Pickering radioactive waste water re-injection well – how to object

Third Energy are applying for another EAP (Environment Agency Permit) application for a radioactive waste-water re-injection well in Ryedale, this time at Third Energy’s existing Pickering well-site.

As with Ebberston South, they are applying to the Environment Agency for a Radioactive Substance Activity Part RSR-A permit to re-inject radioactive waste water from their conventional well site back into the ground.

THE DEADLINE FOR OBJECTIONS TO THIS  HAS PASSED, BUT THEY WILL STILL ACCEPT LATE OBJECTIONS..

You can make your objection by email at: RSR.Rotherham2.NE@environment-agency.gov.uk

Note that this is a new email address from the one previously posted. As they have had so many objections, they have asked us to use this new email address, which is different to the one already posted. However, they have assured us that all objections sent to the previous address have been received and logged.

Please put the following in the subject line: EAP objection Ref: EPR/NB3995DX/A001

For what to say on the objection itself, here is a downloadable letter that you can personalise, then attach to your email. EA-LETTER-TEMPLATE-PICKERING

Alternatively, you can just cut’n’paste some of these reasons to object into the body of the email. Please try and personalise the beginning and end, though, as objections are taken less seriously if they are all exactly the same, and don’t forget to state clearly at the beginning that you are objecting to this application.

In your objection, you may wish to make some of the following points:

1. The area around Pickering is unsuitable for re-injection of radioactive materials into the Sherwood Sandstone layer, because there are major faults (mapped by the British Geological Survey) in what is known as the Vale of Pickering Fault Zone. These faults may allow for migration of re-injected waste water upwards or laterally, endangering our water supplies.
2. The company argues that the re-injected waste water is unable to migrate laterally due to ‘significant geological faulting’ between the injection site and the nearest drinkable water, while at the same time claiming that re-injected waste water can’t migrate upwards due to an unbroken layer of impermeable rock with apparently no faulting at all. These two positions regarding faulting are clearly contradictory, particularly given that the site lies within the Vale of Pickering Fault Zone.
3. The company is planning to re-inject this waste water by modifying an existing well, which has been in use for some years. A full and complete appraisal of this well would need to take place by an independent third party or the Environment Agency to check the condition of this will and its concrete casing before any application is considered.
4. No Environmental Impact Survey has been conducted, even though the site is adjacent to known EA flood risk areas, and no management systems for leakage and flooding is included in the documentation.
5. Third Energy’s claim that re-injection is the Best Available Technology is driven purely by financial considerations and that this technique will ‘maximise commercial viability of gas production’, not because it is the best available environmental option. Detailed comparisons, both practical and financial, with other alternative disposal methods are not included in the application, and the re-injection option seems to have been chosen merely on the basis that it maximises profitability for the company.
6. The Environment Agency have again failed to conduct any independent survey or analysis of the geology or water composition in the area, and are simply relying on data that is presented to them by the applicant.
7. The waste water is extremely saline and radioactive, with many chemical compounds at levels far exceeding drinking water or environmental quality standards.
8. There is no proposed treatment process for the waste water before it is re-injected into the ground, which again does not constitute the best available environmental option.
9. The proposed re-injection wells pass through major aquifers that supply local drinking water to the surrounding towns, farms and villages. If and when the well casings fail – and all wells fail eventually – radioactive waste water would pass into the water supply.
10. Studies in the USA indicate that waste water re-injection is a major cause of seismic activity, and as such is a threat to the land and livelihoods of people living hear the site.
11. The company cannot be 100% certain that waste water won’t travel into nearby aquifers over time, particularly after a large amount of water has been injected into the Sherwood Sandstone layer under pressure.
12. There is no information included in the application regarding regular and independent monitoring of the re-injection well, water tables and seismic activity, which would seem essential for such an application.
13. The application states that while the consequences of contamination would be high, the risk of occurrence is ‘very low’. Unless the risk to drinking water supplies is zero, no radioactive waste water re-injection should take place at all.

Don’t forget to ask for confirmation of receipt, and to urge them to reject this application.