1. Health and Safety Executive Health and Safety Executive The Regulatory Framework for UCG– HSE’s perspective Tony Almond Redacted Health and Safety Policy Health & Safety Executive

2. The health and safety regulatory regime for oil and gas wells HSE’s regulatory regime is long established and is goal setting. The general duties under the Health and Safety at Work Act etc 1974 (HSWA) require risks to workers and the public to be reduced so far as is reasonable practicable. This is supplemented with more specific regulations particular on the extraction of gas and oil through wells, which includes shale gas and CBM operations but not UCG. The Borehole Sites and Operations Regulations 1995. - Onshore specific. These regulations require notifications to be made to HSE about the design, construction and operation of wells, and a health and safety plan which sets out how risks are managed on site The Offshore Installations and Wells (Design and Construction etc) Regulations 1996. These regulations include specific requirements for all wells, whether onshore or offshore, and include well integrity provisions which apply throughout the life of oil and gas wells and the requirement for weekly reports to be provided to HSE This combination of duties ensures that HSE is provided with information at key stages in the lifecycle of a well and allows HSE to assess whether risks are being adequately controlled and, if not, to intervene

3. The health and safety regulatory regime for UCG wells onshore The general duties under the Health and Safety at Work Act etc 1974 (HSWA) require risks to workers and the public to be reduced so far as is reasonable practicable. This is supplemented with more specific regulations particular on the extraction of gas and oil through wells, part of which includes UCG gas operations The Borehole Sites and Operations Regulations 1995 – Syngas is not a ‘mineral’ as described in the Regulations so requirements are reduced to (if within 1km of any mine and 30 metres deep or more); –notification to HSE 30 days before drilling starts, –further notification of any material change, The Offshore Installations and Wells (Design and Construction etc) Regulations 1996 – do not apply –Syngas is not a ‘petroleum’ as described in the Regulations

4. What does this mean in practice? HSE inspectors would use powers from HSWA to insist that wells are constructed to industry standards. However, information supplied to HSE would be much reduced compared with oil and gas wells…

5. Well notification information (1) – pre October 2015 Description of; the drilling rig and other plant to be used, pressure control equipment, how the work will be completed, including a timetable for the work, any activity that could lead to a leak of fluids Purpose – to make sure that; the plant and equipment being used is fit for purpose, any pressure build up in the well can be safely managed, activity that could lead to a leak is being assessed, allows cross check using weekly reports

6. Well notification information (2) - pre October 2015 Drawings of; the location and depth of the well, direction of the borehole, position compared to other wells and mine workings, the completed well Purpose - drawings allow inspectors to check the design and that the risk of drilling through other wells or mines is minimised.

7. Well notification information (3) - pre October 2015 Geological details; information on the geology including formations, strata and any fluids, any geological hazards that could cause fire or blowout, how the well design takes account of the geology, procedures in place to check the direction of the borehole Purpose - to check that any potential hazards from the geology can be safely managed

8. Weekly operators report – pre October 2015 Details of; activity since the work started or since the last report, the diameter and depth of the borehole, the diameter and depth of the casing, drill fluid density Purpose - to check against information in the notification and that the pressure in the well and the well’s stability is as expected.

9. Other onshore requirements Well and reservoir integrity (DCR - Reg 13) Although HSE would insist wells are constructed to industry standards Independent Well Examiner Health and Safety Document requirement of BSOR Notification prior to abandonment Weekly reports for abandonment activity Report of unplanned fluid release or BOP deployed required by RIDDOR

10. The health and safety regulatory regime for UCG wells onshore – post October 2015 The general duties under the Health and Safety at Work Act etc 1974 (HSWA) require risks to workers and the public to be reduced so far as is reasonable practicable. This is supplemented with more specific regulations particular on the extraction of gas and oil through wells, which includes UCG operations Relevant amendments in place The Borehole Sites and Operations Regulations 1995. - Onshore specific. These regulations require notifications to be made to HSE about the design, construction and operation of wells, and a health and safety plan which sets out how risks are managed on site The Offshore Installations and Wells (Design and Construction etc) Regulations 1996. These regulations include specific requirements for all wells, whether onshore or offshore, and include well integrity provisions which apply throughout the life of UCG wells and the requirement for weekly reports to be provided to HSE

11. The health and safety regulatory regime for UCG wells offshore The general duties under the Health and Safety at Work Act etc 1974 (HSWA) require risks to workers and the public to be reduced so far as is reasonable practicable. No offshore UCG proposal anticipated in the next 5 years. There will need to be a level of certainty before we would put forward an amendment [NB – wells drilled from onshore or connected to the shore, for an offshore reservoir are “onshore wells”.]

12. Onshore the regime requirements are much reduced prior to October 2015 Amendment will bring DCR and BSOR requirements for UCG onshore Offshore the regime will be dependent upon the Act until such time as amendments are required Summary