Bothamsall Waste Management Plan
HSE.PL.027
Rev.:
00
Date:
12/7/2016
IGas Energy PLC
HSE
PL
027
00
07/12/2016
Department
Document Type
Number
Rev
Date
HSE.PL.027
Bothamsall Waste Management Plan
Contents
1
Report Context ........................................................................................................................... 3
2
Introduction ............................................................................................................................... 3
2.1
Background ................................................................................................................................ 3
2.2
Scope of Document.................................................................................................................... 3
3
Site Description .......................................................................................................................... 3
3.1
General Site operations ............................................................................................................. 3
3.2
Waste Generating Activities ...................................................................................................... 4
3.2.1
Extractive Wastes from Production Activities ........................................................................... 4
3.2.2
Extractive Wastes from Well Intervention Activities ................................................................. 4
3.3
Waste Management Areas ........................................................................................................ 6
4
Waste Classifications and Quantities ......................................................................................... 7
4.1
Introduction ............................................................................................................................... 7
4.2
Extractive Wastes....................................................................................................................... 7
4.3
Non-Extractive Wastes............................................................................................................... 8
4.4
Arising Estimates ........................................................................................................................ 8
5
Waste Management and hierarchy compliance ........................................................................ 9
5.1
General....................................................................................................................................... 9
5.2
Excess Gas Flaring ...................................................................................................................... 9
5.3
Vented Gas ................................................................................................................................. 9
5.4
Well Completion Equipment...................................................................................................... 9
6
Environmental Risk Assessment .............................................................................................. 10
6.1
Original Permit Application ...................................................................................................... 10
6.2
H1 Risk Assessment.................................................................................................................. 10
6.3
OPRA ........................................................................................................................................ 10
6.4
H5 Site Condition Report ......................................................................................................... 10
7
Monitoring and accident/incident management .................................................................... 10
7.1
Monitoring and Recording ....................................................................................................... 10
7.2
Accident/Incident Recording ................................................................................................... 11
7.3
Reporting of Monitoring Results.............................................................................................. 11
1 Report Context
Island Gas Ltd as operator of the Bothamsall Field has been advised by the Environment
Agency (letter dated 12th August 2016) that following a review of all onshore oil and gas
activities and to continue the current activities on site and comply with the EPR
Regulations 2010 (as amended) the existing permit EPR/MP3731CN will need to be
varied to include additional permits including a Mining Waste Permit (MWP) to carry
out a Tier 2 mining waste operation.
The application is being submitted to cover the following activities identified by the
Agency at the site as generating hazardous extractive waste:
 venting of gas from storage tanks
 well workover extractive wastes
Note: The letter from Agency also listed the flaring of gas as an activity on site,
however, no flaring takes place at the Bothamsall wellsite’s and was not listed under
the original Reg 60 Information summary submitted.
This report details the Waste Management Plan for the site which has been prepared in
line with Environment Agency guidance. The report should be read in conjunction with
other supporting application information.
2 Introduction
2.1
Background
Certain activities at this site fall under the scope of the Mining Waste
Directive (2006/21/EC) and as such the proposed operations will be regulated
under the Environmental Permitting (England and Wales) Regulations (EPR)
2010 (as amended). Under these regulations, any extractive wastes
generated as part of the site operations need to be managed in accordance
with an approved Waste Management Plan (WMP).
2.2
Scope of Document
The purpose of this WMP is to demonstrate that Island Gas will manage the
wastes which results from its occupation and activities at this site in an
environmentally sound manner, and, wherever possible, will use the waste
hierarchy to minimise the potential impact of the operation on its
surroundings.
3 Site Description
3.1
General Site operations
The installation comprises three oil production sites at Bothamsall 05,
Bothamsall 08 and Bothamsall 14. Production fluids are temporarily stored
on site in bunded storage tanks prior to export from site by road tanker to
either Welton Gathering Centre or Gainsborough 05 site for separation of
produced water which is subsequently re-injected to the same producing
reservoir for pressure support to the oilfield. The onsite storage tanks have
vent stacks to allow gas entrained within the production fluids to escape to
atmosphere.
The principal releases into the environment comprise:
(a) Emissions to air of hydrocarbon gases from storage tanks
following separation of volatiles in storage, including volatiles
from road tanker filling operations and captured in the vapour
recovery system.
(b) Releases of engineering waste resulting from maintenance work
to a licensed waste disposal facility.
3.2
Waste Generating Activities
Following a review by the Environment Agency during 2015/16 of the permits
required by the operators of onshore oil and gas installations the Agency
identified the following activities at the Bothamsall site as generating
hazardous extractive waste:
Production

the venting of gas from storage tanks
Well Intervention

well workover wastes
3.2.1 Extractive Wastes from Production Activities
TANK VENTING
Small amounts of gas break out from the production fluid storage
tank on each site which are vented to atmosphere. Gases displaced
during tanker loading operations are returned via a vapour recovery
line to the storage tanks.
3.2.2 Extractive Wastes from Well Intervention Activities
WELL MAINTENANCE ACTIVITIES
During the abstraction process wax and scale can precipitate from the
well fluids and be deposited on the walls of the tubing, casing, rods
and pumps. The deposition if left untreated will result in poor
production efficiency and mechanical failure of the pumping system.
Typical mechanical failures are:



Broken rods
Seized pumps
Plugged tubulars
To prevent the loss of produced fluids and mechanical failures well
maintenance activities are routinely carried out on the pumping
systems. These are:




Hot water washing
Hot oil washing
Wax dissolver treatment
Acid treatment
In all cases this involves circulating fluids around the well pumping
system to dissolve the deposits. These activities can be considered
preventive maintenance measures, if not carried out the result would
lead to a complete pumping system failure. The rectification of the
failure is high cost and a greater operational and environmental risk.
PREVENTATIVE MAINTENANCE TREATMENT PROCESSES
Hot Water Washing – Water either potable or produced is heated to
90°C and pumped down the well annulus and returns to the surface
via the tubing. During this activity the well pumping system is
operating. This process dissolves wax that is deposited on the rods
and tubulars. The melted wax returns to the oil phase. The water
returned to surface is separated in the surface process facilities and
re-injected. During this activity the circulated fluids remains within
the well casing and tubulars and will potentially contact the surface of
the reservoir. This operation does not involve the pressurisation of
the circulating fluids in order to penetrate the reservoir.
Hot Oil Washing – This process is the same as Hot Water Washing but
uses crude oil from the well being treated as the dissolving liquid.
Crude oil is used were the face of the reservoir could be damaged if
hot water was to be used. The circulated fluids return to the oil phase.
This operation does not involve the pressurization of the circulating
fluids in order to penetrate the reservoir.
Wax Dissolver Treatments – Certain crude oils can produce
asphalatines and waxes that become deposited on the tubulars and
rod strings that are not dissolved when using either hot water or oil.
In these circumstances a wax dissolver chemical is use as the
dissolving liquid. The circulated fluid returns to the oil phase. This
operation does not involve the pressurization of the circulating fluids
in order to penetrate the reservoir.
Acid Treatment – During the abstraction process scale from minerals
in the produced water mainly calcium carbonate can deposit on rods,
tubes, pumps and casing perforations. This scale is typically dissolved
from the system by using a 15% solution of hydrochloric acid with
water. The water carrying the dissolved scale is returned to surface
and re-injected. This operation does not involve the pressurization of
the circulating fluids in order to penetrate the reservoir.
Note: In all these cases the returned fluids containing waxes, scales
and acids are incorporated into the oil stock or re-injected into the
reservoir with the produced water and therefore NOT considered
extractive wastes.
WELL WORKOVERS
Despite the preventative maintenance measures taken above there
will be instances where a well workover is required and a workover rig
is temporarily installed on site to workover the well. Typical
mechanical failures are:



Broken rods
Seized pumps
Plugged tubulars
Wastes from Well Workover Activities
In some circumstances the removed rods, tubulars or pumps maybe
re-used on other well completions. If the various parts of the
downhole equipment are unusable these will be tested for the
presence of NORM following the IGas NORM Procedures using a
portable meter. If the tubing is found to contain unacceptable
concentrations of NORM then it will be segregated and temporarily
stored as per conditions set out in the site RSR (Radioactive
Substances Activity) permit prior to further laboratory testing of scale
samples and removal to an appropriately permitted site for
decontamination and subsequent recycling or disposal.
3.3
Waste Management Areas
The regulations define a mining waste operation as the management
of any extractive waste that falls within the scope of the Mining
Waste Directive, including wastes generated as a result of prospecting
activities. The areas associated with storage and handling of
extractive wastes including removed tubing or other well equipment
at the time of workover will be treated as mining waste operations.
Based on the proposed operations, it has been concluded that there
will not be a mining waste facility at the Bothamsall wellsite on the
basis that:
•
non-hazardous extractive wastes will be generated from site
work-over operations and that storage of such materials on
the site will not exceed the 1 year threshold;
•
hazardous extractive wastes that are generated will be
removed from site within one month of production.
4 Waste Classifications and Quantities
4.1
Introduction
Extractive and non-extractive waste streams produced as a result of site
operations must be classified in accordance with the relevant regulatory
requirements. Wastes will be classified according to their properties as
follows:
•
Inert Waste – waste which does not undergo any significant
physical, chemical or biological transformations.
•
Hazardous Waste - as defined by making reference to Article
1(4) of the Hazardous Waste Directive which lists the
properties of wastes which render them hazardous.
•
Non-hazardous waste – this is waste which is neither classed as
inert or hazardous waste.
A description of the anticipated waste streams and estimates of waste
arising’s are presented in the sections below.
4.2
Extractive Wastes
Extractive wastes will consist of:
•
•
Gas vented from oil stock tanks and road tanker loading
Waste Subsurface Equipment – tubulars/pumps/rod strings
All wastes will be transferred to a permitted recycling/treatment/disposal
site using a registered waste carrier as required by the Environmental
Permitting (England and Wales) Regulations 2010 (as amended).
The principles of the waste hierarchy will be applied in that all waste will
either be reused or recycled following treatment.
Extractive wastes for Bothamsall Site are summarised in Table 2.
Table 2 Extractive Wastes Summary
Item
Gas vented from stock
tanks - emission point
(A1, A2, A3)
Discarded equipment
from well workovers –
tubulars/pumps/rod
strings
Source
Description
EWC
Code
Oil Stock
tanks
Small quantities of gas vented off oil stock
tanks through vent stack to atmosphere
16 05 08
01 04 07
Well
Workover
Sub-surface well equipment retrieved from
a well during a workover unable to be reused due to condition and/or presence of
NORM contaminated scale
17 04 09
4.3
Non-Extractive Wastes
To ensure a comprehensive WMP (Waste Management Plan) covering all
other wastes that may be generated during normal production operations at
the Bothamsall site but which are not classified as ‘extractive wastes’ , these
non-extractive wastes have been summarised in Table 3 below.
Table 3: Non-Extractive Wastes
Item
Source
Oil contaminated
absorbents
Maintenance
activities
Used – nominally empty
IBC’s and drums
Process chemical
containers
Non Hazardous Mixed
metal scrap
Demolition wastes –
gravel, concrete, bricks
Redundant process
plant and equipment
Civils infrastructure
projects on site
Transport packaging
from deliveries to
site
Paper/Card/Plastic/
Wood packaging
Oily Water
EWC
Code
Description
absorbents, filter materials
(including oil filters not otherwise
specified), wiping cloths,
protective clothing contaminated
by hazardous substances
packaging containing residues of
or contaminated by hazardous
substances
Site interceptors
15 02 02
15 01 10
Metals
20 01 40
mixed construction and
demolition wastes
17 09 04
mixed packaging
15 01 06
oily water from oil/water
separators
13 05 07
Process controls,
discarded equipment not
portable equipment,
containing hazardous
16 02 14
office electricals
components
Process controls,
Waste electrical and
discarded equipment containing
portable equipment,
16 02 13
electronic equipment
hazardous components
office electricals
Note: European Waste Catalogue (EWC) Codes are provisional and will be confirmed prior to
disposal/treatment
Waste electrical and
electronic equipment
4.4
Arising Estimates
`
The following estimates of waste arising’s (Table 4) have been made based on
records for calendar year 2015.
Table 4: Waste Arising’s Summary
Activity
Gas vented from
stock tanks emission point (A3)
Well workovers –
Waste
Type
Gas
Solid
EWC
Code
16 05 08*
17 04 09*
Waste
Classification
Waste
Estimate
(tonnes)
54 tonnes/year
Hazardous
Hazardous
0.15 tonnes/day
TBC
Management
Route
Vented off oil stock
tanks to
atmosphere
Collected by
discarded
tubulars/pumps/rod
strings
Waste
contractor for
offsite recovery /
disposal
*-mirror hazardous entry
Note: European Waste Catalogue (EWC) Codes are provisional and will be confirmed prior to disposal/treatment
5 Waste Management and hierarchy compliance
5.1
General
The activities will be conducted so as to prevent waste production wherever
possible, reducing the quantities generated wherever possible / appropriate.
In all cases the Waste Hierarchy will be applied, in order to reduce the
amount of material sent to landfill for final disposal, applying recovery /
recycling best practice where applicable / appropriate.
However, the nature of the operations giving rise to the extractive wastes
which are the subject of this Plan means that it is in essence impossible to decouple waste creation from the originating process. The well workover
operations are also subject to a degree of variation, and whilst every effort
will be made to conserve natural resources, and therefore generate as little
waste as possible, a degree of flexibility is required which may mean the
various waste streams will be liable to change.
5.2
Excess Gas Flaring
No flaring is carried out on these sites
5.3
Vented Gas
A small amount of produced gas remains entrained within the oil and
subsequently breaks out during storage in the oil stock tanks on site. This gas
is vented off the stock tanks to atmosphere – emission points A1-A3 on the
varied EPR Installation permit.
5.4
Well Completion Equipment
Following periodic well workovers there will be items of scrapped sub-surface
well equipment (Completion Tubing / Pumps / Rods) these will be tested for
the presence of naturally occurring radioactive materials (NORM). Where
detected and confirmed by laboratory analysis the items will be segregated in
a secure bunded storage with a tarpaulin or similar to provide weather
protection, and signage to indicate NORM storage and any prohibitions as
appropriate e.g. Controlled Area etc. Controlled areas will be signed and
monitored as identified in the local rules for the storage area. NORM items
identified for disposal must be disposed of in accordance with permit
conditions via a permitted waste recipient” Stored contaminated materials
should be inspected regularly (at least once per quarter) to confirm the
oncoming adequacy of protection, i.e. end caps still present sheeting secure
down and in good conditions etc.
Where scrapped items are tested and found to be below twice background
levels the metal is sent off site using a licensed waste carrier to a licensed
metals recycling facility.
6 Environmental Risk Assessment
6.1
Original Permit Application
The original permit application ref TP3839MB submitted September 2006
contains Section B2 ‘Management of Impacts’ and Section B4 ‘Impact of
Proposals on the Environment’ these have been reviewed as part of this
variation application process and the risk control measures are considered to
meet the requirements of the Mining Waste Directive, including the need to
prevent water status deterioration and soil pollution and remain applicable
with no significant impacts.
6.2
H1 Risk Assessment
The H1 has been reviewed as part of this variation application process and
the impacts remain insignificant. Copy attached - see Appendix 5
6.3
OPRA
The OPRA Profile has been reviewed as part of this variation application
process and the score remains unchanged. Copy attached - see Appendix 4.
6.4
H5 Site Condition Report
The H5 SCR has been reviewed as part of this variation application process
and the updated revision is attached - see Appendix 6.
7 Monitoring and accident/incident management
7.1
Monitoring and Recording
The review of the documents under Section 6.0 demonstrated that, due to
the nature of the waste to be generated and the proposed risk control and
mitigation measures put in place, we are confident there will be no significant
risk from odour, noise/vibration, waste, air quality and emissions with global
warming potential, or accidents at the site. Accordingly, the amount of waste
produced by site well work-overs and production operations will be
monitored and recorded, such that minimisation actions can be reviewed
(where appropriate), and the movement of what waste results may then be
moved up the hierarchy, where applicable. Thus, recovery / recycling will be
prioritised over final disposal. The quantity of waste arising will be monitored
and recorded, along with the quantities dispatched off-site for disposal. This
data will be used to inform waste prevention and reduction strategies.
7.2
Accident/Incident Recording
The environmental risk of an accident is predominantly associated with the
potential for spillage of extractive wastes. Given that the site is constructed
with an impermeable membrane (providing spillage containment), that
pipework and storage areas will be inspected daily for leaks and damage in
addition the site is not situated in a Source Protection Zone the assessment
has therefore concluded that the risk of damage to the environment as a
result of waste spillage is low. Incidents relating to the management of waste
are managed using the Company’s OSHENS Incident reporting system.
7.3
Reporting of Monitoring Results
The results of this monitoring will be recorded and will inform the future
monitoring. Details of all accidents, and our response, will be shared with the
Environment Agency and other regulators as appropriate. The relevant
sections of the Site Condition Report (H5) will be updated accordingly.