Medact’s madact on Fracking

Update on Medact; On Thursday 18th June there will be a presentation of the Medact report on Health and Fracking at the Minster in Preston, where they will push the supposed heath risks of fracking, It is regrettable that Medact did not revise their paper to bring it into line with Public Health England. From what we saw at the launch in London we expect the same ill-founded concerns.

Shale Gas Task Force is very critical of Medact Report https://darkroom.taskforceonshalegas.uk/original/e4d05cb29b0269c2a394685dad7516e6:c48ffe7884e9b668b8d4b7799a027874/task-force-on-shale-gas-assessing-the-impact-of-shale-gas-on-the-local-environment-and-health.pdf

See page 29

added 15/7/15

I would still like to know what evidence there is of increased illness in the vicinity of onshore wells in Britain.

Perhaps we should ask if there has been a spike in cancers in Elswick where there has been gas well for over 20 years.

 

On Monday 30th March 2015 Medact launched their report on the health effects of fracking http://www.medact.org/wp-content/uploads/2015/03/medact_fracking-report_WEB3.pdf . Its conclusions are very different to that of Public Health England (PHE) last year https://www.gov.uk/government/publications/shale-gas-extraction-review-of-the-potential-public-health-impacts-of-exposures-to-chemical-and-radioactive-pollutants

Reaction to the Medact report has been swift. It has been welcomed by anti-fracking groups, but has received criticism;  http://oesg.org.uk/news/medact-fracking-report-criticised-by-sme-trade-body/     : and  http://frackland.blogspot.co.uk/2015/03/medact-vs-british-columbia.html where Dr Verdon compares it unfavourably to a recent Canadian Report.

and also the critical response from UKOOG, published in April; .http://www.ukoog.org.uk/about-ukoog/press-releases/146-shale-gas-industry-says-medact-report-fails-to-understand-uk-regulatory-system-and-lacks-credibility

But here is an open letter to Medact from Ken Wilkinson highlighting the flaws of the paper.

Open letter to Medact, calling for the withdrawal of the recently issued Health and Fracking publication.

The reason I am writing this that I am concerned about fundamental flaws in the publication mentioned above. Each one of these is in itself a cause for withdrawal, and the totality means that the only ethical course for Medact is to withdraw the publication for review. As seasoned academics, you will of course accept that clear evidence of fundamental flaws would damn any research that your students might undertake, and lead to its rejection.

I have to state that I am totally independent in my views, and would describe myself as pro fact, rather than pro fracking. I have no financial interests at all, and I value that status. Like many, I give my time up for free for a cause that I believe in (the truth). I am recently retired and this gives me the time to research, when I am not doing my many sporting activities, and volunteering in a tough inner city school.

I have 12 years of experience working as a wireline engineer, finishing up as the most senior engineer in my company, in Libya. I dealt with customer liaison, problem wells, and jobs, and so had to know my stuff. I left in 1990 to become a Physics teacher.

It was made clear in all of the evening discussions, that Medact wanted to bring clarity to the debate. Dr Mccoy discussed this with me at the end of the evening. I am afraid this report brings false data and yet more confusion. It is little more than a propaganda piece for ‘anti’ frackers, not surprising when one of the report’s authors is an anti frack campaigner.

The Medact board is clearly a group of highly qualified academics that have great concerns concerning Climate Change, Global Warming, environmental pollution and health matters. These are issues that I (a humble BSC in Engineering) have great sympathy with. The planet could be on a path to destruction and there needs to be change. The problem would seem to be that simply publicising climate change issues would probably not have the desired effect of forcing a stop to fracking.

It is however unacceptable to present false science to ‘win the argument’ to stop fracking, by scaremongering and citing risks that do not exist in the UK regulatory environment.

Fundamental Flaw No 1

It would seem that Medact is publicising issues of health and safety that will not exist in the UK context. The fact is that there are many differences between practice in the US and the UK. These have not been considered. I would hope that this is due to misinformation only from Mike Hill, rather than the rest of the panel. He does not seem to have a grasp of many basic drilling concepts and has no relevant qualifications. I do not believe he has any experience of fracking, and not much, if any, of drilling. The fact that he so frequently refers to himself as an ‘expert’ is in itself odd. How many doctors would do that? Please see

http://www.thetimes.co.uk/tto/environment/article4397734.ece?shareToken=2ec2db188503e903f28d010eee37c321

http://order-order.com/people/mike-hill/

The clear evidence is that one of the main authors of your report is an anti-frack campaigner. This means that any credibility for Medact immediately vanishes. The Times article states that Dr McCoy was unaware that Mr Hill was standing as an MP on the single issue of opposition to fracking.

http://votehill.org/wp-content/uploads/2015/02/PR08-the-big-risk-press-release-Web.pdf

Fundamental Flaw No 2

At the launch of the report it quickly became apparent that the board had no idea that the use of chemicals in drilling is controlled by laws from the EU and the Environment Agency, the regulatory body concerning risks to groundwater. In particular the JAGDAG list of proscribed chemicals is not mentioned anywhere in the report. As benzene is mentioned in the report it is worth mentioning that this is on List 1 (Hazardous pollutant), along with many other nasty chemicals.

In Balcombe, Cuadrilla wanted to use antimony trioxide in drilling mud. This is a common chemical but permission was denied. Human studies are inconclusive regarding antimony trioxide exposure and cancer, and it is not classed as a carcinogen, but animal studies have indicated it may possibly be a risk. This indicates that the EA regulatory system works.

The European wide Groundwater Directive is European legislation that states. In order to protect the environment as a whole, and human health in particular, detrimental concentrations of harmful pollutants in groundwater must be avoided, prevented or reduced

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0118

The Environment Agency is also covered by statutory instrument.

The pollutants the Environment Agency are concerned with for groundwater are

• Hazardous substances, which are substances or groups of substances that are toxic, persistent and liable to bioaccumulate, and other substances or groups of substances that give rise to an equivalent level of concern.

• Any non-hazardous pollutants, which is ‘any pollutant other than a hazardous substance.http://www.legislation.gov.uk/ukdsi/2010/9780111491423/schedule/22http://www.wfduk.org/sites/default/files/Media/Substances%20transferred%20from%20List%20I%20%26%20II%20to%20hazardous%20or%20non%20hazardous.pdfThis list is under revision to accommodate fracking, and chemicals likely to be requested are being classified.Benzene occurs naturally at very low concentrations in shale gas (parts per billion) and the levels of benzene are similar to domestic gas. Benzene is also found in high concentrations in petrol stations, and near roads.So much of this report relies on the idea that chemical usage is unrestricted. As a point of information, the many toxic chemicals that have been used in the US is largely historic, as the properties needed can be achieved by using food additive based materials. Only 3 materials have been permitted so far. (Polyacrylomide, Glutaraldehyde, and Hydrochloric acid.) In addition the US is moving to compulsory declaration of chemicals.Fundamental Flaw No 3. Failure to understand crucial differences in fluid handling, US/UKhttps://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277211/Water.pdfOther fluid protection requirements are listed on pages 3 and 4, and these should satisfy most that this has been looked at (by the Royal Academy of Engineering, in 2012) and that these requirements have been put in place, to avoid the small number of issues from the US experience.https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277219/Air.pdfAgain this means that the 400+ studies can be ignored, as they are mainly US based.I am not aware of any protests concerning a 7m wide tunnel drilled under London recently (Crossrail). We all assume that the engineers will do their jobs properly and self-regulate. Why should fracking any different? Tying in with the links above, a whole series of information papers has been made available for over a year to inform the public that their genuine concerns are being addressed. It is strange that Mr Hill has been unaware of these, as we (Rev Michael Roberts and myself) referred to some of these in our Advertising Standards Authority complaints against RAFF (Resident Action on Fylde Fracking). I understand Mike is RAFF’s technical ‘go to’ person. RAFF were unable to sustain their false claims and they withdrew the article to avoid the public humiliation of having judgements go against them. (The majority of our complaints were provisionally upheld BTW.) http://www.ukoog.org.uk/images/ukoog/pdfs/UKOOG_progress_in_meeting_Royal_Society_recommendations_March_2015.pdfThere are many other issues that I could raise, that I tried to discuss last night. I understand your desire to limit my speaking (I did speak a lot) but these points include.

 

• UKOOG guidance on the progress of the 10 recommendations. (March 2015)
• There are 10 publications, and they can be seen on https://www.gov.uk/government/publications/about-shale-gas-and-hydraulic-fracturing-fracking (Early 2014 mostly)
• Fundamental Flaw No 4 Failure to take account of Govt issued information and other freely available literature.
• Unlike several statements in your paper, there is NO evidence that fracking is an inherently risky activity, and pollution incidents have NEVER been the cause of aquifer pollution. It has always been leaking wells, illegal dumping, truck accidents and open pits etc. (There is one possible exception to that in Pavillion,Wyoming, where a frack job was done at very shallow depth, but even that is inconclusive)
• Incidentally, examination of the above document also shows how the EA regulatory system works. They require the operator to supply plans to meet the concerns of the EA, using best practice, latest techniques etc. As technology moves on, best practice will always be required. It’s pretty well how every high tech industry works. ‘Regulation’ of doctors is by the Hippocratic oath, codes of conduct, professional standards, and communicating about the latest techniques. Doctors do not bleed patients like in the 18^th century, and progress has been made without the use of statutory instruments.
• In the UK, all oil and gas operators must minimise the release of gases as a condition of their licence from the Department of Energy and Climate Change (DECC). Natural gas may only be vented for safety reasons.
• Another concern is the emission of VOCs (which is ONLY an issue with shale oil wells, and traditional oil wells). There are requirements that no gases are to be released except in an emergency. Please see page 2 of the following link.
• make appropriate plans for storing fluid safely and not in open pits
• On page 15, there is a statement that 33% of pollution incidents in the US have been due to ‘overflowing pits and failures of pit linings’. These are not permitted in the UK as can be seen here, on guidance for operators, page 4.
• One fundamental misunderstanding is that emission of VOCs and benzene is ONLY a concern in shale oil wells. Shale gas has no evidence of these type of emissions, even in the US.
• Many of the papers that refer to HF risks will have BTEX as the main causes of concern.
• Benzene for instance is classed as List 1 ‘Hazardous’ and as such it is not permitted. The EA insist that all frack fluids must follow groundwater rules, even in areas where the water is not potable.
• Classification of chemicals is covered by the JAGDAG list here
• This can be seen on this link, in schedule 22, paras 4 and 5,

• Failure of Mike Hill to accept that flaring will be done in enclosed burners, and that these have low emissions that have been investigated by the EA.
• Failure to understand that a 30 stage injection frack job is like 30 separate frack jobs and is no big thing.
• Failure of Mike Hill to understand that the PH1 well does NOT have an integrity failure. (Integrity means leaking to the environment, and the minor deformation of 0.1 inch ovality over 140 ft is below the regional seal. You need to understand wells to get this, and all of the evidence is that Mike Hill does not have that understanding)
• References to ‘earthquake’ when this is not a significant risk and has been looked into with great detail, and academic research.
• Failure to understand the limitations of bond logs in large casings (I used to run training sessions for oil company engineers on this and other matters many years ago. The technology has changed but the principles are the same)
• Failure to understand that surface casing leaks with modern cementing are rare, and these would involve only methane, which is non toxic.
• Scaremongering by suggesting a 60 multiwell pad would be an issue, when the surface impact would be not much more than a single well.
• Ignoring the AMEC Environmental Impact Assessment and its conclusions. All of the concerns have been addressed, and mitigated, leading to low impact conclusions.
• http://cuadrillaresources.com/wp-content/uploads/2014/06/RW_ERA.pdf
• Ignoring the recent acceptance of fracking technology by Lancs CC and the EA in the case of the Cuadrilla wells. This indicates that the EA are happy with the environmental issues.
• Suggesting that the HPE report is faulty as it should have considered issues of climate change when the HPE are not competent in that area.
• Suggesting that the HPE report is faulty as it should consider noise/light issues when these are planning matters.
• Inaccurate and misleading figures for truck movements due to piping of water and reinjection of flowback fluid.
• Failure to highlight the one definitive paper that is undisputed, and peer reviewed by appropriately qualified people, (NOT anti-frack campaigners) and that shows undisputed HEALTH effects. The ones usually cited as exemplars are McKenzie 2012 (heavily criticised for poor science), and McKenzie 2014( rejected as bad science by the Colorado Chief Health officer) , and Elaine Hill (unpublished, criticised, but still cited in the New York ban)
• http://energyindepth.org/national/the-dubious-scientific-foundation-for-new-yorks-fracking-ban/

• Failure to understand that flowback fluid is classed as mining waste, and is disposed of under strict licence from the EA. This happens to 7 million barrels per annum of fluids produced with onshore oil production, and this has not been a problem before.http://www.ukoog.org.uk/about-ukoog/press-releases/146-shale-gas-industry-says-medact-report-fails-to-understand-uk-regulatory-system-and-lacks-credibilityI have just become aware of the UKOOG response to the Medact report.http://www.ukoog.org.uk/about-ukoog/press-releases/146-shale-gas-industry-says-medact-report-fails-to-understand-uk-regulatory-system-and-lacks-credibility
• [ I would suggest all read UKOOG on the Medact Report as it makes incisive comments , and is from the professional association. MR ]
• I will stop here but I could continue, as this is but a small sample of the appallingly bad science that seems designed to mislead the public into thinking that fracking is a high risk activity.I request that this paper be withdrawn for review.Ken Wilkinson BSc.(Aeronautical Engineering. Manchester University 1971-74) 

  District Engineer (1987-90) Halliburton Welex logging engineer 1980-90 (Open and Cased Hole wireline logging) Libya (land), Kuwait (land), Abi Dhabi(land)  India(offshore).

  Schlumberger Senior Field Engineer 1974-76 (Mainly Open Hole wireline logging) Indonesia (training) Taiwan (offshore), Phillipines (offshore), Saudi Arabia (land), Bangladesh (offshore).