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Regulation and the report of the The Royal Society and The Royal Academy of Engineering, June 2012, part three


Here were my original comments on the royals report summary that didn't make it into Fracking the UK

Para 1

“The health, safety and environmental risks associated with hydraulic fracturing (often termed ‘fracking’) as a means to extract shale gas can be managed effectively in the UK as long as operational best practices are implemented and enforced through regulation.”

This is what was seized on by lazy journalists to form their headlines. The only point to make is that the report is NOT referring to regulation and enforcement methods that are in place NOW. It is referring to what might be in place if its recommendations are carried out.

Para 2

“Hydraulic fracturing is an established technology that has been used in the oil and gas industries for many decades. The UK has 60 years’ experience of regulating onshore and offshore oil and gas industries.”

This is at the heart of the problem of objecting to fracking on technical grounds. Supporters of fracking have used, and will continue to use the argument that fracking is nothing new. But the reality is that shale gas extraction – unconventional gas – has not yet been carried out in this country. If it had been, the report might have concluded that no more regulation was required. But the authors are very aware that the differences between fracking shale gas and what has happened before are several, higher fracking pressure due to the extra well depth, increased water use with a different mix of chemicals, etc. The risks are detailed later in the report, so this comforter for the fracking fraternity is misleading.

The second paragraph refers to the AVAILABLE evidence showing there is no risk of fracking waste water (and 70-80% of fracking slurry just disappears below ground) percolating up to overlying water sources. It DOES, however recognise there are potential risks with faulty wells and leaks and spills related to surface activities. Again it is suggested that this is not a problem confined to shale gas extraction.

The third paragraph elaborates on this. It makes it clear that well examination schemes will have to be modified for onshore well activities. It says wouldn’t it be nice to be able to use non-hazardous chemical additives. Which, apart from being unrealistic avoids the issue of surface activities handling the waste frack slurry brought out of the wells and containing hazardous materials eg radioactive material. The important thing is, the paragraph admits there IS a risk of unforeseen leaks and spills.

The next paragraph deals with seismic effects of fracking, and concludes there is no problem. The detail of the report suggests even at 2.3M tremor level a quake is unlikely to be felt. It suggests that “traffic light monitoring systems” can reduce the risk. Maybe they mean like whether traffic lights fall down, as they did in Blackpool, the Guardian reported, 1st April 2011.

The next section begins with the sentence.

“Monitoring should be carried out before, during and after shale gas operations to inform risk assessments.”

And ends with

“Monitoring of any potential leaks of methane would provide data to assess the carbon footprint of shale gas extraction.

The first is self-evident, although it is worth noting that in the report detail the issue is raised of what happens AFTER a well has been capped and abandoned. There is currently no monitoring as the report recommends. The last sentence will cause anger who believe in the precautionary principle. And who understand the difference between a carbon footprint and a greenhouse gas footprint. Furthermore it says there is NO DATA currently available on fugitive methane emissions. And how can you monitor a “potential” leak?

Further discussion of risk management suggests adopting an approach to reduce risks to “As Low As Reasonably Practicable”. Presumably the reasonably practicable includes an economic rather than a purely risk assessment. The report says that an Environmental Risk Assessment should be mandatory for all shale gas operations, across the whole life cycle of extraction, including waste disposal, seismic risk and abandonment of wells.

The next paragraph considers water requirements can be managed and planned from the outset.

“Should any onshore disposal wells be necessary in the UK, their construction, regulation and siting would need further consideration.”

This is a big hole in the report. It has not considered the issue of waste disposal wells. This is significant because Cuadrilla has talked about the policy of drilling disposal wells, and so it is not of mere academic interest. Given that in the US it appears there is a growing realisation that seismic as well as pollution problems can be caused as much by drilling and injecting at high pressure waste wells as in fracking itself, this is an important issue.

The summary notes that naturally occurring radioactive material in waste water needs careful management, but again says this is nothing new to the industry.

The next paragraph confirms there are currently uncertainties, and today’s operations are very small scale, but repeats dependence on robust monitoring. It also calls for more research, as detailed later. It suggests that with moving to an industrial level of production risks “scale up”, which gives rise to concern. “Regulatory capacity” may have to be increased, in other words there are not currently enough monitoring resources to handle shale gas development.

The report concludes by ducking out and saying it is not their job to determine whether shale gas exploration should go ahead

It makes an important point, though, that the Government should ALSO consider risks associated with use of shale gas, AND climate risks. It says that more work needs doing to research public acceptability of all these risks.

Continued in The Royals Report Part Four

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