Angus Energy want to transport an undefined amount of low-level radioactive waste from their Lidsey site, 40 mies away, to re-inject at Brockham.  The consultation ends Nov 4th and you can respond online via the EA website: RH3 7AU, Angus Energy Weald Basin No 3 Limited, EPR/RB3994DK/V002: environmental permit consultation – Environment Agency – Citizen Space (environment-agency.gov.uk)

We’ve written to object; our letter is below

A few points before you start:

a) It’s a VARIATION on the permit granted last year for Angus Energy to re-inject low-level radioactive waste FROM THEIR OWN SITE. Updated: Go ahead for waste reinjection at Angus Energy’s Brockham oil site – DRILL OR DROP?

They now want to transport waste from the Lidsey site, near Bognor, c 40 miles away. See Angus Energy seeks to import radioactive waste for disposal at Brockham – DRILL OR DROP?

b) It’s an Environment Agency permit, so different fom planning permission. Grounds for objection are on the EA wensite: RH3 7AU, Angus Energy Weald Basin No 3 Limited, EPR/RB3994DK/V002: environmental permit consultation – Environment Agency – Citizen Space (environment-agency.gov.uk)

c) THE CONSULTATION ENDS ON NOV 4TH. It’s esy to respond via their site (follow the link above) though the formatting needs to be checked  before you click that ‘Send’ button.

Here’s our response.  Feel free to use the info but please write in your own words or it won’t be counted.

 

RH3 7AU, Angus Energy Weald Basin No 3 Limited, EPR/RB3994DK/V002: environmental permit consultation

 

Dear Sirs,

We note the above application and that it is an application to re-inject fuels from the Lidsey site at PEDL 421 into the Brockham wellsite.

We recognise that the previous application to re-inject produced water from the Brockham site (PR/BL9763IN/V005) received 240 responses, many of them highly detailed, and have read your responses to them. Clearly you were satisfied that the matters raised would be adequately dealt with.

However, we feel that this application raises several issues on which we seek clarification and welcome your assistance on this. Most are related to the increased volumes of produced fluid and waste that will be dealt with at Brockham and the implications of this.  At present Lidsey is non-productive but Angus Energy have plans to change this (see 3i).

We wish to oppose this application as we consider that Lidsey has sufficient scope to re-inject on its own wellsite and we consider that this would be an unknown increase in volumes transported 40 miles and being stored for up to three months at the Brockham site.

To be more specific:

 

1.Limits on amount reinjected:

• There is no mention in the application of the amount of produced water from Lidsey which would be re-injected and you stipulated in your permission document for PR/BL9763IN/V005 that the maximum daily discharge volume for re-injection via BRX3 (W2) is 24 m3 /day at a maximum rate of 1.3 litres per second.
• What limits would you impose if this new permit is granted? Clearly there would be a huge increase in produced water.  At present Lidsey is non-productive but Angus Energy have plans to spud another well there and re-start other wells (see 3i).
• You wrote in your response to Brockham Parish Council: ‘The permitted groundwater activity is to re-inject a maximum of 24m3 of produced water per day into the Portland Sand Formation for production support. This is a minor volume of produced water that will be re-injected over a period of 7 hours per day. Hydrocarbons and produced water will be extracted from the Portland Sand Formation and produced water will be re-injected at a pressure below the fracture pressure of the formation. The operating procedures specified in the HRA will ensure that there will be no over pressurisation of the reservoir.’ What changes will there be in these requirements if the application is passed?
• Will you impose limits on the hours and days of the week worked?

 

2.Geology of Brockham:

• with the prospect of increased volumes being re-injected into the Portland Sandstone, Professor Smythe’s comments in Section 2 of his report submitted to you re the previous application to re-inject (attached) are particularly relevant. I refer you to pages 6-8, particularly the emphasis on the Brockham Fault. There was a spate of earthquakes in 2018-2019, some felt in Brockham. This points to an element of geological instability in the area.

 

3.Uncertainty about Lidsey.

• Angus Energy indicated in Dec 2021 that their plans for more drilling involve negotiation with IGas, owners of PEDL326 which adjoins their licence. Review of Lidsey oil field alters target location – DRILL OR DROP?  In RNS 1186U AE also mention ‘ low-cost options for remediation of the field’s productivity centre around the reuse, work-over or side-tracking of the existing wells’. However, we have heard nothing more about this or of any other plans for development.
• At present we understand that no oil is being produced at Lidsey.
• We note the application makes specific mention of re-injection from Lidsey. We wish to query whether it would be permitted for Angus Energy to accept produced water from other sites. If so, what limitations would be placed on this?

 

4.Routine checks by Angus Energy and the EA

• The proposal states that produced water will be taken from the Portland Sandstone and returned to similar in Brockham. Can you please comment on the checks that will be made to ensure it will come from the same reservoir? Or does Section 5d of their Application for an Environmental Permit Part RSR‐B4 cover this area?
• Section 5d states: ‘Produced water samples from aqueous waste to be injected into the well will be sent for radiochemical analysis (gamma spectroscopy) once per quarter. For any waste (solid or aqueous) which is to be transferred from the Brockham site for conditioning / treatment and or disposal, representative samples will be taken and sent for radiochemical analysis to enable waste categorisation to determine an appropriate disposal route.’ We think that quarterly inspection of aqueous waste is insufficient and there is no mention of the frequency of checks on waste transferred from Brockham.
• Does the EA have a role in the collection, analysis or monitoring of these checks? If not, who will monitor them?
• You mention elsewhere that the EA will conduct random inspections, unannounced, at least twice a year. In the light of the proposed increased use of the Brockham wellsite for re-injection, can you please confirm that this will take place, hopefully more often than twice a year?

 

5. Vehicle movements: We have not seen any information about the number and frequency of tankers required, or the routes. Is this within your remit? If so, please update us with this information.

 

• On-site storage facilities:
• Document Part RSR‐B4 , section 2d) states:  ‘radioactive waste generated from the production of oil will be accumulated briefly in a tank prior to either re-injection or transfer to a site permitted to take such waste’.
• We understand that radioactive waste in this context is drill cuttings, pipe scale + sludges, sediments and filters. Are we correct here?
• We note that ‘briefly’ is defined in Section 5a) ‘Radioactive waste may be accumulated for short periods (up to three months as existing standard rules permit enables) in order to allow for any delays in prior treatment before re-injection into the well or transfer of solid waste to a permitted site.’
• Section 5b)‘substances resulting from the operation of the production of oil will be stored in a dedicated storage tank within an existing CIRIA compliant bund. The waste will be disposed in the rock formation adjacent to the well bore as soon as practicable.’

Whilst we understand that this is a planning matter, it concerns us that the Brockham site will be used in this way for what, to us, is more than a brief period, ie up to 3 months. We assume that this happens at present as there is a compliant bund onsite and this must be standard procedure, but the prospect of a large increase in amounts of radioactive waste stored onsite is disturbing.

• We would also like to enquire how the ‘up to three months’ is calculated when it appears that the radioactive waste will be added to on a regular basis.
• Section 2e) states: ‘The aqueous waste (produced water) will be pumped directly from the vehicle container into injection well in accordance with the Brockham Water Injection Procedure – BRO-ANGPR-O0003-2’. Are we therefore correct in assuming that no storage will be needed for the produced water?

 

7. Other planning requirements: We have sought information from Surrey County Council as to whether Angus Energy have yet applied for the necessary permissions and will also be contacting the OGA re your comments in Angus energy’s original application about increased earthquake risk.

We look forward to reading your response to our many questions.

With kind regards,

(Mrs) Pat Smith

Dorking Climate Emergency