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Cuadrilla Bowland Ltd
Temporary Shale Gas Exploration
Preston New Road, Lancashire
Environmental Statement
Appendix F – Air Quality
PNR_ES_Vol2_Appndx F – Air Quality
May 2014
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Contents
F1 EPUK Significance Criteria 1
F2 Construction Dust Methodology 4
F3 On site generators 7
F4 Input calculations for ADMS 5 8
F5 Assessment of Radon (Studsvik) 10
F6 Dust Mitigation Measures 11
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F1 EPUK Significance Criteria
Table 1 EPUK Classification of Magnitude of Change
Magnitude of
Change
Change in NO2 Annual Mean
Concentrations (µg/m3)
Large > 4.0
Medium 2.0 – 4.0
Small 0.4 – 2.0
Imperceptible < 0.4
Table 2 EPUK Impact Descriptors for NO2 Annual Mean Concentrations
Absolute Concentration in
Relation to Objective/Limit
Value
Magnitude of Change (change in NO2 annual mean
concentrations)
Small Medium Large
Increase with Scheme
Above Objective/Limit Value
with Scheme (40 µg/m3)
Slight Adverse Moderate
Adverse
Substantial
Adverse
Just Below Objective/Limit
Value with Scheme
(36 - 40 µg/m3)
Slight Adverse Moderate
Adverse
Moderate
Adverse
Below Objective/Limit Value
with Scheme (30 - 36 µg/m3)
Negligible Slight Adverse Slight Adverse
Well Below Objective/Limit
Value with Scheme
(<30 µg/m3)
Negligible Negligible Slight Adverse
Decrease with Scheme
Above Objective/Limit Value
without Scheme (40 µg/m3)
Slight
Beneficial
Moderate
Beneficial
Substantial
Beneficial
Just Below Objective/Limit
Value without Scheme
(36 - 40 µg/m3)
Slight
Beneficial
Moderate
Beneficial
Moderate
Beneficial
Below Objective/Limit Value
without Scheme
(30 - 36 µg/m3)
Negligible Slight Beneficial Slight Beneficial
Well Below Objective/Limit
Value without Scheme
(<30 µg/m3)
Negligible Negligible Slight Beneficial
Table 3 EPUK Factors to Judge Significance
Number of people affected by slight, moderate or major air quality impacts and a
judgment on the overall balance.
Where new exposure is being introduced into an existing area of poor air quality,
then the number of people exposed to levels above the objective or limit value
will be relevant.
The magnitudes of the changes and the descriptions of the impacts at the
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receptors.
Whether or not an exceedance of an objective or limit value is predicted to arise
in the study area, where none existed before, or an exceedance area is
substantially increased.
Whether or not the study area exceeds an objective or limit value and this
exceedance is removed, or the exceedance area is reduced.
Uncertainty, including the extent to which worst case assumptions have been
made.
The extent to which an objective or limit value is exceeded; eg. an annual mean
NO2 of 41μg/m3 should attract less significance than an annual mean of 51μg/m
3.
Figure 1 EPUK Flowchart
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F1.1 Planning Policy Guidance Flowchart
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F2 Construction Dust Methodology
Figure 2 Categorisation of Dust Emission Classes
Dust Emission Magnitude
Small Medium Large
Demolition
• total building volume
<20,000m3
• construction material
with low potential for
dust release (e.g. metal
cladding or timber)
• demolition activities
<10m above ground,
demolition during wetter
months
• total building volume
20,000m3 - 50,000m
3
• potentially dusty
construction material
• demolition activities
10-20m above ground
level
• total building volume
>50,000m3
• potentially dusty
construction material (e.g.
concrete)
• on-site crushing and
screening, demolition
activities >20m above
ground level
Earthworks
• total site area <2,500m2,
soil type with large grain
size (e.g. sand)
• <5 heavy earth moving
vehicles active at any one
time
• formation of bunds <4m
in height
• total material moved
<20,000 tonnes
• earthworks during wetter
months
• total site area
2,500m2 - 10,000m
2,
moderately dusty soil
type (e.g. silt)
• 5-10 heavy earth moving
vehicles active at any one
time
• formation of bunds
4m - 8m in height
• total material moved
20,000 - 100,000 tonnes
• total site area >10,000m2
potentially dusty soil type
(e.g. clay, which will be
prone to suspension when
dry due to small particle
size)
• >10 heavy earth moving
vehicles active at any one
time
• formation of bunds >8m
in height
• total material moved
>100,000 tonnes
Construction
• total building volume
<25,000 m3
• construction material
with low potential for
dust release (e.g. metal
cladding or timber)
• total building volume
25,000m3 - 100,000m
3
• potentially dusty
construction material (e.g.
concrete)
• piling
• on-site concrete batching
• total building volume
>100,000m3
• piling
• on-site concrete batching
• sandblasting
Trackout
• <10 HDV (>3.5t) trips in
any one day
• surface material with low
potential for dust release
• unpaved road length
<50m
• 10-50 HDV (>3.5t) trips
in any one day
• moderately dusty surface
material (e.g. high clay
content)
• unpaved road length 50m
– 100m;
• >50 HDV (>3.5t) trips in
any one day
• potentially dusty surface
material (e.g. high clay
content)
• unpaved road length
>100m
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Figure 3 Examples of Factors Defining Sensitivity of an Area
Sensitivity of
Surrounding
Area
Examples
Sensitivity of People to Dust
Soiling Effects
Sensitivities of People to the
Health Effects of PM10
Low
Enjoyment of amenity would
not reasonably be expected;
There is property that would not
reasonably be expected to be
diminished in appearance,
aesthetics or values by soiling;
There is transient exposure,
where the people or property
would reasonably be expected to
be present only for limited
periods of time as part of the
normal pattern of use of the
land;
Indicative examples include
playing fields, farmland (unless
commercially sensitive
horticulture), footpaths, short
term car parks and roads.
Locations where human exposure
is transient;
Indicative examples public
footpaths, playing fields, parks
and shopping streets.
Medium
Users would expect to enjoy a
reasonably level of amenity, but
would not reasonably expect to
enjoy the same levels of amenity
as in their home;
The appearance, aesthetics or
value of their property could be
diminished by soiling;
Indicative examples include
parks and places of work.
Locations where people exposed
are workers, and exposure is over
a time period relevant to the air
quality objective for PM10 (in the
case of the 24-hour objectives a
relevant locations would be one
where individuals may be
exposed for eight hours or more
in a day);
Indicative examples may include
offices and shops, but will
generally not include workers
occupationally exposed to PM10
as potential is covered by Health
and Safety at Work legislation.
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High
Users can reasonably expect a
enjoyment of a high level of
amenity
the appearance, aesthetics or
values of their property would
be diminished by soiling; and
the people or property would
reasonably be expected to be
present continuously, or at least
regularly for extended periods
as part of the normal pattern of
use of the land;
Indicative examples include
dwellings, museum and other
culturally important collections,
medium and long term car
parks and car showrooms.
Locations where members of the
public are exposed over a time
period relevant to the air quality
objective for PM10 (in the case of
the 24-hour objectives a relevant
locations would be one where
individuals may be exposed for
eight hours or more in a day);
Indicative examples include
residential properties. Hospitals
and schools and residential care
homes should also be considered
as having equal sensitivity to
residential areas.
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F3 On site generators
There are a number of small generators used on the site as part of the various
processes. A summary table is provided for the use of these below. Assessment
of generators has been scoped out of this assessment; details of this are in the
main air quality chapter.
Activity Generators Active time
Drilling 3 x Pramac GCW1500-50L, Diesel Engines, MTU 12V4000G23 3B
24hrs during drilling
Hydraulic Fracturing
1 x Twin Caterpillar C-13 520 bhp engines <12hrs
6 x Caterpillar 3512C 2,500 bhp engines <12hrs
1x Caterpillar C-13 520 bhp engine 24hr during hydraulic fracturing
Other processes 1x Perkins 1104CTA diesel engine <12hrs
2x Caterpillar C-9 350 bhp engines <12hrs
1x Caterpillar C-13 520 bhp engine <12hrs
1x Caterpillar C-13 bhp engine <12hrs
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F4 Input calculations for ADMS 5
The calculations of the flare properties and flare data are provided below.
Table 4 Stack properties
Flare diameter 3 m
Flare height 10 m
Area of Source 7.065 m
Exhaust Temperature 1000 C
Exit Velocity 6.9 m/s
Nitrogen oxides emission rate 7.6 g/s
Benzene emission rate 0.019 g/s
F4.1 Post Processing
In order to predict nitrogen dioxide concentrations from the predicted nitrogen oxides concentrations, the worst-case approach recommended by the Environment Agency
1 was used. This assumes that:
Annual mean nitrogen dioxide concentrations = Annual mean nitrogen oxides x 0.7; and
99.79th
percentile of 1 hour mean nitrogen dioxide concentrations = 99.79th
percentiles of 1 hour mean nitrogen oxides x 0.35.
In practice, these ratios represent conditions some distance away from a release source. Close to a source, the quotient of nitrogen dioxide in nitrogen oxides is typically much lower than this. Applying these ratios thus provides a worst case assessment.
Deposition has not been included in the dispersion model because the principle component of concern is nitrogen dioxide, which is calculated from nitrogen oxides outside of the model. Deposition has been calculated by multiplying the predicted ambient concentrations by a deposition velocity. Deposition velocities are expressed in units of m/s. A concentration of µg/m
3 multiplied by a deposition
velocity in m/s results in a flux of µg/m2/s. This has then been scaled to kg/ha/yr.
The deposition velocity used for this assessment were:
Grassland - 0.0015 m/s
Woodland – 0.003 m/s
1
http://www.environmentagency.gov.uk/static/documents/Conversion_ratios_for__NOx_and_NO2
_.pdf
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Wet deposition has been discounted. Wet deposition of nitrogen oxides this close to the emission source would be restricted to wash-out, or below cloud scavenging. For this to occur, rain droplets must come into contact with the gas molecules before they hit the ground. Falling raindrops displace the air around them, effectively pushing gasses away. The low solubility of nitrogen dioxide mean that any scavenging of this gas will be a negligible factor.
ADMS can include time varying files which replicate source emissions being turned on and off during the modelled period. This method does have the potential to miss the worst case meteorological conditions. As such the model has been run assuming the flare is in continuous operation throughout a full year. The worst case 90 day average has been calculated from the results and a factor derived from the average of this worst case 90 day period compared with the full year results. The annual results are then multiplied by this factor to derive the 90 day emission averages.
As there are two 90 day periods in operation in any 12 month period the worst case 90 day period has been doubled to provide the annual average.
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F5 Assessment of Radon (Studsvik)
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REVISION SHEET Rev.
Description Revised By Checked By Approved By
A
1st Issue
Nick Chambers
Paul Redhead
Dan Myerscough
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EXECUTIVE SUMMARY This report considers the potential exposure of members of the public as a result of the discharge of radon-222 gas (Rn-222) to atmosphere from a Cuadrilla Resources Well Site in Lancashire, as a result of exploratory phase operations. The assessment considers both the potential discharge of Rn-222 which may be transported with any natural gas brought to the surface, and also that which may de-gas from produced waters brought to the surface (following the decay of radium-226 contained within the waters). The assessment is considered to be suitably pessimistic, and estimates a potential effective dose to a member of the public of approximately 0.3 microSv/y. The estimated exposure is considered suitably worst-case, and falls significantly within both the dose constraint of 300 microSv/y for a single source, and the statutory public dose limit of 1000 microSv/y.
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GLOSSARY
EPR10 Environmental Permitting (England and Wales) Regulations 2010 GBq Giga-Becquerels IRR99 Ionising Radiations Regulations 1999 NORM Naturally-occurring Radioactive Material
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CONTENTS
1 INTRODUCTION ............................................................................ 6
2 SOURCE OF RADON ..................................................................... 6
3 ENVIRONMENTAL PERMITTING REGULATIONS 2010 ............... 6
4 IONISING RADIATIONS REGULATIONS 1999 .............................. 7
5 DOSE ASSESSMENT .................................................................... 7
6 CONCLUSION ................................................................................ 8
7 REFERENCES ............................................................................... 8
LIMITATIONS
This report has been prepared by Studsvik UK Limited in their professional capacity as Consultants, with all reasonable skill, care and diligence within the terms of the Contract with the Client. The advice and opinions in this report are based upon the information made available at the date of this report and on current UK standards, codes and legislation. The contents of this report do not, in any way, purport to include any manner of legal advice or opinion. Should the Client release this report to a Third Party, that Third Party does not acquire any rights, contractual or otherwise, whatsoever against Studsvik UK Limited and accordingly, Studsvik UK Limited assumes no duties, liabilities or obligations to that Third Party.
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1 INTRODUCTION This report considers the potential exposure of members of the public resulting from the discharge of radon-222 gas (Rn-222) to atmosphere from a Cuadrilla Resources Well Site in Lancashire, as a result of exploratory phase operations on the site. Although not a requirement of a radioactive substances regulations (RSR) application process [see Section 3 for further detail], on the basis of previous, similar RSR applications a request for additional information has been anticipated in relation to the discharge of Rn-222 during site operations. This request has previously been made with regard to the Air Quality sections of the Environmental Impact Assessments associated with the permitting of other onshore oil and gas exploratory activities.
2 SOURCE OF RADON Radon gas (Rn-222), being the progeny of radium-226 (Ra-226) which is present in the returned waters at elevated activity concentrations, could potentially de-gas and be removed from the produced waters within phase separation equipment and be discharged from site via the flare. More significantly, Rn-222 will also be a component of the natural gas which will potentially travel to the surface during site operations and be discharged via the flare. Thoron-220 (Rn-220) gas will also be generated, however the impact of this radionuclide has not been considered in detail within this assessment. Given the relatively short half-life of Rn-220, and the relatively low specific activity of the radium-228 (Ra-228) parent within the produced waters (relative to that of Ra-226), the radiological impact of this radionuclide (and its progeny) is anticipated as being negligible, and the assessment of potential Rn-222 exposures is considered bounding.
3 ENVIRONMENTAL PERMITTING REGULATIONS 2010 Although, Rn-222 is included as a component of the decay series of some of the EPR10 Schedule 23 radionuclides*, it is not included as a main entry (i.e. is not a standalone ‘EPR radionuclide’). As such, Rn-222 in natural gas is considered to be out of scope of the requirements of the EPR10, and the storage, distribution and use of natural gas is not a listed Naturally-occurring Radioactive Material (NORM) Industrial Activity. However, where radon is present as a result of the accumulation and disposal of in-scope radioactive waste that contains radium (i.e. within the produced waters potentially generated during exploratory operations), the regulatory regime requires consideration of Rn-222 exposures to the public and the environment.
* As amended by the Environmental Permitting (England and Wales)(Amendment) Regulations 2011 (SI: 2043).
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Although only the latter instance requires formal consideration under the EPR10, both potential exposure routes have been considered as part of the EPR10 application process for a Lancashire Well Site operated by Cuadrilla Resources. This assessment relates to a single Well Site, but consideration of cumulative exposure associated with multiple Well Sites in a single locality is considered in Section 5.
4 IONISING RADIATIONS REGULATIONS 1999 Although this assessment is produced in support of an application being made under the EPR10, the requirements of the Ionising Radiations Regulations 1999 (IRR99) also require consideration. This assessment is also considered as to address the specific requirements with regard to potential application of the IRR99. The Approved Code of Practice (specifically, paragraph 11) states that: In the special case of substances containing naturally occurring radionuclides used in work other than a practice†, their activity cannot be disregarded for the purpose of radiation protection where their use is likely to lead to employees or other people receiving an effective dose of ionising radiation in excess of 1 mSv per year. The second aim of the assessment is therefore to determine whether, with regard to potential exposures of the public associated with radon emissions, the IRR99 apply to the work.
5 DOSE ASSESSMENT During the exploratory phase of operations on a single Well Site, the assessment assumes the following programme of work and parameters‡:
• Natural gas is flared at a maximum rate of 130,000 m3 d-1 for a period of 120 days
• Natural gas contains Rn-222 at a specific activity concentration of 200 Bq m-3
• A total of 3.12 GBq Rn-222 is carried with the natural gas and is discharged via the flare over a period of 120 days§
• Each Well Site potentially generates 35,000 m3 of produced water
• Produced water contains Ra-226 at a specific activity concentration of 90 Bq l-1
• 100 % of the Rn-222 produced via the decay of the total, potential Ra-226 inventory of the produced waters is discharged from site as an aerial release (i.e. 3.15 GBq)
† The work does not involve the production, processing, handling, use, holding, storage, transport or disposal of radioactive
substances, which can increase the exposure of individuals to radiation from a radioactive substance containing naturally occurring radionuclides which are processed for the radioactive, fertile or fissile properties, and is therefore not considered to be a practice, as defined within the IRR99. ‡ NOTE: although the proposed operations will be of 120 day duration, the model assumes that the activity is discharged over the
course of 1 year, and gives rise to an annual effective dose. § No radiologically-significant in-growth of progeny, or concurrent transport of significant activities of the volatile species lead-210
(Pb-210) and polonium-210 (Po-210), is anticipated. Concentrations of Pb-210 and Po-210 of 0.005-0.020 and 0.002-0.080 Bq m-3
have previously been reported for natural gas [Reference 1].
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A radiological impact assessment has been performed which follows the Environment Agency’s Initial radiological assessment methodology – part 1 user report [Reference 2] & part 2 methods and input data [Reference 3]. The assessment considers potential exposure of the Local resident family, living in a dwelling at a distance of 100 m from the flare and consuming foodstuffs grown at a distance of 500 m from the flare. Based on a release height of 10 m, the assessment estimates that a member of the Local resident family exposure group could potentially receive an effective dose of 0.3 microSv/y as a result of the hypothetical discharge.
6 CONCLUSION The estimated exposure is considered suitably worst-case, and falls significantly within both the dose constraint of 300 microSv/y for a single source [Reference 3], and the statutory public dose limit of 1000 microSv/y. For context, the estimated dose can be directly compared to that routinely received due to Rn-222 exposure in the home and workplace in the UK, being (on average) 1300 microSv/y [Reference 4]. Although there is a requirement to consider the cumulative impact on members of the public of all radioactive discharges which may occur within the locality, at the exposure level reported for a single site, and given that it is anticipated that during exploratory operations there will be a maximum of two such sites operating within a horizontal distance of 5 km, the cumulative impact due to the potential discharge of Rn-222 will remain radiologically insignificant.
7 REFERENCES 1. IAEA INIS reference
http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/25/063/25063914.pdf 2. Initial radiological assessment methodology – part 1 user report. Science Report:
SC030162/SR1 (Environment Agency, 2006). 3. Initial radiological assessment methodology – part 2 methods and input data.
Science Report: SC030162/SR2 (Environment Agency, 2006). 4. Board Statement on the 1990 Recommendations of the ICRP. Doc NRPB 4(1)
(1993). 5. S J Watson et al. Ionising Radiation Exposure of the UK Population: 2005 Review.
Chilton, HPA-RPD-001 (2005).
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F6 Dust Mitigation Measures
The dust emitting activities assessed in Chapter 6 can be greatly reduced or eliminated by applying the site specific mitigation measures for low risk sites according to the IAQM guidance. The following measures from the guidance are applicable:
F6.1 Communications
Display the head or regional office contact information.
F6.2 Site Management
Record all dust and air quality complains, identify cause(s), take appropriate measures to reduce emission in a timely manner, and record the measures taken.
Make the complaints log available to the local authority when asked.
Record any exceptional incident that cause dust and/or air emissions, either on-or –off site, and the action taken to resolve the situation in the log book.
Workforce education regarding air quality impacts and the mitigations required on site.
F6.3 Monitoring
Undertake daily on-site and off-site inspection, where receptors (including roads) are nearby, to monitor dust, record inspection results, and make the log available to the local authority when asked.
Carry out regular site inspections, record inspection results, and make an inspection log available to the local authority when asked.
Increase the frequency of site inspections by the person accountable for air quality and dust issues on site when activities with a high potential to produce dust are being carried out and during prolonged dry or windy conditions.
Conduct off site air quality monitoring, analyses results and use data to inform on site operations /practices.
F6.4 Preparing and Maintaining the Site
Plan site layout so that machinery and dust causing activities are located away from receptors, as far as possible.
Erect solid screens or barriers around dusty activities or the site boundary that are at least as high as any stockpiles on site.
Keep site fencing, barriers and scaffolding clean using wet methods.
Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site. If they are being re-used on site cover as described below.
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F6.5 Operating Vehicle/Machinery
Ensure all vehicles switch off engines when stationary – no idling vehicles.
Avoid the use of diesel or petrol powered generators and use mains electricity or battery powered equipment where practicable.
F6.6 Operations
Only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction e.g. suitable local exhaust ventilation systems.
Ensure an adequate water supply on the site for effective dust/particulate matter suppression/mitigation, using non-potable water where possible and appropriate.
F6.7 Construction
Ensure sand and other aggregates are stored in bunded areas and are not allowed to dry out, unless this is required for a particular process, in which case ensure that appropriate additional control measures are in place.
Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery.
F6.8 Trackout
Avoid dry sweeping of large areas.
Ensure vehicles entering and leaving sites are covered to prevent escape of materials during transport.
Inspections of access routes.
Core Document 5.19