The following is the full response from Rathlin Energy
The information provided by any of the regulatory authorities, in this case the Environment Agency’s (EA) CAR forms can be relied on to reflect their views of Rathlin’s operations.
As you will be aware the EA’s permitting process in respect of oil and gas exploratory drilling and testing operations has only recently instituted.
In the autumn of 2013, the EA advised all onshore operators that all oil and gas drilling and testing operations would require EA permits for a variety of the operation activities associated with these works. Previously, these operations were not subject to environmental permitting requirements.
In May of 2014, the EA granted Rathlin permits for drilling an additional well and testing operations at both the recently drilled West Newton well and the Crawberry Hill well.
In July of 2014, Rathlin commenced a programme of well testing at the West Newton location.
As with most new regulation or permit requirements there is a settling in period where both regulators and operators need to become familiar with any new permits and their suitability for operations.
Additionally, in the case of exploratory oil and gas drilling and testing operations, there are by the specific nature of these exploratory operations a number of unknowns, ranging from the actual geology to formation pressures and formation fluids or gas composition.
In the case of the testing programme at Rathlin’s West Newton well, some of these unknowns gave rise to unanticipated on site operational challenges. These included odour issues associated with the formation gas discovered and the operation of the flare.
The EA did visit our site on a number of occasions to assess Rathlin’s compliance with the issued permits.
It important to recognise that the original permits issued for West Newton did not have a requirement for Odour Management as is was not anticipated by either the EA or Rathlin and the flaring solution(s) that were originally agreed by the EA for the test operations were overturned, requiring Rathlin and the EA to source and agree a suitable substitute flaring solution during the course of the on site operations.
During the EA site visits the EA officers did record, by way of CAR forms, compliance issues associated with the permits. The CAR form issues you have referenced are either odour related or related to documented management systems and operating procedures.
In these instances the EA has provided advice, guidance and warnings to Rathlin, regarding any compliance concerns they identified.
Rathlin consistently took on board the EA’s reports and sought to address the issues the EA had flagged up.
As with any introduction of regulation, industry and regulators need to work together to identify suitable operational procedures that can be permitted to achieve the operational objectives while minimising any impact on personnel, stakeholder or the environment.
As a direct consequence of the learnings from the West Newton well the EA has provided Rathlin with a permit variation in respect of the proposed Crawberry Hill testing operations which requires Rathlin to review and provide a new flaring solution as well as a new odour management plan prior to any works commencing at Crawberry Hill. The Environment Agency has itself approached a third party organisation to undertake a review of what BAT is for flaring operations. The intent of the exercise is to create a better regulatory environment, but it does require both regulators and industry to adapt rapidly while procedures evolve and has the potential to lead to misunderstandings/ oversights.
This is a good example of regulators and industry working together to find solutions reduce the impact of our operations on the environment.
Rathlin seeks to consistently improve operations and operating procedures and values the input of our regulatory agencies in also seeking continuous improvement.