Regulation

Views sought on permit for Doe Green CBM site

doe-green-well_heads_waste_tank

Doe Green. Photo: Rob Boeuf

The Environment Agency has begun a public consultation on an environmental permit application for Doe Green, a coal bed methane production site near Warrington.

The site was built before legislation required it to operate under an environmental permit. But the regulations changed in 2013 and required operators of oil and gas sites to apply for a mining waste permit.

In 2015, campaigners concerned about operations at Doe Green said they were “staggered” to discover it operated legally without a permit (DrillOrDrop report).

At the time, the EA said it had begun a programme to bring all onshore oil and gas production sites under the environmental permit regulations. It said sites would be required to apply for a permit during 2015 and 2016. Doe Green already has a permit for handling naturally occurring radioactive material.

Key facts

DrillOrDrop has compiled this information from the environmental permit application documents.

Application reference: EPR/EB3506KZ/A001

Permit type: Mining waste operations

Applicant: Wardell Armstrong consultants for INEOS Shale

Public consultation period: 13 January-10 February 2017

Location: 860m to the west of Penketh, Warrington

Address: Doe Green Coal Bed Methane Facility, Farnworth Road, Penketh, Warrington, Cheshire WA5 2TU

Site size: 7,121m2

Access: Off the A5080, Farnworth Road

Surrounding landscape: Farmland

Site history: Construction in 2006. Gas production and electricity generation began in June 2009. INEOS Shale took over operations from IGas in April 2016.

doe-green-map-wardell-armstrong

Location of Doe Green. Image: Wardell Armstrong

Site infrastructure

  • The application mentions four wells: DG1 – logging well (4,036ft); DG2 and DG3 – production wells (3,726ft and 3,438ft); DG4 – suspended after failing to produce gas in sufficient volumes (4,350ft)
  • Gas processing skid, which regulates the pressure of gas delivered to the generator set
  • Pump and control unit, which controls water and gas pressure
  • Tanks: two tanks (20,000 litres and 7,500 litres) to store and treat process water recovered from the well. A third tank (33,000 litres) stores excess water that requires off-site disposal.
  • Oil interceptor and storage tank which collects rainwater falling on the site
  • Two 21,000 litre effluent storage tanks for human waste and grey water, emptied by tanker
  • Generator compound containing generator, storage containers, lubricant and coolant store, office
  • Electricity substation
  • Security and site office, washroom and mess room
  • 2m high security fencing with anti-climb topping

Site activities

  • Gas rich with methane is extracted from DG2 and DG3 wells.
  • Water pressure in the coal seams is lowered, allowing gas within the coal to flow to the surface
  • Water flows from the coal into a sump which forms the base of the well bore
  • If water levels rise the sump is dewatered by pumping water from a stock tank at high pressure
  • Water and gas separate below the surface and the gas reaches the surface through a tubing annulus
  • The water falls into a collection sump at the base of well, from where it is pumped to the surface
  • Gas from the well head flows through a conditioning plant to the 400kw generator, where it is burned to produce electricity, which is exported to the National Grid.
  • The generator is not part of the permitted facility and is owned and operated by a separated company (ENER-G)
  • Maintenance work on the wells, including refurbishment and/or replacement of tubing and components

The permit application does not include hydraulic fracturing, drilling further wells or flow testing. Acid flushing and scale inhibitors or other chemical descalers are not used in well operations at Doe Green, the application stated.

Environmental risk

INEOS has identified what it called “potentially sensitive receptors” near Doe Green:

  • Surface water 3m and 85m from the site, which drains to the Penketh Brook, a tributary of the Mersey
  • Farms and homes about 250m from the site on the A5080 and Sandy Lane
  • Residential areas of Lingley Green (820m) and Penketh (812m)
  • Railway 19m away
  • White Moss Nursery and Garden Centre (480m)

According to INEOS, impacts on them may include:

  • Particulate matter and dust
  • Spillages
  • Mud on roads
  • Noise and vibration

The company said:

“Suitable design and operational measures will be provided at all times, to remove the risks altogether or mitigate them to ensure that there will be no unacceptable impact on the environment or human health.”

The application says there have been no potentially polluting major spillages at the site. A 1mm impermeable membrane was installed when the site was constructed and covered with 300mm of hardcore. It has not been uncovered. According to the application, “it is assumed that the membrane is fit for purpose and has not lost integrity as an impermeable barrier”.

Surface water collects in a drain around the boundary of the site. The application said there were currently no discharges to nearby rivers or streams.

It said the risk of groundwater pollution was negligible because:

  • Any liquids pumped in to wells are not expected to propagate upwards through fractures within the coal seam but it said sub-surface leaks may lead to emissions of fluids into the coal seam
  • The only fluids that are to be used within coal bed methane operations are process water and spacer fluid upon abandonment of a well. These fluids will not cause pollution
  • Emissions to groundwater, surface water or soil as a result of surface spillages or leaks will be prevented through the maintenance of the design measures
  • Site drainage can be isolated and water disposed offsite

Baseline data

The application says there has been no site investigation of soil or groundwater. It said:

“As there is a need to protect the integrity of the membrane, sampling would puncture it”.

Waste

  • Workover waste from the well, including scale and scrap metal
  • Waste from well abandonment, including concrete, spacer fluid and scrap metal
  • Non-extractive wastes, including office/canteen waste,
  • lubricating oils and greases, diesel, sewage, dirty and surface water

Venting and gas releases

The application said:

“Small volumes of gas will be cold vented during site maintenance activities. Gas will also be cold vented for pressure relief if required.”

But it also said:

“Measures will be taken to minimise all fugitive emissions which may cause odours.”

“In the event of any unexpected gas releases the Environment Agency will be notified. Details of the quantities of any gas releases will be recorded, where measurable, along with the measures taken to manage them and made available to the Environment Agency on request.”

Links

Link to application documents

Consultation web page

 

7 replies »

  1. This is unbelievable! Dewatering the site to release methane, measures will be taken to limit escape (fugitive emissions). Site limit is a neat square!! Dewatering changes the whole flood plain. In an age when we know what methane and Co2 are changing climate I hope the Environment Agency have stopped all operations….. if not, why not?

    • I think you missed the point that this site has been running (rather unsuccessfully) since 2009 without incident. You will notice that the seams will be refilled with water once the site is abandoned. This methane is exactly the”fire damp” feared by coal miners which used to be pumped out and just vented or flared at the surface. There is also a smallish company Alkane (now taken over by a bigger concern) which has been for years using methane trapped in actual old mine workings to generate electricity at the surface. If I remember rightly this used to be welcomed by green activists as a useful alternative to flaring or venting.

  2. Just wanted to point out the double standards that seem to operate in this bizarre world. This plant at Doe Green has been operating for 7 years without incident quietly generating energy we all use. On the same day there is a report from West Wales that an anaerobic digestion (AD) plant is being blamed for killing more than 1,000 fish in Wales, with discharged waste killing every single fish along an eight-mile stretch of a local river. Now just imagine that a similar incident happened near an onshore oil field, there would be headlines a mile high. I am not of course seeking to decry the use of anaerobic digestion which seems a useful source of gas and no industry is without its risks. I’d just like a level paying field.

  3. This should be welcomed. No different to when MOT tests were brought in. May find that the site (car) under the new system needs some adjustment, might not, but it gives greater control and scrutiny that was not there before. Surely, everyone gains, apart from (maybe) the “owner” who would have to pay the bill to remedy any defects. Even FOE may be able to raise more funds to fight it!

    • I’m mainly concerned about uncontrolled, unmeasurable leakage from operations like this. With all the implications of climate change, we have to stop the use of fossil fuels, full stop.

  4. “Uncontrolled, unmeasurable” ??

    I thought the premise behind such tightening of regulations was to AVOID much of the risk. Yes, there is no such thing as zero risk, but as alternative energy sources would not stack up without nuclear my point still stands. Yes, John I know Germany takes a different view-it is called coal.

    What else should we put a full stop to? Guardian headlines say there is a courgette crises. These are being transported across Europe to us, by truck. Roses and French Beans being airfreighted to us from Africa. Large numbers of solar panels being manufactured in China with huge inputs of filthy coal energy and then shipped half way round the world to us.

  5. Mike-I don’t see why you are not “mainly concerned” about the world’s population heading towards 10 billion (when the EU population will be below 10%!) The activities of these numbers, many who will be what we call middle class, will be a huge challenge. Perhaps we should put a full stop to procreation? The act itself, when involving such numbers, could produce enough heat to melt a few glaciers!
    And when we have covered good agricultural land with solar farms and windmills, how do we feed those sort of numbers? (It is happening, some of it a mile away from me, at this very moment.) And we are processing wheat, maize, sugar cane to produce green fuels, to placate the eco warriors!
    Lack of food, and water, will be the biggest risk to the world very shortly, and it will produce serious conflict. It has throughout history, but now, we are unlikely to get the balance of disease, and then the balance becomes a reduction in numbers through conflict.
    I, for one, would prefer we sensibly utilise the resources we are blessed with (like seasonal vegetables!), rather than transport it half way round the world. We are committed to using significant fossil fuels for at least 30 years. Security and environment will gain if we manage it ourselves, rather than foist the supply onto somewhere over the horizon so that we can pontificate about it during our courgette fuelled dinner parties! Leak and potato soup and the thermostat turned up, I would recommend it. I will grow my own courgettes in the summer, but the yields could be down as the horses that used to fertilise my vegetable garden have been replaced by Chinese solar panels-literally.

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