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,
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
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 nuisanceincluding 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
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
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
- drilling activities may have an impact on a groundwater
- 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
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.