Regulation

Environmental permit for shale gas drilling at Tinker Lane in Notts – no groundwater monitoring required

tinker-lane-2

The proposed Tinker Lane site in north Nottinghamshire

A second shale gas site has come a step closer in north Nottinghamshire.

The Environment Agency has granted a permit which would allow exploratory drilling by Dart Energy (East England) Ltd at Tinker Lane, near Barnby Moor.

The proposed well would be drilled to a depth of 1,810m, into the Bowland shale. A decision on planning permission is expected before Christmas. The permit does not allow the well to be fracked.

The EA said it would “stringently enforce” conditions to protect groundwater. But it said it would not require groundwater monitoring.

Dart, a subsidiary of IGas, is the named operator of a shale site at Springs Road, Mission, also in north Nottinghamshire, which received planning permission earlier this month.

“Straightforward investigation”

The Environment Agency (EA) described the proposed operation at Tinker Lane as a “straightforward stratigraphic investigation” that would result in no direct emissions to air, soil or water.

The EA said:

“Should IGas receive the appropriate planning permission and begin the permitted activities, we will stringently enforce the conditions of the permit to ensure that waste is managed properly and local groundwater is protected.”

But the EA said it was satisfied that the well construction would protect groundwater. It said the site would be “entirely contained” and any spills would not be able to affect land or surface water.

And it said:

“It is considered that there need be no requirement for [groundwater] monitoring as a condition in the permit. It would be unreasonable to require the Operator to monitor groundwater and surface water for something they are unlikely to find.”

The EA added:

“Any discharge [from drilling muds] to groundwater that may occur would be of a quantity and concentration so small as to obviate any present or future danger of deterioration in the quality of any receiving groundwater.”

It required a daily inspection of all tanks and waste storage containers on the site to ensure they remained “fit for purpose”. This would, the EA said, “aid early identification of any potential release to site from equipment that deteriorates over time”.

A spokesperson for the EA said

“We take a risk based approach for each site so the absence of groundwater monitoring for this type of exploration would not be routine. The type and conditions in the permit will depend on the nature of the activity, geological conditions and environmental risks present at any given site.”

In its application, Dart said it would undertake baseline monitoring of groundwater and soil ground gas and collect monitoring information throughout the site’s operation.

But the Waste Management Plan, included with the application, gave no details of how the monitoring would be carried out in.

The only requirement on monitoring in the permit is a general condition to check on groundwater at least once every five years and soil once every 10 years.

Since the publication of this post, a spokesperson for IGas said:

“If planning permission is granted for exploration at the Tinker Lane site, we will drill three groundwater monitoring boreholes.  These boreholes were referred to within our environmental permit application and we can confirm that we will monitor groundwater before, during and after operations.”

Other conditions

The EA permit requires Dart to meet 33 other conditions, many of them standard to a mining waste permit. They cover issues such as waste disposal, emissions, smell, noise, vibration, monitoring, record-keeping, reporting and notification of failures or environmental problems.

The operator does not have to produce odour, noise or vibration management plans unless the EA requires them because operations have caused pollution. The conditions state that the assessment of whether noise, vibration or smell are causing pollution will be based on the perception of an EA officer.

Reasons for approval

In a decision document published this week (23/11/2016), the EA explained its reasons for granting the permit in response to concerns raised in 13 responses to a public consultation.

Financial security and competence

The EA said:

“We are satisfied that sufficient financial resources are available to the Operator to ensure compliance with the permit conditions.”

According to Companies House, accounts for Dart Energy (East England) Ltd are currently overdue. The latest accounts, for the year ending June 2014, identified net current liabilities of £479,946 and the auditors said Dart required support from the parent company, IGas Energy plc, to remain a going concern. IGas posted a loss of £25.2m for the six months to the end of June 2016.

The EA said it would check that Dart complied with the permit conditions and it added:

“We have no reason to consider that the Operator will not operate the site in accordance with the permit”.

Noise

The EA said noise would be reduced by soil bunds and by acoustic shielding attached to the site fencing. It added that equipment would be specifically selected for “low acoustic performance” and silencers would be fitted to equipment to reduce noise.

A condition of the permit (3.4.1) requires emissions to be “free from noise and vibration at levels likely to cause pollution outside the site”. The EA can require the operator to produce a noise and vibration plan under another condition (3.3.2).

The decision document continued:

“Noise analysis will also be conducted during operations to ensure that planning permission conditions are adhered to. We are satisfied that adequate measures will be in place to manage noise.”

Smell

The EA said smell was not of “particular concern” because the nearest home would be 500m away and the operations would be short-term.

One condition (3.3.1) requires emissions to be free from odour at levels likely to cause pollution outside the site. Another (3.3.2) allows the EA to require the operator to submit an odour management plan if smell becomes a problem.

On air pollution, the EA said the activities were not expected to have an impact on air quality and it was satisfied there were “acceptable controls” to “minimise the risk of fugitive [methane] emissions”.

Health

The EA said:

“We are satisfied that the activities we are permitting will not give rise to significant pollution or harm to human health. We consulted Public Health England in relation to this application; they have raised no concerns regarding health impacts resulting from the proposed operations.”

Chemicals

The EA said it had identified the ingredients of additives and fluids that Dart said it would use in drilling.

“We are satisfied that they will not cause environmental harm at the rates and levels of use proposed.”

Waste

The EA said Dart Energy’s waste management plan had selected drilling muds that would “minimise the risk of pollution” and the minimum amount necessary would be used.

Waste included:

  • Water based drilling muds – classed as non-hazardous (650 tonnes)
  • Water-based Barite-containing drilling muds and waste – classed as non-hazardous (650 tonnes)
  • Oil based drilling muds – classed as hazardous and described as “low toxicity” (no weight given)
  • Water-based rock cuttings – classed as non-hazardous (600 tonnes)
  • Water-based Barite-containing drill cuttings – classed as non-hazardous (600 tonnes)
  • Water-based Chloride-containing drill cuttings – classed as non-hazardous (600 tonnes)
  • Oil-based drilling cuttings – classed as hazardous and described as “low toxicity” (180 tonnes)
  • Concrete – classed as non-hazardous (130 tonnes)

The EA said “In the unlikely event that the activities give rise to pollution” it can require the company to revise its waste management plan.

Impact on wildlife

The EA said:

“The application site is not within the relevant distance criteria of any Protected Sites. There are two Local Wildlife Sites (LWS) within 1.6km of the proposed well site. We are satisfied that due to the mitigating processes proposed by the applicant and the standard conditions of the permit, the operation will not have an impact on the LWS located in the area.”

Precautionary principle

Participants in the consultation said the EA had failed to adopt a precautionary approach in issuing the permit. The EA said this approach should be used when the level of scientific uncertainty or likelihood of risk could not be assessed confidently. It added:

“We are satisfied we have sufficient information to make an informed decision”.

Other issues

Seismic activity: The EA said “We are satisfied that appropriate measures will be in place to ensure that seismicity will not result in pollution or harm to human health”.

Radioactive waste: A radioactive substances permit is not required for drilling wells.

Venting: This is not allowed under the permit, the EA said.

Suitability of the risk assessment: The EA said: “We are satisfied that it complies with our relevant guidance and that it identifies and covers all appropriate risks”.

Well abandonment: The EA said appropriate measures were in place to prevent the company leaving the well in “a state of disrepair”.

Light pollution: The EA said this was not covered by the permit.

Well integrity: The EA said this was the responsibility of the Health and Safety Executive.

Climate change: The EA said UK government policy states “We aim to maximise the economic recovery of the UK’s oil and gas reserves, taking full account of environmental, social and economic objectives”.

Traffic: The EA said this was not covered by the permit

Links

EA press release

Permit and conditions EPR/EB3406XP

Decision document

Waste Management Plan

Updated 1/12/2016 with new quote on groundwater monitoring from IGas spokesperson.

7 replies »

  1. A guaranteed go ahead at this site. The conditions are better than others that have been granted pp this year.
    Despite all the usual negative ramping on here there are no valid reasons to be refused.
    Looking fwd to 2017 everyone.

    • A guaranteed constant upward trend for offshore wind development with prices dropping all the time. Page 14.

      http://www.ewea.org/fileadmin/files/library/publications/statistics/EWEA-European-Offshore-Statistics-2015.pdf

      No wonder we are seeing constant divestment from fossil fuels

      https://www.theguardian.com/environment/2016/nov/22/fossil-fuel-divestment-soars-in-uk-universities

      Exciting times ahead for tackling climate change, cost reduction, common sense and reducing our need for importing gas.

      Looking forward to watching even more shale gas companies going bust in 2017

    • Yup, pp almost guaranteed here. No need for planning officers to ignore/override inconvenient national and local planning policies as was the case at Springs Road. Nevertheless, IGas is still the same IGas that NCC required to put up a restoration bond for Springs Rd, so it would be odd if no financial bond condition applied for Tinker Lane. Wonder how planners will regard IGas’ erection of fencing several months ago in presumption of pp being a shoe-in?

      • A bond can be provided absolutely no problem whatsoever. You need to ask your councils to do a better job and request them at earliest opportunity rather than look at them retrospectively.
        Bonds are part and parcel and won’t hold us back.
        Roll on pp in December.

        • That’s so funny ‘rogue’. When you set a bond, you have to be able to pay it. With I Gas in the brink, I imagine they’ll fold first; leave all their liabilities to the bank aka investors and taxpayers when the govt has to bail them out, then just start up again in another name…..

          • Check who will be in the driving seat if I-Gas bonds are called in – the company will not fold as such, but it will be under new ownership / management (actually under “old” management from Star Energy days is the rumour).

            Yesterday:

            “Further to the announcement of 12 October 2016 relating to the Bond Summons, the Company confirms that it continues to have discussions with key bondholders as well as a number of strategic investors.”

            • ‘discussions with key bondholders as well as a number of strategic investors’
              including 13.14% NEXEN PETROLEUM UK a wholly owned subsidiary of CNOOC Ltd (Chinese- another one for Tindale’s books)?

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