Cold venting at onshore oil and gas sites

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Dear Environment Agency,

I note from the recent permit decision document that the Environment Agency (EA) has granted permission to Rathlin Energy to cold vent methane during nitrogen lifting at its site at West Newton in East Yorkshire. In the latest permit variation application for Preston New Road, Cuadrilla has sought permission for the same operation.

As a reporter, I put the questions below to Defra, which now handles press inquiries for the EA. Defra said the questions had to be dealt with by an FOI.

My questions are as follows:

1. Many environmental permits for onshore oil and gas sites – including the current Preston New Road permit - prohibit cold venting, except in emergencies. Why has the EA allowed cold venting at West Newton and will, potentially, allow it at Preston New Road?

2. Nitrogen lifting is described in the West Newton permit decision document as a common technique to help remove fluids from the well in advance of testing. For sites where the permits prohibit cold venting except in emergencies, how is cold venting avoided during nitrogen lifting?

3. Was cold venting during nitrogen lifting considered Best Available Technique at West Newton? If not, why was it permitted?

4. Has the EA asked Rathlin Energy or Cuadrilla for an estimate of the volume of methane that would be released during cold venting?

5. Does the EA calculate its own estimate of the volume of methane that would be released during cold venting at West Newton or Preston New Road?

6. In the Rathlin Energy permit variation, I can see no conditions which limit the number or duration of cold vents, or the volume of methane that would be released during cold venting. I understand that there is no proposal for this in Cuadrilla’s permit variation application. Why is this?

7. In the Rathlin Energy permit variation, the EA said nitrogen lifting would lead to cold venting for “ a short period of time”. The Cuadrilla application indicated that cold venting was unlikely to exceed one month.
a. How does the EA define “short period of time” at West Newton?
b. Is one month of cold venting typical of the sites where cold venting is allowed?
c. What volume of methane (or range of volumes) would the EA expected to be released during testing one well for one month at Preston New Road?

8. What national inventory of cold vented methane does the EA keep across the onshore oil and gas industry in England? If there is no national inventory, why is this?

9. How many onshore oil and gas sites in England are permitted to cold vent?

10. What is the likely carbon footprint of one month of cold venting methane from Preston New Road?

11. What range of gases, other than nitrogen and methane, could be released from an oil or gas well during cold venting following nitrogen lifting?

Yours faithfully,

Ruth Hayhurst

Enquiries, Unit, Environment Agency

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Dear Ruth,

 

Thank you for your request for information.

 

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Dear National Requests,

Please note that by law the Environment Agency should have responded to my request by 13 September 2019. I'd be grateful if you would provide the information requested as soon as possible.

Yours sincerely,

Ruth Hayhurst

National Requests, Environment Agency

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Dear Ruth

 

We apologise for the delay in providing a response to your request for
environmental data.

 

We are working hard to look at your request and will respond back to you
as quickly as we can.

 

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From: Ruth Hayhurst [mailto:[FOI #597488 email]]
Sent: 16 September 2019 14:01
To: National Requests <[email address]>
Subject: Re: NR139924

 

Dear National Requests,

 

Please note that by law the Environment Agency should have responded to my
request by 13 September 2019. I'd be grateful if you would provide the
information requested as soon as possible.

 

Yours sincerely,

 

Ruth Hayhurst

 

show quoted sections

Dear National Requests,

This is a reminder that your response is now 11 days overdue. By law it should have been sent on 13 September 2019.
I look forward to hearing from you as soon as possible.

Yours sincerely,

Ruth Hayhurst

National Requests, Environment Agency

5 Attachments

Dear Ruth

 

Enquiry regarding management of gas emissions at onshore oil and gas sites

 

Thank you for your enquiry which was received on 15 August 2019. I
apologise for the delay in providing this information.

 

We respond to requests under the Freedom of Information Act 2000 and
Environmental Information Regulations 2004.

 

Taking your enquiry in the order you presented it, please find our
response below:

 

1.     Many environmental permits for onshore oil and gas sites –
including the current Preston New Road permit - prohibit cold venting,
except in emergencies. Why has the EA allowed cold venting at West Newton
and will, potentially, allow it at Preston New Road?

 

In limited circumstances venting may be the best practical and
environmentally appropriate way of managing emissions on an exploration
site. We assessed the use of nitrogen to aid initial flow and reviewed the
justification provided as part of the Gas Management Plan for the West
Newton A site and we are satisfied that it is appropriate.

 

We are still in the process of assessing the proposal from Cuadrilla for
Preston New Road and so cannot comment further.

 

2.     Nitrogen lifting is described in the West Newton permit decision
document as a common technique to help remove fluids from the well in
advance of testing. For sites where the permits prohibit cold venting
except in emergencies, how is cold venting avoided during nitrogen
lifting?

 

The permitting regime requires that operators submit a Waste Management
Plan as part of their permit application. This sets out an operator’s
intended measures to control the waste on site to prevent or, where that
is not practicable, to minimise emissions of waste gases and their overall
environmental impact. There are many variables associated with individual
sites which will influence technology choice, including operational
conditions or the phase of operation.

 

3.     Was cold venting during nitrogen lifting considered Best Available
Technique at West Newton? If not, why was it permitted?

 

We assessed the use of nitrogen to aid initial flow and reviewed the
justification provided as part of the Gas Management Plan for the West
Newton A site and we are satisfied that it is appropriate.

 

4.     Has the EA asked Rathlin Energy or Cuadrilla for an estimate of the
volume of methane that would be released during cold venting?

 

No. During oil and gas exploration waste gas releases are very difficult
to predict. Any releases would typically be at a variable flowrate, but of
short duration or variable composition. 

 

We carry out audits to ensure that an operator has taken appropriate
measures to minimise emissions of waste gases. If we believe an operator
has not taken appropriate steps to minimise emissions we may take
enforcement action against them.

 

5.     Does the EA calculate its own estimate of the volume of methane
that would be released during cold venting at West Newton or Preston New
Road?

 

During permit assessment our aim is to ensure that an operator has set out
appropriate measures to minimise emissions of waste gases as part of their
gas management plan. We then carry out compliance checks to determine
whether an operator has correctly followed the processes as set out in
that plan. If they haven’t we may take enforcement action against them.

 

6.     In the Rathlin Energy permit variation, I can see no conditions
which limit the number or duration of cold vents, or the volume of methane
that would be released during cold venting. I understand that there is no
proposal for this in Cuadrilla’s permit variation application. Why is
this?

 

For the West Newton A site we have assessed the use of nitrogen to aid
initial flow and reviewed the justification provided as part of the Gas
Management Plan and we are satisfied that it is appropriate. We do not
specify a limit on volume or duration, however we do carry out site audits
to check that a company has taken appropriate measures to minimise
emissions.

 

The Preston New Road permit variation is still under consideration.

 

7.     In the Rathlin Energy permit variation, the EA said nitrogen
lifting would lead to cold venting for “a short period of time”. The
Cuadrilla application indicated that cold venting was unlikely to exceed
one month.

 

 a. How does the EA define “short period of time” at West Newton?

 

The agreed process for West Newton is set out in the gas management plan.

 

 b. Is one month of cold venting typical of the sites where cold venting
is allowed?

 

The time period may vary from borehole to borehole as would the rate and
amount of gas flow. We audit flare and gas management to assess compliance
against the Environmental Permit conditions.

 

 c. What volume of methane (or range of volumes) would the EA expected to
be released during testing one well for one month at Preston New Road?

 

The Preston New Road permit variation is still under consideration. We
cannot comment further.

 

8.     What national inventory of cold vented methane does the EA keep
across the onshore oil and gas industry in England? If there is no
national inventory, why is this?

 

Sites with an Industrial Emissions Directive (IED) activity are required
to submit Pollution Inventory annual returns.

 

9.     How many onshore oil and gas sites in England are permitted to cold
vent?

 

We do not collate this information nationally. Operational activities for
each site are described in operators waste management plans.

 

10.  What is the likely carbon footprint of one month of cold venting
methane from Preston New Road?

 

The Preston New Road permit variation is still under consideration.

 

11.  What range of gases, other than nitrogen and methane, could be
released from an oil or gas well during cold venting following nitrogen
lifting?

 

This will differ on a site by site basis. Predicted gas composition for
each site will be included in the permit application through the gas
management plan.

 

Please refer to [1]Open Government Licence which explains the permitted
use of this information.

 

Please get in touch if you have any further queries or contact us within
two months if you’d like us to review the information we have sent.

 

Kind Regards

 

National Request Team

National Customer Contact Centre

Environment Agency

 

( Tel: 03708 506 506

: Web Site: [2]www.gov.uk/environment-agency

 

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