Further information request in response to NR1367 - Use of "green completions" in fracking

The request was successful.

Dear Environment Agency,

In your response dated 21 January 2016 to the above National Request you state:

"In the [sic] England we do not allow the storage of waste waters in open lagoons or allow the venting of waste gases." However, at the Rathlin Energy site known as West Newton A technical issues with pressure led to the cold venting of gas; detailed on Compliance Assessment Report ID: 400996/0219962 breaching permit conditions 3.3.1 and 3.3.2. Despite this, and having no Odour Management Plan to prevent this reoccurring Rathlin Energy were allowed to continue unabated with their flaring. Could you therefore please answer the following questions:

1) Why, if cold venting is not allowed in England, were Rathlin Energy not heavily penalised for polluting the atmosphere but given permission to carry on with their disposal of waste gases using a system that was obviously not fit for purpose or within the parameters of their environmental permit?

2) The Environment Agency, in the full knowledge that Rathlin Energy unsatisfactorily, and in breach of regulations, managed waste gas disposal at West Newton A have you not raised any objections to Rathlin Energy continuing with their drilling programme at West Newton A and B which will once again require the flaring of waste gases?

3) Given Rathlin Energy will be, if they commence work at West Newton A and B, undergoing well testing with the result waste gases will be flared what will the Environment Agency do to ensure that gases are not cold vented in the future?

4) Will the Environment Agency be visiting the sites on an unscheduled monitoring system to ensure a stringent adherence to permits rather than, as was in the case at West Newton A, relying on Activists and Residents to report illegal venting and the release of omissions outside the compound boundary and scheduling in all their visits with Rathlin Energy?

5) Given that Rathlin Energy have stated they are not fracking, and given that the test Rathlin Energy are calling a Mini Fall-Off Test is in fact a DFIT or a Mini-Frack a test, which by any name, will still produce waste gases to be flared what assurances will the Environment Agency give that they will be monitoring the site with the same level of scrutiny and accountability that would be applied to a process that is, in point of fact, fracking?

6) If the system of reporting relies on information being given by Rathlin Energy how will the Environment Agency ensure that Rathlin do not illegally undertake a Mini-Frack but rather state their test is called something else that implies as a company they are not fracking?

Yours faithfully,

Louise Castro

Enquiries, Unit, Environment Agency

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Foers, Kathryn D, Environment Agency

Dear Louise Castro

 

Thank you for your request for information.

 

We are treating your enquiry as an Information Request under the
Environmental Information Regulations 2004/Freedom of Information Act
2000.

 

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reference NR1981.

 

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National Requests, Environment Agency

Dear Louise

 

We will be slightly delayed in providing a response to your request for
information received on 25 January 2016, reference number NR1981.

 

We are currently experiencing high volumes of requests for information and
we are working hard to try to meet the needs of our customers. Your
patience would be appreciated and we will respond to your enquiry as soon
as we can.

 

Please accept our apologies.

 

Kind regards

 

Maria Bisby

Environment Agency

National Requests Team

Part of National Operations

03708 506 506

[1][email address]

 

 

 

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National Requests, Environment Agency

1 Attachment

Dear Louise Castro,

Enquiry regarding the storage of waste waters and West Newton A.

 

Thank you for your enquiry which was received on 25 January 2016.

 

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

 

Please find our response to your questions below.

 

1) Why, if cold venting is not allowed in England, were Rathlin Energy not
heavily penalised for polluting the atmosphere but given permission to
carry on with their disposal of waste gases using a system that was
obviously not fit for purpose or within the parameters of their
environmental permit?

 

Cold venting of flammable hydrocarbon gas from well testing was not a
disposal method authorised by the Environmental Permit for the Rathlin
Energy UK Ltd (Rathlin Energy) West Newton ‘A’ Well Site.

 

We investigated the release of gas from the West Newton ‘A’ well site and
concluded that there had been a permit breach, but this has not had a
significant environmental impact. The permit breach was dealt with in line
with our Enforcement and Sanctions statement and guidance. Following the
permit breach Rathlin Energy put measures in place to prevent a recurrence
of the action which led to the release of gas.

 

2) The Environment Agency, in the full knowledge that Rathlin Energy
unsatisfactorily, and in breach of regulations, managed waste gas disposal
at West Newton A have you not raised any objections to Rathlin Energy
continuing with their drilling programme at West Newton A and B which will
once again require the flaring of waste gases?

 

We were consulted on Rathlin Energy’s planning application for the West
Newton ‘B’ site by East Riding Yorkshire Council. Our response highlighted
that the proposed activities would require environmental permits. The
company have submitted applications for permits and we are currently
assessing these. If an activity poses an unacceptable risk to the
environment, the activity will not be permitted. As explained in the
earlier question Rathlin Energy has put measures in place to prevent
recurrence of the circumstances that led to the release of flammable
hydrocarbon gas at West Newton ‘A’.

 

3) Given Rathlin Energy will be, if they commence work at West Newton A
and B, undergoing well testing with the result waste gases will be flared
what will the Environment Agency do to ensure that gases are not cold
vented in the future?

 

The performance, specification and predicted environmental impact of the
flare under a range of operating conditions will be assessed by the
Environment Agency as part of the environmental permitting process and in
advance of any operations starting. If an environmental permit is issued
for West Newton ‘B’ it will not authorise the disposal of flammable
hydrocarbon gas from well testing by cold venting.

 

As with all oil and gas operations there is potential for minor and
non-significant releases of gas from tank breather pipes, when breaking
containment for sampling (for example disconnecting pipework) or when
dismantling equipment. As part of any application for an environmental
permit an operator must set out the procedures they will follow to
minimise emissions. If a permit is issued part of our regulatory work
would be to carry out site checks during operations to ensure the operator
has done everything necessary to protect the environment.

 

4) Will the Environment Agency be visiting the sites on an unscheduled
monitoring system to ensure a stringent adherence to permits rather than,
as was in the case at West Newton A, relying on Activists and Residents to
report illegal venting and the release of omissions outside the compound
boundary and scheduling in all their visits with Rathlin Energy?

 

We target our compliance of all regulated sites on the basis of risk
giving more attention to activities that have greater potential to cause
environmental harm, or to operators who have history of poor performance.
We will continue to apply those principles to the regulation of any
further activities that may be undertaken by Rathlin Energy.

 

Where reporters notify us of an issue they believe is related to
activities or sites we regulate our response to that report will be
proportionate to the apparent environmental risk. We do not need to give
companies notice of inspections and can make unannounced visits.

 

5) Given that Rathlin Energy have stated they are not fracking, and given
that the test Rathlin Energy are calling a Mini Fall-Off Test is in fact a
DFIT or a Mini-Frack a test, which by any name, will still produce waste
gases to be flared what assurances will the Environment Agency give that
they will be monitoring the site with the same level of scrutiny and
accountability that would be applied to a process that is, in point of
fact, fracking?

 

We take the environmental risks associated with oil and gas exploration
and production very seriously. We are committed to ensuring that people
and the environment are protected. We undertake planned and unplanned site
inspections, audits and spot checks.  We will investigate potential permit
breaches or environmental impacts that may be caused by an operation. If
we think there is a risk to people or the environment we can use our
enforcement powers to shut down an operation.

 

6) If the system of reporting relies on information being given by Rathlin
Energy how will the Environment Agency ensure that Rathlin do not
illegally undertake a Mini-Frack but rather state their test is called
something else that implies as a company they are not fracking?

 

As covered above

 

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.

 

Yours sincerely

 

 

Environment Agency

National Requests Team

Part of National Operations

03708506506

[1][email address]

 

 

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