This is an article by Morag Parnell that originally appeared in Perspectives magazine and is reproduced here with permission.
The processes used in "Extreme" or "unconventional" gas extraction are Hydraulic Fracturing (fracking), Coal Bed Methane (CBM) recovery, tar sands extraction and Underground Coal Gasification(UCG). By these methods energy extraction becomes increasingly intense and destructive and as the easier to extract resources become depleted, the countryside become increasingly devastated.
They are being vigorously challenged by a growing body of citizens across the world.
Some geologists say it takes more energy to extract these “extremes” than can be retrieved from them.
This article is concerned with the most immediate threats in the UK from shale gas and CBM recovery, and in particular with the development at Letham Moss near Airth, Stirlingshire, which Dart Energy has called its “Flagship “development. There are 16 wells already completed, with one operational and supplying gas to South of Scotland Electricity, and a present application for 22 new wells at 14 sites in this area.There are also indications that this may be the beginning of several hundred more wells in the future in this area and possibly thousands across the UK.
We are also concerned that “In 2009 and 2010 the (Coal)Authority received applications for, and granted, some 14 conditional near offshore UCG licenses to companies keen to pursue the technology further in Great Britain.” (see map).
In the UK, the planning authority may ask for an Environmental Impact Assessment (EIA) Such applications require consultation with public bodies to make an assessment of likely significant adverse environmental effects arising from a proposed development.
In the case of Coal Bed Methane extraction by Dart Energy at Airth, bodies consulted were Falkirk and Stirling Councils, five Community Councils (including Airth CC),Scottish Environmental Protection Agency (SEPA), Scottish Natural Heritage (SNH), Historic Scotland, the Royal Society for the Protection of Birds (RSPB), and the Health and Safety Executive (H&SE).
Public exhibitions were also held but were, by report, poorly attended.
These meetings are intended to discuss a variety of environmental concerns.
There is, however, one glaring omission!
In their fairly wide ranging choice of consultees, and although it is well known that there are considerable potential health concerns arising from such operations, they did not include any Public Health specialists. It might therefore appear that the planning process barely recognises people as part of the environment.
Yet according to the Public Health Act Scotland 2008, "there is a duty of Scottish Ministers, Health Boards and Local Authorities to protect public health “to continue to make provision, or secure that provision is made for the purpose of protecting public health in Scotland from infectious diseases; contamination; or other such hazards, which constitute a danger to human health; and includes the prevention of, the control of and the provision of a public health response to such diseases, contamination or other hazards”.
We need a Health Impact Assessment (HIA) for such developments.
There is also a lack of proper assessment of the contribution made by “Unconventional Gas” recovery to Climate Change.
It is widely trumpeted that burning methane creates about half the CO2 than even dirtier coal. True, if we only consider the burning. Taking into account the whole operation of drilling recovery, flaring, leaks, and according to reports, mainly from the US and Australia where such work has been going on for many years, there are many leaks- and a very different picture emerges, especially when we recognise that methane is about 25 times more potent a greenhouse gas than CO2.(1)
The inevitable conclusion must be that it is no longer acceptable to invest new money and resources in the recovery of fossil fuels, which have no long-term viability. If current rates of consumption continue they are almost certain to cause serious environmental damage and extraction is set to grow ever more expensive and ecologically destructive. To know this and still pursue this route is surely folly.
Investment must be directed to energy conservation and clean, locally managed renewable sources of energy, which we know will mitigate environmental harm and last indefinitely.
There are numerous reasons for objecting to the exploration and recovery of “unconventional gas”. Reason enough would be to prevent huge swathes of our wild and beautiful countryside from being devastated. However, we must also focus on the potential major existential effects of the use of fossil fuels on the health of humans and other species and on climate. Many of us, including the Women's Environmental Network Scotland, have for many years been at pains to show the link between these two major aspects of pollution - that from polluting the atmosphere with greenhouse gases and polluting our bodies with the products of burning the same fossil fuels and, in addition, from producing and using the hundreds of everyday products derived from them.
Climate and Public Health: two sides of one coin.
Because of the current explosion of interest in this technology in the UK, we might be forgiven for thinking it is something new. Yet according to Bamberger and Oswald (2), hydraulic fracturing was introduced in the US in the 1940s. Then it was a less destructive operation than now. Only vertical drilling with relatively small quantities of pressurised water was used. This allowed gas to be extracted from small deposits in denser rock like shale. The development of the ability to drill vertically and then horizontally allowed much greater access to small pockets of gas. It also required much larger volumes of water for each drilling - up to 10 million gallons per fracture. This highly pressurised (water is laced with sand (the proppant to hold open the cracks), and a large quantity of chemicals, about 2% volume, to facilitate the extraction.
Shale gas and CBM recovery use different techniques: CBM reservoirs are usually at depths of about 800 to 1,200 metres, shale gas at about 2,000 to 2,300 metres. Fracking is not routinely used in coal beds but is often used in difficult situations.
We have been reassured by Dart Energy that fracking will not take place in the Airth wells, but we know that fracking has been used for CBM when needed.
It is even less reassuring to know that Dart Energy have extensive holdings in Shale beds in Scotland and are ever ready to proclaim this to attract potential shareholders.
Dart Energy have said that it is pulling back from its Australian operations to focus its efforts in the UK, following Chancellor George Osborne’s support for unconventional gas in his last Budget.
Thousands of wells have been drilled in the US, Australia, China, India and some European countries.
It is surprising that few of us were that aware the first drillings started in Scotland in the mid 1990s
Coal Bed Methane Gas Extraction
Operations in Scotland so far have been in coal beds for Coal Bed Methane extraction. A process of “dewatering” the coal seams is used. This pumps out water and along with it the gas. The gas is then dried and the “produced” (dirty) water treated to remove toxins.
Varying volumes of water are pumped from each well. SEPA has set a limit of 300 cubic metres, nearly 66,000 gallons, per day from the current Airth site.
We do not know the levels of the chemicals in the “produced 'water. The only data available is that of the “treated” water, of which we have some from Dart Energy and a bit more from SEPA. The latter was helpful in response to our Freedom of Information requests but was limited by the information it held from Dart. Also, the company can withhold information because of “commercial confidentiality”.
Considering the information available from other researchers, mainly from the US and Australia, we know that the data we have is woefully incomplete.
What we do know, both from SEPA’s response to our FOI and from the Dart Energy website, is that chemicals present in the treated water include those extracted from the coal seams as well as those needed for the machinery and the process to operate smoothly.
Many of these chemicals are known to be highly toxic and are linked to much human and animal illness.
Some of the very few we have identified at Airth so far are: the ‘BTEX’ group of hydrocarbons, Benzene, Toluene, Ethylene, Xylene; arsenic,cadmium,mercury,ethylene glycol, methanol, and ‘NORMS'-Normally Occurring Radioactive Materials. (3)
They are (partially) extracted from the “produced” water and this so-called“treated“ water is then discharged into the River Forth.
Reports from other places tell of the produced water being held in ponds, used to suppress dust on roadways, for irrigation, used for brick making or dumped in waterways.
Although the daily amount of any toxin from an individual well is small, consider the amount from the well’s lifetime ( up to 15 years, although most gas will be extracted in the first few years), and the total number of wells. Although we can only speculate, the indications are that this could run to several hundred wells at Airth alone in the future, if allowed. Multiply again and again for the possible thousands across the UK.
In the US where there has been much more experience of these technologies than we have, Colborn and colleagues have compiled a list of 944 products, containing 632 chemicals, which are used across all natural gas operations. Of those identified
- 75% affect skin and eyes and respiratory and digestive system;
- 40-50% affect the brain and nervous, immune, renal and cardiovascular systems;
- 37% affect the endocrine system;
- 25% could cause mutations and cancer. (4) (5)
(NB. Totals add up to more than 100% because many of the chemicals have multiple effects).
We are told that the toxins extracted from the produced waste water are disposed of at an appropriate site by SEPA. However many have a commercial value so it is right to be vigilant as to their fate.
How much toxin makes a toxin?
The amount of a toxin allowed to be released into air, water, land, people and in products, has been based on the assumption that there is a cut off point below which there is no further effect of that toxin, or on a cost benefit analysis which assesses that the perceived gain to a population is greater than any loss to be experienced.
This is no longer a valid assessment for carcinogens or Endocrine Disrupting Chemicals (EDCs). There is almost universal agreement, including by the World Health Organisation, that there is no safe dose of a carcinogen.
There is no cut off point, no threshold for no effect. The risk may become very small but it does not disappear.(5)
EDCs are effective at extremely low doses of parts per billion/trillion (ppb/ppt).
Major reports have been published by the WHO and UNEP on Endocrine Disruption(6) along with those from the world’s leading body of endocrinologists-The Endocrine Society,(7), the European Commission (8) and many independent biologists, toxicologists, physicians, epidemiologists and others.
These Reports draw attention to the following: our natural hormones and other biochemical reactions occur in our bodies at very low doses - parts per billion, ( ppb), and parts per trillion, (ppt,) levels at which endocrine disrupting chemicals, EDCs, substances with hormone-like properties, can have far reaching effects at the level of our cells ( the mechanisms differ from the direct toxic effects of higher doses) and can programme an exposed individual for future serious illness.
They also recognise the importance of the timing of exposures; The more vulnerable periods-in the foetus, infancy, puberty, pregnancy; the cumulative effects of multiple substances; repeated exposures over time, and other vulnerabilities.
Conventionally risk and “permissible” “safe” even so called “normal” doses are based on calculations of average doses to an average person. What has become clear is that in this context there is no such thing as an average dose nor an average person.
Although REACH ( Regulation, Evaluation, Authorisation and restriction of Chemicals) in Europe is very slowly and partially addressing this. Wide research evidence shows links between such exposures and what have been deemed to be our modern epidemics: cancer, damage to the nervous system, learning and behaviour problems, including ADHD, male and female reproductive disorders, disruption of the immune system, disorders of growth and metabolism, including obesity and type 2 diabetes, circulatory and respiratory disorders.
This emerging knowledge makes an urgent new approach to regulating toxins essential.
Because of the latency periods for the development of some of the disorders mentioned, particularly for reproduction and cancer, many of the most serious health effects are yet to be seen.
This is of particular importance for children, who are most susceptible, and for the reproductive and even survival prospects for future generations(9)
Note too that the economic costs to any Health Service will be untenable. As has been said, “The cost of taking action will be great but the cost of inaction is incalculable.”
What about the workers?
Silica sand is a major component of the fracking process. Massive quantities are used and workers are at risk of high levels of exposure during multiple points of the fracking process, putting them at risk from silicosis.
A recent two-year US National Institute for Occupational Safety and Health (NIOSH) assessment, found that, among those exposed, 79% of samples for silica exceeded the NIOSH Recommended Exposure Limits.
In our FOI to SEPA, WENS asked the following questions:
- What monitoring will be in place for any potential health effects from contaminants;
- In the case of an accident, what information about the nature of potential toxic exposures will be available to rescue and medical staff;
- what identification is displayed on vehicles carrying contaminated water;
- what information is available to employees under COSHH (Control of Substances Hazardous to Health) and who is responsible for the safety and training of workers at all stages of the work.
So far we have had no reply and we cannot find any reference to such questions in Dart’s publications.
On 14th March 2013, the European Parliament approved, with one amendment, a detailed report on EDCs by the Environment Committee, which said: “The EU should act to reduce exposure to suspected hormone-affecting 'endocrine disruptors,’ which have been linked to recent increase in cases of impaired sperm quality, early onset of puberty, certain cancers and other disorders. Current rules should be closely examined with a view to updating or proposing new legislation by June 2015 at the latest.” It was adopted by 489 votes to 102, with 19 abstentions.” It is a non legislative resolution.
MEPs stress that current science does not provide a sufficient basis for setting a limit value below which adverse effects do not occur. Therefore, endocrine disrupters should be regarded as "non-threshold" substances, with any exposure to such substances deemed to entail a risk unless the manufacturer can provide scientific proof that a threshold can be identified.
MEPs also noted that endocrine disruptors should also be treated as "substances of very high concern" in the EU's "REACH" rules.
It does appear that much of Europe and the rest of the world is waking up to the threat to all of us from our addiction to fossil fuels.
Now for the good news
Opposition to unconventional gas operations has grown very fast from citizens across the UK. At Moodiesburn a planning application for CBM was defeated by opposition from the community.
Towards the end of 2012 a few people in Falkirk, concerned by the developments they were seeing in the Airth area, formed a campaign group of local people, now morphed into Falkirk Against Unconventional Gas. A vigorous campaign followed resulting in ( at the time of writing and growing) over 700 objections to Dart’s planning application and 1500 copies of a Community Mandate signed by local residents.This has caused such delays at the Council Planning department that Dart is now appealing to the Scottish Government. Find out and support the Falkirk campaign at their website (10).
- Methane Gas Emissions from Natural Gas Systems Howarth et al, 2012
- New Solutions Special edition on fracking 2013
- Parnell and Hamilton 2013
- Of the substances identified by their CAS numbers by Colborn only 353 currently have Chemical Abstract Service (CAS) numbers . These are IDs assigned to all chemicals with disclosed substance information and described in the open scientific literature. (5) www.endocrinedisruption.com
- Beir V11 Prepared by a body of International radiation experts and published by the US National Academies of Science.
- The State of the Science of Endocrine disrupting Chemicals 2012; publication of United Nations and Unites Nations Environmental Programme http://www.who.int/ceh/publications/endocrine/en/index.html
- European Commission publication 2012: ec.europa.eu/environment/endocrine/documents/
- June 2013. A report from the Royal College of Gynecologists has provoked a storm of comment. The report acknowledges the potential damage from a range of toxins to the mother and developing foetus. This is very significant for the UK as it is the first time a Medical Society here has made such a public statement, and although still guarded, it is welcome. Unfortunately, both the media response and that from other quarters has been either hostile or very guarded. http://www.rcog.org.uk/