Dear Health and Safety Executive,

As the body responsible for the integrity of fracking wells, what steps have you taken, or intend to take, to prevent the vertical migration to surface land and waterways of toxic gases and fluids released (but not harvested) during the fracking process via conduits and pathways presented by :-
(a) capped fracking wells, when over time steel casings will corrode and concrete linings shrink and crack, and
(b) around the head of disused conventional oil and gas wells located near to a fracking well?

Yours faithfully,

John Wilkinson

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 Mr Wilkinson

 

Environmental Information Request Reference No: 201706068

 

Thank you for your request for information about:

 

As the body responsible for the integrity of fracking wells, what steps
have you taken, or intend to take, to prevent the vertical migration to
surface land and waterways of toxic gases and fluids released (but not
harvested) during the fracking process via conduits and pathways presented
by :-

(a) capped fracking wells, when over time steel casings will corrode and
concrete linings shrink and crack, and

(b) around the head of disused conventional oil and gas wells located near
to a fracking well?

 

Your request was received on 5 June 2017 and I am dealing with it under
the terms of the Environmental Information Regulations 2004.

 

You will know from previous correspondence with HSE that it is a key duty
of the well operator to maintain well integrity, ensuring the health and
safety of people and protecting the environment. Therefore, health and
safety regulations require well operators to design, construct, operate
and abandon the well in such a way that there can be no unplanned release
of fluids for its entire life cycle. The operator must design the well in
such a way that it can be safely decommissioned and abandoned.

 

The legal responsibility for ensuring public safety lies with the operator
of the well - HSE uses its regulatory powers to ensure well integrity is
sound, and safe working practices are adopted by operators.

 

Wells drilled to explore for shale oil or gas are designed and constructed
to the same standards as conventional oil and gas wells that have been in
operation in UK for a number of years. There have been 350 onshore oil and
gas wells drilled in the UK since 2000. All wells must be constructed in
line with recognised industry good practice (those established by UK
Onshore Oil and Gas; and Oil and Gas UK) and are cased using steel and
cement to ensure there is no unplanned release of fluids, so far as is
reasonably practicable. Near the surface, where there is nearby
groundwater, or an aquifer, there are normally three layers of this steel
casing. The operator will conduct a range of checks on the well to test
for leaks. Suitable well control equipment must also be provided to
protect against unintentional and uncontrolled release of material from
the well.

 

The operator must agree restoration and aftercare of the site with the
local planning authority. They must also send a notification to HSE before
well abandonment takes place, detailing their proposals for sealing and
abandoning the well. This abandonment notification is scrutinised by HSE
inspectors to ensure that the decommissioning work fulfils the
requirements of the regulations and meets industry good practice. This is
done by blocking the well for hundreds of feet with large volumes of
cement set within and outside the steel casing. During this work, the
operator has a duty to update HSE each week so that activity can be
checked against the plan set out in the notification. If HSE has any
concerns, inspectors will take appropriate regulatory action.

 

If the well is decommissioned to the industry good practice there should
be no release of fluids from it. HSE specialist inspectors scrutinise the
decommissioning process to ensure the correct industry process and good
practice are adhered to and the operator is complying with legal
requirements that there should be no escape of fluids from it, or from the
reservoir to which it is attached, so far as is reasonably practicable. If
there is no escape of fluids from the well or the reservoir post
abandonment, it is difficult to see how other wells nearby could be
impacted.

 

The operator remains responsible for the well post-abandonment. HSE would
only become involved if there was an issue with the well that constituted
a risk to people’s health and safety.

 

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
[1]http://www.nationalarchives.gov.uk/doc/o... or
write to the Information Policy Team, The National Archives, Kew, London
TW9 4DU, or e-mail: [2][email address].

 

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

 

David Salmon

FOI Officer

 

show quoted sections

 

 

References

Visible links
1. http://www.nationalarchives.gov.uk/doc/o...
2. mailto:[email address]
3. mailto:[email address]
4. http://www.informationcommissioner.gov.uk/

Dear Health and Safety Executive,

Thank you for your response dated 6th July 2017.

Although the figure of 350 oil and gas wells drilled since 2000 is impressive, can you please confirm that only one of these involved fracking (at Preese Hall), and that it had to be shut down for safety reasons?

Can you please also explain your meaning of the phrase “as far as is reasonably practicable” which you used twice in relation to unplanned release of fluids?

I live near to the old Formby oilfield, which was abandoned in 1965, and there is a prospect of siting a fracking well in the near vicinity - hence part (b) of my FOI request. Can you therefore please confirm that your controls and procedures will take account of the potential release of migrant fracking fluids through these disused oil wells, which are unlikely to have been capped in accordance with current standards?

Yours faithfully,

John Wilkinson

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 Mr Wilkinson,

Environmental Information Request Reference No: 201707365

Thank you for your additional questions following on from your original request EIR 201706068 including your concern over prospect of fracking site near an old Formby oilfield. As your previous request has now been closed, we are treating this as a new EIR case, EIR 2017073665.

Your request was received on10th July 2017 and we are 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 & Safety Executive deals with requests under the Freedom of Information Act and Environmental Information Regulations can be found on the HSE website at 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

Elspeth More

[FOI Officer]

show quoted sections

Health and Safety Executive

Dear Mr Wilkinson

 

Environmental Information Regulations Reference No: 201707365

 

Thank you for your additional questions following on from your original
EIR request including your concern over the prospect of fracking near an
old Formby oilfield.

 

1.       Although the figure of 350 oil and gas wells drilled since 2000
is impressive, can you please confirm that only one of these involved
fracking (at Preese Hall), and that it had to be shut down for safety
reasons?

 

HSE response - Fracturing of some description has been used in UK wells
for decades as part of attempts to keep wells productive and improve flow
rates. The technique has been used in the North Sea since the 1970s and
low volume fracturing has also been used at Wytch Farm in Dorset, which is
Europe’s largest onshore oil field. Changes in technology now mean that
modern methods involve use of water at high pressure to achieve fracturing
of an impermeable rock formation in order to release the hydrocarbons in
it. This method was used at Preese Hall.

 

The well at Preese Hall was not shut down for safety reasons. The decision
was taken by the operator.

 

HSE inspection activity following the earth tremors found no evidence of
an unplanned release of fluids from the Preese Hall well that could affect
the health and safety of people on or near the site, or the environment.
This inspection activity included two onsite inspections of the Preese
Hall well site by specialist well inspectors, one of which was undertaken
jointly with the Environment Agency (EA). The EA also conducted their own
inspection activity and a British Geological Survey (BGS) study confirmed
the findings. The BGS study found that the casing in a redundant part of
the well (below the casing perforations) was ovalised at the time of the
seismic tremors. There was no indication that this presented a risk to
well integrity and there was no similar effect in the casing sections
higher up the well that are critical to well integrity and preventing the
escape of fluids.

 

As the well was being decommissioned a separate issue with regard to a
pressure increase in the annulus (the gap between the well casings) was
identified. The pressure increase was well within the design parameters of
the well. Pressure increases like this are a known issue in some wells and
so operators have procedures in place to manage the situation.  The
operator agreed remedial action with HSE and this was implemented as part
of the activity to seal and abandon the well. Again there was no loss of
well integrity.

 

The well has been sealed and abandoned in accordance with the provisions
of the Offshore Installations and Wells (Design and Construction)
Regulations 1996. This means that the well must be abandoned in such a way
that there can be no escape of fluids from it or the reservoir to which it
is attached, so far as is reasonably practicable, and  in accordance with
industry standards.

 

 

2.       Can you please also explain your meaning of the phrase “as far as
is reasonably practicable” which you used twice in relation to unplanned
release of fluids?

 

HSE response - The phrase ‘reasonably practicable’ (‘as low as reasonably
practicable’[ALARP] or ‘so far as is reasonably practicable’ [SFAIRP]) is
absolutely central to the British health and safety system as enshrined in
the Health and Safety at Work etc Act 1974.

 

It describes the level to which we expect to see workplace safety
controlled and is about balancing the risk against the sacrifice needed to
further reduce it. The decision is weighted in favour of health and safety
because the presumption is that the dutyholder (the operator) should
implement the risk reduction measure. To avoid having to make this
sacrifice, the dutyholder must be able to show that it would be grossly
disproportionate to the benefits of risk reduction that would be achieved.
Thus, the process is not one of balancing the costs and benefits of
measures but, rather, of adopting measures except where they are ruled out
because they involve grossly disproportionate sacrifices. A simple example
might be:

 

·         To spend £1m to prevent five staff suffering bruised knees is
obviously grossly disproportionate; but

·         To spend £1m to prevent a major explosion capable of killing 150
people is obviously proportionate.

Here is an explanation of the term from HSE’s website:
[1]http://www.hse.gov.uk/risk/theory/alarpg...

 

3.       I live near to the old Formby oilfield, which was abandoned in
1965, and there is a prospect of siting a fracking well in the near
vicinity - hence part (b) of my FOI request. Can you therefore please
confirm that your controls and procedures will take account of the
potential release of migrant fracking fluids through these disused oil
wells, which are unlikely to have been capped in accordance with current
standards?

 

HSE response - The regulations are clear that it is the operator’s
responsibility and legal duty to assess the risks and to put into place
suitable control measures.

 

No operator can commence work on a well without notifying HSE, in
accordance with the Borehole Sites and Operations Regulations 1995 (BSOR).
Among other things the notification must contain details of the precise
location of the top of the well, its directional path, the terminal depth
and location, and its position and that of nearby wells and mine workings
in relation to one another.

 

In the case of a well, operators must pay particular attention to details
of the geological strata and fluids within them through which it may pass
and of any hazards that could cause fire, explosion or blowout. The
notification must also describe the procedures for effectively monitoring
the direction of the borehole and the effects of intersecting nearby
wells.

 

Any material changes to previously notified details must be notified to
HSE.

 

In addition, the Offshore Installations and Wells (Design and
Construction, etc) Regulations 1996 (DCR), which apply both onshore and
offshore, require operators to take all appropriate steps to obtain
predictions of the sub-surface environment which can be expected in the
well. These should be as accurate as possible, and where information is
limited they should identify potential ‘worst case’ conditions. These
steps will help to ensure that the design of the well and the plan of work
for any operations reduce the risks to people to as low as reasonably
practicable.

 

So far as is reasonably practicable, all potential hazards and
circumstances likely to lead to unsafe well conditions should be
identified by the well-

operator, including not only formations which may pose a hazard directly,
but also those which may affect the ability to control a hazardous
situation (such as potential loss zones, zones with the potential for
causing stuck pipe, and over-pressured plastic salt formations etc).

 

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: [2][email address]

Website: [3]http://www.informationcommissioner.gov.uk

 

Yours sincerely

 

Elspeth More

FOI Officer

 

 

 

Elspeth More |  Administrative Manager | Energy Division

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

(: 020 3028 1511 (Ext 1511 if VOIP)

7: 01224 252555 (Fax)

*: [4][email address]

 

 

 

 

References

Visible links
1. http://www.hse.gov.uk/risk/theory/alarpg...
2. mailto:[email address]
3. http://www.informationcommissioner.gov.uk/
4. mailto:[email address]

Dear Health and Safety Executive,

Thank you for your response dated 8th August to my three clarification questions.

I note your further comments about the length of time that fracturing has been used in UK oil and gas wells. However, I would ask you to confirm the number of wells in the UK which have so far employed unconventional vertical and lateral drilling and hydraulic fracturing in order to obtain shale gas?

I followed the link you provided for an explanation of the term 'reasonably practicable'. Can you confirm however that it largely refers to workplace safety, and does not anticipate the impact on the wider community (and its residents) that fracking might have in terms of fugitive emissions, seismic events, air and water pollution etc.?

I note also your comments in relation to the old Formby oilfield. Frankly however, I cannot understand how the 1995 Regulations have relevance to oil wells which were dug between 1939 and 1965. Can you therefore give an assurance that precise information is available to a potential fracking operator about the location, direction and depth of these old workings?

Yours faithfully,

John Wilkinson

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 Mr Wilkinson,

Environmental Information Request Reference No: 201708235

Thank you for your additional questions following on from your last request EIR 201707365. As your previous request has now been closed, we are treating this as a new EIR case, EIR 201708235.

Your request was received on 14th August 2017 and we are 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 & Safety Executive deals with requests under the Freedom of Information Act and Environmental Information Regulations can be found on the HSE website at 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

Elspeth More

[FOI Officer]

Elspeth More |  Administrative Manager | Energy Division
Health & Safety Executive, Lord Cullen House, Fraser Place, Aberdeen, AB25 3UB 
: 020 3028 1511 (Ext 1511 if VOIP)
: 01224 252555 (Fax)
0: [email address]
 

Health and Safety Executive

Dear Mr Wilkinson

 

With regard to your latest request, I am writing to advise that the
deadline has been extended to 28/09/17.  We will endeavour to get your
response to you as soon as possible.

 

Apologies for the delay,

 

Regards

 

Elspeth

 

 

Elspeth More |  Administrative Manager | Energy Division

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

(: 020 3028 1511 (Ext 1511 if VOIP)

7: 01224 252555 (Fax)

*: [1][email address]

 

 

 

 

References

Visible links
1. mailto:[email address]

Health and Safety Executive

Dear Mr Wilkinson

 

Environmental Information Request Reference No: 201708235

 

Thank you for your request for information about UK oil and gas wells.

 

Your request was received on 14 August 2017 and I am dealing with it under
the terms of the Environmental Information Regulations 2004.

 

I have taken each of your comments in turn.

 

I note your further comments about the length of time that fracturing has
been used in UK oil and gas wells. However, I would ask you to confirm the
number of wells in the UK which have so far employed unconventional
vertical and lateral drilling and hydraulic fracturing in order to obtain
shale gas?

 

There are no wells that have employed ‘unconventional vertical and lateral
drilling and hydraulic fracturing’. The term unconventional is used to
describe the ‘tight’ reservoir formations such as shale that the methane
gas can be extracted from. The term ‘unconventional’ is used as unlike
‘conventional’ reservoir formations such as lime stone or sand stone,
tight reservoir formations do not yield the gas without some sort of
stimulation i.e. hydraulic fracturing. This technique has been used for
some time both onshore and offshore in the UK. However, only one well has
targeted a shale reservoir formation and hydraulically fractured that
formation. 

 

I followed the link you provided for an explanation of the term
'reasonably practicable'. Can you confirm however that it largely refers
to workplace safety, and does not anticipate the impact on the wider
community (and its residents) that fracking might have in terms of
fugitive emissions, seismic events, air and water pollution etc.?

 

The health and safety regulations are primarily aimed at preventing death,
injury and ill health in both the workforce and others who could be
affected by the work activity (i.e. people living or working near the
workplace). However, the central requirement on the well operator to
design, construct, operate, maintain and decommission the well in such a
way that there is no unplanned release of fluids from it, so far as is
reasonably practicable, and that the risks to the health and safety of
persons from it or anything in it, or in strata to which it is connected,
are as low as is reasonably practicable, will also offer environmental
protection in the form of preventing fugitive emissions, air and water
pollution. This is why the HSE and Environment Agency work together to
regulate the onshore oil and gas industry. 

 

I note also your comments in relation to the old Formby oilfield.  Frankly
however, I cannot understand how the 1995 Regulations have relevance to
oil wells which were dug between 1939 and 1965. Can you therefore give an
assurance that precise information is available to a potential fracking
operator about the location, direction and depth of these old workings?

 

It is for the operator to establish the risk of connection with existing
oil or gas wells and other underground workings. The operator can draw
information on the location of other wells from a number of sources
including the Oil and Gas Authority and the British Geological Survey. If
they are not sure about the precise location of an existing well they will
need to take this into account in planning the location and direction of
their borehole and take appropriate measures to ensure contact is
prevented. This information will be scrutinised by HSE prior to drilling
taking place to ensure that the requirements of the health and safety
regulations are satisfied.

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: [1][email address]

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

 

Yours sincerely

 

David Salmon

FOI Officer

 

 

 

References

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

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