APPEAL BY ISLAND GAS LTD, PORTSIDE ELLESMERE PORT
APPEAL REFERENCE APP/A0665/W/18/3207952
FINAL – PROOF OF EVIDENCE – FINAL
COLIN D WATSON B.ENG C.ENG MIET
SITE LOCATION AND POTENTIAL IMPACTS
Table of Contents
The Planning application
The Location – Looking Back and Looking Forward
The Location – Changes since the 2017 Planning application
Risk Above Ground
Safe Distance between Well and People
SSSI / RAMSAR / SPA site
Risk to the Groundwater
Appendix 1 – Local Incident 23 Aug 2018
Appendix 2 – Casual Internet Search of Incidents in USA
Appendix 3 – Extract from the Texas Railroad Commission log
Appendix 4 – Statement by Cheshire Wildlife Trust
Appendix 5 – Statement by Chester Zoo
Appendix 6 – Article from “Insurance Journal” (USA)
I hold a Bachelor of Engineering Degree (2:1 Hons) from Liverpool University. I have been a Chartered Engineer for thirty-five years, and am a Member of the Institute of Engineering Technology.
I have extensive experience in the management of industrial processes, large project management and the management of risk. Initially within the nuclear industry, I worked as a control specialist on uranium enrichment and spent fuel reprocessing facilities. Subsequently within the chemicals industry I broadened into facilities design, construction and operation, and latterly was the “Subject Matter Expert” for Project Management in a large multi-national corporation based locally.
I have recently been a PRINCE 2 practitioner and a member of the Project Management Institute, and have contributed to their global standards: the Project Management Body of Knowledge and the Portfolio Management standard.
More recently I have worked as a consultant, training multinational companies based around Europe on Project and Risk Management.
I am aware that I have a duty to assist the inquiry. I confirm that the evidence I produce here is true to the best of my knowledge and belief, representing my honestly held view, informed by my professional experience as set out above.
1.1 In this proof of evidence I address two topics:
- The description of the Planning application, and in particular the ambiguities and contradictions in the IGas case;
- The location of the proposed development, what has changed since the 2010 planning permission was granted, what had changed more recently, and why the location is not sustainable given the risks it imposes.
1.2 Ellesmere Port is a town of 55,000 residents (2011 Census). Since the 2010 permission, and overlapping with the 2017 Planning application, a major housing estate has been built so that there are now houses 320m from the site. When the planning permission was originally granted, the nearest house was 600m away. Also since the 2017 Planning application, new businesses have moved onto the industrial estate and are now directly adjacent to the proposed development, including U Tow Caravans Ltd (Sales and Servicing), and a petroleum distribution terminal. There would also appear to be changes in the long term use of the surrounding land, moving away from any industrial aspirations.
1.3 The principle of Sustainable Development as quoted in the NPPF, is summarised in the following diagram by Johann Dréo (2006):
1.4 It therefore follows that for development to be sustainable it needs to satisfy multiple criteria at the same time. This PoE will demonstrate that this Planning application does not, as a result of its location, satisfy these multiple criteria.
2. The Planning Application
2.1 The Application Form, and all of IGas’s subsequent documents, describe the proposed development as:
“Mobilise well test equipment, including a workover rig and associated equipment, to the existing wellsite to perform a workover, drill stem test and extended well test of the hydrocarbons encountered during the drilling of the EP-1 well, followed by well suspension” (CD 2.3pg 3)
This does not specify the extraction technique. It does not mention an “acid squeeze”, “acid wash”, nor any other form of stimulation.
2.2 The background to this Planning application shows why the local community do not trust IGas, and also why it is not surprising that the local community thought that IGas was applying to carry out some form of an acid frack.
2.3 The initial Planning Approval in 2010 was for Coal Bed Methane, and was accompanied by the following diagram (Fig 1) which states clearly a total vertical depth of 900m, and a lateral reach of 500m.
Fig1 Drawing accompanying the 2010 Planning application
2.4 The Planning Statement section 9.3.6 (CD 1.5) states
“two boreholes will be drilled to an estimated minimum depth of circa 900metres (3,000’). The borehole will typically decrease in diameter from 500mm (20 inches) at the top section to 152mm (6 inches) in diameter at the maximum depth in the coal seam.”
So the drawing, which had to be complied with under condition 3 (CD 1.1 pg 1), specified a 900m maximum depth; the Planning Statement estimated a 900m minimum depth but a maximum depth “in the coal seam”. Whilst there has been much discussion about the actual depth permitted, the Planning application was to the maximum depth specified in the coal seam, which was not the 2,000m drilled to.
2.5 In the initial Planning application (CD 1.5) IGas produced information which they said explained what they would be doing. See for example the Community Information document, (CD 1.8), which only ever mentioned drilling for Coal Bed Methane. The description of the development in the 2010 planning permission was for “Drilling of two exploratory boreholes for coal bed methane appraisal and production.” (CD 1.1). That was supposed to take place “in strict accordance”with the plans, including the plan set out above – see condition 3.
2.6 It was therefore with some surprise that the community found out in the 2017 Planning application, that IGas had in fact explored for shale down to circa 2,000m – much more than the “900m total vertical depth”identified in the drawings accompanying the planning application, reproduced above. Shale extraction involves very different processes than coal bed methane, and the two cannot be compared. The community got the strong impression that IGas breached the 2010 planning permission. This impression remains, even though we understand the Council does not consider that there was a breach. This is in more detail in Prof Smythe’s evidence.
2.7 This is also why there is so much concern about a lack of specificity in the current application. IGas has previously exploited apparent “ambiguity” in a planning application and the subsequent permission to carry out operations that it was never expected would occur.
2.8 It is helpful to set out the Environment Agency (“EA”) definitions from their document “Use of acid at oil and gas exploration and production sites – January 2018” (EP20):
Acid Wash“An acid wash is used to clean the well out following drilling in order to return the natural porosity and permeability of the damaged formation……. Plain water or weaker concentrations of acid (usually HCl at 7%) may be used if it is suitable”.
Matrix Acidisation “Matrix acidisation involves pumping dilute acid into the oil and / or gas reservoir from the well. The acid is injected, or “squeezed”, in to the geological formation at a pressure that is above the geological formation pressure but below the formation fracturing pressure.” “The Environment Agency does consider matrix acidisation to be a form of stimulation”
Acid Fracturing “To enable fracture acidisation the acid is pumped in to the well at pressures above the geological formation fracturing pressure” “The Environment Agency does consider fracture acidisation to be a form of stimulation”
Acid Squeeze“The term acidisation can include acid washes, matrix acidisation and fracture acidisation. Other terms that are frequently used to cover matrix acidisation and fracture acidisation include “acid squeezes” and “stimulation” respectively.”
“An “acid squeeze” is an oil industry term that is generally used when the intention is for the acid to not travel far from the well in to the geological formation. It is most frequently used when the permeability of the geological formation is very low. An acid squeeze results in the acid being squeezed in to the rock formation and dissolving the rock. It may also result in opening up new fractures, although very small and close to the well. This may enhance or create new flow paths to enable the well to be more productive. Exactly the same processes are at work as in acid washing, matrix acidisation and fracture acidisation, but just at a very local scale to the well due to the poor permeability of the geological formation.”
2.9 Whilst the EA document explicitly states that an “acid wash” is not a form of stimulation, it likens an “acid squeeze” to the activities that it defines as “stimulation”:
“Exactly the same processes are at work as in acid washing, matrix acidisation and fracture acidisation”.
2.10 It appears that the key element which makes a process “matrix acidisation” is that the “pressure is abovethe geological formation pressurebut belowthe formation fracturing pressure” (emphasis added), and the only difference between an acid squeeze and matrix acidisation is the distance that the acid travels from the wellbore.
The Planning application and Appeal Documents
2.11 The description of the development is repeated in the Planning Statement in section 2.1 (CD 2.4). Because the description does not set out the actual extraction technique, the Planning Statement “clarifies” in this way:
“For clarity, the proposed development does not involve any drilling or deepening of the existing EP-1 well and does not involve any hydraulic fracturing. It only relates to the flow testing of the EP-1 well and associated preparatory works (workover) necessary to prepare the well for test.” (CD 2.4pg 10)
2.12 It is clear IGas is concerned to rule out hydraulic fracturing. At this point we note the definition of “hydraulic fracturing” as defined in the Infrastructure Act 2015, pg 56 Section 4a:
“Associated hydraulic fracturing” means hydraulic fracturing of shale or strata encased in shale which:
(a) is carried out in connection with the use of the relevant well to search or bore for or get petroleum, and
(b) involves, or is expected to involve, the injection of (i) more than 1,000 cubic metres of fluid at each stage, or expected stage, of the hydraulic fracturing, or (ii) more than 10,000 cubic metres of fluid in total.
Note that the definition is purely volume based, and the Planning Statement (CD2.4) makes no reference to volumes of fluid used.
2.13 But saying it is not hydraulic fracturing does not explain what the extraction process is. While we know now that IGas describes the process as an “acid squeeze”, in fact that phrase is not used anywhere in the Planning Statement. It only mentions “acid” once, in section 6.2.3 and 6.3, where it talks in broad terms about the well being “flowed”. It sets out that there will be a Drill Stem Test (“DST”) and Well Clean-up (pgs 21-22) and then an Extended Well Test (“EWT”) (pg 24), and then states:
“In order to re-establish natural flow, a dilute acid, most commonly hydrochloric acid (HCI) at 15% concentration with water is applied to the near wellbore formation through the perforations.” (CD 2.4section 6.2.4 pg 22)
2.14 This does not state the type of acid process that will be used, but the reference to a 15% concentration seems to exclude an “acid wash” according to the EA definition document EP20, as set out above, but could include “acid squeeze” “matrix acidisation”, and “acid fracturing”.
2.15 The lack of clarity in the Planning Statement meant that the local community was not able to tell which of the processes using acid was planned. The Planning Statement does not say anything about the pressure, or the volumes planned.
2.16 There has been a lot of justified concern about the use of acid as a way to avoid the controls on hydraulic fracturing – see the documents produced by the Weald Action Group EP5 (Everything you wanted to know about acidizing) and EP8(Fracking under the radar), who have experience in dealing with planning applications for acid stimulation for oil.
2.17 Furthermore, the Planning Statement identifies that there will be 125 HGV movements during the key phases (CD 2.4Section 6, subsequently clarified to 57 + 60 wellbore movements in EP23– IGas letter 5th Nov), and that IGas will be using a fluid “most commonly hydrochloric acid”(CD 2.4Section 6.2.4), which generates some doubt over what fluid will be actually used since the alternative is the highly reactive hydrofluoric acid identified by the EA (EP20).
2.18 The lack of clarity continues in I Gas’s Appeal Statement of Case (July 2018, CD 4.1). The proposed development is described in section 3, in the same terms as in the Planning Statement, with the DSTandEWTdescribed in terms of “flowing” the formation (paragraphs 3.2.3-6 pg 5). The use of acid is addressed in paragraph 3.2.4:
“The DST is expected to last for 14 days within a 28-day operational period, on the basis of 24 hour working days….To re-establish natural flow in the formation, a dilute acid (most commonly hydrochloric acid) at 15% concentration with water is applied to the near wellbore formation through the perforations.”
The EWT will “use the same process as the DST” (paragraph 3.2.6).
The concerns noted in 2.12 above remain.
2.19 CD 4.1 Paragraph 3.2.4. is the only paragraph in the whole of the Appeal Statement of Case that mentions the word “acid” in this context, or describes the process. Yet again, there is no mention of its purpose, or of the pressure to be used. It therefore does not rule out “matrix acidisation”, nor “acid fracturing”.
Pre-Inquiry Correspondence with IGas
2.20 FFEP&U wrote to IGas a number of times to ask them to clarify what the proposed method of extraction actually was. Initially, on 5 November 2018 (EP23), IGas responded:
“With regard to your request for confirmation that the proposed development is not for conventional oil and gas extraction, we can confirm that the Pentre Chert is a conventional resource. The Appellant will not be carrying out any drilling, hydraulic fracturing or acid fracturing activities as part of the proposed development.”
2.21 FFEP&U wrote back on 12 November (EP23), pointing out that IGas Statement of Case supported the grant of planning permission because it would obtain data on “theunconventional hydrocarbon resourcein the area …without the need to construct a new compound or the need to drill a new well”. That letter also challenged the description of the Pentre Chert as a “conventional resource”, as FFEP&U’s understanding was that “Pentre Chert is a tough, brittle rock which is not permeable. Rock with low permeability is classified as an “unconventional resource”, as will be developed further in the evidence submitted by Prof. Smythe.
2.22 On 22 November (EP23), IGas wrote:
“the method of extraction is simply the perforation of the well casing and acid washing or, if required, an acid squeeze (applying the definitions of those terms by the Environment Agency). This is reflected in the terms of the Environmental Permit granted by the Environment Agency, which is the appropriate regulatory regime and which was the subject of public consultation.
The proposed extraction method is reliant solely upon the pressure within the formation flowing the natural gas to surface. No stimulation (the development of new fractures) or artificial lift of the natural gas is proposed.”
Before this date, IGas had never said in any of the planning documents that they would potentially carry out an “acid squeeze”.
2.23 IGas did not acknowledge this in their letter of 22 November (EP 23). Instead, they effectively relied on the ambiguity in their Planning Statement. The letter continues “As set out in Section 6.2.4 of the Planning Statement submitted with the planning application, the purpose of the acid (be it an acid wash or an acid squeeze) is to deal solely with the drilling fluid, fine cuttings, cement etc impeding natural permeability.”The lack of clarity in the statement allows IGas to undertake either an “acid wash” or an “acid squeeze”, but without actually setting out that is what they intend to do.
2.24 IGas went on in the letter to accept that the Pentre Chert is “low permeability” and that “no stimulation or artificial lift is required or proposed for this scheme”.
The Environmental Permit
2.25 As IGas specifically referred to the Environmental Permit, it is necessary to see what it says, and also to look at the permit application documents which are cross-referred to in the Permit.
2.26 The Environmental Permit, varied on 10 November 2017 (CD 2.12) does not mention the terms “acid wash” or “acid squeeze”. Instead, it lists table S1.2 in Schedule 1 what the “operating techniques” are that are permitted, by way of cross-reference to the various application documents provided by IGas (pg 10). The Non-Technical Summary of these documents (CD 1.9) states at paragraph 6.5.3:
“During the DST, if it is evident that the flow of petroleum is restricted an acid, most commonly hydrochloric acid (HCI) at 15% concentration with water (i.e. 150kg of HCI with 850kg of water), is applied to the formation through the wellbore. The operation is very much akin to acidisation of boreholes in the water well industry and results in high permeability channels through which water or petroleum can flow.
An acid wash is applied using low pressure and can be used to clean out the natural fractures, having potentially been blocked as a result of the initial drilling operation. An acid squeeze is applying the acid to the formation under pressure not exceeding the fracture pressure of the formation, resulting in the acid being squeezed through the natural fractures within the formation and increasing the near hole permeability.”
2.27 As set out above, the key indicator of whether the use of acid is matrix acidisation in the EA definition document is that the acid is squeezed in “at a pressure about the geological formation pressure but below the formation fracturing pressure”.Thus the Permit permits the acid squeeze to be applied “not exceeding the fracture pressure of the formation”. While this prevents acid fracturing, it does not prevent matrix acidisation.
2.28 This is the same with the other documents referred to in Table S1.2 in the Environmental Permit Variation (EPR/BB3708GN). The Waste Management Plan (CD 1.9)uses the same wording as the Non-Technical Summary (CD 1.9– section 7.1.3 pg 20), so it also permits matrix acidisation.
2.29 The Environmental Risk Assessment (CD 1.9– table 005) states: “Acid is used during well clean up (treatment) operations. The acid is used to expandexisting channels within the rock formation to aid petroleum products to flow to surface.”This makes it explicit that the acid is being used to stimulate – expand – and is consistent with matrix acidisation.
Other Observations on the Planning application
2.30 In the Planning Statement (CD 2.4) Section 2.4 states:
“The reservoir comprises interbedded chert, silicious shales and occasional sands deposited in an offshore, deep water environment towards the bottom of a siliclastic ramp.
The zone of interest is from 1,795 to 1,849mMD, with the primary interval being between 1,846 and 1,849mMD.”
IGas’s intentions are unclear. Is it the 54m zone of interest, or is it the 3m primary interval?
2.31 Use of nitrogen – In the letter of 22 November 2018 (EP23), IGas states “no stimulation or artificial lift is required or proposed for this scheme”, but the Non-Technical Summary for the Permit (CD 1.9section 6.5.2 pg 16)states:
“To aid the initial flow of petroleum, nitrogen may be injected into the wellbore to displace wellbore fluids, reducing its hydrostatic weight. Nitrogen is classified as an inert waste and venting of such considered a closed loop system, insofar as nitrogen is extracted from the atmosphere and is vented back atmosphere. No nitrogen will remain in the formation.”.
2.32 Within the two phases identified above (the DSTand the EWT) the Planning Statement identifies 81 and 60 HGV (CD 2.4– 6.2.4 and 6.3.1) movements respectively, subsequently clarified to 57 and 60 HGV wellbore movements respectively (EP23 – 5thNov Letter). Within the Planning Statement there is no reference as to what these movements contain: acid, spent acid, oil or flowback fluid. The nature of the offsite hazards are not known to the consultees or the community.
2.33 The description of the development and the relevant EA application are often conflicting, and it is difficult to draw a conclusion as to what is intended, and therefore what is permitted by the subsequent EA Permit. From the definitions presented, when IGas refer to carrying out an “acid squeeze”, in line with the EA definition document this could amount to Matrix Acidisation. As a result, the inquiry should assess the proposed development on the basis that it includes Matrix Acidisation, unless the description of the development is changed to clarify the technique being permitted.
3. The Location – Looking Back and Looking Forward
3.1 Ellesmere Port is a town with a population identified as 55,715 in the 2011 census. It grew around the opening of the River Dee / River Mersey interconnecting canal in 1795, hence its name “Port”. The opening of the Manchester Ship canal in 1894 increased its connectivity to the industrial hubs of Birkenhead and Manchester, and Ellesmere Port became a significant base of industrial activity radiating away from the original canal development, which is now classed as the National Waterways Museum, and is being developed as a national tourist attraction.
3.2 During World War 2, a pipeline was built to supply fuel to the Allied troops re-entering Europe in 1944. The pipeline ran from Stanlow to Calais feeding fuel from the north Atlantic convoys directly to the advancing allied armies. This established the area as a strategic petrochemical complex which it remains to this day. It goes without saying that with the need for fuel to support the war effort, planning was not uppermost in people’s minds.
3.3 During the 1950s a uranium enrichment facility was built just to the south of the town employing some 2,000 people in its hey-day. Recently a “tails management facility” has been built to reprocess generations of low grade uranium “waste”. It still remains a site of significant activity and there are plans to build a nuclear reactor decommissioning facility there.
3.4 Many of the old manufacturing industries suffered severe decline through the latter part of the 1900s leaving the town with a very significant “rust belt”. Many of these sites have been regenerated for residential purposes, in conjunction with the development of three major out of town industrial parks, and a large retail outlet site (Cheshire Oaks Designer Outlet). The council has been successful in its regeneration plans as a trip around the town shows many recent and current developments. The council is now turning its attention to Ellesmere Port town centre.
Council Vision for Ellesmere Port
3.5 In 2010, Cheshire West and Chester Council established a new strategic regeneration and investment partnership for Ellesmere Port, the “Ellesmere Port Development Board”, which developed a Vision and Strategic Regeneration Framework (V&SRF) in 2011 (EP 29) to support the physical and economic transformation of the town. The V&SRF identified the transformation of Ellesmere Port Town Centre as a key priority in order to secure its future as an attractive retail, service, leisure and residential location.
3.6 As a result, Ellesmere Port has enjoyed significant levels of investment in recent years, including the Cheshire College South and West Campus, the University of Chester Church of England Academy (UCEA) and the Ellesmere Port Sports Village. This has helped deliver a step change in the quality of the built environment in the town. In addition, considerable investment in new housing development is now underway on sites adjacent to and within easy reach of the town centre (including Cromwell Road, Sutton Way, Thornton Road, McGarva Way, Rossfield Park and Ledsham Road) alongside an aspiration to create a world class centre; specialising in high quality arts and culture for children, young people and their families at Whitby Hall. A significant amount of this redevelopment is on previously industrial sites (the rust belt).
3.7 The Council Plan articulates a long term vision for a thriving borough through the delivery of new houses; creation of new jobs; investment in regeneration and key infrastructure projects; support to vulnerable individuals, families and communities; and encouragement of new businesses into the borough. This is also supported by the Science Corridor, a crescent of land across north Cheshire seeking to create a synergy of high tech business across the area. Supporting this are significant investments in the Chester University Science Park near Stanlow to the East, the British Geological Society’s natural laboratory at Ince Marshes, and the Capenhurst Technology Park to the south of the town.
3.8 Since 2010 1,536 new dwellings have been built in the environs of Ellesmere Port with approval for approx. 1,500 more (CW&C Annual Monitoring Update 2018). In addition three areas for employment are undergoing substantial regeneration and growth, these are Stanlow, Ince Park and the New Bridge Road areas to the East of the Town, and Hooton Park to the West of the town.
3.9 The town has excellent access to the M53 and the M56, and Merseyrail with its frequent service to Birkenhead and Liverpool makes it a convenient location for people commuting to the major areas of employment in Cheshire, the Wirral, Lancashire, and North Wales.
4. The Location – Changes since the 2017 Planning application
4.1 When Planning Permission was initially granted in 2010, the area was substantially derelict land previously used for railway sidings servicing the docks.
4.2 Since the well was drilled in 2014, and overlapping the 2017 Planning application, a petrochemical distribution facility has come into service some 100m from the site, and a retail caravan site has established some 50m from the site.
Photo 1 – Taken from the entrance of U-Tow Caravans Ltd looking towards the site (green fencing)
4.3 Just to the north west of the site Peel Holdings is developing a port complex and some 33.2MW of gas generating plant has recently been installed.4.4 The local Development Board has a vision to convert the whole area to the north of the motorway to residential as can be seen on the following map (Fig 2) taken from the V&SRF (EP 29). The well lies beneath the number “8”, identified as “Residential Projects”. The same document contains detailed plans to develop from the National Waterways Museum half way to the well. The land is currently largely derelict.
Fig 2: Map from “Ellesmere Port Development Board – Vision and Strategic Regeneration Framework 2011”
4.5 On the other side of the M53, land that was originally designated for industrial development has become a major housing estate with housing now 320m from the site, not the 600m when permission was initially granted. Looking at the development (Fig 3 below), there appears to be an intention to extend to within 250 m of the site, though planning permission has not been granted at this time.
Fig 3 Google Earth map of area
4.6 The various changes in the immediate area mean that a location which was not particularly sustainable in the first place (see the points made in the next section) is now obviously unsustainable. The image above (Fig 3) shows the site and its proximity to the dock, the residential development, the nearby other businesses, and shows the difficulty of access/egress caused by the cul-de-sac for large vehicles.
4.7 Since the original Planning application granted in 2009, Ellesmere Port has undergone significant regeneration / boundary growth, and the development strategy has changed for this area. Residential development is now 320m from the site, and the Development Board has identified the area of the site for future residential development. The development of an UOG extractive industry simply does not fit into this development scenario.
5. Unsustainable Location
5.1 In even the safest and best-regulated development, any decision to grant permission must take into account what the impact would be if, despite the regulation and despite safety practices, something were to go wrong. This “residual risk” is relevant because the risk of an accident, including a major accident, can never be zero.
5.2 This was vividly illustrated to the local community on 23 August this year when an explosion occurred in a chemical plant on the same site as the Stanlow Oil Refinery (see Appendix 1). Co-incidentally on 5thJune this year, the Council refused retrospective planning permission for Thornton Science Park buildings to continue to be used for the University of Chester’s Faculty of Science and Engineering, because of its proximity to the Stanlow Oil Refinery site. The explosion came as a timely reminder of the hazards of mixing the public with a hazardous industry.
5.3 IGas has not provided any information about the potential impact of a blowout or a gas leak on the new residential development. All of the assessment in the Planning Statement CD 2.4was on the basis that the residential development was 600m away: see pages 8, 16, 18, 33, 35 and 40. Although the IGas Statement of Case notes that “residential receptors” are located “circa 350m to the southeast of the appeal site” (CD 4.1 para 2.4; see also para 11.1), the only impacts considered are noise and air quality. Not even the Environment Agency has assessed the impact of the development on the new residential development, as the EA documents shows it thought the nearest residential receptors were around 745m away (EP 29– EA OOG Screening tool).
5.4 IGas has also not addressed the potential impact of a gas cloud on vulnerable receptors: the site is 800 metres from a children’s play centre and 860 metres from the closest of two large residential homes for the elderly, including highly vulnerable people with poor mobility.
5.5 There are also significant concerns that this site is down a long cul-de-sac with issues surrounding policing and access for emergency vehicles in the event of a blowout / fire. Certainly employees in the Reynolds tanker maintenance site at the end of the cul-de-sac would have to run towards the site of the blowout / fire to escape from it. It should be noted that the legal requirement for multiple routes of escape for a site like this have not been met, nor has an emergency plan been agreed with the Emergency Services.
5.6 There are a quite a number of issues that come together to make this an unsustainable location. As can be seen from Fig 4 below, the site is:
a. identified for future residential development in the Strategic Framework for the Town (see Fig 1 above)
b. located at the end of a cul-de-sac with constrained access (see Fig 3 above)
c. adjacent to a railway line.
d. located on the edge of the Rossmore Ward which is within the 5% most deprived wards in the country (2015 HM Gov. Indices of Multiple Deprivation). This will be addressed in the evidence from Dr Saunders and Dr Szolucha
e. within 100 metres of over 5 local business. The proximity to one can be seen in the Photo 2 below.
Photo 2 taken at the end of the cul-de-sac showing proximity of site (green barricade) to the Reynolds business
f. 150 metres from the M53, the major link from Birkenhead to the rest of the UK.
g. 200 metres from an explosives store (exact location not known for security reasons)
h. 250 metres from the epicentre of an earth tremor registering M1.6 in 1992.
i. 250 metres from the Manchester Ship Canal which is used to carry petroleum and hazardous chemicals to the Stanlow petrochemical complex
j. 270 metres from one of the most important wildfowl overwintering sites in the UK which is classed as a SSSI / RAMSAR / SPA site, with cross national boundary implications
k. 320 metres from a high-density residential area, which could be developed to within 250m of the well (see Fig 3 above)
l. 800 metres from a children’s play centre.
m. 860 metres from the closest of two large residential homes for the elderly, including highly vulnerable people with poor mobility.
n. 1 km from several schools.
o. 1 km from a hotel / tourist attraction complex (National Waterways Museum)
p. 1 km from Rivacre Brook. This brook is addressed in the Evidence from Mr Grayson. It contains Uranium from the local nuclear facility and events that resuspend the Uranium into the water could be significant.
q. 2 km from an existing Air Quality Management Area running through the town centre.
r. 7 km from the centre of Ellesmere Port.
Fig 4 – Map of Sites.
s.5,000 residences within a 2km radius. A zone that many Australian states would class as a “buffer zone” between wells and residences / public buildings, and which the USA emergency services would evacuate in the event of a well blowout – Note this includes all of the above locations
t. 3. 3 km from significant water extraction points identified as “for human consumption” by the EA (downstream from the site in aquifer terms).
u. 4.5 km from a nuclear site which has strict seismic criteria in its nuclear licence.
v. above the Sherwood Aquifer which the British Geological Society considers to be the second most important aquifer in the country. This aquifer supplies many Cheshire villages with excellent drinking water and also many farms for crop irrigation and livestock drinking water.
w. At the centre of a 5 km radius containing between a significant number of aquifer water extraction facilities, including some identified by the EA as for “human consumption” (i.e. Hooton).
x. Within an area that is designated as the “Cheshire Science Corridor”, a crescent of land where the Council and the Local Enterprise Partnership are attracting nationally and internationally significant research facilities and businesses. It is being marketed as a science hub and seeking to attract 20,000 hi-tech jobs into the area.
Observations on location
5.7 Fires and explosions may be triggered by adjacent sources such as smoking, vehicles, sparking electrical equipment, lightning etc. that can ignite clouds of gas. It should be noted that there are numerous industrial units within 100 metre of the IGas well, the closest being an office facility 50 metres from the well. All of these sources of ignition are capable of triggering explosion should a cloud of gas escape from the well. It should be noted that if the rig caught fire then the employees of some of these units would not be able to escape safely since they would have to travel towards the well to initiate escape. This is contrary to HSE Guidance on the Borehole regulations of 1995 (EP36)
“114 Where perimeter security fences are required, they should be to recognised standards and where necessary, emergency exits should be provided so as to permit safe exit without having to pass through an area which may be affected by fire or gas escape.
5.8 The site is far from perfect for access by the emergency services. The HSE guidance on the Boreholes Regulations 1995 (EP36) states:
“124 At the roadway terminus there should be an area sufficient to allow the largest emergency vehicle to turn around without undue manoeuvre”
“126 Operators should consult with the local Fire and Rescue Service on these matters.”
“127 The emergency services should be consulted at the planning stage so that such matters as rescue methods, casualty handling, the need for any decontamination zones and any special equipment can be discussed and procedures agreed”.
None of these have been complied with at the time of writing, as verified by Freedom of Information Requests (FoI’s). Whist it is recognised that the Inquiry cannot rule on legislation (EP36), access, and the ability of the Emergency Services to respond should be part of the planning consideration.
5.9 This location is unusually complex from a receptor point of view, and the full impacts on these receptors have not been adequately assessed.
5.10 There is now new residential development 320m from the site, which may extend closer to the site.
5.11 The Development Board has identified the area of the site for future residential development.
5.11 There is now new business development neighbouring the site, meaning there are several offices within 100m of the well.
5.12 The site does not offer multiple safe escape requirements for either IGas employees, or for the businesses at the end of the cul-de-sac.
5.13 At the time of writing FoI’s indicate that consultation with the Emergency Services has not been undertaken to assure the efficient management of an incident.
6. Risk Above Ground
6.1 When placing an activity like gas extraction in such a densely populated area it is essential to fully evaluate risks to the population and the environment that they depend upon for good health. The Planning Statement (CD2.4) makes inadequate provision for this. There is some reference to burner malfunction cold venting gas, but there are no plans as to what to do with this vented gas. The following is my view of the risk posed to the local community by the proposed development, based upon my 40 years of managing risk in the nuclear and chemical industries.
The Nature of Risk
6.2 IGas quotes “There are no unusually complex or hazardous environmental effects associated with the intended development”(CD 2.4Page 18). This industry is regulated by the Health and Safety Executive Hazardous Installations Directorate for the obvious reason that it is hazardous. The statement indicates the superficial manner in which IGas has approached risk in this Planning application.
6.3 There is always a finite risk that the well site could experience a significant gas leakage or explosion, particularly since IGas quote a pressure at the flare of 150 bar, and the vagaries of the geography could impose significant and unpredictable increases of pressure (the industry calls it a “kick”). The chances of loss of control are greater during the exploratory stage than at production because there are greater unknowns about the exact pressure, formation and content, and also the operations that a well completion entail can result in loss of control of the well.
6.4 IGas claim that “The natural gas produced during the DST and EWT is not expected to contain hydrogen sulphide (H2S). This expectation is based on results from mud logging during well drilling operations to well total depth (TD) including the Pentre Chert intervals where no H2S was recorded.” (CD 2.4 Air Quality 1.0 Scope). That IGas affirms there is no H2Sin the Chert is meaningless, since Chert will not contain H2S. The H2Swill come from the same source as the hydrocarbons that IGas are hoping to find. Mr Grayson will demonstrate the high probability of H2Sin his evidence. Due to a superficial, and flawed analysis, IGas is putting local employees and residents at risk. The presence of H2Sshould be the working assumption until proved otherwise.
6.5 PetroWiki states (ref Hydrogen Sulphide) “Drilling H2S-bearing formations poses one of the most difficult and dangerous problems to humans and equipment. If it is known or anticipated, there are very specific requirements to abide by in accordance with Intl. Assn. of Drilling Contractors rules and regulations. Shallow gas may be encountered at any time in any region of the world. The only way to combat this problem is to never shut in the well; divert the gas flow through a diverter system instead. High-pressure shallow gas can be encountered at depths as low as a few hundred feet where the formation-fracture gradient is very low. The danger is that if the well is shut in, formation fracturing is more likely to occur, which will result in the most severe blowout problem, underground blow.”
Note that if the well is shut in fracturing may take place. IGas cannot guarantee this will not happen, and this potential event needs to be considered in the Planning application.
Risk and its Consequences
UK North Sea Experience
6.6 There is little onshore experience of UOG in the UK to draw from. The two most advanced attempts to to-date have run into difficulty. The 2011 Preese Hall (Blackpool) well triggered an earth tremor sufficient to cause the well to be abandoned, and the 2018 Preston New Road (Blackpool) well ceased fracking when the earth tremors reached 1.1ML. At the time of writing it is not known if the well has been damaged, but given Cuadrilla claim the cost of the operation is £94,000 per day, a 30 day cessation (at the time of writing) indicates a serious problem. Fortunately there have been no significant contamination issues reported at this time.
6.7 To provide some background on the risk to which this operation will expose local employees and residents, let us first look at the most significant oil and gas industry in this country, the very successful North Sea. Reporting on the safest year yet, (EP31– Offshore Statistics and Regulatory Activity) the HSE reports:
- There were no fatal injuries in 2017 (there have been six fatalities in the last 10 years)
- There were 65 “over 7 day” injuries, with a rate of 219 per 100,000 FTE (0.2%)
- There were 196 dangerous occurrences reported
- There were 110 hydrocarbon releases
- 914 non-compliance issues were raised with operators
- 44 enforcement notices were issued
This is across a population of approx. 260 operational rigs in the North Sea.
6.8 The North Sea is clearly well regulated. However it is not without risk. The International Association of Oil and Gas Producers in their report in 2010 “Blowout Frequencies” (EP32) indicates a blowout / release frequency of 0.18% per operation well completion and workover of a gas well.
6.9 The high pressures involved mean that any leakage of gas can be significant. IGas expects to be handling gas at 151 bar as it emerges from the well (CD 2.9– Flare Technical Document). At these pressures a small leak may involve a large quantity of gas.
6.10 If we review the HSE data set for offshore hydrocarbon releases (EP33) which is the latest detaileddata released, we note that there were 74 incidents involving a leakage of gas, of which over 16 involved the release of over 20 kg of gas (6.1% per installation). The biggest release being 43,600 kg. Fortunately, there were no fires or explosions due to the intrinsically safe design of the equipment used on North Sea rigs. Onshore releases have a higher chance of explosion due to adjacent sources of ignition of the gas (electrical equipment in adjacent buildings, adjacent vehicles, adjacent smokers etc.). Some of the local business units near the site involve grinding operations that create the sparks necessary to ignite stray gas, vehicles and smokers regularly pass along the road adjoining the site.
6.11 Whilst it is recognised that offshore installations are of a slightly different nature they will contain similar process equipment (i.e. valves / flanges / separators / storage vessels etc). When reviewing risks one has to work with the data that is available and until a substantial database for onshore activity is built up, these are the numbers we have to work with. When managing and making decisions on risk, it is the magnitude of the risk that is important, and not the precise number.
6.12 Even in well run operations, there is always residual risk and there may be shortcuts taken. An example arose on this site, during the original drilling in 2014. A BBC interview with the CEO of IGas (Mr Blaymires) took place on the site. The cameraman was rightly bemused and focussed on a process valve which was attached with half the bolts missing, and a coupling held on with duct tape – shown below in Fig 5.
Fig 5 – BBC Northwest 17/12 2014
Onshore Exploration in America
6.13 If we do not accept the numbers derived from North Sea operations because it is offshore, let us take a look at the country with the most highly developed UOG industry, the USA. America has a mature industry with a similar legal / safety culture to our own. Indeed, the Oil and Gas industry is a global industry with common operating practices, and often a global workforce. For example, the fracking that is taking place close to Blackpool, Lancashire is being undertaken by Schlumberger, an international oil and gas services company based in Houston, Texas.
6.14 Petroleum exploration is inherently risky since it involves the combination of heavy mechanical handling, using / recovering hazardous / explosive materials, with the vagaries of geology to contend with. For example, on 22 January 2018 an unconventional well in Oklahoma experienced a blow-out resulting in the death of 5 workers, with another severely injured. The after effects are shown in the Photo 3 below.
Photo 3 Oklahoma well blowout 22 January 2018
6.15 Events of this nature are not infrequent in the USA. In 2015 there were approximately 978 rigs in operation (Baker Hughes rig count) across the USA, and there were 89 deaths associated with the industry (US Bureau of Labor). Since most of the accidents happen during exploration / development we can determine that each rig attracts in the region of a 9% annual fatality rate,with fire, blowout, and exposure to harmful substances accounting for 24% of those 89 fatalities (2.2% annual fatality rate). These statistics are published routinely by the government body the US Bureau of Labor, and a breakdown of these fatalities is shown in Fig 6 below.
Fig 6 Breakdown of Fatal Injuries in the USA oil and gas extraction industries
6.16 Reporting the “adequacy of Current State Setbacks for Directional High Volume Hydraulic Fracturing in the Marcellus Barnett and Niabrara Shale Plays (CD 35 pg328) indicated a blowout rate of 0.17% in the Marcellus Shale. A number remarkably similar to the 0.18% we observed for the North Sea (6.8 above).
6.17 Texas Railroad Commission database reports that in 2017 there were 6,914 well completions, of which there were 14 reported blowouts, a failure rate of 0.2%. (This data is replicated in Appendix 3). A similar figure to that quoted by Considine et al above and that of the North Sea.
6.19 This section has demonstrated the fatalities due to fire, blowout, and exposure to harmful substances to onsite employees as a means to demonstrate the difficulties the UOG industry faces in its operations. Whilst homes and residents have been harmed by UOG incidents, there is no reliable data to quote. However the impact of these incidents is demonstrated by a casual search of the internet, the results appear in Appendix 2. A further article from the “Insurance Journal” (USA) indicates the extent of the problem to the insurance industry (Appendix 6).
Comparison of Risks
6.20 As noted above when making decisions based on risk it is not the absolute number that is important when making decisions it is the magnitude of the number that is important. Let us compare risks across a number of activities:
2.1% USA employee fatality due to fire, blowout, and exposure to harmful substancesper onshore rig per year
0.17 – 0.2% American onshore blowout / release per operation
0.18% North Sea blowout / release per operation
0.0001% to 0.00001% Nuclear Industry design criteria
It is worth noting that the 0.003% UK Traffic Fatality per inhabitant per year is broadly considered by UK society as a “tolerable risk”. This is offered as a benchmark of public perception, not as a comparison.
6.21 Whilst not all blowouts lead to fatalities, they potentially lead to increased levels of risk and potential evacuation. It would appear to me that this increased level of risk is not acceptable where the wellhead is within 100m of offices, and 375m from residences.
6.22 Cumulative risk does not appear to have been assessed. The HSE has expressed concern over an explosives store some 250 metres from the well (EP34), and arrangements have been made to accommodate. The risk assessment covered the use of explosives during the perforating operation by IGas, but did not include well blowout / explosion in the analysis. The combination of a hazardous operation (well completion) together with an adjacent oil and gas facility, and explosives store is unacceptable in my view. This is the classic disaster scenario where one incident triggers a chain reaction.
6.23 I defer to the competence of the Planner, Ms Copley providing evidence to this Inquiry, but note Local Plan part 2 DM33:
“Hazardous substances consent or development proposals which either creates new hazardous installations or extends existing hazardous installations, including pipelines will be supported where:
“the development does not create or increase risk to the general public or environmental sensitive areas and retains an appropriate distance from the hazard.”
I note that the statement does not specify an absolute value for risk, only that the development “does not create or increase risk to the general public or environmental sensitive areas and retains an appropriate distance from the hazard.”This proposal fails this test.
6.24 All the evidence demonstrates that UOG exploration is a risky business. IGas has not made public an effective risk analysis for this planning application. Indeed it claims “There are no unusually complex or hazardous environmental effects associated with the intended development”(CD 2.4Page 18). This would not appear to align with the evidence.
6.25 A full cumulative risk analysis has not been undertaken. The effects of a well explosion on the explosives store or the adjacent petroleum distribution centre, or vice versa has not been considered.
6.26 IGas has demonstrated a disregard for the community, the council, and the regulatory bodies in the way that it has not been open and honest on the risks associated with the proposal, and in the manner in which it is managing these risks.
6.27 The planning application does pose an increase in risk to the general public, particularly given the distances from neighbouring businesses and the proposed development’s position on a cul-de-sac. This weighs in favour of the planning application being refused.
7. Safe Distance between Well and People
7.1 When reviewing the North Yorkshire Local Plan in April 2018, the Inspector Elizabeth Ord agreed at its examination that a 500m setback distance was reasonable to prevent nuisance (traffic, dust, noise) to residents.
“I am satisfied that there should be a 500m buffer, or whatever you want to call it. We have a situation with a new industry and a lot of fear about it. I accept that fear should not make planning policy but the precautionary principle is well established and there is justification of treading carefully in the first five years of the plan.”
Blowout and fire was not considered at that examination, only normal operation.
7.2 Unfortunately in this country we have no significant experience of the UOG industry operating in and urban environment, and so we have to look to Australia, Canada and the USA where the industry is mature, and who have established a “setback distance” to keep people safe from the effects of a well, based on the experience we do not have. The setback is designed to protect people from:
- Release of hazardous substances during normal operations (fugitive gas)
- Release of hazardous substances during abnormal operations (blowout / leakage)
- Burn from the effects of a well fire
Setback distances vary:
- Australia = 2,000m from a residence, public building, equine, or viniculture.
- Canada = 100 to 1,500m dependent on hydrogen content
- USA = 200ft to 1,500ft (State / County dependent)
7.3 A report in 2016 reviewed setback distances “Adequacy of Current State Setbacks for Directional High-Volume Hydraulic Fracturing in the Marcellus, Barnett, and Niobrara Shale Plays” (EP01). Some Observations from that report:
7.3.1 Discussing normal operations (pg 1329):
“Odour exposure is also associated with negative mood, stress, and annoyance for those living near H2S-producing facilities. Combined with the VOCs, this produces a potentially new set of exposures, possibly at distances of 2 km”
7.3.2 Discussing evacuations (pg 1328):
“In the evacuation data we collected, the average evacuation zone was 0.8 mi (range of 660–13,200 ft) and the average number of homes / families displaced was 149 (range of 3–500 per event……During a level 3 event involving a gas well, officials should have a clear plan of notification, transportation, and evacuation routes for high-occupancy buildings)”
7.3.3 Discussing radiant heat (pg1328):
“At the common Texas setback distance of 300 ft and the Colorado outdoor recreational distance of 320 ft, based on the calculation of radiant heat flux, second degree burn blisters would be expected to form after approximately 16 sec and 22 sec, respectively”
7.3.4 Discussing the disadvantaged (pg 1329):
“Air pollution from inadequate setbacks is of particular concern for vulnerable populations. The economically disadvantaged, people > 65 years old, and younger people with disabilities are most likely to have chronic health conditions which require institutional care”
7.3.5 The report concludes (pg1330):
“Current natural gas well setbacks in the Barnett Shale of Texas, the Marcellus Shale of Pennsylvania, and the Niobrara Shale of Colorado cannot be considered sufficient in all cases to protect public health and safety. Based on historical evacuations and thermal modelling, people within these setback distances are potentially vulnerable to thermal injury during a well blowout. According to air measurements and vapor dispersion modelling, the same populations are susceptible to benzene and hydrogen sulfide exposure above health-based risk levels. Texas, Pennsylvania, and Colorado should consider adopting more generous setback distances, particularly in reference to vulnerable populations”
7.4 To prevent undue risk to local employees and residents, a safe distance between them and the well (setback) needs to be established.
7.5 Due to the immaturity of the UOG industry in this country a national setback distance (distance between a well and people) has yet to be agreed.
7.6 In the absence of a national ruling, the precedent accepted by Inspector Elizabeth Ord when reviewing the North Yorkshire plan should be considered as sound guidance (500m).
7.7 There are a significant number of businesses and residences within the setbacks discussed who would potentially require evacuation in the event of a blowout / explosion. This weighs in favour of the Planning application being refused.
8. SSSI / RAMSAR / SPA site
8.1 The site lies 270 m from the Mersey Estuary wildfowl site which has local, regional and continental significance. The Mersey Estuary is a large, sheltered estuary which comprises large areas of saltmarsh and extensive intertidal sand- and mud-flats, with limited areas of brackish marsh, rocky shoreline and boulder clay cliffs. The intertidal flats and saltmarshes provide feeding and roosting sites for large populations of water birds. During the winter, the site is of major importance for ducks and waders. The site is also important during the spring and autumn migration periods, particularly for wader populations moving along the west coast of Britain.
8.2 A local wildfowl expert notes:
“Manisty is important for overwintering and migrating waders and wildfowl. Birds specifically protected present near Manisty are Redshank and Black-tailed Godwits present in nationally important numbers, sometimes internationally important. The Mersey is the best place in the UK for overwintering Dunlin (with over 60,000 present in the last few winters – internationally important). A large proportion of these use Manisty Bay (the closest point to the well). Also present are overwintering common snipe and Jack snipe, holding 1% or more of the UK population (nationally important). For wildfowl Manisty Bay is important for overwintering Teal. In the recent past 7,000 to 10,000 (international importance) was not unusual but more recently 2,000 has been a good count (nationally important). Their decline is of concern. Mallard, Wigeon and Pintail also use Manisty Bay but not in nationally important numbers. Little Egrets have recently colonised Britain and flocks of 20 to 30 occur in Manisty Bay, with several Great Egrets.
8.3 We therefore have great concern with the response from Natural England (CD 3.1) that:
“Currently the APIS website does not hold critical loads for all habitat types within the designated site, and some habitats advise ‘please seek site specific advice’. The habitat types used in the assessment (Fen, marsh and swamp, and Ringed plover) are not representative of the habitat lying within the influence of the proposal, and in this case saltmarsh would have been more appropriate.“ And we have reviewed the information in light of the above points and can conclude that due to the higher threshold (saltmarsh) and the temporary nature of the flare there should be no significant impacts on the Mersey Estuary”.
8.4 We note the requirement of a Natura 2000 site (which this is) defines;
“In practice, this means that in Natura 2000 land owners/managers/users must avoid any actions that will have a negative impact on the ecological structure and functions of protected habitats or on the suitability of habitats for protected species (e.g. as feeding, resting or breeding places). It also means avoiding any actions that may cause a significant disturbance of protected species, especially during their breeding, resting or feeding periods”
We do not consider that the application has been rigorously screened for pollution and noise.
9. Risk to the Groundwater
9.1 A study of 15,000 conventional wells by the US Mineral Management Service demonstrated that wells fail with time (Fig 7). The study referred to the presence of sustained casing pressure to the surface, which is the first stage of failure of the well. It is relatively easy to measure this nature of failure: failure subsurface, for obvious reasons is not measured and will be significantly higher than failures seen at the surface.
9.2 A more recent paper “Oil and Gas Wells and their Integrity: Implications for shale and unconventional resource exploitation” (EP40) demonstrated that currently 10% of UK North Sea, and 38% of abandoned Norwegian wells are showing signs of failure to the top of the well.. The report concludes “Well barrier and integrity failure is a reasonably well documented problem for conventional hydrocarbon extraction and the data we report show that it is an important issue for unconventional wells as well.”
9.3 Well failure provides a clear route to contamination of the aquifer and groundwater. This is addressed in the evidence of Robin Grayson, and more information on the geology is given in the evidence of Prof Smythe.
9.4 Currently there exists a well down to circa 2,000 m. The well has not been perforated / stimulated and so there are no significant paths for liquid / gas to flow into and up the well. If perforation / stimulation takes place, or even if it does not but the well is “flowed” using the natural pressure of the gas, then the well is prepared to collect petroleum and conduct it to the surface as it is designed to do. However over time normal well failure mechanisms will apply, and if IGas stimulate or flow the well a pathway to the surface, or to surrounding faults, will exist. At the top of the well a surface zone to exclude buildings from methane, and potentially radon ingress will be required to be maintained for decades / centuries. Because the land will subsequently be developed either into light industry, or residential as the Development Board Strategy suggests, the sterilisation of land, and subsequent long term monitoring is not economically sustainable.
9.5 Cheshire is a very natural and diverse county rich in wildlife. Chester Zoo is located 7.5 km away and draws all of it water from the aquifer. It is one of the top 5 biodiversity centres globally and its concern is contamination of the aquifer and how it might affect the many thousands of species they have there. Additionally the Cheshire Wildlife Trust have also issued a position statement on UOG extraction. These appear in Appendix 4 and 5. Prof. Smythe demonstrates how this well can contaminate the aquifer and also the SSSI / RAMSAR / SPA site adjacent.
9.6 The “Precautionary Principle”(EP17), enshrined in international, European, and National law states:
“When human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm. Morally unacceptable harm refers to harm to humans or the environment that is:
- threatening to human life or health, or
- serious and effectively irreversible, or
- inequitable to present or future generations, or
- imposed without adequate consideration of the human rights of those affected”
9.7 There are so many unknowns about the potential for contamination of groundwater and the impact on the people that use this resource for drinking, for crop irrigation and animal drinking water that stimulation of this well should not be allowed.
10.1 The initial Planning application was for coal bed methane down to a depth of circa 900m or “the maximum depth in the coal seam”. Shale exploration is a different process at greater depths. The community believes the initial planning permission to have been breached, and has very little confidence in IGas. This is compounded by the nebulous planning application that was rejected by the Planning Committee in January 2018.
10.2 The Planning Statement does not mention what technique will be used, and several attempts to clarify have left us none the wiser. Our understanding is that IGas plan either an acid wash, or an acid squeeze, or even matrix acidisation is not excluded from the statements that we have had. The possibility of unintentional acid fracking if the well has to be “locked in” is also not excluded.
10.3 The Planning Statement is not specific as to what acid will be used: “”most commonly hydrochloric” acid does not provide much reassurance when the alternative is the highly reactive hydrofluoric acid, which is of real concern to the community.
10.4 Attempts to clarify have sometimes led to a conflict between the clarification and the actual documentation. For example on the 22 Nov we had a statement that “no artificial lift is required or proposed” however the documentation provided to the EA clearly state that a nitrogen lift will be used.
10.5 In the Planning Statement there is no mention of what the various lorry movements during the DST and the EWT will comprise. Not knowing what quantities of acid, oil, spent acid, formation water means that consultation with the consultees (i.e. Highways Agency) and the community has been incomplete.
10.6 Overall the lack of any information has left the community deeply suspicious that IGas will do whatever they choose to do, as was the case in the first planning application for Coal Bed Methane on 2009.
10.7 The Council has put a lot of effort into regenerating Ellesmere Port, and there has been much infrastructure investment, residential development, and the development of major out of town business parks. This has led to the expansion of domestic residences currently to 320m from the site, and a strategic vision for residential development around the site of the well. Clearly times have moved on and the well is potentially a hindrance to future development. In this respect it is economically unsustainable.
10.8 The location has changed since the grant of the original Planning Permission in 2010. There is now new residential development 320m from the site and new business development neighbouring the site. There are multiple businesses within 100m of the well. These changes make the location unsustainable for UOG exploration
10.9 This location is unusually complex from a receptor point of view. Not only are the businesses and residences nearby, as just set out, but the site is 800 metres from a children’s play centre and 860 metres from the closest of two large residential homes for the elderly, including highly vulnerable poor mobility people The full impact on these receptors has not been adequately assessed.
10.10 There are safety concerns over the site. The site does not offer multiple safe escape requirements for either IGas employees, or for the businesses at the end of the cul-de-sac.
10.11 At the time or writing Requests for Information to the local Emergency Services indicate that consultation with the Emergency Services has not been undertaken to assure the efficient management of an incident.
10.12 All the evidence demonstrates that UOG exploration is a risky business. IGas has not made public an effective risk analysis for this Planning application. Indeed it claims “There are no unusually complex or hazardous environmental effects associated with the intended development”(CD 2.4Page 18). This would not appear to align with the evidence.
10.13 A full cumulative risk analysis has not been undertaken. The effects of a well explosion on the explosives store or the adjacent petroleum distribution centre, or vice versa has not been considered.
10.14 IGas has demonstrated a disregard for the community, the council, and the regulatory bodies in the way that it has not been open and honest on the risks associated with the proposal, and in manner in which it is managing these risks.
10.15 The planning application does pose an increase in risk to the general public, particularly given the distances from neighbouring businesses and the proposed development’s position on a cul-de-sac. This weighs in favour of the planning application being refused.
10.16 To prevent undue risk to local employees and residents, a safe distance between them and the well (setback) needs to be established.
10.17 Due to the immaturity of the UOG industry in this country a national setback distance (distance between a well and people) has yet to be agreed.
10.18 In the absence of a national ruling, the precedent accepted by Inspector Elizabeth Ord when reviewing the North Yorkshire plan should be considered as sound guidance (500m).
10.19 The number of local businesses and residences within that distance weighs against this planning application being refused.
10.21 The Natural England advice would appear to be is based on incomplete information. This analysis seems flawed and should be revisited.
10.22 There are so many unknowns about the potential for contamination of groundwater and the impact on the people that use this resource for drinking, for crop irrigation and animal drinking water that the “Precautionary Principle” should evoked and stimulation of this well should not be allowed.
Appendix 1 – Local Incident 23 Aug 2018
“Scaffolders run for their lives after explosion at Stanlow oil refinery”
“Dramatic images show scaffolders running for their lives after a fireball explosion at an oil refinery in Cheshire.
Massive plumes of thick black smoke could be seen for several miles after a large fire broke out at the Stanlow oil refinery on Wednesday afternoon.
Firefighters were called to reports of a fire in Oil Site Road, Ellesmere Port at 2.16pm on Wednesday.
Images sent to ScaffMag from inside the oil refinery show the terrifying fireball coming from the SHOP chemical plant area of the refinery site. Bilfinger and Cape pre-shutdown scaffolders on site had been working in the area but were fortunately cabined up when the explosion happened.
(Image identifying personnel running from explosion removed for privacy)
All staff and contractors had been accounted for and evacuated from the affected area.
The Stanlow refinery owned by Essar Oil UK employs more than 900 staff and 500 contractors on site and supplies 16% of all road transport fuels.
A spokesman for Cheshire Fire and Rescue Service told local media: “Shortly after 2pm today emergency services received reports of a fire within the SHOP chemical plant at the Stanlow site in Ellesmere Port.
“Crews from Cheshire Fire and Rescue Service along with onsite firefighters from Essar quickly brought the fire under control and it was fully extinguished within three hours. The fire caused a large plume of smoke above the site, which has now dispersed.”
“The incident was confined to the manufacturing area of the site and did not affect the refinery. All staff within the affected area were evacuated as a precaution and there were no reports of any injuries.”
Investigations are now underway for what caused the fire.”
Extract from “Scafmag” Aug 23 2018 (One photo removed)
Appendix 2 – Casual Internet Search of Incidents in USA
Aliso Canyon 23 Oct 2015 – Well blowout – 2000 homes evacuated
Oklahoma 22 Jan 2015 – Well blowout – 5 killed 1 injured
Weld County 21 Jan 2012 – Well blowout – Explosion – 3 injured
Weld County 13 Nov 2014 – Well accident – 1 killed 2 seriously injured
Garfield County Oct 2014 – Well blowout – 1 killed
Firestone 17 April 2017 – Severed gas well line – 2 residents killed
Logan County 26 May 2017 – Well blowout – local evacuation
DeSoto Parish 19 Nov 2009 – Well blowout – 2 mile evacuation
Caddo Parish 20 Apr 2010 – Well blowout – 105 homes evacuated
Acadia Parish 26 Feb 2014 – Well blowout – 1.5 mile evacuation
Red River Parish 14 April 2017 – Well blowout – local evacuation
DeSoto Parish 18 Apr 217 – Well blowout – 1 dead 2 injured
Wayne County 20 Jul 2012 – Well blowout – 1 mile evacuation
Lake Sakakawea 17 Dec 2012 – Well blowout
Lake Sakakawea 13 Feb 2014 – Well blowout
Tuscarawas County 16 July 2012 – Well blowout – 1 killed
Geauga County 15 Dec 2015 – Well Blowout
Boston Heights 23 Feb 2014 – Well blowout – local roads closed
Morgan County 4 May 2014 – Well leak – 7 evacuated
Monroe County 28 Jun 2014 – Well fire – I injured, residents evacuated
Jefferson County 28 Oct 2014 – Well Blowout – 400 families evacuated
Monroe County 13 Dec 2014 – Well leak – local families evacuated
Belmont County 19 Mar 2018 – Well explosion – 1 mile evacuation
Watonga 20 Sep 2011 – Well blowout – no details
Sweetwater 5 Jan 2012 – Well blowout – Aquifer contamination
Pittsburgh County 16 Feb 2017 – Well blowout – 1 worker injured
Pittsburgh County 22 Jan 2018 – Well blowout – 5 workers killed one injured
Clearfield County 3 Jun 2010 – Well blowout – local road closed
Bradford County 19 April 2011 – Well Blowout – uncontrolled leak of fluid
Greene County 11 Feb 2014 – Well blowout burnt for 5 days – 1 injured 1 dead
Mercer County 6 Sept 2014 – Well fire – one mile evacuation, 20 homes
Somerset county 30 Nov 2017 – Well fire – residents evacuated
Susquehanna County 4 Jan 2018 – Well blowout – 4 injured
Moundsville 7 Jun 2010 – Well blowout – 7 injured
Taylor County 5 Feb 2012 – Well blowout – 2 dead
Dodridge County 7 Jul 2013 – Well fire – five injured
Dodridge County 25 May 1015 – Well storage tank explodes – I dead 3 injured
Wyoming 18 Jul 2014 – Well blowout – 25 homes evacuated
Denton 19 Apr 2013 – Well blowout – diversion of airport flights
West Texas 8 Apr 2013 – Well blowout – 2 dead 2 injured
Loving County 30 Apr 204 – Well blowout – 2 dead 9 injured
Upton County 11 Mar 2015 – Well blowout – 3 dead
Arlington 13 Apr 2015 -Well blowout – 115 evacuated
Note Texas is reviewed in a more detail in Appendix 3
Appendix 3 – Extract from the Texas Railroad Commission log
The following extracts are from the voluntary log for 2017.
12/01/17 Frio Testing the well when pressure had developed, causing the release of gas and produced fluids. There were no injuries, however as a precaution the section of Hwy 85 nearest to the well was closed off.
12/18/17 Tarrant Acid flowback to surface through a stuck/broke valve.
12/07/17 Hale The stripper rubbers failed on the BOP causing the uncontrolled release of CO2 and approximately 5 barrels of produced water. H2S monitors and personnel were set up in the area during the release
12/06/17 Fort Bend Operator encountered gas pocket and incurred a kick which has allowed well to begin blowing gas, oil, water, and drilling fluids.
09/07/17 Jackson Overnight, apparently the annular BOP rams failed and the tubing dropped, causing well fluids to flow to the surface. Less than one barrel of fluid is on the ground.
7/21/17 Reeves Glenn Gainey inspected the well and it is currently spewing gas through a flange on the wellhead. Pressure at the wellhead is unknown. Some fluid has pooled on location. NBL has set up a safety corridor around the well.
7/13/17 Reagan Workover rig was going in the hole with tubing and stacked out hard on bottom and bent tubing where the crew could not close the BOP. At that time the well started to blow oil and gas.
06/06/17 Jefferson They had produced water leaking into the cellar and had what appeared to be communication between their casing strings. Mr. Mayfield noted that the well was leaking about 30-bbls of produced water an hour and a small amount of gas.
5/16/17 Victoria During workover the wellhead and tubing were in poor condition and remedial work worsened the condition causing a total loss of the wellhead.
4/20/17 Matagorda Well finished drilling and during flow testing a loss of control occurred.
4/19/17 Montague The Tubing broke at the well head during the inspection. Well began to flow.
3/14/17 Hale An uncontrolled well from a workover that had produced water and water based drill mud going into a dry Playa lake. The amount of fluid lost was 5000 barrels (bbl.) including both water and mud.
1/21/17 Loving Well had an incident during facture stimulation.
01/03/17 Hemphill While drilling the well started receiving gas kicks
During this period there were 6,914 well completions. Against the 14 reported failures above this is a failure rate of 0.2%. During this period there were 33 related fatalities.
Appendix 4 – Statement by Cheshire Wildlife Trust
With climate change presenting a significant and serious long-term threat to biodiversity and societies worldwide, The Wildlife Trusts believe that:
- a reduction in energy demand and greater energy efficiency measures should provide the central focus of Government’s approach to sustainable energy policy;
- there should be a reduction in dependency on fossil fuels (coal, natural gas and oil);
- Government funding should be prioritised on the development and implementation of renewable technologies;
- Restoring ecosystems, such as peatlands to absorb carbon (as well as a range of other ecosystem services) should be a key consideration in mitigating the potential impact of shale gas exploration and extraction.
The Wildlife Trusts recognise that all forms of energy generation will entail some environmental costs and that the risks and benefits associated with each must be weighed against each other and considered in the context of location and scale. This position focuses on The Wildlife Trusts views and recommendations with regards to on-shore hydraulic fracturing (fracking) which is used to access natural gas reserves in shale rock.
The Wildlife Trusts believe that the extraction of shale gas undermines UK efforts to reduce greenhouse gas emissions and tackle climate change. New evidence from the Climate Change Committeeindicates that methane sourced by fracking will be in addition to existing emissions rather than substituting for them. In addition, shale gas extraction often results in fugitive methane emissions, i.e. methane that is leaked directly into the air.
The extraction of shale gas by hydraulic fracturing presents a number of additional environmental risks to wildlife and society. Impacts on the environment are not well understood but they could be potentially significant and existing environmental regulation seems to be inadequate to manage these risks.
We are particularly concerned about the impacts on habitats, species and ecosystems due to:
Reduction in water quality (surface and ground water contamination) and quantity (water stress and availability).
Cumulative impacts of disturbance, damage, loss and fragmentation at the landscape level. Commercial extraction of shale gas involves establishing many drill sites and pads dotted across the landscape. This large area, and the associated construction infrastructure, is likely to have a significant impact on landscape fragmentation and direct impacts on many sites that are rich in wildlife.
The Wildlife Trusts oppose fracking in principle because of its contribution to greenhouse gas emissions and climate change.
If, despite this, extraction does go ahead, then to address and minimise other, avoidable risks associated with hydraulic fracturing, proposals should be aligned with the Are We Fit to Frackreport (2015) and the recommendations set out below.
Recommendations if extraction is permitted
To minimise the potential risks associated with hydraulic fracturing, The Wildlife Trusts believe that:
Allproposals for shale gas extraction should go through the full planning process and in each case include public consultation, compliance with EU Directives and a full Environmental Impact Assessment (EIA).
The EIA should be undertaken, prior to the submission of a planning application and cover the lifetime of the project through to decommissioning of the site. It should:
- include baseline ecological data and baseline data for air and water quality;
- disclose all chemicals involved in the process;
- assess the risks of waste water disposal against reuse of waste water;
- identify the least damaging disposal route for the waste water (including an assessment of the potential impacts of discharging waste water into the marine environment);
- fully assess the effects on the local hydrological regime and water supplies;
- a lifetime assessment of carbon emissions associated with the site (including transport, gas leakage etc);
- set out how the abandoned wells will be monitored to ensure well integrity is maintained in the long term; and include current and future operation proposals to ensure that the total ecological footprint of the development and phased future wells are accounted for.
Planning consent should be refused for shale gas extraction in protected sites or where operations would pose a significant direct or in-combination impact to wildlife, habitats or ecosystems or where the potential risk of environmental damage is high, regardless of mitigation.
An abstraction licence should be refused where there is likely to be a significant impact on the local hydrological regime and water supplies.
There should be strict interpretation and enforcement of the regulatory regime to ensure that wildlife habitats and ecosystems are protected from the potentially damaging effects of shale gas extraction. This will require a sufficient number of adequately skilled and resourced regulators.
To minimise risks to the water environment:
- fracturing should never be permitted where the separation zone between an aquifer and the gas extraction zone is less than 600 m. Where geological conditions are particularly risky, this separation zone may need to be greater and as such, the separation zone should always be assessed on a case by case basis.
- only substances assessed as non-hazardous should be used in the fracturing fluid.
- options for treating and disposing of waste water must be planned and agreed with the planning authority and the regulating body – these options should assess and address the potential impacts of discharging waste water into the sea; and the potential for reusing waste water.
- wastewater should not be re-used in the fracturing fluid if it contains chemical contaminants and radioactive materials that may pose a risk to the water quality of the aquifer.
Air quality (including methane emissions) and the water environment (for methane and other contaminants), should be monitored and funded by the operator during production operations and all findings should be regularly reported to the appropriate regulating body.
Consented operations should result in a net gain in biodiversity in line with current legislation, the National Planning Policy Framework and other biodiversity commitments.
The precautionary principle should always be adopted until adequate scientific evidence exists with regards to the immediate and long-term environmental impacts.
Appendix 5 – Statement by Chester Zoo
This statement has been approved by the North of England Zoological Society’s Board of Trustees:
Chester Zoo has carefully considered the future of Unconventional Gas Extraction (UGE). As this is a recent technology, scientific analysis of UGE is still developing, but the balance of evidence available suggests that there is a potential for damaging long-term environmental impacts. Based on the potential impact within West Cheshire therefore, we object to Unconventional Gas Extraction in the local area because:
There are specific concerns about the impact on the aquifer (the underground layer of water bearing rocks), from which we draw water for our 21,000 animals, our plantcollection and grounds. Although Chester Zoo works hard to reduce its water consumption, in 2017 we drew on 155,140 cubic metres of water and as a charity, and with such a large and varied collection of plants and animals, some of which are critically endangered, access to this supply is vital. If the supply became degraded or reduced, this could become a major risk to not only our zoo but also our nature reserve and wider estate as well as putting at risk the millions of pounds of gross value added the zoo brings to the local economy. As such, the potential impacts of unconventional gas extraction processes have been elevated on our risk register and are subject to regular monitoring.
There is potential for direct and indirect negative impacts on wildlife and the wider community both during the construction and operational phases of unconventional gas extraction. The process will contribute to habitat loss and fragmentation at a landscape level.
Chester Zoo is cognisant of the new global change scenarios outlined in the IPCC Special Report on Global Warming published in October 2018 and fully supports all moves to reduce the world’s carbon footprint as a matter of urgency. Chester Zoo recognises that keeping down the cost of energy is a very important issue for UK householders and businesses and it does recognise that shale gas reportedly produces less CO2 than imported liquefied natural gas (the UKs current major source of energy).Chester Zoo remains convinced the ultimate goal for the source of energy production in the UK and the wider world is renewables.
Appendix 6 – Article from “Insurance Journal” (USA)
Changing Oil & Gas Industry Delivers New Risks, New Challenges
By Pascal M. Ray | January 11, 2016
While this new technology has created many new issues for the insurance industry, this particular article is centered on risks that exist with the 4.3 million existing wells in the U.S. that have already been drilled and completed since the first commercial oil well was drilled in Pennsylvania in 1859.
Non-Infinite Life Span
Oil and gas wells do not have an infinite life span. With thousands of wells across the nation now over 150 years old, the evolving risks that come from aging oil and gas wells failing are becoming more apparent. A well can “blowout” in any phase of its life, even when it is producing, shut-in, or plugged and abandoned. As the casing and cementing on older wells deteriorate, the risk of failure increases. At some point in the future, well failures from these older wells may become more commonplace and could have a major impact on the insurance industry.
Oil and gas wells are known to pollute ground water, air and surface areas, as long as we have been drilling wells. Even with millions of wells safely drilled, hazardous pollutants can escape during a blowout, as the Gulf of Mexico blowout in 2010 substantiated.
Well integrity is critical for the reliability and longevity of a well. The well casing and cementing are the front line defense to keep unwanted substances from migrating outside of the well and possibly making it into the groundwater, or reaching the surface, causing a cratering event. Pollution arising from oil and gas wells mostly involve surface events, such as spills or other surface-related occurrences, but these events also can involve underground crossflows of water and/or hydrocarbons between sub-surface strata. When a sub-surface event arising directly from a well does occur, one of the major causes of this is the failure of the well casing and cement that seals it in place.
In October 2015, a natural gas storage facility well blowout occurred in Los Angeles in an area known as Porter Ranch. The well went into operation in 1954 and was converted into a gas storage well in 1973. The cause of loss was predicted to be a casing failure possibly due to corrosion, but no one knows for certain at this time. This blowout is ongoing and expected to be brought under control in late February or March 2016 via relief wells being drilled.
The Porter Ranch blowout is unique as it is developing into what may be one of the largest evacuations due to a well blowout in U.S. history. Several thousand people evacuated the area and more are considering evacuation from this populated area of 30,000. Evacuation expenses from this will be significant.
Proximity of well operations to populations of people is an often overlooked exposure, and evacuation costs need to be factored into the decision on how much insurance coverage, in terms of limits of insurance, a client should purchase. Defense costs are another significant and often overlooked exposure that need to be quantified and defined in clear language on the policy.
The Porter Ranch blowout is attracting media’s attention, several class action lawsuits have been filed, and celebrities and activists are getting involved. Public opinion may have an effect on jury verdicts arising from the lawsuits, which may significantly increase exposure to insurers.
As risks in the oil patch evolve, so should the insurance program of clients in this business.
|EP01||Adequacy of Current State Setbacks for Directional High-Volume Hydraulic Fracturing in the Marcellus, Barnett and Niobrara Shale||M Haley, M McCawley, A C. Epstein, B Arrington and E Ferrell Bjerke, Environmental Health Perspectives July 2016|
|EP05||Everything you always wanted to know about Acidising||Kathryn McWhirter et al. for Weald Action Group, Revised 2018|
|EP08||Fracking under the Radar||Weald Action Group 2017|
|EP14||Site Map of proposed development site||Frack Free Ellesmere Port and Upton|
|EP19||Ellesmere Port Development Board Vision and Strategic Regeneration Framework: Executive Summary||Ellesmere Port Development Board 2011|
|EP20||Use of acid at oil and gas exploration and production sites||HM Government Environment Agency 2018|
|EP23||Letters to Estelle Dehon||IGas|
|EP28||Environmental Permit EPR/BB3708GN||Environment Agency|
|EP29||EA Screening tool V1 EPR BB3708GN DST||Environment Agency|
|EP31||Offshore Statistics and Regulatory Activity 2017||HSE|
|EP32||OGP Blowout Frequencies||International Association of Oil and Gas Producers|
|EP33||HSE Offshore Hydrocarbon Releases||HSE|
|EP34||Letter from HSE to CW&C 4 Dec 2017||HSE|
|EP35||Environmental regulation and compliance of Marcellus Shale gas drilling||Timothy J. Considine et al – 2014|
|EP36||A guide to the Borehole Sites and Operations Regulations 1995||HSE|
|EP40||Oil and Gas Wells and their Integrity: Implications for shale and unconventional resource exploitation||RJ Davies et al 2014|