Rathlin Energy have applied to the Environment Agency to vary the Environmental Permit for their West Newton A wellsite.
Here is a guide that you may find useful when objecting.
What has Rathlin Energy applied for?
- Changes to the types of waste streams, including but not limited to, carbon dioxide (CO2) as part of a liquid CO2 treatment.
- Changes to the installation permit to accommodate well clean up operations and extended well testing operations.
- Add an additional activity for the storage and handling of crude oil under section 1.2 of Schedule1 of EPR2016.
How can I respond?
When is the deadline?
Monday 11th February 2019
What should I tell the EA?
Why you are objecting – What is your interest in the site? E.g. Are you a local person? Do you have a business close by?
What can I mention on my objection?
You could mention (using your own words):
Well clean up operations
- It is of concern that Rathlin Energy are only applying for changes now having already carried out a similar operation in 2014.
- What are the reasons that Rathlin Energy are discussing ‘acid washes’ now and have never discussed this previously?
Acid Wash and Squeeze
- An independent well inspector is to oversee the operation for the duration. It is unclear who will do this, when, or how ‘independent’ they will be.
- Public access to this information is also a concern. It is unclear how the EA will monitor this.
- There are concerns related to the point at which an acid wash or squeeze may cross the boundary and become well stimulation, or acid fracturing. The pressures required are critical to prevent an acid wash from becoming well-stimulation. Rathlin Energy is prohibited from carrying out an Acid Frack activity under the ‘no fracking’ condition of its existing EA permit.
- The EA is not in a position to verify objectively the company’s self-assessment of its procedures. At the same time it cannot have full confidence in the company’s self-assessments because of the licence breaches committed by Rathlin Energy in the past.
- The use of acid in well-stimulation is a relatively new and unresearched method, and the risk is such that the EA must be satisfied that there is no risk of accident or pollution. In its response to the findings of the EA and the HSE following the EA permit breaches in 2014, the company admitted ‘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.’
- The EA needs to ensure that the intentions of the company are exactly as stated, that there is no likelihood of accidentally crossing the boundary between well maintenance and well stimulation, and that the processes proposed will be carried out in strict accordance with the permit requirements. Given the limited resources of the EA this is a matter of great concern. The acidisation processes proposed could lead to environmental damage
- Acidisation is due to be banned in Florida along with High Volume Hydraulic Fracturing. So it is of concern.
- Hydrochloric acid is a highly toxic and there is a risk of ‘Slight pollution occurrence which would be restricted by well control’. Hydrochloric acid entering soil where current or future food production is of great concern. Especially as Rathlin Energy appears to intend to use around 17 tonnes of solution containing this highly toxic substance!
- Again the EA cannot be certain that the well will be constructed to a high enough standard as the EA only has the independent well examiners assessments to go on via the EA and this information is very difficult to obtain in the public domain. The public is putting an awful lot of trust in Rathlin Energy.
- How can the EA be sure that the well being drilled really is vertical? The well itself will be something diagonal. How can the EA be sure that Rathlin Energy will not Matrix acidise or acid frack in the future if it is not doing that now as ‘claimed’ (Though it is a high percentage of Hydrochloric acid to use in simple acid washes).
Multiple Extended Well tests
What do Rathlin Energy mean by ‘multiple’? Why has this changed now?
Handling and Storage of Crude Oil
“Management action ‘should prevent’ spills from happening” does not fill one with confidence. This should read as ‘MUST’ even within a Risk Management Plan.
Changes to waste streams – CO2
Why has this been changed now? If this adds to the overall CO2 emissions output as shown by Rathlin Energy – how can the EA be sure that the figure Rathlin Energy has quoted is accurate (however small)?
Other things you could mention:
AIR EMISSIONS RISK – Climate Change
Rathlin Energy states that there may be “Minute levels of CO2 compared to global scale”
in relation to emissions from the power generator, flaring natural gas and from vehicles attending the site. This is deceptive; it actually means around 30 tonnes of CO2 per day at the point of well test.
The region urgently needs to reduce the emissions of CO2 urgently if Hull and East Yorkshire, along with the UK is to meet its climate change targets and avoid climate breakdown.
This is adding to the issue no matter how ‘small’ they claim it is. The public rely on the EA to safeguard our environment. Is the EA confident that it is doing this?
GLOBAL WARMING POTENTIAL
it is clear again that despite Rathlin Energy’s assurance that the ‘Greenhouse gases’ it is emitting over several stages, is low in comparison to global figures they are nevertheless adding to this which is completely unacceptable given the future implications for the climate and its consequences for us a region. If Rathlin Energy cannot guarantee little or no emissions then this operation should not be going ahead as there is an urgent need to reduce the UK emissions.
How can this be justified as environmentally safe from the EA’s standpoint?
DISPOSAL AND RECOVERY OF WASTE PRODUCED ONSITE
Spent Hydrochloric Acid
Rathlin Energy claim the hydrochloric acid is spent though neither the EA nor the public know this for sure. How does the EA and public know where the acid will really end up? No one knows. Can the EA demonstrate that all hydrochloric acid is actually spent and how will the EA do this?
NORM (Naturally Occurring Radioactive Material) waste is of great concern. Rathlin Energy needs to be absolutely clear about how long low level radioactive waste will be kept on site and where it will be transported if this does not appear in permissions elsewhere.
Incineration of Natural Gas during testing operations
- There is no guarantee that there will be no odour issues as occurred previously, again the EA are relying on the company to follow the Risk Management plan – how can the EA and the public be sure that Rathlin Energy will?
- How can the public be sure that the EA make enough visits to establish that Rathlin Energy are following the Risk Management actions at all times?
FUGITIVE EMISSIONS RISK
VOC’s from exhaust systems and emissions to Air. VOC’s from tanks / pipework.
VOCs are a risk to people in the vicinity if Rathlin Energy do not carry out everything on the Risk Management Plan.
Incineration of Natural Gas during flaring operations
Doesn’t mention the risk of radon or whether this is an issue that requires monitoring and precaution. Radon detectors were fitted in homes around Kirby Misperton by BGS. Does the EA believe that ‘sensitive receptors’ require the same protections? If not why not?
POSSIBLE SOURCES OF ACCIDENTS
The many breaches made by Rathlin Energy have been identified and it has attempted to address them in the risk assessment. However, there have since been further incidents at the site and therefore public confidence has been lost.
Additional note: Suitably qualified employees
- More information is needed on the suitability of the workers to carry out work at this site. Whilst Risk Management Plans look good, they are only as good as those using and FOLLOWING them
- There is not enough evidence that workers are receiving adequate training on the risk management plan, that this is being monitored by an authority and that Risk Management is being followed. Whilst this may fall into HSE’s remit it is important that the EA consider this point in awarding a variation to the current permit.
- Does the EA have the resources to make the necessary checks?
- It is unclear WHEN and WHO will be responsible for undertaking the Risk Management Points
NOISE AND VIBRATION
Again no one can be sure that Rathlin Energy will stick to the agreed plan.
Whilst Rathlin Energy appears to have included an Environmental Risk Assessment there is no reassurance that the Risk Management Actions set out will be followed and adhered to. In 2014 Rathlin Energy was responsible for at least 19 Breaches.
Confidence in Rathlin Energy to follow its Risk Management Plan is doubtful. There are therefore continued risks to nearby amenities including the SSSI, SPA and water features and ‘sensitive receptors’ (as Rathlin Energy refers to them).
Rathlin Energy has shown that they have poor management, pour odour control, staff competency is an issue and reporting has been inadequate.
The EA should therefore be fully satisfied regarding the company’s future performance, its intentions, and the likelihood of its full compliance with the permit as well as being confident in its ability to monitor this site, before granting any variation.