Operating responsibly
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Committed to the highest standards
Egdon Resources plc wishes to build value through developing sustainable long-term relationships with all stakeholders and is committed to the highest standards of health, safety and environmental protection. These aspects command equal prominence with other business considerations.
The onshore oil and gas industry has an excellent record in relation to health and safety and environment protection.
Well integrity
The integrity of a well is the industry’s highest priority, and here in Britain we have a unique well examination scheme that was set up so that independent, specialist experts could review the design and construction of every new well. This is a legislative requirement regulated by the Health and Safety Executive. The method and verification of well construction is vital to ensure that any freshwater aquifers are isolated and protected from wellbore fluids or deeper horizons, and to ensure that there can be no unplanned escape of fluids from the well itself. This statement applies equally to conventional as well as unconventional wells.
The well design and construction process is conducted in accordance with industry best practice and guidelines, independent third party scrutiny and a regulatory regime that is considered a global exemplar and presided over by NSTA, HSE and the Environment Agency. Onshore well integrity in Britain follows the same stringent guidelines as for the offshore industry.
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Groundwater protection
We understand that as a company we are involved in production of fluids that have the potential to cause pollution if not managed correctly, and it’s always our aim to ensure that we put in place robust measures to prevent our activities having any impact on the local environment. There are stringent regulations on environmental protection enforced by the regulatory authorities, and so the principle for us is to establish very high levels of environmental mitigation built in to the design and construction of a site before any activities (including drilling) take place.
Before a new site is built, data and information is evaluated to determine whether there are shallow groundwaters beneath a proposed site location that are classed as aquifers or contribute or feed to usable water supplies. The Environment Agency usually classify usable groundwaters as being those within source rocks up to 400m depth from surface.
We use impermeable membranes to line our sites. These membranes provide "tertiary containment" and are installed to prevent any potential for contaminants to percolate down through soils into groundwater aquifers. This is the mechanism installed as a “failsafe” in the event of the failure of the primary and secondary containment systems, or to cater for any minor spillages on the site area itself. Primary containment is the equipment that directly contains the materials being stored or transported, such as storage tanks and secondary containment is the area immediately around those containers such as concrete or masonry bunds which are designed to hold fluids if a storage tank fails or overfills.
When drilling, water-based non-hazardous drilling fluids are used when drilling through any aquifer sections, and the make-up of these fluids has to be formally assessed by the Environment Agency to ensure that they will not have any detrimental impact. Steel pipes known as casings, are installed as described within the “How we construct a well” section to provide a multi-layered barrier to protect near-surface groundwater from any fluids used within the wellbore during the drilling of deeper sections, or during the testing and production phases where hydrocarbons (oil and gas) are recovered to surface.
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Monitoring
It’s vital that we have processes in place to demonstrate the effectiveness of the measures taken to protect groundwater.
We commission specialist environmental consultants to develop groundwater monitoring plans, whereby boreholes are installed on site to enable sampling and analysis of shallow groundwater. Usually, these are installed before any drilling starts, in order to obtain a baseline for the water quality, and then ongoing analysis of groundwater continues through all of the operational phases to compare water quality data against the baseline. The water quality parameters and the design of the boreholes themselves are subject to Environment Agency review and approval, who also review the results of the analysis.
This process means that we can check that our operations are not having any detrimental impact on shallow groundwater.
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Regulation
The onshore oil and gas industry is regulated by a number of statutory bodies including the Environment Agency (EA) in England, Scottish Environment Protection Agency (SEPA) in Scotland and Natural Resources Wales (NRW) in Wales, Health and Safety Executive (HSE) and the Department for Business, Energy and Industrial Strategy (BEIS).
Onshore oil and gas regulation in the UK has been recognised as an exemplar by the rest of the world.
In addition the industry is governed by 14 separate pieces of European legislation.
Who is responsible for what?
Under the Petroleum Act of 1998, the Crown has all ownership rights to hydrocarbon resources in the UK. Responsibility for administration on behalf of the Crown falls to the Secretary of State for the Department for Business, Energy and Industrial Strategy (BEIS).BEIS issues a ‘Petroleum Exploration and Development Licence’ (PEDL), which gives a company or group of companies (a joint venture) exclusive rights to explore for, and develop, the resource in a particular defined area.
The role of Environment Regulation is handled by the Environment Agency (EA) in England, Natural Resources Wales (NRW) in Wales and the Scottish Environment Protection Agency (SEPA) in Scotland.
In England & Wales, onshore oil and gas exploratory activities require environmental permits issued under the Environmental Permitting Regulations (EPR2016) and other permissions from the Environmental Regulator, depending on the methods used and the geology of the site.The Environmental Regulator is also a statutory consultee during planning applications conducted by the MPA and also in the assessment of the Environmental Impact Assessment if this is required.
The Health and Safety Executive (HSE) monitors oil and gas operations from a well integrity and site safety perspective. It ensures that safe working practices are adopted by onshore operators as required under the Health and Safety at Work etc Act 1974, and regulations made under the Act.
The HSE works closely with the environment regulator and the Department for Business, Energy and Industrial Strategy to share relevant information on such activities and to ensure that there are no material gaps between the safety, environmental protection and planning authorisation considerations, and that all material concerns are addressed.
Minerals Planning Authorities (as part of local councils) grant planning permission for the location of any wells and well sites, and impose conditions to ensure that the impact on the use of the land is acceptable.
The planning system controls the development and use of land in the public interest. This includes ensuring that any new development is appropriate for its location. This takes into account the effects (including cumulative effects) of potential pollution on health, the natural environment or general amenity. In doing so the focus of the planning system is on whether the application is an acceptable use of the land, and the impacts of those uses. Any control processes, health and safety issues or emissions themselves are then subject to the approval of the other regulators mentioned above.
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