RE: Brockham/EA...27 Nov 2018 00:11
Its quite clear and translates into you can fix the problems on the list but you cant do ANYTHING on site that will create the need to treat the water whether drilled or contaminated run off until this has been applied for. Reading the bottom paragraph the company are more than aware of this and for reasons best known to them have failed to deal with it................. Incompetence!!!!
There are no groundwater activities authorised by this permit. Any reinjection of produced water and treated site surface water into borehole BRX3 will require a new application to be submitted to add this activity.
Final assessment of re-permitting for groundwater activity of re-injection of produced water We cannot progress the application for the groundwater activity for the reinjection of produced water into the Portland Sand Formation based on the information provided and therefore this groundwater activity for re-injection cannot be included in the environmental permit. If the operator wishes to carry out re-injection they will need to apply for a permit variation
, with the relevant details available, in line with the Onshore Oil and Gas Sector Guidance.We have explained this to the operator as part of the final determination.
Having assessed the information provided in the application it appears that there may be a risk to the ground water environment. As a result, after several requests for further information, and allowing additional time for further submissions, holding meetings with the applicant and their consultants and carefully reviewing the revised information,we have decided to remove the groundwater activity from the application.
No groundwater activity is allowed in the new environmental permit for this site. Any subsequent proposals
for a groundwater activity to re-inject produced water will require the applicant to apply for a variation to
their environmental permit.Having reviewed the information submitted in the September 2018 version
5of the HydrogeologicalRisk Assessment (HRA), in the light of the re-permitting process, we still had concerns regarding the proposals to continue re-injecting at this location using the existing well, infrastructure and the present procedures. The information required to complete an HRA to the correct standard for this site does not appear to exist at present. Our technical decision for removing the groundwater activity of re-injection is set out in more detail below