is required to ensure that there is no unplanned release of
fluids from the well, so far as is reasonably practicable, throughout its
lifecycle (from construction to decommissioning). There are several
methods for testing the integrity of the well. The method used would
depend on the level of risk and any identified issues. There is no
legislative requirement for the operator to perform a ‘cement bond log’ if
0.5m[L] is exceeded.

 

4) Is there a requirement for HSE/ independent Well examiner to make a
site visit after seismic events at or greater than 0.5ML? If so, please
state the dates of these visits to Preston New Road by HSE and/ or the
Independent Well examiner.

 

There is no requirement for HSE to make a site visit after events at or
greater than 0.5M[L]. As we have explained in previous correspondence with
you, the operator is responsible for identifying and managing the health
and safety risks throughout the lifecycle of an oil and gas well. Please
see regulation 7 of the Borehole Sites and Operations Regulations 1995 for
further information.  

The operator is responsible for all activity on the well, not the
independent well examiner nor HSE. Any requirement for well integrity
testing following seismic activity is for the operator to determine, not
HSE, as the operator has the legal duty to maintain well integrity. 

 

5) Which of the following methods are permissible to satisfy the HSE that
well integrity has been checked?  Please state 'yes' or 'no' for EACH of
the following procedures, and if any require additional measurements to be
undertaken:

•             Checking the annular pressure at the surface

•             Pressurising the well with liquid nitrogen and checking for
loss

•             Running a Cement Bond Log

•             As is stated in 
[3]https://cuadrillaresources.com/wp-conten...

if a ‘vibration monitoring array’ be utilized to assess the impact.

 

Please refer to the answer to question 3 above. There are several methods
for testing the integrity of the well, the method used will depend on the
level of risk and any identified issues.

 

6)  I refer to the following document available at
[4]https://cuadrillaresources.com/wp-conten...
p23

i) Please state if HSE require the operator to provide them with Well
Integrity testing after any seismic events occurring during pumping which
have occurred within the 'amber zone' 0.0Ml- 0.5ML;

ii) Please state if HSE require the operator to provide them with Well
Integrity Testing after any seismic events occurring during 'trailing
events' where seismic activity 0.5ML: 

[5]https://cuadrillaresources.com/wp-conten...

‘A trailing event with magnitude >0.5 ML will require a well integrity
check be performed and reported in the same manner as those events
detected while pumping is taking place’.

 

HSE does not set prescriptive thresholds and targets beyond the
requirement that operators must ensure there is no unplanned release of
fluids for the lifetime of the well. Operators should be monitoring well
integrity constantly, and must be aware of the status and condition of the
well at all times. It is therefore for operators to determine their own
thresholds for intervention and to decide when integrity testing is
needed, in addition to normal industry guidance, by using a variety of
resources.

HSE would only intervene if an operator was seen to be (or prior to)
carrying out activities that were potentially unsafe following any
incident or unplanned event.

Well Integrity Testing at Preston New Road

 

7) Please confirm who is checking the well integrity onsite?

Is it Cuadrilla, or their contractor (eg Schlumberger), or another agency?

 

It is the operator’s responsibility; and that applies whether they appoint
a contractor or not.

 

8) Please state 'yes' or 'no' if the well integrity was checked after each
of the seismic events measured at or above 0.5ML during pumping:

•               0.48 ML on Wednesday 24th October

•               0.8 ML on Friday 26th October

•               0.8 ML on Saturday 27th October (deemed a trailing event
by Cuadrilla)

and 1.1 ML on Monday 29th October and provide the time of the testing
along with a copy of each report.

 

I can confirm that the Health and Safety Executive holds the following
information:

 

 1. TLS Report PNR1z Trailing Event 27/10/18 issued 28/10/18
 2. TLS Report PNR1z Final Report 29/10/18 issued 29/10/18
 3. Morning Report PNR1z 29/10/18 issued 30/10/18

 

9) Please provide a copy of all written communications from Cuadrilla to
HSE from 22nd October 2018- 29th October 2018, to include a copy of all
daily reports/ other reports made to HSE.

 

I can confirm that the Health and Safety Executive holds the following
information:

 

 4. Email from Cuadrilla to HSE dated 30/10/18 and attachment

Information numbered 1 - 4 can be partially disclosed to you and copies
are attached. Personal data is being withheld by virtue of regulation 13.

 

Information that would identify the location of seismic monitoring array
is being withheld by virtue of regulation 12(5)(g) – protection of the
environment. This is a qualified exception and is subject to the public
interest test.

I have taken the following factors into account in favour of disclosure:

 

o Disclosure would benefit public understanding of the environmental
monitoring being undertaken at this site.
o This site is subject to legitimate public interest and there are
genuine public concerns about the safety of fracking operations taking
place at Preston New Road.

I have taken the following factors into account in favour of non
disclosure:

 

o There is a likelihood of equipment being damaged and HSE has received
evidence of previous criminal damage in respect of this site.
o Damage to 3^rd party property hosting monitoring equipment is also
likely.
o Monitoring of the site is necessary for the protection of the
environment and for human health and safety.

Without being able to detect seismic events there is an increased risk to
the integrity of the wells at this location and I believe that the balance
of the public interest favours withholding this information for the
protection of the local environment, workers at the site, and members of
the wider public likely to be affected by any environmental incident.

 

The information supplied to you continues to be protected by the
Copyright, Designs and Patents Act 1988. You may re-use this information
(not including logos) free of charge in any format or medium, under the
terms of the Open Government Licence. To view this licence, visit
[6]http://www.nationalarchives.gov.uk/doc/o... or
write to the Information Policy Team, The National Archives, Kew, London
TW9 4DU, or e-mail: [7][email address].

 

Information you receive which is not subject to Crown Copyright continues
to be protected by the copyright of the person, or the organisation, from
which the information originated. You must ensure that you gain their
permission before reproducing any third party (non Crown Copyright)
information.

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: [8][email address]

Website: [9]http://www.informationcommissioner.gov.uk

 

Yours sincerely

 

Dave

 

Dave Salmon / OSDR Competent Authority Office / 

Energy Division ED7.1

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

 

 

show quoted sections

 

 

References

Visible links
1. http://www.hse.gov.uk/offshore/shale-gas...
2. https://www.hse.gov.uk/aboutus/howwework...
3. https://cuadrillaresources.com/wp-conten...
4. https://cuadrillaresources.com/wp-conten...
5. https://cuadrillaresources.com/wp-conten...
6. http://www.nationalarchives.gov.uk/doc/o...
7. mailto:[email address]
8. mailto:[email address]
9. http://www.informationcommissioner.gov.uk/