Shale Gas - Energy and Climate Change Contents

Supplementary memorandum submitted by the Environment Agency (SG 23a)

Q1  How will the Environment Agency monitor emissions from shale gas exploration and production including NOx, volatile organic compounds, particulate matter, SO2, and methane?

The Environment Agency will not normally monitor emissions to air from shale gas exploration and production activities because the activities will not normally require a permit issued by the Agency under the Environmental Permitting Regulations (EPR) 2010 for emissions to air.

Such a permit will only be required if the activities involve the refining or large scale combustion of gas as described below:

Refining of gas: We expect that shale gas will normally be pure enough not to need refining. However if it is refined then an EPR permit will be required for emissions to air. The Environment Agency will be the regulator if the quantity refined exceeds 1,000 tonnes per year and the local authority will be the regulator if it is less than 1,000 tonnes per year.

Combustion of gas: We expect that shale gas will only be burned on a small scale (less than 20 megawatts (MW) thermal input). However if it is burned on a large scale then an EPR permit will be required for emissions to air. The Environment Agency will be the regulator if the combustion plant has a thermal input greater than 50 MW and the local authority will be the regulator if it is between 20 and 50 MW.

If the activities did require an EPR permit for emissions to air the operator would be required to monitor emissions of oxides of nitrogen, volatile organic compounds, sulphur dioxide and methane. The permit issued to the activity would have due regard to the Government's Air Quality Strategy. Monitoring results would be reported to the regulator. In addition the regulator could carry out its own monitoring.

Where there is no requirement for a permit, there will be controls under Part III of the Environmental Protection Act 1990 in relation to statutory nuisances, and under health and safety legislation as regards safeguarding the workforce from emissions. Local authorities are responsible under the 1990 Act for inspecting their areas for nuisance—including odour and noise associated with the venting or flaring of gas. The Health and Safety Executive will ensure safe operation at both exploration and production phases (eg by minimising releases and the flaring of vented gases) and these controls may also have an environmental benefit.

Q2  Is the Environment Agency concerned by the production and storage of volatile "wet gas" or "gas condensates" produced along with shale gas?

No. We expect most shale gas wells to produce a high quality gas that will not need refining so there will be no gas condensates produced.

However, the composition of Shale Gas varies on a site by site basis depending on the underlying geology, with some being "wetter" than others. If the shale formation produces a "wet gas" operators will need to refine gas before injecting it into a natural gas pipeline. If "wet gas" is combusted on-site, it will require a permit as described in the answer to Question 1.

Q3  How will gases and waste water produced during well completion (when the well bore is made free of debris, gas, and water prior to production) be dealt with?

Operators will require a permit from the Environment Agency under EPR 2010 in advance of beginning the production phase where:

  • drilling activities may have an impact on a groundwater resource;
  • certain onsite activities (eg refining and/or large scale combustion of gas) are taking place; and
  • operators wish to discharge waste or waste water to the environment.

The Environment Agency will not normally regulate the emissions of gases produced during well completion. However we can make recommendations during the planning application process to ensure the well design and construction minimises any environmental impacts.

Waste water treatment and disposal options will vary depending on the nature of the waste and local environmental conditions. The Environment Agency will assess this on a case by case basis and in accordance with the EPR 2010.

  • An environmental permit would be required for a discharge into a surface environment, for example to a local watercourse. Pre-treatment is likely to be needed to ensure the discharge can meet environmental standards.
  • Operators may be allowed to dispose of waste water back into the strata from which it has been extracted, subject to environmental safeguards and providing only waste directly from the shale gas extraction operation is involved.
  • If groundwater is present in the strata then the disposal would become a groundwater activity under EPR 2010 and a permit would be required.
  • Where an operator needs to transfer waste fracking water offsite for treatment, they will need to satisfy any conditions required by the waste receiver/treatment facility, who in turn will be operating under an environmental permit. It will be necessary for the waste receiver to ensure that the waste is suitable for treatment at their facility and that they can continue to meet their own responsibilities under the legislation.

Q4  Is the Environment Agency aware of "green completion" technology and equipment developed in the US that allows such emissions to be captured (and then sold)?

The Environment Agency has not yet encountered "green completion" technology since there has not yet been any commercial development of shale gas in the UK. In the event that an operator would need a permit under EPR 2010 from the Environment Agency, we would require operators to use Best Available Techniques for the management of shale gas emissions and/or the disposal of waste fracking water. The operator wants to sell the natural gas so it will be in their commercial interests to minimise gas releases into the air, and to maximise the reuse of water.

April 2011

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© Parliamentary copyright 2011
Prepared 23 May 2011