Regulation

Rule change approved for Cuadrilla’s shale gas site despite fears of intensified fracking

PNR 171203 Ros Wills4

Cuadrilla’s Preston New Road shale gas site, 3-4 December 2017. Photo: Ros Wills

Cuadrilla has been allowed to change controls on fracking and flaring at its shale gas site near Blackpool.

The Environment Agency announced yesterday that it had approved variations to the environmental permit on the volume of fracking fluid and the duration of flaring.

Friends of the Earth has opposed the changes for the Preston New Road site, saying they could lead to more intensive fracking and more lorry loads of potentially radioactive waste on Lancashire roads.

Volume of fracking fluid

The original permit, grated in January 2015, allowed Cuadrilla to pump 765m3 of fracture fluid a day.

Under the change, the company could pump up to 765m3 per fracture stage. Cuadrilla has confirmed that it could carry out multiple fracture stages in a day.

Friends of the Earth said the change could intensify fracking at the site, with no limit on how many fracking stages would be allowed daily.

It had called on the Environment Agency to undertake a full assessment of treatment techniques available to process the waste flowback fluid on site to minimise the volume of potentially radioactive waste that would be transported on local roads.

The organisation also said there were discrepancies in Cuadrilla’s figures for flowback fluid and, as a result, the number of tankers needed to transport it. Tanker movements could top 2,000 if the company was unable to reuse some of the fluid, Friends of the Earth said.

But the Environment Agency wrote in its decision document:

“There is no increase in risk to groundwater associated with this change. The maximum quantity of waste flow back fluid that can be stored on site has not been changed and remains at 3,000 cubic metres.”

It added:

“In the event that the operator [Cuadrilla] could not somewhere to take their waste, the operator would have to take the necessary measures to ensure that no further waste of this type is generated until alternative treatment/disposal routes were in place.”

The EA also said:

“Any increase in vehicle movements that may result from this change would be managed by the operator in accordance with their planning permission and would be regulated by the local authority.”

PNR 171201 Ros Wills4

Cuadrilla’s Preston New Road shale gas site, 1 December 2017. Photo: Ros Wills

Flaring duration

The original permit allowed Cuadrilla to flare waste gas during the initial flow testing phase for 90 days for each of the four proposed wells.

The variation permits the company to flare for a total of 360 days for the whole site.

In its decision document, the EA said the change allowed Cuadrilla to be more flexible. The company could spend more time testing the earlier wells without increasing the overall duration.

The EA said the change would not result in harm to human health or the environment.

According to the decision document, an EA screening exercise had concluded that the “predicted environmental concentration of each pollutant modelled is not expected to exceed 70% of the applicable environmental quality standard and as such and EQS breach is considered highly unlikely.”

The EA said Cuadrilla would have to maintain a daily flaring register, recording each day on which flaring of any duration took place, up to a maximum of 360 days. Cuadrilla would have to include its proposed seven-day commissioning periods for the two proposed flares within the 360-day total.

The EA added that the actual environmental performance of the flare would now be monitored, instead of the previous scheme which relied on monitoring by calculation. There would also be “strict” annual emission limits for oxides of nitrogen, carbon monoxide and total volatile organic compounds, the EA said.

Fracturing plans

Under the revised permit, the EA said it required a separate hydraulic fracturing plan for each individual well, rather than one plan for all four wells. It said:

“This will allow the Environment Agency to scrutinise and review each stop of the process as operation proceed on site.”

It would also allow Cuadrilla to update and refine subsequent hydraulic fracturing plans, the EA said.

PNR 171201 Ros Wills5

Cuadrilla’s Preston New Road shale gas site, 1 December 2017. Photo: Ros Wills

Flaring plan and procedures

The EA said Cuadrilla must produce an updated site plan showing the location and designation of the two proposed flares before flaring could start.

The application for permit variations did not include detailed operational procedures and controls for the flaring activity, the EA said. Cuadrilla must also provide these procedures for approval before flaring.

Seismic monitoring

The permit changes allow Cuadrilla to monitor any seismic events using downhole seismic geophones. The original permit required an array of monitors on the surface.

The EA said the variation would result in more accurate information. While one well was being fracked, an adjacent well could be used to monitor fracture growth, it said. .

Cuadrilla had agreed to use the government’s traffic light system for seismic events from 4 weeks before injection operations to 2 weeks afterwards, the EA added.

Smell

The EA said odour was “not considered likely to be an issue” because the site was 250m away from what were described as “the nearest sensitive receptor”.

Noise

The EA said:

“Noise and vibration are not considered to be an issue due to the design of the flare, the rural location of the site, the distance to the nearest receptor … and the level of background noise”.

In response to concerns about noise, the EA said:

“In the unlikely event that the activities give rise to pollution due to noise and vibration outside the site, a noise and vibration management plan be requested.”

Pollution

The EA said it was satisfied that appropriate measures were in place to prevent environmental accidents that may cause pollution. If there were an accident, the consequences would be minimised, the EA said.

Trust and competence

The EA said some people who took part in its consultation on the permit changes were concerned about Cuadrilla’s competence and its lack of transparency when dealing with the public.

Four permit breaches have been recorded against the company since operations began at Preston New Road in January 2017.

But in its decision document, the EA said:

“We have no reason to think that they [Cuadrilla] would not comply with permit requirements and conditions.”

People who took part in the consultation also said Cuadrilla had not explained the scope of the changes and that the information was different from that in the planning application. But the EA said it was satisfied there was sufficient detail to decide to vary the permit.

The EA said it received 189 responses to the first public consultation on the permit changes, ending in August 2017. There were 33 responses to its consultation on the draft decision which closed last month.

Links

Environment Agency decision document on permit variation (11 December 2017)

Revised permit EPR/AB101MW (11 December 2017)

Environment Agency documents about Cuadrilla’s Preston New Road site

70 replies »

  1. At least you wrote ‘I thought’ Martin. You thought incorrectly as I’ve pointed out many times. I don’t know where you keep dredging that idea up from. Fracking has been profitable for US Gov tax revenues and for some big companies, and helped turn a few investors (and large scale property owners) into billionaires, and if you ignore the fact that it has created a far greater number of bankruptcies, polluted and toxified several water courses, depleted water tables, ruined many farms, caused an untold number of health issues and contributed millions of tons of methane (the most powerful greenhouse gas into the atmosphere), if you take commercial profitability as your only criteria you could say – as you do – that fracking has been a success in the USA. However if you did a total costing, taking all the remediation and long term costs (of impacts) properly into account I’m sure you would come up with a very different story. The corporate profiteers won’t care though, having extracted huge tax concessions and socialised the risks and ongoing/legacy problems and costs (with regular tax payers bearing the burden).

    The other thing your counter argument doesn’t comprehend Martin is that some things are actually locked into a time warp, particularly the geology and strata – for millions of years at a time. And there’s a delicious irony in how fond you are of deriding anything based on internet sources when you are this site’s most avid commentator – should we believe anything you say then? not according to your gospel – as we keep finding your thoughts plastered over the – er – internet.

  2. Oh dear PhilipP. Your usual attempts at conflation.

    The success of US fracking is there in $s for everyone to see-including those in the UK who happen to fill their cars at the fuel station. The “costs” you indicate are speculative. I will keep with the facts and leave the speculation to yourself. (By the way, check the radioactive material down a hole story. I’m sure Giggle will show you just about every hole in the UK has featured such speculative nonsense. It is so abused as to be laughable, and simply shows the arguments are now entering into the territory of previous “mythology”.)

    There is no irony. I use the internet to communicate my views from a wide variety of information sources, which has been pretty clear over the last few months, but rarely from a search engine. Strangely, I also use it to purchase certain items, but do not decide on which items to purchase from a search engine.
    By the way, I am not this site’s most avid commentator, but factual representation is not your aim. However, it does raise the question that when you misrepresent something like that which is so factual, should your other posts be viewed the same way? Facts take a little time, speculation is much easier and quicker.

    • Your ‘only stick to the facts’ security blanket is wearing so thin it’s virtually see-through Martin. I’m quite familiar with factual research, from front line and primary through to secondary and anecdotal but thanks for the mini lecture. As you wish, call the costs of pollution and climate change impacts speculation. Anyway, that’s up to others, and hey that’s their problem and their cost isn’t it. It’s true the costs or hurricane and flood damage from Puerto Rico and Miami to Houston and wildfires from Southern California to Canada, will all be speculation for quite some time. Will anyone even be able to count the total costs of these things, exacerbated by global warming, that people fear will be the ‘new normal’? Your Times reading fraternity will no doubt continue their ritual climate change denying beliefs a taking aim at the BBC whenever it dares mention the phenomenon – ‘how dare it be raised in the context of Blue Planet II’. Each to their own religion but please be aware how fact get distorted through those prisms.

      • Well well, Talk about a timely release of information? This is perhaps the most important report you will read this year, thanks to inside climate news reporters.

        This is interesting for all those who claim that climate change is not a man made phenomenon, it would appear that Exxon, started to release documents from studies revealed by Exxon senior scientist James F Black, that revealed man’s use of oil and gas would influence climate change. Indeed as far back as July 1977.

        https://insideclimatenews.org/news/15092015/Exxons-own-research-confirmed-fossil-fuels-role-in-global-warming

        “James F Black estimated quick action was needed. “Present thinking,” he wrote in the 1978 summary, “holds that man has a time window of five to ten years before the need for hard decisions regarding changes in energy strategies might become critical.”

        “Then, toward the end of the 1980s, Exxon curtailed its carbon dioxide research. In the decades that followed, Exxon worked instead at the forefront of climate denial. It put its muscle behind efforts to manufacture doubt about the reality of global warming its own scientists had once confirmed. It lobbied to block federal and international action to control greenhouse gas emissions. It helped to erect a vast edifice of misinformation that stands to this day.”

        “Michael Mann, director of the Earth System Science Center at Pennsylvania State University, who has been a frequent target of climate deniers, said that inaction, just like actions, have consequences. When he recently spoke to InsideClimate News, he was unaware of this chapter in Exxon’s history.

        “All it would’ve taken is for one prominent fossil fuel CEO to know this was about more than just shareholder profits, and a question about our legacy,” he said. “But now because of the cost of inaction—what I call the ‘procrastination penalty’—we face a far more uphill battle.”

        This series of six documents reveals why we have not only gone astray from the all ready known effects of man made climate change, that we are now in dire straights due to the efforts of Exxon and others to totally deny and obfuscate research.

        Here is the link again, it is that important.

        https://insideclimatenews.org/news/15092015/Exxons-own-research-confirmed-fossil-fuels-role-in-global-warming

        Please read this for yourselves, i am still plowing through it.

        What is the phrase that characterises this situation? Oh yes, “Do Your Own Research”.

  3. Threadbare Government science. So the EA staff have to keep fingers crossed and work to the dictats of their political masters. So sad that they have come to this … under the control of Mr Gove, an English graduate and former journalist who seems content to encourage the rape of the Fylde.

  4. On the simple matter of smells …. the report states ….
    “Odour not LIKELY to be an issue” because “the site was 250m away from the nearest sensitive receptor”. Oh really …
    In the foothills of Bowland overlooking the Fylde, we used to regularly smell emissions from the Courtaulds factory at Redscar on the outskirts of Preston. This was a chemical plant producing man-made fibre. It was 10 miles away. So, EA, have you any idea how flaring emissions will be kept within 250m?

    • Muriel
      The emissions are not kept to 250m of course, no more than the emissions from a domestic gas boiler is limited to 250m. The mean that you should not notice them in terms of odour, and various limits will not be exceeded.
      That information will be in the RSK report. But in practice, one will find out I guess.

      Re the factory you refer to, I believe it was built in 1939 and closed in 1979.

      The standards it was built and operated to would not now be allowed ( in the UK ).

  5. The operations Cuadrilla is proposing even in this updated permit don’t qualify as fracking under the current government definition of hydraulic fracturing, as none of the stages will be above 1,000 cu meters. Why then is this well still classed as a fracking operation? Is it to turn away the attention from the fact that the definition of fracking has been changed under the influence of the industry creating a massive loophole?

    • Looks like it. That’s around 220 gallons per cubic meter so you’re easily into the 3 to 8 million gallons for a 15 plus stage (moderately long lateral) frack, with the potential to double if the formation is favorable. Those figures wouldn’t be unusual for fracking operations in the US. I think it should be classified by the use (and combination) of slick water or viscosity agents and propant, and the pressures used to force them into the target zone, It’s just clever wordplay otherwise especially if the number of stages aren’t disclosed. To lower gallon threshold per stage may get you out of the ‘high volume’ definition but it’s still fracking.

    • ‘high-volume hydraulic fracturing’ means: “injecting 1,000 m3 or more of water per fracturing stage or 10,000 m3 or more of water during the entire fracturing process into a well”

      They plan to frack up to 45 stages at up to 756 m3 each, so u to 34,000 m3 which is considerably more than the 10,000 in the “or” clause there.

      • careful ‘refracktion’, Cuadrilla rely on the general public to advise them when they’re doing stupid things and breaking the rules. Better to let them dig their own grave, even though the EA etal will keep them on life support as long as possible.

    • Kathryn
      I cannot share your dystopian view of the EA having met a number of them. But I have not met them all personally, so maybe those you know fit your description.
      Re the receptors, the good news is that this is standard terminology and not limited to the English EA. The principle is the source, pathway, receptor model of risk assessment. If humans and animals are not receptors, then we have no need to worry about them, but I think we should.

  6. So now PhilipP, you even try and justify not following the facts! Each to their own, but I simply prefer to live in the real world rather than speculate around fake and (often) unassociated stories.
    Meanwhile back in the real world, we have one pipeline in Scotland down, costing £20m/day, and another in Austria cutting off most of the gas to Italy. But, of course some will speculate that there are plenty of supplies instantly available and it will not cost to replace these sources, whilst in the UK petrol prices continue to rise at the pumps. I find it does not work if I tell the attendant that John insists there should be no increase in the price/litre as a “report” stated our sources of supply were secure, or that I should be able to buy diesel cheaper because another “report” said we should convert to diesel cars. Inflation at 3.1% and will be stubborn to reduce now with energy prices rising.

    And Jack, I’m sure the populations in parts of Africa who enjoy good reserves of gas and are building plants to convert that into fertilizer will be really chuffed with the World Bank! Not to worry, China will fund it. But then ask the question-why? And what will be the result? The answers are probably not on Giggle, and certainly not in the Guardian.

    • For the avoidance of doubt:
      ‘In exceptional circumstances, the Bank said it would consider lending for oil and gas projects in the very poorest countries but only where it helped the poor get access to energy and the project did not conflict with commitments to reduce greenhouse gases made in the 2015 Paris climate change accord.’ so this will likely include some of those ‘parts of Africa’ but not the definitely not the UK.

  7. Interesting to note that the seismic traffic light regulation will cease 2 weeks after a frack. Without any detailed geological qualifications, I would have thought that pumping water into the ground at massively high pressure, laced with chemicals to make it nice and slippery would effectively grease the works of any cracks, fissures and faults it may come across (water is very effective at doing that without even huge pressure applied). Why would oiling the works suddenly cease after 2 weeks? Any genuine experts out there feel able to comment sensibly?
    Having spent many years working closely with the EA, can I point out that the agency is stuffed full of environmentalists (clue in the title) and there will be a great number opposed to fracking. However, the EA must do the bidding of it’s political masters, aided and abetted by senior career civil servants, many of whom would sell their granny for another notch up the greasy pole. The rest of them will probably be very reluctantly keeping hold of their jobs prior to the next round of cuts, yet still expected to police and enforce those fabled gold standard regulations.
    Finally, having listened to first hand accounts of those who have suffered at the hands of the fracking industry in US, Canada and Australia, they all say they were promised gold standard regulation, then in reality it all ends up the same, with govts, industry, regulators and even the judiciary colluding to cover up the worst excesses and poor practises. Strange how we’ve not even started and the standards are eroding already.

    • Mike
      Re the traffic light system
      It is designed to operate as you frack. Start fracking, no induced seismicity then crack on. If you get M 0 to 0.5 then proceed with caution, maybe reduce injection rate. Exceed M 0.5 then stop.

      Starting to monitor prior to fracking gives a base line, and post gives info on any post fracking issues, but as you have stopped fracking, it is only information for the next frack.

      The normal monitoring for earthquakes continues, frack or no frack, see we.earthquake.bgs

  8. I would suspect Mike, that the key aspect to the PNR site over the next few months, and when fracking starts, is to conduct a frack and then record the results of that frack. Based upon that, then maybe the next frack will utilise the data from the previous frack(s) to adjust the technique, and then go again. Could be very different if and when production is underway. I think the EA comments indicate that they recognise that adjustments may be built in eg. the requirement for individual plans for individual wells.
    There does seem to be a “failure” by some to remember this is a test site currently and to extrapolate/speculate on what might develop. I can understand that but the focus currently should be on safely collecting meaningful data so a judgement can be made whether to proceed or not. Call me old fashioned but I prefer an evidence based decision drawn from such a test in the UK than relying upon those with their own agendas/experiences from thousands of miles away.

    • So, off went the Emperor in procession in his diesel four wheeled drive. Everyone in the streets and the windows said, “Oh, how fine is the gas from the shale! We shall worry no more that the lights will go off. And see the benefit to the community and the jobs it has created!” Nobody would confess that he couldn’t see any sign of viable sweet gas, for that would prove him either unfit for his position, or a fool. No utterance the Emperor had sworn before was ever such a complete success.

      “But he hasn’t turned anything on,” a low birth weight child said, coughing.

      “Did you ever hear such innocent prattle?” said its father, wheezing. And one person whispered to another what the child had said, “He hasn’t turned anything on. A child says he hasn’t turned anything on.”

      “But he hasn’t got anything to turn on!” the whole town cried out at last.

      The Emperor shivered in the arctic blast, for he suspected they were right. But he thought, “This procession has got to go on.” So he walked more proudly than ever; even as the ground shook; as his noblemen held high the planning permission document with 101 changes, for the gas that wasn’t there at all.

    • In some ways I agree Martin. Safely collecting meaningful data to inform future regulation, tick. Which of course includes 100% essential baseline data on every aspect before anything begins, or it ceases to be meaningful. Where we diverge is the ludicrous suggestion that data from 10+ years of practical experience from fracking in other countries should be inadmissible. Irrespective of the gung ho, suck it and see approach the industry appears to have used extensively in other ‘desolate’ locations, a huge amount of data and evidence should be directly transferrable and valid despite variations in regulatory regimes. These range from health issues, air pollution, seismicity, effects of traffic, waste water composition and treatment etc. To start again from scratch involves ignoring a whole raft of well known and proven risks (no, don’t google, look at the peer reviewed science). What possible motive could there be for such an approach? Perhaps to set the precedent of allowing the industry a credible foothold with a moderate number of wellpads, all with the excuse of ‘test fracking’, followed coincidentally by a few years of commercial use, should they prove viable?
      From what I’ve seen and heard first hand, I think the EA has been given precious little choice in what it thinks, says or does. I also think it will be quite unable to police or enforce its own constantly watered down regulation beyond the first couple of wells – and even those are debatable. But that’s just my own opinion and will need some very credible evidence to change it – not the sort of industry line trotted out in the comments on here.
      A final point: Robust monitoring, data collection and analysis is there for everyone, whether pro, anti or don’t give a toss. Without it, nobody can PROVE what went wrong (or right), why and how to correct it. None of it is effective without a baseline. Nobody will know the extent of methane leakage and therefore whether fracked gas is less worse than coal burning. It costs money and takes time and effort though. Justifying that expense depends whether we want a reasonable and habitable environment to live in, now and for future generations, locally and globally, or whether short term profit, personal wealth and industrial growth trump all. We quite evidently have differing views.

      • Very well argued Mike Potter. I hope others see your points. Baselines will get fudged providing a ‘get out’ for O&G here no doubt (re scientific proof of culpability). Now there’s 10 years plus of statistics though and these figures will catch up with the industry ie with the pollution and health issues. Pity it’s taking so long to get laws and regulations up to scratch but these toxic, ghg emitting practices will go the way of ddt, thalidomide and tobacco for sure.

        • Thanks Philip. I’ve had nigh on 5 years of practise with those same arguments and either been ignored or received the half truth, weasel word replies. Some people see the points, others evidently have specific reasons for not seeing the points and for not responding satisfactorily. Sometimes they just go mysteriously quiet. As you say, the hard evidence grows and grows, so every delay has value.

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