With Cuadrilla on the point of fracking the first well in the UK since 2011 we are more reliant than ever on the efficacy of regulations here in the UK. The UK fracking companies’ PR mantra is that regulation in the UK is far better than it is the USA and that therefore we will not suffer the same consequences here as they have across the Atlantic. However, it would seem that this is far from the case.
6 years ago, in March 2012 Newsnight ran an investigation into fracking and interviewed Chartered Engineer and local resident Mike Hill
You can see the report by following this link
Mr Hill has campaigned for a long time to ensure that if fracking is allowed to go ahead then we will be adequately protected by effective regulation.
Unfortunately, as things stand today the current regulatory environment is still manifestly inadequate. It doesn’t really matter whether you believe shale gas drilling could bring the economic advantages that Cuadrilla and their PR friends are trying to persuade us are awaiting us. It would be a serious dereliction of duty if the government were to allow fracking to go ahead without a properly defined and implemented regulatory environment.
Speaking in the parliamentary debate on Shale Gas Profits on 19th December 2012 , Preston MP Mark Hendrick, accused the Government of allowing a “cavalier approach” by failing to introduce adequate new regulation when it gave the industry the green light to start work again.
He said
The Secretary of State has made it clear that the exploratory and experimental phase that has been given the go-ahead for the next two years may yield results that highlight the need for new regulation. However, that amounts to using Lancashire as a guinea pig for the rest of the country. That is a cavalier approach to serious industrial activity.
Across in Canada, where they have the dubious privilege of having much greater experience of the fracking industry, Alberta’s Energy Resources Conservation Board (ERCB) spokesman Darin Barter, stated in January 2013
“There is no amount of regulation that can overcome human error”
He was referring specifically to an investigation report that cites inadequate management of risks as one of the main causes of a September 2011 accident that contaminated groundwater with toxic hydraulic fracturing chemicals, including the cancer causing agent known as BTEX (benzene, toluene, ethylbenzene, and xylene).
Cuadrilla meanwhile tell us that there is “no evidence of aquifer contamination from hydraulic fracturing” and that “All of our work is highly regulated”.
A typical shale gas well
Here are some of the things that need to be looked at:
Specific On Shore Gas Regulations
There is a clear need of specific On Shore exploration regulations. At present there are none. The offshore regulations developed in the 1990s (Borehole Site and Operations Regulations (BSOR) 1995 & Offshore Installations and Wells (Design and Construction). 1996 (DCR)) in the wake of the Piper Alpha disaster are not sufficient to address the issues with on shore drilling, exploration and production.
Verification
Independent (financially and professionally) verification, testing and inspection of the wells to meet the required onshore regulations is a sine qua non of safe shale gas extraction . Presently virtually all testing & inspection is self –regulatory. What is now required is a ‘hands on’ inspection regime of a type similar to that a number of US states have adopted. Each well needs to be inspected with both random and pre-arranged trips – approx 10/15 times whilst the well is being drilled and then “fracked”.
Specific areas that need regulation
Regulations need to cover cement quality via on site sampling and laboratory testing , cement bond logs, annular pressure readings (instruments used, calibration, how recorded in SCADA etc.), examination of formation integrity tests as they are executed, seismic monitoring , surface methane detection (baseline and operational), post tremor actions, publication of which “fracking” chemicals used at each well with MSDS, flow back water storage and disposal (Permit), recycling of flowback , flowback water quantity verification, green tanking, fugitive emission monitoring and reduction, bond for abandonment, sourcing water from mains (pressure issues) and testing of local boreholes/wells.
Effective Co-ordination of Regulatory Bodies
Overview – BEIS should appoint a person or body to oversee the regulation of the Shale Gas Sector in the U.K. Mike Hill has collated a number of examples of confusion and misunderstanding between the authorities with no one person taking on the responsibility. Each has a number of different roles to perform. To ensure all are performed an overview is needed so that the public can be given re-assurance and the regulators can be given logistical assistance when and where needed.
Compliance – The regulations should be implemented through random and agreed on site visits when key actions (like cementing) are happening. There needs to be serious repercussions if an operator is found to be in breach of the regulations. These might include fines, license revocation and criminal proceedings as required.
Funding – a seriously robust regulatory regime requires funding. Random inspections, frequent site visits to a rapidly expanding industry will mean a significant increase in costs to the HSE and EA. A new funding structure, negotiated with the industry, needs designing and implementing. This must be done and soon to ensure we have not only the regulations but also the implementation of them at the well site.
What can YOU do?
Please write to your M.P. and to Tom Wheeler, Director of Regulation, The Oil & Gas Authority, 21 Bloomsbury Street, London, United Kingdom, WC1B 3HF, and make your views known.
Please use the material above as the basis for your letter.
If the status quo persists for the rest of exploratory phase and on to development, and if this lack of regulation continues then the local environment and economy will be at serious risk.
Until this situation is satisfactorily resolved the only sane course of action is to call for a moratorium on shale gas extraction in the UK.
Here is a video discussing the America Regulatory experience.
A Review of Regulatory Effectiveness in the USA and some of the issues they face over there.
Lou Allstadt spent 31 years working in the oil and gas industry. He was Executive Vice President of Mobile Oil Corporation responsible for exploration and production (drilling for oil and gas) in the US, Canada and Latin America. Previously, he headed Mobil’s worldwide supply, trading and transportation operations. He is a member of the US Oil and Gas Association.
