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Fracking Treatment

Fracking TreatmentWith Mike Hill's public meeting at 7.00 pm, this Thursday (18 October 2012), at St Annes United Reform Church, Hall in St George’s Road, St. Annes. ( Please follow this link for more details ), we thought this might be a good opportunity to bring readers up to date with what has come our way since our last report in July.

Notably, and perhaps sadly, the special meeting that Mr Hill put on for local Councillors seems not to have been very well attended. That's a shame. We know from experience that it takes quite a bit of work and not an insignificant cost for an individual to put on such an event. Readers can follow this link to read about the poor showing of Councillors. Well done to those who did manage to make it.

We get the impression there is a lot of backing-away going on by some parts of the local political establishment, as national politicians make it more and more clear that they intend to let the exploitation phase go forward.

The Chancellor's announcement that he was creating a specially favourable tax regime to support fracking set the ball rolling. The Government has said gas will continue to be an important part of the UK energy mix. They spoke of the potential of shale gas to create jobs and support UK energy security, and of "engaging with companies to ensure that the final structure of the tax regime is appropriately targeted while maintaining a fair return for the Exchequer."

In an echo of George Osborne's apparent assumption of control of planning policy in St. Eric Pickles' department, we heard that the Department of Energy and Climate Change Department didn't appear to know about the Treasury's plans to encourage fracking with tax breaks before the announcement was made by Mr Osborne. Whether that's right or not we're not sure. But it wouldn't surprise us if the Chancellor was trying to influence UK energy policy as well as its planning policy.

But in any case, the DECC Minister is in support anyway. Ed Davey told a gas conference in London "I hope it will prove possible for me to give a green light to shale." He was also reported to have said "In principle, I'm all in favour of exploiting new resources. I would welcome as much as anyone a way to boost Britain's indigenous gas supplies and to reduce energy prices to consumers and businesses alike."

But at least he did also sound some alarms on the lack of a proper regulatory regime, and appeared to say it was necessary.

In another development, the court case of three anti-fracking protesters who invaded the Cuadrilla site at Hesketh Bank produced some startling news. This wasn't so much about the trial itself, (two people were acquitted and one was found guilty under the Criminal Justice and Public Order Act at Preston Magistrates Court. She was ordered to pay a £250 fine and £750 costs.), but it was that Stuart Perigo, the head of planning at Lancashire County Council admitted that he had allowed Cuadrilla to continue drilling for two months after their planning permission to do so had expired.

Cuadrilla had continued to drill two months beyond their agreed time limit, and Mr Perigo also confirmed they had failed to meet a key condition to safeguard bird life from the adjacent Ribble Estuary Site of Special Scientific Interest. According to the 'Tarleton and Hesketh Bank News' website on 4th September 2012, the Council officer also "admitted the Council had few resources and very limited powers to police developers and that they largely relied on developers meeting their obligations."

Assuming the quote from the Hesketh Bank publication is accurate, we have to say to him - For God's sake man! What on earth do you think you are doing? How do you expect people to have ANY confidence in the officials that are SUPPOSED to be policing this process when you go around making comments of that sort.

Mind you, we're not altogether surprised. It's not the first time we've known LCC's Mr Perrigo to have had egg on his face.

On the macro scene, we also hear that in the US (and as our regular readers know, we're not that enamoured of US / UK comparisons because things are so different), there has been a big fall in gas prices in the US and shale extraction is now thought to have a less than certain future there. Some commentators are talking about a Shale Gas bubble having been created.

Also 'over there' is a possible alternative extraction method which uses gelled propane instead of water. According to 'GasFrac Services', a relatively new Canadian oilfield service company, this type of propane fracturing can deliver economic and environmental benefits. Readers can follow this link for more details sourced by one of our readers.

But as far as we are concerned, the biggest news relates to the treatment of the waste water from fracking. This is one of the two areas we think causes the biggest risks and concerns.

We were told by one reader that the Environment Agency had in effect turned a blind eye and let the company move the waste.We haven't been able to establish that with any certainty. But what does appear to have happened is that Cuadrilla have come up with a way of disposing of it and the Environment Agency looked at the proposal on paper, were happy in principle, and agreed a sort of trial run to demonstrate and test the idea in practice.

Whether this is a good way to proceed or not is open to conjecture. It is a new system for disposing of such waste, and if it hasn't been tested in this context before, then someone has to be first (if it's going to happen at all). We can but hope that the Environment Agency are on top of their game - at least until a new regulatory framework is in place. The need for a new regulatory regime now seems to be a widely accepted need, and we expect it will happen.

In terms of what's happening to the waste water, we did hear that initially it was being transported to Davyhulme (Manchester) treatment works at the start of the fracking, but either new Environmental Regulations, or maybe the presence of minor levels of naturally occurring radiation from the shale rock put a stop to that, and the waste water was temporarily stored in Cuadrilla's tanks on site pending another disposal arrangement being identified.

We do know that Cuadrilla now believe they have found a way to solve that problem. They appear to be happy with the pilot scheme they tested and have applied for formal permission from the Environment Agency to use that system to dispose of what they call 'flowback' water from the fracturing process.

From what we can see, they have teamed up with a specialist waste disposal company based on Liverpool Road in Penwortham, just outside Preston, called 'Remsol Limited' whose registered address is Nelson Court Business Centre, in Preston. They seem a relatively young and small company, having been founded on 19 Jun 2002.

We wonder if their specialism is REMoving SOLids from liquids, because that's the process they have proposed to clean up the waste water for Cuadrilla.

Remsol say they were originally engaged 6 months ago to help Cuadrilla identify a safe and sustainable way of managing the waste waters generated in the hydraulic fracturing process. Over the summer, they worked closely with Cuadrilla to find, then prove, a method of successfully dealing with these waste waters.

Apparently they did a series of successful laboratory and plant-scale trials with a group of what they describe as "carefully selected industrial waste treatment plants", and they have since "constructed the necessary commercial arrangements to facilitate the routine delivery of the waste waters to these plants." (We think that means they've organised some lorries to transport it).

If permission is given by the Environment Agency, Remsol "will be responsible for managing the waste waters for compliance and performance, and overseeing the entire end-to-end operation of removing them for safe treatment and disposal."

They say that longer term, they plan to help Cuadrilla find a way of re-using the waste waters so they can also reduce their demand for clean water.

Their website quoted their own managing director (Lee Petts) as saying ".... I'm also a pragmatic environmentalist, and in this case wanted to make a positive difference by helping Cuadrilla to control and mitigate its environmental risks. I think it's important to keep those environmental risks in perspective. The hydraulic fracturing takes place at depths of more than 8,000ft - that's the equivalent of fifteen Blackpool Towers stood on top of one another - compared to the shallow aquifer that is at about 100ft beneath our feet. The well is also designed to protect the aquifer. So it seems extremely unlikely that the fracturing fluid or waste waters will migrate from the well to contaminate near-surface aquifers."

Remsol also believes that its experience and expertise can be extended to other companies considering shale gas exploration in the UK

According to Duedil  Remsol have "7 associated directors - 2 are current, and 5 are former. Lee Robert Petts is the Remsol Limited's sole shareholder with a total of 1000.00 shares. The company has no known group companies. The business has assets of £273,467 plus liabilities of £89,152. They are due to pay £74,830 to creditors and are owed back £72,361 from trade debtors. As of their last financial statement, they had £201,106 in cash reserves. The company's current net worth is £214,826, and the value of their shareholders' interest is £214,826."

All the details of what is being proposed as treatment is on the Cuadrilla website, but it's in a mass of linked documentation - most of which says very little and repeats itself a great deal, so you have to plough through lots and lots of documents to find it, but it is there.

It's in the document called "A Description Of Arrangements For Disposing Of Radioactive Wastes Generated At Exploration Sites", and in essence it sets out a chemical settlement and filtration process to remove the solids and what becomes their 'attached' radiation.

It is claimed that the process was identified as a suitable method of removing 'Naturally Occurring Radioactive Material' (NORM) from the waste "owing to the way in which the radionuclides co-precipitate with calcium when in an alkaline environment", and a variation of this treatment has been successfully used in the UK nuclear industry for over forty years, removing artificially produced radionuclides from effluents where the radionuclides are present at similar levels to the NORM radionuclides present in the extractive waste generated in Cuadrilla's activities.

It is also claimed that the process has been used to successfully remove NORM radionuclides from liquid wastes generated in Titanium Dioxide manufacturing, and that removing the NORM from the water waste so that, after further biological treatment, the liquid can be returned to the natural environment and once again become part of the water cycle, was also a significant reason for selecting this method instead of others that were explored..

In a bit more detail, the process applied for is as follows.

The waste water will be taken by road tanker to one of several chemical waste treatment facilities in the UK that already hold environmental permits to receive, keep, treat and store industrial wastes for disposal, and are permitted to accumulate and dispose of radioactive waste. The application does not give the geographic location of any of the receiving sites that Cuadrilla plan to use, because "the exact destination of the waste may vary from day-to-day in accordance with operational needs and treatment/disposal capacity".

When the waste water is received at the treatment facility it will be sampled (to ensure it complies with the permit conditions), then unloaded into dedicated (usually steel) reception/ storage tanks that are bunded within an impermeable pavement and sealed drainage to provide secondary spill containment greater than the volume of the tank itself.

The waste water will then be treated with an acid/alkali treatment commonly used in processing a wide range of industrial wastes for disposal.

From the reception/storage tanks, it will be pumped directly into a reaction vessel where it will first be mixed with iron-rich acids which act as flocculants. This stage of treatment introduces a charged particle to the wastewater which attracts the colloidal particle to form a larger mass, and promotes the settling-out of microscopic solids within the waste. The pH is also reduced to acidic condition.

Next, a slurry of Calcium Hydroxide (lime) is added to the reaction vessel and mixed with the partially treated waste. This has the effect of raising the pH to a neutral or mildly alkaline condition. It also causes any heavy metals present in the mixture to precipitate out of solution, becoming bound to the particles in the lime and forming insoluble metal salts.

The naturally occurring radionuclides present in the waste water are to a large extent removed by co-precipitate with the other metals present.

Finally, the resultant slurry is dewatered using a filterpress.

To do this, the slurry is passed through a series of filter membranes housed in chambers, until all the chambers are full. Flowing under pressure, the solid particles begin to deposit on the surface of the filter media forming what is referred to as a “pre-coat” layer.

Once applied, this pre-coat layer becomes the actual filtering medium. As filtering continues, the thickness of the deposit gradually increases to form a 'filtercake'. Additional slurry continues to be pumped into the filterpress to displace more liquid, resulting in a dryer, firmer and denser filtercake, with the cycle continuing until liquid flow from the press is reduced to virtually nil.

At this point, pressure is reduced and the chambers are separated to allow the filtercake to drop out under gravity into a receiving skip.

The solid filtercake waste is said to be "suitable for disposal to non-hazardous landfill, and duly consigned to modern, suitably engineered landfill sites that provide total containment".

The filtered water generated in the dewatering phase of the process is then discharged to foul sewer, from which it is conveyed to the nearest sewage treatment facility for further biological treatment (to remove any organic material present) before being returned back to the natural environment.

The proposals also note that "Any LSA solid waste that is generated will be consigned for landfill disposal at Augean plc, located at Kings Cliffe landfill" (This is between Leicester and Peterborough).

From what we can see, LSA means Low Specific Activity material within what is called Class 7 (radioactive). It is material with limited specific activity which appears to include.... (readers please note that note we're not nuclear physicists and treat this with caution)

  • Ores containing only naturally occurring radionuclides and uranium or thorium concentrates of such ores; or
  • Solid unirradiated natural uranium or depleted uranium or natural thorium or their solid or liquid compounds or mixtures; or
  • Class 7 (radioactive) material, other than fissile material, for which the A2 value is unlimited; or
  • Mill tailings, contaminated earth, concrete, rubble, other debris, and activated material in which the Class 7 (radioactive) material is essentially uniformly distributed and the average specific activity does not exceed 10-\6\A2/g.

... and some other materials

We noted that some folk in the Leicester area aren't too keen to have what they call "the dumping of nuclear waste at Kings Cliffe" at all, and there is already a fairly active protest group in existence called 'Kings Cliffe Waste Watchers' who are opposing the deposition of low level waste from the nuclear industry.

Quite what they will make of this idea we don't know. We don't even know if they are aware that fracking waste might be taken there.

Whilst this is the process Cuadrilla are applying for at the present time, they note it is likely that additional facilities will be considered in the future, particularly "where these appear to offer an advantage capable of helping us to achieve our continuous improvement goals. In such instances, the candidate sites will be evaluated and a Radiological Impact Assessment of the receiving sewage treatment works performed to satisfy us that there will be no adverse impacts to the environment, before such sites are added to our register of approved treatment and disposal facilities and prior to any consignment of waste to those facilities"..

Finally, they address what they will do if treatment and disposal capacity is restricted or is temporarily unavailable. They first note this is an unlikely event but say that if they are nearing on-site storage capacity, operations at the exploration well(s) would be temporarily suspended until such time as waste stocks had been reduced once off-site treatment and disposal capacity has been restored.

So far as we can ascertain, that's the main process in the application for the disposal permit.

Readers with a more scientific bent can follow this link to the source document for this information, and follow this link to the Cuadrilla page with all the application documents.

Dealing with the waste products of the site was one of our two chief concerns - (the other being the integrity of the well bore) - so we regard this application as an important step.

Whether the process will be judged acceptable by the Environment Agency remains to be seen, but given that they appear to have undertaken a 'trial run' before the formal application, there are grounds to believe that Cuadrilla would not have made the formal application had there not been a good chance of permission being granted.

The great difficulty we, and probably other undecided but concerned people have, is that we simply don't know how much we can trust in the judgement of bodies like the Environment Agency.

The admission that LCC are not able to police the planning applications they grant - even when they are as sensitive as this one - gives us little confidence.

So far as the Environment Agency itself is concerned, we know of instances where we have been less than happy with their past decisions, which leaves us with a nagging doubt (as indeed the experts analysing the West Coast Main Line bids left a nagging doubt about their professional ability)..

Frankly, we'd like to see the work of the Environment Agency on this permission reviewed by trusted academics in the same way that the fracking-induced earthquakes were considered. One thing that all sides seemed able to agree on at that time was the validity and accuracy of those findings. We'd like to see something similar on the treatment of the waste water.

Dated:  16 October 2012


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