June 2015 FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU BRIEFING
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June 2015
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT
WILDLIFE AND PEOPLE IN THE UK AND EU
BRIEFING
This briefing was produced by CHEM Trust, a UK-based charity working at UK, EU and International level to protect humans and wildlife from harmful chemicals.
This briefing accompanies a detailed report, “Chemical Pollution from Fracking” which is available at:www.chemtrust.org.uk/frackingreport
CHEM Trust’s particular concerns relate to chemicals with hormone disrupting properties, persistent chemicals that accumulate in organisms, the cocktail effect and the detrimental role of chemical exposures during development in the womb and in early life. CHEM Trust strongly supports the conservation of biodiversity and believes in the importance of wildlife protection. Furthermore, monitoring wildlife populations can provide vital insights into contaminant related threats to human health.
For more about our work, including our regularly-updated blog, see www.chemtrust.org.uk
Further copies of this briefing, and the full report, can be downloaded from www.chemtrust.org.uk/fracking
About the authorsThis briefing was written by Dr Michael Warhurst, Executive Director of CHEM Trust, with the assistance of Gwen Buck, Campaign intern at CHEM Trust. Some of the text comes from the “Chemical Pollution from Fracking” report, written by Philip Lightowlers.
CHEM Trust also thanks all those who have given their time to read and comment on this briefing, and on the “Chemical Pollution from Fracking” report.
AcknowledgementsCHEM Trust gratefully acknowledges the support of the Esmée Fairbairn Foundation for their support to CHEM Trust, which helped fund the writing of this briefing and the “Chemical Pollution from Fracking” report.
Cover photos clockwise from top left, Diagram of fracking process [Credit US Environmental Protection Agency-Wikimedia Commons], Morecambe Bay Estuary [Credit Kevin Eaves- Shutterstock.com], Brown Hawker dragonfly Aeshna grandis [Credit Lydeke Bosch- Shutterstock.com], Jonah oil and gas site, Wyoming, USA [Credit EcoFlight], Creek chub Semotilus atromaculatus [Credit Brian Gratwicke-Wikimedia commons], Common blue butterfly Polyommatus icarus [Credit Radka Palenikova- Shutterstock.com]
@CHEMTrustEmail: [email protected]
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High volume hydraulic fracturing or ‘fracking’, is a controversial technology used for extracting oil or gas resources which are trapped in shale rocks, coal seams and similar deposits. In the US, where fracking is carried out extensively, there are many examples of fracking causing chemical pollution leading to health and environmental impacts.
Due to our concerns about fracking, CHEM Trust commissioned a detailed examination of the impacts of fracking with respect to chemical pollution; the detailed report “Chemical Pollution from Fracking” is available at:www.chemtrust.org.uk/frackingreport
This briefing summarises the “Chemical Pollution from Fracking” report, discussing some of the latest developments and includes our recommendations for the future.
Fracking operations require large numbers of wells, and need substantial volumes of water and chemicals. This chemical use, combined with the substances that flowback from underground, makes fracking a potentially significant source of air, land and water pollution.
In addition, fracking operations also generate substantial noise and air pollution from vehicles and other equipment. Note that in this briefing we use the term ‘fracking’ to cover the entire process of shale gas exploration and production.
Our key recommendations are:
1) All chemicals used in fracking must be disclosed, with no provision for commercial confidentiality.
2) Stronger EU regulation of fracking is required, ensuring that Environmental Impact Assessments (EIA) are required for all sites, chemical use is controlled and transparent, effective monitoring is obligatory and wastewater management is safe, including an absolute ban on disposal of wastewater by re-injection into the ground.
3) Regulations must protect the environment and people even when fracking wells are no longer used, including financial bonds to cover clean-up costs.
4) Effective monitoring and enforcement is essential to ensure that regulatory controls are followed. This means that regulators must have the resources to carry out these functions; this is a particular concern in the UK where the Environment Agency (EA) is experiencing substantial budget cuts.
In CHEM Trust’s view there should be an EU-wide moratorium on fracking until all our recommendations (see end of briefing) are in place.
CHEM Trust’s focus is on the toxic effects of pollutants, and so this briefing and our position excludes consideration of fracking’s effects on climate change and its potential to cause earthquakes.
There is further information for those involved in campaigning against fracking available from our website, www.chemtrust.org.uk/frackingcampaign
Summary
Contents
1. What is fracking? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Fracking: a source of pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1 Water and land pollution from fracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.2 Air pollution from fracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3. Impacts of fracking on human health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.1 Pollution risks to local people from fracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2 Chemical risks to workers from fracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
4. The implications of fracking on wildlife and the countryside . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.1 Wildlife impacts of pollution incidents in the US . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.2 UK Wildlife sites under threat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.3 A threat to rare species in the UK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5. Can regulation solve the problem? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13
5.1 Will EU regulations prevent pollution? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
5.2 Will UK regulators be able to protect people and wildlife? . . . . . . . . . . . . . . . . . . . . . . . . .14
5.3 Concerns for the future . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
6. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
6.1 Recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
7. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18
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FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
High-volume horizontal hydraulic fracturing, or ‘fracking’ is a way of releasing oil or gas resources that are trapped in shale rocks, coal seams and deposits. This technology has been developed to a commercial scale in the US over the past 20 years. It involves drilling deep wells both vertically and horizontally, and then pumping large volumes of ‘fracking fluid’ into the well at high pressure (see Figure 1). Note that in this briefing we use the term ‘fracking’ to cover the entire process of shale gas exploration and production.
Fracking fluid is a mixture of water, sand and chemicals, and when pumped into the well at high pressure it causes the shale to fracture and the sand to flow into the crevices, keeping them open. When the pressure is released, gas or oil flows to the surface, along with initially large volumes of wastewater or ‘flowback’ from the fracking process.
A similar process can be used to extract coal bed methane (CBM), releasing the methane associated with coal deposits by drilling horizontal wells, fracturing the coal and draining the seams. CBM also produces large volumes of contaminated wastewater. Shale oil, shale gas and coal bed methane are collectively called unconventional oil and gas (UOG) resources.
It’s worth noting that each fracking operation, which may be repeated dozens of times for each well, requires a large amount of water. The Institute of Civil Engineers estimated that 10,000 to 25,000m3 of water would be required for each well.1 This water demand, in itself, could have substantial environmental impacts. For example, not only drying out certain habitats, but also the increased water extraction from rivers could exacerbate the impact of other pollutants (e.g. from agriculture or sewage works) due to reduced dilution.
1.What is
fracking?
5
Figure 1: Diagram of fracking process [Credit US Environmental Protection Agency/Wikimedia Commons]
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
Fracking presents greater cumulative risks to public health and the environment than conventional drilling due to: (i) the chemicals required; (ii) the large volumes of water involved; (iii) the additional contaminants in the flowback; (iv) the need for many transport movements; and (v) the larger number of wells needed to reach a similar level of production.
As the United Nations Environmental Program (UNEP) has stated, in its review of shale gas: “[Hydraulic] fracking may result in unavoidable environmental impacts even if [unconventional gas] is extracted properly and more so if done inadequately.” 2
The scale of commercial fracking shouldn’t be underestimated. For example, it has been estimated – based on data from the petrochemical company INEOS - that this one company is planning over 1000 fracking wells in the central belt of Scotland alone.3
There have been many cases of pollution from fracking in the US, from a range of causes. A frequent one is the failure of the well casings in the upper part of the well (see examples below).
2.Fracking:
a source of pollution
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UNEP: “[Hydraulic] fracking may result in unavoidable environmental impacts even if [unconventional gas] is extracted properly and more so if done inadequately.” 2
UNEP
2.1 Water and land pollution from frackingThe main potential pathways of water and land pollution during fracking are:
• Accidental spillages during the mixing and transport of drilling and fracking chemicals and water prior to injection into the well.
• Leaks from failure or inadequacy of well casings in the upper part of the well. A large number of pollution incidents in the US have been due to this sort of failure4, which has allowed methane and fracking chemicals to migrate into groundwater, drinking water or nearby properties, sometimes causing explosions, evacuations and necessitating the replacement of water supplies.5
• Fissures in rock, potentially accentuated by the fracking process, leading to contamination of important groundwater reserves, potentially contaminating drinking water, springs etc.
• Leaks from storage and treatment of the large volumes of flowback water produced.
• Leaks from transport of flowback water.
• Inadequate treatment of flowback prior to discharge, and leaks from re-injection of flow back into the ground (where permitted).
Flowback contains the substances added to facilitate fracking, combined with salts, hydrocarbons, heavy metals and naturally occurring radioactive materials (NORM) present in the rock. Flowback waters should be treated before any release into the environment. In the UK this has so far been done by taking the flowback to a sewage treatment works by tanker.
The substantial volumes of fracking fluids and flowback involved in UOG production are potentially significant pollutants of air, groundwater, surface water and soil.
Jonah oil and gas site, Wyoming, USA [Credit EcoFlight]
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
2.2 Air pollution from frackingFracking is a source of air pollution, including:
• Evaporation from fracking fluids – including any stored flowback.
• Emissions from the flaring and treatment of gas.
• Diesel fumes from the constant running of pumps, generators, compressors and from heavy vehicles transporting large volumes of water and wastewater to and from the fracking site.
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What chemicals are used in fracking?
Fracking fluids are about 91-95% water, 5-9% sand and less than 0.5% chemical additives. Because the volumes of water involved are huge, this small proportion of chemicals adds up to significant quantity, perhaps totalling many tonnes in each operation.
The sand is a proppant, designed to keep rock fractures open, while the other additives include scale inhibitors and acids to prevent blockages, gelling agents to help carry the sand, biocides to prevent bacterial growth, friction reducers to increase pumping efficiency, surfactants (detergents) to aid penetration, clay stabilisers and “breakers” which reduce viscosity and help fluid recovery.
Different wells use different mixtures of chemicals, and these mixtures may also change over time. This makes it impossible to predict which chemicals will be used where and when. CHEM Trust strongly believes that there should be full disclosure of chemicals being used or planned to be used in fracking. This should include the full disclosure of the chemicals present in proprietary mixtures, with no ability to claim commercial confidentiality.
A 2011 study in the US, which questioned 14 major fracking companies, found they used many toxic chemicals, such as benzene, naphthalene, methanol, ethylene glycol, caustic soda and formaldehyde. It also found 279 products contained at least one chemical that manufacturers deemed a trade secret.6 The “Chemical Pollution from Fracking” report gives more details about the chemicals used in fracking, see Chapter 4.
Hormone disrupting chemicals
CHEM Trust is particularly concerned about the use of hormone (or endocrine) disrupting chemicals, chemicals that can disrupt the sensitive hormonal control systems in our bodies and those of wildlife leading to negative impacts on reproduction, neurodevelopment, behaviour and metabolism. Such chemicals have also been linked to hormonally driven cancers (e.g. breast, prostate and testicular cancers) and coronary heart disease.
In the US, researchers examined the properties of chemicals used in fracking and found many were known to be hormone disrupting or reproductive toxicants.7 A separate study tested fracking chemicals and surface and groundwater near fracking sites for hormone-related activities. The scientists found a range of hormone disruption related activities in fracking chemicals, and in the surface and groundwater samples, including imitation and blocking of male and female hormones.8
“CHEM Trust strongly believes that there should be full disclosure of chemicals being used or planned to be used in fracking”
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
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3.1 Pollution risks to local people from fracking Fracking is a concern to local people because of the potential for air and water pollution. Noise is also likely to be an issue in many cases.
In a letter recently published by the British Medical Journal, 20 high-profile doctors, pharmacists and public health academics said the “inherently risky” fracking industry should be prohibited in the UK on “public health and ecological grounds.”9
Preliminary studies in the US have shown that there is a higher incidence of skin conditions and upper respiratory problems in communities living close to fracking operations.10 In a provisional study in Australia, 58% of people living close to fracking operations reported health problems including coughs, tight chests, rashes, difficulty sleeping, joint pains, muscle pains, nausea and vomiting.11
3.2 Chemical risks to workers from frackingThe UK Trades Union Congress (TUC) has raised concerns over the health and safety of those employed in fracking operations in the UK. Their briefing states that the biggest health risks lie in potential explosions, exposure to the hydrocarbons and other chemicals in fracking fluid, including biocides, and exposure to silica, which is linked to serious illness, including lung cancer.12
Hormone disrupting chemicals used in fracking fluid have a range of toxic properties which could be relevant to workers, including reducing sperm counts, affecting menstrual cycles and impairing fertility. Heavy metals like lead and arsenic, which are found in flowback, also affect fertility and are associated with a greater risk of miscarriage or stillbirth.13
3.Impacts of
fracking on human health
“20 high-profile doctors, pharmacists and public health academics said the “inherently risky” fracking industry should be prohibited in the UK on “public health and ecological grounds” 9
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
4. The implications
of fracking on wildlife and the
countrysideFracking poses a range of threats to wildlife and the countryside, including potential pollution of watercourses, land-take and disturbance from fracking-related operations. There are also reports of damage to livestock on farms14.
4.2 UK Wildlife sites under threatA large amount of the UK has been defined as available for fracking exploration, though the Infrastructure Act 2015 has restricted fracking within certain protected areas. Figure 2 shows a map showing the areas where exploration licenses have been granted, as of 1st May 2015. A much wider area of the country is available for licensing, see the interactive map available on the gov.uk site.17
4.1 Wildlife impacts of pollution incidents in the USExperience from the US has shown that pollution from fracking can have devastating impacts on wildlife. For example, spills of fracking fluids have killed fish (including creek chubs and blacknose dace), salamanders and frogs.15
A fracking-related fire and spill in Ohio, USA, is estimated to have killed over 70,000 fish – showing the scale of damage that fracking accidents can cause.16
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Creek chub Semotilus atromaculatus [Credit Brian Gratwicke/Wikimedia commons]
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Petroleum Act 1998
Areas currently under Licence
SCALE 1:900,000
For further details on the UK onshore, contact either:Toni Harvey tel: 0300 068 6037, email: [email protected] Hawkins tel: 0300 068 6038, email: [email protected]
Index to National Grid numbers09
08
07
06
05
04
03
02
01
00
19
18
17
16
15
14
13
12
11
10
29
28
27
26
25
24
23
22
21
20
39
38
37
36
35
34
33
32
31
30
49
48
46
47
45
44
43
42
41
40
59
58
57
56
55
54
53
52
51
50
69
68
67
66
65
64
63
62
61
60
79
78
77
76
75
74
73
72
71
70
89
88
87
86
85
84
83
82
81
80
99
98
97
96
95
94
93
92
91
90
Gas Field
Oil Field Oil Discovery
Gas Discovery
Mines Gas Developments (active)
0 10 20 30 40 50 60 70 80 90 100 110 Kms
0 10 20 30 40 50 60 70 Miles
M
M
M
M
M
M
M
M
MM
M
M
M
M
M
M
M
M
CAUNTON
PEDL005
PEDL005
EGDON
EGDON
DART
EXL288
DART
EXL288
(Area 1 Fenwick)(Area 1 Rest)
(Area 1 Rest)(Area 2)
(Area 2)
PEDL183RATHLIN
PEDL179DART
PEDL174DART
PEDL178DART PEDL182
EGDON
PEDL173DART
PEDL180EUROPA PEDL241
EGDON
PEDL181EUROPA
PEDL253EGDON
PEDL169ALKANE
PEDL200DART
PEDL207DART
PEDL210DART PEDL210
DART
PEDL210DART
PEDL210DART
PEDL208NEWTON
PEDL202ALKANE
PEDL203EGDON
PEDL209BLACKLAND
ALKANEPEDL011
ALKANEPEDL011
ALKANEPEDL011
ALKANEPEDL011
ALKANEPEDL011
COURAGEEXL141
SE TA
SK TF
Bilsthorpe Vent
Newmarket Vent
CIRQUEEXL294
Cadeby Vent
PEDL001ALKANE
ALKANEPEDL001
DART
EXL288(Area 1 Trumfleet)
Calverton Vent
Harworth
Warsop Main
Kings Mill Vent
Mansfield Toray
Maltby Vent
Askern Vent
IGAS
IGAS
EGDON
DART
ALKANE
DART
SCOTTISH
DART
IGAS
COURAGE
WINGAS
DART
ALKANE
C.E.
IGAS
COURAGE
DART
IGAS
SCOTTISH
IGAS
DART
COURAGE
COURAGE
EGDON
IGAS
ALTAQUEST
IGAS
IGAS
ALKANE
IGAS
DART
ONSHORE IGAS
EUROPA
ALKANE
IGAS
IGAS
BLACKLAND PA
DART
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
DART
ALKANE
ALKANE
ALKANE
ALKANE
ALKANE
EUROPA OIL & GAS (WEST FIRSBY) LTD
ALKANE
BLACKLAND PA
PEDL011
PEDL140
PL162
PL179
PEDL146
PEDL139
PEDL130
PEDL006
EXL288
PEDL043
EXL294
PL162
PL161
ML004
ML003
PEDL006
PEDL090
PEDL012
PEDL005ML004
EXL141
PEDL090
PL161
EXL141
ML007
ML006
ML004
DL001
AL009
PEDL118
EXL288
PL215
PL213
DL003
PL199
PL199
PL179
PL178
EXL288
EXL250
PEDL001
PEDL001
PEDL001
PEDL001
PEDL037
PEDL037
PEDL037
PEDL001
PEDL037
PEDL037
PEDL037
PEDL037
PEDL001
PEDL001
PEDL001
PEDL001
PEDL037
PL215
PEDL037
Whitwell Vent
Wheldale Vent
HoughtonMainVent
Old Mill Lane Vent
Shirebrook Vent
Bevercotes Vent
BECKINGHAM
WELTON
HATFIELD
KEDDINGTON
EGMANTON
SALTFLEETBY
WHISBY
HATFIELD
COLD HANWORTH
TRUMFLEET
EAKRING
CALOW
GLENTWORTH
BRIGG
CORRINGHAM
STAINTON
EVERTON
TORKSEY
REEPHAM
BROUGHTON
SCAMPTON
KELHAM HILLS
NETTLEHAM
BECKERING
FISKERTON AIRFIELDNEWTON-ON-TRENT
CROSBY WARREN
WEST FIRSBY
IRONVILLE
SCAMPTON NORTH
FARLEYS WOOD
EAST GLENTWORTH
BOTHAMSALL
HEMSWELL
SOUTH LEVERTON
KIRKLINGTON
LINCOLNSHIRE
NOTTINGHAMSHIRE
EAST RIDING OF YORKSHIRE
DONCASTER
NORTH LINCOLNSHIRE
DERBYSHIRE
NORTH YORKSHIRE
YORK
LEEDS
ROTHERHAM
WAKEFIELD
BARNSLEY
SHEFFIELD
NORTH-EAST LINCOLNSHIRE
KINGSTON-UPON-HULL
440000
440000
445000
445000
450000
450000
455000
455000
460000
460000
465000
465000
470000
470000
475000
475000
480000
480000
485000
485000
490000
490000
495000
495000
500000
500000
505000
505000
510000
510000
515000
515000
520000
520000
525000
525000
530000
530000
535000
535000
540000
540000
545000
545000
550000
550000
350000 350000
355000 355000
360000 360000
365000 365000
370000 370000
375000 375000
380000 380000
385000 385000
390000 390000
395000 395000
400000 400000
405000 405000
410000 410000
415000 415000
420000 420000
425000 425000
430000 430000
435000 435000
440000 440000
445000 445000
450000 450000
0 5 10 15 20 25 30 35 40 Kms
0 5 10 15 20 25 Mls
SCALE 1:250,000
M
Onshore Licensing1 May 2015
Coal Bed Methane Field
Gas Storage Location
County and Unitary Authority Boundaries
© Crown copyright 2015.Contains Ordnance Survey data © Crown Copyright and database right 2015.You may re-use this information (not including logos)free of charge in anyformat or medium, under the terms of the Open Government Licence.To view this licence, visit www.nationalarchives. gov.uk/doc/open-government-licence/version/3/or write to the Information Policy Team, The National Archives, Kew, LondonTW9 4DU, or email: [email protected] enquiries regarding this publication should be sent to us [email protected] document is also available from our website athttps://www.gov.uk/oil-and-gas-onshore-maps-and-gis-shapefiles
10
Figure 2: On shore licences for oil and gas in the UK
Map showing onshore licences for oil and gas in the UK [Credit Gov.uk; latest version: https://www.gov.uk/oil-and-gas-onshore-maps-and-gis-shapefiles
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
Fracking company Cuadrilla has drilled exploratory wells in Lancashire and there are fears that if fracking goes ahead it could harm wildlife in the River Wyre estuary, a site of special scientific interest (SSSI) which is only a few kilometres away. The concerns are based both on the impacts of extracting water for fracking, and the potential impacts from pollution.
The Wyre estuary forms part of Morecambe Bay, a wetland of international importance under the Ramsar convention. This wetland hosts 11 wading bird species of international importance and four species of national importance and also includes a large area of salt marshes and reed beds and meadows which provide habitats for bees and northern marsh orchids, common blue butterflies and brown hawker dragonflies. The local farmland is also an important feeding ground for overwintering birds.18
11
Morecambe Bay Estuary [Credit Kevin Eaves/ Shutterstock.com]
Hawker dragonfly Aeshna grandis [Credit Lydeke Bosch/ Shutterstock.com]
Common blue butterfly Polyommatus icarus [Credit Radka Palenikova/ Shutterstock.com]
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
4.3 A threat to rare species in the UKThe Royal Society for the Protection of Birds (RSPB), with the aid of other wildlife charities in the UK, investigated the likely impacts of shale gas or oil development on British wildlife.19
They concluded that many different aspects of fracking could negatively affect wildlife, in addition to pollution and reduction in available water resources. The significant land required by a large number of wells, and the noise and other disturbance created by fracking activities - which may be 24 hours per day at times - are both likely to have a negative impact on wildlife.
The RSPB believes that fracking could have negative impacts on some of the UK’s rarest species, like the Barbastelle bat, which could particularly suffer due to light pollution. The bat is found on the Sussex Weald which is currently vulnerable to fracking operations.
12
Barbastelle bat Barbastella barbastellus [Credit Hugh Clark / Bat Conservation Trust]
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
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5.1 Will EU regulations prevent pollution?The core of environmental regulation across Europe is provided by EU-level legislation agreed by the Governments of EU Member States and Members of the European Parliament. National or regional legislation may then be added to this by individual governments.
As a result of the expected growth in fracking, the European Commission started a range of research projects to examine whether the EU regulatory system was adequate to prevent pollution. The impact assessment produced during this process concluded that improvement of existing EU regulations would be beneficial,21 but the UK government played a key role in ensuring that no EU regulatory changes were proposed,22 and instead the Commission adopted a non-binding recommendation in January 201423.
The non-binding recommendation encourages EU Member States to adopt minimum principles, which include: reducing health and environmental risks by conducting a strategic environmental assessment (SEA) and an environmental impact assessment (EIA), involving the public in consultations, protecting water quality and monitoring and treating flowback. However, without revised and binding EU legislation, few of these voluntary recommendations are likely to be enforced by Member States.
Strong, fully enforced, regulation should reduce the impacts of fracking and reduce the risk of pollution. However, pollution has occurred in the US, despite US states having legislation and regulation designed to protect the environment.
Given that fracking could result in many thousands of wells across the EU, the challenge for regulators is considerable.
Will regulators in all relevant Member States be able to ensure:
• That all these wells will be constructed to a sufficiently high standard to avoid pollution?
• That all chemicals are being used safely?
• That there will be no pollution from the flowback water?
• That all the wells’ integrity will continue to be monitored once officially closed, as substantial amounts of contaminated water are likely to remain in the well?
Furthermore, the issue is not just one of regulation, but also independent monitoring and enforcement of this regulation. Without this even stringent regulations will have little impact.
It is clear that such monitoring is required; for example, in Denmark in May 2015, the regulator stopped Total drilling its first exploratory shale gas well, accusing it of using an unauthorised chemical, though drilling later re-started after new assurances regarding chemical handling.20
In the UK, and in many other countries around the EU, cuts in public spending are reducing the capacity of regulators to do their job effectively. Other EU countries, particularly newer Member States, may not have effective environmental – or worker safety - regulators.
5.Can regulation
solve the problem?
“the UK government played a key role in ensuring that no EU regulatory changes were proposed”
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
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5.2 Will UK regulators be able to protect people and wildlife?In recent years the previous UK Coalition Government has been strongly pro-fracking, with the Prime Minister, David Cameron, saying the government was going “all out” for shale gas.28 The Chancellor of the Exchequer, George Osborne, has given fracking companies the ‘most generous tax breaks in the world’29 and a leaked letter to Cabinet colleagues has shown him asking them to fully support a fast track for fracking in the UK.30 The new Conservative government is expected to continue with the same pro-fracking approach.
The UK Infrastructure Act 201531 will halt fracking in - though not under or near - certain (not yet fully defined) wildlife and groundwater related protected areas. This is likely to include National Parks and Areas of Outstanding Natural Beauty. Both Scotland and Wales have put a moratorium on fracking, but a vast amount of England remains available for fracking.32
All fracking sites, whether exploratory or producing, require Petroleum Exploration and Development Licences, planning permission, well construction notification and approval and environmental permits. But they do not require an Environmental Impact Assessment (EIA) despite this being part of the Commission’s recommendation. During the parliamentary debate on
The role of the EU’s REACH chemicals legislation
The main law controlling chemical use in Europe is REACH, and it was identified in the European Commission’s studies as not properly addressing the use of chemicals in fracking.24
As a result of this realisation, the European Chemicals Agency (ECHA) has recently announced that a ‘use category’ for chemicals used in fracking will be introduced for REACH registration from 2016.25 Companies selling chemicals for use in fracking will have to specify this use category in their REACH registration dossiers. This should provide more transparency about which chemicals are used in fracking, via the European Chemical Agency’s (ECHA) public database of registration information26. However, this database won’t provide information on which chemicals are being used at specific sites.
REACH also, in most cases, obliges those using hazardous chemicals that are registered within REACH to ensure that their use is covered by an ‘exposure scenario’, which details how a chemical should be used in order to ensure that risks are ‘adequately controlled’. This exposure scenario should be produced by either the chemical producer, the distributer or the end user, and can be viewed by government regulators – though the public has no general right of access.
In the case of fracking, an exposure scenario should, for example, include how flowback should be treated to ensure risks from the chemical are adequately controlled. It is unclear whether exposure scenarios are adequate at the moment, particularly given that an industry-led process to draft industry guidance on exposure scenarios for fracking has not yet led to publication of a final document.27 Without full transparency of exposure scenarios it is not possible to analyse their quality.
In CHEM Trust’s view all exposure scenarios relating to chemicals used in fracking should be publicly available. This will allow others to assess the suitability of the chemicals being used, and whether they are being used in accordance with the exposure scenario.
In addition, the analysis of chemical risks relating to fracking should consider the impacts of leakage from the well and from above ground piping, storage and transport, as these are clearly foreseeable risks.
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
15
the Infrastructure Act 2015, environmental groups had asked to include a requirement for EIAs, but this was not included in the final Act.
UK regulation of fracking is complex and split between a number of regulators. For example, in England these include the Environment Agency (EA), Health and Safety Executive (HSE), the Minerals Planning Authority, the British Geological Survey and the UK Department of Energy and Climate Change (DECC). A new “Oil and Gas Authority” now regulates the licensing of onshore oil and gas sites in the UK, and large areas of the country are now licensed for exploration, see figure 2.
5.3 Concerns for the futureCHEM Trust is not only concerned about the current regulation of fracking, but also what may happen in the future. Given the scale of operations that the fracking industry would like put in place across Europe, it is vital that effective environmental and human health protection policies, adequately tailored to the particular threats of fracking, are enshrined in law.
Particularly worrying issues for the future include:
1) A strong lobby from many parts of business for ‘better regulation’, which frequently means deregulation or at least regulatory delays. Such a lobby could lead to a government removing regulatory requirements. For example, it could be conjectured that the UK might reduce the controls on treatment and disposal of flowback fluid, increasing risks to the public and the environment.
2) On-going cuts in regulatory authorities, such as the EA in England, including loss of staff and redeployment of staff towards other priorities such as flooding. This will reduce their capacity to identify failures and enforce licence conditions in important regulatory areas such as fracking.
3) If the UK were to leave the EU it would mean that some or all of the agreed EU laws regulating fracking would no longer apply here. If the UK were to end up with a similar status as Norway, for example, the REACH chemical regulations would still apply (as these are part of the EU internal market for products). However, EU Regulations controlling the drilling site might not apply, as these are not part of the EU Internal Market legislation. That said, it’s worth noting that Norway & other countries in the European Economic Area (EEA) have decided to follow the Water Framework Directive.33
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
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Fracking has the potential to have a massive impact on the countryside and those who live in it – be it people, livestock or wildlife. The potential scale of fracking operations is huge, creating major water pollution risks from the large amount of chemicals used, and wastewater generated. Alongside the water pollution risks, there are also serious risks of local air pollution and land pollution.
In CHEM Trust’s view there should be an EU-wide moratorium on fracking until all our recommendations (below) are in place.CHEM Trust’s focus is on the toxic effects of pollutants, and so this briefing and our position excludes consideration of fracking’s effects on climate change and its potential to cause earthquakes.
There is further information for those involved in campaigning against fracking available from our website, see:www.chemtrust.org.uk/frackingcampaign
6.Conclusions
6.1 Recommendations
Regulations
• The European Commission’s January 2014 recommendations on fracking need to be turned into legislation. Without effective and legally binding legislation designed to deal with fracking, then people and wildlife in the EU are not going to be properly protected.
• All fracking operations, including exploration, should be covered by Environmental Impact Assessments.
• It is clear that faulty wells are a major pollution risk, therefore the quality of well construction and safety standards must be strongly regulated and enforced.
• The toxic and possibly radioactive waste from fracking will require careful disposal and should be addressed specifically in EU regulations. In particular, underground disposal of wastewaters (e.g. through re-injection) should be banned.
• Companies undertaking fracking should have to deposit bonds sufficient to cover any future compensation claims and to pay for clean up at the end of the life of the well. A failure to have sufficient resources in restoration bonds for the clean up of opencast coal mines is now creating a major social and environmental crisis in Scotland.34
Chemical disclosure
• There must be full public disclosure of all the chemicals used, with adequate data on their hazard profiles, and clear, publicly available, assessment of all the potential health and environmental effects. There should be no opportunity for industry to withhold chemical identities based on claimed commercial confidentiality.
• Manufacturers and distributers of chemicals must produce and communicate human and environmental exposure scenarios for fracking substances. These
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
17
exposure scenarios should be publicly available, and must make clear what are the assumptions made in calculating adequate control, for example, with respect to the storage and fate of flowback.
• In addition, the analysis of chemical risks relating to fracking (including exposure scenarios) should consider the impacts of leakage from the well and the above ground piping, storage and transport, as these are clearly foreseeable risks.
Monitoring
• Under the supervision of a regulator, operators of fracking wells should undertake extensive air, land and water monitoring in the vicinity of their sites prior to, during and after the operation. This is to ensure that clear baselines are set and any subsequent pollution is apparent.
• There should be detailed and ongoing inspection of operations by independent experts in geology and ground water protection, to ensure safe well construction and proper disposal of all chemicals, including contaminated water, muds and other wastes.
• There must be systems in place to identify emerging chronic or acute health effects in workers, residents, livestock and wildlife.
• Even when wells are exhausted and sealed, they remain a threat to ground waters and must be monitored. Operators need to commit resources to ensure that any future problems are identified and can be remediated.
Regulators
• The regulation and monitoring of a large number of fracking wells will be a challenge for regulators. There must be sufficient staff and resources to do this job effectively. This is a particular concern in the UK, where the staffing of regulators such as the EA has been reducing in recent years.
• It is also vital that regulators have sufficient expertise in the full range of issues relevant to fracking, including, for example, the safety of wells.
Location
• The vulnerability of ground waters to pollution from fracking should be recognised and there should be no operations in groundwater source protection zones.
• There should be no fracking on, near, or underneath, key wildlife sites, including Natura 2000 sites (both Special Areas of Conservation (SACs) and Special Protection Areas (SPAs), and in the UK, National Parks and Sites of Special Scientific Interest (SSSIs).
• Local communities should be involved in any decisions on fracking in their area; see the Friends of the Earth position on fracking for more information on this and other issues.35
Water supply
• Regulators must forbid fracking where there is insufficient water available for the fracking operation, or if extracting this water will negatively affect wildlife or people.
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
1 House of Commons Environmental Audit Committee, Environmental Risks of Fracking, 2014-15. http://bit.ly/1CgA16Z
2 UNEP Global Environment Alert Service, Gas fracking: can we safely squeeze the rocks?, November 2012. http://na.unep.net/geas/archive/pdfs/GEAS_Nov2012_Fracking.pdf
3 Friends of the Earth Scotland, INEOS- the figures they don’t want you to believe and the numbers they don’t want you to know, 18th March 2015. http://www.blog.foe-scotland.org.uk/index.php/2015/03/ineos-the-figures-they-want-you-to-believe-and-the-numbers-they-dont-want-you-to-know/
4 Washington Post, Study: Bad fracking techniques let methane flow into drinking water, 15th Sep 2014.
http://www.washingtonpost.com/blogs/wonkblog/wp/2014/09/15/study-bad-fracking-techniques-let-methane-flow-into-drinking-water/
5 Massachusetts Institute of Technology, The Future of Natural Gas Appendix 2E, 2011. http://mitei.mit.edu/publications/reports-studies/future-natural-gas
6 US House of Representatives Committee on Energy and Commerce, Chemicals used in hydraulic fracturing, 2011. http://democrats.energycommerce.house.gov/sites/default/files/documents/Hydraulic-Fracturing-Chemicals-2011-4-18.pdf
7 Webb, E., Bushkin-Bedient, S., Cheng, A., Kassotis, C. D., Balise, V., & Nagel, S. C. (2014). Developmental and reproductive effects of chemicals associated with unconventional oil and natural gas operations.
http://www.degruyter.com/view/j/reveh.2014.29.
issue-4/reveh-2014-0057/reveh-2014-0057.xml
8 Kassotis, C. D., Tillitt, D. E., Davis, J. W., Hormann, A. M., & Nagel, S. C. (2014). Estrogen and Androgen Receptor Activities of Hydraulic Fracturing Chemicals and Surface and Ground Water in a Drilling-Dense Region. Endocrinology http://press.endocrine.org/doi/full/10.1210/en.2013-1697
9 The Guardian, Doctors and academics call for ban on ‘inherently risky’ fracking, 2015. http://www.theguardian.com/environment/2015/mar/30/doctors-and-academics-call-for-ban-on-inherently-risky-fracking
10 P. Rabinowitz, I. Slizovskiy, V. Lamers, S. Trufan, T. Holford, J. Dziura, P. Peduzzi, M. Kane, J. Reif, T. Weiss and M. Stowe, Proximity to Natural Gas Wells and Reported Health Status: Results of a Household Survey in Washington County, Pennsylvania, Environmental Health Perspectives, vol. 123 (1), January 2015. http://ehp.niehs.nih.gov/1307732/
11 M. McCarron, Symptomatology of a gas field: An independent health survey in the Tara rural residential estates and environs, April 2013. http://www.ntn.org.au/wp/wp-content/uploads/2013/05/Symptomatology-of-a-gas-field-An-independent-health-survey-in-the-Tara-rural-residential-estates-and-environs-April-2013.pdf
12 Trade Union Congress, TUC shale gas briefing: Fracking and workers’ health and safety, January 2015, https://www.tuc.org.uk/industrial-issues/energy/union-issues/workplace-issues/tuc-shale-gas-briefingfracking-and-workers’
7References
18
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
13 E. Webb, S. Bushkin-Bediant, A. Cheng, C. D. Kassotis, V. Balise and S. C. Nagel, Developmental and reproductive effects of chemicals associated with unconventional oil and natural gas operations, Reviews of Environmental Health, vol. 29(4), pp. 307-318, 2014. http://www.degruyter.com/view/j/reveh.2014.29.issue-4/reveh-2014-0057/reveh-2014-0057.xml
14 Bamberger & Oswald, Impacts of gas drilling on human and animal health, New Solutions, Vol. 22(1) 51-77, 2012
http://www.psehealthyenergy.org/data/Bamberger_Oswald_NS22_in_press.pdf
15 Pennsylvania Department of Environmental Protection, DEP Penalizes Range Resources $141,175 for Spill in High Quality Waterway, 2010.
http://www.portal.state.pa.us/portal/server.pt/community/newsroom/14287?id=11412&typeid=1
16 Mother Jones, Halliburton Fracking Spill Mystery: What Chemicals Polluted an Ohio Waterway? 24th July 2014.
http://www.motherjones.com/politics/2014/07/halliburton-ohio-river-spill-fracking
17 Department of Energy and Climate Change, Oil and gas: onshore maps and GIS shapefiles:Interactive map, 23rd March 2015.
https://www.gov.uk/oil-and-gas-onshore-maps-and-gis-shapefiles
18 Over-wintering birds stop fracking plan, ENDS Report, November 2013.
http://www.endsreport.com/41327/
19 RSPB, Angling Trust, National Trust, Salmon & Trout Association, The Wildlife Trusts and Wildfowl & Wetlands Trust, Shale Gas: The evidence, March 2014.
http://www.rspb.org.uk/Images/shale_gas_report_evidence_tcm9-365779.pdf
20 Denmark to allow Total to reopen fracking site, thelocal.dk, 13th May 2015
http://www.thelocal.dk/20150513/denmark-to-allow-total-to-resume-fracking-project
21 European Commission, Executive Summary of the Impact Assessment, 22nd January 2014.
http://ec.europa.eu/environment/integration/energy/pdf/swd_2014_22_en.pdf
22 The Guardian, UK defeats European bid for fracking regulations, 14th January 2014.
http://www.theguardian.com/environment/2014/jan/14/uk-defeats-european-bid-fracking-regulations
23 Environmental Aspects on Unconventional Fossil Fuels, European Commission, January 2014
http://ec.europa.eu/environment/integration/energy/unconventional_en.htm
24 JRC Scientific and Policy Reports, Assessment of the use of substances in hydraulic fracturing of shale gas reservoirs under REACH, September 2013. http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/29386/1/req_jrc83512_assessment_use_substances_hydraulic_fracturing_shale_gas_reach.pdf
25 European Chemicals Agency, ECHA clarifies how to report substances used in hydraulic fracturing.
http://echa.europa.eu/documents/10162/21779840/
annex+to+a+news+item+ 20150318.pdf
26 ECHA: Registered Substances public database
http://echa.europa.eu/information-on-chemicals/registered-substances
27 Email from European Oilfield Speciality Chemicals Association, 12th May 2015.
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28 Nicholas Watt, Fracking in the UK: ‘We’re going all out for shale,’ admits Cameron, January 2014, http://www.theguardian.com/environment/2014/jan/13/shale-gas-fracking-cameron-all-out
29 Terry Macalister and Fiona Harvey, George Osborne unveils ‘most generous tax breaks in world’ for fracking, July 2013,
http://www.theguardian.com/politics/2013/jul/19/george-osborne-tax-break-fracking-shale-environment
30 Damien Carrington, George Osborne urges ministers to fast-track fracking measures in leaked letter, January 2015, http://www.theguardian.com/environment/2015/jan/26/george-osborne-ministers-fast-track-fracking
31 Legislation.gov.uk, Infrastructure Act 2015: Onshore hydraulic fracturing: safeguards.
http://www.legislation.gov.uk/ukpga/2015/7/section/50/enacted
32 Ends Report, Government slammed for watering down fracking safety, 24th February 2015.
http://www.endsreport.com/47298
33 Letter regarding Norway’s implementation of the Water Framework Directive, May 2012
https://www.regjeringen.no/globalassets/upload/md/2012/pmer/skm322m12053114260.pdf
34 Opencast coal mining: Liability for restoration works, RSPB and Friends of the Earth Scotland, July 2013
http://www.rspb.org.uk/Images/opencast-coal-mining_tcm9-353523.pdf
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35 Friends of the Earth, All that glitters... Is the regulation of unconventional gas and oil exploration in England really ‘gold standard’?, June 2014
https://www.foe.co.uk/sites/default/files/downloads/executive-summary-all-glitters-critique-fracking-regulation-46661.pdf
FRACKING POLLUTION: HOW TOXIC CHEMICALS FROM FRACKING COULD AFFECT WILDLIFE AND PEOPLE IN THE UK AND EU
Notes:
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ii) Frogs at risk and possible implications for humans? Why EU chemicals legislation needs updating to address chemicals that damage the immune system, eport and press release, by Professor Susan Jobling, Dr Alice Baynes and Dr Trenton W.J Garner (2013)
iii) A review of the science linking chemical exposures to obesity and diabetes, (available in French, Spanish and German), report, briefing & press release, by Professor Miquel Porta and Professor Duk-Hee Lee (2012)
iv) Concerns about bisphenol A and recommendations for action, briefing and press release, by Professor Miquel Porta and Professor Duk-Hee, (2010)
v) A review of the role pesticides play in some cancers: Children, farmers and pesticide users at risk? By Gwynne Lyons and Professor Andrew Watterson (2010)
vi) Why Mollusc Toxicity Tests for Endocrine Disruptors and Other Chemicals Are Needed – CHEM Trust briefing, by Gwynne Lyons (2009)
vii) Male Reproductive Health Disorders and the Potential Role of Exposure to Environmental Chemicals, including briefing, by Professor Richard Sharpe of the Medical Research Council (2009)
viii) Effects of Pollutants on the Reproductive Health of Male Vertebrate Wildlife – Males Under Threat, Report, Executive Summary and Press Release, by Gwynne Lyons (2008)
ix) Breast Cancer and exposure to hormonally active chemicals: An appraisal of the scientific evidence, including briefings in French, Spanish, German and Italian, by Professor Andreas Kortenkamp of the London School of Pharmacy (2008)
x) Chemicals Compromising Our Children: Neurological Impairment in Children, by Gwynne Lynons (2007)
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