Air emissions, Environmental controls, Flaring, Legislation, Local Impacts, Pollution prevention & control, Waste storage, Well integrity

“Dear Aunty, should green completions be mandatory in the UK?”

The simple answer to this question, sweeties, is no – they shouldn’t.

To understand why, you first need to know what ‘green’ completions are, and this handy description from Energy In Depth explains that very well: http://energyindepth.org/marcellus/natural-gas-and-green-completion-in-a-nut-shell/

Now, whilst a lot is said about the need for green completions in the UK, it is usually suggested that they are a means of eliminating flaring, but that’s not quite accurate. As you’ll see from the Energy In Depth post, even the US rules that impose the requirement for reduced emissions completions go on to say the captured gas, if it can’t be marketed, must be sent to completion combustion device (flare). It’s really about preventing unabated releases of methane.

I’ve posted on flaring before, if you recall sweetpeas, noting that we are unlikely to see anything like the amount of production flaring witnessed in some parts of the US, particularly in the Bakken shale play in North Dakota, but we will see some flaring in the early exploration wells.

Why poppets? Well, during exploration well testing, there is no alternative. That’s because:

(a) there may not be any gas at all
(b) if there is, there may be too much to use on site, but…
(c) there may be too little to warrant export to grid, and…
(d) the PEDL doesn’t allow the sale of hydrocarbons anyway

With no obvious alternative, gas produced during well testing has to be flared. But green completions may still be used, and in fact Cuadrilla already plans to use them in Lancashire.

Yes, that’s right dears: Cuadrilla will be performing green completions in Lancashire but will still have to flare some gas during exploration well testing.

How do we know this, if it isn’t mentioned anywhere in their public literature? Well, because they told us in the environmental permit applications they made in 2012, which were subjected to two separate rounds of public consultation with all the application documents being made available to view. In those applications, my darlings, they describe the high efficiency separator that separates the gas from flowback waste in the wellstream. That’s green completion. If the Environment Agency grants the permits, Cuadrilla must ever after continue to use green completions because it’s what is specified in the applications – so, dears, it’s not something they can occasionally choose to do just for PR reasons.

So, if they’re a good idea, why shouldn’t green completions be mandatory in the UK?

Well, it’s very simple pumpkins: they sort of already are. You see, our regulations oblige operators to prevent the fugitive escape of substances from the wells they drill, but they don’t specify how that should be achieved. It is quite rightly left to operators themselves to determine this. What people call green completions is just one way of preventing unabated methane releases, but there could be others that are better. If we start getting into the realms of prescription, rather than maintaining our goal-setting approach to regulation, we could very easily encourage complacency rather than continual improvement, and that would be a mistake sweeties.

I’ll leave you with one final point to remember: anybody that says green completions or ‘green tanking’ can eliminate the requirement for flaring altogether during exploration is either ignorant of the facts or attempting to deliberately mislead.

Until next time xxx

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