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$: Environmental Statement - WordPress.com Bowland Limited Temporary shale gas exploration at Preston New Road, Lancashire Environmental Statement Issue | 29 May 2014 Page F \\GLOBAL.ARUP.COM\EUROPE\MIDLANDS\JOBS\230000\230382-00\04$
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

Core Document 5.19

Core Document 5.19

Cuadrilla Bowland Limited Temporary shale gas exploration at Preston New Road, Lancashire Environmental Statement

Issue | 29 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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Page F1

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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Page F2

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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Page F3

F1.1 Planning Policy Guidance Flowchart

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Page F4

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


20,000m3 - 50,000m

3

• potentially dusty

construction material

• demolition activities

10-20m above ground

level


>50,000m3


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


time

• formation of bunds

4m - 8m in height


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


time

• formation of bunds >8m

in height


>100,000 tonnes

Construction


<25,000 m3

• construction material

with low potential for

dust release (e.g. metal

cladding or timber)


25,000m3 - 100,000m

3


construction material (e.g.

concrete)

• piling

• on-site concrete batching


>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;


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;


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);


residential properties. Hospitals

and schools and residential care

homes should also be considered

as having equal sensitivity to

residential areas.

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Page F7

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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Page F9

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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Page F10

F5 Assessment of Radon (Studsvik)

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Core Document 5.19

Report Reference: P0560/TR/001 Revision: A

Date: 19/02/2014

UNCONTROLLED IF PRINTED Page 2 of 8

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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Page F11

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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Page F12

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.

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