Joint Research Programme on Environmental Impacts of Unconventional Gas Exploration & Extraction

Date released: Nov 30 2016, 2:14 PM

The EPA has today published an integrated synthesis report and a series of related reports (eleven in total) arising from the Joint Research Programme on Environmental Impacts of Unconventional Gas Exploration & Extraction (UGEE). The research was undertaken by a consortium of independent organisations comprising CDM Smith Ireland (Ltd), the British Geological Survey, University College Dublin, Ulster University, AMEC Foster Wheeler and Philip Lee Solicitors.

The research programme was made up of five projects which looked in detail at the potential impacts of UGEE on water, seismicity and air quality as well as a comprehensive literature review of operational practices and regulatory regimes.

The programme was designed to produce outputs to assist regulators – both North and South - in fulfilling their statutory roles regarding impact assessment and regulation of any potential UGEE operations in Ireland.  The two key questions posed for the research programme were:

1. Can UGEE projects/operations be carried out in the island of Ireland whilst also protecting the environment and human health?
2. What is ‘best environmental practice’ in relation to UGEE projects/operations?

The work has now concluded and the reports and associated data, information and assessments provide a technical and evidence-based framework in which to consider the potential impacts on the environment and human health from UGEE projects and operations, including construction, operation and aftercare.  The work will also, as stated in the Government’s White Paper on Energy, help inform policy in this area but in the context of the objective of achieving a low carbon energy system in which the use of oil and gas is gradually curtailed and, in the longer term, is eliminated from our energy mix.

The EPA will continue to provide the necessary scientific and technical support through its research, monitoring and assessment activities to facilitate the policy discussions and decisions about this and the wider issues around the transition to a low carbon economy and society. 

The conclusions of the Integrated Synthesis Report of UGEE Joint Research Programme are attached to this release. All the reports are available on the EPA website.

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Notes to Editor
In late 2011 the Environmental Protection Agency (EPA) was requested by Mr. Pat Rabbitte, former Minister for Communication, Energy and Natural Resources, to commission and coordinate the management of research in relation to the environmental impacts of Unconventional Gas Exploration & Extraction (UGEE). 

Following this request, the EPA established a Steering Committee of relevant stakeholders and held a detailed public consultation in 2013 to inform the terms of reference for such a Research Programme. Funding for the research programme was committed by the Department of Communications, Energy and Natural Resources (DCENR), the Department of Environment, Community & Local Government (DECLG) and the Northern Ireland Environment Agency. Following an Open Tender Competition in late 2013, six tenders were received by the EPA. In August 2014, the contract to carry out the research was awarded to a consortium led by CDM Smith Ireland Limited, following the tender evaluation. 

The research programme was funded by the Department of Communications, Climate Action and Environment, DCCAE (formerly DCENR and the Environment Division of the Department of Environment, Community and Local Government (DECLG)) and the Northern Ireland Environment Agency (NIEA).

The research programme was managed by a steering committee comprising the EPA, representatives from DCCAE, the Geological Survey of Ireland, Commission for Energy Regulation, An Bord Pleanála, NIEA, the Geological Survey of Northern Ireland and the Health Services Executive.

Research Outputs (All reports are available online - Bold denotes available in hard copy also)

1. Final Report 1: Baseline Characterisation of Groundwater, Surface Water and Aquatic Ecosystems (567 pages)
2. Summary Report 1: Baseline Characterisation of Groundwater, Surface Water and Aquatic Ecosystems (72pages)
3. Final Report 2: Baseline Characterisation of Seismicity (197 pages)
4. Summary Report 2: Baseline Characterisation of Seismicity (52 pages)
5. Final Report 3: Baseline Characterisation of Air Quality (93 pages)
6. Summary Report 3: Baseline Characterisation of Air Quality (28 pages)
7. Final Report-4: Impacts & Mitigation Measures (649 pages)
8. Summary Report 4: Impacts & Mitigation Measures (32 pages)
9. Final Report 5: Regulatory Framework for Environmental Protection (250 pages)
10. Summary Report 5: Regulatory Framework for Environmental Protection (36 pages)
11. UGEE Joint Research Programme Integrated Synthesis Report (72 pages)

 
Extract from Conclusions Section of Integrated Synthesis Report of UGEE Joint Research Programme

The UGEE Research Programme has examined the process, impacts and mitigation measures associated with hydraulic fracturing around the world. International regulatory frameworks have been reviewed and the suitability of legislation in Ireland and Northern Ireland reviewed and potential gaps identified.

Public concern about hydraulic fracturing generally focuses on health, water resources, induced seismic activity and GHG emissions, although in some areas potential changes to the character of the environment are an issue. The relative importance of these issues varies from place to place and with time.

This study concluded that UGEE projects/operations comprise multiple activities, over a period of up to 25 years, which have the potential to impact both human health and the environment. However, many of these activities are conventional, in the sense that they are infrastructure developments that are frequently undertaken within both Ireland and Northern Ireland and, consequently, the legislation and regulation that relates to them are well established and widely accepted by society. Examples of these activities are access road construction, site preparation and materials transport. These types of activities, across many industries, have well-established impacts and measures to mitigate their impacts. A wide range of potential impacts was assessed including those relating to water, air quality, noise, landscape, seismic activity and social issues.

Project B demonstrated that operational requirements and practices in different jurisdictions vary significantly and that this relatively new industry is evolving rapidly, especially in North America. The regulatory regimes of North America are very different from those of the EU and many of the more environmentally damaging practices may not be permissible in the island of Ireland (e.g. open wastewater lagoons, flaring, disposal of wastewater by deep underground re-injection). Industry best practice guidance, such as that issued by the UK industry group, collates best practice and addresses many of the concerns raised by stakeholders.

The JRP scope was developed to address two key questions: can UGEE projects/operations be carried out in the island of Ireland while also protecting the environment and human health; and what is best environmental practice in relation to UGEE projects/operations?

The programme concluded that many of the activities associated with UGEE projects/operations could proceed on the island of Ireland, while protecting the environment and human health. This should be done using the best practices identified in Report 4: Impacts and Mitigation Measures and applying the current regulations, together with a small number of additions and modifications that should be complemented by adequate implementation and enforcement.

However, there are three main impacts where the data and/or experience do not permit a reliable assessment of their consequences and these would require clarification before environmental protection and human health can be ensured. The three potential impacts that cannot be discounted by regulatory control and good practice are as follows:

1. Groundwater aquifers could be polluted as a result of the failure or deterioration of well integrity. The drilling and construction of wells is a routine activity in the water and oil and gas sector and standards for their design and construction are well established. However, experience shows that there are examples of wells that have failed or have deteriorated well integrity. It is believed that a rigorous process of design, design review, construction supervision and operational monitoring (with remedial works  if necessary) could mitigate this impact, but this cannot be demonstrated without further evidence.  Such a process should be a requirement of any UGEE operations in the island of Ireland. There is incomplete knowledge of the aquifer systems in the two study areas, with specific data gaps related to the deep hydrogeological characterisation and how the deeper groundwater flow systems may be hydraulically connected to shallow aquifers and receptors. As a consequence, the impacts cannot be reliably addressed in the absence of baseline monitoring data.
2. The fracking process intentionally generates cracks in the rocks that typically extend to 100–200m; however statistical analysis suggests that they can extend by up to 300 m and, in extreme circumstances, by up to 500 m. If the separation between the fracking activity and the base of the aquifer is less than these distances, then there will be a risk of pollutant and gas migration to the aquifer, although this could be reduced if impermeable rock layers separate the two. This risk is compounded by the possibility of pollutant and gas migration in the newly fractured (after fracking) shale rocks towards pre-existing permeable faults that could also provide a pollutant and gas pathway to the aquifer. The seismic elements of this programme have developed a new approach to evaluate fracture propagation and length, which requires site-specific data on seismic activity, rock characteristics and existing fracture networks to refine these estimates for the two study areas. These data would come both from the baseline monitoring (originally anticipated to be within the scope of work for the programme) and from detailed monitoring during UGEE operations.
3. Gas emissions have been cited by the public to be of concern from a human health viewpoint. During active operations, these can be adequately managed by mitigation measures that address the health and safety of the workforce, who would be at a much higher level of exposure than the general public. Following closure of a well, it is sealed and capped to prevent egress of gas. However, there is evidence from conventional oil and gas wells that this closure process is not always successful or can deteriorate with time and that stray gas leakage has occurred. Neither the reasons for this, nor the scale of the emissions is quantitatively known and so their impact cannot be reliably assessed until further data are available. Methane is an important GHG and therefore this is an issue of concern, although it should be noted that approximately 90% of GHG emissions are likely to occur during the generation of electricity rather than at the production stage.

Prior to any authorisation for hydraulic fracturing, these issues should be resolved. Adequately designed baseline monitoring programmes for water and seismicity will assist in improving site-specific knowledge and therefore the assessment of the risks of groundwater contamination by well failure and induced seismicity.

Similarly, two- and three-dimensional seismic surveys, which would be expected to be undertaken by the operators prior to any hydraulic fracturing activity, will provide further subsurface knowledge that will allow better characterisation of subsurface geology, hydrogeology and natural seismic activity.

Long-term gas emissions are more difficult to address, since local datasets are not available. Long term, post-closure methane emissions are the topic of ongoing studies internationally, but these studies will take time to conclude. If UGEE projects are initiated, then it is recommended that more complete closure of wells, testing of closure procedures (cementing, etc.) and long-term monitoring should be specified. Funding for post-closure monitoring could be arranged through the provision of a bond by the developer. Existing regulations in Ireland and Northern Ireland have widespread applicability to potential UGEE project/operations, but there remain some potential deficiencies and ambiguities that should be clarified, notably in relation to the MWD BREF. These include whether an EIA is required or not (especially for small-scale projects), the requirement for a SEA at national-, regional- or
multiproject-level; and the form of protection for air and water.

The EC Recommendation (2014/70/EU) and emerging best practice attempt to cover gaps in underground risk protection, but there is no guarantee that the proposed approaches will be required by regulators or adopted by industry.

Many of the potential uncertainties in legislation could be covered through guidance that clearly identifies how legislation will be applied. Best practice guidance should, therefore, be adopted or developed for UGEE operations in the island of Ireland. The guidance should, as a minimum, address all the points raised in the EC Recommendation and in this project. At this early stage of development of UGEE and HIA in the island of Ireland, incorporating HIA within EIAs as a best-practice requirement is likely to be the best approach, as this will allow developments in the understanding of UGEE and in the practice of HIA to be accommodated. In addition, developments in HIA for UGEE in other countries should be tracked, and the approach in Ireland and Northern Ireland adapted where improvements are identified.