DISPOSAT OF PRODUCED WATER

AT EBBERSTON MOOR A WEIISITE

for
Third Energy UK Gas Limited
Knapton Generating Station
East Knapton
Malton
North Yorkshire
YO17 8JF
by
-I
II
JD
THIFlD
ENEfIGY
Envireau Water
North Office
646 Market Street
Whitworth
Lancashire
OL12 8LD
01332 87L882
01332 8748s0
north @envireauwater.co.uk
www.e nvirea uwater.co. u k
envrreau
WATR

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Ref: P\Third Energy Ebberston Moor (1484)\Reporting\Report v7.6.docx
December2013
DISPOSAT OF PRODUCED WATER
AT EBBBRSTON MOORA WELLSITE
Verslon 7.6
December2013
envrea Lt
WATCR

OEnvkeu tU.2013
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John Dewar
Director, Thlrd Energy UK Gas
Report recelved by:
03hzl20t3
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James Dodds MSc CGeol FGS
Managing Director, Envireau Water
Reportchecked by:
29ltu20t3 lil*;no
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PennyJenklnson MSc FGS
Senlor Hydrogeologist, Envireau Water
Dr Phll Ham MEng PhD MSEE
Princlpal Hydrogeologist, Envlreau Water
Report prepared by:
DISPOSAL OF PRODUCED WATER
AT EBBERSTON MOOR A WELTSITE
CONTENTS
Glossary
1 INTRODUCTION
1.1 Third Energy UK Gas.......
1.2 Ebberston Moor Fie|d...........
1.3 Gas Production and Injection of Produced Water
1.4 Proposed Disposal Method
1.5 Report Context...
2 REGULATORYCONTEXT...............
2.1 European Directives.................
2.2 English Regulation and Policy..
2.3 Defining Groundwater..............
2.4 Environment Agency Approach to Groundwater Protection..............
2.5 Drinking Water Protected Areas (DrWPAs)............
2.6 Oil & Conventional Gas Exploration and Extraction.....
2.7 Hazardous Substances..............
2.8 Non-Hazardous Substances
2.9 Exemption's under the Groundwater Daughter Directive (GWDD)......
2.10 Environmental Permitting Regulations
2.11Disposal of Production Water at the Ebberston Moor Field
2.12 Dialogue with the Environment Agency......
3 ENVIRONMENTALBASELINE
3.1 1ocation.......................
t
t
t
L
2
2
3
3
3
3
4
4
5
5
5
6
6
7
7
8
8
8
8
8
9
9
3.2 Hydrological Setting .......................
3.3 Geological Description....................
3.3.1 Regionalgeology
3.3.2 Local geo|ogy............
3.3.3 Geological structure........
3.4 Hydrogeological Description
3.4.1 Regional aquifer potential.....
3.4.2 Local aquifer potential .......
3.4.3 Sherwood Sandstone.........
10
LL
LL
t2
4 PROTECTEDRIGHTS.......
4.1 Licensed Abstractions................
4.2 Deregulated Licences
4.3 Private Water Supplies (<20m3lday) ...................
4.4 BGS Boreholes and Wells Database
4.5 Source Protection Zones
5 WATER
QUALITY.....
5.1 Polluting Substances..................
5.2 Associated (KAF) Water.........
5.3 Separation & lnjection Additives...............
5.4 lnjection Water......
5.5 Sherwood Sandstone Formation Water.........
5.5.2 Hydrocarbons......
5.5.3 Analysis Results
5.6 Sea Water Qua1ity................
5.7 Comparison of Water Types.....
6 DISPOSAL METHOD
6.1 Engineering Method
6.2 lnjection Pressures.:....................
6.3 lnjection Rates and Volumes.....
6.4 lnjection Water Composition and lnjection Additives.......................
7 CONCEPTUALMODEL.......
8 RISK ASSESSMENT
8.1 Assessment Methodology
8.1.1 Receptor Sensitivity................
8.1.2 Magnitude of lmpact........
8.1.3 Significance of Effect.....
8.2 Hazard |dentification......................
8.3 Receptor Sensitivity...
8.4 Magnitude of lmpact
8.5 Significance of Effect
8.5.1 Embedded Mitigation ...........
...t7
,,t4
..14
..15
..15
t4
t4
L7
L7
L7
18
19
19
2L
2L
23
23
25
25
25
25
25
26
27
27
27
28
29
29
30
30
30
31
31
8.5.2 Additional Mitigaton ............
9 ALTERNATIVETECHNOLOGIES
33
33
33
34
34
34
35
36
36
9.1 Best Available Technique .....
9.2 Technology Options
9.2.1 lnjection to Sherwood Sandstone Formation (Base Case)..........
9.2.2 lnjection to Production Formation (KAF) - Ebberston M
9.2.3 lnjection to sub Permian Strata - Ebberston Moor..........
9.2.4 lnjection to Production Formation (KAF)
-
Vale of Pickering
9.3 Scoring Matrix
10 JUSTIFICATION FOR INJECTION TO THE SHERWOOD SANDSTONE
TI SUMMARY & CONCLUSION
L2 8t811OGRApHy...................
FIGURES
....38
39
40
Figure 1
Figure 2
Fure 3
Fure 4
Figure 5
Fure 6
Figure 7
Figure 8
Figure 9
Figure 10
Figure 11
Figure 12
Figure 13
Ebberston Moor Field Location Plan
EB-A Site Setting
Regional Bedrock Geology
East-West Cross Section (a, b & c)
Northeast-Southwest Cross Section (a & b)
Licensed Surface Water and Groundwater Abstractions within 10km
Licensed Groundwater Abstractions within 70km
Deregulated Licences within 10km
Private Water Supplies within 10km
BGS Boreholes and Wellswithin 10km
Source Protection Zones within 70km
Sca rborough Source Protection Zone
Conceptual Hydrogeological Model
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
Table 12
Table 13
Table 14
Table 15
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
TABTES
RegionalGeology
Major Cations, Anions and General Chemistry of Produced Water
Diesel& Petrol Range Organics plus MineralOils
Cleethorpes No.1 Well Chemical Analysis
Major Cations, Anions and General Chemistry of Shenrood Sandstone Formation Water
Diesel & Petrol Range Organics plus Mineral Oils in the Sherwood Sandstone
Comparison of Produced, Formation and Sea Waters
Proposed lnjection Rates & Volumes
Receptor Sensitivity
Magnitude of lmpact
Significance of Effect
Source-Pathway-Receptor Linkage (lnjection of Produced Waterto Sherwood Sandstone)
lnjection of Produced Water- Risk Assessment Summary
Water Related Risks Associated with a Produced Water Pipeline
BAT Scoring Matrix
APPENDCES
Boundaries of Third Energy's Petroleum Licences
Environment Agency Meeting Minutes
Bedrock Geology beneath EB-A
Hazardous and Non-Hazardous Substances
'Resource Protection Values' List
lnjection Additives
lnjection Water Chemistry
Shenrood Sandstone Formation Water Chemistry
BAT
GLOSSARYOFTERMS
Best Available Technique
Best Available Technique Not Entailing Excessive Cost
British Geological Survey
Best Practicable Environmental Option
Department of Energy and Climate Change
Department for Environment, Food and RuralAffairs
Drinking Water Protected Areas
Ebberston Moor A well site
Environmental Protection Agency
Environmental Permitting Regulations
Environmental
Qua
lity Sta nda rds
Green Leaves lll
Groundwater Protection Principles and Practice
Groundwater Directive
Groundwater Da ughter Directive
Water Framework Directive
Joint Agencies Groundwater Directive Advisory Group
Permian Kirkham Abbey Limestone Formation
Knapton Generating Station
Scottish Environmental Protection Agency
Source Protection Zone
Total Dissolved Solids
United Kingdom Technical Advisory Group
World Health Organisation
BATNEEC
BGS
BPEO
DECC
DEFRA
DTWPA
EB-A
EPA
EPR
EQS
GL III
GP3
GWD
GWDD
WFD
JAGDAG
KAF
KGS
SEPA
sPz
TDS
UKTAG
WHO
Ref: P :\Third Energy Ebberston Moor (1484)\Reporting\Report v7.6.docx December2073
DISPOSAT OF PRODUCED WATER
AT EBBERSTON MOOR A WELLSITE
NON TECHNICAL SUMMARY
Third Energy UK Gas Limited (lhird Energr/') is a subsidiary of Third Energy, a private limited company with a head
office in London and an operations facility at Knapton Generating Station (KGS), within the Vale of Pickering, North Yorkshire.
At the present time, Third Energy holds interests in a total of six onshore Petroleum Licences granted by the Secretary of State
at the Department of Energy and Climate Change (DECC). The focus of this assessment is the 46km2 area of land covered by
Petroleum Licence P1077, known as the Ebberston Moor Field. The licence area s located approximately 12km north of
Knapton Generating Staton.
Gas production wells are free flowing as long as reservoir pressures are sufficient for the gas to flow to surface and rates
high enough to lift any produced water (the water produced from the well with the gas). ln the case of Third Energ/s historc
operations in the Vale of Pickering, produced water is separated at surface and injected back into the production formation
(the Permian Kirkham Abbey Limestone Formation
[KAF])
via a dedicated injection well. Experience shows that this initially
provides an appropriate disposal route for produced water but over a period of a few years, results in 'watering offl of
production wells and poor overall rates of gas recovery. DECC requires petroleum licence holders to maximise economic
recovery of oil and gas. ln order to achieve higher rates of recovery and maximise the long-term commercial viability of the
Ebberston Moor Field, Third Energy must therefore explore other methods of disposing of produced water.
Ths report considers the option for disposing of produced water through injection into the Triassic Sheruood Sandstone
geological formation that overlies the KAF. Both reservoirs contain very similar and very saline water. Disposal of produced
water to the Sherwood Sandstone geological formation will facilitate a much higher rate of gas recovery from the Ebberston
Moor Field and, on account of the geology at Ebberston Moor, will not present any discernible risk or impact on the quality of
the Sherwood Sandstone formation water or any other potential receptors.
This report has been designed to support an application to discharge to groundwater under the Environmental
Permitting Regulations 2010 and should be read and considered within that context. This report presents:
,/
An overview of the relevant legislation and UK regulation
/
A detailed, technical appraisal of the geology and hydrogeology beneath the Ebberston Moor Field
,/
A comprehensive risk assessment for the proposed method of disposal, conducted in accordance with the
approach set out in DEFRA's Green Leaves lll (Gt lll)
r'
A robust
justification
for the alternative method of disposal, based on the principles of Best Practicable
Environmental Option (BeEO) and Best Available Technique (BAT)
A detailed review of the regulatory context of this application has been undertaken and discussed at length with the
Environment Agency. The review demonstrates that under European and English law and regulation that the proposed
discharge can be permitted if:
'/ The receiving water is permanently unsuitable and has no resource value
r'
The discharge lies within the policy described by the Environment Agency in Groundwater Protection
Principles and Practice (GP3)
/
The discharge represents BAT
/
The discharge meets the requirements of the Water Framework Directive and Groundwater Daughter
Directive
This report concludes that the regulatory requirements are met.
North Office, 646 Market Street
Whtworth, Lancashire, OL12 8LD
t 01332 871882
f 01332 871850
e info@envireauwater.co.uk
w www.envireauwater.co.uk
e nv rea u
WATR
ErMeu Ltd. ReSlstercd ln ErEhnd & Walos No.6647619
Regstoed offc: daF 8m Fam, Martot Stmt, oEy@tt, Ded/shlrc, DF/2 3N8, UK

DISPOSAL OF PRODUCED WATER

AT EBBERSTON MOORA WELLSITE
NONTECHNICALSUMMARY
It is criticalfrom a technical point of view that any injection does not pose a risk to the environment and other beneficial
users of the water system. To this end, a detailed technical assessinent has been undertaken based on published and peer
reviewed documents as well as data from independent nstitutions and field sampling which has examined the following:
,/
The geographical, hydrological, geological and hydrogeological setting
/
Examination of protected water rights within a 70km radius of Ebberston Moor A site
,/
Examination of the quality of the formation water within the KAF and the Sherwood Sandstone formation
both by analysis of samples and with reference to published information
,/
Examination of proposed additives
r'
Comparison of injection water with sea water
,/
Review of the injection method, rates and volumes
The technical assessment has been drawn together into a conceptual model which is presented in Figure A and can be
summarised as follows:
There are four hydrostratigraphic units
-
namely:
o The geology above the Oxford Clay (Layer 1)
o The geology from the base of the Mercia Mudstone to the Oxford Clay (Layer 2)
o The Triassic Sherwood Sandstone (Layer 3)
o The Zechstein (Permian)/ Carboniferous (Layer 4)
o The lateral variation in geology, is controlled by dip and east-west faultng.
o
Natural recharge to the Sherwood Sandstone formation is limited to the outcrop and subcrop areas in Vale of
York
/
Mowbray. Recharge to the geology above the Oxford Clay is limited to the outcrop on the North
Yorkshire Moors.
o Hydraulic properties ofthe layers have been defned by literature search, but broadly Layer 1 can be taken as
having useful hydraulic conductivity and storage; Layer 2 is poorly permeable (very low hydraulic conductivity)
and has limited useful storage; Layer 3 has useful hydraulic conductivity and storage; and Layer 4 has limited
hydraulic conductivity and storagg and poorly permeable clay and mudstone horizons effectively hydraulically
separate the Permian (Layer 4) from the overlying Triassic water bearing formation.
o
Differences in water quality between the water bearing formations has been defined by literature search and
confirmed in the case of Layer 3 &
4
from sampling and analysis.
o The change in salinity of the formation water in the Sherwood Sandstone is illustrated by an arbitrary line on
Figure B. This line denotes a change from what we describe as groundwater to formation water. The line has
been located based on the literature search and can be conceptualised as an isochlor (a line of equal salinity
lor
more accurately chloride concentrationl).
When combined, the various aspects of the conceptual model produce a system with no transfer of water vertically
between the permeable Layers 1 and 3, either upward or downward. This is achieved by the low permeability and thickness
of Layer 2 and low vertical hydraulic conductivity of Layer 4. The effectiveness of the hydraulic separation is demonstrated by
the marked difference in water quality between Layers 1 and 3, where the Sherwood Sandstone is at great depth.
The quality of the Shenrood Sandstone formation water at depth demonstrates that circulation of recharge into the
formation is limited to near the outcrop/subcrop areas, with very little deep circulation occurring. Evidence published in the
literature from isotope and ionic ratio analysis indcates that the NaCl in the sandstone water s mineral rather than sea water
based. The significant down dip distance of the EB-A site effectively isolates it volumetrically from the aquifer zone.
Comparison of the North Sea salinity with the main constituents of the produced and formation waters shows that the
KAF water is approximately two times more saline than the Sherwood Sandstone formation water, owing to a higher
concentration of sodium chloride. However, this is within the context of both the KAF water and Shenood Sandstone
formation water having totat dssolved solids concentration (TDS) in excess of 180,000mg/1. Both waters show significant
amounts of naturally occurring hydrocarbons, with the produced water from the KAF showing more, as would be expected.
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Page ii of iv
DISPOSAL OF PRODUCED WATER
AT EBBERSTON MOOR A WELLSITE
NONTECHNICALSUMMARY
The produced water and Shentrood Sandstone formation water are 10 and 5 times more saline than the North Sea,
respectvely. The salinity of the Shenvood Sandstone formation water means that is has no resource value.
The conceptual model has been used as the basis of a risk assessment for the proposed disposal of produced waters to
the Sherwood Sandstone at Ebberston Moor; prepared in accordance with the DEFRA GL lll methodology. The risk
assessment has covered:
r'
Hazard ldentification
./
Source
-
Pathway
-
Receptor linkage analysis
/
Consequence- Likelihood
-
Risk analysis
/
Mtigation analysis
The analysis shows that while the consequence of contamination would be high, the likelihood and therefore the risk of
occurrence is very low. The likelihood of occurrence is low because:
injection and the nearest groundwater supplies.
formation provides potable water is in excess of 40km. 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 in the region of lkm, with pressure effects limited to less than 5.2km.
Therefore the only plausible risk of contamination of water supplies would relate to inadequate construction of the
injection well. ln accordance with best practice, a number of mitigation measures will be taken to minimise the operational
(construction) risks associated with the disposal of produced waters to the Sherwood Sandstone formation. These will be
based on The Offshore lnstallations and Wells (Design and Construction, etc.) Regulations 1996 to ensure that the well is
designed, modified, constructed, commissioned, operated and abandoned; such that there is no unplanned escape of fluids
from the well and that the risks to the health and safety of person from it or anything in it, or in strata to which it is connected,
are as low as is reasonably practicable. This will be confirmed in writing by an independent competent person before the well
is commenced, to ensure that the well is designed and constructed properly and is maintained adequately. These regulations
ensure that the well is designed and planned to the highest standards. ln addition, 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. Based on
the application of these mtigation methods, the residual risk associated with the proposed injection of produced water to the
Sherwood Sandstone is negligible.
Alternative disposal technologies have been examined, including; installing an injection well at Ebberston Moor to target
the KAF; installing an injection well at Ebberston Moor to target the Carboniferous strata below the KAF; nstalling a produced
water transfer pipeline to transport produced water back to KGS, from where it would be transported out to the existing
injection well in the Vale of Pickering. The frst option is currently undertaken in the Vale of Pickering and leads to 'watering
offl of the gas production well. This significantly reduces the recovry efficiency to a point where gas extraction is not viable.
The second option involves injection of the formation water nto low permeability strata, requiring much higher pressures to
achieve the injection rates required. This increases the risk of hydraulic breakthrough to the overlying strata, resulting in
'watering offl. The third option involves overground transfer of the production water. lt is considered that this option results
in an environmental risk to shallow groundwater systems that are not easily or cost effectively mitgated, due to the risk of
leakage of highly saline brine. This compares to the proposed solution which poses negligible risk; with surface pipework of
limited len4h and which is easily monitored and serviced and any leaks easily identified and contained.
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Page iii of iv
DTSPOSAL OF PRODUCED WATER
AT EBBERSTON MOOR A WELT,SITE
NONTECHNICALSUMMARY
tn summary and based on the technical work and risk assessments, the alternative methods of water disposal will:
o Reduce productivity and the rates ofgas recovery
o Limit the commercial viability of gas producton from the bberston Moor Field
o lntroduce significant environmental risk
By comparison, the proposed method of water disposal by injection to the Sherwood Sandstone formation will:
o Maximise productivity and the rates of gas recovery
o
Maximise the commercial viability of gas production from the Ebberston Moor Field
o Minimise environmental risk to shallow groundwater, most significantly because there is no requirement for a
surface pipeline to transfer saline formation water
It s therefore considel:ed that in this particular case, the disposal of produced water to the Sherwood Sandstone formation
represents both BAT and BPEO.
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Page v of iv
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v7.6.docx
December 2073
DISPOSAT OF PRODUCED WATER
AT EBBERSTON MOORA WETLSITE
1. INTRODUCTION
l.l ThirdEnergrUKGas
Third Energy UK Gas Limited ('Third Energy'') is a subsidiary of Third Energy, a private limited company with a
head office in London and an operations facility at Knapton Generating Station (KGS), North
yorkshire.
Third
Energy operates gas fields within the Ryedale Valley in the Vale of Pickering on the western side of the North
york
Moors; from which gas is piped back to KGS and used to generate electricity.
At the present time, Third Energy holds interests in a total of six onshore
petroleum
Licences granted by the
secretary of state at the Department of Energy and climate change (DEcc). under the
petroleum
Licensing
system this grants Third Energy the exclusive right to 'seorch, bore ond get petroleum within the licence
boundory'. The boundaries of Third Energy's petroleum licences are presented
as Appendix A.
1,2 Ebberston Moor Field
The focus of this assessment is the 46km2 area of land covered by Petroleum Licence
pLo77,
known as the
Ebberston Moor Field. The field is located approximately 12km north of KGS (see Figure 1).
The Ebberston Moor Field (previously
known as Lockton) was discovered by Home Oil Canada in 1966 and
production began in 1971. However, production
ceased after only two years due to the production of large
volumes of produced
water and the problems relating to the injection of this produced
water back to the
production
formation.
ln 1980, Taylor Woodrow Energy acquired additional seismic data in an attempt to better understand the
structural geology of the field. Exploratory drilling targeted the Permian Kirkham Abbey carbonate reservoir in an
east-trendng structural high and results were encouraging. Several appraisal wells were subsequently drilled to
prove the reserve.
Third Energy acquired the Ebberston Moor Field in 2003 and intends to develop the known gas reserves within
the Kirkham Abbey Formation for production
of electricity at KGS. The success of the venture is dependent on the
successful disposal of produced water.
1.3 Gas Production and Iniection of
produced
Water
Gas production wells are free flowing as long as reservoir pressures are sufficient for the gas to flow to surface
and rates high enugh to lift any produced water up the production well. The rate of production
will depend on a
number of factors including the properties
of the reservoir formation, reservoir pressure, and the volume of
produced
water.
North Offce, 646 Market Street
Whitworth, Lancashirg OL12 8LD
t 01332 871882
f 01332 8748s0
e info@envireauwater,co.uk
w www.envireauwater,co,uk
envirea u
WATCR
ENircau Ltd. Registrud ln Eqland & Was No.6e7619
R3sbteEdofoe: ceda6 8am Fam, MarktStrct, DGytot Drl/shl, DF/2 3NB, Ul(
0
Envireau llater
ln the case of Third Energy's historic operatons in the Vale of Pickering, produced water is separated at surface
and injected back to the production formation via a dedicated injection well. Experience shows that this initially
provides an appropriate disposal route for produced water but over a period of a few years, results in 'watering
off of production wells and poor overall rates of gas recovery (around 30%).
DECC requires petroleum licence holders to maximise economic recovery of oil and gas. ln orderto achieve higher
rates of recovery and maximise the long-term commercial viability of the Ebberston Moor Field, Third Energy
must therefore explore other methods of stimulating gas production and disposing of produced water.
L.4 Proposed Disposal Method
This report considers the option for disposing of produced water through injection into the Triassic Sherwood
Sandstone geological formation that overlies the Permian Kirkham Abbey Limestone Formation (KAF). Both
reservoirs contain very similar and very saline water; water which is more saline than seawater. Disposal of
produced water to the Sherwood Sandstone formation will facilitate a much higher rate of gas recovery from the
KAF (up to70o/oor more) and, on account of the naturalgeological setting at Ebberston Moor, will not present any
discernible risk or impact to any other potential receptors.
1.5 ReportContext
This report presents:
.A detailed overview of the relevant legislation and UK regulation governing disposal of produced water from
onshore oil and gas production, within the context of the proposal to dispose of produced water from the
KAF to the Sherwood Sandstone geologicalformation.
A detailed, technical appraisal of the geology beneath the Ebberston Moor Field and the quality of the
relevant water bearing formations.
A comprehensive risk assessment for the proposed method of disposal, conducted in accordance with the
approach set out in DEFRA's Green Leaves lll (GL lll) and the methodology presented in the Environment
Agency's Hl Environmental Risk Assessment framework
-
Annex J (Groundwater).
A robust
justification
for the alternative method of disposal, based on the principles of Best Avaifable
Technique (BAT) a nd Best Practicable Environmenta I Option (BPEO).
a
o
a
a
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Rev: 10/022014 2:45 PM
Page 2 of4l
Envireau llater
2 REGUIITTORY CONTEXT
The Environment Agency regulates the disposal of produced water produced from onshore gas exploration and
extraction in England and Wales; where produced water is discharged to the environment.
It is worth noting that this is different to the disposal of produced water in the offshore industry which is
regulated by DECC under The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations
2005 (as amended 2OLLl.ln the offshore industry there are a number of options for disposing of produced
water
and water is not always injected back to the production formation.
2,1 EuropeanDirectives
All discharges, disposals or other existing activities that release listed substances to groundwater are subject to
controls under the European Water Framework Directive (200O/6O{EC) (WFD), Groundwater Daughter Directive
(2006
/
LL8,
I
EC) (GWDD) a nd the 1980 G ro u ndwater Di rective (S0/6S/E EC) (GWD).
The requirements of the GWD are similar in principle to the 'prevent and limit requirements'of the WFD/GWDD.
The GWD will be repealed in December 20L3 and until then as far as possible the requirements of the
WFD/GWDD and the GWD have to be considered in parallel. Even when the GWD is repealed, Article 4 of the
WFD requires that at least the same level of protection is provided.
2.2 English Regulation and Policy
The regulations and policy relevant to the proposed disposal of produced water to the Shenrood Sandstone
formation are:
Environmenta I Permitting Regulations ( EPR), 2010
Groundwater Protection: Principles and Practice (GP3)
a
a
The impacts of the regulations on the disposal are discussed in detail in the following sections.
2.3 DefiningGroundwater
Groundwater is defined in the WFD and GP3 as "all water which is below the surface of the ground in the
saturation zone and in direct contact with the ground or subsoil". By this definition, a groundwater body is any
formation that contains groundwater, regardless of resource value.
The United Kingdom Technical Advisory Group (UKTAG) on the WFD is a partnership of UK environment and
conservation agencies, and was set up to interpret and support the implementation of the WFD. UlfiAG have
issued a guidance paper entitled 'Defining & Reporting on Groundwater Bodies', which states that where water
exists in formations at extreme depth and is permanently unsuitable for use as a resource, e.g. where salinity is
greater than seawater, it should not be considered as a groundwater body and is considered to have no resource
value. UKTAG have also defined 400m as a default depth value beyond which groundwater loses its resource
value, although actual resource boundaries should be amended where local hydrogeological and hydrochemical
information is available.
The same UKIAG guidanie paper also states that
ore
water in low permeability deposits do not represent
groundwater as a receptor because they do not provide a useful water resource and travel times through these
deposits are extremely low. Similarly, in a separate guidance paper entitled 'Application of Groundwater
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Standards to Regulation', UKTAG states that pore water in low permeabil'rty deposits should not be considered
groundwater and cites that the properties and the function of low permeability materials are recognised in
existing European Legislation, for example the Landfill Directive where low permeability materials can be used as
geological barriers to support engineering measures for groundwater protecton.
The development of the definition of groundwater within the context of the WFD and GWDD has been discussed
with a UK member on the GWDD drafting panel. lt is clear from these discussions that in the considerations
during drafting the issues associated with deep, saline formation water were never considered. The definition
was not deliberately developed to encapsulate these formation brines and as they were not considered, they
were not actively excluded either. The consideration of groundwater was within the context of what would
reasonably, practically and pragmatically be considered to be "easily exploitable groundwate/', that is water that
would normally be exploited for wholesome or industrial use, within practical engineering reach of the surface
and which would require no or only modest amounts of treatment. This is consistent with the approach adopted
by UKI'AG.
2.4 EnvironmentAgencyApproachto Groundwater Protecton
GP3 sets out the Environment Agenqy's approach to the protection and management of groundwater in England
and Wales; based on the requirements of the WFD and GWDD.
The Environment Agenqy's aim is to "prevent and limif' pollution of groundwater. The priority is to protect water
supplies intended for human consumption as well as ensure protection of groundwater quality that supplies
dependent ecosystems
[GP3,
p. 19]. The Environment Agency applies a general level of protection for all drinking
water sources through the use of source protection zones (SPZs), which focuses control beyond the general
groundwater protection measures applied to aquifers as a whole. Where there is uncertainty about the
consequences of certain actions and the potential for serious or irreversible harm to groundwater, then the
Environment Agency will adopt a precautionary principle.
The Environment Agenqy's approach to managing and protecting groundwater is set out through a number of
position statements in GP3, which provide a framework for Environment Agency staff to make decisions, though
still enabling them to use local information to be flexible in meeting the needs of the local environment and
communities
[GP3,
p. 52].
2.5 Drinking Water Protected Areas (DrWPAs)
Article 7.1of the WFD requires member states to identifo:
all bodies of water used for the abstraction of water intended for human consumption providing more than
10m3 a day as an average or serving more than 50 persons; and
o
a those bodies of water intended for such future use
The Environment Agency refers to such bodies as drinking water protected areas (DrWPAs) and has classified all
groundwater bodies in England and Wales as DrWPAs, on account of the low abstraction thresholds set out in the
WFD
[GP3,
p.56].
Article 7.3 of the WFD requires member states to ensure the necessary protecton for DTWPAs with the aim of
avoiding deterioration in their quality in order to reduce the level of purification treatment required in the
production of drinking water.
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The compliance point for Article 7.3 is at the point of abstraction, which means that applying protection measures
equally over the entire land area of the DrWPA is not necessary to meet this objective
[GP3,
p. 56].
2,6 Oil & Conventional Gas Exploration and Extraction
The Environment Agenqy's position statement for oil and conventional gas exploration and extraction
[GP3,
p. 66]
is to:
object to hydrocarbon exploration, extraction infrastructure or activity within SPZI. Outside SPZ1, the
Environment Agency will object to an activity that would have an unacceptable effect on groundwater;
expect BAT to be applied where any associated drilling or operation of the boreholes passes through a
groundwater resource. Elsewhere, established good practice for pollution prevention should be applied; and
o
where such activities already exist, work with operators to assess and if necessary mitigate the risks.
Article 11.3) of the WFD places a prohibition of direct discharges of pollutants into groundwater. Subject to
appropriate conditions, Member States may authorise injection of water containing substances resulting from the
operations for exploration and extraction of hydrocarbons or mining activitieg and injection of water for technical
reasons, into geological formations from which hydrocarbons or other substances have been extracted or into
geologicalformations which for natural reasons are permanently unsuitable for other purposes.
2,7 HazardousSubstances
The WFD defines hazardous substances as substances or groups of substances that are toxiq persistent and liable
to bio-accumulate, and other substances or groups of substances which give rise to an equivalent level of
concern.
Article 6(1) of the GWDD requires Member States to implement measures necessary to prevent hazardous
substances from entering groundwater; and limit inputs of non-hazardous substances into groundwater so as to
ensure that such inputs do not cause deterioration
[in
status] or sigificant and sustained upward trends in the
concentration of pollutants in groundwater.
The WFD/GWDD requirement to prevent the entry of hazardous substances is very similar to the requirement to
prevent the entry of List I substances under the GWD. Member States are required to determine which
substances are hazardous and this task is undertaken by the agencies in the U( whose decisions are peer
reviewed and confirmed by the Joint Agencies Groundwater Directive Advisory Group (JAGDAG) but may be
overridden by Ministerial Direction or decision on a permit appeal. JAGDAG was originally set up to consider
substance determination under the GWD.
Though not explicit in Article 6.1 of the GWDD, the rest of the directive makes it clear that the 'limit' requirement
should be implemented so as to prevent pollution, which is necessary to maintain the existing level of protection
afforded by GWD when it is repealed in December 2013.
2.8 Non-HazardousSubstances
The WFD only defines hazardous substances. Although Annex Vlll of the WFD highlights groups of Main
Pollutants, the GWDD makes it clear that all other pollutants come within the scope of the 'limit' objective. This
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brings substances that are unlisted and therefore excluded from control under the GWD into the scope of the
WFD/GWDD
2,9 Exemption's under the Groundwater Daughter Directive (GWDD)
Article 6.1 of the GWDD sets out a programme of measures that Member States must carry out to protect
groundwater quality; through preventing or limiting inputs of hazardous and non-hazardous substances into
groundwater.
The GWDD requires that Member States take all measures necessary to prevent inputs of hazardous substances
into groundwater, subject to the exemptions noted in Article 6.3.
Article 6.3(b) gives Member states the ability to exempt from these measures, inputs of pollutants that are
considered by the competent authorities to be of a quantity and concentration so small as to obviate any present
or future danger of deterioration in the quality of the receiving groundwater.
Article 6.3(e)(i), enables competent authorities to exempt from the requirement to take all measures to prevent
or limi inputs that are technically feasible but would result in increased risks to human health or the quality of
the environment as a whole. This enables a degree of balancing of risks between groundwater and the wider
environment. However, the agencies would not apply any lesser degree of protection to groundwater than to
other environmental media. The timescales over which impacts may occur and over which risks are assessed
would be a particular concern for groundwater.
2.10 Environmental PermittingRegulations
Environmental legislation in England and Wales is implemented through the Environmental Permitting
Regulations (EPR) 2010, which effectively apply the relevant Directives "as is" and without further interpretation.
The Directives therefore remain as the fundamental source material.
Under EPR 2010 the Environment Agency may grant a permit for the injection of water containing hazardous
substances from hydrocarbon activities where strata have been determined as permanently unsuitable
[GP3,
p. 1611. The following should be considered over the timescale over which the injection will have an effect:
o
the impact of the inection on existing or potential use of ground (mineral and agricultural) resources;
o
the hydraulic properties of the rock strata;
o
the quality of any receiving groundwater.
The geologicalformation must be examined before being deemed permanently unsuitable and EPR 2010 states
that this must be due to reasons of natural geology and groundwater conditions. The Environment Agency states
the only applicable situations
[GP3,
p. 162] are likely to be:
.
vry deep, isolated permeable strata (such as former oil bearing strata kilometres below the surface);
.
very low permeability environments;and
o certain isolated lnses with minimal resource value.
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lf groundwater
can be yielded from such environments but would still be unsuitable for use even after intense
physical
and chemical treatment using BAT, the geological formation may be a candidate for permanently
unsuitable status, provided there are no other conceivable uses, e.g. industrial cooling, managed aquifer recharge
[GP3,
p.163].
ln making an application for an environmental permi! GP3 asks applicants to consider a number of factors and
produce a risk assessment n accordance with the principles set out in Green Leaves lll. An assessment of resource
value of the geological formation and the degree of isolation from the soil zone or vegetation is also required.
2.11 Disposal of Production Water atthe Ebber$on Moor Field
The Triassic Shenruood Sandstone formation beneath the Ebberston Moor Field is considered to be permanently
unsuitable as defined by UKI'AG and EPR 201Q on account of the natural geology and prevailing groundwater
conditions. A detailed, technical appraisal is provided in Section 3.
Any water, regardless of its quality, can be treated to an acceptable standard for human consumption. The
formation water contained in the Sherwood Sandstone formaton at the Ebberston Moor Field is of such poor
quality (it is more saline that seawater) that it would require ntense physical
treatment using BAT to make it fit
for human consumption. ln practice,
treating the formation water to this standard would be financially prohibitive
as easier and cheaper sources
-
including water from the North Sea
-
are more accessible.
As shown in Section 5, injecting produced water from gas operations will have no discernible impact to the
existing quality of the Sherwood Sandstone formation water at this location. Even though the prospect
of this
formation water being exploited at any point in the future is unlikely, the proposed disposal of produced water
will not impact any future ability to treat the formation water for human consumption or utilise it for any other
conceivable use. The proposed disposal of produced water can therefore be exempted under Article 6.3(b) of the
GWDD.
Similarly, the proposed disposal method will not present a risk to any groundwater
bodies or indeed ground or
surface water supplies used for human consumption, or other environmentally sensitive features. A risk
assessment is presented in Section 8.
lnjection to the Sherwood Sandstone represents the BPEO and BAT n terms of disposal of produced water from
Ebberston Moor, as demonstrated in Section 9 and
justified
in Section 10.
z.LZ Dialogue with the EnvironmentAgency
The proposed disposal of produced water to the Sherwood Sandstone at this location has been discussed with the
Environment Agency at both a national (polcy)
and local (technical) level. The minutes of the discussions are
included in Appendix B.
The discussions with the Environment Agency have shown that there is scope within national policy to dispose of
produced water into the Sherwood Sandstone formation at Ebberston Moor, subject to an appropriate level of
ssessment and
justification
being provided to support the permttng process.
The discussions with the Environment Agency have determned the scope of the technical work required to
establish an environmental baseline, carry out an appropiiate hydrogeological risk assessment, and provide a
justification
for the proposed disposal; all of which are presented in the following sections of this report.
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