environmental risks, opportunities and regulatory challenges

Mark Broomfield, AEA Technology, UK

Environmental risks, opportunities and regulatory challenges in the US and Europe: European perspective

Overview of presentation

Setting the scene

Environmental and health risks of unconventional gas extraction• Literature review; stakeholder consultation• Preliminary risk assessment

Review of control options• Environmental risk management• Carbon footprint: fugitive methane control

European regulatory landscape• Existing acquis• Gap analysis• Options assessment

Next steps• European Commission research• Supply chain analysis

Setting the scene

Stage 1: Site identification & preparation

Stage 2: Well design, drilling, casing & cementing

Stage 3: Technical hydraulic fracturing

Stage 4: Well completion, management of wastewater

Stage 5: Well production (refracturing may be carried out)

Stage 6: Well abandonment

Setting the scene

Energy resources• 25% of Europe’s energy needs supplied by natural gas in 2008• Substantial shale gas resources

High volume hydraulic fracturing• New activity in Europe• Defined as >1,000 m3 fluid per stage

HVHF in Europe• Introduced in Europe in the early 1980s. • Multi-stage hydraulic fracturing in tight gas reservoirs in horizontal wells in

the Soehlingen field in Germany, and in the South Arne field in Denmark• Hydraulic fracturing has been carried out elsewhere in Germany, the

Netherlands and the United Kingdom • These fracturing operations did not use sufficient fluid to be classified as

HVHF.

• Exploratory drilling for shale gas with hydraulic fracturing in Germany, Poland and the UK commenced in 2010.

Setting the scene

European Commission Context• February 2011: European Council concluded that Europe should assess its

potential for sustainable extraction and use of conventional and unconventional fossil fuels.

• 2011 report commissioned by the European Parliament drew attention to the potential health and environmental risks associated with shale gas.

• Half of EU Member States are interested in developing shale gas resources• However, several MS have prohibited, or are considering prohibiting, the use of

hydraulic fracturing. • Several EU Member States are considering the appropriateness of national

legislation, and may introduce national requirements for hydraulic fracturing.• Commission saw a growing need for a coherent approach to unconventional

fossil fuels and in particular shale gas developments in an area where economics, finances, environment and in particular public trust are essential.

• The Commission is investigating the impact of unconventional gas, primarily shale gas, on EU energy markets

• DG ENV commissioned an initial assessment of the environmental and health risks and impacts associated with the use of hydraulic fracturing.

• Concurrent research into carbon footprint commissioned by DG CLIMA

Environmental and health risks

Literature review• Focus on peer-reviewed research where available• Fast-moving area of engineering and science• Over 200 documents referenced, but many

common data sources• Some key documents:

• Draft New York State DEC SGEIS (2011)• Lechtenböhmer et al for European Parliament (2011)• Broderick et al (Tyndall Centre) (2011)• US EPA Drinking water study plan (2011)• Academic studies of specific issues (e.g. Davies et

al. 2012; Considine et al. 2012)• API guidelines HF1, HF2, HF3• Papers published by Society of Petroleum Engineers• IEA Golden Rules; Empfehlungen des Neutralen

Expertenkreis


Stakeholder consultation• Engaged with a range of specialists from Europe and North

America• Regulators• Geological surveys• Academic specialists

• Useful feedback in specific areas• Peer review of final report

http://www.gfz-potsdam.de/

http://www.usgs.gov/



http://www.ministryofinfrastructureandtheenvironment.nl/

http://www.environment-agency.gov.uk/default.aspx

http://www.pitt.edu/


Environmental aspect

Project phase

Site identification

and preparation

Well design drilling, casing,

cementing

Fracturing Well completion Production

Well abandonment

and post-abandonment

Overall rating across all

phases

Individual site

Groundwater contamination Not applicable Low Moderate-

High High Moderate-High Not classifiable High

Surface water contamination Low Moderate Moderate-

High High Low Not applicable High

Water resources Not applicable Not

applicable Moderate Not applicable Moderate Not applicable Moderate

Release to air Low Moderate Moderate Moderate Moderate Low Moderate

Land take Moderate Not applicable

Not applicable

Not applicable Moderate Not classifiable Moderate

Risk to biodiversity Not classifiable Low Low Low Moderate Not classifiable Moderate

Noise impacts Low Moderate Moderate Not classifiable Low Not applicable Moderate –

High

Visual impact Low Low Low Not applicable Low Low-moderate Low - Moderate

Seismicity Not applicable Not applicable Low Low Not applicable Not applicable Low

Traffic Low Low Moderate Low Low Not applicable Moderate


Environmental aspect

Project phase

Site identification

and preparation

Well design drilling, casing,

cementing

Fracturing Well completion Production

Well abandonment

and post-abandonment

Overall rating across all

phases

Cumulative

Groundwater contamination Not applicable Low Moderate-

High High High Not classifiable High

Surface water contamination Moderate Moderate Moderate-

High High Moderate Not applicable High

Water resources Not applicable Not

applicable High Not applicable High Not

applicable High

Release to air Low High High High High Low High

Land take Very high Not applicable

Not applicable

Not applicable High Not classifiable High

Risk to biodiversity Not classifiable Low Moderate Moderate High Not classifiable High

Noise impacts Low High Moderate Not classifiable Low Not

applicable High

Visual impact Moderate Moderate Moderate Not applicable Low Low-moderate Moderate

Seismicity Not applicable Not applicable Low Low Not applicable Not

applicable Low

Traffic High High High Moderate Low Not applicable High


Preliminary environmental and health risk assessment• Structured risk assessment• Defined quantitative/qualitative criteria• Limited by available data• Focused attention on key risks

• Cumulative impacts, requiring consideration at initial stages of exploration

• Very high: Land take• High: Groundwater contamination, accidents/spillages, water

resources, air pollution, noise, traffic

• Enables priority areas for future research to be identified• High/very high impact areas• Biodiversity impacts• Long-term post-abandonment phase

Control options

Reviewed regulatory and technical control measures• Appropriate siting of developments, to reduce above and below-

ground risks• Measures and approaches to reduce land disturbance and land-

take • Measures to address releases to air and to reduce noise during

drilling, fracturing and completion• Measures to address water resource depletion • Measures to reduce the negative effects caused by traffic• Measures to improve well integrity and to reduce the risk of

ground and surface water contamination• Measures to reduce the pressure on biodiversity

Control options

Aspect Description of measure

DatabaseCreation of a national database of public sources of informationDevelop database of baseline water quality and quantity, and geologic information across a shale gas formation, prior to the commencement of HVHF

Peer review Funding to enable peer review of regulatory activity

Zoning (general)

Identifying zones which are off-limits to hydraulic fracturing if required for environmental protectionPrevent HVHF in reforestation areas, wildlife management areas and high quality aquifersPrevent HVHF in areas specified for protection of groundwater

Buffer zones

Minimum distance to private water well: 150 mMinimum distance to public water well or reservoir: 300 mMinimum distance from well to surface watercourse: 90 mMinimum distance from disturbance to surface watercourse: 90 mMinimum distance to watersheds used for drinking water supply: 1,200 mMinimum distance to residential areas: 1,600 m (where possible)Distance within which detailed investigation of noise mitigation is needed: 305 mRequire site-specific separation from abandoned wells and other potential pathways for fluid migrationRequire additional containment to prevent surface water impacts for sites within 800 m of surface water supply locations

NotificationNotification to local communities when drilling is plannedNotification to water suppliers in the event of spills or leaks

Mitigation credit system

Voluntary ecological initiatives within critical habitats that would generate mitigation credits which can be used to offset future development

Environmental management systems

Encourage or require accreditation for shale gas installation operators to secure ongoing environmental improvements

Control options

Aspect Description of measureDatabase Creation of a national database of public sources of informationSurface and water quality monitoring

Surveys of water quality and levels to be carried out before, during and after HVHF operations

Air quality monitoring

Surveys of air quality to be carried out before and during HVHF operations

Pit liners Require pit liners to be installedSecondary containment

Require secondary containment for storage of specified hazardous fluids

Spill control plans

Require spill control plans to be produced and maintained

Well spacingMinimum spacing of well pads of one per 2.6 square km, with all the horizontal wells in the unit drilled from a common well padSpecify minimum well spacing

Minimise habitat fragmentation

Implement mitigation measures to minimise ecological impacts.

Minimise impacts on sensitive habitats

Develop and implement a specific mitigation plan and monitor in sensitive wildlife areas

Invasive species plan

Develop and implement an invasive species mitigation plan

Noise mitigation

Locate sites away from occupied structures and places of assemblyImplement management measures to minimise noiseImplement barrier methods to minimise noiseCarry out noisy operations during the day

Control options

Aspect Description of measureSeismicity monitoring

Monitoring of seismic activity with intervention in the event of events occurring

Visual impact mitigation

Standard measures to minimise visual impacts with regard to site location, lighting and paintwork

Minimise impacts of traffic

Road use agreement/transportation plan covering vehicle routeing and timingUse existing roads where possibleLocate access roads away from residential areasCentralise gathering facilities to reduce truck trafficMinimise impacts of new road construction via design and use of appropriate standards; build in mitigation at design stageLimit truck weightsVehicles to conform with highest emissions standardsUnnecessary idling to be preventedCarry out effective maintenanceRepair road damage, or make payments to allow damage to be repairedUse temporary pipeline for water transportation

Site selection Comprehensive assessment to identify optimum siteManagement Staff selection, training and supervision in environmental protection

Land restoration

Maintain land used for gas extraction to a suitable standard to enable restoration so far as possibleStockpile surface soils for use in restorationLoose soil should be covered with geotextiles or other materials

Pace of development

Limiting the pace of development could reduce some acute effects associated with shale gas development

Control optionsAspect Description of measure

Site layoutUse cut areas for surface impoundment construction to avoid unnecessary increases in facility footprint

Minimise risks from liquid storage and handling

Avoid the use of surface impoundments and reserve pits where possibleAvoid the use of surface impoundments and reserve pits in flood zones or other sensitive areasSilt fences, sediment traps or basins, hay bales, mulch, earth bunds, filter strips or grassed swales can be used to slow runoff and trap sediment from leaving the site.Where possible, activities should be staged to reduce soil exposure and coincide with a season of low rainfallContingency planning and training to address spillage risksVisual inspection of primary containment before hydraulic fracturing is carried outUse conductance monitors for rapid detection and assessment of spillages

Minimise risks from temporary pipelines

Pipelines should not be located on steep hillsides or within watercourses

Extent of surface casing

Surface casing to extend to at least 30 m below aquifersSurface casing to extend to at least 15 m below aquifersSurface casing to extend below aquifersSurface casing to extend to at least 30 m below ground levelSurface casings should be cemented before reaching a depth of 75 metres below underground sources of drinking water.

Extent of production casing

Production casing should be cemented up to at least 150 metres above the formation where hydraulic fracturing will be carried out

Control options


Well integrity

Pressure tests of the casing and state-of-the-art cement bond logs should be carried outRegulation and inspection regime needed to confirm effective repair of defective cementingMeasure compressive strength with benchmarks between 2.1 and 8.3 MPa, based on setting times between 4 and 72 hoursInclude well integrity measures in permit specified under Mining Waste DirectiveComplete cementing and isolation of underground sources of drinking water must be carried out prior to further drillingCasing centralizers should be used to centre the casing in the holeTesting of well integrity should take place at construction, and throughout the lifetime of the well

Minimum depth for hydraulic fracturing

Fracturing at depths of less than 600 m requires a specific permitFracturing not permitted with a separation of less than 46 m between fracture zone and aquiferFracturing at depths of less than 600 m or with less than 300 m separation between fracture zone and aquifer requires a specific analysis and reviewFracturing with a separation of less than 600 m between horizontal section of well and aquifer should not be permitted

Multi-stage fracturing

Maintain hydraulic isolation between porous zones

Disclosure

Operators should disclose publicly the chemical constituents of hydraulic fracturing fluid, including product name and purpose/type; proposed composition of fracturing fluid by weight; and proposed volume of each additiveOperators should disclose publicly the results of well integrity tests

Drilling engines

Emissions from diesel engines to conform with highest applicable standardsUse natural gas powered engines and compressors where feasibleUse electrically driven engines and compressors where feasibleUse selective catalytic reduction to reduce emissions from drilling rig engines

Control options


Drilling fluidsDrillers should select fluids to minimise the environmental hazard posed by drilling wastesSeparation of drilling fluids and processing to facilitate re-useUse closed-loop systems to reduce drilling time, drilling fluid use and surface disturbance

Composition of HVHF fluid

Develop guidance for use of diesel fuel in HVHF fluidProhibit use of diesel fuel in HVHF fluidProhibit use of specified volatile organic compounds in groundwater zoneUse of specified volatile organic compounds in HVHF fluid requires prior authorisationSelect appropriate additives to minimise environmental impactsMinimise biocide use, e.g. via use of UV disinfection techniques in place of chemical biocidesSelect proppants which minimise the HVHF treatment required

Water resource management

Develop and use an integrated water management systemRequire use of alternative sources of waterAvoid sensitive areas for water withdrawals

Control of invasive species

Implement precautions to prevent invasive species from water storage by cleaning vehicles and appropriate disposal of surplus water

Control of HVHF process

Predictive modelling to optimise fracturing strategiesShare data from nearby fracturing operationsEnsure equipment compatible with composition of fracturing fluid Use all available techniques to minimise risk of fracturing taking place outside the target reservoirThorough planning and testing of equipment prior to fracturing operationsDevelopment of contingency plan prior to fracturing operationsDetailed monitoring of process during fracturing operations

Control options


Wastewater management

Develop pre-treatment standards for discharges of shale gas extraction wastewater to municipal wastewater treatment plantsEstablish treatment requirements/discharge limits for treatment and final discharge of wastewaterRe-use waste water where possibleStore waste water in storage tanks, or in double lined lagoons constructed with regard to local topographyEnsure receiving treatment works is capable of handling wastewatersInstall on-site wastewater treatment if appropriateMeasure the composition of the stored return waterUse closed-loop systems manage and reprocess waste waters

Emissions to air from well completion

Develop and adopt air emission standards for methane, air toxics, ozone-forming pollutants, and other airborne contaminantsRequire Reduced Emissions Completions to be carried outProhibit venting of gases, and minimise use of flaringControl of VOC emissions by combustion for any tank emitting more than 6 tons VOCs per yearProhibit use of open-top or blow down tanksSpecify required reductions in uncontrolled VOC emissions Use low-bleed or no-bleed pneumatic controllersReplace glycol systems with alternatives

Leakage to air during operation

Survey well head equipment to identify and address leakageUse equipment with low potential for leakageAutomatic fail-safe equipment on pipelinesReduce the number of storage tanks on site

Temporarily abandoned wells

Set requirements for plugging and inspection of shut-in wellsInspect and maintain wellheads every 90 days

Control options


Permanent well abandonment

Plug with 30 m of cement every 760 m and at least 30 m cement at the surface, with 30 m of cement in horizontal sectionPlug with 15 m of cement above every zone to be protectedPlug at least 15 m below the deepest perforation and 15 m above the shallowest perforationPlug at least 15 m above and below the base of the deepest usable aquiferPlug at least 30 m above and 15 m below each fluid-bearing stratumPlug from 15 m below to 15 m above the base of the treatable water zoneSet requirements for inspection of abandoned wellsEnsure a micro-annulus is not formed at temporary plugsCarry out ongoing monitoring programmeMaintain records of well location and depth indefinitelyTransfer ownership and liability to competent authority on surrender of permit to ensure long-term management

Well pad restoration

Remove surface impoundments as soon as possible when no longer neededRemediate well pads on an ongoing basis to facilitate return to original conditionsWell sites must be restored as soon as possible after the end of extraction operations

BondingAll operators are required to have financial security for the wells through performance bonds on an individual well or a field of wells

Wider area development

Operators should work cooperatively with regulatory agencies and other stakeholders to promote best practices, and improve communication with local communities. Neighbouring operators work together to ensure efficient provision of gas collection and water treatment infrastructure

Transboundary co-operation

Competent authorities should co-operate in jointly meeting regulatory requirements

Legislative review

Aim of legislative review• To identify potential uncertainties regarding the extent to which

shale gas exploration and production risks are covered under current EU legislation

• To identify those risks not covered by EU legislation• To draw conclusions relating to the risk to the environment and

human health of such operations in the EU

Gap analysis• Inadequacies in legislation• Potential inadequacies – uncertainty in applicability• Potential inadequacies – uncertainty in MS implementation

Legislative review

Gaps identified in legislative review• EIA Directive Annex I threshold for gas production• EIA Directive Annex II definition of “deep drilling”• EIA Directive scope: no requirement to address geological features• Water Framework Directive: definition of “pollutants”• Mining Waste Directive/IPPC: no relevant

BREF document• Air and noise emission limits for larger

off-road machinery• Coverage of Environmental liability directive• Applicability of IPPC Directive/Industrial

Emissions Directive• Classification under MWD• Applicability of Seveso II Directive• Member State implementation of a number of directives

Next steps

Next phase of European Commission studies• Development of risk framework• Member state implementation• Mitigation of climate impacts of possible future shale gas extraction

Our work• Regulatory guidance• Supply chain market analysis• Ongoing regulatory support

in US

Supply chain

DATA REVIEW

SELECT TEST SITE

TRIAL DRILL/ FRACK

TRIAL DATA ANALYSIS

SELECT PRODUCTION ZONE

WELLPAD IDENTIFICATION

DRILLING/FRACKING

Analysts

Public relations

EIA

Planning

Drill rig

Horizontal drilling

Water supply

Frack project manager

Waste and water treatment/disposal

Chemical supplier

Chemical manufacturing

Compression plant

Site preparation

Generator plant

Logistics

Technical/ engineering

expertise

Risk assessment

Monitoring

Public relations

EIA

Planning

SEA

Ecology

Financing

Financial advice

Audit/ due diligence

Regulatory liaison

COMPLETIONPRODUCTIONABANDONMENT

Green completion expertise

Water treatment/ recycling disposal

Services

SITE CONSTRUCTION

Planning

Engineering

Environmental monitoring

Site restoration Well maintenance

WORKOVERS

EXPLORATION

DEVELOPMENT

Monitoring

Ecology

Personnel messing, catering, sanitation, accommodation etc

Engineering expertise

Specialist drilling/casing

suppliers

Public relations

Liaison with pipeline operator

AS FOR EXPLORATION

PHASE

Expertise

Environmental management

Geology andGeophysics

Legal

Technical/constructionInfrastructure

analysis

Reprocessingof historical data

Analysis andinterpretation

Political/Geopolitical

Trial data acquisition

Gravimetry

Geochemical survey

2D Survey

3D Survey

EM Survey

Well plugging

Road repair

Landscape Repair

Sludge disposal


PRODUCTIONDECOMMISSIONING

Production gathering

Pipeline connectivity

PIPELINE CONSTRUCTION

Water pond construction

Road, site and pad preparation

Road and site construction

Survey design and planning


Common to conventional and unconventional

Greater or different requirement withunconventional

New requirement for unconventional

KEY

Gravimetry

Geochemical survey

2D Survey

3D Survey

EM Survey

ED58399_SC_v4

environmental risks, opportunities and regulatory challenges

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