The purpose of this series is to summarize the application by INEOS to the Derbyshire County Council for planning permission to start its search for shale gas from a site off Bramleymoor Lane near Marsh Lane, Eckington. This is to enable people who are opposed to such a major development towards fracking in the area, to develop their own counter-arguments when making their own submissions to the County Council.
The whole of the INEOS submission is 731 pages long. My own summaries are highly selective and far from perfect. But hopefully they may be of some assistance to those seeking to tackle INEOS's analysis and arguments.
This is summary (D) of the pattern I provided earlier. It is entitled "The Proposals" and is 42 pages long.To find the full version click here. I use the numbering system from the County Council's web-site.
Pages 3 to 6. Introduction.
Page 3 "On completion, the well would be temporarily suspended with the potential to use a "listening well" to monitor subsurface impacts arising from other operations in the region should such operations receive the relevant planning consents and environmental permits. This proposal is not to ... test or produce gas by hydraulic fracturing - a separate application would be required... "(they could then) "support a separate planning application for further work". Which "may include future wells on the same pad".
On page 4 appears INEOS's own summary of its proposals. It can be accessed via the link I provide above.
On page 5 is "Box 1 : Health and Safety" which mainly relates to the position of their workers. So it is worthwhile to check our INEOS's record in this area, to see if they have failed to live up to their claims.
On page 6 is "Box 2 : Aims of Core Well", i.e. geographical and safety, health and environmental issues.
From page 7 to 25 is a "Summary of the Proposals". There is the question of how far this is just a standard submission of theirs.
From page 10 is Table 1 on "Environmental Protection Measures" covering in turn - water and soil, air, noise, traffic, ecology, visual impact, flood, cultural heritage and archeology,waste and monitoring - these are all areas open to challenge.
Page 14 deals with "Drilling, Coring and Suspension". In blue below is the summary provided by INEOS -
Stage 2: Key Points
DURATION – APPROXIMATELY 3 MONTHS
Rig Assembly – 2 weeks
Drilling and Coring – 10 weeks
Suspension and Demobilisation – 2 weeks
HOURS OF WORKING
Assembly, drilling, coring and suspension – Monday-Sunday – 24 hours per day; 12 hour shifts
Site deliveries
Monday – Friday 0700-1900 – Saturday – 0700-1300 - Sunday or Bank/ Public holiday – no working
unless in an emergency or as agreed with the MPA
STAFF NUMBERS
Staff on site at one time during Stage 2 – up to approximately 25 (plus approx. 3 security)
Approximate total staff – 45
As the drilling operations would take place over 24 hours, the site would be continually manned.
SAFETY
Standard well safety equipment would be present on the site during drilling, including a blow-out
preventer, vent for emergency venting of gas encountered and methane (and radon) monitoring as outlined in the Borehole Regulations.
Safety measures for any construction site would also be followed, including an emergency plan,maintenance of fire extinguishers, and routine monitoring of plant to ensure safe operation.
Pollution prevention measures would be used including bunding, spill kits and training of staff.
Page 15 gives the "Rig Parameters". The rigs maximum height will,be 60 metres (i.e 86% the height of the Crooked Spire at Chesterfield .HB).
Page 16 on "Well Design and Geological Understanding of the Site". THERE IS AN IMPORTANT DIAGRAM ON THIS PAGE WHICH SHOWS THAT AT THE BRAMLEYMOOR LANE SITE THERE ARE 'WESTPHALIAN COAL MEASURES' ESPECIALLY AT 1,000 FEET BELOW GROUND. THEN AT 3,000 FEET AND BELOW THERE IS NAMURIAN BOWLAND SHALE. THE SHALE IS LIKELY TO BE RELATED TO WHAT INEOS ARE AFTER. BUT THIS COULD DISTURB THE COAL MEASURES NEAR THE SURFACE - ESPECIALLY IF LATER FRACKING RIGHTS WERE OBTAINED IN THE AREA. WHAT THEN OF SUBSIDENCE PROBLEMS?
Pages 17 shows boxes on "Drilling Fluids" and "Coring and Logging". Includes a section on "Environmental Protection Measures".
Pages 18 to 21 give tables with over 50 points on "Environmental Considerations and and Protection Measures". Page 20 (as Stage 3) being on the Maintenance of the Suspended Well Site. Page 21 giving "Features of Vertical Core Well" showing a photo of a large pool of water and a chart of the proposed well suspension.
Pages 21 to 22 give Environmental Considerations and Protection Measures, the Possible Workover of a Suspended Well and Use of the Well as a Listening Well.
Page 23 features a stage of the vertical corewell site (Although a photo is should show is missing at this stage)
Page 24 on "Abandonment (Decommissioning) and Restoration" leads to page 25 on aftercare, including a table with 8 points on "Environmental Protection Measures".
Pages 26 to 36 has 49 sections and contains 32 photos.
Page 33 has a table on "Summary of Traffic Movements via Vehicle Type".
Page 34 has a table on "The Breakdown of Total Traffic".
Page 35 has a table on the "Maximum Daily Traffic Movements" which it claims will average 240 per day drawn from (1) Site Construction - 266 movements (2) Drilling and Coring Suspension - 200 (3) Routine Maintenance (annual) - 96 (3a) Well Intervention/ Workover - if required 184 (4) Listening Well Operations - 174 (5) Decommissioning and Restoration - 281.
Page 36 is on Regulation and Internal Management, including working with the Coal Authority on its interaction with coal seams (There could be hope here that the depth of information the Coal Authority hold on (a) mine entrances, exits and other entry points called "adits" (b) on development high risk areas - two of them on the site INEOS wish to use, and (c) on a whole range of other information which can be discovered via this following link, can be used to destroy INEOS's case. -click here)
Page 36 Gives five sets of figures - (1) Site Development and Establishment, (2) Drilling and Coring, (3) Maintenance of Suspended Well Site Listening Well, (4) Use of Well as a Listening Well (5) Abandonment (Decommissioning) and Restoration.
Page 38, 39 and 40 contain six sideways photos - with boxes of information placed on them.
INEOS case can be overturned by the Derbyshire County Council, District Councils and individuals checking out their case and adding counter-information from the sources it often uses itself.
Page 16 on "Well Design and Geological Understanding of the Site". THERE IS AN IMPORTANT DIAGRAM ON THIS PAGE WHICH SHOWS THAT AT THE BRAMLEYMOOR LANE SITE THERE ARE 'WESTPHALIAN COAL MEASURES' ESPECIALLY AT 1,000 FEET BELOW GROUND. THEN AT 3,000 FEET AND BELOW THERE IS NAMURIAN BOWLAND SHALE. THE SHALE IS LIKELY TO BE RELATED TO WHAT INEOS ARE AFTER. BUT THIS COULD DISTURB THE COAL MEASURES NEAR THE SURFACE - ESPECIALLY IF LATER FRACKING RIGHTS WERE OBTAINED IN THE AREA. WHAT THEN OF SUBSIDENCE PROBLEMS?
Pages 17 shows boxes on "Drilling Fluids" and "Coring and Logging". Includes a section on "Environmental Protection Measures".
Pages 18 to 21 give tables with over 50 points on "Environmental Considerations and and Protection Measures". Page 20 (as Stage 3) being on the Maintenance of the Suspended Well Site. Page 21 giving "Features of Vertical Core Well" showing a photo of a large pool of water and a chart of the proposed well suspension.
Pages 21 to 22 give Environmental Considerations and Protection Measures, the Possible Workover of a Suspended Well and Use of the Well as a Listening Well.
Page 23 features a stage of the vertical corewell site (Although a photo is should show is missing at this stage)
Page 24 on "Abandonment (Decommissioning) and Restoration" leads to page 25 on aftercare, including a table with 8 points on "Environmental Protection Measures".
Pages 26 to 36 has 49 sections and contains 32 photos.
Page 33 has a table on "Summary of Traffic Movements via Vehicle Type".
Page 34 has a table on "The Breakdown of Total Traffic".
Page 35 has a table on the "Maximum Daily Traffic Movements" which it claims will average 240 per day drawn from (1) Site Construction - 266 movements (2) Drilling and Coring Suspension - 200 (3) Routine Maintenance (annual) - 96 (3a) Well Intervention/ Workover - if required 184 (4) Listening Well Operations - 174 (5) Decommissioning and Restoration - 281.
Page 36 is on Regulation and Internal Management, including working with the Coal Authority on its interaction with coal seams (There could be hope here that the depth of information the Coal Authority hold on (a) mine entrances, exits and other entry points called "adits" (b) on development high risk areas - two of them on the site INEOS wish to use, and (c) on a whole range of other information which can be discovered via this following link, can be used to destroy INEOS's case. -click here)
Page 36 Gives five sets of figures - (1) Site Development and Establishment, (2) Drilling and Coring, (3) Maintenance of Suspended Well Site Listening Well, (4) Use of Well as a Listening Well (5) Abandonment (Decommissioning) and Restoration.
Page 38, 39 and 40 contain six sideways photos - with boxes of information placed on them.
INEOS case can be overturned by the Derbyshire County Council, District Councils and individuals checking out their case and adding counter-information from the sources it often uses itself.
No comments:
Post a Comment