Special Digest


28/04/2015



Waste water injection now an official policy?

The seismic risk from the fracking process as evidenced in the US is said by the pro-fracking lobby to be irrelevant here, as the main evidence is that earthquakes have been triggered by injection of fracking waste water for disposal rather than fracking itself. They have always claimed that this will not be allowed here in the UK.

Is this true? The answer now seems a definitive NO. Until now the regulatory authorities have maintained that any application for waste injection would be closely scrutinised. Here's for example what DECC still say in their document dated 19th December 2013 "About shale gas and hydraulic fracturing (fracking)"

"...large scale re-injection of frac disposal fluids poses a recognised earthquake risk and, if proposed in the UK will be closely scrutinised)."

That has been the official UK position - NOT a ban as has been claimed, with wastewater injection banned by EU law. (Of course if the pro-frackers insist that any injection of fracking wastewater IS banned in the EU then fine, this will be just one more nail in UK fracking's coffin!)

In August last year it was confirmed that a Yorkshire well was given a permit for waste injection - see our fracking digest report Injection Wells Coming For Shale?.

This year we have seen two permits in the Fylde for Preston New Road and Roseacre Wood shale wells giving approval for wastewater injection - or "recycling" as it is somewhat euphemistically called. The rationale for this - despite the endless promises we have heard over the years that in the UK injected fracking fluids would ONLY contain specifc non-hazardous named components - is that harmful substances VOCs (Volatile Organic Compounds), BTEX (benzene, toluene, ethylbenzene, xylene), radioactive TENORM (Technologically Enhanced Naturally Occurring Radioactive Materials) etc all collected from the shale and returned to the surface in toxic wastewater can be reinjected for the simplistic reason that's where they originated in the first place.

Now we have further confirmation of Environmental Agency policy, courtesy of David Smythe.

From an email by the Environment Agency South East Press Office 10th February 2015 - maybe not coincidentally just before the Infrastructure Act received royal assent, making it legal for the industry to leave any substance down fracked wells as a byproduct of their activities -
"Operators may re-inject produced water back into the geological formation either to stimulate production or for disposal. This reinjection is allowed under Environmental Permitting Regulations (paragraph 8(a) of schedule 22 EPR 2010). The intention is to allow for the return of water naturally present in geological formations."

The regulation referred to in the above reads -
"8. Despite paragraph 6, provided it does not compromise the achievement of any of the environmental objectives relating to groundwater in Article 4 of the Water Framework Directive, the regulator may grant an environmental permit foró
(a)the injection of water containing substances resulting from the operations for exploration and extraction of hydrocarbons or mining activities, and injection of water for technical reasons, into geological formations from which hydrocarbons or other substances have been extracted or into geological formations which for natural reasons are permanently unsuitable for other purposes, provided that the injection does not contain substances other than those resulting from the above operations,"


The Infrastructure Act has confirmed this creation of underground fracking waste dump sites is entirely legal as a byproduct of oil/gas activities. The only restriction appears to be injection into the same formation the waste came from.

The worry, of course, is not just of seismic activity which could damage surface property and infrastructure. The concern is that even relatively small seismic activity may affect the integrity of fracking wells, also that fracking and reinjection will open up existing faults creating in time pathways for migration of spent fracking fluid, with enhanced levels of pollutants reaching the surface or aquifers.

In a recent paper David Smythe contested a report from Cuadrilla which identified the fault which fracking stimulated to cause the 2011 earthquakes. Although the location was agreed, the orientation is disputed, and Professor Smythe says -

"I have re-interpreted the fault position to honour the seismic data, as shown by the solid red line in Figure 2. This version is consistent with the earthquake focal plane solution, and intersects the wellbore. It also shows that the fault runs through the well in the zone where the well casing was deformed."

Professor Smythe also draws attention to a recent presentation by Professor Styles of Keele University at Davos in March 2015, where Styles clearly from his slide presentation indicates that there should be a minimum separation distance from fracked wells of at least 850m and perhaps up to 5,000m from significant faults.

This has not been adopted as regulatory policy nor as far as we can tell in industry's own practice guidelines. No wonder. If this stand-off distance were observed then the applications outstanding in the Fylde could call for immediate refusal on these grounds alone.

Equally to the point, as an aside regarding stand-off distances, the European Union recommended rather than legislated for governments to define separation distances between fracking pads and residential areas. The government has turned a complete blind eye to this. Again unsurprisingly as residential property at Roseacre Wood and Preston New Road is within the very small distance of 180 metres to 260 metres of the proposed fracking sites, outrageously short separations which would be unlawful in some US states.

But back to the main point, we have not heard the last of the seismic risks due to fracking, despite the much-vaunted "traffic light" system, and we have not heard the last of the dispute regarding reinjection of returned fracking wastewater.


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