Summary of Objections to Canatxx Gas Storage Proposal
1 This localised Canatxx scheme is not needed to guarantee the supply of gas to the UK market.
2 The depth, thickness and structure of the salt bed creates real safety concerns.
3 The proposed storage for the gas area is one which is prone to earthquakes and ground movement.
4 The connecting pipes to the caverns will not be vertical as illustrated by Canatxx but angled which adds to safety fears.
5 The caverns will be adjacent to the disused brine wells and salt mines with their associated collapses.
6 The Hutchinson (Kansas) disaster was a result of pressurised natural gas leaking from a gas storage salt cavern into disused underground workings.
7 Kansas State Law now prohibits underground gas storage within 3 miles of a municipality and other states are considering similar legislation. Nearly 100,000 people live within 3 to 4 miles of the proposed Wyre gas storage caverns.
8 There are 49 Institute of Chemical Engineers records of natural gas escaping from such installations.
9 The security of the site is not adequately considered especially with regard to terrorism. No emergency plan has been submitted. These would have severe additional environmental impacts.
10 The discharge of the salt into the sea is a waste of a natural resource and would be environmentally disastrous.
11 There would be severe adverse impacts on several important and sensitive environments - 3 SSSI’s, a number of BHS’s and the SPA of Morecambe Bay.
12 The area of Over Wyre where the infrastructure would be built (wellheads, stations, pipes, access roads) Moreover, it is liable to subsidence.
13 As compensation there would be minimal economic benefit to the local community or to Wyre Borough. There is a potential for this to be detrimental to the tourist trade and housing markets which would damage the economics and infrastructure of the area in the longer term.
14 In the event of Canatxx going bankrupt, Wyre Borough Council would be responsible for making good and safe the damage already caused. This bill would be picked up by the residents and all because Canatxx want to line the pockets of their shareholders.
Details of Objections to Canatxx Gas Storage Proposal
1 Economic and Strategic Arguments
Transco (Ten Year Statement 2003) state that if all the proposed gas and supply/storage plants came to fruition, they will not be able to use all of them. We are therefore asking for a sequential approach to be adopted with regard to gas supply and storage.
“There are more than sufficient potential projects to meet the needs of the UK market (for gas) over our ten year planning horizon”.
“The key security of supply issue associated with the rapidly increasing import dependency is one of timing”.
The argument that the UK does not have the storage capacity of other EU countries needs to be set in context because whilst France for instance relies on nuclear power for 75% of its energy, it can easily accommodate a strategic gas store at one deep site in the Alps (Tersanne).
Germany stores its gas in salt domes and depleted gas fields which are much safer and deeper that the bedded salt under the Wyre and one site at Winterhall is something in the order of four times that which Canatxx propose to make gas instantly available to German gas customers.
The Canatxx facility, although large, is far too small for a strategic store should supplies of natural gas from abroad become cut off. The use of the depleted North Sea and Irish Sea gas fields could fulfil this role. The Rough Field in the North Sea is already being used for this purpose.
2 Geological Character of the Salt Bed
The caverns would not be lined but would rely on the natural qualities of the salt and ground pressure to retain the gas. However, the salt beds are not pure but are divided by at least two layers of mudstone which may allow the gas to escape. The roofs of the caverns would be at a depth of 1200 feet. The normal depth for gas storage is much deeper - between 3,000 and 4,000 feet and those at Hornsea in
East Yorkshire are at 6,000 feet. The deeper the beds the less chance the gas has to escape. Canatxx state (p6 of the application) that the salt bed has a thickness of 366m. The information derived from the British Geological Survey Memoir (BGS 1990) shows that the maximum thickness of the bed is 183m. The BGS shows the salt bed in the form of a downfold (syncline) the axis of which underlies
the salt marshes and the Heads.
Canatxx intend to extract the salt from this area stating that they “believe” that ICI did not exploit the salt from under this area. They do not know this. Canatxx has only now - 2 months after the application was submitted - started drilling boreholes to test the geology. (ICI boreholes reports being confidential).
3/4 The Threat of Earthquakes
The pipes are to be drilled under the muds and marshes of the estuary not vertically but in the form of a lazy ‘S’. (This is not what the Canatxx pamphlet shows, i.e. the one that Canatxx distributed at the public meetings called by Wyre Borough).
This potentially makes these pipes all the more prone to rupture from earth movements notably along the Burn Naze Fault which runs north-south under the estuary and from the continued collapse of the ground around the Preesall and Stalmine brine field.
In 1984 and again in 1990 there were two earthquakes measuring between 4.5 and 5.5 on the RichterScale which affected the area and damaged pipes to the brine wells. It is proposed to fill the first caverns with gas whilst adjacent caverns are being drilled, another factor
which could cause the ground to shift. It is interesting to note that Heysham Power Station has had to be built to withstand earthquakes.
Canatxx do not mention this.
5 The proximity of disused brine wells and salt mine
The caverns will be excavated in the same salt bed as the now disused brine wells and salt mine. These have left caverns of unknown size and shape which are all subject to eventual and unexpected collapse.
Dramatic collapses have occurred at the surface west of Preesall village producing craters up to 600 feet across and 150 feet deep.
ICI were convinced that the most recent brine pumping techniques used towards the estuary would maintain the cavities and stop subsidence. Very worryingly this has not been the case. It is no longer possible to walk along Aggleby’s Road because it has been swallowed up by a crater and now a new hole is developing a little way to the west and the two could easily coalesce.
To the south on the top of Height o’ th’ Hill, just a few years ago, a depression appeared in the ground without any prior warning and since then it has deepened and opened out into a crater that now measures some 300 feet in diameter, possibly 500-1000 feet deep, and it is still growing.
Along the sea wall to the east of Barnaby’s Sands, the gas well heads would be located within 150 feet of old brine well heads which might well collapse in the same way. If the gas escapes from the caverns and traverses the 150 feet into the brine wells, it could spread
under the whole area eastwards towards Stalmine and Preesall. A particular worry is well head 107 at the end of Highgate Lane which was used over a period of 21 years by ICI for the disposal of 47,000 tonnes of toxic mercury sludge. The pressure of BW107 is less than the proposed gas storage caverns thus the gas could use this well as an exit route bringing toxic mercury Sulphide to the surface with any
escaped gas.
6 The Hutchinson Disaster
This is exactly what happened in 2001 at Hutchinson (Kansas). Gas escaped from a salt cavern, moved along a non salt bed, and travelled 7 miles to collect in old brine workings under the town of 40,000 people and methane mixed with oxygen is highly explosive. Water and gas geysers erupted across the town, fires raged, property destroyed and 2 people lost their
lives.
7 Kansas State Law
Canatxx make much reference to Joe Ratigan’s Report on Hutchinson which puts the blame fully on human error and PWG do not dispute this report. What Canatxx do not include is Joe Ratigan’s recommendation to the Kansas State Legislature that gas storage wells should not be located within 3 miles of a municipal settlement or within 1 mile of any well (gas, brine, oil, etc – used or disused).
The report recognises that even if caverns were engineered and operated to the highest safety standards, there is always a possibility of human error or unforeseen ground movement so the chance of any escaped gas surfacing and exploding is minimised by these separation safety zones.
Nearly 100,000 people in Fleetwood, Thornton, Cleveleys, Anchorsholme, Carleton, the northern half of Poulton, Hambleton, Stalmine, Preesall and Knott End, live within 3 miles of this proposed gas storage site and some of the Canatxx well heads would be within a few hundred feet of existing brine wells!
8 Gas Leaks & Accidents Happen
Canatxx claims that the storage of natural gas in salt caverns is well used technology and safe. Nothing is ever safe, as the numerous gas leaks from storage prove. There is well documented evidence of these and the IChemE database lists 49 such incidents. We would draw your attention to the following accidents which illustrate the serious consequences of escaping gas….
Flixborough release of flammable gas cloud Ignition 28 fatalities
Abbeystead release of methane Ignition 16 fatalities
Mexico gas pipeline ruptured by landslide 4 fatalities, 50 injured
Feyzin leaking gas cloud travelled offsite Explosion and fire 18 fatalities
San Francisco natural gas pipeline punctured No ignition 30,000 evacuated
Phillips 66 highly flammable vapour cloud Ignition. 23 fatalities
Mexico City LPG escape. Fire and explosion 500 killed
9 Site Security and Emergency Plans
Canatxx plans, or lack of them, suggests a grossly inferior site security arrangement than is already in place just 1 Km away at the old ICI Hillhouse Site, and one which is the norm at other top tier COMAH sites.
It is usual to surround such sites with security fencing and to operate a process of access control via a security lodge/gatehouse. The Canatxx planning application does not include for the building of a security lodge. Canatxx’s description of security intent is contained in para 14.5.3 of their Environmental Statement. There is apparently no intention to exclude the public from free roam around the site should they so desire, - even if these be potential vandals or even terrorists. Simply to exclude from a minimum distance of around ten metres from multiple well heads by building steel security fences around them, - hardly a challenge for committed terrorists.
There is no mention of excluding the public from the area of installations but this would presumably be a necessity. What sort and extent of exclusion zone are we looking at?
There is no emergency plan submitted or what such a plan would entail e.g. in staffing numbers. Thesite would need an emergency fire water system, roadside drainage and proper roads to take emergency vehicles. Does Wyre Borough intend to install these facilities at its own cost for this site?
The proper measures needed to be taken for security, especially against terrorism and to deal with an emergency would have significant impacts on the area which are not discussed in the application. For example a high security perimeter fence around the whole site would involve security lighting and CCTV and would block the Wyre Way and other public rights of way.
10 The Discharge of Brine into the Irish Sea
There are ecological implications which arise from the Canatxx plan which are extremely disturbing. The brine from the cavities would be discharged into the sea a mile and a half off Rossall School at a rate of 80 million litres per day continuously over the 10 year construction period. Besides being a complete waste of a valuable natural resource, brine with a 26% salt content would have a disastrous
effect on sea life. All life on the sea bed would be killed off within 150 feet of the outfall but a much wider area would be
substantially affected. It is estimated that it would take between 6 and 11 years for recovery to take place after the discharge
has ceased so we are looking at disturbance and habitat destruction over a 20 year period. But this is only an estimate because no one knows the circulation pattern of waters within Morecambe Bay and adjacent coastlines.
No wonder the Fleetwood fishermen, the inshore anglers and the Salmon and Trout Association are all opposed. The last named body has a very active group on the Wyre whose aim is to protect these important species.
Wild Atlantic Salmon are listed as being the 10th most endangered species and as they detect their native river by smell, they may not be able to return to their spawning grounds if their river of origin is obscured by brine. Serious conservation efforts are being made to re-inrtroduce these species to the rivers Ribble, Lune and Wyre
The brine pipeline running south of Fleetwood would also have a significant impact on 3 Biological Heritage Sites - at Rossall School playing fields, Broadwater Wood and Fleetwood Marsh industrial land (which includes the old power station site). Ironically the last site has just been accepted as a nature reserve by Wyre Borough.
11 Environmental Impacts
The whole of the Wyre Estuary was designated as part of the Morecambe Bay Special Protection Areaby the European Union just a few years ago because it is an internationally important site for birds. Significant populations of waders - godwit, lapwing, curlew, dunlin, redshank, and oystercatcher - use the estuary for feeding at low tide and roost on Arm Hill, a small eroded drumlin joined to the mainland
by a shingle spit.
On this very site a well head with an access road along the spit has been proposed. There would be serious disturbance caused to the birds during the construction of the road and the well head, not so much from the noise but more from the movement of people.
The fields Over Wyre are used for grazing by large numbers of pink footed geese in winter and by breeding lapwing and redshank in the spring and summer. This is where Canatxx propose to develop their infrastructure.
The spit at Arm Hill encloses the salt marsh of Barnaby’s Sands and south of the Heads Peninsula, a similar salt marsh exists at Burrow’s Marsh. These marshes were designated as Sites of Special Scientific Interest in 1968 and are cared for by the Lancashire Wildlife Trust.
They are the largest areas of ungrazed salt marsh in North West England and are floristically rich because they show the whole range of salt marsh vegetation zones.
In summer the marshes are bright with the purple flowers of common sea lavender (Limonium vulgare) and the much rarer rock sea lavender (L. humile). The Clods Carr BHS supports purple ramping-fumitory which is nationally scarce as well as tall ramping-fumitory which is rare in Lancashire.
The proposed development would result in the permanent loss of this habitat. The original Canatxx proposals would have filled in the salt marshes. The present plan is to locate the well heads on the sea wall immediately behind the marshes and drill at an angle beneath them. This still raises questions as to the risks of pollution resulting from spillage of chemicals and oil and from the construction of access roads.
A separate environmental statement from Robert Lobell, PWG’s environmental group coordinator is attached for your additional information.
12 The Over Wyre Countryside
If this proposal goes ahead, then the peaceful countryside of Over Wyre will be disturbed if not totally shattered. The drilling of the boreholes has the potential to be a noisy operation and will continue over 10 years. Good agricultural land will be lost to build the Booster Pumping Station near Coat Walls Farm and the Gas Compressor Station near Burrow’s Farm and in fact Burrow’s Farm would become uninhabitable.
The caravan sites on the Heads would be “removed” in order to construct the well heads and as well as turning the Heads into an area where people would not want to take holidays any more, it would have a direct effect on the local economy to which these park home residents currently contribute. Between the Pumping Station and each of the well heads, pipes would have to be laid to supply the water and take away the brine.
From each well head, gas pipelines would then be laid to the Compressor Station. New roads would have to be laid across land liable to subsidence to allow 20 tonne construction lorries to access the stations and the well heads and during the construction period there would be 150 additional heavy goods vehicle journeys per day.
These new roads would connect to the existing single track lanes which characterise this rural area. As they meet with the main arterial roads they will have a severe impact on the already overloaded A585 and who knows the safety implications of these vehicle movements during school journey times.
13 The Economic Benefit for the Local Community
Canatxx state (p54) that 150+ temporary jobs will be created during the construction. Most of the work will be completed during the first year during the pipeline laying, road and building construction.
When United Utilities laid new water mains, they used a contractor and labour brought in from outside the area so it is envisaged that only in the drilling and washing processes will the jobs continue. The number of these is not specified and the work most likely to be done by specialist contractors and skilled workers from outside the area.
There will be just 15 permanent jobs created and these will be highly paid professionals. Canatxx suggest 5 indirect jobs will be created for each direct job, but admit that 10 jobs will be lost at then caravan sites and the farm. So the total benefit is 5 direct jobs and perhaps 25 indirect.
Canatxx claim that the Hillhouse Site will become attractive to power stations and energy intensive processing facilities (p55). But they give as the rationale for the scheme as the need to top up the National Transmission System in times of peak demand and not to supply a gas fired power station.
Canatxx were recently quoted in a BBC interview as stating that they wished to build a gas fired power station on Anglesey which would be fed from their storage facility in Fleetwood by a sea pipeline.
14 Who is going to underwrite Canatxx?
What happens if things go wrong in the future? There are no proposals by Canatxx to underwrite any future disasters.
Will Wyre Borough Council and its residents be left to pick up the pieces and if so at what cost?
What other projects have Canatxx successfully completed in the UK? Are there any?