IGas has been granted a mining waste permit for two exploration wells at its proposed shale gas site at Springs Road, Misson, north Nottinghamshire.
The Environment Agency (EA) said in a decision document published yesterday: “We are satisfied that the imposition of conditions on the permit will mean it is operated in a way which protects the environment and human health.”
A spokesperson added:
“The permits set out the conditions that IGas must follow in order to protect groundwater, surface water and air quality and to ensure the safe storage, management and disposal of waste materials.
“Should IGas receive the appropriate planning permission and begin the permitted activities, we will stringently enforce the conditions of the permits to ensure that waste is managed properly and local groundwater is protected.”
IGas Chief Executive, Stephen Bowler, described it as an important step towards exploratory drilling at the site.
“Such a detailed review by the regulator alongside the public consultation demonstrates that, as we have committed, our proposed exploratory operations will be carried out safely and in an environmentally responsible manner.”
The company proposes to drill a 3,500m vertical well and a second well to a depth of 2,500m followed by a horizontal section of up to 1,500m.
The permit does not allow hydraulic fracturing, venting or the handling of naturally-occurring radioactive material (NORM). The Environment Agency said the permit would need variations if IGas chose to frack, carry out well-testing or produce hydrocarbons from the well.
IGas has applied for planning permission for the site. A decision by Nottinghamshire County Council is expected later in the summer.
The Springs Road site was a Cold War missile test centre. It is 268m from the nearest building, Prospect Farm, and 125m from the boundary of Misson Carr, a wetland Site of Special Scientific Interest (SSSI).
According to the EA, the operation at both wells will use water-based drilling muds to drill through the Magnesian Limestone to a depth of about 1,500 metres.
Oil based drilling muds will then be used to complete the second section of both wells to approximately 2,500m at the bottom of the Bowland Shale formation.
For the final section of the vertical well (to be called Springs Road-1 if it gets permission) water based drilling muds will be used again, to drill through the Carboniferous Limestone.
According to the decision document, drilling is estimated to produce:
- 3,500 tonnes of waste clays and sands
- 7,000 tonnes of water-based rock cuttings
- 3,500 water-based drilling muds and waste
- 775 tonnes of low toxicity oil-based drilling cuttings
The EA carried out two public consultations on the permit application. The decision document shows the organisation’s responses to issues raised by statutory consultees and members of the public. We’ve listed the main concerns alphabetically.
Climate change In response to concerns that the development was not in line with national energy and climate change policy, the EA said:
“One of the policy’s main goals is to maximise the economic recovery of oil and gas from the UK’s oil and gas reserves, whilst taking full account of environmental, social and economic objectives.”
Decommissioning The EA said monitoring at the site would continue into the post-decommissioning period and would have to demonstrate that no impact has occurred and that there are no ongoing environmental issues.
Drilling chemicals There were concerns that no details of chemical in the permit documentation. The EA said IGas has provided a full list, adding:
“We have assessed the additives to be used and we are satisfied that they will not cause environmental harm at the rates and levels of use proposed.”
Emissions Public Health England said IGas had not considered source emissions from diesel fuelled plant. The EA said the site was unlikely to “give rise to significant dust or impact on air quality”. It added:
“The largest source of emissions will be from vehicles, generators etc, which are not covered by the permit”.
Fire and Rescue Service There were concerns that the EA had not consulted Nottinghamshire Fire and Rescue department. The EA said this wasn’t necessary.
Flooding. The EA said it was satisfied sufficient measures were in place to protect the site rom flooding.
Geological fault lines not mapped correctly The EA said its Hydrogeological Risk Assessment had accurately documented the risks.
Impacts on property values The EA said these were not relevant.
Light pollution This was outside the remit of the permit, the EA said.
Noise The EA said:
“Concerns have been raised that the activities will cause noise pollution. We are satisfied that the activities, if carried out in accordance with the Permit, will not cause noise pollution.”
Protected species and water levels in the SSSI Natural England requested clarification on how water levels, water use, drainage and quality would be affected by the borehole. There were also concerns about the impact on protected species. The EA said
“The assessment concluded that the proposed activity was not an operation likely to damage SSSIs… There are no records of protected bat, owl or bird populations in the area”.
Rights of way Some comments said the site was unacceptably close to public rights of way and the Beech Hill Railway crossing. The EA said this was a matter for Nottinghamshire County Council. “We do not consider any emissions from the permitted activities will impact on any Public Rights of Way”, the document said. It added:
“Subject to any other condition of this permit, periodic monitoring shall be carried out at least once every 5 years for groundwater and 10 years for soil, unless such monitoring is based on a systematic appraisal of the risk of contamination.”
Viability and trust in IGas The EA said no reason to think IGas would not comply with permit requirements and conditions or operate in accordance with the permit.
“We will assess the Operator’s activities and we will be checking they comply with the permit conditions as part of our compliance work.”
Vibration risk to unexploded ordnance The EA said the permit did “not authorise drilling per se”. Decisions over land use were for Nottinghamshire County Council, it added.
Well integrity The EA said it was satisfied with the proposed well construction, drilling additives, testing activities and site design.
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Excellent news. A step in the right direction.
Thats funny, many seem to believe there is no regulation in the UK?? Looks like there really is quite a lot that the EA have to look at! Its science after all.
As I was away I did not respond to this post. In fact I took part in “consultations” leading up to this permit and my response to Ken Wilkinson is to say that the regulatory process as evidenced by the issuing of this permit was a joke. Nor was it in the slightest bit scientific – indeed the permitting process evades addressing a scientific approach to risk assessment. My own submission into this process can be found re-posted on the website of Feasta here:
In essence my objection was a challenge to the adequacy of the risk management process and the Environment Agency response to my submission was to misrepresent what I had written.
As I commented in my follow up:
The EA misrepresents my case. The central point of my submission was whether the Environment Agency consideration of an environmental permit for IGas should be based on numerical evidence arising in objective peer reviewed scientific studies or, alternatively, whether it is acceptable for them to accept the purely subjective opinions purchased by the permit applicant from a consultancy. This consultancy (AECOM) has a business interest in seeing the permit granted so as to get more work. The issue is about was about what counts as acceptable evidence and as acceptable sources of evidence for considering issues of environmental safety.
This was particularly important because, as I showed in my submission, there is much evidence of what is called in academic literature “optimism bias” by companies in the field of health and safety and environmental care. So it is important to ensure that the evidence is sound and not contaminated by “optimism bias”. The Treasury instructs civil servants who receive tenders for contracts to correct them for optimism bias. The likely time until completion and the tendered bid are increased according to various criteria to make them more realistic. The Environment Agency should expect risk assessments to be over-optimistic too, given the literature on this, and correct them.
The safety and wellbeing of the public and the quality of the living environment are at stake so attempts to fudge and obscure the issue are not only issues of methodology they are issues of ethics and possibly of law.
The wording chosen by the Environment Agency to describe my objection refers to the issue raised by me as one of the “categorisation” of risk assessments. “Category” is a word with several possible meanings in this context. Categorisation might mean the types of risk ( e.g. water contamination or atmospheric contamination). Or categorisation might be taken to mean falling into a group of cases distinguished by greater or lesser degrees of probability or greater or lesser degrees of impact. Alternatively “categorisation” might mean the choice of methodology to do the ratings with – either a subjective methodology based on the opinion of a consultant or objective and based on published data in a statistical form from academic and other studies done by people without a money interest in the situation at hand.
I made it quite clear in my original submission that I was concerned that assessment of risk should as far as possible draw on research evidence and statistics from comparable situations, corrected as far as possible for local circumstances. I made it quite clear that it is unacceptable to ignore a growing body of scientific research and accept instead the un-evidenced opinion of a consultancy firm. This is especially the case when the consultancy grade the likelihood and possible impact of risks using a non numerical rating scale for which no objective calibrated data is offered. This makes it impossible to falsify or validate the consultancies judgements and makes it well nigh impossible to challenge how they assign cases and situations into their rating categories.
The consultancy firm uses a rating scale which uses these words “virtually impossible”, “remotely possible”, “moderately likely”, “likely” and “virtually certain”. But these words are undefined and uncalibrated so that if an event like a well leaking within one year is judged by them to be “remotely possible” there is no way of proving them right or wrong. This is not acceptable when there is a body of research that can be drawn on, and there is. That makes should make it mandatory for risk assessments to be calibrated to actual field experience in the nearest known comparable situations with reasoned adjustments for any differences in the local case. To say that it is remotely possible that a well will leak and that wells in a comparable situation have failed 8% of the time is a totally different thing. The one is untestable opinion and the other is evidence based.
This subjective quality of the consultants judgements has important implications for the Environment Agency response to me.
This is what was said in the response:
“We have reviewed the assessment, and we are satisfied that it complies with our relevant guidance and that it identifies and covers all appropriate risks and that measures are in place to address them.”
If this complies with the relevant guidance then the “relevant guidance” is inadequate and is in urgent need of review and revision. In this case my objection is to the relevant guidance as well as to this decision. If the relevant guidance is flawed is it actually legally sound?
(a) Since the judgement of likelihood and impact are in undefined purely subjective categories it is impossible to assess them. If this shoddy procedure is acceptable it would be difficult for the applicant to fail no matter how much they downplay real and significant dangers because there is no way that the purely subjective process of airbrushing the dangers away can be proven to be a misleading and dangerous.
(b) In these circumstances too “covering all appropriate risks” merely requires the consultancy to mention risks and mentioning “measures” to cover them – again without needing any consideration of how much the stated risk mitigation when applied in other comparable places has been successful or not.
To repeat what is happening here is that the Environment Agency is happy to accept the industry’s say-so based on purchased opinions. This is even though it is patently obvious that the consultancy company has an interest in more business of this kind and therefore has no interest in raising difficult issues. On the other hand, if members of the public go to the trouble of looking at what peer reviewed academic research says on the matters at hand – and wants them considering, they are an embarrassment and inconvenience and thus require someone to write a fudge and a brush off.