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$: 30056R2 Ebberston Moor South - Ryedalefrackfreeryedale.org/wp-content/uploads/2014/10/Ebberston-Moor... · Ebberston Moor South wellsite. Hydrogeological Review: Planning Application$
H FRASER CONSULTING LTD PO BOX 4804, SHREWSBURY, SY1 9JH

T: 01743 352797 M:07527 006625 E:[email protected] www.hfraserconsulting.co.uk

Registered Company No 07712855

H FRASER CONSULTING CONTAMINATED LAND AND HYDROGEOLOGY

Ebberston Moor South wellsite

Hydrogeological Review

Planning Application

Prepared for: Frack Free Ryedale and

Frack Free North Yorkshire

Date: 23/10/2014

Status Final Reference: 30056R2

© H Fraser Consulting Ltd 2014 Prepared by: H Fraser Consulting Ltd

H FRASER CONSULTING CONTAMINATED LAND AND HYDROGEOLOGY

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The advice and opinions in this report should be read and relied on only in the context of the report as a whole, taking account of the terms of reference agreed with the client. The findings are based on the information made available to H Fraser Consulting at the date of the report (and will have been assumed to be correct) and on current UK standards, codes, technology and practices as at that time. They do not purport to include any manner of legal advice or opinion. New information or changes in conditions and regulatory requirements may occur in future, which will change the conclusions presented here.

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Ebberston Moor South wellsite. Hydrogeological Review: Planning Application

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CONTENTS

1 INTRODUCTION ................................................................................... 1

1.1 Objective .......................................................................................................... 1

1.2 Scope of works ................................................................................................. 1

2 TECHNICAL ASSESSMENT .................................................................... 2

2.1 Environmental Sensitivity .................................................................................. 2

2.2 Risk of pollution ................................................................................................ 2

2.2.1 Geological and hydrogeological controls ............................................................. 3

2.2.2 Borehole integrity ............................................................................................ 4

2.2.3 Drilling at Ebberston B ...................................................................................... 5

2.2.4 Site Drainage ................................................................................................... 5

2.2.5 Site construction .............................................................................................. 6

2.2.6 Potential Impacts of the pipeline ....................................................................... 7

2.3 Injection rates and risk of seismicity .................................................................. 7

2.3.1 Injection rates ................................................................................................. 7

2.3.2 Rock strength and seismicity ............................................................................. 8

2.4 Best Available Techniques ................................................................................. 9

3 IMPLICATIONS FOR PLANNING ........................................................ 10

4 CONCLUSIONS AND RECOMMENDATIONS ........................................ 13

5 REFERENCES ...................................................................................... 15

TABLES Table 2.1 Water quality ................................................................................................. 2


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1 INTRODUCTION

Frack Free North Yorkshire and Frack Free Ryedale have commissioned H Fraser Consulting Ltd to undertake a hydrogeological review of Ebberston Moor South wellsite planning application and Environmental Permit Application.

Third Energy Limited and Moorland Energy Limited have submitted a planning application for:

• gas production and water re-injection at an existing borehole at the Ebberston Moor South well site;

• construction of a second borehole for water production and re-injection;

• transfer of natural gas via a proposed 13.9 km long 12" diameter steel underground pipeline from Ebberston Moor South well site to the Knapton Generating Station; and

• a new gas reception module at the Generating Station.

Additionally, an Environmental Permit Application has been submitted to the Environment Agency for a radioactive substances activity (the produced water is known to be radioactive, and production and re-injection of water is therefore deemed a radioactive substances activity and subject to Environmental Permitting Regulations).

1.1 Objective

The objective of the review is to examine the following aspects of the application:

• The environmental sensitivity of the site, with respect to groundwater

• The risks of groundwater pollution arising from the activities, to include the role of geological controls on pollution, borehole integrity, site drainage, construction activities, and the potential impacts of the pipeline

• Injection rates and the risk of seismicity

1.2 Scope of works

The following works have been undertaken:

• Review of Environmental Statement and Environmental Permit Application

• Review of relevant technical information and data

• Reporting

It is noted that a Technical Assessment submitted with the Environmental Permit application has not been made publically available by the Environment Agency.

The work has been undertaken by Hannah Fraser, Director of H Fraser Consulting Ltd, who is a Chartered Geologist with 17 years’ experience as a hydrogeologist and environmental consultant.


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2 TECHNICAL ASSESSMENT

The key documents reviewed were:

• Environmental Statement submitted with the planning application

• Environmental Permit Application, including a Non-Technical Summary

2.1 Environmental Sensitivity

The Ebberston South site is located within Zone 2 of a Groundwater Source Protection Zone, and lies within 250 m of Zone 1 of the same protection zone. These source protection zones are designed to protect significant groundwater abstractions, in this case from the Corallian Limestone Group. The Corallian Limestone is designated by the Environment Agency as a Principal aquifer. These are layers of rock or drift deposits that have high intergranular and/or fracture permeability - meaning they usually provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. The site is also located above an aquifer that is of local importance as a source of raw water for treatment and domestic consumption. There are currently 13 groundwater abstraction licences in the vicinity, the closest being 500 m distant at Givendale Head Farm. The environmental setting is therefore highly sensitive with respect to groundwater resources.

Harrison et al (2005) describe ‘an area affected by the Vale of Pickering-Flamborough Head Fault Zone… where hydrocarbons generated within and migrating out of the centre of the [Cleveland] basin may have been trapped in structures that were formed along the fault zone, during its development from late Jurassic to early Cretaceous times. Two horizons within Permian Strata are productive with the source of gas thought to be the coal measures in the subcrop.’ The site is therefore within an area affected by the Vale of Pickering Fault Zone.

2.2 Risk of pollution

Table 2.1 presents the expected water quality of the produced water, and compares it with Environmental Quality Standards and with Drinking water standards.

Table 2.1 Water quality

Determinand Units Produced water Quality standard

pH 5.6 1 pH units 5.6 6.5 - 10

ammonia 2 mg/l NH3 46.9 0.2

chloride 1 mg/l 170000 250

sulphate 1 mg/l 1050 250

aluminium 1 µg/l 63 200

zinc 2 µg/l 11 8

sodium 1 mg/l 84000 200

conductivity1 µS/cm 208000 2500

TPH ali/aro:3 ug/l 7400 10

Radioactivity 21GBq per month 20 MBq

1 Water Supply (Water Quality) Regulations 2000 2 The River Basin Districts Typology, Standards and Groundwater Threshold Values (Water Framework Directive)

(England and Wales) Directions 2010 3 Former drinking water guideline


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It is clear that the produced water presents a risk of pollution, with many parameters exceeding quality standards by several orders of magnitude.

It is noted that whilst the quality of the produced water and of the Sherwood Sandstone has been assessed, the groundwater quality in the shallow aquifers, including the Corallian Limestone aquifer, has not been tested. There is therefore not a baseline against which to measure future changes in water quality.

2.2.1 Geological and hydrogeological controls

The Non-Technical Summary states that

‘When combined, the various aspects of the technical assessment describe a system with no transfer of water vertically between the shallow aquifers and deep water bearing formations, either upward or downward. This is achieved by the low permeability and thickness of intervening layers. The effectiveness of the hydraulic separation is demonstrated by the marked difference in water quality between the shallow aquifers and deep water bearing formations, where the Sherwood Sandstone is at great depth’

and

The likelihood of occurrence [of pollution] is very low because:

• approximately 700m of low permeability formations provide a vertical separation between the point of injection and the nearest groundwater supplies.

• The lateral distance between the point of injection and the feather edge of the Triassic Sandstone where the formation provides potable water is approximately 35km. Significant geological faulting between the injection point and the outcrop area will limit lateral movement. lnjection displacement of formation water over the lifetime of the scheme is less than 1km, with pressure effects limited to less than 4.2km.

It is not clear from the available information how the faulting in the area governs groundwater movement. Faults can act as conduits or barriers to groundwater flow. Major faults mapped by the British Geological Survey show a large number of east-west trending faults in the Vale of Pickering Fault Zone, the nearest being 3.6 km to the south. In addition, the Sherwood Sandstone generally has a well-developed secondary permeability arising from a network of smaller faults and fissures. The lack of assessment of the risks arising from faults is considered a significant failing in the application; it is imperative that the applicant and regulators have a full understanding of the role of the local fault system prior to the application decision being made.

There is virtually no specific information provided regarding rest water levels in the various aquifer units at the site; Figure 12.1 of the Environmental Statement shows that the site elevation is approximately 220 m above Ordnance Datum (aOD), the upper aquifers (including the Corallian Limestone aquifer) extend to c. -100 m aOD, and groundwater elevations are of the order of 100 m aOD, potentially lower where there are groundwater abstractions.

The hydrostatic pressure (expressed as piezometric elevation) in the Sherwood Sandstone will be a governing factor in the injection pressures required to re-inject produced water. It is imperative that there is not an upward hydraulic gradient between the Sherwood Sandstone and the Corallion (or for that matter, the KAF and the Corallion) as this would represent a significant pollution risk in perpetuity, as the borehole degrades. Additionally, future drilling and groundwater abstraction in the Corallion may lower groundwater levels to below the piezometric elevation in the Sherwood Sandstone, thereby creating a potential pathway for migration of brine, particularly up the borehole pathway but also potentially along faults and fractures.


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The lack of information regarding the piezometric elevations within the permeable strata at the site is seen as a significant failing of the application. It is essential that this information is made available prior to the application decision being made, along with an assessment of the implications for long term risk and aquifer management at the site.

2.2.2 Borehole integrity

The RSE application Non Technical Summary states

‘the only plausible risk of contamination of water supplies would relate to inadequate construction of the injection well, resulting in groundwater contamination’

Davies et al (2014) provide numerous examples of well barrier and integrity failure, which can lead not only to pollution of water resources but release of toxic and explosive gases to atmosphere. These can include failure of the grouting to adhere to the formation, failure of the grouting to adhere to the casing, migration of fluids between well plug and casing, through a well plug, and along a sheared well bore. In the most extreme examples, blowouts at gas wells can cause explosion, release of gas and brine to the environment with air and water pollution as a result.

It is clear that there is significant potential for pollution at the site, in addition to health and safety implications. It is vitally important that construction, operation, decommissioning and restoration of the borehole(s) are undertaken to the highest standards to prevent significant environmental harm. Given the nature of the risk and the sensitivity of the setting, it is considered inappropriate that so little information regarding borehole design, operation and restoration has been provided. Section 11.113 of the Environmental Statement says:

The initial drilling operations will utilise an existing borehole that is isolated from shallow groundwater aquifers by steel casings and there will be no effect on the aquifers from this operation. The water injection borehole will be drilled later and a new borehole will be constructed that penetrates the groundwater aquifers. The effects on groundwater of drilling the water injection borehole are assessed in Chapter 12.

And Section 12.47 states that:

The modification and construction of the boreholes will be controlled by the offshore Installations and wells (design and construction etc) regulations 1996.

Given the pivotal role that design and construction of the boreholes will have on protecting the groundwater resource, it is considered that this information should be publically available before the permit/planning decision is made, and not conditioned as part of the planning application.

Appendix 5.2 of the Environmental Statement provides some detail of the methods proposed to modify the existing borehole, but does not address the construction of the new borehole. The process outlined does not include for testing the integrity of the existing casing to ensure that there are no migration pathways into the Corallion aquifer.

The borehole design and operation should seek to:

• Demonstrate the current borehole integrity by means of pressure testing and downhole surveys to examine the integrity of the grout seal and the casing.

• Maintain separation between the Kirkham Abbey Formation and the Sherwood Sandstone Aquifer. This will presumably be achieved by the use of borehole packers. No information is provided as to how these will be operated, tested and maintained to ensure an ongoing seal between the units. Decommissioning and restoration should ensure that the seal between the aquifers is maintained in perpetuity.

• Maintain hydraulic separation between the Sherwood Sandstone and the overlying Corallion aquifer. In order for this to be achieved, the well casing must be grouted


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against the upper formations, which is likely to be hard to achieve in the Corallion which may be subject to the formation of dissolution features . Decommissioning and restoration should ensure that the seal between the aquifers is maintained in perpetuity.

• Provide for regular and frequent independent testing of borehole integrity.

• Plan for decommissioning, and provide expected design life and criteria that would trigger decommissioning prior to the integrity of the borehole being compromised.

• Provide a restoration that will maintain an effective seal between aquifer units in perpetuity. The propensity for long term leakage between aquifer units and pollution will be governed by the hydraulic relationships between aquifer units, which have not been adequately described.

Full details of the restoration are not provided. If it cannot be demonstrated that the pollution risk will be managed in perpetuity, either by ongoing management or by an unequivocal blocking of the entire borehole column, then the radioactive brine should be treated prior to reinjection into the Sherwood Sandstone Aquifer.

Given the crucial role that borehole design, operation and restoration have in providing environmental protection to the important groundwater resources at this site, it is considered wholly inappropriate to grant an Environmental Permit prior to full details being submitted for examination.

2.2.3 Drilling at Ebberston B

We understand that drilling at Ebberston B site was abandoned after difficult drilling conditions were encountered. The Corallion aquifer is subject to dissolution and loss of drilling fluids to voids in the formation can create difficult drilling conditions. Even where drilling is successful, it can be very difficult to ensure a good seal between casing and formation due to loss of grout into the formation.

Full disclosure of the events surrounding the abandonment of the Ebberston B site is necessary to understand the potential issues encountered and to assess whether similar conditions are likely to be encountered at Ebberston South.

2.2.4 Site Drainage

The following description of site drainage arrangements is taken from the Environmental Statement:

11.82 The EMS Well Site was constructed in 2009 by levelling the ground and then laying a bentonite membrane across the well Site, protected by sand layers and geotextiles from risk of puncture. This forms an effective impermeable membrane underlying the EMS Well Site that traps any fluids produced on the well Site, either from the construction or operation phases, or rainfall.

11.83 The bentonite membrane was continued through into the ditches forming the EMS Well Site boundaries and up over bunds to provide a sealed drilling site with capacity to contain any discharge from tanks on site and a nominal 50 barrels/day flow of oil from the wellhead in the event that control of the borehole was lost. Oil has not been discovered so the likelihood of that event occurring is non -existent.

11.84 The existing scheme of water management on the EMS Well Site is as follows:

• All surface water on the impermeable central part of the EMS Well Site drains into the perimeter ditch;

• Soil bunds outside the perimeter ditch prevent escape of water from the EMS Well Site;


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• Flow in the perimeter ditch is under gravity to a sump located at the south east of the EMS Well Site;

• Water from the sump is pumped into two onsite storage tanks for use during the operations;

• Excess surface water not required for site operations will be removed by a licenced waste carrier; and

• There is no discharge of water from the EMS Well Site

However, paragraph 11.119 states that

‘Rainwater will continue to be collected within the Well Site and discharged via the oil interceptors and soakaway into the ground resulting in negligible effects during the operational phase’

And paragraph 11.143 states that

When the EMS Well Site is developed the surface water management will be modified so that rainwater will be gathered in the ditches and either used on site or discharged through an oil interceptor and soakaway into the ground. The oil interceptor will be located at the south eastern corner of the EMS Well Site and will provide control on all discharge and a monitoring point will permit sampling to check the discharge. Valves fitted to the outflow pipe from the Site will enable isolation of the interceptor during drilling operations and the risk of contamination to the aquifer will be negligible. The location of the interceptor in this position moves the point of discharge to the outer edge of the SPZ Zone 2

There drainage arrangements, which play a fundamental role in environmental protection, are clearly inadequate and incomplete. It is unclear how surface water is to be managed at the site, and this has significant implications for pollution response and spill management.

The use of a site interceptor and soakaway at this site is considered highly inappropriate due to the small but real risk of a significant and major pollution incident caused by a blow-out, in combination with the sensitivity of the setting. In addition, an interceptor deals with free phase hydrocarbons but would be ineffective in preventing release of radioactive and highly saline brine.

Given the sensitivity of the setting and the highly polluting potential of the radioactive brine, it is considered wholly inappropriate to grant an Environmental Permit for the site prior to provision of full details of the following:

• A quantified site water management plan detailing the arrangements for management of rainwater, run-off, and produced water, including any treatment and storage systems;

• An environmental monitoring plan to include monitoring of groundwater quality at the site, at local groundwater users, and of any site discharges

• Site-specific environmental management and pollution response procedures.

2.2.5 Site construction

Section 5.7 of the Environmental Statement says that

The construction phase will involve: foundation excavation and construction; installation of below and above ground services, the fibre optic cable and pipeline; construction of structures including separator and storage tanks; and construction of services and facilities at the EMS Well Site.

It has already been demonstrated that the bentonite mat underlying the site is of paramount importance in mitigating the potentially high polluting effects of either chronic long-term


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slow release pollution or more acute pollution incidents. It is not at all clear how the integrity of this bentonite layer will be maintained during construction activities, and how structures that penetrate the mat, including the new borehole, will be sealed against downward migration of pollutants. Further details should be provided prior to an application decision being made.

2.2.6 Potential Impacts of the pipeline

Drilling of the pipeline south of the railway line, is described in the Environmental Statement as follows:

11.79 In the area south of the A170, the underlying bedrocks are from the Kimmeridge Clay Formation which have been considered impermeable with no useful aquifer capacity even if they may have some groundwater. The Kimmeridge Clays are overlain by superficial deposits that vary according to their location. A narrow strip of Glacial deposits of silts and sands overlie the Kimmeridge Clay immediately south of the A 170 and the remainder of the pipeline route to the railway line is overlain by superficial Lacustrian deposits comprising silts sands and clays of variable permeability. The Envirocheck report (Appendix 15.1) suggests the presence of running sands and quicksands in places. These water-bearing gravels and sands will present groundwater issues as there are some abstraction boreholes that are used to supply farms.

11.116 ‘the pipeline passes through deposits that are a minor aquifer so that a spillage will potentially have a moderate/major adverse effect that will persist until the pollutant had been removed or pumped out’

There is the potential for the pipeline ditch to intercept a shallow water table south of the A170, in which case there may be a requirement to dewater the ditch during construction activities. Dewatering activities have the potential to derogate water features and groundwater users; this impact on the local groundwater environment has not been considered by the Environmental Statement. The following information is required in order for the likely impacts to be assessed:

• A hydrogeological impact assessment to include identification of sections pipeline route that require dewatering, a water features survey to identify water features at risk of derogation, and an impact assessment to estimate the influence of dewatering activities and identify any mitigation measures that may be required. An assessment of potential impacts of dewatering on wildlife habitats and designated nature conservation sites should also be made.

2.3 Injection rates and risk of seismicity

2.3.1 Injection rates

The Non-Technical Summary states that 556 m3/d are to be injected into the existing injection well, as does table 12.7 of the Environmental Statement. It is noted that paragraph 12.46 of the Environmental Statement says that the diameter and construction of the borehole will limit the injection rate to 573 m3/d. Clarification of the proposed rate should therefore be sought.

Table 12.7 of the Environmental Statement says that an additional 1344 m3/d will be injected via a new well, and paragraph 12.72 states that:

the combined rates of injection at the EMS Well Site and Ebberston ‘A’ Well Site will not exceed the 1,900m /day (11,951bbl/day) rate that has been permitted. Consequently, there are no cumulative effects , over and above that which has already been permitted, to consider.


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There is contradiction between the Non-Technical Summary and the Environmental Statement as to which volumes will be injected at which sites. It is noted that the current permit application only mentions 556 m3/d from the existing borehole and does not provide injection rates for the new borehole. Unless the existing permit for Ebberston A is transferred, granting of the permit would result in a total permitted volume of 2456 m3/d, with only 556 m3/d injected at Ebberston South. If there are to be no cumulative effects between the two sites, the Ebberston A permit should be rescinded, or transferred to Ebberston South. If the applicant intends to inject the total 1,900 m3/d at Ebberston South, the current Environmental Permit application does not allow for this.

2.3.2 Rock strength and seismicity

Injection of produced water to deep aquifers has been linked with seismic activity, with injection pressure seen as a factor in inducing seismic activity.

Seismic activity is not induced by lubrication of faults by injected fluid, rather by an increase in pore pressure which effectively reduces the natural friction on a fault (GWREF, 2013). The volume of water injected therefore has a role to play, as well as the injection pressure. In fact, Saar and Manga (2003), describe hydroseismicity caused by naturally occurring recharge due to snowmelt, indicating that in some settings hydroseismicity occurs under low pressures. Hydroseismicity induced by recharge from surface reservoirs is also well documented (Talwani & Acree, 1985),as is seismicity induced after groundwater recharge (Roth et al, 1992) and rainfall events (Jiménez & Garcıa-Fernández, 2000).

Paragraph 12.53 of the Environmental Statement claims that

The moderate hydraulic conductivity of the Sherwood Sandstone formation means that no high pressure injection is anticipated, since the “injectivity” of the well should be sufficient to provide the required injection flow rates.

However, the proximity of the wells site to the Vale of Pickering fault zone may mean that seismicity could be induced under low injection pressures. The Non-Technical Summary states that

‘lnjection displacement of formation water over the lifetime of the scheme is less than 1km, with pressure effects limited to less than 4.2km’.

However, a major fault is located 3.6 km south of the site. In addition to major faults, the Sherwood Sandstone is well recognised for its secondary permeability (permeability that is developed through faults and fissures rather than its pore structure) and it is likely that there will be myriad small faults and fissures far closer to the site.

No information is provided on the piezometric elevation within the Sherwood Sandstone and the effect this will have on injection rates. If the piezometric elevation is relatively high, there will be less driving head in the water column in the well to allow the injection to occur by gravity alone. Failure to achieve the required injection rates will result in either an increase in injection pressures, potentially giving rise to seismic activity, or will result in large volumes of radioactive produced brine accumulating at surface.

The Non-Technical Summary states that

‘injection pressures will be generally low and will always be controlled to ensure they do not exceed the strength and fracturing pressure of the formation’.

However, it is not clear how or whether the strength and fracturing pressure of the formation has been measured, or whether it will be monitored during operations. Rock strength is typically measured in lab samples, but this fails to account for the in-situ strength of the rock which may be fractured and faulted. Additionally, no information has been provided on the injection pressures required to inject water in to the formation.


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The risk of hydroseismicity has not been explicitly addressed, other than to state the injection pressures will be low. Clarification should be sought regarding the injection pressures that are considered appropriate for the setting, however it is considered equally important that further assessment of risks arising from low pressure injection should be undertaken particularly with regard to the setting in the Vale of Pickering Fault Zone. Independent monitoring of seismicity throughout the operation is recommended.

2.4 Best Available Techniques

The assessment of BAT should include an assessment of pre-treating the radioactive waste water prior to re-injection, as this provides significantly more environmental protection than the proposed operation.


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3 IMPLICATIONS FOR PLANNING

The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 define an Environmental Statement as

‘a statement

(a) that includes such of the information referred to in Part 1 of Schedule 4 as is reasonably required to assess the environmental effects of the development and which the applicant can, having regard in particular to current knowledge and methods of assessment, reasonably be required to compile, but

(b) that includes at least the information referred to in Part 2 of Schedule 4’

The relevant parts of Schedule 4 are presented below in italics, along with a summary of the aspects of the Environmental Statement that are considered to be lacking with regard to the required environmental information.

Part 1 of Schedule 4 (information for inclusion in Environmental Statements) includes:

Description of the development, including in particular—

1 (c) an estimate, by type and quantity, of expected residues and emissions (water, air and soil pollution, noise, vibration, light, heat, radiation, etc) resulting from the operation of the proposed development.

No quantitative assessment has been made of the potential emissions to groundwater or surface water. Potential pathways include via the borehole(s), via site discharges of surface water to groundwater, and by catastrophic release to ground.

3. A description of the aspects of the environment likely to be significantly affected by the development, including, in particular, population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the inter-relationship between the above factors.

There is no consideration of potential seismicity in the Environmental Statement, and the effects this may have on the population and water environment. There are no baseline water quality data to describe the water environment.

4. A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development, resulting from—

(a) the existence of the development;

(b) the use of natural resources;

(c) the emission of pollutants, the creation of nuisances and the elimination of waste, and the description by the applicant or appellant of the forecasting methods used to assess the effects on the environment.

The Environmental Statement does not consider of the role of faults in promoting the transport of pollutants. The description of the protective effects of low permeability geological layers geology fails to acknowledge the disruptive effect that drilling through these layers will have, and does not adequately acknowledge the loss of environmental protection arising from the existence of the borehole(s). The effects of construction activities on the integrity and environmental protection afforded by the bentonite matting is not taken into account. Surface water drainage plans are incoherent and contradictory, which means that it is not possible to conclude the likely effects on the environment. The effects of dewatering the pipeline ditch south of the A170 have not been considered.


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5. A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment.

Site drainage is a key aspect of preventing significant adverse effects on the environment, and the contradictory information presented in the Environmental Statement is wholly inadequate as a description of the measures required in Section 5 above. There is insufficient information regarding borehole construction, operation, decommissioning and restoration to enable the efficacy of environmental protection measures to be judged. Further information on environmental monitoring, to include groundwater and surface water quality seismic monitoring, and monitoring of any site discharges is also required.

Part 2 of Schedule 4 (information for inclusion in Environmental Statements) includes

2. A description of the measures envisaged in order to avoid, reduce and, if possible, remedy significant adverse effects.

As a minimum, this should include:

• Full details of borehole design construction, operation, decommissioning and restoration

• Surface water drainage arrangements to include a quantified site water management plan detailing the arrangements for management of rainwater, run-off, and produced water, including any treatment and storage systems;

• An environmental monitoring plan to include monitoring of groundwater quality at the site, at local groundwater abstractions, and of any site discharges should be provided

• Site-specific environmental management and pollution response procedures

• Further details of plans to maintain the integrity of the bentonite mat during construction

• Independent monitoring of seismicity

3. The data required to identify and assess the main effects which the development is likely to have on the environment.

As a minimum this should include quantitative baseline groundwater and surface water quality data, data concerning the piezometric elevations within all relevant aquifer bodies, further information on the role of faults, additional details on borehole design (etc) and surface water management, and the monitoring aspects described above.

The Ryedale Plan – Local Plan Strategy Development Plan Document 5 September 2013 includes SP 17 ‘Managing Air Quality, Land and Water Resources’, which states that

‘Within Source Protection Zones 2 and 3 a risk based approach will be applied to the consideration of development proposals with the exception of development involving deep soakaways, sewerage, trade and storm effluent to ground which will not be permitted unless it can be demonstrated that these are necessary, are the only option available and where adequate safeguards against possible contamination can be agreed.’

Paragraph 11.143 of the ES states that

‘When the EMS Well Site is developed the surface water management will be modified so that rainwater will be gathered in the ditches and either used on site or discharged through an oil interceptor and soakaway into the ground.’

As the site discharge will include storm effluent, the Environmental Statement is considered to be in contravention of SP17 of the Ryedale Plan.

Paragraph 109 of the National Planning Policy Framework (NPPF) states that


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‘The planning system should contribute to and enhance the natural and local environment by:

• preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability’

Section 2.3 of the Environment Agency’s ‘Guidance for developments requiring planning permission and environmental permits’ (Environment Agency, 2012) states that

‘When deciding on a planning application, planning authorities should:

• Be confident the development will not result in unacceptable risks from pollution when considering if the development is an appropriate use of the land.’

It is judged that the environmental information provided in the Environmental Statement is not sufficient to be confident that the development will not cause unacceptable levels of water pollution or land instability, as required by the NPPF and Environment Agency (2012) guidance for developments requiring environmental permits. Additionally, the Environmental Statement does not fully comply with the requirements of the EIA Regulations (2011), nor SP17 of the Ryedale Plan.


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4 CONCLUSIONS AND RECOMMENDATIONS

The site is in a sensitive environmental setting, in Zone 2 of a source protection zone, within 250 m of Zone 1 of the same source protection zone, and on a the Corallian Limestone aquifer, a Principal aquifer. Numerous (at least 13) groundwater abstractions depend on the local groundwater for a mixture of local and strategic water supply.

The chemistry of the produced water is highly saline and radioactive, with many chemical parameters exceeding drinking water or environmental quality standards by several orders of magnitude. The nature of the proposed activity carries with it a risk of catastrophic pollution event such as a blow-out or explosion, or more low level chronic release to the environment. These chronic risks will be present in perpetuity owing to the nature of the installation, which creates a pathway between the aquifers and the source of saline brine. If such a pollution event were to be realised, the impact on the Corallian Limestone aquifer and shallow local aquifers could be severe and long lasting.

It is judged that the environmental information provided in the Environmental Statement is not sufficient to be confident that the development will not cause unacceptable levels of water pollution or land instability, as required by the NPPF and Environment Agency (2012) guidance for developments requiring environmental permits. Additionally, the Environmental Statement does not fully comply with the requirements of the EIA Regulations (2011), due to a lack of information (as listed below), nor SP17 of the Ryedale Plan, due to the intention to discharge storm water via a soakaway.

In order for this scheme to proceed, it must be demonstrated that Environmental Protection can be achieved. The application and supporting information are silent or contradictory on a number of important aspects that have a direct bearing on Environmental Protection, and it is considered necessary that further information is provided prior to any application decision being made.

• Baseline groundwater quality data should be provided in order for environmental performance to be monitored in the future

• The role of faults in migration of pollution should be assessed

• Piezometric elevations of the relevant aquifer units should be provided and implications for long term aquifer management assessed

• Full details of borehole design construction operation decommissioning and restoration should be provided

• Disclosure of events surrounding abandonment of drilling at the Ebberston B site should be made

• A quantified site water management plan detailing the arrangements for management of rainwater, run-off, and produced water, including any treatment and storage systems should be provided

• An environmental monitoring plan to include monitoring of groundwater quality at the site, at local groundwater abstractions, and of any site discharges should be provided

• Site-specific environmental management and pollution response procedures should be provided

• Further details of plans to maintain the integrity of the bentonite mat during construction should be provided.

• A hydrogeological impact assessment to assess impacts of dewatering along the pipeline route, to include an assessment of impacts on designated conservation areas and wildlife habitats.


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• The permit application and planning application should be consistent with regard to injection volumes, and the Ebberston A permit rescinded or transferred appropriately

• A technical assessment of the appropriate injection pressures should be provided

• An assessment of potential hydroseismicity under low and planned injection pressures should be made

• Independent monitoring of seismicity should be undertaken throughout the operation

• A BAT assessment should be undertaken to include pre-treatment of produced water


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5 REFERENCES

Davies, R.J., et al., 2014. Oil and gas wells and their integrity: Implications for shale and unconventional resource exploitation, Marine and Petroleum Geology (2014), http://dx.doi.org/10.1016/j.marpetgeo.2014.03.001

Environment Agency, 2012. Guidance for developments requiring planning permission and environmental permits.

Groundwater research and education forum (GWREF), 2013. A White Paper Summarizing a Special Session on Induced Seismicity, February 2013.

Harrison et. al 2005. Mineral resource information in support of National, regional and local planning. Humberside (comprising East Riding of Yorkshire, North Lincolnshire, Northeast Lincolnshire and City of Kingston upon Hull). British Geological Survey. Commissioned report CR/04/227N

Jiménez, M.-J., Garcıa-Fernández, M. ,2000. Occurrence of shallow earthquakes following periods of intense rainfall in Tenerife, Canary Islands Journal of Volcanology and Geothermal Research Volume 103, Issues 1–4, 20 December 2000, Pages 463–468

Roth, Ph., Pavoni, N., Deichmann, N. (1992) Seismotectonics of the eastern Swiss Alps and evidence for precipitation-induced variations of seismic activity. Tectonophysics Volume 207, Issues 1–2, 30 June 1992, Pages 183–197 The European Geotraverse, Part 8.

Saar, M. O. & Manga, M., 2003. Seismicity induced by seasonal groundwater recharge at Mt. Hood, Orego Earth and Planetary Science Letters 214 (2003) 605-61

Talwani, P. & Acree, S., 1985. Pore Pressure Diffusion and the Mechanism of Reservoir-Induced Seismicity PAGEOPH, Vol. 122 (1984/85).

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