Fit for fracking

9th February 2017


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Author

Alan Wilson

Lucie Ponting looks at the issues facing practitioners working to minimise the risks of onshore gas operations

The decision by the government last October to overrule Lancashire County Council and allow onshore gas operator Cuadrilla to drill at its Preston New Road site is further evidence, if it were needed, of the strength of its commitment to shale gas extraction. This latest move – alongside Third Energy’s planning consent for a site near Kirby Misperton in North Yorkshire, which is being challenged in the High Court – makes it likely that hydraulic fracturing will again be under way in England by the end of this year.

Public disquiet over fracking, including opposition from local communities and environment groups, persists. Amid this, environment practitioners are taking pivotal roles to identify, minimise and control the risks associated with the process and ensure the shale gas operators meet the necessary standards.

Steve Thompsett, executive director of UK Onshore Oil and Gas (UKOOG), which represents the operators, says: ‘Without environmentalists scrutinising the industry, looking at the process, asking the questions and trying to assess where the risks are, we would all be learning by our mistakes,’ he says. ‘That is to an extent what has happened in the US. In the UK, we keep ahead of the curve by engaging openly on environmental matters. What we have here is an opportunity to say, “These are what we believe are the most significant risks and this is what we should do to address those”.’

Effective management

Whether working for the operators, independent consultancies, regulators or other stakeholders, environment practitioners are key players at all stages, from planning and understanding the makeup of sites to advising on operations and ultimately decommissioning and site restoration.

An obvious question in any emerging sector is whether current methods, technologies, skills sets and regulatory safeguards are adequate to deal with the risks. The government and regulators are clearly confident this is the case for hydraulic fracturing. A much-quoted report from 2012 by the Royal Society and Royal Academy of Engineering concluded the health, safety and environmental risks associated with fracking ‘can be managed effectively in the UK, as long as operational best practices are implemented and enforced through regulation’. Along similar lines, the House of Commons Environmental Audit Committee (EAC) stated in January 2015: ‘Evidence from a range of government bodies and independent scientific institutions is generally in agreement that fracking can proceed in the UK safely and without harm to the environment provided proper environmental safeguards are introduced and adhered to.’

John Barraclough, senior adviser in the Environment Agency’s onshore oil and gas programme and a member of IEMA’s Midlands steering group, says all the usual principles of environmental protection and the associated risk assessment tools applicable to industrial regulation and water protection are also broadly pertinent to the sector. ‘We understand the oil and gas industrial process and techniques, and have been through a rigorous learning process on fracking and assessed the risks. We have expert hydrogeologists and other technical people to assess applications and enforce permits.’

Within the industry, Thompsett believes there is also ‘very good knowledge’ of the risks and tools and techniques to control them. ‘We develop conceptualised site models of the existing environment – both surface and subsurface – to understand how everything interacts, and carry out hydrogeological risk assessments to understand the vulnerabilities of water. We have the tools we need to understand risk. What we then have to do is gather the evidence and monitor to prove that we’re complying and not exposing the environment to unnecessary risk.’

Not so different?

The key environmental concerns arising from the fracking process, according to the British Geological Survey (BGS), include:

  • carbon dioxide and methane emissions, particularly the potential for increased fugitive methane emissions during drilling, compared with drilling for conventional gas;
  • the volumes of water and chemicals used and their subsequent disposal;
  • the possible risk of contaminating surface water and groundwater; and
  • the physical effects of fracking in the form of changes in seismic activity.

To this list, the EAC added habitats and biodiversity, and noise and disruption to local communities. Broader issues a planning authority should consider include dust, overall air quality, lighting, visual intrusion, landscape character, archaeological and heritage features, traffic, risk of contamination to land, and site restoration and aftercare.

Thompsett argues that, for surface work, the risks from shale gas extraction – noise, dust, disruption, transport, visual issues, surface water pollution – are broadly similar to other types of industrial development. Even at the subsurface, although there are some specific exceptions, the work is not so different from conventional oil and gas operations.

‘All the environmental issues associated with development proposals have to go through the same checks and balances and permitting,’ he says. ‘The surface risks are fairly standard stuff in terms of development but the monitoring and controls have to be relevant.’ When it comes to subsurface risks, he acknowledges that the challenges are more unusual. ‘It’s about how the industry interacts with groundwater, with the geology, and the types of substances that might be used subsurface and how these interact within the well and local geology. The need to undertake hydrogeological risk assessment, for example, is very clear when high-volume hydraulic fracturing is being considered.’

No blanket coverage

Most of the environmental practitioners who manage subsurface risks and stimulation are already likely to have experience in conventional oil and gas. There is also the broader role of the hydrogeological experts and geologists, many of whom have environmental expertise and can apply their skills to the unconventional onshore industry. ‘For the surface assessment, development and monitoring activities, it’s more standard,’ says Thompsett. ‘They don’t need to be oil and gas experts.’

Gillian Gibson, a consultant and chair of IEMA’s professional standards committee, has been involved in health impact assessments (HIAs) for the sites at Preston New Road and nearby Roseacre Wood, which Cuadrilla also wants to develop. She accepts the similarities with conventional oil and gas extraction, but points out that there are also ‘a lot of issues people have not previously been required to address’. Offshore, for example, there is no comparable impact on communities in terms of traffic, noise and the landscape.

Gibson’s key piece of advice to environment professionals, and anyone involved overseeing the sector, is to keep in mind that each case is different. ‘Don’t go for blanket coverage,’ she warns, ‘because one size does not fit all.’ The two Cuadrilla sites illustrate this point perfectly. Although they are only about 5 km apart, they raise very different issues, particularly for local communities. ‘The process of fracking is very similar, but there are vast differences in terms of how rural the sites are, transport links, site access, potential waste disposal issues and background noise levels,’ Gibson says.

Barraclough agrees, and points to the Environment Agency’s publication, Onshore Oil & Gas Sector Guidance, first issued in August 2016. ‘The industry now knows what to expect [when applying for permits]; what we will be asking to see. But ultimately each application is decided on individual merits. Overriding principles apply but it’s all based on site-specific assessments.’

Gibson also urges practitioners with different areas of expertise not to be insular. ‘We need to get out of our silos and look at how this process impacts everything,’ she says. ‘The social, economic, public health, and environmental aspects are all important. We need to look at the cumulative impacts, the totality – how it affects the community and what it means, and this is where the HIA can help in pulling together all the different strands.’

Traffic lights

Two of the most common concerns are the potential for groundwater contamination and seismicity. The Royal Society’s report suggested the risk of fractures propagating from shale formations to reach overlying aquifers was ‘very low provided shale gas extraction takes place at depths of many hundreds of metres or several kilometres’. It argued the more likely causes of contamination include faulty wells, and leaks and spills associated with surface operations. It stated that well integrity ‘must remain the highest priority to prevent contamination’.

In view of this, UKOOG has produced industry guidelines on best practice for shale wells. The Health and Safety Executive, which has an agreement with the Environment Agency on working together to regulate unconventional oil and gas developments, is responsible for regulating well integrity and has a long history of dealing with conventional wells. Disclosure of the constituents of fracturing fluid is mandatory and the environmental permits include conditions that require substances used in associated hydraulic fracturing to be approved by the relevant regulator. Fluids returning to the surface through the well – known as flowback and produced waters – are categorised as mining waste, so the operator must have an environmental permit for their disposal and an agreed waste management plan. Wastewaters may contain naturally occurring radioactive material (NORM) present in shale but NORM management is not unique to shale gas extraction.

‘From the water point of view, the crucial difference between hydraulic fracking and conventional oil and gas extraction is the sheer volume of water used,’ says Jim Marshall, policy and business adviser at Water UK. ‘A fully fractured site could take 20 mega-litres, which is sizeable, especially if there are several operators in the same water supply area. The other issue is the wastewater that comes back – what you don’t tend to get from conventional sites is the flowback water – and how that is managed.’

Seismicity is a concern that has arisen mainly from experiences in the US and incidents in the UK in 2011 when Cuadrilla suspended operations in Lancashire after two earthquakes of 1.5 and 2.3 magnitude. Research concluded it was ‘highly probable’ the test drilling had triggered the quakes.

A panel of government-appointed independent experts subsequently estimated that the UK geology would preclude any earthquake of more than magnitude 3 – a size that occurs three to four times a year in any case – being triggered by fracturing. In response, the Oil and Gas Authority (OGA) has imposed a traffic light system, which triggers a ‘red light’ if tremors or quakes of magnitude 0.5 or above are recorded. Thompsett says: ‘If operators hit that, which is set very low, they have to stop pumping and listen for up to 24 hours and report all findings to the OGA.’

Back to baselines

The degree of public concern makes rigorous monitoring and reporting more critical than ever. Baseline monitoring is a key part of this, and something that was lacking in the US in the early days of the fracking industry. ‘One of the problems in the US,’ says Barraclough, ‘is that when methane was found in the water it was very difficult to determine the source – whether it was actually from shale – so we’re keen to make sure we have baseline environmental information in the UK to identify any changes.’

The Infrastructure Act 2015 includes a specific provision that hydraulic fracturing consent cannot be issued unless the level of methane in groundwater has been or will have been monitored in the 12 months before the fracking begins. The Environment Agency includes specific baseline, operational and other monitoring requirements in its permits, and UKOOG has produced its own industry guidelines on establishing environmental baselines.

Outside this, the BGS is carrying out regional studies of baseline conditions of groundwater, seismicity, air quality, soil gas and radon to establish whether changes that occur can be linked to hydraulic fracturing and will continue during extraction and after completion. BGS is providing independent monitoring as well as the permit requirements at the Kirby site as part of a government-funded project.

UKOOG is currently looking at best available techniques (BAT) for establishing baselines and for operational monitoring. ‘In terms of receptors, there’s groundwater, air, soil and so on, and many ways of collecting information,’ says Thompsett. Added to these are opportunities to establish efficient and effective BAT for monitoring for the production phase. The importance of this is evident in the US, where there have been lawsuits over the efficacy of techniques to monitor methane leaks from pipework. ‘There’s a need to make sure we have the appropriate equipment and skills to collect the right information throughout the life of the activity,’ Thompsett says. ‘It’s not only what you look at but also the equipment you use to look at it with.’

Another challenge for environment practitioners, given public concern, is how to communicate information, including monitoring data to stakeholders in a useful, measured way. ‘Transparency will be key, but this means putting out data that is properly calibrated and interpreted,’ says Thompsett.

Barraclough adds: ‘Once sites are operating, the public will require monitoring information. It’s the operator’s role to provide this reassurance.’ Reinforcing the importance of sound interpretation and analysis, he says: ‘There is a long list of parameters, and the meaning of raw data may not be obvious to a layperson. There can be spikes in readings, for example, that are not in practice any cause for concern.’

Keep it cautious

Looking to the future, the Royal Society’s report concluded by cautioning that there was ‘greater uncertainty about the scale of production activities should a future shale gas industry develop nationwide’ and ‘attention must be paid to the way in which risks scale up’. It further warned that co-ordination between the numerous bodies with regulatory responsibilities must be maintained and regulatory capacity may need to be increased.

From the water perspective, Water UK’s Marshall also has concerns about scaling up: ‘This is where the biggest unknowns are. At exploration stage, with a handful of wells going up, it’s quite easy to give the appropriate scrutiny and attention. Keeping that level of scrutiny going when, and if, it turns into a more mainstream industry is something we need to bear in mind. Regulators such as the agency and HSE are going to have to adapt in terms of their resources and skills to meet the expanded scope as the industry matures.’

But he is optimistic that, by keeping a dialogue open with the industry and regulators, most of the concerns about scaling up, such as greater demand for water supply and treating more wastewater, can be addressed in the longer term. ‘If the commerciality is proven, this will also likely drive technical innovation and investment,’ he says.

The need for the industry, regulators and those environmentalists working in the sector to adapt and keep learning is clear. Responding to the Lancashire announcement, Mike Stephenson, director of science and technology at the BGS, said Britain needed ‘a cautious approach to shale gas development if commercial amounts of gas are found’. He added: ‘Regulation has to listen to the science and ensure that engineering is up to the job and that spills and leaks don’t occur. The science being done right now will provide regulators and government with the evidence they need to achieve that environmental assurance.’

Multi-regulatory control

The main regulators covering the environmental risks of unconventional gas extraction are the Environment Agency (and its sister agencies for Scotland, Wales and Northern Ireland), which issues environmental permits; the Oil and Gas Authority (OGA), which handles licensing; and the Health and Safety Executive, which oversees well design and integrity. The Mineral Planning Authority (MPA) – usually the county or unitary local authority – is responsible for planning permission and enforcement.

The OGA requires an environmental risk assessment (ERA) for proposed shale gas operations where hydraulic fracturing is planned as a matter of good practice. The ERA informs other evaluations, such as the environmental impact assessment, if the MPA decides any of these are required.

The Environment Agency permits can cover the protection of water resources, including groundwater; treatment and disposal of mining waste produced during borehole drilling and fracturing; treatment and management of naturally occurring radioactive materials; and disposal of waste gases through flaring.

The fracking process

Shale is a sedimentary rock with very low permeability and formed from deposits of mud, silt, clay and organic matter. The gas trapped in it is mainly – but not exclusively – methane. Because the gas does not readily flow into a well, additional stimulation, known as hydraulic fracturing or ‘fracking’, is used to access it.

The British Geological Survey describes the process: ‘After initial exploration of the shale deposits, a borehole is drilled into the shale horizon at a carefully selected site. It may be drilled horizontally to increase the volume of rock that can be accessed by the borehole. A process called hydraulic fracturing (fracking) is undertaken. This involves pumping water into isolated sections of the borehole at pressures high enough to fracture the surrounding rock. Sand entrained in the water helps to “prop” open the fractures, create permeability in the rock and allow the gas to flow into the borehole. Chemicals are also added to improve the efficiency of the fracking operation.’

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