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Regulating the Frackers Just how robust is the legislative framework? Michael Hill B.Sc. (Hons.) C.Eng. MIET. © Michael Hill – ORIS.
Who and Why? Michael Hill B.Sc. (Hons.) C.Eng. MIET. Chartered Electrical Engineer Ex-oil and gas (wireline and seismic) 16 years in Oil and Gas Process Automation 3 year study into Shale gas regulation onshore Evidence submitted to DECC & Royal Society Developed DECC Response/RS Summary/ORIS/Nec Regs Consulted with/advised UK Gov, UK Regulators, Councils, Industry, Professional Bodies – BGS, IET, IGEM. Local resident in the key U.K. shale gas zone © Michael Hill – ORIS.
Hydraulic Fracturing– Is it new or old? 1.High Volume Hydraulic fracturing using slick water and other additives into lateral sections in unconventional reservoirs at high pressures is new ! Developed over the last decade. 2.Original Hydraulic fracturing into vertical wells located in conventional reservoirs at lower pressure is “old”. Developed in the US in the late 1940s. 3.The two are about as related as a small grocers shop and a hypermarket. 4.Conventional reservoirs generally allow gas/oil to flow easily once punctured. 5.Unconventional reservoirs do not generally allow gas and oil to flow easily (ultra low permeability) and so require HVHF. As in 20M litres of chemicals, sand & water per well to be introduced at various stages, at pressures in order of 6000psi and typically leave 50% of the fracking fluid in the target formation post frack. This is NEW not old. © Michael Hill – ORIS.
“Regulations are Robust” – Aren't they? © Michael Hill – GCAL. 1.UK Gov constantly stating regulations are robust. UK has best in the world standards. Prime Minister and Ministers precede each new statement with this line. 2.Regs developed Post Piper Alpha. Entirely self regulatory/goal setting. Primarily directed at protecting workers and plant. Crucially not public or countryside. Neither exist offshore. 3.Gov now determined to remove regulation (streamlining) to maximise interest from operators in UK onshore. OUGO offering tax breaks of 50% and overseeing wholesale scaling back of regulatory framework. OSD- scrapped. EA – 2 week permits (from 3-6months!) by Feb 2014. Same office in charge of both monitoring regulation and cheerleading for the shale gas industry. 4.HSE made zero visits to ensure the HVHF wells drilled by Cuadrilla Resources were constructed according to what had been agreed. – Well Integrity. Zero inspections. 5.EA “confused” as to what visits it has made and whether they were random or not. Does not verify fracking chemicals – what they are and in what concentrations. Trust the operator to say. Does not verify flowback quantity.
“EU Regulations are Robust”–Aren't they? © Michael Hill – GCAL. 1.EIA Directive - 2011/92/UE.( Precautionary principle). 1 Ha size and above. Industry easily avoids by making pads 0.9 Ha. No need for EIA at all. 4 exploratory pads close to my home. None with EIA. Precautionary principle means take precautions to ensure you do not need an EIA ! Where politically required then scoping doc brought in to significantly reduce the impact of the impact assessment! 2.WFD - 2000/60/EC (exemptions for oil and gas). Article 11(3)(j) Water injection. EU- view that exception does not apply. Member states do not agree! Clarification. 3.MWD - 2006/66/EC. (open to interpretation). Pushed for all waste to be inc. not just flowback. Finally EA relented but industry now fighting back. June Conf – Lawyers from London stating clarification urgently needed. They are being instructed by industry to re-open the MWD. In UK 3.7M litres from PH-1 went into Manchester Ship Canal after being “treated”. No treatment for NORM. New methods being sought. EA consider it standard industrial effluent. It’s not. Not when it can leak 5 miles below the surface!
“EU Regulations are Robust” –Aren't they? © Michael Hill – GCAL. 1.EA now reducing time to issue Permit from avg 3/6 months (to allow for full consultations and objections and due process) to 2 weeks under pressure from UK Gov and OUGO. (streamlining). 2.Article 1 – The competent authority may reduce or waiver the requirements for the deposit of non-hazardous waste. EA consider flowback fluid non-hazardous! Lead at 1438 times drinking water, Cadmium 36 times, Chromium 72 times, Arsenic 20 times, NORM at 90 times max permissible limit. This is “non-hazardous” according to UK competent authority! 3.MWD needs specific provision for exploration and exploitation of unconventional fossil fuels. Specific clarification of the points to ensure compliance is clear for all member states. Compliance with the MWD needs monitoring and enforcing across the EU. 4.Regulations/ Directives come to nothing if they are not monitored, not complied with and that non compliance is not policed, not punished, not reported ! 5.So is the UK system robust ? Is the EU system robust?
Why do we need Regs at all? 1.If well integrity not built in (cementing/casing) then the well will leak. 2.This leakage is vertical and horizontal. The vertical leakage is where fracking fluid and methane move up the outside of the casing (in the annulus between) and up to weakest formation. This represents the bulk of the risk initially post frack. 3.Horizontal leakage is out of the target formation and through faults/pores etc. over time. This represents the bulk of the risk over the long term (decades). 4.Leaks from flanges/valves etc. on surface – poor maintenance. 5.Can repair well if leak discovered :APs, CBLs, Acoustic gas detectors etc. 6.Wells need monitoring over their lifetime – and not just their commercial lifetime (which can be as short as twelve months as drop off can be rapid) © Michael Hill – ORIS.
So what if a well leaks- does it matter? © Michael Hill – GCAL. Methane is a much more potent greenhouse gas than CO 2 Approx. 20 times more. So all the green “advantages” of burning gas than coal eliminated in event of such leakage. Worse – It makes shale gas “dirtier”. Fracking fluids contain substances that if contaminating the aquifer then will spread over a large area (100s of km 2 ) and pose a significant threat to agriculture, wells and livestock – i.e. the food chain. Public Health.EU bans. Losses. Compensation. One well will leave 10 million litres of fracking fluid in the ground. Just one exploratory well leaking has the potential to cause widespread damage to the environment and poses a risk to public health. Just the one and only well fracked in the UK so far (PH-1) 200m from Weeton Village and 5 Km from Blackpool (pop 250,000) caused two tremors at 1.4 and 2.3 M L and damaged the well over a very large interval with severe deformation for 240 ft.
A Typical Well © Michael Hill – GCAL.
Flowback. Chemicals. Quantities. © Michael Hill – ORIS.
Flowback. Chemicals. Quantities. 1.Superpad 10 – 40 lateral sections © Michael Hill – ORIS.
Flowback. Chemicals. Quantities. © Michael Hill – ORIS. 75 miles X 50 miles. 3000 wells NG Magazine – March 2013.
PEDL 165 – 120 Pads – 3000 Wells © Michael Hill – ORIS. Production area approx. 30km X 30km
Flaring. © Michael Hill – ORIS.
Regulation in the U.K. – Needed Onshore specific regs: (Public and Environment) 1.Baseline methane, production and legacy, 2.flowback qty verification, flowback recycle, storage & disposal, 3.seismic TL, 4.bond for abandonment, 5.flaring, ORIS – New body required to Inspect, Tests and Verify. Planning Assistance, Public Liaison. Funded by levy with no taxpayer input. Need a robust inspection regime with maintained by random visits to CBL, FIT, Cementing etc. and testing of cement samples, mud, chemicals for fracking and verification of flowback qty etc. © Michael Hill – ORIS.
Radiation Wireline. Density uses gamma source Cs137 2 Curies. This is a category 3 source – Permanent injury/Death. Porosity uses Neutron AmBe-241 (8 – 23 Curies). This is a category 2 source – Death. Main Issues : Keep away whilst logging. Security. © Michael Hill – ORIS.
Traffic Traffic/ Standard pad. 20 M Gallons flowback. Avg 26T Tanker hold 26,000 L. Need 3,384 trips to dispose. Traffic/ Super pad. 80 M Gallons flowback. Avg 26T Tanker hold 26,000 L. Need 13,538 trips to dispose. This is just to dispose of flowback. 120 Standard pads – Approx. 406,080 initial trips. © Michael Hill – ORIS.
Traffic © Michael Hill – ORIS.
Regs for more than just leakage! So we need regulations for traffic and flaring too. Maybe EU considers these local state issues but if local states not protecting citizens then EU needs to step up and take responsibility. No need to flare off. Can green tank and separate, compress and transport off. Only need for safety flare (approx 1m height) not 20m but need to define the process and regulate it. Private companies will not do this without enforcement. Why should they? Hits profits, hits investment, hits share price – costs money and if your competitors not doing it then why should you? © Michael Hill – ORIS.
Conclusion Regulations need to be developed to cover exploratory, field development plan and production stages. Not just production! Fracking a few hundred meters from 2,500 homes in Lytham St.Annes. 20M litres/well. If well leaks then large area at risk. Existing regulations are not sufficient (or in need of additional clarification) for the new practice of intensive HVHF onshore and in close proximity to large urban conurbations. The inspection and monitoring needs a considerable amount of work to move from the self-regulatory model to a more balanced approach between prescriptive and goal setting. With frequent random inspections by completely independent monitors (commercially, reporting and technically). © Michael Hill – ORIS.
Conclusion Need enforcement to be coupled with compliance. Proportionate fines, licenses revocation and criminal proceedings. Shale gas and other unconventional fuels are seen by some (inc. entire UK Gov) as a fantastic opportunity for the member states but from my research I know it needs close monitoring to prevent an environmental catastrophe and serious risk to public health. EU must act now not wait for production. Exploratory phase is under way. Regs and monitoring needed in place now for this phase. To protect public and environment and to be ready for scale up to FDP and production. The directives need urgent updating and clarification to cope with this industry. This needs to be achieved with the assistance engineering/science to ensure relevance and effectiveness. © Michael Hill – ORIS.
And Finally… Shale gas and unconventional fossil fuels may make considerable revenues for member states. They may assist in energy security. They could help reduce CO 2 emissions. They could assist in a transition to renewables and carbon free power generation. It could be done in a safer manner. Not safe – but much safer. However, this is not happening. Not the way the EU and in my own state, the UK, are proposing to develop it. Quite the opposite. We are heading towards increasing CO 2 emissions, diverting valuable resources and attention away from renewables, risking public health, damaging the environment, destroying jobs (tourism/farming), industrialising whole areas of countryside, causing havoc to local communities (as in millions of people) and for what? To make some extra profit for the few at a great cost for the many. © Michael Hill – ORIS.
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