Regulation and the report of the The Royal Society and The Royal Academy of Engineering, June 2012, part four
And here were my original detailed comments on the royals report recommendations that also didn't make it into Fracking the UK
THE REPORT’S RECOMMENDATIONS
Recommendation 1 To detect groundwater contamination.
The title of the recommendation is enough to persuade us that the report’s authors believe groundwater contamination IS possible.
They recommend that government regulators and BGS carry out comprehensive national baseline surveys of methane and other contaminants in groundwater. There is no indication on the map they provide of ANY existing groundwater methane analyses in Lancashire. This, of course, is necessary BEFORE any fracking takes place, and would be enough to postpone commencement of operations until the survey is complete. The recommendation goes on to say operators should carry out site-specifc monitoring, before, during and after operations.
The recommendation pays particular attention to the abandonment of wells and what happens afterwards. Clearly an operator is not going to commit to monitoring in perpetuity. Hence the post-production monitoring must be initiated AND PAID FOR by the state.
The report says “Operators are required to design, construct and operate wells so that they can be suspended or abandoned in a safe manner, after which there can be no unplanned escapes of fluids” After abandonment no further monitoring is currently required.
Clearly the authors do not believe this is adequate. In other words they do not believe that wells can be abandoned and not cause future problems, and they are therefore calling for new legal safeguards. They say “Monitoring arrangements should be developed to detect possible well failure post abandonment.” They note “Operators are responsible for wells once abandoned. Operators have an open-ended liability to remediate any ineffective abandonment operations. Consideration should be given to establishing mechanisms, such as a common liability fund, to ensure funds are available to respond to well failure post-abandonment in the case that the operator can no longer be identified.”
This would be an incentive for development companies to take their profits and close down their UK companies. Either wells will NOT go monitored into the future – and it could be many decades after fracking that wells might start leaching back up into groundwater, (despite the reports not accepting there is YET any evidence for this except through well failure) –OR the government will have to pick up the tab – another hidden cost to weigh against short term gain.
It’s worth noting that the report says “At present, the environmental regulator does not permit fracturing below freshwater aquifers.” BUT draws attention to the fact that this could change, in which a new set of regulations would be required. The report notes that at Preese Hall the overlying aquifer is saline. Is the whole of the Fylde without freshwater aquifers? If not then this would require close attention.
Recommendation 2 To ensure well integrity.
The detail thinking starts off encouragingly “The probability of well failure is low for a single well if it is designed, constructed and abandoned according to best practice.”
But then goes on to say that the existing well examination scheme must be adapted for onshore shale purposes. In other words this does not yet cover shale gas adequately.
The report notes that existing regulation requires operators to pay for a well examiner who should under 1996 regulation be sufficiently independent from the line management of the operator, as well as being competent. HOWEVER it does not prevent the well examiner from being a member of the same company as the operator. The report suggests the regulations should be amended so that a well examiner should work for a separate company. But even then what’s to stopa well examiner could not eg work for Cuadrilla Resources Holdings Ltd, or Cuadrilla Resources Ltd, when the op[eration is carried out by Bowland Resources Ltd. This is all unacceptable. Well examiners should be genuinely independent.
The report suggests that current requirements for well design to be extended to cover environmental perspective, rather than just H&S and pollution risks as at present.
The report notes that seismic activity caused damage to Cuadrilla’s Preese Hall well. This somewhat at variance with its playing down of seismic risks.
Recommendation 3 – to mitigate induced seismicity.
My first comment on this is that in the introduction the report states that “Concerns in the UK have focused on seismicity induced by hydraulic fracturing.”
To my mind this is contentious. Whilst an issue, for many of us it is one of many concerns, and not necessarily the most important. However, reading further in the report detail it is of more concern to me personally than it was before!
The report plays down the potential effect of any seismic event below scale 3. However, it also states that most quakes in the UK are at a depth of more than 10km. The April 1st quake at Blackpool was said to be at a depth of only 3.6km. On this single evidence it would have been worth considering how much greater the practical effect is when quakes are at this far shallower depth. The report claims that “Vibrations from a seismic event of magnitude 2.5 ML are broadly equivalent to the general traffic, industrial and other noise experienced daily”. However evidence from the Guardian report of the 1st April event in Blackpool – according to the report magnitude 2.3 – was enough to topple traffic lights, crack a railway bridge and shake property some distance from the epicentre.
The report states “There are insufficient data on faults in the Bowland Shale to support a definitive conclusion about whether seismic events similar to those at Preese Hall might occur in the future.” It suggests BGS carry out nation-wide surveys to identify faults. Currently only major faults have been mapped and minor pre-stressed faults that the Cuadrilla team hit in their ignorance are uncharted. They say that there is“the potential presence of faults that cannot be detected given the limits of seismic reflection survey.”
They add “There is no reliable way of detecting them but it may be possible to statistically predict the presence of such faults”. That seems clear enough. My conclusion is, with or without a full survey, earthquakes are likely to occur again.
The two seismic events at Preese Hall are identified in the report as being caused by those of 5 test frackings which had high pressure, high volume injection and low flowback. The other test frackings at lower pressures etc did not cause the same seismic events. This seems to me to illustrate exactly why we are able to say that fracking in deep shale (and – even worse - with horizontal drilling which hasn’t even been tested yet) IS different from any fracking that has gone on previously in the UK. I’d have to check the figures, but for example at Elswick I think the fracking injection pressure was something like 3000bpi but at Preese Hall was carried out at around 8000. And the injection volume would have been substantially less at Elswick - there seems no argument about the extra volumes of water shale fracking needs.
The report mentions the fact that the seismic activity at Preese Hall damaged the well.
It also mentions the risk of seismic activity in disposal wells, an issue which it does not explore in depth.
The report makes much of a traffic light monitoring system to detect seismology – green carry on fracking – orange level proceed with caution, red stop. Howeever the report makes no attempt to evaluate or to bridge the gap between Cuadrilla’s suggested trigger levels for colour change and the far lower thresholds in the DECC report on seismicity. It also suggests that traffic light systems are limited unless continuous monitoring is in place, and this is costly. In other words this recommendation is unlikely to be carried out.
So overall their recommendations for surveys, sesmic assessments and monitoring to be carried out and consideration given to how induced seismicity is to be regulated amount to next to nothing in view of the remarks I have picked on. My conclusion remains that we can expect fracking to hit more undetected pre-stressed faults and cause more “events”.
Recommendation 4 To detect potential leakages of gas.
In the recommendation itself is the first suggestion that emissions data would inform wider assessments, eg “carbon footprint”.
The report recognises there are complications with methods of measuring emissions. It recognises “green completion” can be used as in some of US to reduce (but not eliminate) carbon and methane emissions compared with venting and flaring.
Recommendation 5 Water should be managed in an integrated way.
By which the report means attempts to minimise water use should be made and treatment and disposal of wastes should be planned from the outset.
The report detail includes possible alternatives to freshwater which might be interesting to investigate, eg saline water and gelled liquid petroleum gas. It does not make any recommendation about disposal methods, but notes in the US it is common to inject waste onto disposal wells. The report admits it has not considered this issue in depth – “The construction, regulation and siting of any future onshore disposal wells need further investigation.”
but does consider possible seismic effects of disposal wells, noting and accepting US experience.
Recommendation 6 To manage environmental risks
All this recommendation consists of is for a mandatory Environmental Risk Assessment (ERA) for all operations, to assess risk at all stages pre and post production and for specific guidelines to be drawn up. This is not currently the case.
The report recommends the engagement of the local community at the earliest possible opportunity!
Recommendation 7 Best practice for risk management should be implemented.
This should be self-evident. But gain it is clear that there are measures needed to be put into force which are not there currently.
The report outlines a desirable goal-based approach, in contrast to a minimum standard approach which standardises practice and limits development of new risk assessments and management techniques. All sounds good, but there is too much reliance on a willing government and a willing industry.
Recommendation 8 is brief so here it is in full – “The UK’s regulators should determine their requirements to regulate a shale gas industry should it develop nationwide in the future. Skills gaps and relevant training should be identified. Additional resources may be necessary.”
In other words a new apporoach to fracking-specific regulations must be taken AND PAID FOR by government before industrial-scale extraction proceeds.
Recommendation 9 The bodies involved in regulation need co-ordination.
It should be clear where responsibilities lie, there should be more formal mechanisms to share information, and mechanisms.
If this has to be said, it’s clear this DOES NOT HAPPEN at the moment.
Hidden in the detail is ” A single body should take leadership to ensure co-ordination of the numerous central and devolved bodies with responsibilities for regulating shale gas extraction in the UK.”
The report confirms “Shale gas extraction was not considered when regulations for conventional gas extraction were formulated in the 1990s. There is no specific mention of shale gas in UK legislation.”
This is something that has to change. There are a number of comments on what might become relevant in the future to planning applications for shale gas operations, eg involvement of community in Minerals Planning Authories’ responses.
But at the end of the day this is not much more than a wish list.
Recommendation 10 (summary) More research is needed.
This really sums up the report’s overall message. We don’t know enough. It’s worth looking at a couple of the suggestions in detail.
“Uncertainties affecting the small scale exploratory activities in the UK can be addressed through effective monitoring systems and research programmes before shale gas extraction commences on any significant scale.”
BUT the detail recommendations for further research display an unrealistic expectation, eg
“monitoring the long term behaviour of wells, including after abandonment”
No prizes for spotting the fundamental flaw – how do they expect government and industry to wait for long term studies to complete before pressing for industrial scale go-ahead?
The report accepts “More significant uncertainties concern the scale of production activities should a shale gas industry develop nationwide.”
This is of fundamental interest, because the report expresses concern about the unknown effects of commercial shale gas exploration on climate change. It records that, although there is lack of clear data, the Cornell study concluded that the carbon footprint of shale gas extraction is significantly greater than conventional gas extraction because of releases of methane.
The report expresses uncertainties about the economic argument for shale gas, the quantity of onshore reserves, and – not least – that shale gas go-ahead will eliminate in the short term investment in renewable energy.
It says “It will be some years before shale gas production data and the impact of regulatory and economic conditions allow a rigorous estimate of the UK’s proven reserves of shale gas.”
The report suggests studies are necessary by various bodies in various areas. Including s survey of the public attitude to shale gas.
Here’s my considered response to the suggested study of public opinion. Onshore fracking for shale gas is the most stupid antisocial, antienvironmental crack-brained plan to step into the unknown for short term profit that I have come across in years. Don’t do it.
Continued in The Royals Report Part Five