UKOOG Response to Chemtrust report on Fracking

22 June 2015

UKOOG, the representative body of the UK onshore oil and gas industry, notes the content and timing of the report by Chemtrust on fracking published today. The report has clearly been issued at a time to try and influence local decision makers with respect to planning applications. It should also be noted that a sponsor of Chemtrust is Greenpeace and the report makes use of reports either directly written by Friends of the Earth or by well-known activists.]

The report, however, does not include a detailed review of UK regulations, which is borne out by a number of recommendations it makes that are already covered either by existing regulation or stated industry best practice. The report also ignores and fails to heed warnings by recognised experts of the dangers of incorrectly and inappropriately applying experiences from other countries to the UK; and the report is at odds with recognised, authoritative experts such as Public Health England (PHE) and the Scottish Government Independent Expert Scientific Panel on Unconventional Oil and Gas.

Ken Cronin, CEO of UKOOG, said: “The timing of this report is clearly designed to influence local councillors right at the end of an already exhaustive 15 month process, which has been professionally reviewed by a number of agencies and officials. I am concerned about the lack of independence of sponsors of this organisation as well as the fact that a number of recommendations are already best practise in the industry.

“The industry has been working within areas of outstanding natural beauty, national parks, SSSIs and other similar areas for many years without impact to the environment, community or habitats of species – something this report fails to even mention.”

Report Recommendations

The report includes a number of recommendations that are already part of industry common practice or regulation in the UK:

  • - All fracking operations are subject to an environmental impact assessment.
  • - The quality of wells in the UK is regulated by the HSE through Borehole regulations that have been in place for nearly 20 years.
    • - Inspectors also have the authority to come whenever they please and do so on a risk basis  
  • - Disposal and treatment of water is covered by Environmental permits under the jurisdiction of the Environment Agency (and SEPA and NRW in Scotland and Wales).
  • - Financial liability is already fully covered by the Oil and Gas Authority.
  • - There is already full chemical disclosure of fracking fluids in the UK.
    • - The Environment Agency would not authorise the use of a hazardous substance for an activity, including hydraulic fracturing.
  • - In the UK baseline monitoring, operational monitoring and post decommissioning monitoring are all standard practice and are now covered additionally by the Infrastructure Act.
  • - Health is already addressed through the regulatory assessment and permitting process in the UK.
    • - The report ignores the founding principle and purpose of Environmental Impact Assessment (EIA) which is to investigate potential environmental effects that may pose a risk to environment and health at a development planning stage.
    • - The report also ignores the fact that environmental permitting exists to regulate industrial processes to ensure that they operate within defined environmental standards and a raft of wider regulations set to protect health.
  • - Regulators in the UK have made statements that they are sufficiently resourced.
  • - Groundwater protection zones are already subject to Environmental regulation by the Environment Agency.
  • - For planning purposes, the approach to unconventional hydrocarbon development in sensitive areas, like National Parks, are set out in planning practice guidance published in July 2013 (1).
  • - Local communities are involved in the process through:
    • - Industry engagement as per UKOOG community engagement charter;
    • - Environmental permitting public consultation;
    • - Local planning consultation.
  • - The industry has agreements with Water UK and British Water to work together on common issues. Water companies are also statutory consultees to the planning process.


Contact

UKOOG               

Ken Cronin  0207 680 6550

Newgate Communications

Deborah Saw/Jason Nisse

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0207 680 6550

DETAILED NOTES

Independent Reports

There have been a number of truly independent reports published over the last 12 months, which include the report for the UK government by Public Health England and for the Scottish Government by an Independent Panel of Experts. Both have concluded that in the context of UK regulation the risks are minimal:

“An assessment of the currently available evidence indicates that the potential risks to public health from exposure to the emissions associated with shale gas extraction will be low if the operations are properly run and regulated” Public Health England June 2014

“Many of these social (and environmental) impacts can be mitigated if they are carefully considered at the planning application stage. Added to which there are already considerable legislative safeguards to ensure such impacts are not realised” Independent Panel of Experts for the Scottish Government June 2014.

Public Health England, incorporating the Centre for Radiation, Chemicals and Environmental Hazards (Wales) and World Health Organisation Collaborating Centre for Chemical Incidents (formerly the UK Health Protection Agency) is a recognised authoritative body.

The European Parliament found that “possible health effects are mainly caused by the impacts of the relevant emissions into air or water,” but added that these are “potential effects” with actual effects “rarely documented”. Another European Parliament report concluded that: “No official or other reputable sources have demonstrated any systematic connection between shale gas and shale oil extraction and human or animal health." There have also been reports by the Royal Society and Royal Academy of Engineering and the Chartered Institution of Water and Environmental Management that have also concluded that risks are minimal and manageable.

UKOOG acknowledges that there are many reports in existence but cautions, as do independent experts, that many of the reports suffer from a number of issues including self-selection of sites, lack of peer review, size of surveys, leading questions, ignoring other influences within the same geography, anecdotal evidence and short term measurements against long term thresholds.

In addition many reports seek to rebut other reports. This must be very confusing and concerning for the general public and we therefore urge that reports from independent experts with no axe to grind are clearly the best route for the best information.

The Independent Panel of Experts for the Scottish Government commented:

“At the present moment in time many of these reports are ‘anecdotal’ in the sense that the observations have not been corroborated by objective study using factual evidence or properly quantified”.

Well Integrity and Barrier Assurance

The Health and Safety Executive (HSE) regulates onshore oil and gas operations for well integrity and occupational health and safety. Prior to any drilling activity, the operator must send its proposed well design to an independent well examiner. Once the design has been satisfactorily assessed by the examiner, the operator must then notify the HSE of the well design and operation plans. The HSE carries out its own review of these plans, taking into account any comments or recommendations made by the independent well examiner. The design of wells is regulated by the Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996 (DCR) (2). These regulations include specific requirements for all wells, whether onshore or offshore, and include well integrity provisions which apply throughout the life of wells.  The design and construction of the well is key to subsurface environmental protection. Through the use of multiple physical barriers of casing and cement, as well as utilising natural impermeable geology layers as protection, the well will protect any migration of hydrocarbons or well fluids into the surrounding rock formation. Before hydraulic fracturing commences, the well will be tested for integrity and suitability for fracturing. 

The DECC will only allow operations to proceed once the HSE has assessed the drill programme, all relevant environment permits have been granted and planning permission is satisfied.

A weekly report is sent to the HSE showing progress with the well, as well as the results of integrity testing that is completed as part of the drill plan. (See also: - Independent Well Examiner section 4.1.3.1).  The HSE visit well sites on both an announced and unannounced basis to review operations as it deems necessary.

Financial capacity and environmental liability

There are a number of measures in place to ensure that operators have adequate financial capacity.

The first set of these measures is at the licence approval stage.  DECC’s guidance on operatorship states that the following assurances will be considered in applications for onshore operatorship: "In considering any request for operatorship, DECC will look at the competence of the company – more specifically the following factors: technical experience and capability to supervise, manage and undertake the proposed operation, their risk-assessment and hierarchy of decision-making, plans for public engagement and scope of relevant insurance coverage for operations and well abandonment activity. In some cases, DECC may request independent verification. (3)" 

The second set of assurances is at the well consent stage.  DECC’s "UK Petroleum Licensing: Financial Guidance" document states: "DECC’s policy requirement is to ensure that no well consents are issued unless we are satisfied that the licensee(s) has (have) access to sufficient funds to meet its(their) share of the actual drilling costs, the plugging and abandonment of the well if it is proven to be ‘dry’ or otherwise non-viable and a minimum contingency of 50% of the drilling costs. (4)"

Secondly, there are a number of measures with respect to environmental liabilities that are worth highlighting.

The Environmental Regulator (EA in England, SEPA in Scotland and NRW in Wales) has the power to enforce the conditions in the environmental permits for a well or wells until the point in time that it accepts a surrender of those permits – the operator is not simply at liberty to hand back the permit.  For England and Wales, the permit surrender process is agreed with the Environmental Regulator, and for wells that are hydraulically fractured this is likely to include the need for a period of aftercare and monitoring of any potential residual environmental impacts.  The regulator may require the operator to supply a financial bond or other form of security for performance of its permit obligations.

With respect to the Minerals Planning Authority, planning consent for the site may also include planning conditions (which are legally binding) designed to ensure that the site is restored to its original surface condition at the end of operations.
DECC's consent is required under the terms of the operator's petroleum licence before a well can be decommissioned.  The decommissioning process must be done in accordance with a specification agreed with the HSE, with reference to the Oil & Gas UK best practice on well abandonment and with the oversight of the HSE and an appointed Well Examiner.

If a well is not decommissioned in line with the approved plan, the licence holder or well-operator at the time of decommissioning can be prosecuted by the HSE for non-compliance with HSE regulations, and this could be pursued even after the petroleum licence and environmental permits have ceased to exist.

Taken together, if a company causes damage, harm or pollution to the environment, they can be required under these regimes to remediate the effects and prevent further damage or pollution.  This is the same approach that applies to other industries.  Environmental regulators and planning authorities have the power to require upfront financial bonds to address these risks.  The industry does not wish to leave this to the taxpayer or the landowner.  As a less expensive alternative to upfront bonds, UKOOG is working with Government on the development of an industry scheme that will step in and pay for liabilities.

Finally, the Infrastructure Aill makes clear that landowners are not liable for any loss or damage which is attributed to the exercise of the right of underground access. 

Water

Water is a critical component in Hydraulic Fracturing and an important resource in facilitating onshore oil and gas in general. The industry believes water should be considered holistically throughout the planning, operational and waste management stages. The industry has established close relationships with Water UK and British Water, having also recently commenced an initiative to consider ‘Integrated Water Management for Onshore Oil and Gas’.

The Environment Agency (EA), which regulates shale extraction, has investigated the likelihood of groundwater contamination in detail and judged that the environmental risks at each individual stage of exploratory shale gas operation, after proper management and regulation, are “low”5 . The EA will not permit activities if they are close to drinking water sources, such as groundwater from aquifers.

According to a joint Royal Society and the Royal Academy of Engineering report the risk of water contamination is very low provided that shale gas extraction takes place at depths of many hundreds of metres or several kilometres – which would be the case in the UK (6).

The Chartered Institution of Water and Environmental Management (CIWEM) also agree that risks to groundwater quality are generally considered to be low in the UK where the shale rock in question often exists at considerable depths below aquifers and gas would be required to migrate many hundreds of metres between source rock and sensitive groundwater (7).

With regards to interaction between shale and overlaying aquifers, a study by the ReFINE (Researching Fracking in Europe) project found that there was a less than 1% chance of a stimulated hydraulic fracture propagating upwards more than 350 metres, and that the maximum recorded distance was 588 metres. This study recommended that all horizontal fracking wells are drilled at least 600m below aquifers to minimize the risk of stimulated hydraulic fractures providing a pathway for natural gas to migrate upwards into aquifers (8).

Fears of water shortages arising from shale gas development have been overstated. The demand for water from onshore shale operators, even at high levels of activity, would be comparable to demand by other industrial useRs. The Strategic Environment Assessment undertaken for the 14th Onshore Oil and Gas Licensing Round (9) predicted that under a high activity scenario, annual water use could be up to 9 million cubic metres, representing far less than 1 per cent of total UK annual non- domestic mains water usage. Abstraction from other sources e.g. groundwater is assessed on a case by case basis by the Environment Agency only permitted in non-water stressed environments.  Technological advances are already being commercially utilised in the USA enabling recycling/re-use of Flowback fluid, subsequently reducing the water footprint.

Groundwater and Surface Water Environment

Hydraulic Fracturing Fluids

Concerns about pollution of groundwater by hydraulic fracking fluidS are largely based on reports of past practice in the US. The regulatory position in the UK is very clear and operators are required to fully disclose all chemicals used in hydraulic fracking fluid to the Environment Agency under the Environmental Permitting Regulations 2010 (as amended). Well pads are required to have secondary containment to prevent spills and leaks entering groundwater. Regulators do not permit use of hazardous chemicals, which must be assessed on a case by case basis via the JAGDAG assessment methodology (examines persistency, bioaccumulation and toxicity). The composition of hydraulic fracturing fluids pose a very low risk to groundwater in the UK as they will only be permitted by the environmental regulator if determined as non-hazardous to groundwater.

Methane in Groundwater

As part of the establishment of a Site Condition Report, as required within the Environmental Permits, groundwater boreholes are sunk to establish levels of naturally occurring methane levels in groundwater and potentially their origin e.g. biogenic or thermogenic. Methane is naturally occurring in many groundwater deposits across the UK. The weight of scientific opinion is that the risk of methane migrating from shale rock many thousands of feet up natural faults and into aquifers is highly unlikely due to the impermeable layers above the target zone and also the requirement in regulation to provide assessment of the risks on a case by case basis. The risk of methane migrating into aquifers through natural fractures is also very low. As part of a DECC approved Hydraulic Fracturing Plan (HFP), the plan is also reviewed by the Environment Agency to review the geological target zone and potential risk to groundwater. It should be noted that methane is not a pollutant and can be readily removed from groundwater in a water treatment process.

The British Geological Survey, through its work in establishing a national picture of the background methane in groundwater has initially concluded that natural methane levels in groundwater are widely prevalent, generally low and that surface seasonal changes have very low impact (10).

Waste Management - Disposal and treatment of flow-back water

Flowback fluid contains very low levels of Naturally Occurring Radioactive Material, minerals and salts which returns to the surface inside a multi- barrier well and is stored at surface within secondary containment. Flowback fluid has been assessed by the Environment Agency as a non-hazardous waste stream and can be controlled by operators at the surface with redundant storage capacity that complies with local permitting. Specific control measures are described in detail as part of an approved Waste Management Plan and Radioactive Waste Arrangements by the Environmental Regulator in accordance with the Environmental Permitting Regulations 2010 (as amended).
Disposal of fluids, derived from Oil and Gas activities, has been an accepted activity, where treatment and disposal in the UK has taken place for many years. The industry is fully committed to storing of flowback fluids in sealed tanks as stated in UKOOGs Shale Gas Well Guidelines (11).

Surface Water and Spills

The management of surface water on a site must comply with permitting arrangements established with the environmental regulator and with any conditions imposed by the minerals planning authority through planning consents. Operations must be designed to avoid any discharge of surface water into the local environment through appropriately designed bonding and near/sub-surface barriers. Localised spills must be contained within the site, such that they do not pose a danger to the local environment. A site must be designed such that any natural occurring surface water (rain/run-off) is captured and captained within the site, where it can be suitably treated or taken away to a designated waste treatment facility.

Groundwater protection

According to the joint Royal Society and the Royal Academy of Engineering report, at the time the report was produced, the available evidence indicates that the risk of water contamination in the UK is very low provided that shale gas extraction takes place at depths of many hundreds of metres or several kilometres – which would be the case here.

The Chartered Institution of Water and Environmental Management (CIWEM) also agrees that risks to groundwater quality are generally considered to be low in the UK where the shale rock in question often exists at considerable depths below aquifers - meaning that the gas would have to migrate many hundreds of metres between the source rock and overlaying aquifers.

With regards to interaction between shale and overlaying aquifers, a study by the ReFINE (Researching Fracking in Europe) project found that there was a less than 1% chance of a stimulated hydraulic fracture propagating upwards more than 350 metres, and that the maximum recorded distance was 588 metres. This study recommended that all horizontal fracking wells are drilled at least 600m below aquifers to minimize the risk of stimulated hydraulic fractures providing a pathway for natural gas to migrate upwards and contaminate aquifers.

In the UK, operators have to seek permission from the Environment Regulator (EA in England, SEPA in Scotland) before they can introduce any fluids or chemicals into the ground under rules designed to protect groundwater resources. This is part of a suite of up to eight environmental permits operators have to apply for connected to 17 EU directives.

The Environment Regulator is the statutory body that controls what chemicals can be used, The EA policy for example is detailed below.

Under EPR Schedule 22, paragraph 6 we must take all necessary measures to: (a) prevent the input of any hazardous substance to groundwater; and (b) limit the input of non-hazardous pollutants to groundwater so as to ensure that such inputs do not cause pollution of groundwater.

The Environment Agency would not authorise the use of a hazardous substance for an activity, including hydraulic fracturing.

The pollutants the Environment Agency are concerned with for groundwater are:

  • - ‘Hazardous substances’, which are substances or groups of substances that are toxic, persistent and liable to bioaccumulate, and other substances or groups of substances that give rise to an equivalent level of concern (EPR Schedule 22, paragraph 4)
  • - Any non-hazardous pollutants, which is ‘any pollutant other than a hazardous substance (EPR, Schedule 22, paragraph 5).

Substances on List I of the Groundwater Directive (80/68/EEC) are taken to be hazardous substances. 

The list of proscribed chemicals is here. The labelling is simple,
List 1= Hazardous, and there for not permitted under any circumstances and.  
List 2 = Non Hazardous pollutant. Permitted for use as long as steps are made to avoid it

There have in fact been numerous studies of groundwater in the Pennsylvania region and further afield. For example:

  • - The most comprehensive study ever carried out by the US Environmental Protection Agency (12). This took five years and covered more than 38,000 oil and gas wells in the US in which they could find no evidence that hydraulic fracturing has “led to widespread, systemic impacts on drinking water resources in the United States.”
  • - Molofsky et al. (2013), who studied over 1,700 wells in Pennslyvania, with some that included baseline conditions, and found no correlation between methane and shale gas wells (and found correlation instead with topography, implying a natural methane source).entering ground water.
  • - A study of 230 water wells made by the Centre for Rural Pennslyvania, which found no impacts from shale drilling.
  • - A baseline study made by the USGS in undrilled parts of Sullivan County, PA, which recorded similar levels of naturally occurring methane to those found by Osborn.
  • - A second baseline study made by the USGS across the Pennsylvania-New York border, which again recorded similar levels of naturally occurring methane to those found by Osborn
  • - The study performed by Warner et al. (2013) over the Fayetteville shale, Arkansas, which found no impact from drilling.

There have been a few examples of water contamination in the US - a recent report from Ohio University found some instances of water contaminated with natural gas. However, this was caused by faulty wells, not by the hydraulic fracturing (“fracking”) process. This indicates that water contamination can be prevented with strict regulation from Government and good well design and construction which in the UK is overseen by the Health and Safety Executive.

Chemicals used

Allied to the point above, it's vital to recognise that fears about hundreds of chemicals being used in a 'toxic cocktail' are just unfounded in the UK.  So far, at the only shale gas well to have been hydraulically fractured (at Preese Hall in Lancashire) the only additives used were a Polyacrylamide friction reducer (a non-hazardous polymer often used as a flocculant to remove solids in drinking water treatment and that readily biodegrades) and a salt tracer.  Although it's true that much larger ranges of chemical additives have been used in the US, partly as a result of weaker legislation, it's also true that operators have been experimenting with less chemicals and finding that it improves gas yields.

All chemicals used in the UK must be declared and published, a further disincentive to the use of problematic chemicals. Many service companies now offer frack fluids composed entirely of food-grade additives, so there is no requirement for chemicals to be used in order to achieve commercial gas production rates.

UK operators, in applying for the separate permits they need to manage waste from what are  considered 'mining operations', also have to declare the composition of any drilling muds and fracturing fluids they plan to use, along with the expected composition and quantity of any wastes.  They also have to set out their arrangements for managing the same, and it is all a matter of public record - in fact, the public are even invited to consult on the permit applications.  None of this is the case in the US.

The UK shale gas industry has committed to the full public disclosure of fracture fluid via the following guidelines, on a well-by-well basis. Information for fluid disclosure should include:

  • - Any EA/SEPA authorisations for fluids and their status as hazardous/non-hazardous substances.
  • - Material Safety Data Sheets information.
  • - Volumes of fracturing fluid, including proppant, base carrier fluid and chemical additives.
  • - The trade name of each additive and its general purpose in the fracturing process.
  • - Maximum concentrations in percent by mass of each chemical additive.
  • - The Public Disclosure of Fracture Fluid Form is shown in appendix 2 and will be downloadable from www.ukoog.org.uk

Produced water and flowback

In the UK, unlike in the US, wastewater will never be stored in open impoundment pits; this would simply not gain regulatory approval.  Instead, it will be stored in above-ground steel tanks (which can be more easily inspected for leaks, prompting an appropriate and speedy response where required) that are provided with adequate secondary containment to capture any spills and prevent them from reaching the surrounding environment.   Impoundment pits appear to be the biggest source of pollution incidents linked to shale gas extraction in the US.  Another significant difference is that wastewater will undergo appropriate treatment in the UK, after which it will eventually be safely released back into the environment to once again become part of the water cycle, whereas in the US, it is typically injected into underground disposal wells.

A proportion of the injected fracturing fluid remains in the target formation and doesn't flow back to the surface immediately after hydraulic fracturing has been performed.  However, over the 20-30 year producing life of a shale gas well, all of the injected fluid will eventually return to the surface to be taken away for safe treatment and disposal.  In the meantime, we needn't be concerned about this fluid escaping, as some suggest it might, and that's because the shale rock, whilst porous, is virtually impermeable which is why it needs to be stimulated to get the gas out.  The over-pressure from the surrounding rock, and lack of permeability, means the fluid - and gas, for that matter - only has one place to go, and that's to the low pressure area of the well.

Baseline Monitoring

One of the major issues about the research in other countries is that there has been a lack of baseline data by which to properly compare operational results. The industry believes through the establishment of a scientific based and transparent Environmental Baseline Assessment, the embedded control measures can demonstrate that the protection of the natural environment and disruption to local community is minimised during hydraulic fracturing operations. UKOOG has worked with the industry to develop a set of guidelines for the establishment of environmental baselines; such guidelines enable a ‘site condition schedule’ to be established against which permits can be granted and monitored for compliance by the regulators. This guidance has been scientifically reviewed by an independent group provided by the Society for the Environment and is now backed by the Infrastructure Act.

A number of the independent reports caution that reports and research often do not look at all the contributory factors to the results of post operational monitoring activities:

“Environmentally associated disease is rarely a case of single hazard-single impact. In general, environmental factors are on of several factors that interact to determine the probability of developing a clinical illness.” The Independent Panel for the Scottish Government

This is why it is critical to obtain proper baseline and operationally monitoring results in order to really understand what is causing what.

Health

There is a basic lack of understanding around process and regulations in how health is addressed within the planning and permitting system.

For all sites involving hydraulic fracturing in the UK an Environmental Impact Assessment (EIA) is completed and is used as part of the planning system in order to achieve planning consent and is also used in the environmental permitting system. Both these systems allow for significant public consultation and also involve public health bodies as statutory consultees. 

The founding principle and purpose of an EIA is to investigate potential environmental effects that may pose a risk to health at a development planning stage. Equally environmental permitting exists to regulate industrial processes to ensure that they operate within environmental standards set to protect health.

An EIA is to investigate environmental effects that may pose a risk to health including environmental health pathways. Health pathways for example include air quality and water quality and therefore an EIA examines a health pathway before it becomes a public health issue

The regulatory system in this country and the best practices of the industry follow international standards around the source – pathway – receptor model, i.e. it is not sufficient to have a hazard source alone; there must be a source-pathway-receptor linkage – there must be a plausible means whereby humans may be exposed to the hazard in sufficient quantities to cause harm. For instance a harmful substance (source/hazard) may not represent a significant possibility (risk) of causing harm to humans (or other receptors) if:

  • - There is no pathway (exposure route) by which receptors (humans) may encounter the substance physically or
  • - The concentration of the pollutant in the environment is so low that the substance cannot be inhaled/ingested or otherwise absorbed in a dose big enough to cause an adverse physiological or clinical impact to humans

For example, approval by the environmental regulator for the use of chemicals in the UK will only occur if consideration of the likely concentrations and pathways from a source to a given receptor is minimal. This is also why the environmental regulator insists on the use of non hazardous products.

The Independent Panel for the Scottish Government summarises “ it should be noted that the existence of a potential problem does not mean it will occur. There are numerous regulations and assessments in place to reduce or eliminate adverse occurrences”.

The industry is regulated by four separate regulators and has to adhere to 17 EU directives and up to eight environmental permits that span before, during and after operation. In addition to this there are numerous points for public consultation during the pre-consultation, planning and permitting processes.

Air Quality and Flaring

It is not disputed whether there are potential sources of air pollution during the shale gas extraction process. However, what is more important is whether these potential sources of pollution will actually create air quality issues.

VOCs are cited as a potential pollutant. Many papers have made extensive measurements of VOCs. For example Bunch et al. (2014) examined extensive air quality measurements made over the Barnett Shale, and did not find levels of air pollution that would cause concern. Similar surveys in Pennsylvania made by the PA DEP (2010) "did not identify concentrations of any compound that would likely trigger air-related health issues associated with Marcellus Shale drilling activities", and overall emissions inventories show a reduction in air pollution as power generation has switched from coal to shale gas (PA DEP air emissions inventory, 2011).

Flaring unwanted gas will only happen for a relatively short duration of about 30 days per exploration well, and it's only 'unwanted' because there is too much to use on site, but too little and for too short a time to warrant the investment and local disruption of installing a pipe connection to the national transmission system.  The flares used in the UK will be low level, and with an enclosed flame so as to minimise light and noise pollution.  The gas is burned at temperatures exceeding 800 degC, leading to at least a 98% methane destruction efficiency and giving rise to water and carbon dioxide emissions - not the nasty vapours some claim.  It is worth noting that this gas is the same as the gas burned on stoves in kitchens throughout the country, only that takes place indoors with no process controls and substantially less ventilation.  In the US, it is admittedly very different in some places: their flare design sees huge naked flames lighting up the night sky, and in remote North Dakota - where they're producing oil from shale - gas that is co-produced with the oil is cheaper to flare than it is to develop the pipeline infrastructure to get the gas away.

Normally Occurring Radioactive Material (NORM)

NORM management is not unique to shale gas extraction. In its review of the potential health impacts of shale gas, Public Health England considered NORM. It made the point that it is common for waste from oil and gas production to contain NORM.

There is a comprehensive regulatory regime for managing NORM; compliance with this regime should ensure that any public health impact is minimised. Even if a very large number of wells were drilled in the UK, the amount of radioactive materials produced would be a tiny fraction of that produced by work in the medical sector and universities.

In the UK, an environmental permit is required for accumulating, disposing of or receiving naturally occurring radioactive material (NORM) wastes that exceed very low concentrations. The Radioactive Substances act of 1993 and Environmental Permitting (England and Wales) Regulations 2010 and the Radioactive Substances Exemption (Scotland) Order 2011 provide regulation for the management of NORM.

The UK has built up considerable knowledge of how to deal with low level radioactive waste safely as a result of 60 years' experience producing electricity from nuclear energy.”

There has been some recent work by Almond et al. (2014), who examined this issue in detail, and found that “in no scenario was the 1% exceedance exposure greater than 1mSv – the allowable annual exposure allowed for in the UK”, and that “the radioactive flux of per energy produced was lower for shale gas than for conventional oil and production, nuclear power production and electricity generated through burning coal.”

Environmental Impact Assessment

Companies in the UK are now expected to undertake detailed Environmental Impact Assessments (EIA) before any drilling can take place.  These assessments make sure that environmental issues are raised when a project or plan is first discussed and that all concerns are addressed as it gains momentum through to implementation. Recommendations made by the EIA may necessitate the redesign of some project components, require further studies, suggest changes which alter the economic viability of the project, or cause a delay in project implementation.  Again, this is not yet a requirement in the US, where in some states it's possible to obtain all the necessary regulatory approvals to drill within two weeks of securing a lease granting access to a landowner's property.

References

(1) Planning Practice Guidance - https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/224238/Planning_practice_guidance_for_onshore_oil_and_gas.pdf 

(2) http://www.hse.gov.uk/offshore/notices/on_37.htm

(3) https://www.gov.uk/oil-and-gas-operatorship

(4) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/322319/FinancialGuidance.pdf

(5) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296949/LIT_8474_fbb1d4.pdf

(6) https://royalsociety.org/~/media/policy/projects/shale-gas-extraction/2012-06-28-shale-gas.pdf

(7) http://www.ciwem.org/media/1023221/Shale%20Gas%20and%20Water%20WEB.pdf

(8) http://refine.org.uk/research/hydraulic-fractures-rb-source/fractures-rb-source.aspx

(9) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/273997/DECC_SEA_Environmental_Report.pdf

(10) http://www.bgs.ac.uk/research/groundwater/quality/methane_groundwater.html

(11) http://www.ukoog.org.uk/images/ukoog/pdfs/ShaleGasWellGuidelines.pdf

(12) http://cfpub.epa.gov/ncea/hfstudy/recordisplay.cfm?deid=244651

 

DETAILED NOTES

Independent Reports

There have been a number of truly independent reports published over the last 12 months, which include the report for the UK government by Public Health England and for the Scottish Government by an Independent Panel of Experts. Both have concluded that in the context of UK regulation the risks are minimal:

“An assessment of the currently available evidence indicates that the potential risks to public health from exposure to the emissions associated with shale gas extraction will be low if the operations are properly run and regulated” Public Health England June 2014

“Many of these social (and environmental) impacts can be mitigated if they are carefully considered at the planning application stage. Added to which there are already considerable legislative safeguards to ensure such impacts are not realised” Independent Panel of Experts for the Scottish Government June 2014.

Public Health England, incorporating the Centre for Radiation, Chemicals and Environmental Hazards (Wales) and World Health Organisation Collaborating Centre for Chemical Incidents (formerly the UK Health Protection Agency) is a recognised authoritative body.

The European Parliament found that “possible health effects are mainly caused by the impacts of the relevant emissions into air or water,” but added that these are “potential effects” with actual effects “rarely documented”. Another European Parliament report concluded that: “No official or other reputable sources have demonstrated any systematic connection between shale gas and shale oil extraction and human or animal health." There have also been reports by the Royal Society and Royal Academy of Engineering and the Chartered Institution of Water and Environmental Management that have also concluded that risks are minimal and manageable.

UKOOG acknowledges that there are many reports in existence but cautions, as do independent experts, that many of the reports suffer from a number of issues including self-selection of sites, lack of peer review, size of surveys, leading questions, ignoring other influences within the same geography, anecdotal evidence and short term measurements against long term thresholds.

In addition many reports seek to rebut other reports. This must be very confusing and concerning for the general public and we therefore urge that reports from independent experts with no axe to grind are clearly the best route for the best information.

The Independent Panel of Experts for the Scottish Government commented:

“At the present moment in time many of these reports are ‘anecdotal’ in the sense that the observations have not been corroborated by objective study using factual evidence or properly quantified”.

Well Integrity and Barrier Assurance

The Health and Safety Executive (HSE) regulates onshore oil and gas operations for well integrity and occupational health and safety. Prior to any drilling activity, the operator must send its proposed well design to an independent well examiner. Once the design has been satisfactorily assessed by the examiner, the operator must then notify the HSE of the well design and operation plans. The HSE carries out its own review of these plans, taking into account any comments or recommendations made by the independent well examiner. The design of wells is regulated by the Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996 (DCR)[1]. These regulations include specific requirements for all wells, whether onshore or offshore, and include well integrity provisions which apply throughout the life of wells.  The design and construction of the well is key to subsurface environmental protection. Through the use of multiple physical barriers of casing and cement, as well as utilising natural impermeable geology layers as protection, the well will protect any migration of hydrocarbons or well fluids into the surrounding rock formation. Before hydraulic fracturing commences, the well will be tested for integrity and suitability for fracturing. 

The DECC will only allow operations to proceed once the HSE has assessed the drill programme, all relevant environment permits have been granted and planning permission is satisfied.

A weekly report is sent to the HSE showing progress with the well, as well as the results of integrity testing that is completed as part of the drill plan. (See also: - Independent Well Examiner section 4.1.3.1).  The HSE visit well sites on both an announced and unannounced basis to review operations as it deems necessary.

Financial capacity and environmental liability

There are a number of measures in place to ensure that operators have adequate financial capacity.

The first set of these measures is at the licence approval stage.  DECC’s guidance on operatorship states that the following assurances will be considered in applications for onshore operatorship: “In considering any request for operatorship, DECC will look at the competence of the company – more specifically the following factors: technical experience and capability to supervise, manage and undertake the proposed operation, their risk-assessment and hierarchy of decision-making, plans for public engagement and scope of relevant insurance coverage for operations and well abandonment activity. In some cases, DECC may request independent verification.”[i]  

The second set of assurances is at the well consent stage.  DECC’s “UK Petroleum Licensing: Financial Guidance” document states: “DECC’s policy requirement is to ensure that no well consents are issued unless we are satisfied that the licensee(s) has (have) access to sufficient funds to meet its(their) share of the actual drilling costs, the plugging and abandonment of the well if it is proven to be ‘dry’ or otherwise non-viable and a minimum contingency of 50% of the drilling costs.”[ii]

Secondly, there are a number of measures with respect to environmental liabilities that are worth highlighting.

The Environmental Regulator (EA in England, SEPA in Scotland and NRW in Wales) has the power to enforce the conditions in the environmental permits for a well or wells until the point in time that it accepts a surrender of those permits – the operator is not simply at liberty to hand back the permit.  For England and Wales, the permit surrender process is agreed with the Environmental Regulator, and for wells that are hydraulically fractured this is likely to include the need for a period of aftercare and monitoring of any potential residual environmental impacts.  The regulator may require the operator to supply a financial bond or other form of security for performance of its permit obligations.

With respect to the Minerals Planning Authority, planning consent for the site may also include planning conditions (which are legally binding) designed to ensure that the site is restored to its original surface condition at the end of operations.

DECC's consent is required under the terms of the operator's petroleum licence before a well can be decommissioned.  The decommissioning process must be done in accordance with a specification agreed with the HSE, with reference to the Oil & Gas UK best practice on well abandonment and with the oversight of the HSE and an appointed Well Examiner.

If a well is not decommissioned in line with the approved plan, the licence holder or well-operator at the time of decommissioning can be prosecuted by the HSE for non-compliance with HSE regulations, and this could be pursued even after the petroleum licence and environmental permits have ceased to exist.

Taken together, if a company causes damage, harm or pollution to the environment, they can be required under these regimes to remediate the effects and prevent further damage or pollution.  This is the same approach that applies to other industries.  Environmental regulators and planning authorities have the power to require upfront financial bonds to address these risks.  The industry does not wish to leave this to the taxpayer or the landowner.  As a less expensive alternative to upfront bonds, UKOOG is working with Government on the development of an industry scheme that will step in and pay for liabilities.

Finally, the Infrastructure Aill makes clear that landowners are not liable for any loss or damage which is attributed to the exercise of the right of underground access. 

Water

Water is a critical component in Hydraulic Fracturing and an important resource in facilitating onshore oil and gas in general. The industry believes water should be considered holistically throughout the planning, operational and waste management stages. The industry has established close relationships with Water UK and British Water, having also recently commenced an initiative to consider ‘Integrated Water Management for Onshore Oil and Gas’.

The Environment Agency (EA), which regulates shale extraction, has investigated the likelihood of groundwater contamination in detail and judged that the environmental risks at each individual stage of exploratory shale gas operation, after proper management and regulation, are “low”[2]. The EA will not permit activities if they are close to drinking water sources, such as groundwater from aquifers.

According to a joint Royal Society and the Royal Academy of Engineering report the risk of water contamination is very low provided that shale gas extraction takes place at depths of many hundreds of metres or several kilometres – which would be the case in the UK[3].

The Chartered Institution of Water and Environmental Management (CIWEM) also agree that risks to groundwater quality are generally considered to be low in the UK where the shale rock in question often exists at considerable depths below aquifers and gas would be required to migrate many hundreds of metres between source rock and sensitive groundwater[4].

With regards to interaction between shale and overlaying aquifers, a study by the ReFINE (Researching Fracking in Europe) project found that there was a less than 1% chance of a stimulated hydraulic fracture propagating upwards more than 350 metres, and that the maximum recorded distance was 588 metres. This study recommended that all horizontal fracking wells are drilled at least 600m below aquifers to minimize the risk of stimulated hydraulic fractures providing a pathway for natural gas to migrate upwards into aquifers[5].

Fears of water shortages arising from shale gas development have been overstated. The demand for water from onshore shale operators, even at high levels of activity, would be comparable to demand by other industrial useRs. The Strategic Environment Assessment undertaken for the 14th Onshore Oil and Gas Licensing Round[6] predicted that under a high activity scenario, annual water use could be up to 9 million cubic metres, representing far less than 1 per cent of total UK annual non- domestic mains water usage. Abstraction from other sources e.g. groundwater is assessed on a case by case basis by the Environment Agency only permitted in non-water stressed environments.  Technological advances are already being commercially utilised in the USA enabling recycling/re-use of Flowback fluid, subsequently reducing the water footprint.

Groundwater and Surface Water Environment       

 

Hydraulic Fracturing Fluids

Concerns about pollution of groundwater by hydraulic fracking fluidS are largely based on reports of past practice in the US. The regulatory position in the UK is very clear and operators are required to fully disclose all chemicals used in hydraulic fracking fluid to the Environment Agency under the Environmental Permitting Regulations 2010 (as amended). Well pads are required to have secondary containment to prevent spills and leaks entering groundwater. Regulators do not permit use of hazardous chemicals, which must be assessed on a case by case basis via the JAGDAG assessment methodology (examines persistency, bioaccumulation and toxicity). The composition of hydraulic fracturing fluids pose a very low risk to groundwater in the UK as they will only be permitted by the environmental regulator if determined as non-hazardous to groundwater.

Methane in Groundwater

As part of the establishment of a Site Condition Report, as required within the Environmental Permits, groundwater boreholes are sunk to establish levels of naturally occurring methane levels in groundwater and potentially their origin e.g. biogenic or thermogenic. Methane is naturally occurring in many groundwater deposits across the UK. The weight of scientific opinion is that the risk of methane migrating from shale rock many thousands of feet up natural faults and into aquifers is highly unlikely due to the impermeable layers above the target zone and also the requirement in regulation to provide assessment of the risks on a case by case basis. The risk of methane migrating into aquifers through natural fractures is also very low[1]4. As part of a DECC approved Hydraulic Fracturing Plan (HFP), the plan is also reviewed by the Environment Agency to review the geological target zone and potential risk to groundwater.   It should be noted that methane is not a pollutant and can be readily removed from groundwater in a water treatment process.

The British Geological Survey, through its work in establishing a national picture of the background methane in groundwater has initially concluded that natural methane levels in groundwater are widely prevalent, generally low and that surface seasonal changes have very low impact[7].

Waste Management - Disposal and treatment of flow-back water

Flowback fluid contains very low levels of Naturally Occurring Radioactive Material, minerals and salts which returns to the surface inside a multi- barrier well and is stored at surface within secondary containment. Flowback fluid has been assessed by the Environment Agency as a non-hazardous waste stream and can be controlled by operators at the surface with redundant storage capacity that complies with local permitting. Specific control measures are described in detail as part of an approved Waste Management Plan and Radioactive Waste Arrangements by the Environmental Regulator in accordance with the Environmental Permitting Regulations 2010 (as amended).

Disposal of fluids, derived from Oil and Gas activities, has been an accepted activity, where treatment and disposal in the UK has taken place for many years. The industry is fully committed to storing of flowback fluids in sealed tanks as stated in UKOOGs Shale Gas Well Guidelines[8].

Surface Water and Spills

The management of surface water on a site must comply with permitting arrangements established with the environmental regulator and with any conditions imposed by the minerals planning authority through planning consents. Operations must be designed to avoid any discharge of surface water into the local environment through appropriately designed bonding and near/sub-surface barriers. Localised spills must be contained within the site, such that they do not pose a danger to the local environment. A site must be designed such that any natural occurring surface water (rain/run-off) is captured and captained within the site, where it can be suitably treated or taken away to a designated waste treatment facility.

Groundwater protection

 

According to the joint Royal Society and the Royal Academy of Engineering report, at the time the report was produced, the available evidence indicates that the risk of water contamination in the UK is very low provided that shale gas extraction takes place at depths of many hundreds of metres or several kilometres – which would be the case here.

 

The Chartered Institution of Water and Environmental Management (CIWEM) also agrees that risks to groundwater quality are generally considered to be low in the UK where the shale rock in question often exists at considerable depths below aquifers - meaning that the gas would have to migrate many hundreds of metres between the source rock and overlaying aquifers.

 

With regards to interaction between shale and overlaying aquifers, a study by the ReFINE (Researching Fracking in Europe) project found that there was a less than 1% chance of a stimulated hydraulic fracture propagating upwards more than 350 metres, and that the maximum recorded distance was 588 metres. This study recommended that all horizontal fracking wells are drilled at least 600m below aquifers to minimize the risk of stimulated hydraulic fractures providing a pathway for natural gas to migrate upwards and contaminate aquifers.

 

In the UK, operators have to seek permission from the Environment Regulator (EA in England, SEPA in Scotland) before they can introduce any fluids or chemicals into the ground under rules designed to protect groundwater resources. This is part of a suite of up to eight environmental permits operators have to apply for connected to 17 EU directives.

 

The Environment Regulator is the statutory body that controls what chemicals can be used, The EA policy for example is detailed below.

 

Under EPR Schedule 22, paragraph 6 we must take all necessary measures to: (a) prevent the input of any hazardous substance to groundwater; and (b) limit the input of non-hazardous pollutants to groundwater so as to ensure that such inputs do not cause pollution of groundwater.

 

The Environment Agency would not authorise the use of a hazardous substance for an activity, including hydraulic fracturing.

 

The pollutants the Environment Agency are concerned with for groundwater are:

 

· ‘Hazardous substances’, which are substances or groups of substances that are toxic, persistent and liable to bioaccumulate, and other substances or groups of substances that give rise to an equivalent level of concern (EPR Schedule 22, paragraph 4).

· Any non-hazardous pollutants, which is ‘any pollutant other than a hazardous substance (EPR, Schedule 22, paragraph 5).

 

Substances on List I of the Groundwater Directive (80/68/EEC) are taken to be hazardous substances.  

 

The list of proscribed chemicals is here. The labelling is simple,

List 1= Hazardous, and there for not permitted under any circumstances and.  

List 2 = Non Hazardous pollutant. Permitted for use as long as steps are made to avoid it

 

There have in fact been numerous studies of groundwater in the Pennsylvania region and further afield. For example:

 

·         The most comprehensive study ever carried out by the US Environmental Protection Agency. This took five years and covered more than 38,000 oil and gas wells in the US in which they could find no evidence that hydraulic fracturing has “led to widespread, systemic impacts on drinking water resources in the United States.”

·         Molofsky et al. (2013), who studied over 1,700 wells in Pennslyvania, with some that included baseline conditions, and found no correlation between methane and shale gas wells (and found correlation instead with topography, implying a natural methane source).entering ground water.

·         A study of 230 water wells made by the Centre for Rural Pennslyvania, which found no impacts from shale drilling.

·         A baseline study made by the USGS in undrilled parts of Sullivan County, PA, which recorded similar levels of naturally occurring methane to those found by Osborn.

·         A second baseline study made by the USGS across the Pennsylvania-New York border, which again recorded similar levels of naturally occurring methane to those found by Osborn

·         The study performed by Warner et al. (2013) over the Fayetteville shale, Arkansas, which found no impact from drilling.

 

There have been a few examples of water contamination in the US - a recent report from Ohio University found some instances of water contaminated with natural gas. However, this was caused by faulty wells, not by the hydraulic fracturing (“fracking”) process. This indicates that water contamination can be prevented with strict regulation from Government and good well design and construction which in the UK is overseen by the Health and Safety Executive.

 

Chemicals used

 

Allied to the point above, it's vital to recognise that fears about hundreds of chemicals being used in a 'toxic cocktail' are just unfounded in the UK.  So far, at the only shale gas well to have been hydraulically fractured (at Preese Hall in Lancashire) the only additives used were a Polyacrylamide friction reducer (a non-hazardous polymer often used as a flocculant to remove solids in drinking water treatment and that readily biodegrades) and a salt tracer.  Although it's true that much larger ranges of chemical additives have been used in the US, partly as a result of weaker legislation, it's also true that operators have been experimenting with less chemicals and finding that it improves gas yields.

 

All chemicals used in the UK must be declared and published, a further disincentive to the use of problematic chemicals. Many service companies now offer frack fluids composed entirely of food-grade additives, so there is no requirement for chemicals to be used in order to achieve commercial gas production rates.

 

UK operators, in applying for the separate permits they need to manage waste from what are  considered 'mining operations', also have to declare the composition of any drilling muds and fracturing fluids they plan to use, along with the expected composition and quantity of any wastes.  They also have to set out their arrangements for managing the same, and it is all a matter of public record - in fact, the public are even invited to consult on the permit applications.  None of this is the case in the US.

 

The UK shale gas industry has committed to the full public disclosure of fracture fluid via the following guidelines, on a well-by-well basis. Information for fluid disclosure should include:

 

·         Any EA/SEPA authorisations for fluids and their status as hazardous/non-hazardous substances.

·         Material Safety Data Sheets information.

·         Volumes of fracturing fluid, including proppant, base carrier fluid and chemical additives.

·         The trade name of each additive and its general purpose in the fracturing process.

·         Maximum concentrations in percent by mass of each chemical additive.

·         The Public Disclosure of Fracture Fluid Form is shown in appendix 2 and will be downloadable from www.ukoog.org.uk.”

Produced water and flowback

In the UK, unlike in the US, wastewater will never be stored in open impoundment pits; this would simply not gain regulatory approval.  Instead, it will be stored in above-ground steel tanks (which can be more easily inspected for leaks, prompting an appropriate and speedy response where required) that are provided with adequate secondary containment to capture any spills and prevent them from reaching the surrounding environment.   Impoundment pits appear to be the biggest source of pollution incidents linked to shale gas extraction in the US.  Another significant difference is that wastewater will undergo appropriate treatment in the UK, after which it will eventually be safely released back into the environment to once again become part of the water cycle, whereas in the US, it is typically injected into underground disposal wells.

 

A proportion of the injected fracturing fluid remains in the target formation and doesn't flow back to the surface immediately after hydraulic fracturing has been performed.  However, over the 20-30 year producing life of a shale gas well, all of the injected fluid will eventually return to the surface to be taken away for safe treatment and disposal.  In the meantime, we needn't be concerned about this fluid escaping, as some suggest it might, and that's because the shale rock, whilst porous, is virtually impermeable which is why it needs to be stimulated to get the gas out.  The over-pressure from the surrounding rock, and lack of permeability, means the fluid - and gas, for that matter - only has one place to go, and that's to the low pressure area of the well.

Baseline Monitoring

One of the major issues about the research in other countries is that there has been a lack of baseline data by which to properly compare operational results. The industry believes through the establishment of a scientific based and transparent Environmental Baseline Assessment, the embedded control measures can demonstrate that the protection of the natural environment and disruption to local community is minimised during hydraulic fracturing operations. UKOOG has worked with the industry to develop a set of guidelines for the establishment of environmental baselines; such guidelines enable a ‘site condition schedule’ to be established against which permits can be granted and monitored for compliance by the regulators. This guidance has been scientifically reviewed by an independent group provided by the Society for the Environment and is now backed by the Infrastructure Act.

A number of the independent reports caution that reports and research often do not look at all the contributory factors to the results of post operational monitoring activities:

“Environmentally associated disease is rarely a case of single hazard-single impact. In general, environmental factors are on of several factors that interact to determine the probability of developing a clinical illness.” The Independent Panel for the Scottish Government

This is why it is critical to obtain proper baseline and operationally monitoring results in order to really understand what is causing what.

Health

There is a basic lack of understanding around process and regulations in how health is addressed within the planning and permitting system.

For all sites involving hydraulic fracturing in the UK an Environmental Impact Assessment (EIA) is completed and is used as part of the planning system in order to achieve planning consent and is also used in the environmental permitting system. Both these systems allow for significant public consultation and also involve public health bodies as statutory consultees. 

The founding principle and purpose of an EIA is to investigate potential environmental effects that may pose a risk to health at a development planning stage. Equally environmental permitting exists to regulate industrial processes to ensure that they operate within environmental standards set to protect health.

An EIA is to investigate environmental effects that may pose a risk to health including environmental health pathways. Health pathways for example include air quality and water quality and therefore an EIA examines a health pathway before it becomes a public health issue

The regulatory system in this country and the best practices of the industry follow international standards around the source – pathway – receptor model, i.e. it is not sufficient to have a hazard source alone; there must be a source-pathway-receptor linkage – there must be a plausible means whereby humans may be exposed to the hazard in sufficient quantities to cause harm. For instance a harmful substance (source/hazard) may not represent a significant possibility (risk) of causing harm to humans (or other receptors) if:

·         There is no pathway (exposure route) by which receptors (humans) may encounter the substance physically or

·         The concentration of the pollutant in the environment is so low that the substance cannot be inhaled/ingested or otherwise absorbed in a dose big enough to cause an adverse physiological or clinical impact to humans

For example, approval by the environmental regulator for the use of chemicals in the UK will only occur if consideration of the likely concentrations and pathways from a source to a given receptor is minimal. This is also why the environmental regulator insists on the use of non hazardous products.

The Independent Panel for the Scottish Government summarises “ it should be noted that the existence of a potential problem does not mean it will occur. There are numerous regulations and assessments in place to reduce or eliminate adverse occurrences”.

The industry is regulated by four separate regulators and has to adhere to 17 EU directives and up to eight environmental permits that span before, during and after operation. In addition to this there are numerous points for public consultation during the pre-consultation, planning and permitting processes.

Air Quality and Flaring

It is not disputed whether there are potential sources of air pollution during the shale gas extraction process. However, what is more important is whether these potential sources of pollution will actually create air quality issues.

 

VOCs are cited as a potential pollutant. Many papers have made extensive measurements of VOCs. For example Bunch et al. (2014) examined extensive air quality measurements made over the Barnett Shale, and did not find levels of air pollution that would cause concern. Similar surveys in Pennsylvania made by the PA DEP (2010) "did not identify concentrations of any compound that would likely trigger air-related health issues associated with Marcellus Shale drilling activities", and overall emissions inventories show a reduction in air pollution as power generation has switched from coal to shale gas (PA DEP air emissions inventory, 2011).

 

Flaring unwanted gas will only happen for a relatively short duration of about 30 days per exploration well, and it's only 'unwanted' because there is too much to use on site, but too little and for too short a time to warrant the investment and local disruption of installing a pipe connection to the national transmission system.  The flares used in the UK will be low level, and with an enclosed flame so as to minimise light and noise pollution.  The gas is burned at temperatures exceeding 800 degC, leading to at least a 98% methane destruction efficiency and giving rise to water and carbon dioxide emissions - not the nasty vapours some claim.  It is worth noting that this gas is the same as the gas burned on stoves in kitchens throughout the country, only that takes place indoors with no process controls and substantially less ventilation.  In the US, it is admittedly very different in some places: their flare design sees huge naked flames lighting up the night sky, and in remote North Dakota - where they're producing oil from shale - gas that is co-produced with the oil is cheaper to flare than it is to develop the pipeline infrastructure to get the gas away.

Normally Occurring Radioactive Material (NORM)

NORM management is not unique to shale gas extraction. In its review of the potential health impacts of shale gas, Public Health England considered NORM. It made the point that it is common for waste from oil and gas production to contain NORM.

 

There is a comprehensive regulatory regime for managing NORM; compliance with this regime should ensure that any public health impact is minimised. Even if a very large number of wells were drilled in the UK, the amount of radioactive materials produced would be a tiny fraction of that produced by work in the medical sector and universities.

 

In the UK, an environmental permit is required for accumulating, disposing of or receiving naturally occurring radioactive material (NORM) wastes that exceed very low concentrations. The Radioactive Substances act of 1993 and Environmental Permitting (England and Wales) Regulations 2010 and the Radioactive Substances Exemption (Scotland) Order 2011 provide regulation for the management of NORM.

 

The UK has built up considerable knowledge of how to deal with low level radioactive waste safely as a result of 60 years' experience producing electricity from nuclear energy.”

 

There has been some recent work by Almond et al. (2014), who examined this issue in detail, and found that “in no scenario was the 1% exceedance exposure greater than 1mSv – the allowable annual exposure allowed for in the UK”, and that “the radioactive flux of per energy produced was lower for shale gas than for conventional oil and production, nuclear power production and electricity generated through burning coal.”

Environmental Impact Assessment 

Companies in the UK are now expected to undertake detailed Environmental Impact Assessments (EIA) before any drilling can take place.  These assessments make sure that environmental issues are raised when a project or plan is first discussed and that all concerns are addressed as it gains momentum through to implementation. Recommendations made by the EIA may necessitate the redesign of some project components, require further studies, suggest changes which alter the economic viability of the project, or cause a delay in project implementation.  Again, this is not yet a requirement in the US, where in some states it's possible to obtain all the necessary regulatory approvals to drill within two weeks of securing a lease granting access to a landowner's property.

 



[1] http://www.hse.gov.uk/offshore/notices/on_37.htm

[2] ttps://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296949/LIT_8474_fbb1d4.pdf

[3] https://royalsociety.org/~/media/policy/projects/shale-gas-extraction/2012-06-28-shale-gas.pdf

[4] http://www.ciwem.org/media/1023221/Shale%20Gas%20and%20Water%20WEB.pdf

[5] http://refine.org.uk/research/hydraulic-fractures-rb-source/fractures-rb-source.aspx

[6] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/273997/DECC_SEA_Environmental_Report.pdf

[7] http://www.bgs.ac.uk/research/groundwater/quality/methane_groundwater.html

[8] http://www.ukoog.org.uk/images/ukoog/pdfs/ShaleGasWellGuidelines.pdf

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