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Hi David

 

I thought that the Part 2A regime was created to deal with the legacy of historic contamination. Wouldn’t contamination that occurs in the future be dealt with under the relevant permitting regime and/or the Environmental Damage Regs?

 

https://www.gov.uk/government/publications/environmental-damage-prevention-and-remediation-regulations-2009-guidance-for-england-and-wales

 

 

Regards

 

Christopher Taylor

Enforcement Officer

Regulatory Services

Brent Council

 

Tel: 020 8937 5159

Fax: 020 8937 5150

www.brent.gov.uk

 

 

 

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of David Jackson
Sent: 28 July 2014 13:50
To: [log in to unmask]
Subject: Re: Gov't Sale of Fracking Licenses

 

Frank

In order that sites are returned to pre-development conditions presumably they will undergo a “baseline assessment” and that samples of soils and groundwater will be tested for the chemicals (and natural substances and radio-nuclides (NORM)) which may be used and encountered during the fracking process.  Hence, a comprehensive list of substances will still need to be created.

 

If the clean-up does not return the site to pre-development baseline levels (just like IPPC) it would still have to satisfy Part 2A assessment and would still be required to be demonstrably suitable for any subsequent development later on down the track, so the derivation of C4SL and GACs would still be required – hence my question(?).

 

Best wishes to all,

David E Jackson

Sometime freelancer

 

 

 

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of F J Westcott
Sent: 28 July 2014 13:40
To: [log in to unmask]
Subject: Re: Gov't Sale of Fracking Licenses

 

Off the top of my head, and without delving into the permitting requirements for Fracking, I would guess that any eventual clean up requirement of a fracking wellhead site will be established on the basis of the EU industrial Emissions Directive, i.e. return the site to its pre existing condition, rather than through Part IIA. 

Therefore neither C4SLs nor GACs will have any relevance (at least that's one thing we wont need to argue about!)

 

If a list of chemicals is to be put together, it should of course include any substances in the formation to be fracked that might be liberated, as well as fracking chemicals themselves - presumably that is what Tony is referring to.

 

I welcome any

Regards

 

Frank Westcott

 

Technical Solutions for Sustainability and Brownfield Development

 

Magnolia House, 15a Fore Street, Roche, St Austell, Cornwall PL26 8EP

0330 330 8015

07973 616197

 

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On 28 Jul 2014, at 13:23, Tony Windsor wrote:

 

Don't forget to include NORMs on the list.  We had detectable levels in Quebec but, not at concentrations of toxicological significance.  I would suspect the "list" will vary depending on the fracking agents used and the formation in question though.

 

Tony Windsor M.Sc., P.Eng

 


Tony Windsor

 

 

On 28 July 2014 05:30, David E Jackson <[log in to unmask]> wrote:

Dear All
In preparation for the deluge of "fracking applications" anticipated now expoloraory licenses are being marketed for sale, I thought it might be helpful to regulators, planners and practitioners to prepare a definitive list of "Chemicals of Potential Concern" associated with fracking practices.

I would be grateful if those that known, could point me in the direction of a list(s) (I've seen a number of lists on US and Wikipedia type webpages) of fracking chemicals and more importantly their respective C4SL/GAC for soils, and health and ecological surface and ground-water screening standards.

I would anticipate that such a list would be used to set appropriate operational acceptance criteria, to inform post operational clean up, and determined suitability of the sites for future uses (and possible Part 2A determination), thereafter?

Best wishes,
David E Jackson
Sometime Freelancer

 

 

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