Legislation, Well integrity

“Dear Aunty, is well integrity properly regulated?”

Well, of course it is my dears – after all, this is the UK where we are inundated with legislation from Europe!

Let’s take a quick look at some of the key rules and what they protect, shall we?

Borehole Sites and Operations Regulations 1995

The first thing to note, cupcakes, is that despite repeated protestations to the contrary in some quarters, these rules apply specifically and only to onshore installations, as we can see in regulation 3 here:

3.—(1) These Regulations shall not apply to offshore installations or activities carried out from such installations.

Now, it is fair to say that at first glance, these regulations look like they are only there to protect workers. But have a look at regulation 8 cherubs, and you’ll see another very important duty:

Additional duties of the operator

8.—(1) The operator shall ensure that every workplace on a borehole site is designed, constructed, erected and maintained and has sufficient stability to afford adequate protection for employees and to withstand the environmental forces anticipated at the site.

Read that again – boreholes (or wells) must be built so they can withstand the environmental forces that are expected. So, my lovelies, you can see that these regulations also convey an important duty on operators that relates to well integrity, which in the case of shale gas will also extend to making sure they’re strong enough to put up with the hydraulic fracturing pressures etc.

The Offshore Installations and Wells (Design and Construction etc) Regulations 1996

Now, pumpkins, these regulations have a ghastly title that leads those with no experience of oil and gas to assume that they they only apply to offshore oil and gas operations, but that’s not true at all my lovelies (something good grammar and a simple comma after “Installations” and “Wells” might have prevented)

3.—(1) Subject to paragraphs (2) and (3), these Regulations shall apply—

(a)in Great Britain; and

(b)to and in relation to installations, wells and activities outside Great Britain to which sections 1 to 59 and 80 to 82 of the 1974 Act apply by virtue of articles 4(1) and (2)(b) and 5 of the 1995 Order.

(2) These Regulations shall apply to a well in Great Britain, and activities in relation to it, only if—

(a)it is drilled from an installation; or (emphasis added)

(b)it is drilled with a view to the extraction of petroleum.

(3) In paragraph (2) “petroleum” means any mineral oil or relative hydrocarbon and natural gas existing in its natural condition in strata, but does not include coal or bituminous shales or other stratified deposits from which oil can be extracted by destructive distillation.

Again, it sometimes helps to read these things through a couple of times to get a grasp of what they’re actually telling us (those pesky Government lawyers!) but it’s clear that these rules apply just as much to land-based drilling as they do to offshore activities. Only those with no experience of applying legislation like this would try to claim otherwise.

What duties do these regulations impose dears? Well, all sorts actually – too many for me to run through here! But here’s something that stands out:

General duty

13.—(1) The well-operator shall ensure that a well is so designed, modified, commissioned, constructed, equipped, operated, maintained, suspended and abandoned that—

(a)so far as is reasonably practicable, there can be no unplanned escape of fluids from the well; and

(b)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.

So, operators must take all reasonable precautions to prevent the escape of fluids from a well, and to prevent anything in the well or the rock it penetrates from harming the health and safety of persons – even after abandonment.

Which, in short, brings us back to the issue of well integrity cherubs.

Regardless of what some people would have us believe (see tweet from supposed expert Michael Hill, @FrackingRegs on Twitter) I think we can safely conclude that we do have regulations in place to ensure we’re all protected my dears. And, if you look at the number of onshore oil and gas wells that have been drilled in the UK so far, you’ll find we have a very good record of following these rules.

That’ll do for now – I’ve got some lovely scones baking my dears, and I’d hate for them to burn!

Until next time xxx

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